UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN _____________________________________

GRACE ENGINEERING CORP., Plaintiff, v. WASP ARCHERY PRODUCTS and WEAVER OUTDOOR, INC., Defendants. ____________________________________/ James Moskal (P41885) WARNER NORCROSS & JUDD LLP Counsel for Plaintiff 900 Fifth Third Center 111 Lyon Street NW Grand Rapids, Michigan 49503 (616) 752-2000 ____________________________________/

Case No. Hon. COMPLAINT FOR PATENT INFRINGEMENT

DEMAND FOR JURY TRIAL

Plaintiff complains against defendants for patent infringement as follows: 1. This an action for patent infringement under the laws of the United States. The

Court has jurisdiction pursuant to 28 U.S.C. '' 1331 and 1338(a). Venue is proper under 28 U.S.C. '' 1391 and 1400. 2. Plaintiff, Grace Engineering Corp., is a Michigan corporation. Graces

headquarters and principal place of business are at 34775 Potter Street, Memphis, Michigan. 3. Defendants Wasp Archery Products and Weaver Outdoor, Inc., are both

Pennsylvania entities capable of being sued. Defendants have a place of business at 601 Carlson Road, Hummelstown, Pennsylvania. Defendants have committed acts of infringement and are subject to personal jurisdiction in this judicial district. 4. United States Patent No. 6,935,976, entitled Mechanical Broadhead With Sliding

Blades was duly issued on August 30, 2005. Plaintiff, by assignment, is the sole and exclusive owner of all rights, title and interest to this patent. A copy of this patent is attached as Exhibit A. 5. Defendants have been and are manufacturing, using, offering for sale, or selling

products that infringe this patent, as a direct result of which plaintiff has sustained damages. 6. Defendants will continue to infringe this patent and cause plaintiff irreparable

harm unless enjoined by the Court. WHEREFORE, plaintiff requests that the Court enter judgment against defendants as follows:

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(a) patent; (b) 284; (c) and (d)

Preliminarily and permanently enjoining defendants from infringing the

Awarding plaintiff damages and enhanced damages under 35 U.S.C. '

Awarding plaintiff interest, costs and attorney fees under 35 U.S.C. ' 285;

Awarding plaintiff all additional relief to which it is entitled. DEMAND FOR JURY TRIAL

Plaintiff demands a trial by jury. Dated: July 28, 2011 WARNER NORCROSS & JUDD LLP

By: s/ James Moskal James Moskal (P41885) 900 Fifth Third Center 111 Lyon Street NW Grand Rapids, Michigan 49503 Telephone: (616) 752-2000 Counsel for Plaintiff
126255.145364 5635870-1

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