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Inventor Robert Randall Kelly
P.O. Box 678 Merlin, Oregon 97532
Phone: 805 340 8302
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U.S. District Court for Oregon
Medford Division
310 West Sixth Street, Room201, Medford OR 97501
Clerk: 541-776-3926
Robert Randall Kelly,
Plaintiff
v
Joseph Wortsmith dba Laser Tools Company,
Laser Tools Company, Inc. a/k/a LTCI
Robert Sean Kelly,
Patrick R. Kelly,
Estate of Robert Royce Kelly,
Ryobi Technologies Incorporated, a Delaware Corporation a/k/a RTI,
Ryobi America Corporation,
One World Technologies, Inc.
Techtronic Industries Co. Ltd. a/k/a TTI,
Attorney Robert Bugos,
Attorney Brandenberg,
Jeff Dils,
and unnamed defendants,
Defendants
Case Number: CV 05- ____________
Document #6420 Version 0.73
COMPLAINT for Patent Infringement, RICO, and common fraud.
JURY DEMANDED
Complaint for Money Damages, Declaratory and Injunctive Relief for Infringement for conversion, fraud, common counts, embezzlement, identify theft, conspiracy, and infringement on my patent #5,862,727.
Complaint for Money Damages for false marking.
Demand for an accounting.
Petition for imposition of constructive trust.
List of Exhibits.
Proposed Orders.
Contents of this complaint:
Plain Statement of Facts pursuant to Rule 8:
Brief List of the main players
Re: Sears. They are not a defendant. They are nonetheless part of the story.
Ryobi. See further below for their causes of action
Cause of Action against Ryobi: Interference in potential advantage. I could have sold to Sears.
Robert Sean Kelly and his brother Patrick Kelly. See further below for their causes of action
Techtronic Industries - parent of Ryobi
One World Technologies - Ryobi affiliate: fraud on me and the patent office
History of my patent pertinent to all causes of action
The video that I made and Joe Wortsmith misappropriated to perpetrate his poseur scheme
The head start by Sears ruined my chance to license Skil/ Bosch.
Discussion with Sears led me to Ryobi - who had rejected my offer 6 years earlier
Ryobi having paid the poseur in May 2001 was now caught red-handed.
Robert Sean Kelly - the poseur/ accomplice.
1st cause of Action: Infringement by Ryobi
Unfair Competition defined by Section 337 of Tariff act of 1930
Cause of action: Patent Infringement
Induced and contributory patent infringement
Appendix #1: Supplemental List of Parties who were players not amounting to defendants.
List of statutes cited in this complaint:
1. This court has jurisdiction pursuant to 28 USC 1338 which reads in pertinent part:
Section 1338. Patents . . . and unfair competition: (a) The district courts shall have original jurisdiction of any civil action arising under any Act of Congress relating to patents . . . .. Such jurisdiction shall be exclusive of the courts of the states in patent . . . cases. (b) The district courts shall have original jurisdiction of any civil action asserting a claim of unfair competition when joined with a substantial and related claim under the . . . patent . . . or trademark laws.
2. This court has pendant jurisdiction in other claims.
3. Venue is proper here in Medford, Oregon, pursuant to 28 USC 1391. 28 USC 1391 in pertinent part reads as follows:
28 USC 1391. Venue generally (a) [Irrelevant: Pertains to diversity only.] (b) A civil action wherein jurisdiction is not founded solely on diversity of citizenship may, except as otherwise provided by law, be brought only in (1) a judicial district where any defendant resides, if all defendants reside in the same State, (2) a judicial district in which a substantial part of the events or omissions giving rise to the claim occurred, or a substantial part of property that is the subject of the action is situated, or (3) a judicial district in which any defendant may be found, if there is no district in which the action may otherwise be brought. (c) For purposes of venue under this chapter, a defendant that is a corporation shall be deemed to reside in any judicial district in which it is subject to personal jurisdiction at the time the action is commenced. In a State which has more than one judicial district and in which a defendant that is a corporation is subject to personal jurisdiction at the time an action is commenced, such corporation shall be deemed to reside in any district in that State within which its contacts would be sufficient to subject it to personal jurisdiction if that district were a separate State, and, if there is no such district, the corporation shall be deemed to reside in the district within which it has the most significant contacts. (d) An alien may be sued in any district. (e)(Irrelevant: Defendant officer of U.S.) (f) (Irrelevant: Action against foreign state.)
4. Venue is proper in Medford, Oregon, under 28 USC 1391 because it is. . .” (2) a judicial district in which a substantial part of the events or omissions giving rise to the claim occurred” in that identity theft, fraud, and embezzlement happened in this judicial district.
5. Venue is proper here under 28 USC 1(b) which reads in pertinent part as follows:
Section 1400. Patents and copyrights, mask works, and designs 1 . . .(b) Any civil action for patent infringement may be brought in the judicial district where the defendant resides, or where the defendant has committed acts of infringement and has a regular and established place of business
6. Some of the actions of the defendant happened in Grant’s Pass, Oregon, which is located within the geographical boundaries of this Medford division of this court.
Notice of Upcoming Motions
7. We will be asking for bifurcation on the issue of the first manufacturing run of Ryobi.
8. We will seek a court order demanding immediate payment of $810,000 by Ryobi as compensation for infringement of the first 135,000 units.
9. These 135,000 units have already been sold.
10. In the interim I have sold Laser Arbors in this quantity for $2 each.
11. Triple damages for 135,000 units at $2 each = $810,000.
12. Ryobi practiced unfair business practices by refusing to license my invention.
13. They would only buy the entire patent thus depriving me of my rightful monopoly.
14. They had already sold infringing devices when I discovered the infringement.
15. Had they done the right thing upon discovery of Wortsmith’s fraud we would not be in court.
16. We will seek an Order to Show Cause why Ryobi should be ordered to immediately disgorge itself of the $270,000 rightful license fee built into their price to Sears for the first 135,000 units - reserving the issue of triple damages for later.
17. Plain Statement of Facts pursuant to Rule 8:
Plaintiff/ Inventor Robert Randall Kelly
18. I, Robert Randall Kelly am the Robert R. Kelly who invented and owns patent #5,862,727.
19. I own one other patent.
20. I have received two other patents for a total of 4, to wit:
21. I received a 3rd patent which I assigned to my then-employer.
22. I received a 4th patent as a team of 4 inventors.
23. In this case Defendant Robert Sean Kelly accepted money from Ryobi under false pretenses.
24. I am not related to Robert Sean Kelly.
25. I had never heard of Robert Sean Kelly until I began investigating this case of patent infringement.
26. Robert Sean Kelly fraudulently posed as the son of an inventor.
27. Robert Sean Kelly’s deceased father is Robert Royce Kelly.
Brief List of the main players
28. I am Robert Randall Kelly. I am the plaintiff and inventor. I was born in 1951.
29. Robert Royce Kelly was born in 1923. He died in 2000. His 2 sons are the poseurs. His death certificate is Exhibit 5. His will of December 1998 is Exhibit 6. He mentions no patent in his will. This should have been a tip off to the lawyers from Ryobi.
30. Robert Sean Kelly is one of the 2 poseurs. He is the son of the late Robert Royce Kelly. He accepted money from Joe Wortsmith in exchange for a patent that he never owned. He wrote the Affidavit depicted in Exhibit 4.
31. Patrick R. Kelly is the other poseur. He is the son of the late Robert Royce Kelly.
32. Patrick John Kelly is one of the attorneys in this case. He did the probate work.
33. Joe Wortsmith is the main villain. He found the late Robert Royce Kelly but was careful to avoid actually talking to him while he was still alive. Joe Wortsmith bought the patent from the poseurs and then sold it to Ryobi for $1 million. On information and belief we state that he kept the money.
34. Attorney Bugos is employed by Defendant Ryobi. Bugos directed Attorney Brandenberg in Michigan and Attorney Lindi in Grants Pass to assist him in defrauding me.
35. Jef Dils is the executive at Ryobi. He perpetrated this fraud and fails to do the right thing.
36. My patent is shown in Exhibit #3.
37. My patent can be seen online at the U.S. Patent Office http://www.uspto.gov/ at this following page:
38. One the face of this patent is clear proof that Robert Royce Kelly was not the inventor; my lawyers have their names on the patent, i.e. Attorney William S. Lovell and Attorney Eric Karich are named on the patent.
39. Lovell and Karich are easily reachable from the information on the patent.
40. The clear proof that the poseur was not the son of the inventor is on the face of the patent, to wit: my address: 747 Bridge Street, Grants Pass, Oregon 97526.
41. More clear proof is in the video which I sent to defendant Wortsmith with an invitation to become a licensee of my patent.
42. This video shows a house and yard that is not the house and yard of the deceased dad of the poseur brothers.
43. This video is at this link __ on the cd that contains the e-version of this complaint.
44. The poseur’s Dad never lived at that address on the patent.
45. Wortsmith never communicated with the poseurs at that address that is on the patent.
46. Robert Sean Kelly and other defendants could simply have inquired of either of my lawyers.
47. The poseurs knew that their Dad never lived at the address designated on the patent.
48. The poseurs knew that their Dad did not know the 2 lawyers listed on the patent.
49. The poseurs knew or should have known that the owner of my invention was not their deceased father.
50. Had they simply called either of these lawyers they would have discovered that the true inventor is still alive.
51. By comparison the father of the poseurs is deceased.
52. Therefore the living inventor cannot be the deceased father.
53. Q.E.D.
54. Patent #5,862,727 pertains to my invention called a Laser Arbor.
55. At first it could be seen at any Sears store.
56. It continues to be sold at Sears, Home Depot, Lowes, Diamond and the biggest retail tool stores.
57. It can be seen on the website for defendant Joe Wortsmith’s LTCI who infringes my patent by offering to sell the device at www.lasertools.com
Venue considerations of the main defendants: Ryobi, LTCI
58. Laser Tools Company, Inc., hereinafter “LTCI” is a corporation with adequate contacts pursuant to International Shoe Co. v. Washington (1945) http://laws.findlaw.com/us/326/310.html 326 U.S. 310, 66 S.Ct. 154, 90 L Ed 2nd 95 to qualify under 28 USC 1391(c).
59. Similarly, Ryobi and the affiliated Ryobi corporations have adequate contacts pursuant to International Shoe Co. v. Washington to qualify under 28 USC 1391(c).
60. All defendants named herein have adequate contacts pursuant to International Shoe Co. v. Washington to qualify under 28 USC 1391(c).
61. I offered my invention to Sears, Ryobi, and LTCI and many other prospective vendors.
62. They each rejected my invention.
63. Thereafter LTCI embezzled my sales materials and offered my invention to Ryobi who ultimately manufactured it for Sears.
64. All of the defendants knew that the invention was mine.
65. Sears and other vendors have sold millions of my Laser Arbors.
66. No defendant has ever paid me even a penny for their infringement of my invention.
Re: Sears. They are not a defendant. They are nonetheless part of the story.
67. Sears sells my patented device.
68. Early in this story Sears indicated that it expected Ryobi and me to work out a deal.
69. Sears calls my patented device a “Laser Trac.”
70. My Laser Arbor is on a variety of their Craftsman brand power saws such as the 10" Miter Saw, 12" Miter Saw, Radial Arm Saw, Compound Miter Saw and possibly more.
71. My Laser Arbor has the Sears part number 0015901.
72. It could at one time be purchased online or at any Sears for $55.72 plus applicable taxes and S/H.
73. On October 26, 1997, I emailed Craftsman from their web site mentioning my new invention.
74. Tom Murphy, a Sears employee responded by telling me to contact him when I got my patent.
75. After receiving my patent I contacted him by regular mail on March 25, 1999. I never got a response back.
76. Other persons contacted in the Sears organization are Michael J. Burke, the Sears trademark attorney.
77. I got his name off a 'trade name/ trade mark' internet site.
78. I contacted him on 5/19/01 about their infringing Sears Laser Trac miter saw.
79. I wanted to know if the device was patented and if they were in the stores.
80. He didn't know.
81. A few days later on 5/21/01, I got a call from someone named Stew Stanstrom, who said he was a Sears buyer at the corporate head office in Chicago.
82. He asked me if I was interested in the Laser Trac.
83. He said it was in stock and gave me a stock #24315.
84. After the learning of the infringing Sears Laser Trac product, my lawyer, Eric Karich, wrote a letter dated May 31, 2001 to Lynn Hudson Boone, general counsel for Sears.
85. Eric asked why Murphy did not answer my letter to him regarding the infringing Laser Trac.
86. I believe Sears at this point deferred the issue to Ryobi who manufactures the device for them.
Ryobi. See further below for their causes of action
87. Ryobi Technologies Inc., hereinafter “RTI” is at 1428 Pearman Dairy Road, Anderson, SC 29625.
88. The phone number is 800 323-4615.
89. Ryobi is a Japanese group.
90. RTI manufactures the infringing Laser Trac device for Sears at RTI’s China facilities.
91. RTI’s China plant is also know as the “Singer plant.”
92. I believe that RTI had an agreement to supply Sears with the infringing Laser Trac devices till December 31, 2003.
Cause of Action against Ryobi: Interference in potential advantage. I could have sold to Sears.
93. I could have sold that first production run of 135,000 units!
94. Ryobi and LTCI stole that opportunity.
95. Robert Bugos, general counsel for RTI is the first attorney that my lawyer Eric Karich dealt with after becoming aware of the infringement.
96. Wortsmith clearly lied to the poseurs when he told them that he knew me well and had long talks with me. See the declaration of Robert Sean Kelly in that regard. Exhibit #4. I only spoke to Wortsmith twice. That was on the phone. It was brief. I asked if he wanted to license my patent. He said No.
97. He found a then-living Robert Royce Kelly and duped his sons into believing a cock and bull story that paid $30,000.
98. Bugos wanted to believe. He had a duty to look at the address on the patent and investigate the veracity of the dead inventor story.
99. Even after Bugos was informed of the truth he continued to perpetrate the lie by directing Attorney Brandenberg to defraud the patent department with the fraudulent assignment using the papers depicted in Exhibit #19.
100. Extrapolating from the 3% letter depicted in Exhibit 8 it is obvious that Wortsmith was paid exactly $1,000,000 by Ryobi.
101. It appears that the $30,000 paid to the poseurs was sold to them as a royalty. Indeed the contract in exhibit 9 is called a “royalty agreement.” In fact the poseurs did not know that Wortsmith has sold their putative rights for $1 million. It is fraud like this that makes the defendants eligible for RICO punishment.
102. As seen in Exhibit 9 , Ryobi took over the responsibility for paying the 3% mentioned in the original deal with Wortsmith depicted in Exhibit 8.
103. To add insult to injury, Ryobi only advanced 10% of their meager $30,000 to the poseurs who were themselves have been victims to sharp dealing - as seen in Exhibit 9. They sold their million dollar patent for $30,000.
Robert Sean Kelly and his brother Patrick Kelly. See further below for their causes of action.
104. Defendant Robert Sean Kelly is one of the 2 poseurs. He lives at 1415 Bidwell, Portland, Oregon 97207. Home phone 503 232-5670. Cell 503 449-5304.
105. He was the executor of the estate of his father who was Robert Royce Kelly of Grants Pass.
106. The then-living Robert Royce Kelly was, according to the poseurs, unable to communicate with them regarding the patent.
107. However, the head poseur appears to be a convenient liar.
108. He backdated the date of death of his father by one year in his affidavit. This affidavit is depicted is Exhibit #4. The backdating happens in the last line of the first substantive paragraph.
109. The backdated death date precludes the question of why they did not simply ask their dad about the invention.
110. Exhibit 8 shows that the poseur son Robert signed the agreement with Wortsmith on 12 Feb 2000 nearly 2 months before his father died.
111. From Exhibit 9 Robert Sean Kelly and his brother Patrick were to receive a check for $3,000 upon signing from defendant RTI (Ryobi group) for a my patent - something that they never did own.
112. To their credit they say that they did not cash the check.
113. Their lawyer is Patrick John Kelly, 717 NW 5th Street, Grants Pass, Oregon. Phone: 541 474 1908.
114. Lawyer Kelly was paid to handle the estate of the deceased Robert Royce Kelly.
115. However the will (Exhibit 6) does not mention a patent. That was a clue that should not have been ignored - and would not have been ignored but for fraud.
116. See page 6 of Exhibit 9 for the signature of Attorney Lindi Baker on the letter to the poseurs. Attorney Lindi of Schultz, Salisbury, Cauble & Dole (hereinafter “Attorney Schultz etc.”), 111 S.E. 6th street, Grant’s Pass, Oregon 97528 ( 888 870 8825) acted at the behest of Ryobi to perpetrate the infringement on my patent.
The attempt to create plausible deniability for the lawyers who drew up the various documents instrumental to the fraudulent assignment
117. Attorney Lindi Baker knew or should have known that the poseur was a poseur.
118. Attorney Linda Baker executed an affidavit of Robert S. Kelly (Exhibit attached) and fraudulent assignment (Exhibit 8 attached) to RTI of my patent.
119. Attorneys Brandenberg and Bugos conspired to record the fraudulent assignment depicted in Exhibit 20.
120. Attorney Bugos of RTI directed the writing of the fraudulent assignment.
121. They did so by the fraudulent application package depicted in the certified record from the patent office depicted in the 19 pages that constitute Exhibit 19.
122. I contacted Ryobi via certified mail on June 8, 1995 as depicted in Exhibit 11.
123. They replied with a letter of no interest depicted in Exhibit 12.
Techtronic Industries - parent of Ryobi
124. Techtronic Industries Company Limited, a/k/a TTI Power Tools, hereinafter TTI is the parent of Ryobi.
125. Roy Chi Ping Chung is their Managing Director.
126. Patrick Chan is their executive director.
127. Their Headquarters is at 24/F CDW Building, 388 Castle Peak Road, Tsuen Wan, N.T. Hong Kong. Telephone 852 2402 6888. Fax: 852 2413 5971,
128. Chairman's Office, Horst J. Pudwill CEO 1806 Central Plaza 18 Harbour Road Wan Chai Hong Kong Tel: 852 2802 9068. Fax: 852 2827 0082.
One World Technologies - Ryobi affiliate: fraud on me and the patent office
129. One World Technologies, Inc., hereinafter “OWT” Anderson, South Carolina is another corporation that is part of the Ryobi group of companies.
130. It is located in the same state as RTI.
131. It has the same employees earning and handling the patents that have issued to Ryobi.
132. This company filed a design patent on May 9, 2001 for a Laser Arbor. This application is depicted in page 2 of Exhibit 10.
133. Not coincidentally, this was one day before Ryobi fraudulently infringed by fraudulently obtaining a signature from the poseurs on a fraudulent assignment depicted in Exhibit 9.
134. Their patent issued July 16, 2002.
135. Their design patent names my Utility patent as Prior Art.
136. Their design patent is a fraud.
137. In order to sue Caluori and others without using my patent, Ryobi further defrauded the patent office with the bogus patents depicted in Exhibit 10 - especially Design patent 460469.
138. The law requires permission of the utility owner in order to obtain a design patent.
139. The conspiring perpetrators perpetrating this fraud against me and the patent office are:
140. Yue; Siu Sum (Hong Kong, CN
141. Thurler; James E. (Pickens, SC)
142. Kaiser; William E. (Anderson, SC)
History of my patent pertinent to all causes of action
143. In December 1993 I invented my Laser Arbor.
144. On November 28, 1994 a notary public notarized my sketch of my Laser Arbor for me.
145. On Feb 6, 1995 I filed a document disclosure with the US Patent office by certified mail.
146. Thereafter on Feb 10, 1995 I received from the Patent Office confirmation #369701 for my disclosure.
147. Thereafter I built a prototype of my invention.
The video that I made and Joe Wortsmith misappropriated to perpetrate his poseur scheme
148. Thereafter, on June 16, 1995, I produced a video tape of my invention in actual use.
149. This video is Exhibit 27. It is on the cd and can be seen at this link: _______
150. This is the video that defendant con artist Joe Wortsmith misappropriated.
151. Although Joe Wortsmith knew it was my video tape of my invention, he found a person with the same name as was on my patent (to wit: Robert R. Kelly) in the same town (Grants Pass).
152. Then Joe conspired with the son of the dead person to pose as the executor of the estate of a patent holder.
153. At Exhibit 9 Ryobi promises to pay $30,000 to the poseurs.
154. This is the 3% promised by Worthsmith in Exhibit 8.
155. The proof of scienter is in the other fraudulent activities that they did on the same day, to wit:
a. Ryobi obtained a design patent based on my utility patent.
b. They intended to rely on the design patent thereby reducing scrutiny.
156. I began to produce literature to market my invention.
157. On March 11, 1996 I received my provisional patent with an application number of 60/ 033, 244.
158. The significance of this was that I could then say that I had a “patent pending”.
159. On October 26, 1997, I emailed Craftsman from their web site mentioning my new invention. Mr. Tom Murphy a Sears Craftsman Associate responded by telling me to contact him when I got my patent. After receiving my patent I contacted him by regular mail on 3/25/99. I never got a response back.
160. On January 26, 1999 I received my utility patent #5,862,727.
161. A utility is the dominant and major patent.
162. A utility patent is distinguished from a design patent in that the utility patent is the patent on the function and operation of the machine.
163. By comparison, a design patent is merely a decoration or accessory.
164. Defendant Ryobi attempted to bolster their previous fraud by obtaining a fraudulent design patent.
165. A design patent is parasitical to a utility patent.
166. Ryobi has no utility patent for the Laser Arbor.
167. Therefore Ryobi’s design patent is a legal nullity, the product of fraud.
168. On or about 4 October 1995 I telephoned Joe Wortsmith, president of LTCI in Little Rock, Arkansas.
169. I invited him to license my patent for his exploitation.
170. He asked me to send my video.
171. On October 11, 1995, feeling secure that my invention was officially disclosed I sent to LTCI a certified letter enclosing a freshly produced video of my Laser Arbor in action.
172. This letter is depicted in Exhibit 16.
173. I sent the video to Joe Wortsmith and Dennis Milam via certified mail #Z 202 252 037.
174. The address of LTCI was 12221 Arch Street Pike Little Rock, Arkansas 72206.
175. Their phone number is 501 888 8831 and 800 598-5973.
176. I made a follow up call a month later.
177. Joe Wortsmith said he was not interested.
178. I asked for a return of the video tape.
179. He did not ever return the video.
180. LTCI continues to advertise my Laser Arbor on their website as you can see on page b of Exhibit 14.
181. They infringe by offering to sell a device that infringes on my patent.
182. I received no letter back from LTCI.
183. I heard nothing back from LTCI until 7 years later, in the year 2001
184. In retrospect I now see that Wortsmith sold a fake patent for $1,000,000 to Ryobi.
185. The poseurs might reasonably have expected 3% of the gross sales from Laser Arbors.
186. Instead they paid a 97% commission for Wortsmith to sell their patent to Ryobi - or so they thought.
187. The 3% amounted to $30,000 as shown in page of Exhibit 9.
The head start by Sears ruined my chance to license Skil/ Bosch.
188. In October of 2000 my lawyer Eric Karich sent me to David Halstead who eventually led me to be in a position to license my invention to Skil/ Bosch.
189. David Halstead is a major buyer and supplier of tools to the construction industry,
190. He used his access to the executives at Skil/ Bosch to obtain an introduction for me.
191. I signed an agreement with Skil/ Bosch.
192. I built a prototype of my Laser Arbor for Skil/Bosch.
193. As depicted in Exhibit 15 Skil/ Bosch sent me a letter of intent to continue moving toward a licensing agreement on May 1, 2001.
194. On May 14, 2001 Skil/ Bosch announced that they discovered that Sears was selling a Laser Arbor which Sears called Laser Trac.
195. Skil/ Bosch did no more business with me although I eventually did a deal with Bosch.
Discussion with Sears led me to Ryobi - who had rejected my offer 6 years earlier
196. On May 17, 2001 I began an internet search regarding the infringing Sear Laser Trac.
197. Note that this was only 5 days after Ryobi has tricked the poseurs into selling their putative “million dollar patent” for a mere $3,000 up front and $27,000 more later.
198. I found the name of an attorney who did the trademark filing for Sears.
199. On May 18, 2001 I telephoned this man; he is Attorney Michael Burke, in-house counsel for Sears.
200. Burke told my lawyer Eric Karich that Ryobi manufactured the infringing devices for Sears.
201. The product had been on the market by Sears for 3 weeks then.
202. I bought one.
203. It infringed on my patent.
204. It had a patent number. That number 3 054 901 is depicted in Exhibit 2.
205. On Dec 17, 2001 I photographed the infringing Laser Arbor.
206. That photograph is depicted in Exhibit 2.
207. The patent number was a false marking applied by Ryobi.
The fraud and deception of Ryobi: Telling me that they weren’t interested and then conspiring to defraud me; false marking; conspiring with Wortsmith and the poseur; defrauding the patent office with a bogus fraudulent design patent on the same day.
208. That patent number pertains to an expired patent for an irrelevant lighting device having nothing to so with the infringing device.
209. It proves that Ryobi was well aware of the infringement when they manufactured the very first batch of 135,000 Laser Arbors.
210. My lawyer Karich immediately began negotiating with Attorney Bugos.
211. Bugos is in-house counsel for RTI (Ryobi Technologies Incorporated).
212. Ryobi had previously rejected my offer to license 6 years ago.