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Case: 1:21-cv-03987 Document #: 1 Filed: 07/27/21 Page 1 of 10 PageID #:1

UNITED STATES DISTRICT COURT


FOR THE NORTHERN DISTRICT OF ILLINOIS

HEADWATERS, INC.,
a Massachusetts corporation,

Plaintiff, Case No.: 21-3987

v.

THE PARTNERSHIPS AND


UNINCORPORATED ASSOCIATIONS
IDENTIFIED ON SCHEDULE A,

Defendants.
________________________________________________________________

COMPLAINT AND DEMAND FOR JURY TRIAL

For this Complaint and Demand for Jury Trial in this matter, Plaintiff Headwaters, Inc.

alleges as follows:

PARTIES

1. Plaintiff Headwaters, Inc. (“Headwaters”) is a corporation organized under the laws

of the State of Massachusetts with its principal place of business at 134 Pleasant Street,

Marblehead, MA 01945.

2. Upon information and belief, the partnerships and unincorporated associations

identified on Schedule A (“Defendants”) are residents of the .

JURISDICTION AND VENUE

3. This Court has original subject matter jurisdiction over the claims in this action

pursuant to the provisions of the Patent Act, 35 U.S.C. § 1, et seq., 28 U.S.C. § 1338(a)-(b), and

28 U.S.C. § 1331.

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4. Venue is proper in this Court pursuant to 28 U.S.C. § 1391 because each of the

Defendants specifically targets business activities toward consumers in the United Sates, including

in Illinois, through the operation of fully interactive e-commerce stores that operate under the seller

usernames (the “Seller Usernames”) identified in the attached Schedule A. Specifically, the

Defendants have targeted residents of the State of Illinois by creating and advertising e-commerce

stores to Illinois residents, offering goods to residents of the State of Illinois through those e-

commerce stores, and manufacturing, selling, and shipping goods to residents of the State of

Illinois that infringe upon Headwaters’ patent rights. Each of the Defendants is committing tortious

acts in Illinois, is engaging in interstate commerce, and has wrongfully caused Headwaters

substantial injury in the State of Illinois.

INTRODUCTION

5. Headwaters has filed this action to stop the widescale infringement of its patent

rights and to stop Defendants from making, using, offering for sale, selling, and/or importing into

the United States for subsequent sale or use unauthorized and unlicensed products, specifically,

air purifiers that infringe upon Headwaters’ utility patent, U.S. Patent No. 6,919,053 (the “’053

Patent”), a copy of which is attached as Exhibit 1, referred to as the “Infringing Products”. The

Defendants have created e-commerce stores and have utilized third party e-commerce platforms,

such as Amazon.com, to make, use, offer for sale, sell, advertise and/or otherwise deal with, and/or

import into the United States for the subsequent sale or use the Infringing Products. These

ecommerce stores utilize similar names and advertise, offer for sale and/or sell similar products,

which ties them together and that suggests that Defendants are operating under a common scheme

and that the claims asserted in this case arise out of the same transaction, occurrence, or series of

occurrences.

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STATEMENT OF FACTS

Plaintiff’s Business

6. Headwaters is a corporation organized under the laws of the State of Massachusetts

with its principal place of business at 134 Pleasant Street, Marblehead, MA 01945.

7. Headwaters is well and favorably known throughout the United States as a

developer and retailer of personal air purifiers sold under the AIRTAMER trademark, and

Headwaters have been substantially, continuously and extensively marketed worldwide its

AirTamer products.

8. Headwaters’ AirTamer products are wearable personal battery-operated air

purifiers that utilize negative ions and electrostatic purification to clean the air of pollutants around

an individual’s head.

9. Headwaters sells its products through its own website at https://www.airtamer.com

and through third party retailers such as Amazon.com and Walmart.com.

10. Headwaters’ AirTamer products are known for their patented design, structure,

composition, and/or function, which uses a portable, low power, battery-operated ion generator

that is worn in the form of a pendant necklace and can be operated with a standard coin cell or

rechargeable battery.

11. More specifically, Headwaters’ AirTamer products utilize a conductive lanyard

whereby the body becomes electrically connected to the device’s electrical circuit to serve as a

counter-electrode to induce emission of ions by the ion-emitter contained within the device.

12. Headwaters is the lawful assignee of all rights, titles, and interest in and to, and has

obtained patent protection of the ‘053 Patent for the invention “Portable ion Generator and Dust

Collector” which is registered with the United States Patent and Trademark Office.

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The Defendants

13. Defendants are individuals and business entities who own and operate one or more

of the e-commerce stores identified in Schedule A and other sellers who are not yet known to

Headwaters.

14. Defendants are believed to reside in or operate from the

and manufacture and distribute their products from the .

15. Upon information and belief, and based on private investigative reports performed

by contractors for Headwaters, Defendants are located within the .

16. Upon information and belief, Defendants either individually or jointly operated one

or more of the e-commerce stores under the Seller Usernames identified in Schedule A. Defendants

have attempted to conceal their identities and the scope of their counterfeiting operations to make

it virtually impossible for Headwaters to learn their true identities and the interconnectedness of

their network.

DEFENDANTS’ INFRINGEMENT

17. Headwaters has not assigned or licensed the ‘053 Patent to anyone, including

Defendants.

18. The Defendants manufacture, advertise, offer to sell, and sell the Infringing

Products titled under the following model numbers: , , and .

19. The Infringing Products infringe one or more claims of the ‘053 Patent.

20. Specifically, and not by way of limitation, the Infringing Products infringe

independent claims 5 and 17, and dependent claim 6, of the ‘053 Patent.

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21. Headwaters has identified a number of e-commerce stores, including those

operating under the Seller Usernames, which have advertised, offered for sale or sold Infringing

Products to consumers in the State of Illinois and throughout the United States.

22. The third-party service providers utilized by the Defendants do not adequately

require sellers to confirm their identities, which allows infringers to use false or obscured names

and addresses.

23. These third-party online commerce platforms often allow sellers to have many

different profiles under a number of false or obscured names that allow the sellers to appear

unrelated even though the Defendants’ e-commerce stores are believed to be commonly owned

and operated with their products being sourced from the same places.

24. Defendants have created e-commerce stores and have listed their Infringing

Products for sale on e-commerce platforms that target sales to Illinois residents.

25. Defendants’ e-commerce stores and listings offer to ship Infringing Products into

the State of Illinois.

26. Upon information and belief, Defendants have sold and shipped Infringing

Products to individuals located within the State of Illinois.

27. Defendants deal and/or sell identical and/or highly similar Infringing Products by

way of using a variety of Seller Usernames and/or by utilizing similar and/or the same advertising

techniques and marketing materials across their e-commerce stores and their listings on e-

commerce platforms.

28. Defendants’ e-commerce stores accept payment in US Dollars via Google Pay,

PayPal, and via credit card through the Amazon.com platform.

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29. Upon information and belief, Defendants have utilized false, inaccurate,

misleading, or incomplete contact information when creating the accounts associated with the

Seller Usernames without the consent and/or authority of Headwaters and/or fraudulently to

obfuscate their infringement scheme from the e-commerce platforms through which they deal

and/or sell their Infringing Products to the consuming public.

30. Even though Defendants operate under multiple usernames and accounts, the e-

commerce stores and Seller Usernames set out in Schedule A share common identifiers, such as

the sale of identical products, the use of identical or similar marketing copy, the use of identical

product photographs, and the acceptance of similar methods of payments.

31. Through various test buys and the research conducted by a team of private

investigators who were personally situated within the , Headwaters

believes that the Infringing Products sold by Defendants are manufactured in the same location

and that Defendants are believed to be directly related to the manufacturer of the Infringing

Products.

32. Upon information and belief, Defendants are in regular communication with each

other and share tactics for avoiding detection and litigation.

33. Upon information and belief, Defendants operate under the Seller Usernames so

that they can continue operating despite Headwaters’ enforcement efforts. Specifically, upon

information and belief, Defendants receive payments from US consumers through their US-based

payment accounts and then quickly transfer the money received to other overseas bank accounts

to avoid the seizure of their accounts due to their infringing activities by the relevant authorities

and to avoid the payment of any monetary judgment rendered in litigation.

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34. Headwaters, through counsel, has previously issued demand letters to several of the

Defendants presumed contact information, notifying them of their infringement, and those

warnings have gone unheeded.

35. Defendants’ infringement of the ’053 Patent in making, using, offering for sale,

advertising and/or otherwise dealing with, selling, and/or importing the Infringing Products into

the United States is willful.

36. Defendants’ infringement of the ’053 Patent in connection with the making, using,

offering for sale, advertising and/or otherwise dealing with, selling, and/or importing into the

United States for subsequent sale or use of the Infringing Products, including the making, using,

offering for sale, advertise and/or otherwise deal with, selling, and/or importing into the United

States for subsequent sale or use of Infringing Products into the State of Illinois, is irreparably

harming Headwaters.

COUNT I
PATENT INFRINGEMENT OF THE ‘053 PATENT
UNDER 35 U.S.C. § 271

37. Plaintiff incorporates by reference each and every one of the preceding allegations

as if set forth fully herein.

38. Defendants manufacture, use, offer to sell, sell advertise and/or otherwise deal with

air purifier products that embody the invention claimed in Plaintiff’s ‘053 Patent and continue to

do so.

39. The foregoing activities constitute infringement of the ‘053 Patent in violation of

35 U.S.C. § 271 and Defendants will continue to infringe the ’053 Patent until enjoined by this

Court.

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40. Defendants have caused Plaintiff irreparable harm for which there is no adequate

remedy at law.

41. As a result of Defendants’ actions, Plaintiff has suffered damages.

42. This is an exceptional case as that term is defined by 35 U.S.C. § 285.

COUNT II
WILLFUL PATENT INFRINGEMENT OF THE ‘053 PATENT
UNDER 35 U.S.C. § 271

43. Plaintiff incorporates by reference each and every one of the preceding allegations

as if set forth fully herein.

44. Defendants manufactured, used, offered to sell, advertised and/or otherwise dealt

with and sold air purifiers that embody the invention of the Plaintiff’s ‘053 Patent.

45. The foregoing activities constitute infringement of the ‘053 Patent in violation of

35 U.S.C. § 271 and Defendants will continue to infringe the ‘053 Patent until enjoined by this

Court.

46. Defendants have caused Plaintiff irreparable harm for which there is no adequate

remedy at law.

47. Defendants’ infringement has been willful by making, using, selling, advertise

and/or otherwise deal with, or offering to sell air purifiers that embody the invention of Plaintiff’s

‘053 Patent with knowledge that their conduct was an infringement of Plaintiff’s ‘053 Patent.

48. As a result of Defendants’ willful infringement, Plaintiff has suffered damages.

49. This is an exceptional case as that term is defined by 35 U.S.C. § 285.

REQUEST FOR RELIEF

Plaintiff respectfully requests this Honorable Court:

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A. Permanently enjoin Defendants and their officers, agents, servants, employees, and

attorneys, and those in active concert or participation with them who receive actual notice

of the Order, from infringing the ‘053 Patent and manufacturing, selling, offering to sell,

or using the products that infringe the ‘053 Patent;

B. Award Plaintiff monetary damages adequate to compensate Plaintiff for past infringement

consistent with Defendants’ profits on its sale of infringing air purifier products pursuant

to 35 U.S.C. § 289 but not less than a reasonable royalty under 35 U.S.C. § 284;

C. Treble the amount of damages assessed in view of the willful infringement by Defendants,

together with costs and prejudgment interest;

D. Award Plaintiff its reasonable attorney fees pursuant to 35 U.S.C. § 285; and

E. Award all other relief this Court deems appropriate.

Respectfully submitted,

Date: July 27, 2021 Headwaters, Inc.

/s/ John Di Giacomo


John Di Giacomo
Eric Misterovich
Amanda Osorio
Attorneys for Plaintiff
Revision Legal, PLLC
444 Cass St., Suite D
Traverse City, MI 49684
Phone: (231) 714-0100
Fax: (231) 714-0200
john@revisionlegal.com
eric@revisionlegal.com
amanda@revisionlegal.com

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Case: 1:21-cv-03987 Document #: 1 Filed: 07/27/21 Page 10 of 10 PageID #:10

JURY DEMAND

Plaintiff hereby requests a trial by jury for all eligible counts contained within this

Complaint.

Respectfully submitted,

Date: July 27, 2021 Headwaters, Inc.

/s/ John Di Giacomo


John Di Giacomo
Attorneys for Plaintiff
Revision Legal, PLLC
444 Cass St., Suite D
Traverse City, MI 49684
Phone: (231) 714-0100
Fax: (231) 714-0200
john@revisionlegal.com
eric@revisionlegal.com
amanda@revisionlegal.com

10
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SCHEDULE A
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EXHIBIT 1
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USOO691.9053B2

(12) United States Patent (10) Patent No.: US 6,919,053 B2


Joannou (45) Date of Patent: Jul.19, 2005

(54) PORTABLE ION GENERATOR AND DUST 5,196,171 A 3/1993 Peltier ........................ 422/121
COLLECTOR 5,296,019 A 3/1994 Oakley et al. . ... 96/95
5,435,837 A 7/1995 Lewis et al. ................... 96/54
(76) Inventor: Constantinos J. Joannou, 93 Hobart t A 5. Siberg - - - - - - - - - - - - - - - - - - - - - - 2.
2- ---Y-2 OaC) -- - -

RSK's y (Nepean), Ontario 5.535,089 A 7/1996 Ford et al. . ... 361/231


s 5,538,692 A 7/1996 Joannou ..................... 422/121
- 5,578,112 A 11/1996 Krause .......................... 96/24
(*) Notice: Subject to any disclaimer, the term of this 5,607,497 A 3/1997 Brown ............................ 95/3
patent is extended or adjusted under 35 5,667,564 A 9/1997 Weinberg . ... 96/58
U.S.C. 154(b) by 79 days. 5,814,135 A 9/1998 Weinberg ...................... 96/58
6,042,637 A 3/2000 Weinberg ...................... 96/58
(21) Appl. No.: 10/067,433 6,077,334 A 6/2000 Joannou - - - - - - - ... 96/66
6,126,722 A 10/2000 Mitchell et al. ... 95/57
(22) Filed: Feb. 7, 2002 6,149,717. A 11/2000 Satyapal et al. ............... 96/16
O O 6,176,977 B1 1/2001 Taylor et al. ............... 204/176
(65) Prior Publication Data 6,312,507 B1 11/2001 Taylor et al. .. ... 96/19
6,379.427 B1 4/2002 Siess ......... ... 95/57
US 2003/0147784 A1 Aug. 7, 2003 6,508.982 B1 1/2003 Shoji........................... 422/22
(51) Int. Cl. ................................................. B01J 19/08 2.2- Y-12 E. 2. E.
aylor etIt al...
al. . . . . . . . . . . . . .1st
..
(52) ... 422/186; 422/186.04 6,632,407 B1 10/2003 Lau et al. ................... 422/186
(58) Field of Search ............................. 422/186, 186.04
* cited by examiner
56 References Cited
(56) Primary Examiner Steven Versteeg
U.S. PATENT DOCUMENTS (74) Attorney, Agent, or Firm-David J. French
2,590,447 A 3/1952 Nord, Jr. .................... 128/393 (57) ABSTRACT
2.949,550 A 8/1960 Brown .......................... 31.0/5
3,096,762 A 7/1963 Winchell et al. ............ 128/190 This invention relates to a portable, battery-operated ion
4,173,229 A 11/1979 Halfon .............. 128/419 R generator featuring an electronic high Voltage System which
4,227,894. A 10/1980 Proynoff ...................... 55/126 uses extremely low battery power. The ion generator can be
4,477.263 A 10/1984 Shaver et al....... ... 55/6 made in the form of a pendant using a Standard 9-volt
4,632,135 A 12/1986 Lenting et al. ... ... 132/85 alkaline battery, which can last for Several months of con
4,643,745 A 2/1987 Sakakibara et al. ... 55/137 tinuous operation. The ion generator can also Serve as a dust
4,713,724 A 12/1987 Voelkel ............. ... 361/231 llector f rol. ificati I ticular, the dust collecti
4,811,159 A 3/1989 Foster, Jr. . ... 361/231 collector Ior air purlineauon. In particular, Ine aust collecting
4.941,068 A 7/1990 Hofmann .... ... 361/231 electrode is removable for ease of cleaning.
5,024,685 A 6/1991 Torok et al. .... ... 55/117
5,141529 A 8/1992 Oakley et al. ................... 55/2 22 Claims, 3 Drawing Sheets
Case: 1:21-cv-03987 Document #: 1-2 Filed: 07/27/21 Page 3 of 9 PageID #:15

U.S. Patent Jul.19, 2005 Sheet 1 of 3 US 6,919,053 B2

sef F.G. 1

FIG 3
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U.S. Patent Jul.19, 2005 Sheet 2 of 3 US 6,919,053 B2


Case: 1:21-cv-03987 Document #: 1-2 Filed: 07/27/21 Page 5 of 9 PageID #:17
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US 6,919,053 B2
1 2
PORTABLE ON GENERATOR AND DUST output capacitor. This capacitor can be the last capacitor of
COLLECTOR a diode-capacitor multiplier circuit in the form of a “ladder”
network. Either a Single capacitor or group capacitors con
Stitutes a capacitor means, as hereafter So referenced. The
FIELD OF THE INVENTION capacitors in the bank of capacitors in the diode-capacitor
multiplier each charges up to twice the output transformer
This invention relates to ion generators and in particular Voltage. The entire diode-capacitor ladder network multi
battery-operated portable ion generators for personal use and plier can build the voltage up by 10 times or more. The
for air purification. output capacitor means in all cases Supplies Voltage to the
ionizing element, e.g. to an ion generating needle(s).
BACKGROUND TO THE INVENTION In my experiments, I have found that the Voltage on the
Negative ion generators have been extensively used for output capacitor means will remain high for a while even
many years to improve the air environment in a room or in after the input the oscillator Stops operating. The reason for
a car. Typically these ion generators require power from this is that the ionizing needle(s) take a very Small current
household outlets or from car cigarette lighter Sockets. This 15 out of the capacitor means (a few microamperes). In View of
fact makes Such units awkward to install because of the the above, I reasoned that the oscillator does not have to be
wires involved. operating all the time in order to provide Sufficient Voltage
Ion generators have also been used as air purifiers by to the ionizing needle(s). Instead it can operate intermit
acting as dust collectors. An example of Such an application tently. In this way, a lot of energy from the battery can be
Saved.
is U.S. Pat. No. 5,538,692 (adopted by reference herein). Thus, according to the invention, the driving oscillator is
During my experiments with ionizers, I found that a good turned ON for only intermittent intervals, e.g. only approxi
Stream of ions can be produced having a very Small current mately one tenth of the time, without much loSS of output
passing through the ionizing needles. For instance 1 micro voltage on the ionizing needle(s). In particular, an experi
ampere of current will produce (10x6.28x10') or 6.28x 25 mental ionizer operating from a 9-volt battery has been
107 ions per second where 6.28x10°X is Avogadro's shown to draw only 120 microamps from the battery and is
number, namely the number of electrons in one Coulomb of expected to last for in excess of three months of continuous
charge. One coulomb per Second is one ampere. Therefore, operation.
the number of ions per Second generated by a current of one In making ion generators completely Self contained with
microampere is 628 followed by 15 Zeroes. out connection to a power outlet, there is a need to provide
ASSuming the ionizer is powered by a 9 Volt battery and a counter electrode. The counter electrode must be con
assuming an ideal transformation circuit to generate high nected to an output lead of the transformer to provide a
voltage, the current drawn from the battery would be current flow through the ladder network. Normally this lead
inversely proportional to the voltage of the battery. Thus, if would be grounded to earth through the power Source i.e. the
the ionizing voltage is 6x10 volts, the battery current drawn 35 grid power outlet or the cigarette lighter Socket in a car. But
from a 9 volt battery would be 1x10'x(6x10/9)=0.666 in case of a Self-contained unit, there is no readily apparent
milliamps. Even if one assumes a 50% efficient for a place for connection of the counter electrode.
practical transformation circuit, a battery current of only be I have found that a relatively large conducting body
1.33 milliamps would be required to generate 6.28x10" compared to the ion emitter can be made to act as a counter
ions/sec. Current of this magnitude could be easily accom 40 electrode. This can be a large piece of metal that the unit sits
modated by an ordinary battery, particularly those of the on or a human body, as in the case where an ionizer is worn
alkaline type. as a pendant. Conveniently, the Strap or chain Suspending the
My present invention provides for such an efficient volt ionizer may provide the electrical connection to the body.
age converter. Ions will then be drawn to the body completing the circuit.
It is therefore an object of my invention to provide an ion 45 When a large plate is used as the counter-electrode, it will
generator which is portable, battery operated and Small attract the ions being generated, thus similarly completing
enough to be worn as a pendent with a very long battery life. the electrical circuit.
It is another object of my invention to provide a battery According to a further aspect, my invention provides a
operated, Self-contained, ionizing dust collector which can Self contained battery-operated ionizer which can also col
be placed on a desk or on a car dash. 50 lect dust by using a conductive or partially conductive dust
The invention in its general form will first be described, collecting Surface which is connected as a counter electrode.
and then its implementation in terms of Specific embodi This dust collecting Surface, which is of an opposite polarity
ments will be detailed with reference to the drawings from that of the needle(s), collects the dust particles which
following hereafter. These embodiments are intended to are charged by the ions emitted by the ionizing needle(s) in
demonstrate the principle of the invention, and the manner
55 the manner of U.S. Pat. No. 5,538,692. An especially useful
of its implementation. The invention in its broadest and feature of this present invention is that the dust collecting
more specific forms will then be further described, and Surface is separable from its base and may be removed for
defined, in each of the individual claims which conclude this cleaning.
Specification. The foregoing Summarizes the principal features of the
60
invention and Some of its optional aspects. The invention
SUMMARY OF THE INVENTION may be further understood by the description of the pre
ferred embodiments, in conjunction with the drawings,
My invention, in one aspect is based on a circuit which which now follow.
includes an oscillator which changes the battery voltage BRIEF DESCRIPTION OF THE DRAWINGS
from DC to AC. The AC voltage is then transformed to a 65
higher Voltage by a Voltage conversion circuit. Preferably, FIG. 1 shows the basic electronic circuit for the battery
Such a circuit includes a transformer which charges an operated portable ionizer.
Case: 1:21-cv-03987 Document #: 1-2 Filed: 07/27/21 Page 7 of 9 PageID #:19

US 6,919,053 B2
3 4
FIG. 1a is a timing diagram showing the current wave tive Voltage on capacitor 7. This negative Voltage buildup
form over time at the input to the transformer of FIG. 1. eventually biases the transistor OFF. This state lasts until the
FIG. 1b is a timing diagram showing how the high Voltage Voltage accumulated on the capacitor 7 leaks off via the
at the output of the diode-capacitor multiplier varies with resistor 8 and the proceSS Starts all over again.
time. FIG. 3 shows a practical application of one aspect of the
FIG. 2 is a practical circuit which produces the waveform invention where a battery-operated negative ion generator is
of FIG. 1a. made into a pendant 9. Strap 10 is made of either a metallic
FIG. 3 shows an ionizer made into a pendant with a chain or a cord made of conducting plastic or the like. Strap
conductive cord by which can be worn by a person. The 10 is connected internally to the ground terminal of the
perSon in Such case acts as the counter electrode. transformer or diode-capacitor multiplier. The wearer acts as
the counter electrode to the needle electrode 5. Other forms
FIG. 4 is a similar circuit as that of FIG. 1 intended for a
of conductive connection means to the body may also be
dust collector with the addition of an optional Second provided, Such as by a metal plate that is held in the hand.
diode-capacitor multiplier to produce a Second Voltage of FIG. 4 is a variant of the circuit of FIG. 1. Here, another
opposite polarity which is connected to an element which 15 diode-capacitor multiplier 4a is added to produce a positive
acts as the counter electrode.
high Voltage. The positive high Voltage of ladder network 4a
FIG. 5 shows a practical application of the circuit of FIG. is connected to a metal counter electrode, in this case ring
4, wherein the ring in the middle of the cylinder acts as the 11. (Polarities in this and other applications may be
counter electrode and also collects dust which is charged by reversed). This ring 11 is exposed to receive dust particles 22
the ions. charged by ions 21 emitted by needle 5. Upon being
FIG. 6 shows another application of the apparatus of FIG. discharged by contact with ring 11 the dust particles 22 will
5. In this case a removable conducting ring is located above generally remain attached to the ring 11. Periodically, the
the ionizing needle. Ions generated by the needle are ring 11 may be cleaned of Such dust particles.
attracted to the ring, which also collects dust which has been FIG. 5 shows an arrangement where the ionizer unit is
charged by the ions. 25
made in a cylindrical case 12 Serving as a base having an
DESCRIPTION OF THE PREFERRED
ionizing needle 5 on top and the counter electrode ring 11 in
EMBODIMENT
the middle of the case. The ring 11, being for example at
positive potential, attracts anything that is charged nega
In FIG. 1, a battery 1 supplies power to electronic circuit tively including dust 22. In this way, the ionizer also
2. Circuit 2 provides an AC voltage to transformer 3. Circuit becomes an air cleaner.
2 is Such that it produces an interrupted or intermittent AC FIG. 6 shows a similar arrangement as that of FIG. 5,
voltage to transformer 3 as shown in FIG.1a. While a single except in this arrangement the counter electrode ring 11 is
high Voltage transformer may be employed as a voltage located, for example above the ionizing needle 5, mounted
conversion circuit, a preferred System relies upon a ladder 35 above a base 23 by spaced struts 25 which serve as a support
network as in FIG.1. Connected to the output of transformer and provide electrical contact between the circuit 2 and ring
3 is a diode-capacitor multiplier 4 which produces a high 11. Air may pass freely over this base 23, flowing to the
voltage (in this case negative) to ionizing needle 5 which needle 5 and upwardly through the ring 11. The dust
Serves on an ion-emitter. Ions 21 are rapidly repelled out particles 22, charted by the negative ions 21 produced by the
wardly from the tip of the needle 5 by their repulsive charge. 40 needle 5, are attracted by the positively charged ring 11
During the period of time when circuit 2 is active (ON), the which acts as a counter electrode. Some of the charged dust
capacitors in the diode-capacitor multiplier 4 get charged up; 22 attracted by the ring 11 adheres to it. The ring 11 in FIG.
and during the inactive period (OFF), the capacitors keep 6 may be readily removed from its Support for cleaning.
their voltage minus a Small amount due to current drawn out The relative positions of the ring 11 and needle 5 requires
by the ionizing needle. 45 only that they be in a Spaced relationship So that, mixed with
FIG.1b shows the waveform of the voltage at the ionizing air, ions will flow from the needle 5 to the ring
needle. With this arrangement, the ionizing needle keeps CONCLUSION
emitting ions even during the time when the circuit 2 is OFF.
The ratio of time during which circuit 2 is ON as compared The foregoing has constituted a description of Specific
to the time it is OFF can be as much as 10 to 1 or greater. 50 embodiments showing how the invention may be applied
The current drain on the battery is much smaller than if the and put into use. These embodiments are only exemplary.
circuit 2 were ON continuously. In this way, a battery The invention in its broadest, and more Specific aspects, is
Supplying power to the ionizer unit will last for a very long further described and defined in the claims which now
time with very little sacrifice in efficiency of the ionizer. In follow.
one case, an ionizer built using a Standard 9 volt alkaline 55 These claims, and the language used therein, are to be
battery is estimated to last for 3 months of continuous understood in terms of the variants of the invention which
operation. Using larger batteries, Size C for example, a have been described. They are not to be restricted to such
portable ionizer can be built where the batteries may last for variants, but are to be read as covering the full Scope of the
more than a year, Subject to their inherent shelf-life. invention as is implicit within the invention and the disclo
FIG. 2 shows a very simple circuit for an oscillator which 60 Sure that has been provided herein.
can be used to produce the intermittent Voltage. A tickler coil The embodiments of the invention in which an exclusive
20 on the transformer 3 induces oscillations because the base property or privilege is claimed are defined as follows:
of transistor 6 receives an out-of-phase Voltage from the 1. A portable battery operated ionizer comprising:
transformer 3 which produces positive feedback causing a) an electrical circuit adapted to be powered by a
oscillations. When the oscillator starts, the base circuit 65 low-voltage current Supplied by a battery;
winding produces an AC voltage which gets rectified by the b) an oscillator circuit within the electrical circuit for
base-emitter junction of the transistor and develops a nega being powered by the low-voltage current Supplied by
Case: 1:21-cv-03987 Document #: 1-2 Filed: 07/27/21 Page 8 of 9 PageID #:20

US 6,919,053 B2
S 6
the battery, Said oscillator circuit being connected to a 9. An ionizer as in claim 8 wherein the oscillator, when it
Voltage conversion circuit to provide an ionizing Volt is not producing oscillations, is not producing Oscillations
age to an output capacitor means, for up to ten times as long as when the oscillator is producing
oscillations.
c) am ion-emitter connected to receive charge from the 10. An ionizer as in claim 6 comprising intermittent
Voltage conversion circuit and output capacitor means,
Said ion-emitter being eXposed for possible direct oscillator control mean whereby said oscillator produces
manual contact by a user and for release of ions into the intermittent oscillations Such that the Voltage established at
Surrounding environment; and the output capacitor means provides Said ionizing Voltage
while oscillations are occurring, and wherein Said ion emis
d) electrode connection means to provide for a counter Sion continues during the time the oscillator is not producing
electrode to be connected to Said electrical circuit, to oscillations, Supplied by charge from the output capacitor
induce the emission of ions from the ion-emitter, CS.
wherein Said oscillator producer intermittent oscilla 11. An ionizer as in claim 10 wherein the oscillator, when
tions Such that the Voltage established at the output it is not producing oscillations, is not producing Oscillations
capacitor means is an ionizing Voltage and wherein, ion 15 for up to ten times as long as when the oscillator is producing
emission continues from Said ion-emitter during the oscillations.
time the Oscillator is not producing oscillations, Sup 12. An ionizer as in claim 5 wherein the Voltage conver
plied by charge from the output capacitor means. Sion circuit comprises a diode-capacitor multiplier network
2. An ionizer as in claim 1 wherein She Voltage conversion driven by transformer for producing Said ionizing Voltage,
circuit comprises a high Voltage Step-up transformer and the and Said diode-capacitor multiplier network comprises Said
output capacitor means comprises a diode-capacitor multi out put capacitor means.
plier network driven by the transformer for producing Said 13. An ionizer as in claim 12 comprising intermittent
ionizing Voltage. oscillator control means whereby Said oscillator produces
3. An ionizer as in claim 1 wherein Said electrode con intermittent oscillations Such that the Voltage established at
nection means comprises a conductive connection means 25
the output capacitor means provides Said ionizing Voltage
whereby an external body may become electrically con while oscillations are occurring, and wherein Said ion emis
nected to Said electrical circuit to Serve as at least part of the Sion continues during the time the oscillator is not producing
counter-electrode. oscillations, Supplied by charge item the output capacitor
4. An ionizer as in claim 3 wherein Said conductive CS.
connection means is a conductive Strap that Supports the 14. An ionizer as in claim 13 wherein the oscillator, when
ionizer as a pendant for attachment to a human being as the it is not producing oscillations, is not producing Oscillations
external body. for up to ten times as long as when the oscillator is producing
5. A battery-operated, portable ionizer comprising: oscillations.
a) an electrical circuit adapted to be powered by a 15. An ionizer as in claim 5 comprising intermittent
low-voltage current Supplied by a battery; 35 oscillator control means whereby Said oscillator produces
b) an oscillator circuit within the electrical circuit for intermittent oscillations Such that the Voltage established at
being powered by the low-voltage current Supplied by the output capacitor means is an ionizing Voltage and
the battery; wherein Said ion emission continues during the time the
c) a voltage conversion circuit connected to the oscillator oscillator is not producing oscillations, Supplied by charge
circuit to provide an ionizing Voltage to an output 40
from the output capacitor means.
capacitor means, 16. An ionizer as in claim 15 wherein the oscillator, when
d) an ion-emitter connected to receive charge from the it is not producing oscillations, is not producing Oscillations
Voltage conversion circuit and output capacitor means for up to ten times as long as when the oscillator is producing
oscillation.
and provide ion-emission, Said ion-emitter being 17. A battery-operated, portable ionizer comprising:
exposed, when in use, for release of ion into the open 45
air, and a) an electrical circuit adapted to be powered by a
e) a conductive connection means whereby an external low-voltage current Supplied by a battery;
body may become electrically connected to Said elec b) an oscillator circuit within the electrical circuit pow
trical circuit to Serve as, at least, part of a counter ered by the low-voltage current Supplied by the battery;
electrode to induce emission of ions by the ion-emitter. 50 c) a voltage conversion circuit connected to the oscillator
6. An ionizer as in claim 5 wherein Said conductive circuit to provide an ionizing Voltage to an output
connection means is a conducive Strap that Support the capacitor means,
ionizer as a pendant for attachment to a human being as the d) an ion-emitter connected to receive charge from the
external body. Voltage conversion circuit and output capacitor means,
7. An ionizer as in claim 6 wherein the Voltage conversion 55 Said ion-emitter being exposed, when in use, for release
circuit comprises a diode-capacitor multiplier network of ions into the open air, and
driven by a transformer for producing Said ionizing Voltage, e) a conductive connection means whereby a human body
and Said diode-capacitor multiplier network comprises said may become electrically connected to Said electrical
out put capacitor means. circuit to Serve as a counter-electrode to induce emis
8. An ionizer as in claim 7 comprising intermittent oscil 60 Sion or ions by the ion-emitter.
lator control means whereby said oscillator produces inter 18. An ionizer as in claim 17 wherein the voltage con
mittent oscillations Such that the Voltage established at the version circuit comprises a diode-capacitor multiplier net
output capacitor means provides Said ionizing Voltage while work driven by a transformer for producing Said ionizing
oscillations are occurring, and wherein Said ion emission Voltage, and Said diode-capacitor multiplier network com
continues during the time the Oscillator is not producing 65 prises Said out put capacitor means.
oscillations, Supplied by charge from the output capacitor 19. An ionizer as in claim 18 comprising intermittent
CS. oscillator control means whereby Said oscillator produces
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US 6,919,053 B2
7 8
intermittent oscillations Such that the Voltage established at intermittent oscillations Such that the Voltage established at
the output capacitor means provides Said ionizing Voltage the output capacitor means provides Said ionizing Voltage
while oscillations are occurring, and wherein Said ion emis while oscillations are occurring, and wherein Said ion emis
Sion continues during the time the oscillator is not Sion continues during the time the oscillator is not producing
producing, Oscillations, Supplied by charge from the output oscillations, Supplied by charge from the output capacitor
capacitor means. CS.
20. An ionizer an in claim 19 wherein the oscillator, when 22. An ionizer as in claim 21 wherein the oscillator, when
it is not producing oscillations, is not producing oscillations it is not producing oscillations, is not producing Oscillations
for up to ten times as long as when the oscillator is producing for up to ten times as long as when the oscillator is producing
oscillations. 10 oscillations.
21. An ionizer as in claim 17 comprising intermittent
oscillator control means whereby Said oscillator produces

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