Form 16. Complaint for
Infringement of Patent
1. Allegation of jurisdiction.
2. On May 16, 1934, United States Letters Patent No. were
duly and legally issued to plaintiff for an invention in an electric
motor; and since that date plaintiff has been and still is the owner
of those Letters Patent.
3. Defendant has for a long time past been and still is infringing
those Letters Patent by making, selling, and using electric motors
embodying the patented invention, and will continue to do so
unless enjoined by this court.
4. Plaintiff has placed the required statutory notice on all
motors manufactured and sold by him under said Letters Patent,
and has given written notice to defendant of his said infringement.
Wherefore plaintiff demands a preliminary and final injunction
against continued infringement, an accounting for damages, and
an assessment of interest and costs against defendant.
(As amended Jan. 21, 1963, eff. July 1, 1963.)