Case 1:20-cv-01637-RMB-KMW Document 1 Filed 02 / 14 / 20 Page 9 of 10 PageID : 9
observer who is familiar with the prior art in the field , appears substantially similar to the ornamental design of the D ’ 332 patent .
34 . Defendants have damaged and will continue to damage Cambria in an amount to be determined at trial .
35 . Defendants have irreparably injured Cambria and such injury will continue unless Defendants are enjoined by this Court .
WHEREFORE , in consideration of the foregoing , Cambria respectfully requests that this Court enter an Order granting the following relief :
A .
Enjoin Defendants and any person acting in concert with them from further infringement of the D ’ 332 patent pursuant to 35 U . S . C . § 283 ;
B .
Declare that the D ’ 332 patent is valid , enforceable , and infringed by Defendants ; and
C . Award Cambria the profits of Defendants , in accordance with 35 U . S . C . § 289 , resulting from Quartz Master ’ s and Raphael Stone ’ s infringement of the D ’ 332 patent , actual damages to Cambria in an amount not less than a reasonable royalty for Quartz Master ’ s and Raphael Stone ’ s infringement , and other damages and relief allowed as by 35 U . S . C . § 284 :
( i ) order the removal from the marketplace and destruction of all of Defendants ’ products that infringe the D ’ 332 patent ;
( ii ) prohibit Defendants from further using , selling , offering for sale , or importing all of Defendant ’ s products that infringe the D ’ 332 patent ;
( iii ) award Cambria its reasonable attorney fees ; ( iv ) award Cambria interest and costs ;
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