Joint Appendix (Part 1)

Case 2:10-cv-02225-VBF -JC Document 62 Filed 03/18/11 Page 2 of 9 Page ID #:98512345678910111213141516171819202122232425262728Plaintiff, Jake Lee (“Plaintiff”) hereby pleads the following claims for patentinfringement, trademark infringement and false advertising against DefendantsMike’s Novelties, Inc. d.b.a. Mike’s Worldwide Imports (“MWI”) and ManischChander, a.k.a. “Mike Chander”, a.k.a. “Manisch Chandra”, a.k.a “Mike Chandra”(“Chander”), and alleges as follows:THE PARTIES1. Plaintiff, Jake Lee is an individual who resides in the State ofCalifornia in the county of Los Angeles.2. On information and belief, Defendant MWI is a Texas corporationwith its principal place of business in Houston, Texas.3. On information and belief, Defendant Chander is an individual whoresides in the State of Texas. On further information and belief, Chander is the soleofficer, director and shareholder of co-defendant MWI.4. Chander and MWI are alter egos of one another that share a completeunity of ownership and operation between one another. Chander intentionallyconceived and manipulated MWI as a device to avoid personal liability for hiswrongful acts. On information and belief, Chander and MWI commingle theirassets and debts. As such, failure to disregard the corporate entity MWI as separateand distinct from Chander would sanction a fraud and promote injustice.JURISDICTION AND VENUE5. This is an action for patent infringement arising under the patent lawsof the United States of America, 35 U.S.C. § 1, et seq., including section § 271.This Court has subject matter jurisdiction over the matters pleaded herein under 18U.S.C. §§ 1331 and 1338(a).6. This Court has personal jurisdiction over Defendants MWI andChander because they have done and continue to do business in this District, andhave harmed Plaintiff in this District, by, among other things, using, selling andoffering to sale infringing products in California. MWI and Chander promote,1-A166-