UNITED STATES DISTRICT COURT DISTRICT OF MARYLAND

FICEP CORPORATION, 2301 Industry Court, Forest Hill Industrial Park, Forest Hill, Maryland 21050 Maryland County of Residence: Harford County Plaintiff, v. VOORTMAN USA CORP., 450 South Spruce Street, Manteno, Illinois 60950 Civil Action No.: _______

Defendant. COMPLAINT FOR PATENT INFRINGEMENT I. PARTIES 1. Plaintiff Ficep Corporation (Ficep) is a Maryland corporation having offices at

2301 Industry Court, Forest Hill Industrial Park, Forest Hill, Maryland 21050. 2. On information and belief, defendant Voortman USA Corp. (Voortman) is an

entity organized under the laws of Illinois and having a place of business at 450 South Spruce Street, Manteno, Illinois 60950. II. BACKGROUND 3. This action for patent infringement arises under the patent laws of the United

States, 35 U.S.C. 1 et seq.

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Ficep is the owner of all rights, title and interest including the right to bring a

suit for patent infringement in U.S. Patent No. 7,974,719, entitled Method and Apparatus for Automatic Manufacture of an Object with Multiple Intersecting Components (the 719 Patent) (copy attached as Exhibit A, hereto). 5. Ficep is an industry leader and principal supplier of structural steel and plate

fabrication and processing systems. The 719 patent generally relates to systems and methods for the manufacture of construction components, such as steel beams, including for example by cutting or shaping the component or marking particular locations thereon based upon construction information that may be stored in a computer. 6. This Court has jurisdiction over the subject matter of this action under 28 U.S.C.

1331 and 1338(a). III. CLAIM FOR RELIEF 7. herein. 8. Defendant Voortman has directly and/or indirectly infringed one or more claims Ficep incorporates by reference each of the foregoing paragraphs, as if fully stated

of the 719 Patent, in violation of one or more subsections of 35 U.S.C. 271 including at least one or more of subsections 271(a), (b), (c), (f) and (g). 9. By correspondence from its counsel dated March 20, 2012 and/or April 16, 2012,

Ficep told Voortman of Voortmans infringements on account of at least one or more of Voortmans V704M layout marking system products, V806 and V808 coping products, V603 and V630 drilling products, and V330C and V330S plate processing products.

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Voortmans direct infringements and/or the direct infringements of others, for

which Voortman would be liable as an indirect infringer satisfy all the limitations of one or more claims of the 719 Patent, either literally or by equivalents. 11. Defendant Voortman is liable as a direct infringer because it has made, used, sold,

offered to sell, or imported into the U.S., products or services that are within the scope of one or more claims of the 719 Patent and/or Defendant Voortman has made, used, sold, offered to sell, or imported into the U.S. products, made by methods claimed in the 719 Patent. 12. Defendant Voortman is liable as an indirect infringer for the direct infringement

of others that have made, used, sold or offered to sell, or imported into the U.S., products or services that are within the scope of one or more claims of the 719 Patent and/or that have made, used, sold, offered to sell, or imported into the U.S., products made by methods claimed in the 719 Patent. 13. On information and belief, defendant Voortman has actively induced infringement

of the 719 Patent, at least by intentionally encouraging the direct infringement of one or more claims of the 719 Patent by customers, buyers, sellers and others. On information and belief, prior to this action, Voortman had knowledge of and intended to cause direct infringement by others and/or Voortman willfully blinded itself to the existence of the 719 Patent and such infringement. 14. On information and belief, defendant Voortman is also a contributory infringer of

one or more claims of the 719 Patent, at least because it sells, offers to sell, or imports into the U.S. a material or apparatus for use in practicing subject matter claimed in the 719 Patent, constituting a material part of the invention, knowing the same to be especially made or especially adapted for use in such infringement, and not a staple article or commodity of

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commerce suitable for substantial non-infringing use. On information and belief, prior to this action Voortman had knowledge of the 719 Patent and intended to cause direct infringement by others, and/or Voortman willfully blinded itself to the existence of the 719 Patent and such infringement. 15. Ficep has sustained damages as a result of Voortmans direct and/or indirect

infringement of the 719 Patent identified herein and Voortman is liable for such damages in this action, including pre-suit damages. 16. Ficep has no adequate remedy at law for Voortmans continued infringement of

the 719 Patent such that the Court must enjoin Voortman from further acts of infringement. 17. On information and belief, Voortmans direct and/or indirect infringement of the

719 Patent is and has been willful and deliberate, justifying increased damages under 35 U.S.C. 284. 18. In addition, Voortmans infringement of the 719 Patent is exceptional and

entitles Ficep to an award of attorneys fees and costs incurred in prosecuting this action under 35 U.S.C. 285. IV. DEMAND FOR JURY TRIAL Ficep hereby demands a trial by jury of all issues so triable in this action. V. PRAYER FOR RELIEF WHEREFORE, Ficep respectfully requests the following relief: A. Enjoin Voortman and each of its respective affiliates, subsidiaries; officers, directors, employees, agents, representatives, licensees, successors, assigns and all those acting for them, on their behalf, or in concert with them from further infringement of the 719 Patent as alleged herein.

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B. Award Ficep compensatory damages, costs, prejudgment interest, and postjudgment interest for infringement of the 719 Patent; C. Award Ficep treble damages per 35 U.S.C. 284; D. Declare the claim for relief asserted herein to be exceptional under 35 U.S.C. 285 and award Ficep its reasonable attorneys fees and costs incurred in prosecuting this action; and E. Award such other and further relief as this Court may deem just and proper.

Dated: February 7, 2013

/s/ Lisa S. Mankofsky Lisa S. Mankofsky Gen. Bar No. 04940 FOLEY & LARDNER LLP 3000 K Street, N.W. Suite 600 Washington, D.C. 20007-5109 Telephone: (202) 672-5300 Facsimile: (202) 672-5399 lmankofsky@foley.com Attorneys for Plaintiff FICEP CORPORATION

Of Counsel: Robert J. Silverman FOLEY & LARDNER LLP 111 Huntington Avenue Boston, MA 02199 Telephone: (617) 342-4000 Facsimile: (617) 342-4001 rsilverman@foley.com

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