IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION CAO GROUP, INC.

, Plaintiff, v. DENTLIGHT, INC., Defendant.

Civil Action No. 6:13-cv-00187 JURY TRIAL DEMANDED

PLAINTIFF CAO GROUP, INC.S ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT Plaintiff CAO Group, Inc. (CAO) hereby complains and alleges against Defendant Dentlight, Inc. (Dentlight) as follows: PARTIES 1. Plaintiff CAO is a corporation organized and existing under the laws of Utah,

with its principal place of business at 4628 West Skyhawk Drive, West Jordan, Utah 84084. 2. On information and belief, Dentlight is a corporation organized and existing under

the laws of Texas, with its principal place of business at 1825 Summit Avenue, Suite 210 Plano, Texas 75074. NATURE OF THE ACTION 3. This is an action for patent infringement arising under the Patent Laws of the

United States 35 U.S.C. 1 et seq., including 35 U.S.C. 271. 4. On information and belief, Dentlight has infringed and continues to infringe

CAOs U.S. Patent Nos. 6,331,111 (the 111 Patent); 6,719,559 (the 559 Patent); 6,755,648 (the 5,648 Patent); 6,783,362 (the 362 Patent); 6,953,340 (the 340 Patent); 6,971,875 (the 875 Patent); 6,988,891 (the 891 Patent); 7,077,648 (the 7,648 Patent); 7,086,858 (the 858 Patent); 7,094,054 (the 054 Patent); and 7,252,678 (the 678 Patent) (collectively the Asserted Patents).

JURISDICTION AND VENUE 5. This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C.

1331 and 1338. 6. This Court has personal jurisdiction over Dentlight because, on information and

belief, Dentlights principal place of business is located within this judicial District. 7. In addition, on information and belief, Dentlight does and has done substantial

business in this judicial District, including: (a) committing acts of patent infringement in this judicial District; (b) regularly conducting business in the State of Texas and this judicial District; (c) directing advertising to or soliciting business from persons residing in the State of Texas and this judicial District through at least in-person sales efforts, and (d) engaging in other persistent courses of conduct, and/or deriving substantial revenue from products and/or services provided to persons in the State of Texas and this judicial District. 8. Venue is proper in this Court pursuant to 28 U.S.C. 1391 and 1400(b). FACTUAL BACKGROUND 9. Plaintiff CAO designs, develops, manufactures, and markets various products for

dental and forensic applications, including but not limited to dental curing lights and lights for forensic illumination. 10. CAO has sought protection for its technological innovations, which has resulted

in numerous issued patents, including the Asserted Patents. 11. The 111 Patent issued on December 18, 2001, and is titled Curing Light System

Useful for Curing Light Activated Composite Materials. CAO is the owner by assignment of the 111 Patent. 12. The 559 Patent issued on April 13, 2004, and is titled Curing Light. CAO is

the owner by assignment of the 559 Patent. 2

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The 5,648 Patent issued on June 29, 2004, and is titled Curing Light. CAO is

the owner by assignment of the 5,648 Patent. 14. The 362 Patent issued on August 31, 2004, and is titled Dental Curing Light

Using Primary and Secondary Heat Sink Combination. CAO is the owner by assignment of the 362 Patent. 15. The 340 Patent issued on October 11, 2005, and is titled Light for Use in

Activating Light-Activated Materials, the Light Having a Detachable Light Module Containing a Heat Sink and a Semiconductor Chip. CAO is the owner by assignment of the 340 Patent. 16. The 875 Patent issued on December 6, 2005, and is titled Dental Curing Light.

CAO is the owner by assignment of the 875 Patent. 17. The 891 Patent issued on January 24, 2006, and is titled Curing Light. CAO is

the owner by assignment of the 891 Patent. 18. The 7,648 Patent issued on July 18, 2006, and is titled Curing Light. CAO is

the owner by assignment of the 7,648 Patent. 19. The 858 Patent issued on August 8, 2006, and is titled Semiconductor Curing

Light System Useful for Curing Light Activated Composite Materials. CAO is the owner by assignment of the 858 Patent. 20. The 054 Patent issued on August 22, 2006, and is titled Dental Curing Light.

CAO is the owner by assignment of the 054 Patent. 21. The 678 Patent issued on August 7, 2007, and is titled Forensic Light Using

Semiconductor Light Source. CAO is the owner by assignment of the 678 Patent. 22. On information and belief, Dentlight develops, markets, and/or manufactures for

dental and forensic applications, including dental curing and oral examination systems that include light emitting diodes (LEDs). 3

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On information and belief, some of Dentlights dental curing and oral

examination systems are sold under the trade name Fusion and include, for example, the Fusion 3.0 and the Fusion DOE. These products are exemplary and are referred to collectively hereafter as the Accused Products. 24. On information and belief, Dentlight operates and maintains a website at

www.dentlight.com, where Dentlights products, including the Accused Products, are marketed to consumers worldwide. 25. Brochures, technical information including user and service manuals and

brochures relating to the Accused Products are available for download through Dentlights website. These documents provide information regarding how to use the Accused Products. COUNT ONE (Infringement of U.S. Patent No. 6,331,111) 26. Plaintiff realleges and incorporates by reference Paragraphs 125 of this

Complaint as though fully set forth herein. 27. On information and belief, Dentlight has infringed and continues to infringe at

least claim 9 of the 111 Patent by developing, making, using, offering to sell, selling in and/or importing into this District and elsewhere in the United States, the Accused Products, including at least the Fusion 3.0. 28. Dentlights actions constitute infringement of at least claim 9 of the 111 Patent in

violation of 35 U.S.C. 271. 29. CAO has sustained damages and will continue to sustain damages as a result of

Dentlights aforesaid acts of infringement. 30. CAO is entitled to recover damages sustained as a result of Dentlights wrongful

acts in an amount to be proven at trial.

31.

Dentlights infringement of CAOs rights under at least claim 9 of the 111 Patent

will continue to damage CAOs business, causing irreparable harm, for which there is no adequate remedy at law, unless it is enjoined by this Court. COUNT TWO (Infringement of U.S. Patent No. 6,719,559) 32. Plaintiff realleges and incorporates by reference Paragraphs 125 of this

Complaint as though fully set forth herein. 33. On information and belief, Dentlight has infringed and continues to infringe at

least claim 16 of the 559 Patent by developing, making, using, offering to sell, selling in and/or importing into this District and elsewhere in the United States, the Accused Products, including at least the Fusion 3.0. 34. Dentlights actions constitute infringement of at least claim 16 of the 559 Patent

in violation of 35 U.S.C. 271. 35. CAO has sustained damages and will continue to sustain damages as a result of

Dentlights aforesaid acts of infringement. 36. CAO is entitled to recover damages sustained as a result of Dentlights wrongful

acts in an amount to be proven at trial. 37. Dentlights infringement of CAOs rights under at least claim 16 of the 559

Patent will continue to damage CAOs business, causing irreparable harm, for which there is no adequate remedy at law, unless it is enjoined by this Court. COUNT THREE (Infringement of U.S. Patent No. 6,755,648) 38. Plaintiff realleges and incorporates by reference Paragraphs 125 of this

Complaint as though fully set forth herein.

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On information and belief, Dentlight has infringed and continues to infringe at

least claim 8 of the 5,648 Patent by developing, making, using, offering to sell, selling in and/or importing into this District and elsewhere in the United States, the Accused Products, including at least the Fusion 3.0. 40. Dentlights actions constitute infringement of at least claim 8 of the 5,648 Patent

in violation of 35 U.S.C. 271. 41. CAO has sustained damages and will continue to sustain damages as a result of

Dentlights aforesaid acts of infringement. 42. CAO is entitled to recover damages sustained as a result of Dentlights wrongful

acts in an amount to be proven at trial. 43. Dentlights infringement of CAOs rights under at least claim 8 of the 5,648

Patent will continue to damage CAOs business, causing irreparable harm, for which there is no adequate remedy at law, unless it is enjoined by this Court. COUNT FOUR (Infringement of U.S. Patent No. 6,783,362) 44. Plaintiff realleges and incorporates by reference Paragraphs 125 of this

Complaint as though fully set forth herein. 45. On information and belief, Dentlight has infringed and continues to infringe at

least claim 20 of the 362 Patent by developing, making, using, offering to sell, selling in and/or importing into this District and elsewhere in the United States, the Accused Products, including at least the Fusion 3.0. 46. Dentlights actions constitute infringement of at least claim 20 of the 362 Patent

in violation of 35 U.S.C. 271.

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CAO has sustained damages and will continue to sustain damages as a result of

Dentlights aforesaid acts of infringement. 48. CAO is entitled to recover damages sustained as a result of Dentlights wrongful

acts in an amount to be proven at trial. 49. Dentlights infringement of CAOs rights under at least claim 20 of the 362

Patent will continue to damage CAOs business, causing irreparable harm, for which there is no adequate remedy at law, unless it is enjoined by this Court. COUNT FIVE (Infringement of U.S. Patent No. 6,953,340) 50. Plaintiff realleges and incorporates by reference Paragraphs 125 of this

Complaint as though fully set forth herein. 51. On information and belief, Dentlight has infringed and continues to infringe at

least claim 1 of the 340 Patent by developing, making, using, offering to sell, selling in and/or importing into this District and elsewhere in the United States, the Accused Products, including at least the Fusion 3.0. 52. Dentlights actions constitute infringement of at least claim 1 of the 340 Patent in

violation of 35 U.S.C. 271. 53. CAO has sustained damages and will continue to sustain damages as a result of

Dentlights aforesaid acts of infringement. 54. CAO is entitled to recover damages sustained as a result of Dentlights wrongful

acts in an amount to be proven at trial. 55. Dentlights infringement of CAOs rights under at least claim 1 of the 340 Patent

will continue to damage CAOs business, causing irreparable harm, for which there is no adequate remedy at law, unless it is enjoined by this Court.

COUNT SIX (Infringement of U.S. Patent No. 6,971,875) 56. Plaintiff realleges and incorporates by reference Paragraphs 125 of this

Complaint as though fully set forth herein. 57. On information and belief, Dentlight has infringed and continues to infringe at

least claim 1 of the 875 Patent by developing, making, using, offering to sell, selling in and/or importing into this District and elsewhere in the United States, the Accused Products, including at least the Fusion 3.0. 58. Dentlights actions constitute infringement of at least claim 1 of the 875 Patent in

violation of 35 U.S.C. 271. 59. CAO has sustained damages and will continue to sustain damages as a result of

Dentlights aforesaid acts of infringement. 60. CAO is entitled to recover damages sustained as a result of Dentlights wrongful

acts in an amount to be proven at trial. 61. Dentlights infringement of CAOs rights under at least claim 1 of the 875 Patent

will continue to damage CAOs business, causing irreparable harm, for which there is no adequate remedy at law, unless it is enjoined by this Court. COUNT SEVEN (Infringement of U.S. Patent No. 6,988,891) 62. Plaintiff realleges and incorporates by reference Paragraphs 125 of this

Complaint as though fully set forth herein. 63. On information and belief, Dentlight has infringed and continues to infringe at

least claim 11 of the 891 Patent by developing, making, using, offering to sell, selling in and/or importing into this District and elsewhere in the United States, the Accused Products, including at least the Fusion 3.0. 8

64.

Dentlights actions constitute infringement of at least claim 11 of the 891 Patent

in violation of 35 U.S.C. 271. 65. CAO has sustained damages and will continue to sustain damages as a result of

Dentlights aforesaid acts of infringement. 66. CAO is entitled to recover damages sustained as a result of Dentlights wrongful

acts in an amount to be proven at trial. 67. Dentlights infringement of CAOs rights under at least claim 11 of the 891

Patent will continue to damage CAOs business, causing irreparable harm, for which there is no adequate remedy at law, unless it is enjoined by this Court. COUNT EIGHT (Infringement of U.S. Patent No. 7,077,648) 68. Plaintiff realleges and incorporates by reference Paragraphs 125 of this

Complaint as though fully set forth herein. 69. On information and belief, Dentlight has infringed and continues to infringe at

least claim 10 of the 7,648 Patent by developing, making, using, offering to sell, selling in and/or importing into this District and elsewhere in the United States, the Accused Products, including at least the Fusion 3.0. 70. Dentlights actions constitute infringement of at least claim 10 of the 7,648

Patent in violation of 35 U.S.C. 271. 71. CAO has sustained damages and will continue to sustain damages as a result of

Dentlights aforesaid acts of infringement. 72. CAO is entitled to recover damages sustained as a result of Dentlights wrongful

acts in an amount to be proven at trial.

73.

Dentlights infringement of CAOs rights under at least claim 10 of the 7,648

Patent will continue to damage CAOs business, causing irreparable harm, for which there is no adequate remedy at law, unless it is enjoined by this Court. COUNT NINE (Infringement of U.S. Patent No. 7,086,858) 74. Plaintiff realleges and incorporates by reference Paragraphs 125 of this

Complaint as though fully set forth herein. 75. On information and belief, Dentlight has infringed and continues to infringe at

least claim 2 of the 858 Patent by developing, making, using, offering to sell, selling in and/or importing into this District and elsewhere in the United States, the Accused Products, including at least the Fusion 3.0. 76. Dentlights actions constitute infringement of at least claim 2 of the 858 Patent in

violation of 35 U.S.C. 271. 77. CAO has sustained damages and will continue to sustain damages as a result of

Dentlights aforesaid acts of infringement. 78. CAO is entitled to recover damages sustained as a result of Dentlights wrongful

acts in an amount to be proven at trial. 79. Dentlights infringement of CAOs rights under at least claim 2 of the 858 Patent

will continue to damage CAOs business, causing irreparable harm, for which there is no adequate remedy at law, unless it is enjoined by this Court. COUNT TEN (Infringement of U.S. Patent No. 7,094,054) 80. Plaintiff realleges and incorporates by reference Paragraphs 125 of this

Complaint as though fully set forth herein.

10

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On information and belief, Dentlight has infringed and continues to infringe at

least claim 6 of the 054 Patent by developing, making, using, offering to sell, selling in and/or importing into this District and elsewhere in the United States, the Accused Products, including at least the Fusion 3.0. 82. Dentlights actions constitute infringement of at least claim 6 of the 054 Patent in

violation of 35 U.S.C. 271. 83. CAO has sustained damages and will continue to sustain damages as a result of

Dentlights aforesaid acts of infringement. 84. CAO is entitled to recover damages sustained as a result of Dentlights wrongful

acts in an amount to be proven at trial. 85. Dentlights infringement of CAOs rights under at least claim 6 of the 054 Patent

will continue to damage CAOs business, causing irreparable harm, for which there is no adequate remedy at law, unless it is enjoined by this Court. COUNT ELEVEN (Infringement of U.S. Patent No. 7,252,678) 86. Plaintiff realleges and incorporates by reference Paragraphs 125 of this

Complaint as though fully set forth herein. 87. On information and belief, Dentlight has infringed and continues to infringe at

least claim 19 of the 678 Patent by developing, making, using, offering to sell, selling in and/or importing into this District and elsewhere in the United States, the Accused Products, including at least the Fusion DOE. 88. Dentlights actions constitute infringement of at least claim 19 of the 678 Patent

in violation of 35 U.S.C. 271.

11

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CAO has sustained damages and will continue to sustain damages as a result of

Dentlights aforesaid acts of infringement. 90. CAO is entitled to recover damages sustained as a result of Dentlights wrongful

acts in an amount to be proven at trial. 91. Dentlights infringement of CAOs rights under at least claim 19 of the 678

Patent will continue to damage CAOs business, causing irreparable harm, for which there is no adequate remedy at law, unless it is enjoined by this Court. PRAYER FOR RELIEF WHEREFORE, Plaintiff CAO requests this Court to enter judgment in its favor and against Defendant Dentlight and to grant the following relief: A. Judgment that one or more claims of each of the Asserted Patents has been

infringed by Defendant; B. Orders of this Court temporarily, preliminarily, and permanently enjoining

Dentlight, its agents, servants, and any and all parties acting in concert with it, from infringing in any manner any of the claims of the Asserted Patents pursuant to at least 35 U.S.C. 283; C. An award of damages adequate to compensate CAO for Dentlights infringement

of the Asserted Patents in an amount to be proven at trial; D. attorney fees; E. awarded; and F. Any further relief that this Court deems just and proper. An assessment and award of pre- and post-judgment interest on all damages A finding that this is an exceptional case and an award of Plaintiffs costs and

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DEMAND FOR JURY TRIAL Plaintiff hereby demands a trial by jury as to all claims and all issues properly triable thereby. Respectfully submitted, /s/ James N. Willi C.J. Veverka* (UT Bar No. 07110) cveverka@mabr.com Kirk R. Harris* (UT Bar No. 10221) kharris@mabr.com Mark W. Ford* (UT Bar No. 10629) mford@mabr.com MASCHOFF BRENNEN 1389 Center Drive, Suite 300 Park City, UT 84098 Tel (435) 252-1360 Fax (435) 252-1361 Nathaniel L. Dilger* (CA Bar No. 196203) ndilger@onellp.com Peter R. Afrasiabi* (CA Bar No. 193336) pafrasiabi@onellp.com ONE LLP 4000 MacArthur Blvd., West Tower, Ste 1100 Newport Beach, CA 92660 Tel. (949) 502-2870 Fax (949) 258-5081 James N. Willi Texas Bar No. 00795719 jwilli@willi.com Tracy J. Willi Texas Bar No. 00784633 twilli@willi.com WILLI LAW FIRM, P.C. 100 Congress Ave., Ste. 1530 Austin, TX 78701-2717 Tel. (512) 288-3200 Fax (512) 288-3202 ATTORNEYS FOR PLAINTIFF, CAO GROUP, INC. * Pro Hac Vice Applications Forthcoming 13