Free Notice of Related Case - District Court of California - California

Case 3:07-cv-02121-BTM-CAB

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J. MICHAEL KALER, SBN 158296 KALER LAW OFFICES 9930 Mesa Rim Road, Suite 200 San Diego, California 92121 Telephone (858) 362-3151 MELODY A. KRAMER, SBN 169984 KRAMER LAW OFFICE 9930 Mesa Rim Road, Suite 1600 San Diego, California 92121 Telephone (858) 362-3150 Attorneys for Plaintiff JENS ERIK SORENSEN, as Trustee of SORENSEN RESEARCH AND DEVELOPMENT TRUST

UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF CALIFORNIA JENS ERIK SORENSEN, as Trustee of SORENSEN RESEARCH AND DEVELOPMENT TRUST, Plaintiff v. GIANT INTERNATIONAL, INC., a Delaware corporation; and DOES 1-10, Defendants. ) Case No. ) ) AMENDED ) NOTICE OF RELATED CASES ) ) ) ) ) ) ) )

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Case 3:07-cv-02121-BTM-CAB

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Pursuant to Local Civil Rule 40.1(e), Plaintiff JENS E. SORENSEN, as TRUSTEE OF THE SORENSEN RESEARCH AND DEVELOPMENT TRUST ("SRDT"), hereby gives an amended notice of pending cases related to the present case. Specifically, SRD TRUST gives notice of the following related cases that all arise from alleged infringement of United States Patent Number 4,935,184 ("the `184 patent"), whether pending, dismissed, or otherwise terminated:

Jens Erik Sorensen as Trustee of Sorensen Research and Development Trust v. Helen of Troy Texas Corporation, et al, Case No. not assigned, being filed on or about December 4, 2007. Consolidation is not recommended because this related case involves different parties and has different, unrelated products at issue.

Jens Erik Sorensen as Trustee of Sorensen Research and Development Trust v. Esseplast (USA) NC, Inc., et al, Case No. not assigned, being filed on or about December 4, 2007. Consolidation is not recommended because this related case involves different parties and has different, unrelated products at issue.

Jens Erik Sorensen as Trustee of the Sorensen Research and Development Trust v. First International Digital, Inc., et al, Case No. C075525, filed October 30, 2007 in the United States District Court for the Northern District of California. Consolidation is not recommended because this related case involves different parties and has different, unrelated products at issue.

Jens Erik Sorensen as Trustee of the Sorensen Research and Development Trust v. Digital Networks North America, Inc., et al, Case No. C075568, filed November 1, 2007 in the United States District Court for the Northern District of California. Consolidation is not recommended because this related case involves different parties and has different, unrelated products at issue.
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Case 3:07-cv-02121-BTM-CAB

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Jens Erik Sorensen as Trustee of the Sorensen Research and Development Trust v. The Black & Decker Corporation, et al, Civil Case No.: 06CV1572BTN CAB, filed August 7, 2006, in the United States District Court for the Southern District of California. Consolidation is not recommended because this related case involves different parties and has different, unrelated products at issue.

American Safety Razor Co. v. Sorensen Research & Development Trust, Civil Case No. 07CV00730HHK, filed April 20, 2007, in the United States District Court for the District of Columbia. Consolidation is not recommended because this related case involves different parties and has different, unrelated products at issue.

DMS Holdings, Inc. v. Sorensen Research & Development Trust. Civil Case No.: 07CV02690, filed May 11, 2007, in the United States District Court for the Northern District of Illinois. Consolidation is not recommended because this related case involves different parties and has different, unrelated products at issue.

Jens Erik Sorensen as Trustee of the Sorensen Research And Development Trust v. Tecnica USA, Inc and Nordica USA, Inc., Civil Case No. 06CV1941 B MLS, filed September 18, 2006 in the Southern District of California. The action was settled by the parties, and dismissed.

Jens Erik Sorensen As Trustee of The Sorensen Research And Development Trust v. Head USA Inc. Civil Case No.: 06CV1434BTN CAB, filed July 2006 in the Federal District for the Southern District of California. The action was settled by the parties, and dismissed.

Head USA Inc. v. Jens Erik Sorensen (As Trustee of The Sorensen Research
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And Development Trust), and Sorensen Research And Development Trust. Docket No.: 306CV00983, filed June 2006 in the Federal District of Connecticut. The matter was transferred and consolidated with the Sorensen Research And Development Trust v. Head USA Inc. action filed in the Southern District of

California, Civil Case No.: 06CV1434BTM CAB. The action was later settled by the parties, and dismissed.

Nordica USA Corp. v. Jens Ole Sorensen, Jens Erik Sorensen, and Sorensen Research and Development Trust. Docket No. 1:06-cv-91-JM filed March 8, 2006 in the Federal District of New Hampshire. The matter was transferred and consolidated with Jens Erik Sorensen As Trustee of The Sorensen Research And Development Trust v. Tecnica USA, Inc and Nordica USA, Inc., Civil Case No. 06CV1941 B MLS, filed in the Southern District of California. The action was later settled by the parties.

Jens Ole Sorensen, and Jens E. Sorensen, as Trustee Of The Sorensen Research and Development Trust v. DaimlerChrysler AG, and Mercedes-Benz USA, LLC. Civil No. 03-1763 (HAA) filed in the United States District Court for

Northern California and transferred to the United States District Court for New Jersey. This matter has been settled and dismissed.

In the Matter of Certain Automobile Tail Light Lenses And Products Incorporating Same. Investigation No. 337-TA-502 filed in the United States

International Trade Commission. The matter was remanded after appeal to the Federal Circuit Court of Appeals, then settled and dismissed.

Jens E. Sorensen, as Trustee Of The Sorensen Research and Development Trust v. Premier Automotive Group, Ford Motor Company, and Jaguar, Ltd. Case
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No. 03-cv-01107, filed March 14, 2003 in the Federal Court for the Northern District of California. The matter was settled and dismissed.

Lowe's Companies, Inc., et al v. Sorensen Research and Development Trust. Case No. 05-cv-00234 filed July 29, 2005 in the Federal Court for the Western District of North Carolina. The matter was never served and was dismissed.

Digital Innovations LLC v. Sorensen Research and Development Trust. Case No. 05-cv-06428, filed November 9, 2005 in the Federal Court for the Northern District of Illinois. The matter was never served and was dismissed.

Big Lots v. Sorensen Research and Development Trust. Case No. 2:06-cv1089, filed December 29, 2006 in the Federal Court for the Southern District of Ohio. The matter was never served and was dismissed.

Bon-Aire v. Sorensen Research and Development Trust. Case No. 07-cv-054S, filed January 2007 in the Federal Court for the District of Idaho. The matter was never served and was dismissed.

Husqvarna Outdoor Products, Inc. v. Sorensen Research and Development Trust. CIV. NO. CV106-160 in the Federal Court for the Southern District of Georgia on October 30, 2006. The matter was never served and was dismissed.

Sorensen et al v. International Trade Commission et al.

427 F.3d 1375

(Fed.Cir., 2005). After the Federal Circuit ruled in patentee's favor, the parties settled and dismissed.

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DATED this 4th day of December, 2007. JENS ERIK SORENSEN, as Trustee of SORENSEN RESEARCH AND DEVELOPMENT TRUST, Plaintiff /s/ Melody A. Kramer Melody A. Kramer, Esq. J. Michael Kaler, Esq. Attorneys for Plaintiff

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PROOF OF SERVICE I, Melody A. Kramer declare: I am and was at the time of this service working within in the County of San Diego, California. I am over the age of 18 year and not a party to the within action. My business address is the Kramer Law Office, Inc., 9930 Mesa Rim Road, Suite 1600, San Diego, California, 92121. I am a member of the State Bar of California and the Bar of this Court. On December 4, 2007, I served on the parties to this action the following documents:

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(Facsimile) I caused a true copy of the foregoing documents to be transmitted by facsimile machine to the above noted addressees. The facsimile transmissions were reported as complete and without error.
Case No. ______________

AMENDED NOTICE OF RELATED CASES

PERSON(S) SERVED

PARTY(IES) SERVED

METHOD OF SERVICE Email ­ Pleadings Filed with the Court

Allison Goddard J. Christopher Jaczko Jaczko Goddard LLP 4401 Eastgate Mall San Diego, CA 92121 [email protected] [email protected] 858-225-3500 FAX Dale Lischer Elizabeth G. Borland Kerri A. Hochgesang Smith, Gambrell & Russell, LLP Promenade II, Suite 3100 1230 Peachtree St., N.E. Atlanta, GA 30309 404-685-6945 FAX

Defendant Giant International (USA) Ltd.

Defendant Giant International (USA) Ltd.

Email ­ Pleadings Filed with the Court

(Personal Service) I caused to be personally served in a sealed envelope hand-delivered to the office of counsel during regular business hours. (Federal Express) I deposited or caused to be deposited today with Federal Express in a sealed envelope containing a true copy of the foregoing documents with fees fully prepaid addressed to the above noted addressee for overnight delivery.

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Case 3:07-cv-02121-BTM-CAB

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(Email) I emailed a true copy of the foregoing documents to an email address represented to be the correct email address for the above noted addressee. X (Email--Pleadings Filed with the Court) Pursuant to Local Rules, I electronically filed this document via the CM/ECF system for the United States District Court for the Southern District of California.

I declare that the foregoing is true and correct, and that this declaration was executed on Tuesday, December 04, 2007, in San Diego, California. /s/ Melody A. Kramer __________________________ Melody A. Kramer