Craik v. Boeing Company

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION RON CRAIK, Plaintiff,
Case No. 1:13-CV-874 v. JURY TRIAL DEMANDED THE BOEING COMPANY, Defendant. COMPLAINT Plaintiff Ron Craik brings this Complaint against Defendant The Boeing Company ("Boeing") as follows: THE PARTIES 1. Ron Craik is the sole inventor of United States Patent Nos. 7,076,532, 7,383,318
and 8,198,986. He resides in Calgary, Canada. 2. Boeing is a corporation organized and existing under the laws of the State of
Delaware with its principal place of business and corporate offices located at 100 North Riverside Plaza, Chicago, Illinois, 60606. JURISDICTION AND VENUE 3. This is a complaint for patent infringement under the patent laws of the United
States, Title 35 of the United States Code. This Court has original jurisdiction over the subject matter of this Complaint under 28 U.S.C. 1338(a). Venue in this district is proper under 28 U.S.C. 1400(b) and 1391(c).
BACKGROUND 4. Mr. Craik's inventions principally relate to novel methods for the inspection and
maintenance of aircraft. Mr. Craik sought to market and sell his inventions to the industry through his company, Safe Air Solutions. 5. Mr. Craik became known in the industry for his inventions, and Boeing was well
aware of him and his company, Safe Air Solutions. In June 2005, at Boeing's invitation, Mr. Craik attending Boeing's worldwide airline industry conference in Paris, France. 6. Later, in 2008, Boeing sought Mr. Craik's help in crafting an "Aircraft
maintenance solution", specifically requested Mr. Craik's help "in relation to our need to manage our own aircraft portfolio." (Ex. A.) Boeing, however, then changed its mind about bringing Mr. Craik into the project. 7. According to its 2012 press releases, Boeing has developed, tested, and validated
the airline industry's first comprehensive radio frequency identification device (RFID) and contact memory button (CMB) technology for commercial airplanes. Working exclusively with Fujitsu and a major U.S. airline, Boeing has developed, tested, and validated the airline industry's first comprehensive radio frequency identification device (RFID) and contact memory button (CMB) technology for commercial airplanes. This system can significantly reduce an airline's operating costs by eliminating untimely, labor intensive maintenance while providing easy access to maintenance histories. Aeromagazine, Q1, 2012 (Ex. B.) PATENT INFRINGEMENT 8. Mr. Craik owns full right, title and interest in and has the sole and exclusive right
to enforce and has standing to sue and recover damages for infringement of U.S. Patent No. 7,076,532 ("the '532 patent") entitled "System and Method for Storing and Retrieving Equipment Inspection and Maintenance Data" (Ex. C); U.S. Patent No. 7,383,318 ("the '318 patent") entitled "System and Method for Storing and Retrieving Equipment Inspection and Maintenance Data"
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(Ex. D); and U.S. Patent No. 8,198,986 ("the '986 patent") entitled "System and Method for Storing and Retrieving Equipment Inspection and Maintenance Data" (Ex. E). 9. July 11, 2006. 10. June 3, 2008. 11. June 12, 2012. 12. Boeing has directly infringed and/or actively induced infringement of at least The '986 patent was issued by the United States Patent and Trademark Office on The '318 patent was issued by the United States Patent and Trademark Office on The '532 patent was issued by the United States Patent and Trademark Office on
claims 1-8 of the '532 patent through the development, testing and implementation and use of its maintenance program using RFID and CMB technology. 13. Boeing has directly infringed of at least claims 1-11 of the '318 patent through the
development, testing and implementation and use of its maintenance program using RFID and CMB technology. 14. Boeing has directly infringed of at least claims 1-19 of the '986 patent through the
development, testing and implementation and use of its maintenance program using RFID and CMB technology. 15. Mr. Craik has been injured by the infringement caused by the defendants and is
entitled to damages adequate to compensate him for such infringement. REQUESTED RELIEF WHEREFORE, Mr. Craik requests that a judgment be entered as follows: A. An injunction prohibiting the defendants, and all those acting in concert or participation with the defendants, from further acts of infringement of the '532 patent, the '318 patent, and the '986 patent; -3-
B.
An award to Mr. Craik of such damages as he can prove at trial against the defendants sufficient to fully and adequately compensate him for the acts of infringement that have occurred, said damages to be no less than a reasonable royalty with respect to each entity found to infringe any asserted claim of any asserted patent;
C.
Such other relief as this Court and the jury may determine to be proper and just. JURY DEMAND
A trial by jury is hereby demanded on all issues triable to a jury in this case.
Respectfully submitted, /s/Olivia T. Luk Paul K. Vickrey Paul C. Gibbons Olivia T. Luk NIRO, HALLER & NIRO 181 West Madison Street, Suite 4600 Chicago, IL 60602 (312) 236-0733 Fax: (312) 236-3137 Attorneys for Ron Craik
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IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION RON CRAIK, Plaintiff,

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