IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF GEORGIA

ATLANTA DIVISION

RETRACTABLE CORD
TECHNOLOGIES LLC,

PlaintiII,


v.
CIVIL ACTION FILE

NO.

OFFICE DEPOT, INC.,

DeIendants.




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PlaintiII RETRACTABLE CORD TECHNOLOGIES LLC ('PlaintiII), by
and through its undersigned counsel, Iiles this original Complaint against
DeIendant as Iollows:
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1. This is a patent inIringement action concerning DeIendant`s
inIringement oI PlaintiII`s United States Patent No. 5,230,481, entitled 'Cord
Take-Up Device ('the `481 patent), a copy oI which is attached hereto as
Exhibit A.
2

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2. PlaintiII is a Georgia limited liability company having a principal
oIIice in Braselton, Georgia. PlaintiII is the assignee oI all right, title and interest
in and to the `481 patent, including the right to sue Ior all past inIringement. The
`481 patent issued on July 27, 1993, aIter Iull and Iair examination by the United
States Patent OIIice. The `481 patent was valid and enIorceable until its expiration
on or about July 27, 2010.
3. DeIendant OFFICE DEPOT, INC. ('OIIice Depot) is a Delaware
corporation with a principal place oI business at 6600 North Military Trail, Boca
Raton, FL 33496. DeIendant may be served with process by and through its
registered agent, Corporate Creations Network Inc., 2985 Gordy Parkway, 1
st

Floor, Marietta, GA 30066.
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4. This action arises under the Patent Laws oI the United States, 35
U.S.C. 1 HWVHT, including, without limitation, 35 U.S.C. 271, 281, 284, and
285. This Court has subject matter jurisdiction over this case Ior patent
inIringement under 28 U.S.C. 1331 and 1338(a).
5. This Court has personal jurisdiction over each oI the DeIendant
pursuant to O.C.G.A. 9-10-91 and Iederal law on the grounds that, upon
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inIormation and belieI, (i) DeIendant transacts business within the State oI
Georgia; (ii) DeIendant has committed acts oI patent inIringement within and/or
directed toward residents oI the State oI Georgia; (iii) DeIendant`s acts oI patent
inIringement have caused injury within the State oI Georgia, and DeIendant
regularly does or solicits business, engages in other persistent courses oI conduct,
and/or derives substantial revenue Irom goods used or consumed or services
rendered in this state; (iv) DeIendant purposeIully directs activities toward
residents oI the State oI Georgia; (v) the cause oI action set Iorth herein arises Irom
or relates to DeIendant`s activities in the State oI Georgia; and/or (vi) the exercise
oI jurisdiction over DeIendant will not oIIend traditional notions oI Iair play and
substantial justice.
6. More speciIically, DeIendant has shipped, distributed, oIIered Ior sale,
sold, and/or advertised (including by the provision oI interactive web pages) its
products and services in the United States, the State oI Georgia, and the Northern
District oI Georgia. Upon inIormation and belieI, DeIendant has committed patent
inIringement in the State oI Georgia and in the Northern District oI Georgia.
DeIendant has solicited customers in the State oI Georgia and in the Northern
District oI Georgia. DeIendant has had paying customers who are residents oI the
State oI Georgia and the Northern District oI Georgia and who each have used
4

DeIendant`s respective products and services in the State oI Georgia and in the
Northern District oI Georgia.
7. Venue is proper in the Northern District oI Georgia pursuant to 28
U.S.C. 1391 and 1400(b).
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8. PlaintiII realleges and incorporates by reIerence the allegations set
Iorth in paragraphs 1-7, above, as iI set Iorth verbatim herein.
9. DeIendant OIIice Depot, has directly inIringed the `481 patent in
violation oI 35 U.S.C. 271(a) by making, using, selling, or oIIering Ior sale in the
United States miniature electronic cable products that embody the patented
invention. OIIice Depot`s inIringing products include, without limitation, its
Ativa Retractable Handset Cord product, which inIringes at least claim 1 oI the
`481 patent.
10. To the extent any such notice may be required, OIIice Depot received
actual notice oI its inIringement oI the `481 patent at least as early as the Iiling oI
the original complaint in this action, pursuant to 35 U.S.C. 287(a).
11. OIIice Depot`s aIoresaid activities have been without authority and/or
license Irom PlaintiII.
5

12. PlaintiII is entitled to recover Irom OIIice Depot the damages
sustained by PlaintiII as a result oI OIIice Depot`s wrongIul acts in an amount
subject to prooI at trial, which, by law, cannot be less than a reasonable royalty,
together with interest and costs as Iixed by this Court under 35 U.S.C. 284.
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13. PlaintiII hereby requests a trial by jury pursuant to Rule 38 oI the
Federal Rules oI Civil Procedure.
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PlaintiII respectIully requests that the Court Iind in its Iavor and against
DeIendant, and that the Court grant PlaintiII the Iollowing relieI:
A. An adjudication that one or more claims oI the `481 patent have been
inIringed, either literally and/or under the doctrine oI equivalents, by
DeIendant;
B. An accounting and an award to PlaintiII oI damages adequate to
compensate PlaintiII Ior the DeIendant`s acts oI inIringement together
with pre-judgment and post-judgment interest;
C. That this Court declare this to be an exceptional case and award
PlaintiII its reasonable attorneys` Iees and costs in accordance with 35
U.S.C. 285; and
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D. Any Iurther relieI that this Court deems just and proper.

This 22nd day oI December, 2011.
KENT LAW, P.C.

/s/'DQLHO$.HQW
Daniel A. Kent
Georgia Bar Number 415110
dankentiplit.com
555 N Point Ctr E Ste 400
Alpharetta, GA 30022
Tel: (404) 585-4214
Fax: (404) 829-2412

Attorney Ior PlaintiII