Case 1:20-cv-01637-RMB-KMW Document 1 Filed 02 / 14 / 20 Page 4 of 10 PageID : 4
FACTUAL BACKGROUND
9 . Plaintiff Cambria is an industry leader in the design and manufacture of natural quartz surface products . Cambria ’ s natural quartz surface products have a variety of uses in homes and businesses , including , but not limited to , countertops , floor tiles , vanities , fireplace surrounds , wet bars , and showers .
10 . Cambria is an innovator in creating original , unique , and distinct designs for its natural quartz surface products . To protect these designs , Cambria has sought and received intellectual property protection for its designs , including , but not limited to , United States Design Patent D780,332 ( the “ D ’ 332 patent ”).
11 . The D ’ 332 patent issued on February 28 , 2017 . Cambria is the owner of the D ’ 332 patent by assignment . The D ’ 332 patent is valid , enforceable , and duly issued in compliance with Title 35 of the United States Code . A true and correct copy of the D ’ 332 patent is attached as Exhibit A .
12 . The D ’ 332 patent is entitled “ An Ornamental Design for a Slab .” The sole figure from the D ’ 332 patent is shown below :
13 . Cambria ’ s Brittanicca™ quartz surface product from its Marble Collection™ features the design of the D ’ 332 patent .
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