Case 8:13-cv-01155-PSG-JEM Document 1 Filed 07/31/13 Page 1 of 30 Page ID #:17

1 Michael T. Hornak (State Bar No. 81936) email: mhornak@rutan.com Ronald P. Oines (State Bar No. 145016) 2 email: roines@rutan.com 3 Bradley A. Chapin (State Bar No. 232885) email: bcha Dingrutan.com RUTAN & TUCKER, LLP 4 611 Anton Boulevard, Fourteenth Floor 5 Costa Mesa, California 92626-1931 Telephone: 714-641-5100 6 Facsimile: 714-546-9035

7 Attorneys for Plaintiffs HID GLOBAL CORPORATION and ASSA ABLOY AB 9 10 11 12 HID GLOBAL CORPORATION, a Delaware corporation; and ASSA 13 ABLOY AB, a Swedish Limited Liability Company, 14 Plaintiffs, 15
VS.

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

SACV13 - 01155 PSG (JEMx)

Case No.

COMPLAINT FOR INJUNCTION AND DAMAGES FOR 1. PATENT INFRINGEMENT A 2. T OEM ' INFRINGEMENT 3. FALSE ADVERTISING 4. FAIR COMPETITION

SOMERLI PINNOCK, an individual; DEMAND FOR JURY TRIAL 17 JOSEPH PINNOCK, an individual; PROXCARDPRO.COM, an entity of 18 unknown form; and DOES 1 through 10, inclusive, 19 Defendants. 20 21 22 23 24 25 26 27 28
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COMPLAINT FOR PATENT INFRINGEMENT, ETC.

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Plaintiffs HID GLOBAL CORPORATION ("HID") and ASSA ABLOY AB

2 ("AAAB") (collectively, "Plaintiffs"), for their Complaint against defendants 3 SOMERLI PINNOCK, JOSEPH PINNOCK, PROXCARDPRO.COM , and DOES 1 4 through 10, inclusive (collectively, "Defendants"), allege as follows: 5 6 1. JURISDICTION AND VENUE This is an action involving claims of, among other things, patent

7 infringement under Title 35, United States Code, and trademark and unfair competition under the Lanham Act, 15 U.S.C. 1051, et seq. This Court has 9 jurisdiction pursuant to 28 U.S.C. 1331 and 1338(a) and (b). 10 2. Venue is proper with this Court pursuant to 28 U.S.C. 1391(b) and

11 (c), as Defendants reside in this judicial district, a substantial part of the events, 12 omissions and acts which are the subject matter of this action occurred within the 13 Central District of California, and a substantial part of the property that is the 14 subject of the action is located in the Central District of California. 15 3. Defendants have operated a website at www.proxcardpro.com , on

16 which they have advertised, offered to sell and sold the products that are alleged 17 herein to infringe upon Plaintiffs' intellectual property described below. Recently, 18 Defendants apparently took down that website after Plaintiffs obtained an 19 Administrative Panel Decision from the World Intellectual Property Organization 20 ("WIPO"), finding that the domain www.proxcardpro.com is confusingly similar to 21 Plaintiff's "PROXCARD" trademark discussed further below. Shortly thereafter, 22 Defendants began operating their business from www.cardsandkeyfobs.com . At this 23 new domain address, Defendants continued advertising, offering to sell and selling 24 the infringing products described below. At both of these domain addresses, 25 customers can shop for, buy, and have delivered to anywhere in the United States, 26 including in this Judicial District, the infringing products that are the subject of this 27 action. On information and belief, Defendants have delivered products to this 28 Judicial District,
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COMPLAINT FOR PATENT INFRINGEMENT

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THE PARTIES
2 4. HID is a Delaware corporation having its principal place of business 3 located at 15370 Barranca Parkway, Irvine, California. 4 5. AAAB is a Limited Liability Company established under the laws of

5 Sweden and having a principal place of business in Stockholm, Sweden. AAAB is 6 HID's parent company. 7 6. Plaintiffs are informed and believe, and thereon allege, that Somerli

8 Pinnock is an individual who lives in Idaho. 9 7. Plaintiffs are informed and believe, and thereon allege, that Joseph

10 Pinnock is an individual who lives in Idaho. 11 8. Plaintiffs are informed and believe, and thereon allege, that

12 PROXCARDPRO.COM is an entity of unknown form, and is owned and operated 13 by Somerli Pinnock. Defendants' address is P.O. Box 232, Parker, ID 83438. 14 9. Defendants are subject to the jurisdiction of this Court because they

15 operate the two websites identified below through which anyone in the United 16 States, including in this Judicial District, can access the website, order the products 17 that are the subject of this action, and have them shipped to anywhere in the United 18 States. On information and belief, Defendants have sold the products that are the 19 subject of this action to residents of this judicial district, and have delivered such 20 product to this judicial district. 21 10. The true names and capacities, whether individual, corporate, associate

22 or otherwise, of defendants DOES 1 through 10, inclusive, are unknown to 23 Plaintiffs, which therefore sue said defendants by such fictitious names. Plaintiffs 24 will seek leave of this Court to amend this Complaint to include their proper names 25 and capacities when they have been ascertained. Plaintiffs are informed and believe, 26 and based thereon allege, that each of the fictitiously named defendants participated 27 in and is in some manner responsible for the acts described in this Complaint and 28 the damage resulting therefrom.
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11.

Plaintiffs allege on information and belief that each of the defendants

2 named herein as Does 1 through 10, inclusive, performed, participated in, or abetted 3 in some manner, the acts alleged herein, proximately caused the damages alleged 4 hereinbelow, and are liable to Plaintiffs for the damages and relief sought herein. 5 12. Plaintiffs allege on information and belief that, in performing the acts

6 and omissions alleged herein, and at all times relevant hereto, each of the 7 Defendants was the agent and employee of each of the other Defendants and was at 8 all times acting within the course and scope of such agency and employment with 9 the knowledge and approval of each of the other Defendants. 10 11 13.

HID'S BUSINESS
HID is a leader in the delivery of secure identity solutions for millions

12 of customers throughout the world. HID's identity solutions are used in a variety of 13 applications, including physical access control, logical access control, access card 14 printing and personalization, highly secure government identification and animal 15 identification. HID's products, solutions and services are sold through a well16 established network of OEMs, developers, systems integrators and distributors 17 worldwide. End users of HID's products, solutions and services include businesses 18 and organizations in virtually all industry sectors, including government, healthcare, 19 retail, industrial, commercial, airports, ports, finance and education. 20 14. HID's physical access control products and solutions are sold under

21 HID' s well-known brands, including iCLASSO, SmartIDO, HIDO Prox and 22 Indalat Prox. These industry leading products, include radio frequency 23 identification ("RFID") readers and credentials that operate at low frequency 24 (i.e., 125 kHz), high frequency (i.e., 13.56 MHz), or both. 25 26

DEFENDANTS' INFRINGING AND UNLAWFUL CONDUCT

15. Defendants have launched a business pursuant to which they are

27 egregiously advertising, offering to sell and selling products that are blatant knock28 offs of Plaintiffs' products in violation of Plaintiffs' intellectual property rights.
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COMPLAINT FOR PATENT INFRINGEMENT, ETC.

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16.

For example, Plaintiffs own United States patent no. D647,810 (the

2 "810 Patent"), entitled "Key Tag." A true and correct copy of the '810 Patent is 3 attached hereto as Exhibit A. The '810 Patent issued on November 1, 2011. 4 Defendants are advertising, offering to sell and selling a key tag that is nearly 5 identical to the key tag disclosed in the '810 Patent and, therefore, infringes the '810 6 patent. 7 17. Additionally, HID has sold since at least 1999 an RFID reader with a

8 particular product configuration as shown, for example, in United States Trademark 9 Registration No. 4,051,851 (the "851 Registration"). A true and correct copy of the 10 '851 Registration is attached hereto as Exhibit B. HID's use of this trade dress has 11 been continuous and exclusive since that time. HID has expended a significant 12 amount of money and resources in advertising, promoting and selling these readers. 13 This reader configuration is also protected by United States Trademark Registration 14 No. 4,051,821 (the '821 Registration"), a true and correct copy of which is attached 15 as Exhibit C. Defendants are advertising, offering to sell and selling RFID readers 16 that are virtually identical to HID's trade dress, as depicted in the '851 and '821 17 registrations. As a result, Defendants have infringed and are infringing Plaintiffs' 18 '851 and '821 registrations. 19 18. HID also owns numerous registered and unregistered trademarks that

20 Defendants use in commerce by imbedding them in meta tags and/or using them as 21 search "keywords" on or in connection with Defendants websites referred to below. 22 For example, HID has for numerous years used the marks "HIDED," 23 "DUOPROXO," "PROXKEYO," "ISOPROVD" and "MICROPROX," among 24 others. Plaintiffs own United States Trademark Registrations for each of these 25 marks. Plaintiffs' HID mark is registered as no. 2,249,625, which issued on June 26 1, 1999. Plaintiffs' DUOPROX0 mark is registered as no. 2,106,847, which issued 27 on October 21, 1997. Plaintiffs' PROXKEY mark is registered as no. 2,356,123, 28 which issued on June 6, 2000. Plaintiffs' ISOPROX mark is registered as no.
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1 2,106,844, which issued on October 21, 1997. Plaintiffs' MICROPROX mark is 2 registered as no. 2,877, 609, which issued on August 24, 2004. Defendants' use of 3 these marks is likely to cause confusion and, therefore, constitutes trademark 4 infringement under the Lanham Act. 5 19. HID for numerous years has used continuously and exclusively certain

6 numbers to identify certain of its products, including for example, 1336, 1346, 1386, 7 1391 and 1586. HID has expended a significant amount of money and resources in 8 advertising, promoting and selling these products under these numbers. As such, the 9 consuming public recognizes these numbers as identifying the source of these 10 products, namely HID. These numbers are protected trademarks. Defendants use 11 each of these marks in commerce by imbedding them in meta tags and/or using them 12 as search "keywords" on or in connection with Defendants websites referred to 13 below. Defendants also use these marks in commerce by identifying their own 14 products with Plaintiffs' marks. Defendants use of these marks is likely to cause 15 confusion and constitutes infringement under the Lanham Act. 16 20. Additionally, since at least 1986, HID has used the trademark

17 "PROXCARD" in connection with certain products. HID' s use of this trademark 18 has been continuous and exclusive since that time. HID has expended a significant 19 amount of money and resources in advertising, promoting and selling products 20 under the PROXCARD mark. Plaintiffs own United States Trademark Registration 21 No. 1,727,117 (the "117 Registration") for the PROXCARD mark. Defendants 22 have used and are using Plaintiffs' PROXCARD mark in connection with 23 Defendants' business, including in its domain address www.proxcardpro.com . On 24 May 17, 2013, Plaintiff Assa Abloy AB filed a Complaint with WIPO relating to 25 Defendants' domain www.proxcardpro.com . On July 11, 2013, WIPO issued an 26 Administrative Panel Decision finding that Defendants' use of "proxcardpro" in its 27 domain is confusingly similar to Plaintiffs' PROXCARD mark, and that 28 Defendants' use of the mark was in bad faith. Defendants' domain also violates
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1 Plaintiffs' trademark rights under the Lanham Act. 2 21. In addition to the patent and trademark infringements described above,

3 Defendants have made, and continue to make numerous false and misleading 4 statements about their products. For example, Defendants claim that their products 5 are "HID compatible," "ProxCard II compatible," "ProxKey II compatible," IsoProx 6 I compatible" and "DuoProx II compatible." 7 22. These statements are false and misleading. First, the term "HID

8 compatible" is false and misleading because, on information and belief, the products 9 about which this statement is made are not fully compatible with the technologies at 10 issue. Moreover, it is nonsensical to identify a product as "HID compatible," 11 because "HID" identifies the entity HID Global Corporation, which sells numerous 12 access security and other products. 13 23. It is also false and misleading to use the ten -ns "ProxCard II

14 compatible," "ProxKey II compatible," IsoProx I compatible" and "DuoProx II 15 compatible." "ProxCard II," "ProxKey II," "IsoProx I" and "DuoProx II" refer to 16 certain RFID cards sold by HID. It is nonsensical to state that knock of cards sold 17 by Defendants are "compatible" with H1D's RFID cards. 18 24. On information and belief, these false and misleading statements have a

19 tendency to deceive, and have actually deceived, a substantial segment of the 20 consuming public or others. Such deception is material and likely to influence 21 purchasing decisions. 22 25. Defendants have made these statement in interstate commerce, and

23 have caused Defendants' falsely advertised goods to be sold in interstate commerce. 24 On information and belief, HID has been injured by such false statements by the 25 direct diversion of sales and by harm to HID's business, reputation and good will. 26 27 28 26.
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FIRST CLAIM FOR RELIEF

(Patent Infringement '810 Patent)

Plaintiffs reallege each and every allegation set forth in paragraphs 1
COMPLAINT FOR PATENT INFRINGEMENT, ETC.

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1 through 25, inclusive, and incorporate them herein by this reference.

2 27. Defendants make, use, sell, offer for sale, and/or import into the United 3 States products that infringe the design disclosed in the '810 Patent. 4 28. Plaintiffs have marked relevant products and/or product literature with

5 the '810 patent pursuant to 35 U.S.C. 287. On information and belief, Defendants 6 have had actual knowledge of the '810 Patent before and during their infringement 7 of the '810 Patent. On information and belief, Defendants' infringement of the

8 '810 Patent has been and will continue to be willful, wanton and deliberate with full
9 knowledge and awareness of Plaintiffs' patent rights. 10 29. Plaintiffs have been damaged in an amount to be determined at trial,

11 but which is no less than a reasonable royalty, and irreparably injured by 12 Defendants' infringing activities. Plaintiffs will continue to be so damaged and 13 irreparably injured unless such infringing activities are enjoined by this Court. 14 30. Additionally, pursuant to 35 U.S.C. 289, Plaintiffs are entitled to

15 Defendants' profits associated with Defendants' infringement. 16 31. Moreover, in light of the willful nature of Defendants' conduct, this

17 case should be deemed "exceptional" under the Patent Laws. As a result, in addition 18 to damages, Plaintiffs are entitled to enhanced damages and their attorneys' fees and 19 costs incurred herein. 20 21 22 32.

SECOND CLAIM FOR RELIEF (Federal Trademark Infringement 15 U.S.C. 1114)

Plaintiffs reallege each and every allegation set forth in paragraphs 1

23 through 25, inclusive, and incorporate them herein by this reference. 24 33. Defendants' unauthorized use of Plaintiffs' design marks protected by

25 the '851 and '821 registrations, and Plaintiffs' PROXCARD, HID, DUOPROX, 26 PROXKEY, ISOPROX and MICROPROX marks constitutes trademark 27 infringement under the Lanham Act. These acts have caused significant damages, 28 including lost sales and profits in an amount to be determined, and irreparable harm
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1 to Plaintiffs. Moreover, Defendants' conduct has caused and will cause significant 2 harm to Plaintiffs' reputation and goodwill which Plaintiffs have established through 3 years of effort and expense. 4 34. Defendants' conduct has been willful with full knowledge of Plaintiffs'

5 trademark rights. Defendants will continue such willful and intentional conduct 6 unless enjoined by this Court. In light of the willful nature of Defendants' conduct, 7 this is an "exceptional" case under the Lanham Act, which entitles Plaintiffs to their 8 attorneys' fees in this action. 9 10 11 35.

THIRD CLAIM FOR RELIEF

(Federal Trademark Infringement 15 U.S.C. 1125)

Plaintiffs reallege each and every allegation set forth in paragraphs 1

12 through 25, inclusive, and incorporate them herein by this reference. 13 36. Defendants' unauthorized use of Plaintiffs' 1336, 1346, 1386, 1391 and

14 1586 marks constitutes trademark infringement under the Lanham Act. These acts 15 have caused significant damages, including lost sales and profits in an amount to be 16 determined, and irreparable harm to Plaintiffs. Moreover, Defendants' conduct has 17 caused and will cause significant harm to Plaintiffs' reputation and goodwill which 18 Plaintiffs have established through years of effort and expense. 19 37. Defendants' conduct has been willful with full knowledge of Plaintiffs'

20 trademark rights. Defendants will continue such willful and intentional conduct 21 unless enjoined by this Court. In light of the willful nature of Defendants' conduct, 22 this is an "exceptional" case under the Lanham Act, which entitles Plaintiffs to their 23 attorneys' fees in this action. 24 25 26

FOURTH CLAIM FOR RELIEF

(False Advertising and Unfair Competition 15 U.S.C. 1125)

38. Plaintiffs reallege each and every allegation set forth in paragraphs 1

27 through 25, inclusive, and incorporate them herein by this reference. 28 39.
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Defendants' conduct described above constitutes a violation of 15

COMPLAINT FOR PATENT INFRINGEMENT, ETC.

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1 U.S.C. 1125 of the Lanham Act. These acts have caused significant damages, 2 including lost sales and profits in an amount to be determined, and irreparable harm 3 to Plaintiffs. Moreover, Defendants' conduct has caused and will cause significant 4 harm to Plaintiffs' reputation and goodwill which Plaintiffs have established through 5 years of effort and expense. 6 40. Defendants' aforesaid acts constitute deliberate and intentional

7 violations of 15 U.S.C. 1125, causing damages, as well as irreparable harm to 8 Plaintiffs for which there is no adequate remedy at law. Given the willful nature of 9 Defendants' conduct, this is an "exceptional" case under the Lanham Act, entitling 10 Plaintiffs to their attorneys' fees incurred herein. Plaintiffs are informed and 11 believe, and thereon alleges that unless restrained by this Court, Defendants will 12 continue the acts herein complained of. 13 14 15 41.

FIFTH CLAIM FOR RELIEF (Common Law Unfair Competition)

Plaintiffs reallege each and every allegation set forth in paragraphs 1

16 through 25, inclusive, and incorporate them herein by this reference. 17 42. The foregoing acts and conduct of Defendants constitute unfair

18 competition under California common law. 19 43. Defendants' acts have caused damage to Plaintiffs, including incidental

20 and general damages, lost profits, and out-of-pocket expenses in an amount to be 21 determined, and irreparable harm to Plaintiffs. Moreover, Defendants' conduct has 22 caused and will cause significant harm to Plaintiffs' reputation and goodwill which 23 Plaintiffs have established through years of effort and expense. 24 44. Plaintiffs are informed and believe, and thereon allege, that

25 Defendants' conduct was done with a conscious disregard of the rights of Plaintiffs 26 and with the intent to vex, injure, or annoy such as to constitute oppression, fraud, or 27 malice under California Civil Code section 3294 and/or the common law of 28 California, entitling Plaintiffs to punitive damages in an amount appropriate to
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1 punish or set an example of Defendants. 2 45. As a proximate result of Defendants' conduct, Plaintiffs have suffered

3 and will suffer immediate and irreparable injury not compensable by money 4 damages, such that preliminary and permanent injunctions should issue against 5 Defendants. Plaintiffs are informed and believe, and thereon allege that unless 6 restrained by this Court, Defendants will continue the acts herein complained of. 7 8 9 46.

SIXTH CLAIM FOR RELIEF

(California Business And Professions Code 17200 et seq.)

Plaintiffs reallege each and every allegation set forth in paragraphs 1

10 through 25, inclusive, and incorporate them herein by this reference. 11 47. The foregoing acts and conduct of Defendants constitute unfair trade

12 practices and unfair competition under California Business and Professions Code 13 Section 17200 et seq. and have no valid or legitimate purpose except to benefit 14 Defendants at the expense of Plaintiffs. 15 48. Defendants' acts have caused damage to Plaintiffs, including incidental

16 and general damages, lost profits, and out-of-pocket expenses. Defendants should 17 therefore be required to disgorge and restore to Plaintiffs all profits earned by 18 Defendants from their unlawful conduct. Plaintiffs further seek an injunction to 19 enjoin Defendants from continuing said unfair business practices. 20 21 22

PRAYER FOR RELIEF

WHEREFORE, Plaintiffs pray for judgment against Defendants as follows: 1. That Defendants, their officers, directors, agents, servants, employees,

23 and all persons and entities in active concert or participation with them, or any of 24 them, be preliminarily and permanently enjoined and restrained from further 25 infringement of the '810 Patent; 26 2. A judgment by the Court that Defendants have infringed and are

27 infringing the '810 Patent; 28 3.

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An award of damages for infringement of the '810 Patent, and

COMPLAINT FOR PATENT INFRINGEMENT, ETC.

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1 Defendants' profits, together with prejudgment interest and costs, said damages to 2 be trebled by reason of the intentional and willful nature of Defendants' 3 infringement, as provided by 35 U.S.C. 284; 4 4. A determination that this case is "exceptional" under 35 U.S.C. 285,

5 and an award of Plaintiffs' reasonable attorneys' fees; 6 5. That Defendants, their officers, directors, agents, servants, employees,

7 and all persons and entities in active concert or participation with them, or any of

8 them, be preliminarily and permanently enjoined and restrained from infringing or

9 otherwise using without Plaintiffs' authorization Plaintiffs' marks by manufacturing 10 or causing to be manufactured, by purchasing or causing to be purchased, by 11 advertising or causing to be advertised, or by offering for sale or selling goods or 12 services bearing or incorporating Plaintiffs' marks or any confusingly similar mark 13 or design, including any use in a domain name, meta tags or keyword advertising; 14 6. That Defendants be ordered to transfer the domain name

15 www.proxcardpro.com to Plaintiffs; 16 7. That Defendants be required to forthwith deliver up to Plaintiffs for

17 destruction any and all merchandise in their possession, custody, or control that 18 would otherwise violate any of the aforesaid injunctions; 19 8. That Defendants be further required to deliver up to Plaintiffs for

20 destruction any and all boxes, containers, labels, signs, prints, packages, wrappers, 21 advertising, promotional and other material in their possession, custody or control 22 displaying or promoting any merchandise bearing or incorporating Plaintiffs' Marks 23 or any confusingly similar mark or design; 24 9. That Defendants be ordered pursuant to Section 34 of the Lanham Act,

25 15 U.S.C. 1116(a), to file with the Court and serve upon Plaintiffs' counsel, within 26 thirty (30) days of the entry of the injunctions and orders prayed for herein, a written 27 report under oath setting forth in detail the form and manner in which they have 28 complied with said injunctions and orders;
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10.

That Defendants account for all profits realized as a consequence of

2 their unlawful acts of deliberate and intentional trademark infringement, unfair 3 competition and other violations, as alleged herein, and that the amount of profits 4 realized by Defendants by reason of their unlawful acts be trebled, as provided by 5 law pursuant to Section 35 of the Lanham Act, 15 U.S.C. 1117; 6 11. That Plaintiffs be awarded damages in the full amount Plaintiffs have

7 sustained as a consequence of Defendants' acts, trebled where provided by law,

8 pursuant to Section 35 of the Lanham Act, 15 U.S.C. 1117;

9 12. That Plaintiffs have and recover from Defendants reasonable attorneys' 10 fees, costs and disbursements of this action pursuant to 15 U.S.C. 1117; 11 12 13. 14. That this case be deemed "exceptional" under the Lanham Act; That the Court grant Plaintiffs restitution from Defendants by

13 disgorgement of all profits earned through unlawful sales of infringing goods; 14 15. That Defendants, their officers, directors, agents, servants, employees,

15 and all persons and entities in active concert or participation with them, or any of 16 them, be preliminarily and permanently enjoined and restrained from publishing 17 false or misleading statements, as alleged herein; 18 16. That the Court grant Plaintiffs restitution from Defendants by

19 disgorgement of all profits earned through Defendants conduct; 20 17. For restitution of any money or property Defendants wrongfully

21 obtained, pursuant Business and Professions Code section 17203; 22 23 18. 19. For punitive damages; That any monetary award include pre- and post-judgment interest at the

24 highest rate allowed by law; 25 26 27 28

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20. 21.

For costs of suit; and For such other and further relief as the Court may deem just and proper.

COMPLAINT FOR PATENT INFRINGEMENT, ETC. -12-

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1 Dated: July 31, 2013

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
2118/025100-0007 5957619.1 a07/30/13

RUTAN & TUCKER, LLP MICHAEL T. HORNAK RONALD P. OINES BRADLEY A. CHAPIN

onal P ines Attorneys for Plaintiffs HID GLOBAL CORPORATION and ASSA ABLOY AB

COMPLAINT FOR PATENT INFRINGEMENT, ETC.

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1
2

DEMAND FOR JURY TRIAL Pursuant to Local Rule 38-1 of the Local Rules of the United States District

3 Court for the Central District of California, Plaintiffs hereby demand a jury trial in 4 this action. 5 Dated: July 31, 2013 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
2118/025100-0007 5957619,1 a07/30/13

RUTAN & TUCKER, LLP MICHAEL T. HORNAK RONALD P. OINES BRADLEY A. CHAPIN By: Ronald P. Oines Attorneys for Plaintiffs HID GLOBAL CORPORATION and ASSA ABLOY AB

COMPLAINT FOR PATENT INFRINGEMENT, ETC.

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EXHI IT A

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11 II II
(12)

US00D647810S

1111111101111

II 1

II

United States Design atent (10)

Bohrer
(45)

Patent No.: Date of Patent:

US D647,810 S ** Nov. 1, 2011

D3/207 D11/79

(54) KEY TAG (75) Inventor: Jason Christopher Rohrer, L,adera Ranch, CA (US) (73) Assignee: Assa Abloy AB (SE)
(1, 5)

D548,956 S * 8/2007 Rimon D635,483 S * 4/2011 Charles et al. 2010/0328071 AU'` 12/2010 Schmidt et al.

340/568.1

FOREIGN PATENT DOCUMENTS

RU 52821 4/2006

OTHER PUBLICATIONS Official Action with English translation for Russia Patent Application
No. 2010503049, issued May 16, 2011 5 pages.

Term:

14 Years

(21) Appl. No.: 29/359,904 (22) Filed: Apr. 16, 2010

cited by examiner
Primary Examiner Caron D Veynar Assistant Examiner George D Kirschbaum (74) Attorney, Agent, or Firm Sheridan Ross P.C.

(51) LOC (9) Cl. 10-05 (52) U.S. CI. D10/106.9 (58) Field of Classification Search D10/106.9, D10/106,91; D8/354, 356, 364, 373, 380; D131137.1, 137.2, 138.1; 340/572.8, 572.1, 340/578.9, 568.1, 825.54 See application file for complete search history. (56) References Cited U.S. PATENT DOCUMENTS 5,617,751 A * 4/1997 Song
D431,341 S * 9/2000 DiPaolo et al, 6,248,451 B1* 6/2001 Smith D500,808 S * 1/2005 Howard

(57) CLAIM The ornamental design for a key tag, as shown and described, DESCRIPTION FIG. 1 is a perspective view of a key tag; FIG. 2 is a front plan view thereof; FIG. 3 is a right side elevational view thereof; FIG. 4 is a left side elevational view thereof; FIG. 5 is a top elevational view thereof; FIG. 6 is a bottom elevational view thereof; and, FIG. 7 is a back plan view thereof. The portions of the key tag illustrated in broken lines form no part of the claimed design.
1 Claim, 3 Drawing Sheets

701456R D99/34 428/542.2 D20/28

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Nov. 1, 2011

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Case 8:13-cv-01155-PSG-JEM Document 1 Filed 07/31/13 Page 22 of 30 Page ID #:38

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Reg. No. 4,051,851 Registered Nov. 8, 2011 Int. Cl.: 9

TRADEMARK PRINCIPAL REGISTER

ASSA A141,0Y AR (SWEDEN CORPORATION) P.O. BOX 70340, SE-107 23 STOCKHOLM ; SWEDEN FOR: RADIO FREQUENCY IDENTIFICATION (REID) READERS, IN CLASS 9 (U.S. CLS. 21,23, 26, 36 AND 38). FIRST TJSE 5-27-1999; IN COMMERCE 5-27-1999. THE MARK CONSISTS OF A THREE DIMF,NSTONAL CONFTGURATION OF AN RFD READER COMPRISING A RECTANGULAR IIOUSING WITII A FRONT FACE, TWO SIDE EACHS AND TOPAND BOTTOM. THE FRONT EACH INCLUDESA TOPANGLED SURFACE, AND A BOTTOM ANGLED SURFACE WITH THE SIDE FACES TAPERED AT THE TOP AND BOTTOM AT THE ANGLED PORTIONS OE' THE FRONT LACE. ALL FORWARD FACING EDGES THAT TRANSITION BETWEEN SURFACES ARE ROUNDED. SIX HORIZONTAL GROOVES ARE FORMED WITHIN THE FRONT FACE WITH THE SECOND GROVE FROM THE TOP BEING SHORTER AND A CIRCLE PLACED TO THE RIGHT OF THE SHORTER GROOVE. A GAP IS SET BETWEEN THE BOTTOM FOUR LINES AND THE TOP TWO LINES. THE MATTER SHOWN IN BROKEN OR DOTTED LINES IS NOT PART OF THE MARK AND SERVES ONLY TO SHOW THE POSITION OR PLACEMENT OF THE MARK. SEC. 2(E). SER. NO. 85-142 ; 173, FILED 9-30-2010. ADA HAN, EXAMINING ATTORNEY .

Director of the United Stales Patent and Taidernmic Offic

AMBIT

Case 8:13-cv-01155-PSG-JEM Document 1 Filed 07/31/13 Page 23 of 30 Page ID #:39

REQUIREMENTS TO MAINTAIN YOUR FEDERAL TRADEMARK REGISTRATION WARNING: YOUR REGISTRATION WILL BE CANCELLED IF YOU DO NOT FILE THE DOCUMENTS BELOW DURING THE SPECIFIED TIME PERIODS. Requirements in the First Ten Years* What and When to File: First Filing Deadline: You must file a Declaration of Use (or Excusable Nonuse) between the 5th and 6th years after the registration date, See 15 U.S.C. 1058, 1141k, If the declaration is accepted, the registration will continue in force for the remainder of the ten-year period, calculated from the registration date, unless cancelled by an order of the Commissioner for Trademarks or a federal court. Second Filing Deadline: You must file a Declaration of Use (or Excusable Nonuse) and an Application for Renewal between the 9th and 10th years after the registration date.* See 15U U.S.C. 1059. Requirements in Successive Ten-Year Periods* What and When to File: You must file a Declaration of Use (or Excusable Nonuse) and an Application for Renewal between every 9th and 10th-year period, calculated from the registration date.* Grace Period Filings* The above documents will be accepted as timely if filed within six months after the deadlines listed above with the payment of an additional fee. The United States Patent and Trademark Office (USPTO) will NOT send you any future notice or reminder of these filing requirements. *ATTENTION IVIADRID PROTOCOL REGISTRANTS: The holder of an international registration with an extension of protection to tile United States under the Madrid Protocol must timely file the Declarations of Use (or Excusable Notruse) referenced above directly with the USPTO. The time periods for filing are based on the U.S. registration date (not the international registration date). The deadlines and grace periods for the Declarations of Use (or Excusable Nonuse) are identical to those for nationally issued registrations. See 15 U.S.C. 1058, 1141k. However, owners of international registrations do not file renewal applications at the USPTO. Instead, the holder must file a renewal of the underlying international registration at the International Bureau of the World Intellectual Property Organization, under Article 7 of the Madrid Protocol, before the expiration of each ten-year tern of protection, calculated from the date of the international registration. See 15 U.S . C. 1141j. For more information and renewal forms for the international registration, see http://www.wipo.int/madrid/en/. NOTE: Fees and requirements for maintaining registrations are subject to change. Please check the USPTO website for further information. With the exception of renewal applications for registered extensions of protection, you can file the registration maintenance documents referenced above online at littp://www.uspto,gov.

Page: 2 / RN # 4,051,851

Case 8:13-cv-01155-PSG-JEM Document 1 Filed 07/31/13 Page 24 of 30 Page ID #:40

EXHI IT C

Case 8:13-cv-01155-PSG-JEM Document 1 Filed 07/31/13 Page 25 of 30 Page ID #:41

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Reg. No. 4,051,821 Registered Nov. 8, 2011 Int. 9

ASSA AF1LOY AB (SWEDEN CORPORATION) P.O. BOX 70340, SE-107 23 STOCKHOLM, SWEDEN FOR: RADIO FREQUENCY IDENTIFICATION (REE)) READERS, IN CLASS 9 (U.S. CLS. 21, 23, 26, 36 AND 38). FIRST TJSE 5-27-1999; IN COMMERCE 5-27-1999. THE MARK CONSISTS OF SIX HORIZONTAL LINES ANT) A CIRCLE, WHERE THE LINE SECOND FROM THE TOP IS SIIORTER THAN TILE REMAINING LINES, AND IIAS A CIRCLE TO THE RIGHT. TRH DOTTED LINES ARE NOT PART OF NTH:MARK AND SERVE ONLY TO SIIOW TIE PLACEMENT OF TIE MARK UPON TIE FRONT OF TIE PRODUCT. SEC. 2(F). SER. NO. 85-136,450, FILED 9-23-2010, ADA HAN, EXA_MINING ATTORNEY

TRADEMARK PRINCIPAL REGISTER

cIAA:ot

Director of the linked Slates Patent and fradernark Office

EXHIBIT

Case 8:13-cv-01155-PSG-JEM Document 1 Filed 07/31/13 Page 26 of 30 Page ID #:42

REQUIREMENTS TO MAINTAIN YOUR FEDERAL TRADEMARK REGISTRATION WARNING: YOUR REGISTRATION WILL BE CANCELLED IF YOU DO NOT FILE THE DOCUMENTS BELOW DURING THE SPECIFIED TIME PERIODS. Requirements in the First Ten Years* What and When to File: First Filing Deadline: You must file a Declaration of Usc (or Excusable Nonuse) between the 5th and 6th years after the registration date. See 15 U.S.C. 1058, 1141k. If the declaration is accepted, the registration will continue in force for the remainder of the ten-year period, calculated from the registration date, unless cancelled by an order of the Commissioner for Trademarks or a federal court, Second Filing Deadline: You must file a Declaration of Use (or Excusable Nonuse) and an Application for Renewal between the 9th and 10th years after the registration date.* See 15 U .S.C. 1059. Requirements in Successive Ten-Year Poiods* What and When to File: You must file a Declaration of Use (or Excusable Nonuse) and an Application for Renewal between every 9th and 10th-year period, calculated from the registration date.* Grace Period Filings* The above documents will be accepted as timely if filed within six months after the deadlines listed above with the payment of an additional fee, The United States Patent and Trademark Office (USPTO) will NOT send you any future notice or reminder of these filing requirements. *ATTENTION MADRID PROTOCOL REGISTRANTS: The holder of an international registration with an extension of protection to the United States under the Madrid Protocol must timely file the Declarations of Use (or Excusable Nonuse) ieferenced above directly with the USPTO. The time periods for filing are based on the U.S. registration date not the international registration date). The deadlines and grace periods for the Declarations of Use (or Excusable Nonuse) are identical to those for nationally issued registrations. See 15 U S. c. 1058, 1 lit 1 k. However, owners of international registrations do not file renewal applications at the USPTO. Instead, the holder must file a renewal of the underlying international registration at the International Bureau of the World Intellectual Property Organization, under Article 7 of the Madrid Protocol, before the expiration of each ten-year term of protection, calculated from the date of die international registration See 15U U.S.C. 1141.j. For more information and renewal forms for the international registration, see http://wwwwipo.int/madrid/en. NOTE: Fees and requirements for maintaining registrations are subject to change. Please check the USPTO website for further information. With the exception of renewal applications for registered extensions of pmtection, you can file the registration maintenance documents referenced above online at littp://www.uspto.gov .

Page: 2 / RN #4,051,821

OBIT

Case 8:13-cv-01155-PSG-JEM Document 1 Filed 07/31/13 Page 27 of 30 Page ID #:43

UNITED STATES DISTRICT COURT CENT L DISTACT OF CAL:70 IA

A

NOTICE OF ASSIGNMENT TO UNITED STATES MAGISTRATE GE FOR DISCOVERY

This case has been assigned to District Judge Philip S. Gutierrez and the assigned discovery Magistrate Judge is John E. McDermott. The case number on all documents filed with the Court should read as follows:
CV13- 1155 PSG (JEMx)

Pursuant to General Order 05-07 of the United States District Court for the Central District of California, the Magistrate Judge has been designated to hear discovery related motions.

All discovery related motions should be noticed on the calendar of the Magistrate Judge

NOTICE TO COUNSEL
A copy of this notice must be served with the summons and complaint on all defendants (if a removal action is filed, a copy of this notice must be served on all plaintiffs). Subsequent documents must be filed at the following location:

Li Western Division 312 N. Spring St., Rm. G-8 Los Angeles, CA 90012

Southern Division 411 West Fourth St., Rm. 1-053 Santa Ana, CA 92701-4516

[I Eastern Division 3470 Twelfth St., Rm. 134 Riverside, CA 92501

Failure to file at the proper location will result in your documents being returned to you.

CV-18 (03/06)

NOTICE OF ASSIGNMENT TO UNITED STATES MAGISTRATE JUDGE FOR DISCOVERY

Case 8:13-cv-01155-PSG-JEM Document 1 Filed 07/31/13 Page 28 of 30 Page ID #:44 Michael T. Hornak SBN 81936, Dmak@rutan.com Ronald P. Oines SBN 145016, roines@rutan.com Bradley A. Chapin SBN 232885, bchapin@rutan.com RUTAN & TUCKER, LLP 611 Anton Boulevard, Fourteenth Floor Costa Mesa, CA 92626 Telephone: (714) 641-5100 / Fax: (714) 546-9035 Attorneys for Plaintiffs
UNITED STATES DISTRICT COURT CENT L DISTRICT OF CALIFORNIA HID GLOBAL CORPORATION, a Delaware corporation; and ASSA ABLOY AB, a Swedish Limited Liability Company,
PLAINTIFF(S) CASE NUMBER

SACV13 - 01155 PSG (IF:gx)

V. SOMERLI PINNOCK, an individual; JOSEPH P1NNOCK, an individual; PROXCARDPRO.COM , an entity of unknown form; and DOES 1 through 10, inclusive,
DEFENDANT(S).

SUMMONS

TO: DEFENDANT(S): A lawsuit has been filed against you. Within 21 days after service of this summons on you (not counting the day you received it), you must serve on the plaintiff an answer to the attached M complaint amended complaint cross-claim or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer counterclaim II or motion must be served on the plaintiffs attorney, Michael T. Hornal(EsA adley A. Chapin, Esq., Rutan & Tucker, LLP, whose address is 611 Anton Boulevard, Fourreenth Floor, Costa Mesa, CA 92626. If you fail to do so, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court. Clerk, U.S. District Court By:

3
Dated:

DODJIE LAG
Deputy Clerk
(Seal of the Court)

[Use 60 days if the defendant is the United States or a United States agency, or is an officer or employee of the United States. Allowed 60 days by Rule 12 (a)(3)1.

CV-01A (10/11

SUMMONS

American LegalNet, Inc. www.FormsWorkFlow.com

Case 8:13-cv-01155-PSG-JEM Document 1 Filed 07/31/13 Page 29 of 30 Page ID #:45

UNITED S ES DISTRICT COURT, CENTRAL DISTRICT CIVIL COVER SHEET CALIFORNIA I. (a) PLAINTIFFS ( Check box if you are representing yourself

C1 )

DEFENDANTS

( Check box if you are representing yourself Li

HID GLOBAL CORPORATION, a Delaware corporation; and ASSA ABLOY AB, a Swedish Limited Liability Company,
(b) Attorneys (Firm Name, Address and Telephone Number, If you
ore

SOMERLI PINNOCK, an individual; JOSEPH PINNOCK, an individual; PROXCARDPRQ.COM , an entity of unknown form; and DOES 1 through 10, inclusive, (b) Attorneys (Firm Name, Address and Telephone Number. If you are representing yourself, provide same.)

representing yourself, provide same.) Michael T. Hornak SBN 81936 / Ronald P. Oines SBN 145016 Bradley A. Chapin SBN 232885

RUTAN & TUCKER, LLP, 611 Anton Boulevard, 14 th Floor Costa Mesa, CA 92626 Telephone: (714) 641-5100
II. BASIS OF JURISDICTION (Place an X in one box only.)
1. U.S. Government Plaintiff 3. Federal Question (U.S. Government Not a Party) 04. Diversity (Indicate Citizenship of Parties in Item III)

III. CITIZENSHIP OF PRINCIPAL PARTIES-For Diversity Cases Only

(Place an X in one box for plaintiff and one for defendant)
PTF Citizen of This State Citizen of Another State El 1 DEF II 1 II] 2 Incorporated or Principal Place of Business in this State PIP 0 4 DEF 4

0 117

1 1

2. U.S. Government Defendant

Incorporated and Principal Place CI 5 Business in Another State Forei g n Nation El 6

Li 5
El 6

Citizen or Subject of a Forei g n Country 3

El

IV. ORIGIN (Place an X in one box only.)

1. Ori g inal Proceedin g

El 2. Removed from
State Court

Li 3. Remanded from Appellate Court

111

4. Reinstated or
Reopened

5. Transferred from Another District (Specify)

El

6. Multi- District Liti g ation

V. REQUESTED IN COMPLAINT: JURY DEMAND: CLASS ACTION under F.R.Cv.P. 23: VI. CAUSE OF ACTION

Yes No

111

No (Check "Yes" only if demanded in complaint.) MONEY DEMANDED IN COMPLAINT: $ According to proof.

EI Yes El

(Cite the U.S. Civil Statute under which y ou are filin g and write a brief statement of cause. Do not cite jurisdictional statutes unless diversit y .)

This action involves claims of patent infringement under Title 35, United States Code, and trademark and unfair competition under the Lanham Act, 15 U.S.C, Section 1051 et seq.
VII. NATURE OF SUIT (Place an X in one box only).
OTHER STATUTES I CONTRACT REAL PROPERTY CONT. 240 Torts to Land 245 Tort Product Liabilit y 290 All Other Real Propert y TORTS PERSONAL INJURY LII 310 Airplane 315 Airplane Product Liability Li 320 Assault, Libel & Slander Li 330 Fed. Emplo y ers' Liabilit y 340 Marine 345 Marine Product Liability Li 350 Motor Vehicle 355 Motor Vehicle Product Liability Li 360 Other Personal Injur y Li 362 Personal Injur y Med Malpratice 365 Personal Injur y Product Liabilit y 367 Health Care/ Pharmaceutical Personal Injur y Product Liability III 368 Asbestos Personal Injur y SACIVIXLI-01 1155 371 Truth in Lending 380 Other Personal Propert y Dama g e 385 Propert y Dama g e Product Liabilit y BANKRUPTCY IMMIGRATION PRISONER PETITIONS Habeas Corpus: 463 Alien Detainee 510 Motions to Vacate Sentence EI 530 General 535 Death Penalt y Other: IIIII 540 Mandamus/Other EN 550 Civil Rights 555 Prison Condition 560 Civil Detainee Conditions of Confinement FORFEITURE/PENALTY 830 Patent 840 Trademark SOCIAL SECURITY 861 HIA (1395ff) 862 Black Lun g (923) 863 DIWC/DIVVW (405 ( g )) 864 SSID Title XVI Li 865 RSI (405 ( g )) FEDERAL TAX SUITS Li870 Taxes (U.S. Plaintiff or Defendant) 871 IRS-Third Part y 26 USC 7609 PROPERTY RIGHTS III 820 Copyrights

rI

I 375 False Claims Act

400 State Reapportionment 410 Antitrust

LIII 110 Insurance

120 Marine 130 Miller Act 140 Ne g otiable Instrument Li 150 Recover y of Overpa y ment & Enforcement of Judgment Li 151 Medicare Act Li 152 Recover y of Defaulted Student Loan (Excl. Vet.) 153 Recover y of Overpa y ment of Vet. Benefits Li 160 Stockholders' Suits Li 190 Other Contract Li 195 Contract Product Liabilit y 11111 196 Franchise

Li

462 Naturalization Application 465 Other Immi g ration Actions

pi 430 Banks and Bankin g Li 450 Commerce/ICC

Rates/Etc.

TORTS PERSONAL PROPERTY 370 Other Fraud

1 460 Deportation I 470 Racketeer Influenced & Corrupt Or g . 490 Cable/Sat TV

1 480 Consumer Credit

850 Securities/Cornmodities/Exchan g e

Li
I I

Li 422 Appeal 28
USC 158 Li 423 Withdrawal 28 USC 157 CIVIL RIGHTS Li 440 Other Civil Ri g hts

Ei 625 Dru g Related

Seizure of Propert y 21 USC 881 690 Other LABOR IIIII 710 Fair Labor Standards Act 720 Labor/M g mt. Relations 740 Railwa y Labor Act

____I 890 Other Statutor y Actions

891 A g ricultural Acts

I 893 Environmental Matters 895 Freedom of Info. Act

Li 441 Votin g
Li 442 Employment IIII 443 Housin g / Accomodations 445 American with DisabilitiesEmployment Li 446 American with Disabilities-Other

Li 896 Arbitration 899 Admin. Procedures Act/Review of Appeal of A g enc y Decision

REAL PROPERTY
Li 210 Land Condemnation

Li 751 Famil y and Medical

Leave Act Li 790 Other Labor Liti g ation 791 Emplo y ee Ret. Inc. Security Act

I 950 Constitutionalit y of
State Statutes

Li

220 Foreclosure

Li 230 Rent Lease & Ejectment

Pi,

448 Education aE.Mir)

FOR OFFICE USE ONLY: Case Number, AFTER COMPLETING PAGE 1 OF FORM CV-71, COMPLE I E THE INFORMATION REQUESTED ON PAGE 2.
CV-71 (02/13) CIVIL COVER SHEET Pa g e 1 of 2

Case 8:13-cv-01155-PSG-JEM Document 1 Filed 07/31/13 Page 30 of 30 Page ID #:46

UNITED ATES DISTRICT COURT, CENTRAL E. RICT OF CALIFORNIA
CIVIL COVER SHEET VIII(a). IDENTICAL CASES: Has this action been previously filed in this court and dismissed, remanded or closed?
If yes, list case number(s):

rA NO

El YES

VIII(b). RELATED CASES: Have any cases been previously filed in this court that are related to the present case?
If yes, list case number(s): Civil cases are deemed related if a previously filed case and the present case: (Check all boxes that apply) El A. Arise from the same or closely related transactions, happenings, or events; or

11

NO

El YES

El El El
IX. VENUE:

B. Call for determination of the same or substantially related or similar questions of law and fact; or C. For other reasons would entail substantial duplication of labor if heard by different judges; or D. Involve the same patent, trademark or copyright, and one of the factors identified above in a, b or c also is present.

(When completing the following information, use an additional sheet if necessary.)

(a) List the County in this District; California County outside of this District; State if other than California; or Foreign Country, in which EACH named plaintiff resides.

El

Check here if the government, its agencies or employees is a named plaintiff. If this box is checked, go to item (b).
California County outside of this District; State, if other than California; or Foreign Country

County in this District:"

HID Global Corporation resides in Orange County, California

Assa Abloy AB resides in Stockholm, Sweden

(b) List the County in this District; California County outside of this District; State if other than California; or Foreign Country, in which EACH named defendant resides. [1] Check here if the government, its agencies or employees is a named defendant. If this box is checked, go to item (c).
County in this District:* California County outside of this District; State, if other than California; or Foreign Country

Defendants Somerli Pinnock and Joseph Pinnock reside in Idaho. Defendant Proxcardpro.com resides in the Central District of CA pursuant to 28 U.S.C. Section 1391(c)(2)
(c) List the County in this District; California County outside of this District; State if other than California; or Foreign Country, in which EACH claim arose. NOTE: In land condemnation cases, use the location of the tract of land involved.
County in this District:* California County outside of this District; State, if other than California; or Foreign Country

Orange County
*Los Angeles, Orange, San Bernardino, Riverside, Ventura, Santa Barbara, or San Luis Obispo Counties Note: In land condemnation cases, use the location of the tract of land involved X. SIGNATURE OF ATTORNEY (OR SELF-REPRESENTED LITIGANT): DATE: 7

'

1 1 3

Ro ald P. Oi es
Notice to Counsel/Parties: The CV-71 (JS-44) Civil Cover Sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law. This form, approved by the Judicial Conference of the United States in September 1974, is required pursuant to Local Rule 3-1 is not filed but is used by the Clerk of the Court for the purpose of statistics, venue and initiating the civil docket sheet. (For more detailed instructions, see separate instructions sheet). Key to Statistical codes relating to Social Security Cases: Nature of Suit Code Abbreviation 861 NIA Substantive Statement of Cause of Action All claims for health insurance benefits (Medicare) under Title 18, Part A, of the Social Security Act, as amended. Also, include claims by hospitals, skilled nursing facilities, etc., for certification as providers of services under the program. (42 U.S.C. 1935FF(b)) All claims for "Black Lung" benefits under Title 4, Part B, of the Federal Coal Mine Health and Safety Act of 1969. (30 U.S.C. 923) All claims filed by insured workers for disability insurance benefits under Title 2 of the Social Security Act, as amended; plus all claims filed for child's insurance benefits based on disability. (42 U.S.C. 405 (g)) All claims filed for widows or widowers insurance benefits based on disability under Title 2 of the Social Security Act, as amended. (42 U.S.C. 405 (g)) All claims for supplemental security income payments based upon disability filed under Title 16 of the Social Security Act, as amended. All claims for retirement (old age) and survivors benefits under Title 2 of the Social Security Act, as amended, (42 U.S.C. 405 (g)) CIVIL COVER SHEET Page 2 of 2
American LegaiNet, the. k www.FormsWorkFlow.com i

862

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863

DIVVC

863

DIINVV

864 865 CV-71 (02/13)

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