Friend v Keystone Pretzels - Complaint

7/27/2019 Friend v Keystone Pretzels - Complaint

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IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF PENNSYLVANIA

LESLIE FRIEND,

Plaintiff,

v.

KEYSTONE PRETZELS and LAUREL

HILL FOODS, INC.,

Defendants.

)

)

))

)

))

)

))

Civil Action

Electronically Filed

JURY TRIAL DEMANDED

COMPLAINT AND DEMAND FOR JURY TRIAL

Plaintiff Leslie Friend (hereinafter, Ms. Friend), by and through her undersigned

counsel, hereby alleges the following against Defendants Laurel Hill Foods, Inc. and Keystone

Pretzels (hereinafter, Laurel Hill and Keystone):

THE PARTIES

1. Ms. Friend, an individual, is a citizen of the United States residing in Pittsburgh,PA.

2. Upon information and belief, Laurel Hill is a Massachusetts corporation having itsprincipal place of business located at 71 Hampden Road, Suite 100, Mansfield, MA 02048.

3. Upon information and belief, Keystone is a Pennsylvania business with itsprincipal place of business located at 124 West Airport Road, Lititz, PA 17543.

JURISDICTION AND VENUE

4. Ms. Friend brings this action under the Patent Laws of the United States, Title 35of the United States Code. This Court has jurisdiction pursuant to 28 U.S.C. 1331 and 1338.

Case 2:13-cv-01028-DSC Document 1 Filed 07/17/13 Page 1 of 5


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5. Ms. Friend is the owner of all right, title, and interest in United States Patent No.D423,184 (the 184 Patent). A true and correct copy of the 184 Patent is attached hereto as

Exhibit A.

6. Upon information and belief, Keystone regularly conducts business in this district,at least by its website, http://www.keystonepretzels.com/order-our-pretzels/, which is accessible

over the Internet all over the United States, including in this judicial district, and does not purport

to preclude potential customers within this judicial district from obtaining its products or

services.

7.

Laurel Hill advertises its Pretzel Chips products via its website at

http://laurelhillfoods.com/pretzel-chips/, which is accessible over the Internet all over the United

States, including in this judicial district, and does not purport to preclude potential customers

within this judicial district from obtaining any Laurel Hill products or services.

8. Laurel Hill, at its website, http://laurelhillfoods.com/buy-our-chips/#, directsconsumers to an Amazon.com website from which the Pretzel Chips products may be purchased.

The Amazon.com website is accessible over the Internet all over the United States, including in

this judicial district, and does not purport to preclude potential customers within this judicial

district from obtaining any Laurel Hill products or services.

9. Laurel Hill, at http://laurelhillfoods.com/buy-our-chips/#, informs consumers of aselection of retail establishments selling Laurel Hill products. Of the selected retail

establishments listed at http://laurelhillfoods.com/buy-our-chips/#, at least Whole Foods Market

regularly conducts business in this judicial district.

10. Upon information and belief, the Pretzel Chips products have been offered forsale and/or sold in this district.



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11. Venue is proper pursuant to 28 U.S.C. 1391 and 1400.SUMMARY OF THE FACTS

12. The 184 Patent claims an ornamental design for a pretzel resembling a peacesymbol.

13. Upon information and belief, Keystone makes, sells, and offers to sell pretzelproducts. Upon information and belief, Keystone makes and sells to Laurel Hill the Pretzel

Chips for Laurel Hill to, in turn, sell and offer for sale.

14. The shape of Laurel Hills Pretzel Chips resembles a peace symbol. True andcorrect copies of pages from Laurel Hills website showing Laurel Hills Pretzel Chips are

attached hereto as Exhibit B.

15. Upon information and belief, Keystone continues to make, offer for sale, and sellPretzel Chips to Laurel Hill, and Laurel Hill continues to sell and offer for sale its Pretzel Chips.

COUNT I:

INFRINGEMENT OF THE 184 PATENT

16. Ms. Friend repeats and re-alleges each an every averment contained in paragraphs1-15 hereof as if fully set forth herein.

17. Keystone has infringed the 184 Patent at least by making, selling, and offering tosell, and by inducing, aiding, and abetting, actively inducing, and encouraging and contributing

to others sales and offers to sell at least the following pretzel products: (1) Everything Laurel

Hill Pretzel Chips, (2) Sea Salt Laurel Hill Pretzel Chips, and (3) Honey Multigrain Laurel Hill

Pretzel Chips. Keystone received notice of the 184 Patent at least as early as April 11, 2013.

18. Laurel Hill has infringed the 184 Patent at least by selling and offering to sell,and by inducing, aiding, and abetting, actively inducing, and encouraging and contributing to

others sales, offers to sell, and use of at least the following pretzel products: (1) Everything



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Laurel Hill Pretzel Chips, (2) Sea Salt Laurel Hill Pretzel Chips, and (3) Honey Multigrain

Laurel Hill Pretzel Chips. Laurel Hill received notice of the 184 Patent at least as early as April

10, 2013.

19. Keystones and Laurel Hills infringement has injured Ms. Friend, and Ms. Friendis entitled to recover damages adequate to compensate for the infringement that has occurred.

Ms. Friend is entitled to recover at least a reasonable royalty pursuant to 35 U.S.C. 284.

Additionally and alternatively, Ms. Friend is entitled to recover Keystone and Laurel Hills total

profit attributable to the infringing pretzel products pursuant to 35 U.S.C. 289.

20.

Upon information and belief, Keystone and Laurel Hill have been infringing the

184 Patent since at least the 2011 time frame. Keystone and Laurel Hill have infringed the 184

Patent with knowledge of the patent and without legal justification or excuse at least since April

11, 2013 and April 10, 2013, respectively. Keystone and Laurel Hills infringement from these

times forward has been and is willful.

21. Ms. Friend has been injured and is being injured by Keystone and Laurel Hillsinfringement of the 184 Patent, and Ms. Friend will continue to suffer irreparable harm unless

Keystone and Laurel Hills infringement of the 184 Patent is enjoined by this Court.

WHEREFORE, Ms. Friend respectfully requests judgment be entered against Keystone

and Laurel Hill as follows:

A. An award of damages adequate to compensate Ms. Friend for the infringement, inthe form of at least a reasonable royalty, and/or Keystone and Laurel Hills total profit together

with prejudgment interest from the date the infringement began;

B. Any damages permitted in the Courts equitable discretion, including increaseddamages for willful infringement under 35 U.S.C. 284;



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C. A finding that this case is exceptional and an award to Ms. Friend of herattorneys fees and expenses as provided by 35 U.S.C. 285;

D. An injunction permanently enjoining Keystone and Laurel Hill, and all persons inactive concert or participation with Keystone and Laurel Hill, from further acts of infringement

of the 184 Patent; and

E. Such other and further relief as this court deems proper.DEMAND FOR JURY TRIAL

Pursuant to Rule 38 of the Federal Rules of Civil Procedure, ms. Friend hereby demands

a trial by jury of all issues triable by jury.

Respectfully submitted,

Dated: July 17, 2013 s/Russell D. Orkin

Russell D. Orkin (PA ID No. 01331)

[email protected] H. Brean (PA ID No. 208711)

[email protected]

THE WEBB LAW FIRMOne Gateway Center

420 Fort Duquesne Blvd., Suite 1200Pittsburgh, PA 15222

412.471.8815

412.471.4094 (fax)

Counsel for Plaintiff Leslie Friend



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7/18

JS 44AREVISED June, 2009

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA

THIS CASE DESIGNATION SHEET MUST BE COMPLETED

PART A

This case belongs on the ( Erie Johnstown Pittsburgh) calendar.

1. ERIE CALENDAR- If cause of action arose in the counties of Crawford, Elk, Erie,Forest, McKean. Venang or Warren, OR any plaintiff or defendant resides in one of said

counties.2. JOHNSTOWN CALENDAR- If cause of action arose in the counties of Bedford, Blair,

Cambria, Clearfield or Somerset OR any plaintiff or defendant resides in one of

said counties.

3. Complete if on ERIE CALENDAR: I certify that the cause of action arose in

County and that the resides in County.

4. Complete if on JOHNSTOWN CALENDAR: I certify that the cause of action arose in

County and that the resides in County.

PART B (You are to check ONE of the following)

1. This case is related to Number . Short Caption .2. This case is not related to a pending or terminated case.

DEFINlTIONS OF RELATED CASES:

CIVIL: Civil cases are deemed related when a case filed relates to property included in

another suit or involves the same issues of fact or it grows out of the same transactions

as another suit or involves the validity or infringement of a patent involved in another

suit EMINENT DOMAIN: Cases in contiguous closely located groups and in common ownership

groups which will lend themselves to consolidation for trial shall be deemed related.

HABEAS CORPUS & CIVIL RIGHTS: All habeas corpus petitions filed by the same individual

shall be deemed related. All pro se Civil Rights actions by the same individual shall be

deemed related.

PARTC

I. CIVIL CATEGORY (Place x in only applicable category).

1. Antitrust and Securities Act Cases

2. Labor-Management Relations

3. Habeas corpus4. Civil Rights

5. Patent, Copyright, and Trademark

6. Eminent Domain

7. All other federal question cases

8. All personal and property damage tort cases, including maritime, FELA,

Jones Act, Motor vehicle, products liability, assault, defamation, malicious

prosecution, and false arrest

9. Insurance indemnity, contract and other diversity cases.

10. Government Collection Cases (shall include HEW Student Loans (Education),

V A 0verpayment, Overpayment of Social Security, Enlistment

Overpayment (Army, Navy, etc.), HUD Loans, GAO Loans (Misc. Types),

Mortgage Foreclosures, SBA Loans, Civil Penalties and Coal Mine

Penalty and Reclamation Fees.)

I certify that to the best of my knowledge the entries on this Case Designation

Sheet are true and correct

Date:

ATTORNEY AT LAW

NOTE: ALL SECTIONS OF BOTH FORMS MUST BE COMPLETED BEFORE CASE CAN BE PROCESSED.

07/17/2013

s/Russell D. Orkin

Case 2:13-cv-01028-DSC Document 1-1 Filed 07/17/13 Page 2 of 2


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Exhibit A



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Exhibit B



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VIEW NUTRITIONAL INFO

EVERYTHINGBursting with savory sesame, garlic, poppy seed and onionthis pretzel is fully

loaded with flavor. Mouthwatering crunch, thinly baked and downright

delicious!

INGREDIENTS

Wheat Flour, Malt Extract, Sea

Salt, Canola Oil, Sesame

Seeds, Dehydrated Onion,

Dehydrated Garlic, Poppy Seed,

Vegetable Fiber, Yeast, Soda.

Produced in a facility that also

handles soy products, nut free.

EVERYTHING HONEY MULTIGRAIN SEA SALT

CONNECT WITH US BUY OUR CHIPS SELL OUR CHIPS CONTACT SIGN UP

PRETZEL CHIPS TORTILLA CHIPS POTATO CHIPS THE BUZZ OUR OTHER PRODUCTS ABOUT US

Page 1 of 1Everything | Laurel Hill

6/28/2013http://laurelhillfoods.com/chips/pretzel-chips/everything/



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HONEY MULTIGRAINWe have added a touch of honey to our multigrain recipe to make this pretzel

chip a taste sensation. Mouthwatering crunch, thinly baked and downright

delicious!

INGREDIENTS

Wheat Flour, Multigrain Flour

(Oat Flour, Rye Flour, Ground

Whole Wheat), Honey, Malt,

Sea Salt, Canola Oil, Vegetable

Fiber, Yeast, Soda.






Page 1 of 1Honey Multigrain | Laurel Hill

6/28/2013http://laurelhillfoods.com/chips/pretzel-chips/honey-multigrain/



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SEA SALTWe have added a touch of salt to our pretzel recipe voila A (soon to be)

classic Mouthwatering crunch, thinly baked and downright delicious!

INGREDIENTS

Wheat Flour, Malt Extract, Seas

Salt, Canola Oil, Vegetable

Fiber, Yeast, Soda.






Page 1 of 1Sea Salt | Laurel Hill

6/28/2013http://laurelhillfoods.com/chips/pretzel-chips/sea-salt-2/



15/18

AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURTfor the

__________ District of __________

)

)))))))))))

Plaintiff(s)

v. Civil Action No.

Defendant(s)

SUMMONS IN A CIVIL ACTION

To: (Defendants name and address)

A lawsuit has been filed against you.

Within 21 days after service of this summons on you (not counting the day you received it) or 60 days if you

are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.P. 12 (a)(2) or (3) you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 ofthe Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiffs attorney,whose name and address are:

If you fail to respond, 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 OF COURT

Date:Signature of Clerk or Deputy Clerk


Western District of Pennsylvania

LESLIE FRIEND

KEYSTONE PRETZELS and LAUREL HILL FOODS,

INC.

Keystone Pretzels124 West Airport RoadLititz, PA 17543

Russell D. OrkinThe Webb Law FirmOne Gateway Center420 Fort Duquesne Blvd., Suite 1200Pittsburgh, PA 15222


16/18

AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)

Civil Action No.

PROOF OF SERVICE

(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))

This summons for(name of individual and title, if any)

was received by me on(date) .

I personally served the summons on the individual at (place)

on (date) ; or

I left the summons at the individuals residence or usual place of abode with (name)

, a person of suitable age and discretion who resides there,

on (date) , and mailed a copy to the individuals last known address; or

I served the summons on (name of individual) , who is

designated by law to accept service of process on behalf of(name of organization)

on (date) ; or

I returned the summons unexecuted because ; or

Other(specify):

.

My fees are $ for travel and $ for services, for a total of $ .

I declare under penalty of perjury that this information is true.

Date:Servers signature

Printed name and title

Servers address

Additional information regarding attempted service, etc:


0.00

Print Save As... Reset


17/18

AO 440 (Rev. 06/12) Summons in a Civil Action

UNITED STATES DISTRICT COURTfor the

__________ District of __________

)

)))))))))))

Plaintiff(s)

v. Civil Action No.

Defendant(s)

SUMMONS IN A CIVIL ACTION

To: (Defendants name and address)

A lawsuit has been filed against you.

Within 21 days after service of this summons on you (not counting the day you received it) or 60 days if you

are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.P. 12 (a)(2) or (3) you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 ofthe Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiffs attorney,whose name and address are:

If you fail to respond, 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 OF COURT

Date:Signature of Clerk or Deputy Clerk


Western District of Pennsylvania

LESLIE FRIEND

KEYSTONE PRETZELS and LAUREL HILL FOODS,

INC.

Laurel Hill Foods, Inc.71 Hampden Road, Suite 100Mansfield, MA 02048

Russell D. OrkinThe Webb Law FirmOne Gateway Center420 Fort Duquesne Blvd., Suite 1200Pittsburgh, PA 15222


18/18

AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)

Civil Action No.

PROOF OF SERVICE

(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))

This summons for(name of individual and title, if any)

was received by me on(date) .

I personally served the summons on the individual at (place)

on (date) ; or

I left the summons at the individuals residence or usual place of abode with (name)

, a person of suitable age and discretion who resides there,

on (date) , and mailed a copy to the individuals last known address; or

I served the summons on (name of individual) , who is

designated by law to accept service of process on behalf of(name of organization)

on (date) ; or

I returned the summons unexecuted because ; or

Other(specify):

.

My fees are $ for travel and $ for services, for a total of $ .

I declare under penalty of perjury that this information is true.

Date:Servers signature

Printed name and title

Servers address

Additional information regarding attempted service, etc:


0.00

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Friend v Keystone Pretzels - Complaint

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