ME1 17621292v.

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UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT

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ORTRONICS, INC.

Plaintiff,


v.

THE SIEMON COMPANY,

Defendant.
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CIVIL ACTION NO. 3:14-CV-595






MAY 2, 2014

COMPLAINT

Plaintiff Ortronics, Inc. for its Complaint against Defendant The Siemon
Company, hereby alleges, through its attorneys McCarter & English, LLP, as follows:
PARTIES
1. Plaintiff Ortronics, Inc. (Ortronics) is a corporation organized and existing
under the laws of the State of Connecticut, with its principal place of business located at 125
Eugene ONeill Drive, New London, CT 06320.
2. Upon information and belief, Defendant The Siemon Company (Siemon) is a
corporation organized and existing under the laws of the State of Connecticut, with its principal
place of business located at 101 Siemon Company Drive, Watertown, CT 06795.
JURISDICTION AND VENUE
3. This case involves patent infringement and arises under the Patent Laws of the
United States, Title 35, United States Code. This Court has jurisdiction under at least 28 U.S.C.


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1331 (federal question) and 1338 (patent actions).
4. Venue is proper under 28 U.S.C. 1391(b) and (c) and 1400(b). Siemon is
subject to the personal jurisdiction of this Court with respect to this civil action.
INFRINGED PATENTS
5. U.S. Patent No. 8,526,181 (the 181 Patent), entitled Cable Management
System Including Airflow Functionality, issued on September 3, 2013, to Stewart A. Levesque
and Lars R. Larsen. Ortronics is the owner of the 181 Patent. A copy of the 181 Patent is
attached as Exhibit A.
6. The 181 Patent has not expired and is in full force and effect.
7. Pursuant to 35 U.S.C. 282, the 181 Patent and each of its claims are presumed
valid.
8. U.S. Patent No. 8,130,494 (the 494 Patent), entitled Equipment Rack and
Associated Ventilation System, issued on March 6, 2012, to Lars R. Larsen and Stewart A.
Levesque. Ortronics is the owner of the 494 Patent. A copy of the 494 Patent is attached as
Exhibit B.
9. The 494 Patent has not expired and is in full force and effect.
10. Pursuant to 35 U.S.C. 282, the 494 Patent and each of its claims are presumed
valid.
SIEMONS INFRINGEMENT
11. Siemon makes, uses, sells, offers for sale and/or imports within or into the United
States baffled cabinet systems that are covered by one or more claims of the 181 Patent and by
one or more claims of the 494 Patent. The infringing products include, but are not limited to,


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Siemons VERSAPOD cabinets equipped with side baffles.
FIRST COUNT
(Infringement of the 181 Patent)
1-11. Ortronics re-alleges and incorporates by reference paragraphs 1-11 above.
12. In violation of 35 U.S.C. 271, Siemon has been and still is infringing the 181
Patent by making, using, selling, offering to sell and/or importing within or into the United States
the VERSAPOD cabinets equipped with side baffles (the Infringing Product).
13. Ortronics has been and continues to be damaged and irreparably harmed by
infringement of the 181 Patent by Siemon.
SECOND COUNT
(Infringement of the 494 Patent)
1-11. Ortronics re-alleges and incorporates by reference paragraphs 1-11 above.
12. In violation of 35 U.S.C. 271, Siemon has been and still is infringing the 494
Patent by making, using, selling, offering to sell and/or importing within or into the United States
the Infringing Product.
13. Ortronics has been and continues to be damaged and irreparably harmed by
infringement of the 494 Patent by Siemon.

PRAYER FOR RELIEF
Wherefore, Ortronics demands judgment in its favor and against Siemon as follows:
1. A judgment under 35 U.S.C. 271 that Siemon infringes the 181 Patent and the
494 Patent;
2. An order under 35 U.S.C. 283 preliminarily and permanently enjoining Siemon


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ME1 17621292v.1
and its officers, agents, subsidiaries, successors, employees, representatives, and assigns from
infringing the 181 Patent and the 494 Patent;
3. An award of damages under 35 U.S.C. 284 adequate to compensate Ortronics
for infringement of the 181 Patent and the 494 Patent by Siemon and an accounting to
determine the proper amount of such damages;
4. An award under 35 U.S.C. 284 of costs and prejudgment and post judgment
interest on the compensatory damages to be awarded to Ortronics;
5. An award under 35 U.S.C. 285 of Ortronicss attorneys fees incurred in this
action; and
6. Such further relief as this Court deems just and proper.
JURY TRIAL DEMANDED


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ME1 17621292v.1
ATTORNEYS FOR PLAINTIFF
ORTRONICS INC.


By: /s/ Eric E. Grondahl
Eric E. Grondahl (CT08988)
MCCARTER & ENGLISH LLP
CityPlace I
185 Asylum Street
Hartford, CT 06103
Tel.: 860-275-6700
Fax: 860-724-3397
E-mail: egrondahl@mccarter.com