Case 2:16-cv-15260 Document 1 Filed 10/05/16 Page 1 of 11

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF LOUISIANA

BLEACHBRIGHT L.L.C.,

Plaintiff,

v.

GLO SCIENCE, INC. & JBL RADICAL

INNOVATIONS, LLC,

Defendants.

Civil Action No.

Sec.
Judge
Mag.

COMPLAINT FOR DECLARATORY JUDGMENT OF

PATENT NON-INFRINGEMENT
NOW INTO COURT, through undersigned counsel, comes Plaintiff BleachBright L.L.C.
(hereinafter BleachBright or Plaintiff), who hereby presents this Complaint for Declaratory
Judgment of Patent Non-Infringement against Defendants GLO Science, Inc. and JBL Radical
Innovations, LLC (hereinafter collectively Defendants), and alleges as follows:
NATURE OF THE ACTION
1.

This is a civil action brought pursuant to the Declaratory Judgment Act, 28 U.S.C.

2201(a) and 2202, and FED. R. CIV. P. 57, seeking a declaratory judgment of non-infringement of
United States Design Patent No. D636,074 (hereinafter 074 Design Patent) and United States
Design Patent No. D765,255 (hereinafter 255 Design Patent) (hereinafter collectively Design
Patents) under the Patent Laws of the United States, 35 U.S.C. 100, et seq., so as to enable
BleachBright to continue its lawful activities of designing, developing, marketing, and supplying
its teeth whitening products sans Defendants nuisance and challenge of patent infringement that
intend to wrongfully restrain BleachBrights competition of non-infringing goods.

Case 2:16-cv-15260 Document 1 Filed 10/05/16 Page 2 of 11

THE PARTIES
2.

BleachBright is a limited liability company organized and existing under the laws of the

State of Louisiana with its principal place of business in Kenner, Louisiana. BleachBright is in
the business of designing, developing, marketing, and supplying its teeth whitening products
described herein, such as teeth whitening mouthpieces, and is Plaintiff here.
3.

Upon information and belief, JBL Radical Innovations, LLC (hereinafter JBL), the

patentee and apparent licensor of the Design Patents, is a limited liability company organized and
existing under the laws of the State of Delaware with its principal place of business at 923 Fifth
Avenue, New York, New York 10021, and is made Defendant here. JBL may be served with
process through its registered agent for service of process in Delaware, National Registered
Agents, Inc., at 160 Greentree Drive, Suite 101, Dover, Delaware 19904.
4.

Upon information and belief, GLO Science, Inc. (hereinafter GLO Science), a supplier

of teeth whitening products and the apparent exclusive licensee of JBLs patentee rights in relation
to the Design Patents, is a corporation organized and existing under the laws of the State of
Delaware with its principal place of business at 425 Madison Avenue, New York, New York
10017, and is made Defendant here. GLO Science may be served with process in accordance with
FED. R. CIV. P. 4(h) at its principal place of business at 425 Madison Avenue, New York, New
York 10017 by delivery to an officer, a managing or general agent, or any other agent authorized
by appointment or by law to receive service of process.
JURISDICTION AND VENUE
5.

This United States District Court has original and exclusive jurisdiction over the subject

matter of this civil action pursuant to 28 U.S.C. 1331 and 1338(a) for claims asserted herein
arising under the Patent Laws of the United States, 35 U.S.C. 100, et seq.

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6.

This United States District Court also has subject matter jurisdiction based upon an actual

controversy between the parties under the Declaratory Judgment Act, 28 U.S.C. 2201(a) and
2202, for the relief requested herein of declaratory judgment with respect to the Design Patents.
7.

This United States District Court may exercise jurisdiction over GLO Science on the

grounds that, inter alia, it and/or its agents have purposefully directed its activities to the State of
Louisiana and its residents, particularly its patent enforcement activities, including the mailing of
the enforcement letter described herein on behalf of JBL, in connection with a distribution
agreement with distributors headquartered within this State and District, so as to purposefully avail
itself of the privilege of conducting business within the State of Louisiana.
8.

This United States District Court may exercise jurisdiction over JBL on the grounds that,

inter alia, it and/or its agents have purposefully directed its activities to the State of Louisiana and
its residents, particularly its patent enforcement activities, including the authorization of the
mailing of the enforcement letter described herein, in connection with a licensing agreement with
GLO Science, who regularly does business within this State and District as described herein, so as
to purposefully avail itself of the privilege of conducting business within the State of Louisiana.
9.

Venue is proper in this District, the Eastern District of Louisiana, under 28 U.S.C.

1391(b) and 1391(c) on the grounds that, inter alia, Defendants are subject to personal jurisdiction
in this District.
CASE AND CONTROVERSY
074 Design Patent
10.

The 074 Design Patent entitled MOUTHPIECE indicates it was issued by the United

States Patent and Trademark Office (hereinafter USPTO) on April 12, 2011. A true and correct
copy of the 074 Design Patent is attached hereto as Exhibit A.

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11.

The 074 Design Patent claims priority to United States Patent Application No. 29/363,728,

which was filed on June 14, 2010 by inventor Jonathan B. Levine (hereinafter Levine).
12.

JBL currently claims to have right, title, and interest in the 074 Design Patent as the

patentee by assignment, per the Assignment of Assignors Interest, executed by Mr. Levine on
January 5, 2011 and subsequently recorded with the USPTO on February 14, 2011.
13.

Upon information and belief, JBL is the patentee of the 074 Design Patent on behalf and

to the benefit of GLO Science and its ownership, as they are affiliated to each other.
14.

GLO Science is the exclusive licensee of the 074 Design Patent, per Defendants

representations.
15.

Upon information and belief, Defendants licensing agreement structures a relationship

beyond mere receipt of royalty income due to the fact that, inter alia, GLO Science, the exclusive
supplier of teeth whitening products covered by the 074 Design Patent in the State of Louisiana,
undertook the obligation of enforcing the 074 Design Patent on behalf of JBL. As manifested,
each defendant holds the right to enforce the 074 Design Patent in the State of Louisiana.
255 Design Patent
16.

The 255 Design Patent entitled MOUTHPIECE indicates it was issued by the USPTO

on August 30, 2016. A true and correct copy of the 255 Design Patent is attached hereto as Exhibit
B.
17.

The 255 Design Patent claims priority to United States Patent Application No. 29/492,179,

which was filed on May 29, 2014 by inventor Levine.

18.

JBL currently claims to have right, title, and interest in the 255 Design Patent as the

patentee by assignment.

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Case 2:16-cv-15260 Document 1 Filed 10/05/16 Page 5 of 11

19.

Upon information and belief, JBL is the patentee of the 255 Design Patent on behalf and

to the benefit of GLO Science and its ownership, as they are affiliated to each other.
20.

GLO Science is the exclusive licensee of the 255 Design Patent, per Defendants

representations.
21.

Upon information and belief, Defendants licensing agreement structures a relationship

beyond mere receipt of royalty income due to the fact that, inter alia, GLO Science, the exclusive
supplier of teeth whitening products covered by the 255 Design Patent in the State of Louisiana,
undertook the obligation of enforcing the 255 Design Patent on behalf of JBL. As manifested,
each defendant holds the right to enforce the 255 Design Patent in the State of Louisiana.
Defendants Supply and Distribution of Products Covered by the Design Patents
in the State of Louisiana and this District, and Enforcement Thereof
22.

Upon information and belief, GLO Science is the exclusive supplier of teeth whitening

products covered by the Design Patents, which are distributed solely through licensed dentists, in
the State of Louisiana.
23.

Upon information and belief, relying on the GLO Dentist Locator found on GLO

Sciences website, www.gloscience.com, Doctor Gary Parker distributes Defendants products to

residents of Louisiana. Doctor Gary Parker is a licensed dentist in the State of Louisiana and of
Gary A. Parker, D.D.S. A Professional Dental Corporation, a corporation organized and existing
under the laws of the State of Louisiana, located in Bogalusa of Washington Parish.
24.

Upon information and belief, relying on the GLO Dentist Locator found on GLO

Sciences website, www.gloscience.com, Doctor Gary Parker is the exclusive distributor found
within this District.

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Case 2:16-cv-15260 Document 1 Filed 10/05/16 Page 6 of 11

Defendants Purported Monopoly on Teeth Whitening Mouthpieces

25.

BleachBright designs, develops, markets, and supplies teeth whitening products, including

the IBRIGHT teeth whitening system (hereinafter IBRIGHT).

26.

IBRIGHTs design was released into the market as early as July of 2016.

27.

Defendants sent a letter, dated July 22, 2016, from counsel of Defendants to BleachBright

(hereinafter Patent Enforcement Letter), which suggested that BleachBright infringed

Defendants Design Patents. A true and correct copy of the Patent Enforcement Letter is attached
hereto as Exhibit C.
28.

Defendants Patent Enforcement Letter provided no analysis as to how BleachBrights

IBRIGHT is remarkably similar and may infringe the Design Patents besides merely being a
mouthpiece used for teeth whitening purposes.
29.

Nevertheless, Defendants arbitrarily created a deadline for response and demanded that

BleachBright respond to the Patent Enforcement Letter in order to defend its IBRIGHT product
extra-judicially.
30.

In further support of the Patent Enforcement Letter, Defendants counsel sent an e-mail on

September 5, 2016 to BleachBright (hereinafter Patent Enforcement Follow-Up), and reiterated

their position, further suggesting that BleachBright infringed Defendants Design Patents. A true
and correct copy of the Patent Enforcement Follow-Up is attached hereto as Exhibit D.
31.

Defendants Patent Enforcement Follow-Up also provided no analysis as to how

BleachBrights IBRIGHT is remarkably similar and may infringe the Design Patents besides
merely being a mouthpiece used for teeth whitening purposes.

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Case 2:16-cv-15260 Document 1 Filed 10/05/16 Page 7 of 11

32.

Nevertheless, Defendants arbitrarily created a second deadline for response and demanded

that BleachBright respond in accordance with the Patent Enforcement Letter in order to defend its
IBRIGHT product extra-judicially.
33.

Granted the above characterization of the Patent Enforcement Letter and subsequent

communication, Defendants are claiming a monopoly on all mouthpieces used for teeth whitening
purposes, citing the Design Patents.
34.

However, the Design Patents are limited in scope and do not disclose protection over all

mouthpieces used for teeth whitening purposes.

35.

Therefore, Defendants unlawfully claim a monopoly over all mouthpieces used for teeth

whitening purposes when asserting that Plaintiffs IBRIGHT is remarkably similar and may
infringe the Design Patents by merely being a mouthpiece.

Accordingly, BleachBrights

IBRIGHT does not infringe, either directly or indirectly, any valid and enforceable claim of the
Design Patents either literally or under the doctrine of equivalents.
36.

Defendants Patent Enforcement Letter and Patent Enforcement Follow-Up are

unequivocally implying a threat of litigation against BleachBright by virtue of the foregoing

demands and allegations outlined therein.
37.

Defendants Patent Enforcement Letter and Patent Enforcement Follow-Up place a cloud

of fear, uncertainty, and doubt over BleachBrights IBRIGHT and relationships with its
manufacturer, potential distributors, and customers, when BleachBrights IBRIGHT does not
infringe, either directly or indirectly, any valid and enforceable claim of the Design Patents, either
literally or under the doctrine of equivalents.
38.

BleachBrights legal rights are clearly adverse with Defendants allegations and interests.

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Case 2:16-cv-15260 Document 1 Filed 10/05/16 Page 8 of 11

39.

The aforementioned demands, threat of litigation, and cloud of fear, uncertainty, and doubt

will persist absent a resolution of the claim of patent infringement alleged by Defendants in the
Patent Enforcement Letter.
40.

This controversy is amenable to specific relief through a decree of conclusive character

from this Court.

41.

Notwithstanding the following, BleachBright retains the right to assert affirmative defenses

(e.g., patent exhaustion or misuse) as an alternative route of protection of its rights in response to
any counter-claim asserted by Defendants.
FEDERAL CLAIMS
Count I, Declaratory Judgment of Non-Infringement of the 074 Design Patent
28 U.S.C. 2201(a), 2202
42.

BleachBright hereby re-alleges and incorporates by reference each and every preceding

allegation contained in Paragraphs 1 through 41 hereof as if fully set forth herein.

43.

BleachBright has a reasonable apprehension that Defendants will file a lawsuit against

BleachBright alleging infringement of the 074 Design Patent.

44.

BleachBright, and its products, including IBRIGHT, did not infringe and are not infringing,

whether directly or indirectly through contributory or induced infringement, either literally or

under the doctrine of equivalents, any valid and enforceable claim of the 074 Design Patent by
engaging in any act of infringement, including manufacturing, importing, marketing, using,
selling, or offering to sell products that embody any patentable and patented design described in
the 074 Design Patent. Accordingly, BleachBrights activities do not violate 35 U.S.C. 271.
45.

BleachBright, and its products, including IBRIGHT, did not infringe and are not infringing

any valid and enforceable claim of the 074 Design Patent either by applying any patentable and
patented design, or any colorable imitation thereof, described in the 074 Design Patent to any

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Case 2:16-cv-15260 Document 1 Filed 10/05/16 Page 9 of 11

article of manufacture for the purpose of sale or by selling or exposing for sale any article of
manufacture to which such design or colorable imitation has been applied.

Accordingly,

BleachBrights activities do not violate 35 U.S.C. 289.

46.

A judicial declaration is both necessary and appropriate so that BleachBright may ascertain

its rights to manufacture, import, market, use, sell, or offer to sell its products, including IBRIGHT,
in light of the 074 Design Patent broadly asserted against BleachBright in the Patent Enforcement
Letter.
47.

Consequently, a substantial and continuing controversy of sufficient immediacy and reality

exists, constituting as a valid and justiciable controversy between the parties that warrants the
issuance of a declaratory judgment under 28 U.S.C. 2201(a), 2202 and FED. R. CIV. P. 57 that
BleachBrights manufacture, import, market, use, sale, or offer for sale of its products did not
infringe and are not infringing, directly or indirectly through contributory or induced infringement,
any valid and enforceable claim of the 074 Design Patent in violation of the Patent Laws of the
United States, 35 U.S.C. 100, et seq.
Count II, Declaratory Judgment of Non-Infringement of the 255 Design Patent
28 U.S.C. 2201(a), 2202
48.

BleachBright hereby re-alleges and incorporates by reference each and every preceding

allegation contained in Paragraphs 1 through 47 hereof as if fully set forth herein.

49.

BleachBright has a reasonable apprehension that Defendants will file a lawsuit against

BleachBright alleging infringement of the 255 Design Patent.

50.

BleachBright, and its products, including IBRIGHT, did not infringe and are not infringing,

whether directly or indirectly through contributory or induced infringement, either literally or

under the doctrine of equivalents, any valid and enforceable claim of the 255 Design Patent by
engaging in any act of infringement, including manufacturing, importing, marketing, using,

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Case 2:16-cv-15260 Document 1 Filed 10/05/16 Page 10 of 11

selling, or offering to sell products that embody any patentable and patented design described in
the 255 Design Patent. Accordingly, BleachBrights activities do not violate 35 U.S.C. 271.
51.

BleachBright, and its products, including IBRIGHT, did not infringe and are not infringing

any valid and enforceable claim of the 255 Design Patent either by applying any patentable and
patented design, or any colorable imitation thereof, described in the 255 Design Patent to any
article of manufacture for the purpose of sale or by selling or exposing for sale any article of
manufacture to which such design or colorable imitation has been applied.

Accordingly,

BleachBrights activities do not violate 35 U.S.C. 289.

52.

A judicial declaration is both necessary and appropriate so that BleachBright may ascertain

its rights to manufacture, import, market, use, sell, or offer to sell its products, including IBRIGHT,
in light of the 255 Design Patent broadly asserted against BleachBright in the Patent Enforcement
Letter.
53.

Consequently, a substantial and continuing controversy of sufficient immediacy and reality

exists, constituting as a valid and justiciable controversy between the parties that warrants the
issuance of a declaratory judgment under 28 U.S.C. 2201(a), 2202 and FED. R. CIV. P. 57 that
BleachBrights manufacture, import, market, use, sale, or offer for sale of its products did not
infringe and are not infringing, directly or indirectly through contributory or induced infringement,
any valid and enforceable claim of the 255 Design Patent in violation of the Patent Laws of the
United States, 35 U.S.C. 100, et seq.
PRAYER FOR RELIEF
WHEREFORE, BleachBright respectfully requests that this Court enter judgment in its
favor and against Defendants on all claims for relief asserted herein, as follows:

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Case 2:16-cv-15260 Document 1 Filed 10/05/16 Page 11 of 11

A.

Declaring that BleachBright and its product, IBRIGHT, did not infringe and are not

infringing any valid and enforceable claim of the 074 Design Patent in violation of the Patent
Laws of the United States, 35 U.S.C. 100, et seq.;
B.

Declaring that BleachBright and its product, IBRIGHT, did not infringe and are not

infringing any valid and enforceable claim of the 255 Design Patent in violation of the Patent
Laws of the United States, 35 U.S.C. 100, et seq.;
C.

Enjoining, preliminarily and permanently, Defendants and their officers, directors,

employees, servants, agents, affiliates, attorneys, and all others acting in privity or in concert with
any of them, and their parents, subsidiaries, divisions, successors and assigns, from asserting,
including filing or prosecuting any civil action, or threatening to assert any charge of infringement
of the Design Patents against manufacturers, distributors, customers, potential customers, or users
of BleachBrights product, IBRIGHT;
D.

Declaring this to be an exceptional case and awarding BleachBright its costs and expenses

in this action, including reasonable attorneys fees pursuant to 35 U.S.C. 285; and
E.

Granting BleachBright such other and further relief as this Court deems just and proper.

Dated: October 5, 2016

Respectfully submitted,
/ Thomas S. Keaty /
Keaty Law Firm
Thomas S. Keaty 7666, T.A.
365 Canal Street, Suite 2410
New Orleans, Louisiana 70130
Tel.: (504) 524-2100
Fax: (504) 524-2105
tskeaty@keatypatentfirm.com
Attorney for Plaintiff

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