IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF KENTUCKY LOUISVILLE DIVISION

LANTECH.COM, LLC 11000 Bluegrass Parkway Louisville, KY 40299 Plaintiff v. UNISOURCE WORLDWIDE, INC. 6600 Governors Lake Parkway Norcross, GA 30071 Serve Registered Agent: CT Corporation System 306 W. Main Street, Suite 512 Frankfort, KY 40601 Defendant

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CIVIL ACTION NO. _________________

3:11CV-432-S

COMPLAINT WITH JURY DEMAND

Plaintiff LANTECH.COM, LLC complains against defendant Unisource, as follows: NATURE OF THE ACTION 1. This is an action for patent infringement and arises under the patent laws of the

United States, Title 35. THE PARTIES 2. Plaintiff LANTECH.COM, LLC (Lantech) is a Kentucky limited liability

company having its principal place of business at 11000 Bluegrass Parkway, Louisville, Kentucky.

3.

Upon information and belief, defendant Unisource Worldwide, Inc. (Unisource)

is a Delaware corporation having its principal place of business at 6600 Governors Lake Parkway, Norcross, Georgia 30071. JURISDICTION AND VENUE 4. The Court has subject matter jurisdiction over this patent infringement action

pursuant to 28 U.S.C. 1331 and 1338(a). The Court has personal jurisdiction over Unisource by virtue of its substantial and continuous contacts with this judicial district, including its sale, offer for sale, and/or distribution in this judicial district of the infringing products which are subject of this patent infringement action. 5. Venue in this Court is based upon 28 U.S.C. 1391 and 1400(b). CAUSE OF ACTION FOR PATENT INFRIGNEMENT 6. 7. This is a cause of action for patent infringement under 35 U.S.C. 271. Lantech is the sole owner of United States Patent No. RE 37,237 (the 237

patent), which was duly and legally issued on June 26, 2001, and is entitled Stretch Wrapping With Film Severing. A copy of the 237 patent is attached as Exhibit A. 8. Lantech manufactures, sells, and offers for sale stretch wrapping equipment that is

covered by the 237 patent. 9. Upon information and belief, Unisource has manufactured and/or had

manufactured for it, sold, offered for sale, used, and/or imported stretch wrapping equipment, such as the Unisource Private Brand Stretch Wrapper. 10. Unisources stretch wrapping equipment, such as the Unisource Private Brand

Stretch Wrapper, infringes the 237 patent. By virtue of Unisources manufacture, sale, offer for 2

sale, use, or importation of them, Unisource is infringing the 237 patent and will continue such infringing acts unless enjoined by this Court. 11. Unisources manufacture, sale, offer for sale, use, and/or importation of,

infringing stretch wrapping equipment, such as the Unisource Private Brand Stretch Wrapper, has resulted in damage to Lantech. Such damage will continue so long as Unisource

manufactures, sells, offers for sale, uses, and/or imports infringing stretch wrapping equipment, such as the Unisource Private Brand Stretch Wrapper. 12. to be willful. WHEREFORE, Plaintiff LANTECH.COM, LLC prays for relief against Unisource as follows: A. That judgment be entered that Unisource has been and is infringing U.S. Patent Upon information and belief, Unisources infringing acts have been and continue

No. RE 37,237and that the infringement be found willful; B. That Unisource, their agents, sales representatives, servants and employees,

associates, attorneys, successors and assigns, and any and all persons or entities acting by, through, under or in active concert or in participation with any or all of them, be enjoined and restrained preliminarily during the pendency of this action, and thereafter permanently, from further acts of infringement of U.S. Patent No. RE 37,237; C. That a judgment be entered that Unisource be required to pay over to Lantech all

damages sustained by it due to such patent infringement and that such damages be trebled pursuant to 35 U.S.C. 284 for the willful acts of infringement complained of herein;

D.

That this case be adjudged and decreed exceptional under 35 U.S.C. 285

entitling Lantech to an award of their reasonable attorney fees and that such reasonable attorney fees be awarded; E. F. That Lantech be awarded its costs and prejudgment interest on all damages; That Unisource be required to file with the Court within thirty (30) days after

entry of the final judgment of this case a written statement under oath setting forth in detail the manner in which they have complied with the judgment; and G. proper. JURY DEMAND Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Plaintiff Lantech demands a trial by jury. Respectfully submitted, Dated: August 3, 2011 /s/ John S. Reed John S. Reed Michael W. Oyler REED WEITKAMP SCHELL & VICE PLLC 500 W. Jefferson Street, Suite 2400 Louisville, KY 40202 Facsimile: (502) 562-1100 Telephone: (502) 589-1000 E-mail: jreed@rwsvlaw.com moyler@rwsvlaw.com Counsel for Plaintiff LANTECH.COM, LLC That Lantech be awarded such other and further relief as the Court deems just and