1

IN UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF OHIO
EASTERN DIVISION



BETA-CALCO, INC.
25 Kodiak Crescent
Toronto, Ontario
M3J 3E5
Canada

Plaintiff,

v.

SCOTT ARCHITECTURAL LIGHTING and
SCOTT LAMP CO., INC.
355 Watt Drive
Fairfield CA 94534

Defendant.

Civil Action No.


JUDGE


COMPLAINT

JURY TRIAL DEMAND




For its Complaint against Scott Architectural Lighting (Scott Lighting) and Scott Lamp
Co., Inc. (Scott Lamp) (collectively with Scott Lighting, Scott), Beta-Calco, Inc. (Beta-Calco)
states as follows:
THE PARTIES
1. Beta-Calco is a corporation organized and existing under the laws of the Province of
Ontario, Canada, having its principal place of business at 25 Kodiak Crescent, Toronto, Ontario,
M3J 3E5, Canada. Beta-Calco is a leader in the design and manufacture of architectural lighting
products.
2. On information and belief, Scott Lamp Company, Inc., is a corporation organized
and existing under the laws of California, having its principal place of business at 355 Watt Drive,
Fairfield, California 94534.
Case: 5:13-cv-01543 Doc #: 1 Filed: 07/17/13 1 of 6. PageID #: 1
2

3. On information and belief, Scott Architectural Lighting is a sister company or
division of Scott Lamp and has its principal place of business at 355 Watt Drive, Fairfield, California
94534.
4. On information and belief, Scott manufactures and sells architectural lighting
products.
JURISDICTION AND VENUE
5. This is a civil action, arising under the patent statutes, 35 U.S.C. 101 et seq., and in
particular 35 U.S.C. 271, 281 and 289, against Scott for infringement of United States Design
Patent No. D574,993 (the 993 Patent). A true and accurate copy of the 993 Patent is attached as
Exhibit A.
6. This Court has subject matter jurisdiction pursuant to 28 U.S.C. 1331 and 1338(a).
7. Scott is subject to the personal jurisdiction of this Court and venue is proper in this
District because, on information and belief, Scott engages in continuous and systematic business
within this district.
8. Scott is subject to the personal jurisdiction of this Court and venue is proper in this
District also because, on information and belief, Scott is selling and offering to sell its accused
products in this judicial district, including to Lighting Dynamics Inc., located at 211 Springside
Drive, Akron, Ohio 44333, and has placed its accused products into the stream of commerce in this
judicial district.
9. Venue in the Northern District of Ohio is proper pursuant to 28 U.S.C.
1391(b)(2) or (3) and 1400(b).
Case: 5:13-cv-01543 Doc #: 1 Filed: 07/17/13 2 of 6. PageID #: 2
3

COUNT I: INFRINGEMENT OF THE 993 PATENT

10. Beta-Calco incorporates by reference herein the allegations of Paragraphs 1-9 of this
Complaint.
11. Beta-Calco is the owner by way of assignment of the 993 Patent entitled LIGHT
FIXTURE. The 993 Patent was duly and legally issued by the United States Patent and Trademark
Office (USPTO) on August 12, 2008. The 993 Patent is in force and effect and is presumed valid
under the U.S. patent laws.
12. Upon information and belief, Scott has been, and is, directly infringing the 993
Patent by making, using, selling and/or offering for sale light fixtures, including Scotts S2560 model
pendant light fixture (the S2560), that infringe the ornamental design claim of the 993 Patent. A
true and accurate copy of Scotts catalog for the S2560 pendant light fixture is attached as Exhibit
B. A comparison of the light fixture of the 993 Patent and the S2560 pendant light fixture is shown
below:
The 993 Patent The S2560


Case: 5:13-cv-01543 Doc #: 1 Filed: 07/17/13 3 of 6. PageID #: 3
4



13. As shown in paragraph 12, based on a visual comparison of the pictured design of
the 993 Patent and the design of the S2560, an ordinary observer, giving such attention as a
purchaser usually gives, would consider the two designs to be substantially the same. Both designs
have an exterior frusto-conical housing that is generally transparent and an interior cylindrical
housing for a source of light that is visible through the exterior housing. Additionally, the lower
portion of the exterior housing of both designs is not generally transparent.
14. On March 28, 2013, Beta-Calco, by way of its counsel, sent a notice of infringement
letter to Scott. On information and belief, as of March 29, 2013, Scott was aware of Beta-Calcos
allegation that the S2560 infringes the 993 Patent.
15. On or about April 3, 2013, Scott responded to Beta-Calcos notice letter. A true and
accurate copy of the April 3, 2013 letter is attached as Exhibit C. Beta-Calco and Scott exchanged
additional correspondence dated May 1, 2013 and May 17, 2013. A true and accurate copy of Beta-
Calcos May 1, 2013 letter to Scott is attached as Exhibit D. A true and accurate copy of Scotts
May 17, 2013 letter to Beta-Calco is attached as Exhibit E.
16. Scott has knowingly and willfully infringed the 993 Patent. Scott will continue to
infringe the 993 Patent, causing Beta-Calco substantial and irreparable damage, unless enjoined by
this Court.
17. Beta-Calco will be greatly, immediately and irreparably harmed unless the Court
enjoins Scott and its agents, affiliates, servants, employees, attorneys, representatives, and all others
acting on their behalf from infringing the 993 Patent.
18. Beta-Calco has also suffered monetary damages in an amount not yet determined
because of Scotts infringement of the 993 Patent.
Case: 5:13-cv-01543 Doc #: 1 Filed: 07/17/13 4 of 6. PageID #: 4
5

PRAYER FOR RELIEF
Beta-Calco prays for the following relief:
(a) A judgment that Scott has infringed the 993 Patent and continues to do so;
(b) A judgment that Scotts infringement of the 993 Patent has been willful;
(c) A judgment against Scott awarding Beta-Calco damages equal to all revenues and
profits derived by Scott from Scotts infringement of the 993 Patent pursuant to 35
U.S.C. 289;
(d) A judgment against Scott awarding Beta-Calco damages suffered pursuant to 35
U.S.C. 284 on account of Scotts infringement of the 993 Patent;
(e) A judgment that Beta-Calco damages be trebled pursuant to 35 U.S.C. 284 and
that punitive damages be assessed against Scott;
(f) A permanent injunction against Scott and any entity acting in concert with it,
pursuant to 35 U.S.C. 283, preventing Scott and any such entity from infringing the
993 Patent;
(g) A judgment that this is an exceptional case and that Beta-Calco be awarded
reasonable attorney fees pursuant to 35 U.S.C. 285; and
(h) A judgment that Scott be directed to pay Beta-Calco its costs incurred herein and
such other and further relief as the Court deems just and equitable.
JURY DEMAND
Beta-Calco respectfully requests a trial by jury for all issues so triable.

Case: 5:13-cv-01543 Doc #: 1 Filed: 07/17/13 5 of 6. PageID #: 5
6

Dated: July 17, 2013 Respectfully submitted,


s/Nicholas J. Gingo
Mark C. Johnson (0072625)
Nicholas J. Gingo (0083684)
RENNER, OTTO, BOISSELLE & SKLAR, LLP
1621 Euclid Avenue, Nineteenth Floor
Cleveland, Ohio 44115
Telephone: (216) 621-1113
Facsimile: (216) 621-6165

Attorneys for Beta-Calco, Inc.

Case: 5:13-cv-01543 Doc #: 1 Filed: 07/17/13 6 of 6. PageID #: 6
JS 44 (Rev. 12/12)
CIVIL COVER SHEET
The JS 44 civil cover sheet and the inIormation contained herein neither replace nor supplement the Iiling and service oI pleadings or other papers as required by law, except as
provided by local rules oI court. This Iorm, approved by the Judicial ConIerence oI the United States in September 1974, is required Ior the use oI the Clerk oI Court Ior the
purpose oI initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
I. (a) PLAINTIFFS DEFENDANTS
(b) County oI Residence oI First Listed PlaintiII County oI Residence oI First Listed DeIendant
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.

(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)
II. BASIS OF JURISDICTION (Place an X in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an X in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
u 1 U.S. Government u 3 Federal Question PTF DEF PTF DEF
PlaintiII (U.S. Government Not a Party) Citizen oI This State u 1 u 1 Incorporated or Principal Place u 4 u 4
oI Business In This State
u 2 U.S. Government u 4 Diversity Citizen oI Another State u 2 u 2 Incorporated and Principal Place u 5 u 5
DeIendant (Indicate Citizenship of Parties in Item III) oI Business In Another State
Citizen or Subject oI a u 3 u 3 Foreign Nation u 6 u 6
Foreign Country
IV. NATURE OF SUIT (Place an X in One Box Only)
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
u 110 Insurance PERSONAL INJURY PERSONAL INJURY u 625 Drug Related Seizure u 422 Appeal 28 USC 158 u 375 False Claims Act
u 120 Marine u 310 Airplane u 365 Personal Injury - oI Property 21 USC 881 u 423 Withdrawal u 400 State Reapportionment
u 130 Miller Act u 315 Airplane Product Product Liability u 690 Other 28 USC 157 u 410 Antitrust
u 140 Negotiable Instrument Liability u 367 Health Care/ u 430 Banks and Banking
u 150 Recovery oI Overpayment u 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS u 450 Commerce
& EnIorcement oI Judgment Slander Personal Injury u 820 Copyrights u 460 Deportation
u 151 Medicare Act u 330 Federal Employers` Product Liability u 830 Patent u 470 Racketeer InIluenced and
u 152 Recovery oI DeIaulted Liability u 368 Asbestos Personal u 840 Trademark Corrupt Organizations
Student Loans u 340 Marine Injury Product u 480 Consumer Credit
(Excludes Veterans) u 345 Marine Product Liability LABOR SOCIAL SECURITY u 490 Cable/Sat TV
u 153 Recovery oI Overpayment Liability PERSONAL PROPERTY u 710 Fair Labor Standards u 861 HIA (1395II) u 850 Securities/Commodities/
oI Veteran`s BeneIits u 350 Motor Vehicle u 370 Other Fraud Act u 862 Black Lung (923) Exchange
u 160 Stockholders` Suits u 355 Motor Vehicle u 371 Truth in Lending u 720 Labor/Management u 863 DIWC/DIWW (405(g)) u 890 Other Statutory Actions
u 190 Other Contract Product Liability u 380 Other Personal Relations u 864 SSID Title XVI u 891 Agricultural Acts
u 195 Contract Product Liability u 360 Other Personal Property Damage u 740 Railway Labor Act u 865 RSI (405(g)) u 893 Environmental Matters
u 196 Franchise Injury u 385 Property Damage u 751 Family and Medical u 895 Freedom oI InIormation
u 362 Personal Injury - Product Liability Leave Act Act
Medical Malpractice u 790 Other Labor Litigation u 896 Arbitration
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS u 791 Employee Retirement FEDERAL TAX SUITS u 899 Administrative Procedure
u 210 Land Condemnation u 440 Other Civil Rights Habeas Corpus: Income Security Act u 870 Taxes (U.S. PlaintiII Act/Review or Appeal oI
u 220 Foreclosure u 441 Voting u 463 Alien Detainee or DeIendant) Agency Decision
u 230 Rent Lease & Ejectment u 442 Employment u 510 Motions to Vacate u 871 IRSThird Party u 950 Constitutionality oI
u 240 Torts to Land u 443 Housing/ Sentence 26 USC 7609 State Statutes
u 245 Tort Product Liability Accommodations u 530 General
u 290 All Other Real Property u 445 Amer. w/Disabilities - u 535 Death Penalty IMMIGRATION
Employment Other: u 462 Naturalization Application
u 446 Amer. w/Disabilities - u 540 Mandamus & Other u 465 Other Immigration
Other u 550 Civil Rights Actions
u 448 Education u 555 Prison Condition
u 560 Civil Detainee -
Conditions oI
ConIinement
V. ORIGIN (Place an X in One Box Only)
u 1 Original
Proceeding
u 2 Removed Irom
State Court
u 3 Remanded Irom
Appellate Court
u 4 Reinstated or
Reopened
u 5 TransIerred Irom
Another District
(specify)
u 6 Multidistrict
Litigation
VI. CAUSE OF ACTION
Cite the U.S. Civil Statute under which you are Iiling (Do not cite jurisdictional statutes unless diversity):

BrieI description oI cause:
VII. REQUESTED IN
COMPLAINT:
u CHECK IF THIS IS A CLASS ACTION
UNDER RULE 23, F.R.Cv.P.
DEMAND $ CHECK YES only iI demanded in complaint:
JURY DEMAND: u Yes u No
VIII. RELATED CASE(S)
IF ANY
(See instructions):
JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
FOR OFFICE USE ONLY
RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE
BETA-CALCO, INC.
N/A
Mark C. Johnson (0072625) and Nicholas J. Gingo (0083684)
Renner, Otto, Boisselle & Sklar, LLP - 1621 Euclid Ave., 19th Floor -
Cleveland, OH 44115 - (216) 621-1113
SCOTT ARCHITECTURAL LIGHTING and
SCOTT LAMP CO., INC.
35 U.S.C. 271, 281 and 289
Patent infringement
07/17/2013 /s/Nicholas J. Gingo
Case: 5:13-cv-01543 Doc #: 1-1 Filed: 07/17/13 1 of 3. PageID #: 7
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF OHIO
I. Civil Categories: (Please check one category only).
1. General Civil
2. Administrative Review/Social Security
3. Habeas Corpus Death Penalty
*If under Title 28, 2255, name the SENTENCING JUDGE:
CASE NUMBER:
II. RELATED OR REFILED CASES. See LR 3.1 which provides in pertinent part: "If an action is filed or removed to this Court
and assigned to a District Judge after which it is discontinued, dismissed or remanded to a State court, and
subsequently refiled, it shall be assigned to the same Judge who received the initial case assignment without regardfor
the place of holding court in which the case was refiled. Counsel or a party without counsel shall be responsible for
bringing such cases to the attention of the Court by responding to the questions included on the Civil Cover Sheet."
This action is RELATED to another PENDINGcivil case. This action is REFILED pursuant to LR 3.1.
If applicable, please indicate on page 1 in section VIII, the name of the Judge and case number.
III. In accordance with Local Civil Rule 3.8, actions involving counties in the Eastern Division shall be filed at any of the
divisional offices therein. Actions involving counties in the Western Division shall be filed at the Toledo office. For the
purpose of determining the proper division, and for statistical reasons, the following information is requested.
ANSWER ONE PARAGRAPH ONLY. ANSWER PARAGRAPHS 1 THRU 3 IN ORDER. UPON FINDING WHICH
PARAGRAPH APPLIES TO YOUR CASE, ANSWER IT AND STOP.
(1) Resident defendant. If the defendant resides in a county within this district, please set forth the name of such
county
COUNTY:
Corporation For the purpose of answering the above, a corporation is deemed to be a resident of that county in which
it has its principal place of business in that district.
(2) Non-Resident defendant. If no defendant is a resident of a county in this district, please set forth the county
wherein the cause of action arose or the event complained of occurred.
COUNTY:
(3) Other Cases. If no defendant is a resident of this district, or if the defendant is a corporation not having a principle
place of business within the district, and the cause of action arose or the event complained of occurred outside
this district, please set forth the county of the plaintiff's residence.
COUNTY:
IV. The Counties in the Northern District of Ohio are divided into divisions as shown below. After the county is
determined in Section III, please check the appropriate division.
EASTERN DIVISION
AKRON (Counties: Carroll, Holmes, Portage, Stark, Summit, Tuscarawas and Wayne)
CLEVELAND (Counties: Ashland, Ashtabula, Crawford, Cuyahoga, Geauga, Lake,
Lorain, Medina and Richland)
YOUNGSTOWN (Counties: Columbiana, Mahoning and Trumbull)
WESTERN DIVISION
TOLEDO (Counties: Allen, Auglaize, Defiance, Erie, Fulton, Hancock, Hardin, Henry,
Huron, Lucas, Marion, Mercer, Ottawa, Paulding, Putnam, Sandusky, Seneca
VanWert, Williams, Wood and Wyandot)

Summit
Case: 5:13-cv-01543 Doc #: 1-1 Filed: 07/17/13 2 of 3. PageID #: 8
JS 44 Reverse (Rev. 12/12)
INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44
Authority For Civil Cover Sheet
The JS 44 civil cover sheet and the inIormation contained herein neither replaces nor supplements the Iilings and service oI pleading or other papers as
required by law, except as provided by local rules oI court. This Iorm, approved by the Judicial ConIerence oI the United States in September 1974, is
required Ior the use oI the Clerk oI Court Ior the purpose oI initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk oI
Court Ior each civil complaint Iiled. The attorney Iiling a case should complete the Iorm as Iollows:
I.(a) Plaintiffs-Defendants. Enter names (last, Iirst, middle initial) oI plaintiII and deIendant. II the plaintiII or deIendant is a government agency, use
only the Iull name or standard abbreviations. II the plaintiII or deIendant is an oIIicial within a government agency, identiIy Iirst the agency and
then the oIIicial, giving both name and title.
(b) County of Residence. For each civil case Iiled, except U.S. plaintiII cases, enter the name oI the county where the Iirst listed plaintiII resides at the
time oI Iiling. In U.S. plaintiII cases, enter the name oI the county in which the Iirst listed deIendant resides at the time oI Iiling. (NOTE: In land
condemnation cases, the county oI residence oI the "deIendant" is the location oI the tract oI land involved.)
(c) Attorneys. Enter the Iirm name, address, telephone number, and attorney oI record. II there are several attorneys, list them on an attachment, noting
in this section "(see attachment)".
II. Jurisdiction. The basis oI jurisdiction is set Iorth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions be shown in pleadings. Place an "X"
in one oI the boxes. II there is more than one basis oI jurisdiction, precedence is given in the order shown below.
United States plaintiII. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and oIIicers oI the United States are included here.
United States deIendant. (2) When the plaintiII is suing the United States, its oIIicers or agencies, place an "X" in this box.
Federal question. (3) This reIers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution oI the United States, an amendment
to the Constitution, an act oI Congress or a treaty oI the United States. In cases where the U.S. is a party, the U.S. plaintiII or deIendant code takes
precedence, and box 1 or 2 should be marked.
Diversity oI citizenship. (4) This reIers to suits under 28 U.S.C. 1332, where parties are citizens oI diIIerent states. When Box 4 is checked, the
citizenship oI the diIIerent parties must be checked. (See Section III below; NOTE: federal question actions take precedence over diversity
cases.)
III. Residence (citizenship) of Principal Parties. This section oI the JS 44 is to be completed iI diversity oI citizenship was indicated above. Mark this
section Ior each principal party.
IV. Nature of Suit. Place an "X" in the appropriate box. II the nature oI suit cannot be determined, be sure the cause oI action, in Section VI below, is
suIIicient to enable the deputy clerk or the statistical clerk(s) in the Administrative OIIice to determine the nature oI suit. II the cause Iits more than
one nature oI suit, select the most deIinitive.
V. Origin. Place an "X" in one oI the six boxes.
Original Proceedings. (1) Cases which originate in the United States district courts.
Removed Irom State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441.
When the petition Ior removal is granted, check this box.
Remanded Irom Appellate Court. (3) Check this box Ior cases remanded to the district court Ior Iurther action. Use the date oI remand as the Iiling
date.
Reinstated or Reopened. (4) Check this box Ior cases reinstated or reopened in the district court. Use the reopening date as the Iiling date.
TransIerred Irom Another District. (5) For cases transIerred under Title 28 U.S.C. Section 1404(a). Do not use this Ior within district transIers or
multidistrict litigation transIers.
Multidistrict Litigation. (6) Check this box when a multidistrict case is transIerred into the district under authority oI Title 28 U.S.C. Section 1407.
When this box is checked, do not check (5) above.
VI. Cause of Action. Report the civil statute directly related to the cause oI action and give a brieI description oI the cause. Do not cite jurisdictional
statutes unless diversity. Example: U.S. Civil Statute: 47 USC 553 BrieI Description: Unauthorized reception oI cable service
VII. Requested in Complaint. Class Action. Place an "X" in this box iI you are Iiling a class action under Rule 23, F.R.Cv.P.
Demand. In this space enter the actual dollar amount being demanded or indicate other demand, such as a preliminary injunction.
Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.
VIII. Related Cases. This section oI the JS 44 is used to reIerence related pending cases, iI any. II there are related pending cases, insert the docket
numbers and the corresponding judge names Ior such cases.
Date and Attorney Signature. Date and sign the civil cover sheet.
Case: 5:13-cv-01543 Doc #: 1-1 Filed: 07/17/13 3 of 3. PageID #: 9
AO 440 (Rev. 12/09) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________ District of __________
)
)
)
)
)
)
)
Plaintiff
v. Civil Action No.
Defendant
SUMMONS IN A CIVIL ACTION
To: (Defendants name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiffs attorney,
whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
Northern District of Ohio
BETA-CALCO, INC.
SCOTT ARCHITECTURAL LIGHTING and SCOTT
LAMP CO., INC.
SCOTT LAMP CO., INC.
355 Watt Drive
Fairfield, CA 94534
Mark C. Johnson
Renner, Otto, Boisselle & Sklar, LLP
1621 Euclid Ave., 19th Floor
Cleveland, OH 44115
(216) 621-1113
Case: 5:13-cv-01543 Doc #: 1-2 Filed: 07/17/13 1 of 2. PageID #: 10
AO 440 (Rev. 12/09) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)
was received by me on (date) .
u I personally served the summons on the individual at (place)
on (date) ; or
u I left the summons at the individuals residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date) , and mailed a copy to the individuals last known address; or
u I served the summons on (name of individual) , who is
designated by law to accept service of process on behalf of (name of organization)
on (date) ; or
u I returned the summons unexecuted because ; or
u Other (specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:
Servers signature
Printed name and title
Servers address
Additional information regarding attempted service, etc:
0.00
Case: 5:13-cv-01543 Doc #: 1-2 Filed: 07/17/13 2 of 2. PageID #: 11
AO 440 (Rev. 12/09) Summons in a Civil Action
UNITED STATES DISTRICT COURT
for the
__________ District of __________
)
)
)
)
)
)
)
Plaintiff
v. Civil Action No.
Defendant
SUMMONS IN A CIVIL ACTION
To: (Defendants name and address)
A lawsuit has been filed against you.
Within 21 days after service of this summons on you (not counting the day you received it) or 60 days if you
are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
P. 12 (a)(2) or (3) you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiffs attorney,
whose name and address are:
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
You also must file your answer or motion with the court.
CLERK OF COURT
Date:
Signature of Clerk or Deputy Clerk
Northern District of Ohio
BETA-CALCO, INC.
SCOTT ARCHITECTURAL LIGHTING and SCOTT
LAMP CO., INC.
SCOTT ARCHITECTURAL LIGHTING
355 Watt Drive
Fairfield, CA 94534
Mark C. Johnson
Renner, Otto, Boisselle & Sklar, LLP
1621 Euclid Ave., 19th Floor
Cleveland, OH 44115
(216) 621-1113
Case: 5:13-cv-01543 Doc #: 1-3 Filed: 07/17/13 1 of 2. PageID #: 12
AO 440 (Rev. 12/09) Summons in a Civil Action (Page 2)
Civil Action No.
PROOF OF SERVICE
(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any)
was received by me on (date) .
u I personally served the summons on the individual at (place)
on (date) ; or
u I left the summons at the individuals residence or usual place of abode with (name)
, a person of suitable age and discretion who resides there,
on (date) , and mailed a copy to the individuals last known address; or
u I served the summons on (name of individual) , who is
designated by law to accept service of process on behalf of (name of organization)
on (date) ; or
u I returned the summons unexecuted because ; or
u Other (specify):
.
My fees are $ for travel and $ for services, for a total of $ .
I declare under penalty of perjury that this information is true.
Date:
Servers signature
Printed name and title
Servers address
Additional information regarding attempted service, etc:
0.00
Case: 5:13-cv-01543 Doc #: 1-3 Filed: 07/17/13 2 of 2. PageID #: 13
US00D574993S
( 1 2 ) United States Design Patent a o ) Pa tent NO.:
Silver ( 45) Da te o f Pa tent:
US D574,993 S
** Aug. 12,2008
( 54) LIGHT FIXTURE
( 75) Invento r: Remy Silver, To ro nto ( CA)
( 73) Assignee: Beta Calco Inc., Onta rio ( CA)
( **) Term: 1 4 Years
( 21) Appl.No .: 2 9/2 84,575
( 22) Filed: Sep. 1 1 , 2 007
( 30) Foreign Application Priority Data
Ma r. 14, 2007 ( CA) 119893
( 51) LOC( 8) Cl 2 6-03
( 52 ) U.S. CI D2 6/88; D26/128
( 58) Field of Classification Search D26/72,
D26/84, 85, 86, 88-91, 118, 128, 130, 131,
D26/135, 137; 362/147, 404, 407
See a pplica tio n file fo r co mplete sea rch histo ry.
( 56) References Cited
U.S. PATENT DOCUMENTS
5,134,554 A * 7/1992 Do na to et a l 362/407
D433,526 S * 11/2000 Minissi et a l D26/88
D518,914 S * 4/2006 Bra nner D26/88
7,249,871 B2* 7/2007 Chen 362/407
D563,021 S * 2/2008 Hetfieldeta l D26/72
i ! i
I I I
1
1
1 1
1
1
1
1
1
1
1
1
1 1
1
1
1
1
1 1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
i
*'!
i n
D563,025 S * 2/2008 Hetfieldeta l D26/72
OTHER PUBLICATIONS
Ha nging Penda nts sho wn in pho to o n p. 195 o f the IKEA 2005
ca ta lo g.*
Gla ss sha de #SC-276 o n p. 224 o f the Aug. 1997 issue o f Ta iwa n
Lighting.*
"Co ne" fixtures #503R a nd #501P by Electro line. p. 85 o f the Ma y
2001 issue o f Ta iwa n Lighting.*
* cited by exa miner
Primary ExaminerCla re E Heflin
( 74) Attorney, Agent, or FirmRenner, Otto , Bo isselle &
Skla r, LLP
( 57) CLAIM
The o rna menta l design fo r a light fixture, a s sho wn a nd
described.
DESCRIPTION
FIG. 1 is a side view o f the light fixture sho wing my new
design.
FIG. 2 is a perspective view o f the light fixture sho wn in FIG.
1; a nd,
FIG. 3 is bo tto m view o f the light fixture sho wn in FIG. 1.
The bro ken lines sho wn o n the dra wings a re fo r illustra tive
purpo ses o nly a nd fo rm no pa rt o f the cla imed design.
1 Claim, 1 Drawing Sheet
^
Case: 5:13-cv-01543 Doc #: 1-4 Filed: 07/17/13 1 of 2. PageID #: 14
A
U.S. Patent Aug. 12,2008 US D574.993 S
FIG. 1
FIG. 2
rr"
FIG. 3
Case: 5:13-cv-01543 Doc #: 1-4 Filed: 07/17/13 2 of 2. PageID #: 15
S2560-1C42T-WH
Case: 5:13-cv-01543 Doc #: 1-5 Filed: 07/17/13 1 of 2. PageID #: 16
B
P
e
n
d
a
n
t
s
355 WATT DRIVE FAIRFIELD, CA 94534 TEL (707) 864-2172 FAX (707) 864-2182
www.scottarchlighting.com
Scott Architectural Lighting Reserves The Right To Make Design Changes Without Prior Notice
BASE ADD ADD
DIMENSIONS MODEL LAMP FINISH
W H X NO. CODE CODE
10-1/2 96 16-1/4 S2560 * 1C42T BA, PT
Order as a Complete Unit: Model No. + Lamp Code + Finish Code + Option Code + Voltage
ORDERING INFORMATION
TECHNICAL SPECIFICATIONS FINISHES OPTIONS
LAMPING FEATURES
C42T = 42 Watt Triple Tube Compact Fluorescent 4 Pin Electronic, GX24Q-4 Base
EM Emergency Battery Pack
with Fluorescent Lighting
(Integral)
OA Specify Overall Height of
Fixture in Inches; E.G. OA48
DIM Dimmable Integral Ballast
(Consult Factory)
SB2 Clear Silver Braided Cord with
Two Adjustable Aircraft Cables
Ballast: High Power Factor,
Electronic, 120/277
Mounting: Mounts to all Standard Electrical
Junction Boxes (by others) with
Hardware Provided
BA Brushed Aluminum
PT Painted Finishes
(Specify Color Code from
Our Standard Finish Chart)
White SJ Cord with Two Adjustable
Aircraft Cables
Integral Ballast
Clear Glass Cone with Frosted Bottom Trim
Opal Matte Glass Cylinder with Aluminum
Downlight Reflector
* Configuration operates C26T, C32T or
C42T lamp options and can be labeled up
to the highest wattage allowed
Case: 5:13-cv-01543 Doc #: 1-5 Filed: 07/17/13 2 of 2. PageID #: 17
Renner, Otto, Boiselle & Sklar, LLP
1621 Euclid A venue
Nineteenth Floor
Cleveland, Ohio 44115-2191
ATTN: Christopher B. Jacobs
April 3, 2013
RE: Infringement of U.S. Design Patents Nos. D574,993 and D561,928
Ref: SMAR GO 103
Dear Mr. Jacobs:
We do not intend to violate any design patents that are currently in effect. In early automotive history,
Henry Ford sought to supply the masses with an affordable automobile; his progress in doing so was
slowed by ALAM, Association of Licensed Automobile Manufacturers, which claimed to have 25 patents
covering the automobile and did not allow Ford a license to manufacture autos. Ford took the ALAM to
court and as we all know from history, Ford won and all patents held by ALAM were found to be invalid.
With reference to our models you have in question, our S2401 Series is substantially different than the
Beta-Calco item you reference. See our drawing (enclosed) representing this series, as well see the item of
other manufacturers that are visually similar, Winona and Visa. Your claim is eerily reminiscent of the
ALAM claims against Henry Ford.
As for our pendant, S2560, it is by far, substantially different from the Beta-Calco item you reference.
Please further be put on notice that further bullying-type attempts to curtail the items produced by Scott
Lamp Company and Scott Architectural will be met with appropriate actions on our part.
Dennis J. Scott
P r ~ ~ ~
E n ~
355 Watt Drive Fairfield, CA 94534 PH (707) 864-2066 FAX (707) 864-2076
www .sco ttlamp. com
Case: 5:13-cv-01543 Doc #: 1-6 Filed: 07/17/13 1 of 7. PageID #: 18
C
8" SQ. --- 1 - - 1
OVERALL
HIEGHT
TO BE
ADVISED
29 3/4"
0
0
0
0
0
0
CANOPY
(/> l /16" STAINLESS STEEL
CABLE
CLEAR SILVER BRAIDED
ELECTRICAL CORD
(4) OPAL MATTE
ACRYLIC PANELS
n
( 13 7 /8" )
el
ISOMETRIC VIEW
EGG CRATE
LOUVERS
l- 13 7/8" SQ. _j
ELEVATION VIEW

U.L. LISTED
FLUORESCENT FIXTURE
BOTTOM VIEW
ITEM NUMBER:
PEN DANT - 52401 -SERI ES
ARCHITECTURAL
LIGHTING
355 WATTDRIVE
' FAIRFIELD, CA 94534
PH: (707)864-2172
FAX: (707)864-2182
LAMPING (BY OTHERS) : TYPE: WEIGHT: DWG NUMBER:
(4) 40 WATT BIAX COMPACT FLUORESCENT 4 PIN
FINISH: VOLTAGE: SCALE: DATE
(BA) BRUSHED ALUMINUM 120/ 277 N/ A XX-XX-XX
COMMENTS: APP BY: DRAWN BY: REVISION:
Case: 5:13-cv-01543 Doc #: 1-6 Filed: 07/17/13 2 of 7. PageID #: 19
Winona Lighting I Decorative I Pendants I 5600 Page 1 of 1
http://www.winonalighting.com/products/ decorative/pendants/ 5600 4/2/2013
Case: 5:13-cv-01543 Doc #: 1-6 Filed: 07/17/13 3 of 7. PageID #: 20
--
, , d 8 c
I
4
_
114
.. II IMB (Surface Mount)
canopy detail
Ls .. J
11-1/4"
5600-10
Weight Hanging (lbs.)
F39T5, F39T5/H75 I 5600-8
F54T5, F54T5/H75 / 5600-8
F / 5600-10
F/H100 / 5600-10
F/MH100 / 5600-10
13-1/4"
G
5600-12
35 lbs.
40 lbs.
33 lbs.
35 lbs.
37 lbs.

5600-8
F39T5or
F39T5/H75
F / 5600-12
F/H250 / 5600-12
FIMH100 / 5600-12
all pendants over 50 lbs. require additional hanging support.
Notes: Iii:\
UL listed and cUL approved
Winona Lighting products are union made.
Custom Sizes and Finishes available upon request
All Fluorescent fixtures available in 120V and 277V.
Winona Lighting reserves the right to make design
changes without prior notice.
Lamps not included.
L-J
8-3/4"

5600-8
F54T5 or
F54T5/H75
38 lbs.
40 lbs.
42 lbs.
1, ______ ..,
CATALOG#
2 -------;
STEM OPTION
3. - - -----<
LAMPING
4, ______ _
VOLTAGE
5. ______ _
LENS OPTION
6 -------<
FINISH
1 -------;
BALLAST
8, ______ ..,
SPECIAL
Modification
Descriptions:
(if needed)
wi1111
3760 west fourth street winona, minnesota 55987 507 - 454 - 5113 fax: 507 - 454 - 1814
I I I I I I I I www.winonalighting.com

56008
5600-10
5600-12
CSM =CABLE STEM MOUNT
SSTM =SINGLE STEM MOUNT
5600-8
F39T5 = (4) F39T5HO/MINI Bl-PIN
F54T5 = (4) F54T5HO/MINI Bl-PIN
F39T5/H75= (4) F39T5HO/MINI Bl-PI N &
(1) 75W PAR 30 (halogen downlight)
F54T5/H75= (4) F54T5HO/MINI Bl-PI N &
(1) 75W PAR 30 (halogen downlight)
5600-10
F = (4) FT40W/2G11
F/H100 = (4) FT40W/2G11 &
( 1) 1 OOW PAR 38 (halogen downlight)
F/MH100 = (4) FT40W/2G11 &
(1) 100W PAR 38 (metal halide downlighl)
5600-12
F = (4) FT40W/2G11
F/H250 = (4) FT40W/2G11 &
( 1) 250W PAR 38 (halogen downlight)
F/MH100 = (4) FT40W/2G11 &
(1) 100W PAR 38 (metal halide downlighl)
120V = 120 VOLT (halogen option 120V only)
277V = 277 VOLT
OA = OPAL ACRYLIC (etched)
SA1 =VERTICAL PATTERN ACRYLIC (etched)
SA2 =GRID PATTERN ACRYLIC (etched)
SA3 =DOT PATTERN ACRYLIC (etched)
SA4 =WEAVE PATTERN ACRYLIC (etched)
STANDARD
BAL =BRUSHED ALUMINUM
LBP =LIGHT BRONZE PAINT WITH BRUSHED TEXTURE
CUSTOM
CPF =CUSTOM PAINTED FINISH (consult factory)
CMF =CUSTOM METAL FINISH (consult factory)
IMB
RMB
= INTEGRAL ELECTRONIC (see canopy detail I MH downlighl only)
= REMOTE MOUNT MAGNETIC (MH downlighl only)
STD
MOD
=STANDARD
=MODIFIED
Revised: 10-26-11 Page 1of1
Case: 5:13-cv-01543 Doc #: 1-6 Filed: 07/17/13 4 of 7. PageID #: 21
Delray Lighting Inc I Kone Glass Pendants
Decorative Pendants KONE
Click on thumbnail for larger view. (Popup blocker must be
disabled, scripts enabled.)
610 611 620
621 622 623
6010
m ~ BIM
http:// delray lighting. com/kone.html
~ Interactive PDF Spec Sheet
~ Photometry Report
(Right click to download IES file)
mM Revit files ~ Redirect to
Autodesk Seek
KONE Instructions (PDF):
Pendant Installation
Page 1 of 1
More Gloss-Pendants
Vtew All Products
4/4/2013
Case: 5:13-cv-01543 Doc #: 1-6 Filed: 07/17/13 5 of 7. PageID #: 22
KONE CLEAR GLASS LUMINAIRE WITH DOWNLIGHT
KONE CLEAR PENDANT
Canopy mounts to standard )-box.
Compact fluotrescent electronic
ballast fits inside fixture for easy
access, metal halide ballast is in
canopy. Pendant is 45" standard
with push button adjustable
aircraft cable. Finish is silver with
braided power cord. Glass shade
is opal inside, clear outside,
for general illumination with clad
aluminum downlight releccor
for task lighting. Fixtures have
a twist lock socket for secure,
easy relamping. Dimming and
emergency battery backup is
available for CFL. U.L. listed for
damp locations.
KONE CLEAR SURFACE
Canopy mounts to standard
) -box. Electronic ballast fits on
backplate for easy access. Finish
is silver. The dear glass shade
is removable without tools and
is for general illumination, an
interior clad aluminum downlight
relecror for task lighting. Fixtures
feature twist lock socket for secure,
easy relamping. Dimming and
emergency options are not available.
U.L. listed for damp locations.
TYPE:
ORDER NUMBER:
I select I I sel ect I I sel ect
Model# Wattage Voltage
26, 32 or 42 1- 120V
2-277V
Example:
6202
II
26
11
6202.
Fluorescent
6201
Fluorescent
9J
+-9.s -+
PROJECT:
I I select I I sel ect
Option
EM-Emergency battery
(pendant only).
Dimming only for
items marked +.
Choose D3, D4, DS, DB
or D9. (See Back Page)
11
EM
6202EM
Fluorescent
t-5.5"---t
1
50.S"
-+
BURBANK,
CALIFORNIA,
91505
WWW.
DELRAY
LIGHTING.
"'
0
"' m
COM
w
u.
Case: 5:13-cv-01543 Doc #: 1-6 Filed: 07/17/13 6 of 7. PageID #: 23
,
FLUORESCENT
142W PLY
CP DISTRIBUTION
180 ISO'
120
314
628
60'
942
COEFFICIENTS OF UTILIZATION
% CEILING 80 (20% FLOOR)
% WALL 70 50 30
0 73 73 73
1 65 61 58
2 59 54 49
3 54 48 42
4 50 43 37
5 46 39 33
6 43 35 30
7 40 32 27
8 37 29 24
9 35 27 22
JO 33 25 20
6202.42
l -42W triple rube
G24q-3 electronic twist lock socket
Total lumens: 3200
Spacing criteria: .78
NOTES
BALLAST INFO
DIMMING
Ballast mounted inside fooure.
Dimming only available for
items marked t on page 1.
Voltage must be specified.
Controls lumen output down
to 5%.
Compatible dimmers required
for all ballasts.
D3 Advance Mark X for 26, 32
or42Wlamp.
D4 Lutron Tu-Wire for 26 or
32W lamp. 120V only.
D5 Advance Mark Vll for 26,
32 or 42W lamp.
DB Lutron Hi-Lume 1 % for 26
or 32W lamp. Controls lumen
output down to 1 %.
D9 Lutron EcoSystem for 18,
26, 32 or 42W lamp. Controls
lumen output down to 5%.
EMERGENCY
Voltage must be specified.
EM emergency power provides
650 lumens for one lamp for
90 minutes. Ht.= 15.25"
EM 13 emergency power provides
1300 lumens for one lamp for
90 minutes. Ht.=19"
50.5''
-+
OPTIONS
AL-Acrylic Lens. For security and
food service installations.
Use with CFL lamps only.
Case: 5:13-cv-01543 Doc #: 1-6 Filed: 07/17/13 7 of 7. PageID #: 24
Case: 5:13-cv-01543 Doc #: 1-7 Filed: 07/17/13 1 of 3. PageID #: 25
D
Case: 5:13-cv-01543 Doc #: 1-7 Filed: 07/17/13 2 of 3. PageID #: 26
Case: 5:13-cv-01543 Doc #: 1-7 Filed: 07/17/13 3 of 3. PageID #: 27
Case: 5:13-cv-01543 Doc #: 1-8 Filed: 07/17/13 1 of 1. PageID #: 28
E