UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA

ORLANDO DIVISION CLIC GOGGLES, INC., Plaintiff, v. LISA MORRISON, an individual, and LEO KOZLOSKI, an individual, collectively d/b/a PSI PHOTO SHOP a/k/a PSI SUPPLY, Defendants.

Civil Action No.: 6:15-cv-621-Orl-28GJK

FIRST AMENDED COMPLAINT FOR PATENT INFRINGEMENT INJUNCTIVE RELIEF SOUGHT AND DEMAND FOR JURY TRIAL

Plaintiff, CliC Goggles, Inc. (hereinafter “CliC”), by and through undersigned

counsel, hereby sues Defendants, Lisa Morrison and Leo Kozloski (hereinafter

“Defendants”), and alleges as follows:

NATURE OF THE ACTION 1. This is an action for patent infringement in connection with Defendants’

making, importing, offering for sale and selling lightweight, front-connecting eyewear

that are virtually identical to eyewear inventions covered by a United States utility patent

owned and duly assigned to CliC. Defendants have obtained and are selling in the United

States through the Internet knock-offs of the patented CliC eye ware. Defendants’

infringing conduct has damaged CliC and inflicted irreparable harm.

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2. CliC seeks, inter alia, disgorgement of Defendants’ profits from the sale

of infringing products, and injunctive relief.

JURISDICTION AND VENUE

3. This Court has original jurisdiction over the claims for patent infringement

under 28 U.S.C. §§ 1331 and 1338(a) in that said claims arise under the Patent Laws of

the United States, 35 U.S.C. § 1 et seq.”

4. This Court has in personam jurisdiction over Defendants pursuant to FLA.

STAT. § 48.193, in that: (a) Defendants are operating, conducting, engaging or carrying

on a business, in the State of Florida; (b) Defendants have committed tortious acts within

the State of Florida; and (c) Defendants are engaged in substantial and not isolated

activity within the State of Florida.

5. Venue is proper in this District pursuant to 28 U.S.C. § 1391(b) because

Defendants are residents in this District and because a substantial part of the events

giving rise to the claim occurred in this District.

THE PARTIES 6. CliC is a corporation organized and existing under the laws of California,

with its principal place of business located at 408 Tamal Plaza Corte Madera, CA 94925.

7. Upon information and belief, Defendant Lisa Morrison (“Morrison”) is an

individual residing at 1515 State Avenue, Unit L, Holly Hill, Florida, 32117.

8. Upon information and belief, Defendant Leo Kozloski (“Kozloski”) is an

individual residing at 1515 State Avenue, Unit L, Holly Hill, Florida, 32117.

9. Upon information and belief, Morrison and Kozloski have done business

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and are presently doing business under the name PSI PHOTO SHOP and/or PSI

SUPPLY.

10. Upon information and belief, Morrison and Kozloski were managers of a

now-dissolved Florida limited liability company named PSI SUPPLY, INC., with a

principal place of business at 1515 State Avenue, Unit L, Holly Hill, Florida 32117.

CLIC’S BUSINESS

11. Since 2000, CliC has been involved in the business of manufacturing high

quality eyewear, including its innovative lightweight front-connecting eyewear sold in a

variety of markets.

12. CliC offers a variety of eyewear including reading glasses, sunglasses,

goggles, and medical-specific eyewear. All of CliC’s glasses include several innovative

features including a magnetic front closure system at the bridge of the glasses which

facilitates putting on and taking off the glasses. Some of CliC’s glasses also include an

adjustable headband that allows the headband or strap of the glasses to expand or contract

to fit most customers.

13. CliC products are sold throughout the world, including in the United

States and have been a critical success. Indeed, Time Magazine has called CliC’s front

connection technology “the best eyewear innovation since glasses were invented.”

14. As a result of the originality and high quality of its products, CliC has

developed a reputation for excellence and innovation which has generated millions of

dollars in sales and many loyal customers.

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THE CLIC PATENT

15. On July 3, 2001, U.S. Patent No. 6,253,388 (the “388 Patent”), entitled

“Eye Wear with Snap-Together Bridge” was issued by the United States Patent and

Trademark Office, covering an useful eyewear invention. The application from which

the ‘388 Patent issued was filed on December 31, 1999. A true and correct copy of the

‘388 Patent is attached as Exhibit “A” hereto.

16. CliC is the owner by assignment of the ‘388 Patent. CliC has owned the

‘388 Patent during all times relevant to allegations herein. A true and correct copy of the

electronic records pertaining to the assignment information for the ‘388, reflecting CliC

as the owner thereof, is attached as Exhibit “B” hereto.

17. The ‘388 Patent in full force and effect as of the date of this Complaint

and all times relevant to the allegations herein.

18. Subsequent to the filing of the ‘388 Patent, CliC began manufacturing and

selling a line of front-connecting eyewear embodying the invention covered by the ‘388

Patent. These products were and are presently sold under the CLIC trademark. True and

correct copies of pages from CliC’s product catalog illustrating these eyewear products

are attached as Exhibit “C” hereto.

19. All eye-wear embodying the ‘388 Patent sold by CliC since the issuance

of the ‘388 Patent bear the marking “U.S. PAT. 6,253,388.”

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DEFENDANTS’ ACTS OF INFRINGEMENT 20. At least as early as 2015, CliC became aware that Defendants were selling

through eBay “Clic Style” eyewear embodying the invention in the ‘388 Patent.

21. On information and belief, Defendants are operating an eBay account

under the username “psi_photo_supply” and/or “Psi Supply” through which Defendants

offer for sale and sell eyewear embodying the invention in the ‘388 Patent. A true and

correct copy of Defendants’ eBay homepage is attached as Exhibit “D” hereto. A true

and correct copy of Defendants’ eBay listing for “Clic Style MAGNETIC Reading

Glasses FRONT CONNECT Adjustable Readers All Colors” obtained on March 24,

2015 is attached as Exhibit “E” hereto.

22. On February 18, 2015, CliC wrote to Defendants, informing Defendants of

CliC’s patent rights and placing Defendants on notice that they were infringing CliC’s

patents by selling knock-off eyewear embodying the inventions in the patent. Defendants

did not respond. A true and correct copy of the February 15, 2015 letter is attached as

Exhibit “F” hereto.

23. On March 4, 2015, CliC again wrote to Defendants, reasserting its patent

rights and again informing Defendants that they were infringing CliC’s patent. The letter

further asserted that, following receipt of the February 18, 2015 letter, Defendants had

dropped the listing price of the infringing eyewear from $18.32 per unit to $14.97 per

unit in an attempt to “dump” the infringing goods. Defendants did not respond. A true

and correct copy of the March 3, 2015 letter is attached as Exhibit “G” hereto.

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24. On information and belief, Defendants have offered for sale and sold,

through the Internet on eBay and through other means, the knock-off eyewear to

consumers throughout the United States, including within this District.

25. The knock-off eyewear sold by Defendants are in all respects virtually

identical copies of CliC front-connecting eyewear and of the invention covered by the

‘388 Patent. To wit, attached as Exhibits “H” hereto is a chart comparing the invention

claimed in the ’388 Patent with CliC’s genuine eyewear and Defendants’ infringing

eyewear.

COUNT I INFRINGEMENT OF U.S. PATENT NO. 6,253,288

26. CliC re-alleges and incorporates hereto by reference paragraphs 1-25 of

this Complaint as though fully set forth herein.

27. Defendants have infringed and continue to infringe the ‘388 Patent.

Defendants have sold and offered for sale eyewear that are virtually identical to and

embody the invention claimed in the ‘388 Patent, and will continue to do so unless

enjoined by this Court.

28. In addition, through the sale of its knock-off eyewear products to

consumers knowing such consumers would use and wear such eyewear in conventional

fashion, Defendants have induced infringement of the ‘388 Patent by others and have

committed acts of contributory infringement of the ‘388 Patent.

29. CliC has complied with the notice requirement prescribed by 35 U.S.C.

§287 and has otherwise given Defendants actual notice of infringement.

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7

30. Defendants’ infringement of the ‘388 Patent has been willful and

malicious and with actual or constructive knowledge that CliC is the owner of a patent

claiming the infringed invention.

31. CliC has sustained damages as a result of the infringing acts of

Defendants.

32. CliC has suffered and will continue to suffer irreparable harm unless

Defendants’ infringement of the ‘388 Patent is enjoined.

WHEREFORE, Plaintiff CliC prays that the Court:

A. Enter a judgment that Defendants have infringed, induced infringement

and contributed to the infringement of U.S. Patent No. 6,253,388;

B. Order Defendants to pay damages under 35 U.S.C. 285 and 289 to

adequately compensate CliC for Defendants’ patent infringement, including an award of

Defendants’ profits from its infringement of U.S. Patent Nos. 6,253,388 together with

pre- and post-judgment interest;

C. Enter an order permanently enjoining Defendants, their officers, agents,

servants, employees, attorneys, receivers, trustees and other fiduciaries, and all other

persons in active participation with Defendants from importing, selling, offering for sale,

or using of any device that infringes the invention embodied and claimed in the ‘388

Patent;

D. Find that Defendants’ patent infringement was willful and malicious and

award treble damages to CliC under 35 U.S.C. § 284;

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8

E. Find this to be an exceptional case of patent infringement and award

reasonable attorneys’ fees to CliC under 35 U.S.C. § 285;

F. Award such other and further relief as the Court deems just and equitable.

DEMAND FOR JURY TRIAL

CliC hereby demands a trial by jury of all issues so triable.

Dated: March 29, 2016 Respectfully submitted,

s/Geoffrey Lottenberg_____ Barry L. Haley, Esq. Fla. Bar No. 123,351 Email: blh@mhdpatents.com

Geoffrey Lottenberg, Esq. Fla. Bar No. 56,240 Email: gl@mhdpatents.com

MALIN HALEY DiMAGGIO & BOWEN, P.A. 1936 South Andrews Ave. Fort Lauderdale, FL 33316 Telephone: (954) 763-3303 Facsimile: (954) 522-6507 Counsel for Plaintiff CliC Goggles, Inc.

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9

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing was filed electronically

with the Clerk of the Court using the CM/ECF, and will be served on all counsel of record. I

also certify that the foregoing document is being served by process server on March 29,

2016 on all counsel or parties who are not authorized to receive Notices of Electronic

Filings.

Dated: March 29, 2016 By: s/Geoffrey Lottenberg

Geoffrey Lottenberg, Esq.

SERVICE LIST Lisa Morrison 1515 State Avenue, Unit L Holly Hill, Florida 32117 Leo Kozloski 1515 State Avenue, Unit L Holy Hill, Florida 32117

Case 6:15-cv-00621-JA-GJK Document 20 Filed 03/29/16 Page 9 of 9 PageID 226

EXHIBIT A

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United States Patent US006253388B1

(12) (10) Patent N0.: US 6,253,388 B1 Lando (45) Date of Patent: Jul. 3, 2001

(54) EYE WEAR WITH SNAP-TOGETHER 5,390,373 * 2/1995 Flory ...................................... .. 2/430 BRIDGE 5,940,162 * 8/1999 Wong .... .. 351/47

6,012,811 * 1/2000 Chao et a1. . 351/47

(76) Inventor: Ronald Lando, 55 Aptos Ave., San 670767926 * 6/2000 Kostka 351/113 Francisco, CA (Us) 94127 6,098,207 * 8/2000 Burtm .................................... .. 2/431

* . .

( * ) Notice: Subject to any disclaimer, the term of this cued by exammer

patent is extended or adjusted under 35 Primary Examiner_JOhn J_ Calvert U'S'C' 154(k)) by 0 days‘ Assistant Examiner—Katherine Moran

(74) Attorney, Agent, or Firm—Jack Lo (21) Appl. N0.: 09/476,587

(57) ABSTRACT (22) Filed: Dec. 31, 1999

The present eye wear is comprised of a pair of lenses, a pair (51) Int- Cl-7 -- ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ " A61F 9/02 of releasable connectors connected to respective inner ends

U-S- Cl- ...................... .. of the lenses, a pair of temples pivotally Connected to 351/124 respective outer ends of the lenses, and a rigid strap attached

(58) Field of Search ..................... .. 2/426—430, 445—448, between the rear ends of the temples. The strap is positioned 2/454, 452; 351/41, 43, 44, 53, 65, 68, below the lenses so as to not interfere with a hairdo or

98, 124, 125, 133, 118; 600/9, 15; 24/303 helmet. The inner ends of the lenses are releasably secured together by the connectors. To wear, the lenses are separated

(56) References Cited from each other and pivoted outwardly, the strap is wrapped U'S' PATENT DOCUMENTS around the back of the head, and the'lenses are pivoted

toward each other and secured together in front of the eyes. 466,896 * 1/1892 Warren ................................... .. 2/426 The lenses are instantly separable for easily putting on or 871,762 * 11/1907 Meyrowitz 2/426 taking off the eye wear, but they are instantly connectable

1,254,090 * 7/1918 TT°PPI_nan 2/426 together for a secure and accurate ?t. In a second 177607650 * 5/1930 Kruenmg "" " 2/426 embodiment, the strap is comprised of an adjustable-length 2,128,085 * 8/1938 Fischer . . . . . . . . . . . . .. 2/426 ?exible Strap‘

4,479,703 * 10/1984 Enghofer 351/123 4,610,519 * 9/1986 Hyman . . . . . . . . . . . . . . .. 351/86

5,110,198 * 5/1992 Travis et a1. ....................... .. 351/124 14 Claims, 4 Drawing Sheets

Case 6:15-cv-00621-JA-GJK Document 20-1 Filed 03/29/16 Page 2 of 38 PageID 228

U.S. Patent Jul. 3, 2001 Sheet 1 0f 4 US 6,253,388 B1

Case 6:15-cv-00621-JA-GJK Document 20-1 Filed 03/29/16 Page 3 of 38 PageID 229

U.S. Patent Jul. 3, 2001 Sheet 2 0f 4 US 6,253,388 B1

Fig.4

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U.S. Patent Jul. 3, 2001 Sheet 4 0f 4 US 6,253,388 B1

Case 6:15-cv-00621-JA-GJK Document 20-1 Filed 03/29/16 Page 6 of 38 PageID 232

US 6,253,388 B1 1

EYE WEAR WITH SNAP-TOGETHER BRIDGE

BACKGROUND OF THE INVENTION

1. Field of the Invention

This invention relates generally to eye Wear.

2. Prior Art

Eye Wear includes glasses and goggles. Each one typi cally includes a pair of lenses ?xedly connected by a bridge at the inner ends, and a pair of temples hinged to the respective outer ends of the lenses. The rear ends of the temples are disconnected from each other, so that the temples are foldable against the back of the lenses for storge. The eye Wear is put on by opening the temples, positioning them on the sides of the Wearer’s head, and pushing them through the hair and the respective gaps betWeen the ears and the sides of the head. This procedure is a little cumbersome, and occasionally the Wearer is poked in the eye by one of the temples during the process. A retainer strap is sometimes attached betWeen the

temples for hanging the eye Wear on the neck When it is not being Worn. The strap must be looped over the head, Which makes the eye Wear even more cumbersome to put on, and may also disturb a hairdo When looping over the head.

Stylish “DOUBLE MONOCLE” sunglasses offered by Chanel depart from the traditional construction of eye Wear by not having a bridge. It includes a pair of lenses Which are disconnected at their inner ends. A rigid horiZontal loop is positioned behind the lenses and connected betWeen their outer ends. The loop includes a pair of temple sections coplanar With a rear section, and a pair of doWnWardly projecting ear hooks. Because the lenses are completely disconnected at their inner ends, they are dif?cult or even impossible to be aligned With each other. They Would be so loose on the Wearer that they cannot be accurately positioned in front of the eyes. The rear section of the loop is positioned high on the back of the head, so that it Will interfere With a hairdo or a helmet. The loop is not hinged to the lenses, so that the glasses are dif?cult to put on.

OBJECTIVES OF THE INVENTION

Accordingly, the objectives of the present eye Wear are:

to be easily put on Without poking the eye; to position lenses accurately in front of the eyes; to be completely stable and secure When Worn;

to be easily removed; to not interfere With a hairdo or helmet When Worn; and

to conveniently hang around a neck When not being Worn.

Further objectives of the present invention Will become apparent from a consideration of the draWings and ensuing description.

BRIEF SUMMARY OF THE INVENTION

The present eye Wear is comprised of a pair of lenses, a pair of releasable connectors connected to respective inner ends of the lenses, a pair of temples pivotally connected to respective outer ends of the lenses, and a rigid strap attached betWeen the rear ends of the temples. The strap is positioned beloW the lenses so as to not interfere With a hairdo or

helmet. The inner ends of the lenses are releasably secured together by the connectors. To Wear, the lenses are separated from each other and pivoted outWardly, the strap is Wrapped around the back of the head, and the lenses are pivoted

15

25

35

45

55

65

2 toWard each other and secured together in front of the eyes. The lenses are instantly separable for easily putting on or taking off the eye Wear, but they are instantly connectable together for a secure and accurate ?t. In a second embodiment, the strap is comprised of an adjustable-length ?exible strap.

BRIEF DESCRIPTION OF THE SEVERAL VIEWS OF THE DRAWING

FIG. 1 is a front perspective vieW of the present eye Wear.

FIG. 2 is a side perspective vieW thereof.

FIG. 3 is a front perspective vieW thereof When a pair of lenses are separated.

FIG. 4 is a front perspective vieW thereof When Worn on a person.

FIG. 5 is a front perspective vieW thereof When hung around the neck of the person.

FIG. 6 is a side perspective vieW of a second embodiment thereof.

DRAWING REFERENCE NUMERALS

10. Lenses 11. Connectors 12. Temples 13. Rigid Strap 14. Frames 15. Vents 16. Hooked Portions 17. Flexible Strap 18. Cinch 19. Temples

DETAILED DESCRIPTION OF THE INVENTION

A ?rst embodiment of the present eye Wear is shoWn in a front perspective vieW in FIG. 1 and a side perspective vieW in FIG. 2. It is comprised of a pair of lenses 10, a pair of releasable connectors 11 connected to respective inner ends of lenses 10, a pair of temples 12 connected to respective outer ends of lenses 10, and a generally rigid strap 13 attached betWeen rear ends of temples 12.

Lenses 10 are preferably mounted in respective frames 14 Which are provided With vents 15. Connectors 11 are pref erably attached to respective inner ends of frames 14. Temples 12 are preferably telescopic for ?tting different Wearers. Temples 12 are preferably pivoted to the respective outer ends of frames 14. Temples 12 preferably include hooked portions 16 for hooking around the ears. Strap 13 is positioned beloW lenses 10 so as to avoid interfering With a hairdo or helmet. Strap 13 should be springy enough to retain its shape When released, but are preferably also ?exible enough to be bendable to some extent Without breaking. Alternatively, strap 13 may be at the same level as temples 12, but at the loss of some advantages.

Alternatively, connectors 11 and temples 12 may be attached directly to lenses 10. Connectors 11 are preferably comprised of magnets, such as neodymium-iron-boron magnets, for maximum convenience When connecting and disconnecting, but they may be any type of releasable connectors, such as latches, hook-and-loop fasteners, etc. When connectors 11 are connected together, they form a bridge betWeen lenses 10. Although the eye Wear is shoWn as a pair of goggles, it may also be a pair of glasses. The inner ends of lenses 10 are releasably secured

together by connectors 11. To Wear, lenses 10 are separated from each other and pivoted outWardly, as shoWn in FIG. 3, strap 13 is Wrapped around the back of the head, and lenses

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US 6,253,388 B1 3

10 are pivoted back toward each other and connected together in front of the eyes, as shoWn in FIG. 4. The secure connection betWeen lenses 10 ensures that they are accu rately positioned in front of the eyes. Because the present eye Wear is put on from the back of the head, it Will never poke the Wearer in the eye. Lenses 10 are instantly separable for easily putting on or taking off the eye Wear, but are instantly connectable together for a secure and accurate ?t. When the eye Wear is not being Worn, lenses 10 are separated and hung around the neck under strap 13, as shoWn in FIG. 5.

In a second embodiment, lenses 10 are connected betWeen their outer ends by a completely ?exible strap 17, such as a fabric or rubber strap, Which is adjustable in length With a cinch 18 movable there along. Alternatively, strap 17 may be adjusted With other devices, such as a buckle, snaps, etc. Strap 17 is attached to the rear ends of temples 19 as shoWn, or it may be attached directly to the outer ends of frames 14.

Accordingly, the present eye Wear is easily put on Without poking the eye. It positions the lenses accurately in front of the eyes. It is completely stable and secure When Worn. It is easily removed. It generally does not interfere With a helmet When Worn. It can be conveniently hung around a neck When not being Worn.

Although the above description is speci?c, it should not be considered as a limitation on the scope of the invention, but only as an example of the preferred embodiment. Many variations are possible Within the teachings of the invention. Therefore, the scope of the invention should be determined by the appended claims and their legal equivalents, not by the examples given.

I claim: 1. An eye Wear, comprising:

a pair of lenses; a pair of releasable connectors connected to respective

inner ends of said lenses, said connectors being securely connectable together and releasable from each other;

a pair of temples connected to respective outer ends of said lenses; and

a strap connected betWeen rear ends of said temples, said strap being rigid enough to generally retain its shape When said connectors are released, and springy enough to be bendable When ?exed and rebounding When released;

Wherein When said connectors are released from each other, said inner ends of said lenses are separable from each other so that said eye Wear is easy to put on and remove, and When said connectors are connected together, said lenses are secured in position relative to each other for secure and stable positioning in front of a pair of eyes.

2. The eye Wear of claim 1, Wherein said connectors are comprised of magnets.

3. The eye Wear of claim 1, Wherein said temples are comprised of telescopic temples for ?tting different Wearers.

4. The eye Wear of claim 1, Wherein said temples are pivotally connected to said lenses, so that When said con nectors are released from each other, said inner ends of said lenses are pivotable outWardly for making Wearing easier.

5. The eye Wear of claim 1, further including a pair of frames, said lenses being respectively mounted in said frames, said connectors being attached to respective inner

15

25

35

45

55

4 ends of said frames, said temples being attached to respec tive outer ends of said frames.

6. An eye Wear, comprising: a pair of lenses; a pair of releasable connectors connected to respective

inner ends of said lenses, said connectors being securely connectable together and releasable from each other;

a pair of temples connected to respective outer ends of said lenses, rear ends of said temples being hooked doWnWard for Wrapping around a pair of ears; and

a strap connected betWeen said rear ends of said temples, said strap being rigid enough to generally retain its shape When said connectors are released, and springy enough to be bendable When ?exed and rebounding When released, said strap being positioned beloW said lenses for avoiding interfering With a hairdo or a

helmet; Wherein When said connectors are released from each

other, said inner ends of said lenses are separable from each other so that said eye Wear is easy to put on and remove, and When said connectors are connected together, said lenses are secured in position relative to each other for secure and stable positioning in front of a pair of eyes.

7. The eye Wear of claim 6, Wherein said connectors are comprised of magnets.

8. The eye Wear of claim 6, Wherein said temples are comprised of telescopic temples for ?tting different Wearers.

9. The eye Wear of claim 6, Wherein said temples are pivotally connected to said lenses, so that When said con nectors are released from each other, said inner ends of said lenses are pivotable outWardly for making Wearing easier.

10. The eye Wear of claim 6, further including a pair of frames, said lenses being respectively mounted in said frames, said connectors being attached to respective inner ends of said frames, said temples being attached to respec tive outer ends of said frames.

11. An eye Wear, comprising: a pair of lenses; a pair of magnets connected to respective inner ends of

said lenses, said magnets being securely connectable together and releasable from each other; and

a ?exible strap connected betWeen outer ends of said

lenses; Wherein When said magnets are released from each other,

said inner ends of said lenses are separable from each other so that said eye Wear is easy to put on and remove, and When said magnets are connected together, said lenses are secured in position relative to each other for secure and stable positioning in front of a pair of eyes.

12. The eye Wear of claim 11, further including a pair of temples respectively connected to said outer ends of said lenses, said strap being attached betWeen rear ends of said temples.

13. The eye Wear of claim 11, further including a pair of frames, said lenses being respectively mounted in said frames, said magnets being attached to respective inner ends of said frames, said straps being connected to respective outer ends of said frames.

14. The eye Wear of claim 11, further including a cinch movable along said strap for adjusting a length of said strap.

* * * * *

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EXHIBIT B

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EXHIBIT C

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EXHIBIT D

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US $5.94 45m left

MENS WOMENS AVIATOR +3.25...

US $5.84 4h left

WOMENS +2.25 READING GLAS...

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WOMENS +2.00 READING GLAS...

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WOMENS +3.25 READING Glas...

US $12.84Clic Style MAGNETIC Readi...

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Case 6:15-cv-00621-JA-GJK Document 20-1 Filed 03/29/16 Page 25 of 38 PageID 251

EXHIBIT E

Case 6:15-cv-00621-JA-GJK Document 20-1 Filed 03/29/16 Page 26 of 38 PageID 252

3/24/2015 Clic Style MAGNETIC Reading Glasses FRONT CONNECT Adjustable READERS ALL COLORS

http://www.ebay.com/itm/ClicStyleMAGNETICReadingGlassesFRONTCONNECTAdjustableREADERSALLCOLORS/121400241226?pt=LH_… 1/9

Back to search results | Listed in category:  Health & Beauty > Vision Care > Reading Glasses > +1.25 strength

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SellHi Geoff!

 

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Seller informationpsi_photo_supply (3740  )99.8% Positive feedback

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Clic Style MAGNETIC Reading Glasses FRONT CONNECT Adjustable READERSALL COLORS

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Quantity: / 320 sold1

Itemcondition:

New

Sale ends in: 05d 11h 11m

Strength:  Select 

Frame Color:  Select 

   

Was: US $22.37 

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Price: US $12.84 Buy It Now

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psi_photo_supply (3740  ) 99.8%PSI Outlet

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Last updated on  Mar 23, 2015 17:10:17 PDT  View all revisions

Item specifics

Condition: New: A brandnew, unused, unopened, undamaged item (includinghandmade items). See the seller's listing ... Read more

Brand: Unbranded

Colors: Blue Red Clear Black Tortoise Purple Brown Green Model: Full Frame  Full RimAdditonal Colors: Purple Stripe Blue Stripe Leopard Amber Pink

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My eBay

Case 6:15-cv-00621-JA-GJK Document 20-1 Filed 03/29/16 Page 27 of 38 PageID 253

3/24/2015 Clic Style MAGNETIC Reading Glasses FRONT CONNECT Adjustable READERS ALL COLORS

http://www.ebay.com/itm/ClicStyleMAGNETICReadingGlassesFRONTCONNECTAdjustableREADERSALLCOLORS/121400241226?pt=LH_… 2/9

 

* See our reviews and feel secure in your purchase.

"Front Connect" Magnetic Adjustable Reading GlassesFULL FRAME & FULL RIM

PICK YOUR COLOR & YOUR REQUIRED STRENGTHEXCELLENT GIFT!

THAT'S RIGHT! NO Logos or branding, for the more discerning wearer!

Not everyone wants logos and branding on their eyewear. These readers are just that, UNBRANDED. No logos & advertising on the lenses or frames.They do what they are suppose to do  Help you see & read! Simple as that.

 Magnetics allow the glasses to come together at the bridge.

The solid head band is form fitting and wraps around your head to ensure a snug, comfortable fit. Putting them on is simple. Just pull the magnets apart and theglasses will hang comfortably around your neck. That way you know exactly where they are when you need them again.

They also can be fitted for prescription lenses.

Several fashionforward colors available: blue, black, dark brown, yellow, amber, purple, green, blue stripe (zebra), purple stripe(zebra), pink, red, clear, tortoise and more....

Each color offers you 9 different magnification strengths: +1.00, +1.25 and +1.50 mild strengths, +1.75, +2.00 and +2.25 mediumstrengths and +2.50, +2.75, +3.00, +3.25 or +3.50 mature strengths.

   

Style Full Frame  Full RimMaterial Acetate / Magnetic / PolycarbonateSize 140.00 mmGender Men & Women  Unisex

Colors Black / Blue / Green / Red / Clear / Tortoise / Leopard / Purple /Brown, Zebra Stripe & more...

Model Unbranded Front Connect Magnetic Reading Glasses

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THANKS for VISITING!

Case 6:15-cv-00621-JA-GJK Document 20-1 Filed 03/29/16 Page 28 of 38 PageID 254

EXHIBIT F

Case 6:15-cv-00621-JA-GJK Document 20-1 Filed 03/29/16 Page 29 of 38 PageID 255

Case 6:15-cv-00621-JA-GJK Document 20-1 Filed 03/29/16 Page 30 of 38 PageID 256

Case 6:15-cv-00621-JA-GJK Document 20-1 Filed 03/29/16 Page 31 of 38 PageID 257

EXHIBIT G

Case 6:15-cv-00621-JA-GJK Document 20-1 Filed 03/29/16 Page 32 of 38 PageID 258

Case 6:15-cv-00621-JA-GJK Document 20-1 Filed 03/29/16 Page 33 of 38 PageID 259

Case 6:15-cv-00621-JA-GJK Document 20-1 Filed 03/29/16 Page 34 of 38 PageID 260

EXHIBIT H

Case 6:15-cv-00621-JA-GJK Document 20-1 Filed 03/29/16 Page 35 of 38 PageID 261

CLAIM CHART U.S. PATENT 6,253,338 – EYE WEAR WITH SNAP-TOGETHER BRIDGE

Independent Claim 1 Authentic CliC Product Defendants’ Infringing Product An eye wear, comprising: a pair of lenses

a pair of releasable connectors connected to respective inner ends of said lenses, said connectors being securely connectable together and releasable from each other;

Case 6:15-cv-00621-JA-GJK Document 20-1 Filed 03/29/16 Page 36 of 38 PageID 262

a pair of temples connected to respective outer ends of said lenses; and

a strap connected between rear ends of said temples, said strap being rigid enough to generally retain its shape when said connectors are released, and springy enough to be bendable when flexed and rebounding when released;

Case 6:15-cv-00621-JA-GJK Document 20-1 Filed 03/29/16 Page 37 of 38 PageID 263

wherein when said connectors are released from each other, said inner ends of said lenses are separable from each other so that said eye wear is easy to put on and remove, and when said connectors are connected together, said lenses are secured in position relative to each other for secure and stable positioning in front of a pair of eyes.

Case 6:15-cv-00621-JA-GJK Document 20-1 Filed 03/29/16 Page 38 of 38 PageID 264