Case 2:19-cv-04566-MAK Document 1 Filed 10/02/19 Page 1 of 15

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF PENNSYLVANIA

:
KNOLL, INC., :
:
Plaintiff, : CIVIL ACTION NO. ______________
:
v. :
:
SENATOR INTERNATIONAL LIMITED :
D/B/A THE SENATOR GROUP :
:
Defendant. :
:
:

COMPLAINT FOR DESIGN PATENT INFRINGEMENT

Plaintiff Knoll, Inc. (“Knoll” or “Plaintiff”) by and through its undersigned counsel hereby

assert their Complaint against Defendant, Senator International Limited doing business as The

Senator Group (“Defendant”) and hereby alleges as follows:

NATURE OF THE ACTION

1. This is an action for patent infringement arising under the Patent Laws of the

United States, 35 U.S.C. § 1 et seq.

THE PARTIES

2. Knoll is a corporation organized under the laws of the State of Delaware with a

place of business at 1235 Water St., East Greenville, Pennsylvania 18041.

3. Knoll does business in Pennsylvania and the Eastern District of Pennsylvania.

4. Knoll is the owner of U.S. Patent No. D839,638, a true and correct copy of which

is attached hereto as Exhibit A.

5. Defendant is a foreign company incorporated in the United Kingdom.

 Case 2:19-cv-04566-MAK Document 1 Filed 10/02/19 Page 2 of 15

6. Defendant’s principal place of business is in the United Kingdom. Defendant has

its global headquarters located at Altham Business Park, Sykeside Drive Altham, Accrington

BB5 5YE United Kingdom. Defendant is a United Kingdom private limited company.

7. Defendant offers for sale, sells, distributes, makes, and/or imports office furniture

into the United States, in Pennsylvania, and this judicial district.

8. Defendant makes, uses, offers to sell, sells, and imports office furniture products

into the United States.

9. Defendant’s personnel engage in regular and continuous business operations in

the United States and in this judicial district that includes facilitating corporate relationships

Defendant has with its customers in this judicial district, and assisting customers in identifying

ways Defendant’s products and services meet their customers’ office furniture needs consistent

with Defendant’s corporate objectives. Defendant personnel conduct these operations on behalf

of Defendant as a representative, employee, and agent of Defendant.

10. Defendant offers for sale, sells, distributes, makes, and/or imports office furniture

into the United States and this judicial district. This includes importation, sale, and/or offer of

sale of Array table products that infringe U.S. Patent No. D839,638 as alleged herein.

JURISDICTION AND VENUE

11. This is an action for patent infringement arising under the Patent laws of the

United States, Title 35 of the United States Code.

12. This Court has subject matter jurisdiction over this action under 28 U.S.C. §§

1331 and 1338.

13. Defendant has been and is engaged in business in Pennsylvania and the Eastern

District of Pennsylvania, including advertising and offering to sell its infringing Array tables in

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this judicial district, shipping said products directly or indirectly into or through Pennsylvania,

including through this judicial district, and having sold and/or participated in the offer of sale of

said tables in this judicial district.

14. Defendant directly and/or through its coordinated distribution network regularly

place its Array tables in the stream of commerce with the knowledge and/or understanding that

such products will be sold and used in this judicial district. Defendant is subject to the general

jurisdiction of this Court because it has regular and systemic contacts with this forum such that

the exercise of jurisdiction over it will not offend the traditional notions of fair play and

substantial justice.

15. Further, this Court has personal jurisdiction over Defendant because Defendant

has established minimum contacts with the forum such that the exercise of personal jurisdiction

over Defendant will not offend the traditional notions of fair play and substantial justice.

16. In addition, this Court has personal jurisdiction over Defendant because

Defendant has knowingly and actively engaged in acts that have infringed and will infringe

and/or contribute, induce, aid, and/or abet the direct infringement of claims of the U.S. Patent

No. D839,638 in this judicial district.

17. Venue is proper pursuant to 28 U.S.C. §§ 1391(c) and 1400 because Defendant

has committed acts of infringement in this judicial district and does business in this judicial

District.

18. For instance, venue is proper because of the "long-established rule that suits

against aliens are wholly outside the operation of all the federal venue laws, general and special."

In re HTC Corp., 889 F.3d 1349, 1354 (Fed. Cir. 2018). The “venue laws (as opposed to

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 Case 2:19-cv-04566-MAK Document 1 Filed 10/02/19 Page 4 of 15

requirements of personal jurisdiction) do not restrict the location of suits against alien

defendants.” Id. at 1357.

FACTUAL BACKGROUND

19. Knoll develops, sells, markets, and supports furniture, including office furniture.

Knoll is famous throughout the world for its design and development of furniture, which

includes iconic chairs such as Knoll’s Barcelona chair, the Womb chair, and many other iconic,

well known articles of furniture.

20. Knoll owns U.S. Design Patent No. D839,638 (“the ’638 Patent”), which lawfully

issued on February 5, 2019.

21. Knoll makes and sells a well-known line of tables known as the PIXEL tables.

The C-Leg version of the PIXEL table is covered by the ’638 Patent. An illustrative picture of

this PIXEL table is shown below:

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22. Defendant is a developer, manufacturer, distributor, and importer of furniture

products, including tables and chairs.

23. Defendant makes, offers to sell, and sells a newly introduced line of Array tables.

24. The Array tables were included in an exhibit in Defendant’s showroom at the

trade show referred to as NeoCon that took place in the Chicago Merchandise Mart located in

Chicago, Illinois in June of 2019.

25. Below is an image of an Array table at this NeoCon tradeshow:

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 Case 2:19-cv-04566-MAK Document 1 Filed 10/02/19 Page 6 of 15

26. The Array table looks almost identical to Knoll’s PIXEL table, as can be

appreciated from the below comparisons:

Defendant’s Array Table Knoll PIXEL Table

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 Case 2:19-cv-04566-MAK Document 1 Filed 10/02/19 Page 7 of 15

27. The below table provides a non-limiting exemplary comparison of the Array table

and the ornamental appearance of the Knoll design protected by the ’638 Patent:

Defendant’s Array Table U.S. Design Pat. No. D839,638

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 Case 2:19-cv-04566-MAK Document 1 Filed 10/02/19 Page 8 of 15

Defendant’s Array Table U.S. Design Pat. No. D839,638

28. Defendant’s Array table has an ornamental appearance that is almost identical to

the ornamental appearance of the design shown, described and claimed in the ’638 Patent.

29. Consumers of tables are likely to be confused into thinking that the Array table is

the table shown, described, and claimed in the ’638 Patent.

30. An ordinary observer, familiar with prior art to the ’638 Patent, would be

deceived into thinking that the Array table was the same as the patented design claimed in the

’638 Patent. Egyptian Goddess, Inc. v. Swisa, Inc. 543 F.3d 665, 677-78 (Fed. Cir. 2008).

31. The Array table is advertised, marketed, and offered for sale by Defendant in

Pennsylvania, this judicial district and throughout the United States. (See e.g.

http://www.thesenatorgroup.com/americas/, http://www.thesenatorgroup.com/uk/news/array-by-

senator/).

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THE ’638 PATENT AND DEFENDANT’S KNOWLEDGE OF THIS PATENT

32. On February 5, 2019, the ’638 Patent entitled “TABLE” was duly and legally

issued by the United States Patent and Trademark Office.

33. A true and correct copy of the ’638 Patent is attached as Exhibit A to this

Complaint.

34. Knoll is the assignee and owner of the right, title, and interest in and to the ’638

Patent.

35. The ’638 Patent has a single claim that says “The ornamental design for a table, as

shown and described” and includes a description that states “The broken lines shown in the

drawing Figures form no part of the claimed design.”

36. Knoll practices the claimed invention of the ’638 Patent by making and selling its

C-Leg version of its PIXEL tables.

37. Defendant has had actual knowledge of the ’638 Patent since at least as early as

July 17, 2019.

38. On information and belief, Defendant also had actual knowledge of the ’638

Patent during development of the Array table.

39. On information and belief, Defendant knew the ’638 Patent protected Knoll’s

PIXEL table before the Array table was included in an exhibit at the NeoCon tradeshow in June

of 2019.

40. On information and belief, Defendant designed its Array table to mimic the

design of the Knoll’s PIXEL table, with a goal to develop, make, and sell a table that would

compete with the PIXEL table so that Defendant’s Array table would have the same look as

Knoll’s PIXEL table but would have a lower price point for competition with the Knoll’s

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PIXEL table. On information and belief, these actions were done to try to take market share

away from Knoll’s PIXEL table with a table that had substantially the same ornamental

appearance as Knoll’s PIXEL table.

41. Defendant has continued to offer to sell, make and sell its Array table knowing

that this table infringes the ’638 Patent.

42. Defendant has willfully, deliberately, and intentionally continued to infringe the

claim of the ’638 Patent at least by using, offering to sell, selling, distributing, offering to

distribute, and making its Array table in reckless disregard of the claim of the ’638 Patent.

43. Defendant’s infringement of the ’638 Patent has caused irreparable injury to

Knoll.

COUNT I: INFRINGEMENT OF THE ’638 PATENT

44. Knoll restates and realleges the foregoing allegations as if fully stated herein.

45. In violation of 35 U.S.C. § 271(a), Defendant has directly infringed and continues

to directly infringe, both literally and under the doctrine of equivalents, the claim of the ’638

Patent by making, using, offering for sale, selling, distributing and/or importing the tables that

practice and therefore infringe the subject matter in the claim of the ’638 Patent throughout the

United States and within this judicial district without authority of Knoll.

46. In violation of 35 U.S.C. § 271(b) and (c) Defendant has indirectly infringed and

continues to indirectly infringe the claim of the ’638 Patent, within this judicial district and

throughout the United States without authority of Knoll by actively inducing its customers’

infringement of the ’638 Patent with knowledge of the ’638 Patent and by contributing to the

infringement of that patent by selling at least the Array table to customers for their possession

and use.

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47. The Array table infringes the claim of the ’638 Patent. This table is made,

marketed, distributed, sold and/or offered for sale by Defendant throughout the United States and

in this judicial district. This table include each and every feature of the claim of the ’638 Patent.

48. For example, the below table provides a non-limiting comparison of the Array

table and the ornamental appearance of the Knoll design protected by the ’638 Patent:

Defendant’s Array Table U.S. Design Pat. No. D839,638

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49. The Array table has an ornamental appearance that is almost identical to the

ornamental appearance of the table design shown, described and claimed in the ’638 Patent.

50. Consumers of tables are likely to be confused into thinking that the Array table is

the table shown, described, and claimed in the ‘638 Patent.

51. An ordinary observer, familiar with prior art to the ’638 Patent, would be

deceived into thinking that the Array table was the same as the patented design claimed in the

’638 Patent. Egyptian Goddess, Inc. v. Swisa, Inc. 543 F.3d 665, 677-78 (Fed. Cir. 2008).

52. Knoll has been, and continues to be, damaged and irreparably harmed by

Defendant’s infringement, which will continue unless the Court enjoins that infringement and for

which there is no adequate remedy at law.

53. Knoll under 35 U.S.C. §§ 284 and/or 289, is entitled to recover damages adequate

to compensate for Defendant’s infringement.

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 Case 2:19-cv-04566-MAK Document 1 Filed 10/02/19 Page 13 of 15

54. The infringement of the ’638 Patent by Defendant has been, and continues to be,

deliberate, willful, and knowing.

55. The Court should declare this an exceptional case under 35 § U.S.C. 285, entitling

Knoll to recover treble damages and attorneys’ fees.

56. Pursuant to 35 U.S.C. § 287, the filing of this action constitutes notice to

Defendant of its infringement of the ’638 Patent.

DEMAND FOR JURY TRIAL

57. Knoll demand a trial by jury under Rules 38 and 39 of the Federal Rules of Civil

Procedure for all issues triable by jury.

PRAYER FOR RELIEF

WHEREFORE, Knoll requests that the Court grant the relief requested in the Prayer for

Relief below.

(a) That Defendant be adjudged to have infringed, contributed to, and/or induced the

infringement of the claim of the ’638 Patent;

(b) That Defendant be adjudged to have engaged in willful infringement of the ’638

Patent;

(c) That Knoll be awarded damages for infringement of the ’638 Patent, including

damages adequate to compensate Knoll for Defendant’s past infringement of the ’638 Patent

including lost profits, Defendant’s profits, a reasonable royalty, or other monetary relief

available under 35 U.S.C. §§ 284 and/or 289 and for any continuing or future infringement

through the date such judgment is entered, including interest, costs, expenses, and an

accounting of all infringing acts including, but not limited to, those not presented at trial (35

U.S.C. §§ 284 and 289);

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 Case 2:19-cv-04566-MAK Document 1 Filed 10/02/19 Page 14 of 15

(d) That Defendant pay an ongoing royalty in an amount to be determined for any

continued infringement of the ’638 Patent after the date the judgment is ordered;

(e) That this case be declared an exceptional case under 35 U.S.C. § 285;

(f) That Knoll’s damages be trebled pursuant to 35 U.S.C. § 284;

(g) That Knoll be awarded its attorneys’ fees and costs pursuant to 35 U.S.C. § 285;

(h) That this Court permanently enjoin Defendant, its officers, directors, principals,

agents, servants, employees, successors, assigns, affiliates, and all that are in active concert

or participation with Defendant, or any of them, from further infringement of the ’638 Patent

and that Defendant be permanently enjoined from infringing the ’638 Patent and from

making, using, selling, offering to sell, or distributing the Defendant’s infringing tables;

(i) That Knoll be awarded pre- and post-judgment interest on all damages;

(j) That Knoll be awarded all its costs and expenses in this action; and

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 Case 2:19-cv-04566-MAK Document 1 Filed 10/02/19 Page 15 of 15

(k) That Knoll be awarded such further and other relief as the Court may deem just

and proper.

Respectfully submitted,

By:__________________________
Dated: October 2, 2019 Samuel Braver
samuel.braver@bipc.com
Ralph G. Fischer
ralph.fischer@bipc.com
(pro hac vice pending)
Buchanan Ingersoll & Rooney PC
One Oxford Centre
301 Grant Street, 20th Floor
Pittsburgh, PA 15219-1410
Tel: (412) 392-2121/562-1696

Samantha L. Southall
samantha.southall@bipc.com
Buchanan Ingersoll & Rooney PC
Two Liberty Place
50 South 16th Street, Suite 3200
Philadelphia, PA 19102
Telephone: (215) 665-8700
Facsimile: (215) 665-8760

Attorneys for Plaintiff Knoll, Inc.

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Case 2:19-cv-04566-MAK Document 1-1 Filed 10/02/19 Page 1 of 9

EXHIBIT A
 Case 2:19-cv-04566-MAK Document 1-1 Filed 10/02/19 Page 2 of 9

USOOD839638S

United States Design Patent (10)

(12) Patent N0.: US D839,638 S
Krusin Date of Patent: (45) 44 Feb. 5, 2019

(54) TABLE D776,961 S * 1/2017 Yamamoto A47B 3/0809

...........
D6/656.16
(71) Applicant: Knoll, Inc.; East GreenVille; PA (US) 2015/0118010A1* 4/2015 Krusin A47B 7/02
..................... 414/801

(72) Inventor:MarcKrusinLondon
’ (GB) 2015/0320198
A1* 11/2015
Zebarjad A47B
.................. 9/00
108/147
~ ~ 2016/0309888 A1* 10/2016 Krusin A47B 3/0809
(73) , Knoll, Inc.; East GreenV1lle;PA
Ass1gnee. (US) .................
2017/0135466A1* 5/2017 Randlov A47B 9/20
2017/0224101 A1* 8/2017 Bruder ' .. A47B 9/04
..
(** ) Term: 15Years 2018/0092457
A1* 4/2018Lai ...........................
A47B9/10
(21) Appl. No.: 29/566,209 * cited by examiner

(22) Filed: May 27, 2016 Primary Examiner — Mary Ann Calabrese
(51) LOC (11)Cl. 06-03 (74)Attorney,Agent,or Firmf Buchanan
Ingersoll&
............................................... Rooney
PC
(52) US.Cl.
USPC D6/656.17
......................................................
(58) Field of Classi■cation Search
USPC D6/641,642,656,656.1,656.13, (57) CLAIM
.................
D6/656.157656.18 685 691 691.5 691.6
A47B 3/0803' A47137/06. A47I§ 9/00.
. for a table; as shownanddescnbed.
The ornamentaldes1gn .
CPC
........... A47B 9/12; A47B 9/20; A47B 13/00;
A47B 13/003; A47B 13/02; A47B 13/08;
A47B 2013/006;A47B 21/00;A47B DESCRIPTION
2200/0001; A47B 2200/0011; A47B
2200/0035; A47B 2200/0051; A47B FIG. 1 is a perspective View of a table showing my new
2200/0056; A47B 2200/0057; A47B design;
2200/0061; A47B 2200/0062; A47B FIG. 2 is a front elevational View thereof;
2200/0066; A47B 2200/008 FIG. 3 is a rear elevational View thereof;
See application ■le for complete search history. FIG. 4 is a top plan View thereof;
FIG. 5 is a bottom plan View thereof;
(56) References Clted
. FIG. 6 is a left side elevational View thereof; and;
FIG. 7 is a right side elevational View thereof.
U S PATENT DOCUMENTS
' ' The broken lines shown in the drawing Figures form no part
s * 11/1990
D311,833 Newhouse D6/656.16 of theclaimeddesign
................
9,038,549 B1*
5/2015 Zebarjad 9/02 A47B
..................
108/147 1 Claim, 7 Drawing Sheets
 Case 2:19-cv-04566-MAK Document 1-1 Filed 10/02/19 Page 3 of 9

U S. Patent Feb.5,2019 Sheet1 of 7 US D839,638s

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FIG. 1
 Case 2:19-cv-04566-MAK Document 1-1 Filed 10/02/19 Page 4 of 9

US. Patent Feb.5,2019 Sheet2 of 7 US D839,638s

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 Case 2:19-cv-04566-MAK Document 1-1 Filed 10/02/19 Page 5 of 9

US. Patent Feb.5,2019 Sheet3 of 7 US D839,638s

FIG. 3
 Case 2:19-cv-04566-MAK Document 1-1 Filed 10/02/19 Page 6 of 9

US. Patent Feb.5,2019 Sheet4 of 7 US D839,6388

FIG. 4
 Case 2:19-cv-04566-MAK Document 1-1 Filed 10/02/19 Page 7 of 9

U.S. Patent Feb.5,2019 Sheets 0f7 US D839,638 S

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US. Patent Feb.5,2019 Sheet6 of 7 US D839,638s

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 Case 2:19-cv-04566-MAK Document 1-1 Filed 10/02/19 Page 9 of 9

US. Patent Feb.5,2019 Sheet7 of7 US D839,638s

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 Case 2:19-cv-04566-MAK Document 1-2 Filed 10/02/19 Page 1 of 2
JS 44 (Rev. 02/19) CIVIL COVER SHEET
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)

I. (a) PLAINTIFFS DEFENDANTS

Knoll, Inc. Senator International Limited d/b/a The Senator Group

(b) County of Residence of First Listed Plaintiff Montgomery County County of Residence of First Listed Defendant United Kingdom
(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)

Samantha L. Southall, Buchanan Ingersoll & Rooney PC, 50 S. 16th

Street, Suite 3200, Philadelphia, PA 19102, (215) 665-8700

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)
’ 1 U.S. Government ’ 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State ’ 1 ’ 1 Incorporated or Principal Place ’ 4 ’ 4
of Business In This State

’ 2 U.S. Government ’ 4 Diversity Citizen of Another State ’ 2 ’ 2 Incorporated and Principal Place ’ 5 ’ 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State

Citizen or Subject of a ’ 3 ’ 3 Foreign Nation ’ 6 ’ 6

Foreign Country
IV. NATURE OF SUIT (Place an “X” in One Box Only) Click here for: Nature of Suit Code Descriptions.
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
’ 110 Insurance PERSONAL INJURY PERSONAL INJURY ’ 625 Drug Related Seizure ’ 422 Appeal 28 USC 158 ’ 375 False Claims Act
’ 120 Marine ’ 310 Airplane ’ 365 Personal Injury - of Property 21 USC 881 ’ 423 Withdrawal ’ 376 Qui Tam (31 USC
’ 130 Miller Act ’ 315 Airplane Product Product Liability ’ 690 Other 28 USC 157 3729(a))
’ 140 Negotiable Instrument Liability ’ 367 Health Care/ ’ 400 State Reapportionment
’ 150 Recovery of Overpayment ’ 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS ’ 410 Antitrust
& Enforcement of Judgment Slander Personal Injury ’ 820 Copyrights ’ 430 Banks and Banking
’ 151 Medicare Act ’ 330 Federal Employers’ Product Liability ’ 830 Patent ’ 450 Commerce
’ 152 Recovery of Defaulted Liability ’ 368 Asbestos Personal ’ 835 Patent - Abbreviated ’ 460 Deportation
Student Loans ’ 340 Marine Injury Product New Drug Application ’ 470 Racketeer Influenced and
(Excludes Veterans) ’ 345 Marine Product Liability ’ 840 Trademark Corrupt Organizations
’ 153 Recovery of Overpayment Liability PERSONAL PROPERTY LABOR SOCIAL SECURITY ’ 480 Consumer Credit
of Veteran’s Benefits ’ 350 Motor Vehicle ’ 370 Other Fraud ’ 710 Fair Labor Standards ’ 861 HIA (1395ff) ’ 485 Telephone Consumer
’ 160 Stockholders’ Suits ’ 355 Motor Vehicle ’ 371 Truth in Lending Act ’ 862 Black Lung (923) Protection Act
’ 190 Other Contract Product Liability ’ 380 Other Personal ’ 720 Labor/Management ’ 863 DIWC/DIWW (405(g)) ’ 490 Cable/Sat TV
’ 195 Contract Product Liability ’ 360 Other Personal Property Damage Relations ’ 864 SSID Title XVI ’ 850 Securities/Commodities/
’ 196 Franchise Injury ’ 385 Property Damage ’ 740 Railway Labor Act ’ 865 RSI (405(g)) Exchange
’ 362 Personal Injury - Product Liability ’ 751 Family and Medical ’ 890 Other Statutory Actions
Medical Malpractice Leave Act ’ 891 Agricultural Acts
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS ’ 790 Other Labor Litigation FEDERAL TAX SUITS ’ 893 Environmental Matters
’ 210 Land Condemnation ’ 440 Other Civil Rights Habeas Corpus: ’ 791 Employee Retirement ’ 870 Taxes (U.S. Plaintiff ’ 895 Freedom of Information
’ 220 Foreclosure ’ 441 Voting ’ 463 Alien Detainee Income Security Act or Defendant) Act
’ 230 Rent Lease & Ejectment ’ 442 Employment ’ 510 Motions to Vacate ’ 871 IRS—Third Party ’ 896 Arbitration
’ 240 Torts to Land ’ 443 Housing/ Sentence 26 USC 7609 ’ 899 Administrative Procedure
’ 245 Tort Product Liability Accommodations ’ 530 General Act/Review or Appeal of
’ 290 All Other Real Property ’ 445 Amer. w/Disabilities - ’ 535 Death Penalty IMMIGRATION Agency Decision
Employment Other: ’ 462 Naturalization Application ’ 950 Constitutionality of
’ 446 Amer. w/Disabilities - ’ 540 Mandamus & Other ’ 465 Other Immigration State Statutes
Other ’ 550 Civil Rights Actions
’ 448 Education ’ 555 Prison Condition
’ 560 Civil Detainee -
Conditions of
Confinement
V. ORIGIN (Place an “X” in One Box Only)
’ 1 Original ’ 2 Removed from ’ 3 Remanded from ’ 4 Reinstated or ’ 5 Transferred from ’ 6 Multidistrict ’ 8 Multidistrict
Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation -
(specify) Transfer Direct File
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
35 U.S.C. §§ 271, 284, 285, 287, and/or 289
VI. CAUSE OF ACTION Brief description of cause:
Infringement of patent.
VII. REQUESTED IN ’ CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RULE 23, F.R.Cv.P. 200,000.00 JURY DEMAND: ’ Yes ’ No
VIII. RELATED CASE(S)
(See instructions):
IF ANY JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
10/02/2019 /s/ Samantha L. Southall
FOR OFFICE USE ONLY

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

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JS 44 Reverse (Rev. 02/19) Case 2:19-cv-04566-MAK Document 1-2 Filed 10/02/19 Page 2 of 2
INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44
Authority For Civil Cover Sheet

The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as
required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is
required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of
Court for each civil complaint filed. The attorney filing a case should complete the form as follows:

I.(a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use
only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and
then the official, giving both name and title.
(b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the
time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land
condemnation cases, the county of residence of the "defendant" is the location of the tract of land involved.)
(c) Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, noting
in this section "(see attachment)".

II. Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions be shown in pleadings. Place an "X"
in one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.
United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.
United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box.
Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment
to the Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes
precedence, and box 1 or 2 should be marked.
Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the
citizenship of the different 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 of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark this
section for each principal party.

IV. Nature of Suit. Place an "X" in the appropriate box. If there are multiple nature of suit codes associated with the case, pick the nature of suit code
that is most applicable. Click here for: Nature of Suit Code Descriptions.

V. Origin. Place an "X" in one of the seven boxes.

Original Proceedings. (1) Cases which originate in the United States district courts.
Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441.
Remanded from Appellate Court. (3) Check this box for cases remanded to the district court for further action. Use the date of remand as the filing
date.
Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date.
Transferred from Another District. (5) For cases transferred under Title 28 U.S.C. Section 1404(a). Do not use this for within district transfers or
multidistrict litigation transfers.
Multidistrict Litigation – Transfer. (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C.
Section 1407.
Multidistrict Litigation – Direct File. (8) Check this box when a multidistrict case is filed in the same district as the Master MDL docket. PLEASE
NOTE THAT THERE IS NOT AN ORIGIN CODE 7. Origin Code 7 was used for historical records and is no longer relevant due to changes in
statue.

VI. Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. Do not cite jurisdictional
statutes unless diversity. Example: U.S. Civil Statute: 47 USC 553 Brief Description: Unauthorized reception of cable service

VII. Requested in Complaint. Class Action. Place an "X" in this box if you are filing 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 of the JS 44 is used to reference related pending cases, if any. If there are related pending cases, insert the docket
numbers and the corresponding judge names for such cases.

Date and Attorney Signature. Date and sign the civil cover sheet.
Case 2:19-cv-04566-MAK Document 1-3 Filed 10/02/19 Page 1 of 1
 Case 2:19-cv-04566-MAK Document 1-4 Filed 10/02/19 Page 1 of 1
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA

CASE MANAGEMENT TRACK DESIGNATION FORM

KNOLL I INC. ' CIVIL ACTION

V.
SENATOR INTERNATIONAL LIMITED
DJB/A THE SENATOR GROUP NO. I q_ y:Jo6
In accordance with the Civil Justice Expense and Delay Reduction Plan of this court, counsel for
plaintiff shall complete a Case Management Track Designation Form in all civil cases at the time of
filing the complaint and serve a copy on all defendants. (See§ I :03 of the plan set forth on the reverse
side of this form.) In the event that a defendant does not agree with the plaintiff regarding said
designation, that defendant shall, with its first appearance, submit to the clerk of court and serve on
the plaintiff and all other parties, a Case Management Track Designation Form specifying the track
to which that defendant believes the case should be assigned.

SELECT ONE OF THE FOLLOWING CASE MANAGEMENT TRACKS:

(a) Habeas Corpus - Cases brought under 28 U.S.C. § 2241 through§ 2255. ( )
(b) Social Security - Cases requesting review of a decision of the Secretary of Health
and Human Services denying plaintiff Social Security Benefits. ( )

(c) Arbitration - Cases required to be designated for arbitration under Local Civil Rule 53.2. ( )
(d) Asbestos - Cases involving claims for personal injury or property damage from
exposure to asbestos. ( )

(e) Special Management - Cases that do not fall into tracks (a) through (d} that are
commonly referred to as complex and that need special or intense management by
the court. (See reverse side of this form for a detailed explanation of special
management cases.) (X)

(f) Standard Management - Cases that do not fall into any one of the other tracks.
3/
10/2/19 Samantha L. Southall Plaintiff
Date Attorney-at-law Attorney for
215-665-3884 215-665-8760 saroantha.southall@bipc.com

Telephone FAX Number E-Mail Address

(Civ. 660) l{)/{)2