Case: 1:14-cv-09455 Document #: 1 Filed: 11/25/14 Page 1 of 12 PageID #:1

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
)
)
)
Plaintiff,
)
v.
)
)
PREMIER ACCESSORY GROUP, LLC, )
)
Defendant.
)
)
)
CUSTOM ACCESSORIES INC.,

Civil Case No.

JURY TRIAL DEMANDED

COMPLAINT FOR DESIGN PATENT INFRINGEMENT

Plaintiff Custom Accessories Inc. (hereinafter Custom Accessories), for its complaint
against Defendant Premier Accessory Group, LLC (hereinafter Premier), hereby alleges, upon
personal knowledge as to itself and on information and belief as to all other matters, as follows:
Nature of Action
1.

This action arises as a result of Premiers infringement of United States Design

Patent No. D709,891 (hereinafter 891 patent), attached as Exhibit A, and United States
Design Patent No. D717,305 (hereinafter 305 patent), attached as Exhibit B (collectively, the
USB Adapter patents), in violation of the Patent Act of the United States. Custom Accessories
seeks damages for Premiers infringement and other wrongful conduct, enhancement of damages
due to Premiers willful and knowing infringement actions, reasonable attorneys fees and costs,
a permanent injunction barring Premier from further infringement actions, and other appropriate
relief.

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The Parties
2.

Custom Accessories Inc. is an Illinois corporation organized and existing under

the laws of Illinois, with its principal place of business at 5900 Ami Drive, Richmond, Illinois
60071.
3.

Premier Accessory Group, LLC, is a limited liability company organized and

existing under the laws of the State of New Jersey, having a principal place of business at 305
Clearview Avenue, Edison, New Jersey, 08837.
Jurisdiction and Venue
4.

This is an action for design patent infringement arising under the Patent Act, 35

U.S.C. 101 et seq. The Court has subject matter jurisdiction over this action pursuant to, inter
alia, 28 U.S.C. 1331 (federal question); and 28 U.S.C. 1338(a) (action arising under the
Patent Act).
5.

The Court has personal jurisdiction over Premier for one or more of the following

reasons:
A. The exercise of personal jurisdiction over Premier by this Court is consistent
with the Federal Due Process Clause, Premier having established minimum
contacts with this forum such that the exercise of jurisdiction over Premier
would not offend traditional notions of fair play and substantial justice;
B. Premier has done and continues to do business in the State of Illinois and with
one or more residents of the State of Illinois, including in this District;
C. Premier directs into the State of Illinois, including in this District, commerce,
goods and services, and advertising including by mail, electronic
communications, and other means;

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D. Premier has entered into contracts with one or more residents of the State of
Illinois to supply products or services within the State of Illinois, including in
this District;
E. Premier has offered, and continues to offer, products constituting patent
infringement relating to this complaint in the State of Illinois;
F. Premier has made substantial sales and shipments of infringing goods within
the State of Illinois, including this District; and
G. Premier maintains warranty services, such as those referenced at its website,
www.premieraccessorygroup.com, on infringing products within the State of
Illinois, including in this District;
6.

Venue is proper in this district pursuant to 28 U.S.C. 1391 because Premier has

transacted and continues to transact business within the District, has sold and continues to offer
for sale in this District products that constitute infringement, and has sold and continues to offer
for sale services and products within this District that constitute unfair and deceptive trade
practices which are a substantial part of the events giving rise to this action. In addition, venue is
proper because Custom Accessories principal place of business is in this District, and Custom
Accessories has suffered and is suffering harm in this District.
Background
7.

Custom Accessories is a world leader in the Automotive Aftermarket Accessory

marketplace. For more than forty years, Custom Accessories has provided its customers with a
wide variety of quality products and services. Custom Accessories develops and distributes its
products for various markets, such as interior car accessories, exterior car accessories, car
organization, battery care, sunshades, and many other car care categories.

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8.

On July 29, 2014, United States Design Patent No. D709,891 (the 891 patent)

was duly and legally issued by the United States Patent and Trademark Office. The 891 patent
has remained in force since that time and continues to be in force. On November 11, 2014,
United States Design Patent No. D717,305 (the 305 patent) was duly and legally issued by the
United States Patent and Trademark Office. The 305 patent has remained in force since that
time and continues to be in force.
9.

Custom Accessories Inc. is the sole owner of both the 891 and 305 patents with

all substantial rights in and to the 891 and 305 patents, including the right to bring this action
for any past or present infringement of the 891 and 305 patents, collect past and present
damages and obtain injunctions. Custom Accessories, Inc. is the named assignee on the face of
the 891 patent, having become owner of the 891 patent, and all continuations, including the
'305 patent, through an assignment from the inventors dated May 8, 2013, which was recorded at
the United States Patent and Trademark Office on May 10, 2013, at reel and frame number
030396/0247.
10.

Each of the891 and 305 patents covers ornamental designs for folding electrical

adapters. Custom Accessories has practiced and continues to practice the designs covered by the
891 and 305 patents in connection with the commercialization of its 12V Adjustable Dual USB
Charger products ("Custom Adapter"), as shown for example in the side-by-side comparisons
below:

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891 Patent

Custom Accessories 12V Adjustable Dual

USB Charger

305 Patent

11.

Custom Accessories has promoted, advertised, and used the folding USB adapter

designs of the 891 and 305 patents and the Custom Adapter product in a variety of media
throughout the United States, including but not limited to, product labeling and packaging,
brochures, point of purchase display materials, signage, trade magazine advertisements, trade
show displays and on the web to distinguish its products and services from those offered by
others.

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12.

Custom Accessories marks the packaging of the Custom Adapter with patent

notice information, as provided under 35 U.S.C. 287.

13.

The Custom Adapter products have been commercially successful with their

distinctive design, providing differentiation to other competitors adapter designs, and by being
associated with Custom Accessories as a distinctive and proprietary Custom Accessories adapter
design.
14.

As a result of Custom Accessories substantial promotional efforts, as well as the

high quality of the products associated with the adapter designs of the 891 and 305 patents and
the Custom Adapter line of products, such distinctive adapter design has earned valuable and
residual goodwill and reputation for Custom Accessories being the sole source for such goods in
the United States.
Premiers Infringement
15.

Premier began manufacturing and selling a Dual USB Car Charger with Swivel

Tip folding USB adapter ("Premier Adapter") in competition with Custom Accessories at least as
early as June of 2014. The Premier Adapter has been offered for sale at least in the following
locations in this district: AutoZone, 2743 Hartigan Road, Fox Lake, Illinois 60020; Advance
Auto Parts, 1770 N. Rand Road, Palatine, Illinois 60074.
16.

Premier copied the Premier Adapter design from the design of both the 891 and

305 patents and the Custom Adapter line of folding adapters.

17.

The design of the Premier Adapter is the same or substantially the same as the

folding USB adapter design of both the 891 and 305 patents and the Custom Adapter. The
folding USB adapter designs are so similar as to be nearly identical such that an ordinary
observer, giving such attention as a purchaser usually gives, would be so deceived by the
substantial similarity between the designs so as to be induced to purchase Premiers products
6

Case: 1:14-cv-09455 Document #: 1 Filed: 11/25/14 Page 7 of 12 PageID #:7

believing them to be substantially the same as the folding USB adapter designs protected by the
891 and 305 patents.
18.

In spite of the rights of Custom Accessories, Premier willfully and knowingly

infringed Custom Accessories rights, including as to the 891 and 305 patents.
19.

Custom Accessories has been damaged jointly and severally by the foregoing

infringing acts of Premier, including, without limitation, suffering actual damages.

20.

Premiers wrongful conduct and infringement activities will continue unless

enjoined by this Court.

Count I
(Infringement of United Stated Design Patent No. D709,891)
21.

Premier incorporates by reference the allegations contained in paragraphs 1-20

22.

Premier has infringed and continues to infringe the 891 patent by, inter alia,

above.

making, using, offering to sell, or selling in the United States, including in the State of Illinois
and within this District, products infringing the ornamental design covered by the 891 patent in
violation of 35 U.S.C. 271, including but not limited to the Premier Adapter product.
23.

Premier infringes the 891 patent because, inter alia, in the eye of an ordinary

observer, giving such attention as a purchaser usually gives, the adapter design of the 891 patent
and the adapter designs of Premiers products including without limitation the adapter designs of
the Premier Adapter products are substantially the same, the resemblance being such as to
deceive such an ordinary observer, inducing him to purchase one supposing it to the other.
Below is a side-by-side comparison of the claimed subject matter of the 891 patent and the
Premier Adapter:

Case: 1:14-cv-09455 Document #: 1 Filed: 11/25/14 Page 8 of 12 PageID #:8

891 Patent

24.

Premier Dual USB Car Charger with Swivel

Tip

Premiers acts of infringement of the 891 patent were undertaken without

authority, permission or license from Custom Accessories. Premiers infringing activities violate
35 U.S.C. 271.
25.

Premiers infringement has damaged and continues to damage and injure Custom

Accessories. The injury to Custom Accessories is irreparable and will continue unless and until
Premier is enjoined from further infringement.
26.

Custom Accessories is entitled to a complete accounting of all revenue and profits

derived by Premier, jointly and severally, from the unlawful conduct alleged herein, including
without limitation, Premiers total profit pursuant 35 U.S.C. 289.
27.

Premier has engaged and is engaged in willful and deliberate infringement of the

891 patent. Such willful and deliberate infringement justifies an increase of three times the
damages to be assessed pursuant to 35 U.S.C. 284 and further qualifies this action as an
exceptional case supporting an award of reasonable attorneys fees pursuant to 35 U.S.C. 285.

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28.

Custom Accessories is entitled to a permanent injunction preventing Premier from

further infringing the 891 patent.

Count II
(Infringement of United Stated Design Patent No. D707,305)
29.

Premier incorporates by reference the allegations contained in paragraphs 1-28

30.

Premier has infringed and continues to infringe the 305 patent by, inter alia,

above.

making, using, offering to sell, or selling in the United States, including in the State of Illinois
and within this District, products infringing the ornamental design covered by the 305 patent in
violation of 35 U.S.C. 271, including but not limited to the Premier Adapter product.
31.

Premier infringes the 305 patent because, inter alia, in the eye of an ordinary

observer, giving such attention as a purchaser usually gives, the adapter design of the 305 patent
and the adapter designs of Premiers products including without limitation the adapter designs of
the Premier Adapter products are substantially the same, the resemblance being such as to
deceive such an ordinary observer, inducing him to purchase one supposing it to the other.
Below is a side-by-side comparison of the claimed subject matter of the 305 patent and the Dual
USB Car Charger with Swivel Tip folding USB adapter sold by Premier:
305 Patent

Premier Dual USB Car Charger with Swivel

Tip

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32.

Premiers acts of infringement of the 305 patent were undertaken without

authority, permission or license from Custom Accessories. Premiers infringing activities violate
35 U.S.C. 271.
33.

Premiers infringement has damaged and continues to damage and injure Custom

Accessories. The injury to Custom Accessories is irreparable and will continue unless and until
Premier is enjoined from further infringement.
34.

Custom Accessories is entitled to a complete accounting of all revenue and profits

derived by Premier, jointly and severally, from the unlawful conduct alleged herein, including
without limitation, Premiers total profit pursuant 35 U.S.C. 289.
35.

Premier has engaged and is engaged in willful and deliberate infringement of the

305 patent. Such willful and deliberate infringement justifies an increase of three times the
damages to be assessed pursuant to 35 U.S.C. 284 and further qualifies this action as an
exceptional case supporting an award of reasonable attorneys fees pursuant to 35 U.S.C. 285.
36.

Custom Accessories is entitled to a permanent injunction preventing Premier from

further infringing the 305 patent.

Prayer for Relief
WHEREFORE, Plaintiff, Custom Accessories, prays for the following relief:
A.

A judgment entered in favor of Custom Accessories on its claim that Premier has

infringed the 891 patent;

B.

A judgment entered in favor of Custom Accessories on its claim that Premier has

infringed the 305 patent;

10

Case: 1:14-cv-09455 Document #: 1 Filed: 11/25/14 Page 11 of 12 PageID #:11

C.

A permanent injunction enjoining Premier, its respective officers, directors,

agents, and employees and all those in concert or participation with it who receive notice of
judgment by personal service or otherwise, from:
(1)

making, importing, using, selling, and offering to sell infringing products

practicing the 891 patent and from otherwise infringing, and actively inducing
infringement of the 891 patent; and
(2)

making, importing, using, selling, and offering to sell infringing products

practicing the 305 patent and from otherwise infringing, and actively inducing
infringement of the 305 patent;
D.

A judgment and order that Premier deliver to Custom Accessories for destruction

all product molds, products, sales literature, custom literature, and other trade pieces used in the
infringement of either the 891 patent or the 305 patent;
E.

A judgment and order that Premier make an accounting to Custom Accessories

and jointly and severally pay over to Custom Accessories:

(1)

the extent of Premiers total profit and revenue realized and derived from

its infringement of the 891 patent, and actual damages to Custom Accessories in an
amount not less than a reasonable royalty for Premiers infringement;
(2)

the extent of Premiers total profit and revenue realized and derived from

its infringement of the 305 patent, and actual damages to Custom Accessories in an
amount not less than a reasonable royalty for Premiers infringement; and
(3)

treble damages in accordance pursuant to 35 U.S.C. 284 for Premiers

willful and deliberate infringement, and as permitted under other applicable laws;

11

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F.

An award of costs of this action together with Custom Accessories reasonable

attorneys fees pursuant to 35 U.S.C. 285 for this case being exceptional, and as permitted
under other applicable laws;
G.

An award of interest, including prejudgment interest, on all damages; and

H.

An award to Custom Accessories of such further relief as the Court deems just

and proper.
Demand for Trial by Jury
Custom Accessories hereby demands a trial by jury as to all issues so triable.

Respectfully submitted,
Dated: November 25, 2014

Plaintiff Custom Accessories Inc.

By: _____/s/ Elias P. Soupos____

Gregory C. Bays
Elias P. Soupos
Jonathan B. Thielbar
LEYDIG, VOIT & MAYER, LTD.
Two Prudential Plaza, Suite 4900
180 North Stetson Avenue
Chicago, Illinois 60601
(312) 616-5600
(312) 616-5700 fax
ATTORNEYS FOR PLAINTIFF

12

Case: 1:14-cv-09455 Document #: 1-1 Filed: 11/25/14 Page 1 of 8 PageID #:13

USO0D709891S

(12) United States Design Patent (10) Patent No.:

Alesi et al.
(54)

FOLDING USB ADAPTER

~

(71)

(45) Date of Patent:

D556,730 S *
-

Applicant. CI}ISStOIIlACCSSOIlSIIlC.,R1011m011d,1L
(

1/2008

Siu ............... ..

.. D14/433

D573,578

7/2008

Turksu et al.

.. Dl4/155

D624,548 S *

Inventors: Vincent Anthony Alesi, Richmond, 1L

(US); Anthony Salvatore Ferenzi,
Richmond, IL (Us)

12/2007 Yokoyama ................. .. D14/155

D627,784 S

(72)

Jul. 29, 2014

D559,848 S

13599300 S *

US D709,891 S
*9:

..

9/2009 Klein et a1,

H Dl4/433

9/2010 Yamamoto
11/2010

.. D14/433

Yamamoto ..

.. D14/433

D678,286 S *

3/2013 Cheng

13680539 5
D682,835 s

4/2013 Kim ~~~~~~ ~~

.. Dl4/433
5/2013 Daniel ....................... .. D14/433

*
*

.. D14/433

* cited b examiner

(73) Assignee: Custom Accessories, Inc., Richmond, 1L

(M)
21

Term
A

(Us)
14 Years

pp

1. N .1 29/454 468
0

(22) Filed:
51

(57)
CLAIM
The ornamental design for a folding USB adapter, as shown

May 10, 2013

LOC 10 Cl.

and descnbed

.............................................. ..

E52; U 5 C(1 )

14-02

USPC ....................................................... .. D14/433

.

(58) 51$)ch ClaSSI?cang 22212122 434 453 454 511

""""""" "

FIG' 1 is a

ers ective View taken from the to a from, and

P

showing our new design;

FIG. 2 is a top view ofthe folding USB adapter of FIG. 1;

439//638 928 105 502 719/303/304

FIG. 3 is a bottom view ofthe folding USB adapter ofFlG. 1;

361 679'41 679'55

FIG. 4 is a right side view ofthe folding USB adapter ofFlG.

111406
.

see apphcanon ?le for complete searCh hlstory'

.

(56)

DESCRIPTION
right side of a folding Universal Serial Bus (USB) adapter

D14/203'8 209'1 2381 240 125f

y
Primary Examiner * Austin Murphy
(74) Attorney, Agent, or Firm * Leydig, Voit & Mayer, Ltd.

1;

FIG. 5 is a left side view of the folding USB adapter of FIG.

1;

References Clted

FIG. 6 is a rear elevational view of the folding USB adapter of

FIG. 1; and,

US. PATENT DOCUMENTS

D522,992 S

6/2006

Dayan ........................ .. Dl4/155

D523,413
D538,775
D541,254
D546,811

S
S
S
S

*
*
*
*

6/2006
3/2007
4/2007
7/2007

Dayan
Dayan
Dayan
Neu etal

D548,719 S

8/2007 Dayan

. Dl4/155

D550,197 S *

9/2007 Dayan

Dl4/155

Dl4/155
Dl4/155
Dl4/155
Dl4/155

FIG. 7 is a front elevational view of the folding USB adapter

of FIG. 1.

The broken lines are for purposes of illustrating portions of

the folding USB adapter that form no part of the claimed

design.
1 Claim, 7 Drawing Sheets

Case: 1:14-cv-09455 Document #: 1-1 Filed: 11/25/14 Page 2 of 8 PageID #:14

US. Patent

Jul. 29, 2014

Sheet 1 0f7

US D709,891 S

Case: 1:14-cv-09455 Document #: 1-1 Filed: 11/25/14 Page 3 of 8 PageID #:15

Case: 1:14-cv-09455 Document #: 1-1 Filed: 11/25/14 Page 4 of 8 PageID #:16

US. Patent

Jul. 29, 2014

Sheet 3 0f 7

/\_
q
_

US D709,891 S

Case: 1:14-cv-09455 Document #: 1-1 Filed: 11/25/14 Page 5 of 8 PageID #:17

US. Patent

Jul. 29, 2014

.1

Sheet 4 0f7

US D709,891 S

FIG.4

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US. Patent

Jul. 29, 2014

Sheet 5 0f7

US D709,891 S

FIG.5
r

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US. Patent

Jul. 29, 2014

Sheet 6 0f7

US D709,891 S

FIG.6

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US. Patent

Jul. 29, 2014

Sheet 7 0f7

US D709,891 S

FIG.7

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CIVIL #:
COVER
SHEET

JS 44 (Rev. 3/13)

The 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, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)

I. (a) PLAINTIFFS

DEFENDANTS

CUSTOM ACCESSORIES INC.

PREMIER ACCESSORY GROUP, LLC

(b) County of Residence of First Listed Plaintiff

County of Residence of First Listed Defendant

McHenry

(EXCEPT IN U.S. PLAINTIFF CASES)

(IN U.S. PLAINTIFF CASES ONLY)

IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.

NOTE:

(c) Attorneys (Firm Name, Address, and Telephone Number)

Attorneys (If Known)

Gregory C. Bays
Leydig, Voit & Mayer, Ltd., Two Prudential Plaza, Suite 4900, Chicago, IL 60601
312-616-5600

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)

U.S. Government
Defendant

4 Diversity
(Indicate Citizenship of Parties in Item III)

IV. NATURE OF SUIT

CONTRACT

110 Insurance
120 Marine
130 Miller Act
140 Negotiable Instrument
150 Recovery of Overpayment
& Enforcement of Judgment
151 Medicare Act
152 Recovery of Defaulted
Student Loans
(Excludes Veterans)
153 Recovery of
of Veterans Benefits
160 Stockholders Suits
190 Other Contract
195 Contract Product Liability
196 Franchise

REAL PROPERTY
210 Land Condemnation
220 Foreclosure
230 Rent Lease & Ejectment
240 Torts to Land
245 Tort Product Liability
290 All Other Real Property

(For Diversity Cases Only)

PTF
1

Citizen of This State

PERSONAL INJURY
310 Airplane
315 Airplane Product
Liability
320 Assault, Libel &
Slander
330 Federal Employers
Liability
340 Marine
345 Marine Product
Liability
350 Motor Vehicle
355 Motor Vehicle
Product Liability
360 Other Personal
Injury
362 Personal Injury Medical Malpractice
CIVIL RIGHTS
440 Other Civil Rights
441 Voting
442 Employment
443 Housing/
Accommodations
445 Amer. w/Disabilities
Employment
446 Amer. w/Disabilities
Other
448 Education

2 Removed from
State Court

PRISONER PETITIONS
510 Motions to Vacate
Sentence
Habeas Corpus:
530 General
535 Death Penalty
540 Mandamus & Other
550 Civil Rights
555 Prison Condition
560 Civil Detainee Conditions of
Confinement

Remanded from
Appellate Court

VI. CAUSE OF ACTION (Enter U.S. Civil Statute under which you are filing and
write a brief statement of cause.)

35 U.S.C. s. 271 -- Patent Infringement

VIII. REQUESTED IN CHECK IF THIS IS A CLASS ACTION
UNDER RULE 23, F.R.Cv.P.
COMPLAINT:
IX. RELATED CASE(S)
(See instructions):
IF ANY
JUDGE
X. This case (check one box) Is not a refiling of a previously dismissed action
DATE

November 25, 2014

and One Box for Defendant)

PTF
DEF
4
4

Incorporated or Principal Place

of Business In This State

Incorporated and Principal Place

of Business In Another State

Citizen or Subject of a
Foreign Country

Foreign Nation

FORFEITURE/PENALTY

PERSONAL INJURY
365 Personal Injury Product Liability
367 Health Care/
Pharmaceutical
Personal Injury
Product Liability
368 Asbestos Personal
Injury Product
Liability
PERSONAL PROPERTY
370 Other Fraud
371 Truth in Lending
380 Other Personal
Property Damage
385 Property Damage
Product Liability

DEF
1

Citizen of Another State

(Place an X in One Box Only)

TORTS

V. ORIGIN (Place an X in One Box Only)

1 Original
Proceeding

III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an X in One Box for Plaintiff

625 Drug Related Seizure

of Property 21 USC 881
690 Other

BANKRUPTCY
422 Appeal 28 USC 158
423 Withdrawal
28 USC 157
PROPERTY RIGHTS
820 Copyrights
830 Patent
840 Trademark

LABOR
710 Fair Labor Standards
Act
720 Labor/Management
Relations
740 Railway Labor Act
751 Family and Medical
Leave Act
790 Other Labor Litigation
791 Employee Retirement
Income Security Act

SOCIAL SECURITY
861 HIA (1395ff)
862 Black Lung (923)
863 DIWC/DIWW (405(g))
864 SSID Title XVI
865 RSI (405(g))

FEDERAL TAX SUITS

870 Taxes (U.S. Plaintiff
or Defendant)
871 IRSThird Party
26 USC 7609

OTHER STATUTES

375 False Claims Act

400 State Reapportionment
410 Antitrust
430 Banks and Banking
450 Commerce
460 Deportation
470 Racketeer Influenced and
Corrupt Organizations
480 Consumer Credit
490 Cable/Sat TV
850 Securities/Commodities/
Exchange
890 Other Statutory Actions
891 Agricultural Acts
893 Environmental Matters
895 Freedom of Information
Act
896 Arbitration
899 Administrative Procedure
Act/Review or Appeal of
Agency Decision
950 Constitutionality of
State Statutes

IMMIGRATION
462 Naturalization Application
463 Habeas Corpus Alien Detainee
(Prisoner Petition)
465 Other Immigration
Actions
Reinstated or
Reopened

Transferred from
Another District
(specify)

Multidistrict
Litigation

VII. Previous Bankruptcy Matters (For nature of suit 422 and 423, enter the case

number and judge for any associated bankruptcy matter previously adjudicated by a judge of this Court.
Use a separate attachment if necessary.

DEMAND $

CHECK YES only if demanded in complaint:

Yes
No
JURY DEMAND:
DOCKET NUMBER

is a refiling of case number ____________ previously dismissed by Judge ________________

SIGNATURE OF ATTORNEY OF RECORD

/s/ Elias P. Soupos