BC Media v. Chawla - Complaint

Case 2:20-cv-01692-AJS
2:05-mc-02025 Document
Document
17591 Filed 11/04/20 Page 1 of 8

IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF PENNSYLVANIA
BC MEDIA, INC. )
)
Plaintiff, ) C.A. No. 20-1692
)
vs. )
)
ANUJ CHAWLA ) JURY TRIAL DEMANDED
AND )
ACTIVE PHOTO SERVICES PVT. LTD. )
t/d/b/a PROAIM, )
Defendants.
VERIFIED COMPLAINT
AND NOW COMES plaintiff, BC Media, Inc. (“BC”) by and through its attorneys, Metz
Lewis Brodman Must O’Keefe LLC, and for its Verified Complaint against Anuj Chawla and
Active Photo Services Pvt. Ltd., states as follows:
PARTIES
1. BC is a corporation organized and existing under the laws of the State of South
Carolina, having its principal place of business at 30 Emily Lane, Piedmont, South Carolina,
29673.
2. Upon information and belief, Active Photo Services Pvt. Ltd. (“Active”) is an
Indian corporation with a principal place of business of Plot No. 103, First Floor, Industrial Area,
Phase 1, Chandigarh CH 160002 INDIA.
3. Upon information and belief, Anuj Chawla (“Chawla” and collectively with Active,
“Defendants”) is a principal of Active and may have intellectual property rights in certain Active
products.
Document
17591 Filed 11/04/20 Page 2 of 8

JURISDICTION AND VENUE
4. This action for patent infringement arises under the patent laws of the United States
and more particularly under 35 U.S.C. §§ 1 et seq., including without limitation, 35 U.S.C. §§ 271,
281, 283, 284 and 285.
5. This Court has jurisdiction over the subject matter of this action pursuant to 28
U.S.C. §§ 1331 and 1338(a).
6. Defendants have offered and continue to offer for sale and have sold certain
infringing camera jib having a particular design both within and outside of the United States,
thereby causing harm and tortious injury to Plaintiff in this District and subjecting Defendant to
personal jurisdiction by the United States District Court for the Western District of Pennsylvania,
more particularly pursuant to F.R.C.P. 4(k)(2)(A).
7. Venue is proper in this District pursant to 28 U.S.C. §§ 1391(c)(3) and 1400(b).
COUNT I
Federal Patent Infringement Under 35 U.S.C. § 271
8. The averments of Paragraphs 1 through 7 of the Verified Complaint are
incorporated herein by reference as if set forth in full.
9. On March 17, 2009, United States Design Patent No. D588,621 (hereafter the “‘621
patent”) was issued for a “Camera Jib.” The ‘621 patent was granted in the name of the inventor
Jonathan C. M. Baty, who has duly assigned the patent, as indicated on its face, to Plaintiff.
Plaintiff is and has been the assignee and owner of record in the United States Patent and
Trademark Office. A copy of the ‘621 patent is attached hereto as Exhibit A and is incorporated
herein by reference.
10. On February 17, 2015, United States Design Patent No. D722,637 (hereafter the
“‘637 patent” and collectively with the ‘621 patent, the “Patents”) was issued for a “Camera Jib.”
2
Document
17591 Filed 11/04/20 Page 3 of 8

The ‘637 patent was granted in the name of the inventor Jonathan C. M. Baty, who has duly
assigned the patent, as indicated on its face, to Plaintiff. Plaintiff is and has been the assignee and
owner of record in the United States Patent and Trademark Office. A copy of the ‘637 patent is
attached hereto as Exhibit B and is incorporated herein by reference.
11. The claims of the ‘621 patent include, inter alia, the following designs:
3
Document
17591 Filed 11/04/20 Page 4 of 8

12. The claims of the ‘637 patent include, inter alia, the following designs:
4
Document
17591 Filed 11/04/20 Page 5 of 8

13. Defendants are in the business of manufacturing and/or selling, inter alia, camera
and related film production equipment. Defendants are, more specifically, in the business of
manufacturing and/or selling camera jibs under the name and mark ProAim Astra Camera Jib
Crane having the following design:
14. Defendants have infringed and continue to infringe one or more of the claims of the
Patents in contravention of 35 U.S.C. § 271(a) by manufacturing, using, offering to manufacture
and/or offering to sell and selling in the United States, certain camera jibs with frames and features
as illustrated in the Patents without leave or license of plaintiff and patentee BC Media and in
violation of BC Media’s rights.
5
Document
17591 Filed 11/04/20 Page 6 of 8
15. On information and belief, Defendant will continue to infringe the Patents unless
enjoined by this Court. More specifically, upon information and belief, Defendants are
manufacturing the Astra line of camera jibs which are displayed at the website,
http://www.proaim.com, which, on information and belief, Plaintiff alleges is created, designed,
controlled and maintained by Defendants, an illustrative page of which is attached hereto as
Exhibit C.
16. Upon information and belief, Defendants have manufactured, used, offered to
manufacture and/or offered to sell and sold camera jibs on the Amazon.com website, an illustrative
page of which is attached hereto as Exhibit D.
17. Such infringement is injuring Plaintiff in that is it diverting potential sales from
Plaintiff to Defendants and causing Plaintiff to expend increased time and expense in educating its
consumer base. Additionally, upon information and belief, Defendants are offering infringing
products at prices which may potentially depress the prices of Plaintiff’s competitive camera jibs.
18. As a direct and proximate result of the infringing conduct of Defendants, Plaintiff
has been damaged and will continue to be damaged and will be caused irreparable injury unless
Defendants are enjoined by this Court. Plaintiff has no adequate remedy at law; and irreparable
injury to Plaintiff increases with each and every act of infringement committed by Defendants.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff prays:
A. That a permanent injunction issue enjoining Defendants and their officers, agents,
related companies, servants, employees, attorneys, successors and assignees and all of those acting
6
Document
17591 Filed 11/04/20 Page 7 of 8

under any of their authority or in privity with any of them, from further infringement of the Patents
owned by Plaintiff;
B. That Plaintiff recover from Defendants Plaintiff’s actual monetary damages
associated with Defendants’ infringing conduct, including, without limitation, Defendants’ profits
for the sale of infringing camera jibs;
C. That Defendant make a full report to this Court of its compliance with the foregoing
within 30 days of judgment herein; and
D. That Plaintiff have such other relief, legal and equitable, including, without
limitation, prejudgment interest, as this Court may deem just and proper.
Respectfully submitted,
Metz Lewis Brodman Must O’Keefe LLC
By: /s/Barry I. Friedman

Barry I. Friedman, Esquire
(Pa. I.D. No. 50507)
535 Smithfield Street, Suite 800
Pittsburgh, Pennsylvania 15222
(412) 918-1100
Attorneys for Plaintiff
7
Document
17591 Filed 11/04/20 Page 8 of 8

%$*$*.()$*$ %$,(*%(%$(
%#&"$*)**#$*)*($(%((**%*)*%#.&()%$"!$%-"%($%(#*%$
$"
))**#$*$,(*%$)#)+ **%*&$"*)%&( +(.+$(*"-)
% * $* **)

* )' $
/ ("*$ *% +$)-%($
"(*%$)

%$*$*.
()$*$

Document
1759-1
1-1 Filed 11/04/20 Page 1 of 6
Exhibit A
Document
1759-1
1-1 Filed 11/04/20 Page 2 of 6
Document
1759-1
1-1 Filed 11/04/20 Page 3 of 6
Document
1759-1
1-1 Filed 11/04/20 Page 4 of 6
Document
1759-1
1-1 Filed 11/04/20 Page 5 of 6
Document
1759-1
1-1 Filed 11/04/20 Page 6 of 6
Document
1759-2
1-2 Filed 11/04/20 Page 1 of 8
Exhibit B
Document
1759-2
1-2 Filed 11/04/20 Page 2 of 8
Document
1759-2
1-2 Filed 11/04/20 Page 3 of 8
Document
1759-2
1-2 Filed 11/04/20 Page 4 of 8
Document
1759-2
1-2 Filed 11/04/20 Page 5 of 8
Document
1759-2
1-2 Filed 11/04/20 Page 6 of 8
Document
1759-2
1-2 Filed 11/04/20 Page 7 of 8
Document
1759-2
1-2 Filed 11/04/20 Page 8 of 8
11/4/2020 Case 2:20-cv-01692-AJS
Document
1759-3
Proaim 1-3Camera
Astra Filed 11/04/20 Page 1 of 12
Jib Crane
Enter Your Email × D

Get
Our company is working normally. We currently have full stocks of goods and are ready to ship
from India within 48 hours, however there may be delays at the border due to restrictions imposed
by the Governments.
What are you looking for?
English
Home Proaim Astra Camera Jib Crane
Team Proaim
How can we help? We're here for you!
Type your message…
Chat by Drift
Exhibit C
https://www.proaim.com/products/proaim-astra-camera-jib-crane 1/12
11/4/2020 Case 2:20-cv-01692-AJS
Document
1759-3
Proaim 1-3Camera
Jib Crane

Get
Team Proaim
Chat by Drift
11/4/2020 Case 2:20-cv-01692-AJS
Document
1759-3
Proaim 1-3Camera
Jib Crane

Get
Click to expand
Team Proaim

Proaim Astra Camera Jib
ib C
Crane
Chat by Drift
Available in 4ft, 8ft, 12ft
$98.00
SKU : JB-AS04-00
11/4/2020 Case 2:20-cv-01692-AJS
Document
1759-3
Proaim 1-3Camera
Jib Crane

Get
Select Length of Jib Arm
Proaim Astra 4ft Camera Jib Crane (JB-AS04-00)
Related Accessories
Proaim Heavy Duty Jib Stand (P-JS) (+$80)
Flycam Quick Release Mount for Ronin/M/MX/ & MōVI (DJI-QR) (+$35) (Out of Stock)
Quantity
1
Add to cart
Share this:
Description Specifications Included

uded Videos
Vid User M
U Manuall
Team Proaim
Compact Camera
eraHow
Support for Creative
can we help? We're here for you!
Filmmaking - Proaim Astra 4' Jib!

PType your message…
Chat by Drift
Achieve More Shot Stability
tability & Dramatic Moving Shots
Even In Challenging
hallenging Conditions!
11/4/2020 Case 2:20-cv-01692-AJS
Document
1759-3
Proaim 1-3Camera
Jib Crane
High Build Quality. Completely Tool-Less.

Enter Your Email Lightweight. Get
× D
Quick Setup. Most Affordable Jib Crane.
Invest In Quality and Add Inspiring Shots

to Your Videos!
Our filmmaking dreams don't just sit on the ground so why should our cameras!
Dramatic views and camera move instantly add to the production value of any
project. Proaim has made an affordable camera crane accessible to independent
filmmakers and videographers by launching a CNC Aluminum constructed Astra 4ft
Jib. This Jib is so light and versatile that you'll want to make it an immediate part of
your standard equipment whether you're shooting wedding videos, commercials on
location, music videos in your studio or sporting events in a stadium.
Team Proaim
Chat by Drift
11/4/2020 Case 2:20-cv-01692-AJS
Document
1759-3
Proaim 1-3Camera
Jib Crane

Get
"WHAT YOU SEE IS WHAT YOU GET"
Team Proaim
Chat by Drift
11/4/2020 Case 2:20-cv-01692-AJS
Document
1759-3
Proaim 1-3Camera
Jib Crane

Get
• With the included camera plate you can mount a camera of practically any size
weighing up to 8kg / 17.6lb.
• The camera mount automatically remains parallel to the ground for stable high
angle shots. When you're ready to get more creative; unlock the manual tilt handle,
and you can freely angle your camera for dramatic moving shots.
• Pan your camera 360° to take in a massive Vista, then crane down to move your
audience into the perfect shot.
• The "single rail" design makes it a lightweight
lig crane and can be easily assembled
Team Proaim ed
by one person. It is complemented
ted and made more stable by a second rail that
at
accomplishes the tilt function.
• LCD mounting arm allows adding your monitor easily to view live footage.
ng yo
• The design is completely tool-less,
ess, therefore
t has an amazingly fast setup time.
• Putting your camera on a crane
cra creates excitement and
Chatbrings
by Driftmore
re
professionalism to your film and video projects!
Compact Versatile
Compact Versatile A
Affordable
ffordable C
Camera
amera J
Jib
ib C
Crane-
rane- P
Proaim
roaim A
Astra1…
stra1…
11/4/2020 Case 2:20-cv-01692-AJS
Document
1759-3
Proaim 1-3Camera
Jib Crane

Get
Add IInspiring
Add nspiring S
Shots
hots tto
oYYour
our V
Videos
ideos w
with
ith P
Proaim
roaim A
Astra
stra 1
12ft
2ft C
Comp
omp…
Team Proaim
Video is
s for demonstration only
Actual Product may varyHow
ay va duecan
to we
Product Improvements
help? We're here for you!
View More Videos Here

ew M
Chat by Drift
11/4/2020 Case 2:20-cv-01692-AJS
Document
1759-3
Proaim 1-3Camera
Jib Crane

Get
Compatible With Ronin Gimbal

With the help of this adapter, you can also mount DJI Ronin/M/MX/ & MōVI
Gimbals, to add more variety to your shots.
shots
Team Proaim
Chat by Drift
11/4/2020 Case 2:20-cv-01692-AJS
Document
1759-3
Proaim 1-3Camera
Astra FiledJib 11/04/20
Crane Page 10 of 12

Get
IMAGE GALLERY
Team Proaim
Chat by Drift
11/4/2020 Case 2:20-cv-01692-AJS
Document
1759-3
Proaim 1-3Camera
Crane Page 11 of 12

Get
Supportive accessories are for demonstration purpose only.
Team Proaim

Contact Information

Plot No: 103, Industrial Area
Phase-I, Chandigarh-160002 Chat by Drift
+91-8283902255
 sales@proaim.com
 proaimshop
11/4/2020 Case 2:20-cv-01692-AJS
Document
1759-3
Proaim 1-3Camera
Crane Page 12 of 12

Get
Customer Service
Information
Subscribe
Invite customers to join your mailing list.
Email address Sign up
Follow us
opyright © 2020 Proaim.com.
Team Proaim
Chat by Drift
11/4/2020 Case
Amazon.com 2:20-cv-01692-AJS
2:05-mc-02025
: PROAIM Document
Astra Professional Mini Document
Camera 1759-4
Jib Arm for 1-4 Filed
DSLR Video 11/04/20
Film Page
Camera | Heavy-duty yet 1 of 8 Best Travel/Indoor/O…
Lightweight,
Skip to main content

Deliver to Barry
Electronics
Hello, barry Returns 0
Pittsburgh 15243 Account & Orders
All Holiday Deals Gift Cards Prime Video Customer Service barry's Amazon.com Prime Subscribe & Save Grab your gift deals now
Camera & Photo Deals Best Sellers DSLR Cameras Mirrorless Cameras Lenses Point-and-Shoots Sports & Action Cameras Camcorders
Customers who viewed PROAIM Astra Professional Mini Camera Jib Arm for DSLR Video
Film Camera… also viewed
Sevenoak SK- Neewer 70 ProAm USA
JA20-II 7-Foot inches/177 Orion DVC200
Carbon Fiber Centimeters DSLR Video
Camera Aluminum Alloy Camera Jib
Jib/Crane with Jib Arm Camera Crane Tilt -
26 75
353
$99.95 $279.00
2 used and new $106.49
from $99.95 3 used and new
2 used and new from $279.00
from $106.49
Electronics › Camera & Photo › Video › Camera Supports & Stabilizers › Camera Cranes
S m
Su
Sub PROAIM Astra Buy new: $147.00
Professional Mini & FREE Returns

Su
Sub
ubm
Camera Jib Arm FREE delivery: Friday, Nov 6
Sub
Su
ub
ubm
for DSLR Video Order within 7 hrs and 42
mins Details
Film Camera |
Su
Sub
ubm
b Heavy-duty yet In Stock.
Lightweight, Best Qty: 1
Subm
Subm
Sub
Travel/Indoor/Out
Add toto
Add Cart
Cart
Ca
Sub
Sub
Subm
ubm door Aluminum
Crane with LCD Submit
Buy No
Now
Sub
Subm
ubm
Arm + Bag (JB- Secure transaction
AS04-00, 4ft) Ships from Amazon

Sold by Proaim
Brand: PROAIM
Packaging Shows what's insi…
28 ratings
| 10 answered questions
Details
Price: $147.00 Add gift options

& FREE Returns
Deliver to Barry - Pittsburgh
Get $100 off instantly: Pay 15243
$47.00 $147.00 upon approval

for the Amazon Prime Rewards
Visa Card. No annual fee.
Save with Used - Like New
$117.99
May be available at a lower price
from other sellers, potentially FREE delivery: Friday, Nov 6
without free Prime shipping. Ships from: Amazon
Returnable until Jan 31, 2021 Sold by: Amazon Warehouse
Roll over image to zoom in
COMPACT 4ft CAMERA JIB
fits into tight shooting spaces
Exhibit D
https://www.amazon.com/Professional-Heavy-duty-Lightweight-Aluminum-JB-AS04-00/dp/B078MJQX6Y 1/8
11/4/2020 Case
2:05-mc-02025
: PROAIM Document
Camera 1759-4
DSLR Video 11/04/20
Film Page
Lightweight,
STRONG ALUMINUM FRAME
provides STABILITY
TOOL-LESS DESIGN & New & Used (7) from
Simple Operation – Saves $114.26 FREE Shipping
lots of Production Time
Achieve SUPERIOR SHOTS
that add Incredible Value to Share
Your Productions
BEST MID-SIZED CRANE on Have one to sell?
the market to get Sell on Amazon
Professional Results
New & Used (7) from $114.26

FREE Shipping
Report incorrect product

information.
Video Auto
5% off coupon Dolly
Wi l
Wireless
W Remote Andoer 3-Wheels Wirelesss Camera Video
Control Motorized Auto Dolly with Ballhead…dd
Andoer 3-Wheels Wireless Remote… 109
$79.99 $74.99
Sponsored
Sponsored
Frequently bought together
Total price: $356.48

Sll uth
Add all bmeeit
three
hr to
to Cart
+ + Suthree
Add all bree
thrmitto
t List
This item: PROAIM Astra Professional Mini Camera Jib Arm for DSLR Video Film Camera | Heavy-duty yet… $147.00
Neewer Photography Tripod Dolly, Heavy Duty with Larger 3-inch Rubber Wheels, Adjustable Leg Mounts… $69.49
Video Tripod System, Cayer BV30L 72 inch- Professional Heavy Duty Aluminum Twin Tube Tripod, K3… $139.99
Products related to this item

Sponsored
Sevenoak SK-JA20-II 7- Camgear DSLR Video ProAm USA DVC210 SIRUI Camera Monopod K&F Concept 70"/177cm M
Foot Carbon Fiber Camera Crane Jib DSLR Orion DSLR Video AM-326M, 6-Section Portable Tripod,Outdoor A
Camera Jib/Crane with Tilt with 4 Feet Length Camera Jib Crane Tilt - Carbon Fiber Compact Travel Tripod Compact… M
360° Panning Base and... with Load Capacity... Aircraft Aluminum… Lightweight Multi… 26 S
26 1 44 293 $64.99
$99.95 $205.00 $299.00 $89.90 $
Customers who viewed this item also viewed
11/4/2020 Case
2:05-mc-02025
: PROAIM Document
Camera 1759-4
DSLR Video 11/04/20
Film Page
Lightweight,
Neewer 70 inches/177 Sevenoak SK-JA20-II 7- PROAIM Astra ProAm USA Stand for ProAm USA Orion
Centimeters Aluminum Foot Carbon Fiber Professional Mini Camera ProAm Camera Crane / DVC200 DSLR Video
Alloy Jib Arm Camera Camera Jib/Crane with Jib Arm for DSLR Video Jib Camera Jib Crane Tilt -
Crane with 1/4 and 3… 360° Panning Base… Film… 102 Aircraft Aluminum…
353 26 21 $59 00 75
Have a question?
Find answers in product info, Q&As, reviews
Type your question or keyword
Product description
Proaim Astra 4ft Camera Jib Crane (JB-AS04-00) Compact Camera Support for Creative Filmmaking - Proaim Astra 4' Jib!
High Build Quality. Completely Tool-Less. Lightweight. Quick Setup. Most Affordable Jib Crane.
Proaim has made an affordable camera crane accessible to independent filmmakers and videographers by launching a CNC Aluminum constructed Astra 4ft
Jib. This Jib is so light and versatile that you'll want to make it an immediate part of your standard equipment whether you're shooting wedding videos,
commercials on location, music videos in your studio or sporting events in a stadium.
WHAT'S IN THE BOX
- Proaim Astra 4ft Camera Jib

- LCD Mounting Bracket
- Storage Case
SPECIFICATIONS
- Robust Aluminum Construction

- Total Length of Jib: 4ft 9inch
- Support Cameras up to: 8kg / 17.6lb
- Self Balance: 1kg
- Camera Mounting Bolt: Free holes 1/4"-20
- Product Weight (without packing): 4.20kg / 9.25lb
- Height Range From Ground Level: 7ft when Stand in Minimum Height at 4ft : 8ft 9inch when Stand in Maximum Height at 5.8ft
Product information
Package Dimensions 52 x 7.15 x 5.95 inches Technical Specification
Item Weight 13.62 pounds User Manual [PDF ]
ASIN B078MJQX6Y
Warranty & Support
Item model number JB-AS04-00
Product Warranty: For warranty information about this product, please
Customer Reviews 28 ratings
click here
4.0 out of 5 stars
Best Sellers Rank #75,337 in Electronics (See Top

Feedback
100 in Electronics)
Would you like to tell us about a lower price?
#10 in Camera Cranes
11/4/2020 Case
2:05-mc-02025
: PROAIM Document
Camera 1759-4
DSLR Video 11/04/20
Film Page
Lightweight,
Is Discontinued By Manufacturer No
Date First Available April 21, 2018
Manufacturer SIRGAWAIN
Videos
Videos for this product Videos for related products
3:17 3:57 4:33

Proaim Astra Camera Jib Crane (JB- The 10 Best Camera Cranes The 10 Best Jib Cranes
AS04-00)
The Cinecity Ezvid Wiki Ezvid Wiki
Upload your video
Products related to this item

Sponsored
Sevenoak SK-JA20-II 7- YELANGU Anto Camera Carbon Fiber Tripod- ProAm USA DVC210 CAMVATE Cheese Handle T
Foot Carbon Fiber Slider with Wireless INNOREL ST344C Orion DSLR Video Grip Mounts to Camera's C
Camera Jib/Crane with Remote Control, 3 Speed Professional Heavy Duty Camera Jib Crane Tilt - Hot Shoe for Cinema F
360° Panning Base and... Adjust Camera… Camera Stand with… Aircraft Aluminum… Camera(Black) D
26 4 2 44 8 $
$99.95 $79.99 $240.00 $299.00 $21.80
Bose TV Speaker- Small Soundbar with

Bluetooth and HDMI-ARC connectivity,
Black. Includes Remote Control
514
$
249.00
Add to Cart
Sponsored
Customer Questions & Answers

See questions and answers
11/4/2020 Case
2:05-mc-02025
: PROAIM Document
Camera 1759-4
DSLR Video 11/04/20
Film Page
Lightweight,
Customer reviews Top reviews
4 out of 5
Top reviews from the United States
28 global ratings
5 star 56% Amazon Customer

4 star 17%
IT IS NOT PRECISE AND SHAKES A LOT
3 star 11%
Reviewed in the United States on August 9, 2020
2 star 0%
Verified Purchase
1 star 16%
If you what to film something with a go pro or very small cameras probably is going to work
How are ratings calculated? better, but I'm not happy I use it with the bmpck4k and shakes a lot.
MarHe
kelthpifu
Helpful
H fs lreview Comment Report abuse
Colims Reserve
This jib is great for the price...buy buy buy!!!

Reviewed in the United States on March 5, 2020
Verified Purchase
Yup this is great for the money... smooth movement . Sturdy jib
One person found this helpful
MarHe
kelthpifu
Helpful
Willliam B.
Bose TV Speaker- Small Soundbar with Bl…
WOW built like a tank!!!
514
Reviewed in the United States on June 4, 2019
$
249.00 Shop now
Completely blown away. The Jib was very nicely protected and packaged. This jib is as solid as it
Sponsored gets. was easy to assemble. All the parts are well made. It is a bit heavy but that is to be
expected when you get quality. I am going to order a second one as well as 2 Proaim Flite Pan
Tilt Heads. Way to go Proaim you have a winner in my book.
Bill Brady, Creative Imaginations Productions

2 people found this helpful
MarHe
kelthpifu
Helpful
See all reviews
Top reviews from other countries
Translate all reviews to English
FABRIZIO
11/4/2020 Case
2:05-mc-02025
: PROAIM Document
Camera 1759-4
DSLR Video 11/04/20
Film Page
Lightweight,
esattamente come lo immaginavo

Reviewed in Italy on June 9, 2019
Verified Purchase
forte e ben fatto, corrisponde esattamente alla descrizione e mi sento di dover dire che
corrisponde alle mie esigenze. lo consiglio per chi vuole girare immagini un po diverse dal
solito
2 people found this helpful
Report abuse
Translate review to English
Lewis
Worst Crane Jibever

Reviewed in Canada on September 19, 2018
Verified Purchase
It's unsuable make noise not
smooth etc etc, don't buy this. I
think I will make a bad vlog on
youtube about it
Look at the video and compare it to
the bigger one (not same brand) I
bought this little one for space and
it's totally not usable.
Report abuse
Carlos H. Burgos
very hard to handle it and noisy as it can be

Verified Purchase
what a piece of junk
Report abuse
Rene Beaumier
Produit robuste.
Verified Purchase
Produit d'entré de gamme, ce que je savais. La rotation horizontal est difficile sans une tête de
trépied réellement pro. Le mouvement vertical est assé souple.
Report abuse
Translate review to English
See all reviews
Customers who bought this item also bought
11/4/2020 Case
2:05-mc-02025
: PROAIM Document
Camera 1759-4
DSLR Video 11/04/20
Film Page
Lightweight,
ProAm USA Stand for Proaim Jib Stand SMALLRIG Camera Base Neewer Photography Neewer Photography
ProAm Camera Crane / 9 Plate with Rod Rail Professional Heavy Duty Tripod Dolly, Heavy Duty
Jib $111.00 Clamp for Sony A6500 Tripod Dolly with Rubber with Larger 3-inch
102 FREE Delivery A6600, for Panasonic… Wheels and… Rubber Wheels,…
Sevenoak SK-JA20-II 7-Foot Carbon Fiber Camera

Jib/Crane with 360° Panning Base and Counter
Weight Sandbag for DSLR Cameras - Load Shop now
Capacity 11 lb (5kg)
$99 95 26
Sponsored
Pages with related products. See and discover other items: Best mini studio lights for videos, DSLR Video Cameras, DSLR and Video Cameras, Light
Weight Digital Cameras, dslr video cameras, Video DSLR Cameras
Back to top
Get to Know Us Make Money with Us Amazon Payment Products Let Us Help You
Careers Sell products on Amazon Amazon Rewards Visa Signature Amazon and COVID-19
Cards
Blog Sell apps on Amazon Your Account
Amazon.com Store Card
About Amazon Become an Affiliate Your Orders
Amazon Business Card
Sustainability Advertise Your Products Shipping Rates &
Amazon Business Line of Credit Policies
Press Center Self-Publish with Us
Shop with Points Amazon Prime
Investor Relations Host an Amazon Hub
Credit Card Marketplace Returns &
Amazon Devices › See More Make Money Replacements
with Us Reload Your Balance
Amazon Tours Manage Your Content
Amazon Currency Converter and Devices
Amazon Assistant
Help
English United States
Amazon Music Amazon Amazon Drive 6pm AbeBooks ACX Alexa

Stream millions Advertising Cloud storage Score deals Books, art Audiobook Actionable
of songs Find, attract, and from Amazon on fashion & collectibles Publishing Analytics
engage customers brands Made Easy for the Web
Sell on Amazon Amazon Fresh AmazonGlobal Home Services Amazon Ignite Amazon Rapids
Amazon Business Groceries & More Ship Orders Experienced Pros Sell your original Fun stories for
Start a Selling Everything For Right To Your Door Internationally Happiness Guarantee Digital kids on the go
Account Your Business Educational
Resources
Amazon Web Audible Book Depository Box Office ComiXology DPReview East Dane
Services Listen to Books & Books With Free Mojo Thousands of Digital Designer Men's
Scalable Cloud Original Delivery Worldwide Find Movie Digital Comics Photography Fashion
Computing Audio Box Office Data
Services Performances
Fabric Goodreads IMDb IMDbPro Kindle Direct Prime Now Amazon Photos
Sewing, Book reviews Movies, TV Get Info Publishing FREE 2-hour Unlimited Photo
Quilting & & Celebrities Entertainment Indie Digital & Print Delivery Storage
& Knitting recommendations Professionals Publishing on Everyday Free With Prime
Need Made Easy Items
11/4/2020 Case
2:05-mc-02025
: PROAIM Document
Camera 1759-4
DSLR Video 11/04/20
Film Page
Lightweight,
Prime Video Shopbop Amazon Warehouse Whole Foods Woot! Zappos Ring
Direct Designer Great Deals on Market Deals and Shoes & Smart Home
Video Fashion Brands Quality Used Products America’s Shenanigans Clothing Security Systems
Distribution Healthiest
Made Easy Grocery Store
eero WiFi Neighbors App Amazon Subscription Boxes PillPack Amazon Renewed Amazon Second
Stream 4K Real-Time Crime Top subscription boxes – right Pharmacy Like-new products Chance
Video & Safety Alerts to your door Simplified you can trust Pass it on, trade
in Every Room it in,
give it a second
life
Conditions of Use Privacy Notice Interest-Based Ads © 1996-2020, Amazon.com, Inc. or its affiliates
JS 44 (Rev. 10/20) Case 2:20-cv-01692-AJS
2:05-mc-02025CIVIL
Document
Document
COVER1759-5
1-5 Filed 11/04/20 Page 1 of 3
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
BC MEDIA, INC.
ANUJ CHAWLA and ACTIVE PHOTO SERVICES PVT
LTD t/d/b/a PROAIM
(b) County of Residence of First Listed Plaintiff County of Residence of First Listed Defendant
(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)
Metz Lewis Brodman Must O'Keefe LLC (412.918.1100)

535 Smithfield Street, Suite 800, Pittsburgh, PA 15222
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 880 Defend Trade Secrets 480 Consumer Credit
of Veteran’s Benefits 350 Motor Vehicle 370 Other Fraud 710 Fair Labor Standards Act of 2016 (15 USC 1681 or 1692)
160 Stockholders’ Suits 355 Motor Vehicle 371 Truth in Lending Act 485 Telephone Consumer
190 Other Contract Product Liability 380 Other Personal 720 Labor/Management SOCIAL SECURITY Protection Act
195 Contract Product Liability 360 Other Personal Property Damage Relations 861 HIA (1395ff) 490 Cable/Sat TV
196 Franchise Injury 385 Property Damage 740 Railway Labor Act 862 Black Lung (923) 850 Securities/Commodities/
362 Personal Injury - Product Liability 751 Family and Medical 863 DIWC/DIWW (405(g)) Exchange
Medical Malpractice Leave Act 864 SSID Title XVI 890 Other Statutory Actions
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS 790 Other Labor Litigation 865 RSI (405(g)) 891 Agricultural Acts
210 Land Condemnation 440 Other Civil Rights Habeas Corpus: 791 Employee Retirement 893 Environmental Matters
220 Foreclosure 441 Voting 463 Alien Detainee Income Security Act FEDERAL TAX SUITS 895 Freedom of Information
230 Rent Lease & Ejectment 442 Employment 510 Motions to Vacate 870 Taxes (U.S. Plaintiff Act
240 Torts to Land 443 Housing/ Sentence or Defendant) 896 Arbitration
245 Tort Product Liability Accommodations 530 General 871 IRS—Third Party 899 Administrative Procedure
290 All Other Real Property 445 Amer. w/Disabilities - 535 Death Penalty IMMIGRATION 26 USC 7609 Act/Review or Appeal of
Employment Other: 462 Naturalization Application Agency Decision
446 Amer. w/Disabilities - 540 Mandamus & Other 465 Other Immigration 950 Constitutionality of
Other 550 Civil Rights Actions State Statutes
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 USC §1, et. seq. §271
VI. CAUSE OF ACTION Brief description of cause:
Design patent infringememt
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. JURY DEMAND: ✖ Yes No
VIII. RELATED CASE(S)
(See instructions):
IF ANY JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
November 4, 2020 Barry I. Friedman Digitally signed by Barry I. Friedman
Date: 2020.11.04 15:36:58 -05'00'
FOR OFFICE USE ONLY
RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

Document
1759-5
1-5 Filed 11/04/20 Page 2 of 3
JS 44$REVISED June, 2009

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA
THIS CASE DESIGNATION SHEET MUST BE COMPLETED
PART A
This case belongs on the ( Erie Johnstown Pittsburgh) calendar.
1. ERIE CALENDAR - If
cause of action arose in the counties of Crawford, Elk, Erie,
Forest, McKean. Venang or Warren, OR any plaintiff or defendant resides in one of said
counties.
2. JOHNSTOWN CALENDAR - If cause of action arose in the counties of Bedford, Blair,
Cambria, Clearfield or Somerset OR any plaintiff or defendant resides in one of
said counties.
3. Complete if on ERIE CALENDAR: I certify that the cause of action arose in

County and that the resides in County.
4. Complete if on JOHNSTOWN CALENDAR: I certify that the cause of action arose in

County and that the resides in County.
PART B (You are to check ONE of the following)

1. This case is related to Number . Short Caption .
2. This case is not related to a pending or terminated case.
DEFINlTIONS OF RELATED CASES:

CIVIL: Civil cases are deemed related when a case filed relates to property included in
another suit or involves the same issues of fact or it grows out of the same transactions
as another suit or involves the validity or infringement of a patent involved in another
suit EMINENT DOMAIN: Cases in contiguous closely located groups and in common ownership
groups which will lend themselves to consolidation for trial shall be deemed related.
HABEAS CORPUS & CIVIL RIGHTS: All habeas corpus petitions filed by the same individual
shall be deemed related. All pro se Civil Rights actions by the same individual shall be
deemed related.
PARTC
I. CIVIL CATEGORY (6HOHFWWKHapplicable category).
1. Antitrust and Securities Act Cases
2. Labor-Management Relations
3. Habeas corpus
4. Civil Rights
5. Patent, Copyright, and Trademark
6. Eminent Domain
7. All other federal question cases
8. All personal and property damage tort cases, including maritime, FELA,
Jones Act, Motor vehicle, products liability, assault, defamation, malicious
prosecution, and false arrest
9. Insurance indemnity, contract and other diversity cases.
10. Government Collection Cases (shall include HEW Student Loans (Education),
V A 0verpayment, Overpayment of Social Security, Enlistment
Overpayment (Army, Navy, etc.), HUD Loans, GAO Loans (Misc. Types),
Mortgage Foreclosures, SBA Loans, Civil Penalties and Coal Mine
Penalty and Reclamation Fees.)
I certify that to the best of my knowledge the entries on this Case Designation
Sheet are true and correct
/s/ Barry I Friedman
Date: November 4, 2020
ATTORNEY AT LAW
NOTE: ALL SECTIONS OF BOTH FORMS MUST BE COMPLETED BEFORE CASE CAN BE PROCESSED.
JS 44 Reverse (Rev. 10/20) Case 2:20-cv-01692-AJS
Document
1759-5
1-5 Filed 11/04/20 Page 3 of 3
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.

BC Media v. Chawla - Complaint

Uploaded by

Document Information

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

BC Media v. Chawla - Complaint

Uploaded by

Copyright:

Available Formats

Case 2:20-cv-01692-AJS

Active Photo Services Pvt. Ltd., states as follows:

Phase 1, Chandigarh CH 160002 INDIA.

281, 283, 284 and 285.

U.S.C. §§ 1331 and 1338(a).

more particularly pursuant to F.R.C.P. 4(k)(2)(A).

7. Venue is proper in this District pursant to 28 U.S.C. §§ 1391(c)(3) and 1400(b).

8. The averments of Paragraphs 1 through 7 of the Verified Complaint are

incorporated herein by reference as if set forth in full.

attached hereto as Exhibit B and is incorporated herein by reference.

Crane having the following design:

Patents in contravention of 35 U.S.C. § 271(a) by manufacturing, using, offering to manufacture

violation of BC Media’s rights.

http://www.proaim.com, which, on information and belief, Plaintiff alleges is created, designed,

controlled and maintained by Defendants, an illustrative page of which is attached hereto as

page of which is attached hereto as Exhibit D.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff prays:

B. That Plaintiff recover from Defendants Plaintiff’s actual monetary damages

for the sale of infringing camera jibs;

within 30 days of judgment herein; and

Metz Lewis Brodman Must O’Keefe LLC

By: /s/Barry I. Friedman

Attorneys for Plaintiff

%$*$ *.()$*$ % $,(*%(%$(

))**#$*$,(*%$)#)+ **%*&$"*)%&( +(.+$(*"-)

% * $* **) 

Enter Your Email × D

What are you looking for?

Home Proaim Astra Camera Jib Crane

How can we help? We're here for you!

Type your message…

Enter Your Email × D

How can we help? We're here for you!

Type your message…

Enter Your Email × D

How can we help? We're here for you!

Type your message…

Enter Your Email × D

Proaim Astra 4ft Camera Jib Crane (JB-AS04-00)

Proaim Heavy Duty Jib Stand (P-JS) (+$80)

Description Specifications Included

Filmmaking - Proaim Astra 4' Jib!

High Build Quality. Completely Tool-Less.

Quick Setup. Most Affordable Jib Crane.

Invest In Quality and Add Inspiring Shots

How can we help? We're here for you!

Type your message…

Enter Your Email × D

"WHAT YOU SEE IS WHAT YOU GET"

How can we help? We're here for you!

Type your message…

Enter Your Email × D

Enter Your Email × D

Type your message…

View More Videos Here

Enter Your Email × D

Compatible With Ronin Gimbal

How can we help? We're here for you!

Type your message…

Enter Your Email × D

How can we help? We're here for you!

Type your message…

Enter Your Email × D

%$$.()$$ %$,(%(%$(

))#$$,(%$)#)+ **%&$")%&( +(.+$(*"-)

% $ )