Case 5:18-cv-05024-JLV Document 1 Filed 04/09/18 Page 1 of 19 PageID #: 1

IN THE UNITED STATES DISTRICT COURT

DISTRICT OF SOUTH DAKOTA, WESTERN DIVISION

KUSTOM CYCLES, INC., dba

KLOCK WERKS KUSTOM CYCLES,
a South Dakota corporation, and CASE NO: 5:18-cv-5024

BRIAN KLOCK, JUDGE

Plaintiffs, MAGISTRATE JUDGE

v. COMPLAINT FOR DESIGN

PATENT INFRINGEMENT
DRAGONFLY CYCLE CONCEPTS,
LLC, a California limited liability [DEMAND FOR JURY TRIAL]
company, and KEVIN MICHAEL
MARTIN, individually,

Defendants.

NOW COMES Plaintiff KUSTOM CYCLES, INC., dba KLOCK WERKS

KUSTOM CYCLES (“KLOCK WERKS”) and BRIAN KLOCK, and for their

Complaint against Defendants DRAGONFLY CYCLE CONCEPTS, LLC, and

KEVIN MICHAEL MARTIN (collectively, “DRAGONFLY”), hereby allege and

aver as follows:

PRELIMINARY STATEMENT

1. This is an action for Defendant DRAGONFLY’s infringement of

Plaintiffs’ design patent for a motorcycle windshield. Defendant DRAGONFLY,

who was previously a dealer of Plaintiff KLOCK WERKs’ patented FLARE®

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windshields, copied Plaintiffs’ patented design to create a virtually identical

product, which Defendant DRAGONFLY markets and sells as its “FLIP-OUT”

motorcycle windshield.

JURISDICTION AND VENUE

2. This action arises under the patent laws of the United States, Title 35,

United States Code. This Court has original jurisdiction over the subject matter of

this action pursuant to 28 U.S.C. §§ 1331 and 1338(a).

3. Personal jurisdiction over Defendant DRAGONFLY is proper in this

judicial district because Defendant DRAGONFLY has availed itself of the rights

and benefits of the laws of South Dakota. Defendant DRAGONFLY has derived

revenue from the sale of infringing motorcycle products in South Dakota, and

maintains systematic business contacts with South Dakota. Defendant

DRAGONFLY has regularly attended the Sturgis Motorcycle Rally in Sturgis,

South Dakota, in person, over the past several years. Upon information and belief,

for the past several years, Defendant DRAGONFLY has established a physical

place of business in Sturgis, South Dakota, before and during the annual Sturgis

Motorcycle Rally. Employees of Defendant DRAGONFLY have personally

appeared in South Dakota to render services for, and on behalf of Defendant

DRAGONFLY, including marketing, offering for sale, and selling the product that

is accused herein of infringing Plaintiffs’ patent. Upon information belief, for the

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past several years, Defendant DRAGONFLY has paid sales tax within South

Dakota for products sold here. By regularly establishing a physical presence

within South Dakota, Defendant DRAGONFLY has purposefully availed itself of

the rights and privileges of doing business in the state, and of the protections of

South Dakota’s laws. Finally, upon information and belief, Defendant

DRAGONFLY regularly acquires and maintains business contacts and conducts

business within this judicial district through continuous advertisement, promotion,

and sales of its products—including its infringing products—to customers residing

in and visiting South Dakota.

4. Venue is proper in this judicial district pursuant to Title 28, U.S.C. §

1391(b) and Title 28 U.S.C. § 1400(b) in that Defendant DRAGONFLY annually

maintains a regular and established physical place of business in this judicial

district and has committed acts of infringement in this judicial district by selling

and offering for sale the accused product within this judicial district.

PARTIES

5. Plaintiff KLOCK WERKS is a South Dakota corporation with its

principal place of business located at 915 S. Kimball St., Mitchell, South Dakota.

Plaintiff KLOCK WERKS is in the business of customizing motorcycles and

designing and manufacturing custom parts and accessories for motorcycles.

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Plaintiff KLOCK WERKS is the exclusive licensee of U.S. Patent No. D586,275

(“the ‘275 Patent,” a copy of which is attached hereto as Exhibit 1).

6. Plaintiff BRIAN KLOCK is the president and founder of Plaintiff

KLOCK WERKS. Plaintiff BRIAN KLOCK is also the inventor and owner of the

‘275 Patent.

7. Upon information and belief, Defendant DRAGONFLY CYCLE

CONCEPTS LLC is a limited liability company previously formed under the laws

of the State of California. Upon information and belief, however, the California

Secretary of State has suspended Defendant DRAGONFLY CYCLE CONCEPTS

LLC such that the entity is no longer effective or in good standing. Upon

information and belief, Defendant KEVIN MICHAEL MARTIN is (or was, at the

time of the California Secretary of State’s suspension of Defendant DRAGONFLY

CYCLE CONCEPTS LLC) the sole owner of Defendant DRAGONFLY CYCLE

CONCEPTS LLC. Upon information and belief, Defendant DRAGONFLY (as a

corporate entity, and/or as a dba for Defendant MARTIN, individually) maintains a

principal place of business at 1301 East Orangethorpe Avenue, Suite O, Fullerton,

California, 92831, and is in the business of manufacturing and selling motorcycle

parts and accessories. Defendants’ product offerings have included motorcycle

windshields manufactured by Plaintiff KLOCK WERKS.

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FACTS

8. Plaintiff KLOCK WERKS has designed, manufactured, and sold

unique motorcycle components and accessories for over two decades.

9. Plaintiff BRIAN KLOCK, the founder and CEO of Plaintiff KLOCK

WERKS, is well-known internationally for his creative and innovative motorcycles

and component designs. Numerous magazines, news articles, and television shows

have featured Plaintiff BRIAN KLOCK and his custom motorcycles and

component parts. Among Plaintiffs’ notable achievements was winning the

nationally televised 2006 Discovery Channel Biker Build Off with their

customized “World’s Fastest Bagger” motorcycle. This motorcycle was the

inspiration for Plaintiff KLOCK WERKS’ original FLARE® windshield, which

Defendant KLOCK WERKS later expanded into its series of patented FLARE®

motorcycle windshields. This series of windshield designs includes the design

claimed in the ‘275 Patent, which is the patent asserted here.

10. Plaintiff KLOCK WERKS’ FLARE® windshields became an

immediate success with Plaintiff KLOCK WERKS selling well over 100,000

FLARE® windshields since the line’s debut. KLOCK WERKS has extensively

advertised and promoted its FLARE® windshields. KLOCK WERKS has regularly

and consistently advertised its FLARE® line in Hot Bike, Hot Bike Baggers,

American Baggers, Cycle Source, American Iron, Iron Works, Christian

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Motorsports Illustrated, Motor Market Magazine, and others. Numerous national

magazines such as Hot Bike, Drag Magazine, PowerSports Business, and Heavy

Duty magazine in Australia have published feature articles on KLOCK WERKS’

FLARE® windshields. American Bagger featured a technical install section on the

FLARE® and several industry websites have published product reviews about

KLOCK WERKS’ FLARE® windshields.

11. Jay Barbieri named KLOCK WERKS’ FLARE® windshield as one of

the “Best Products” at the 2008 V-Twin Expo and subsequently featured the

product on the SPEED Channel’s American Thunder series. In February 2009, the

FLARE® won the award for V-Twin Accessory of the Year at the V-Twin Expo’s

Industry Awards. PowerSports Business ran a front-page story describing the

success of the FLARE® windshields in its September 6, 2010, issue. KLOCK

WERKS was the 2014 J&P Cycles Open House Rally “Brand of the Year,” largely

due to the success of the FLARE® line of products. Finally, the FLARE®

windshield won the 2015 MPN “Best of the Web” Reader’s Choice Award.

12. The ‘275 Patent, entitled FLARED WINDSHIELD FOR A

MOTORCYCLE, was duly and legally issued for one model of the FLARE®

windshield on February 10, 2009, naming Plaintiff BRIAN KLOCK as the

inventor. See Exhibit 1 hereto.

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13. KLOCK WERKS has commercialized the design in the ‘275 Patent as

KLOCK WERKS’ 6.5” FLARE® windshield for “batwing fairings” for

motorcycles, generally, and for FHL model Harley-Davidson motorcycles in

particular.

14. BRIAN KLOCK has secured additional design patents for other

models and sizes of the FLARE® windshield, including U.S. Patent Nos.

D586,274; D626,046; D632,235; and D633,018. In addition to these U.S. patents,

KLOCK WERKS holds five international patents covering its FLARE® windshield

designs.

15. Upon information and belief, Defendant DRAGONFLY has infringed,

and continues to infringe, the ‘275 Patent by making, using, selling, and offering

for sale in the United States, and/or importing into the United States, including

within this judicial district, windshields that embody the design shown and claimed

in the ‘275 Patent.

16. Upon information and belief, Defendant DRAGONFLY copied one of

Plaintiff KLOCK WERKS’ products to create the DRAGONFLY 6.5” FLIP-OUT

Batwing windshield.

17. Specifically, upon information and belief, Defendant DRAGONFLY

copied Plaintiff KLOCK WERKS’ commercial embodiment of the ‘275 Patent to

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create the FLIP-OUT Batwing windshield, which KLOCK WERKS refers to as its

6.5” FLARE® windshield.

18. Defendant DRAGONFLY’s FLIP-OUT Batwing windshield

embodies the design claimed in Plaintiffs’ ‘275 Patent, or a colorable imitation

thereof.

19. A representative of Plaintiff KLOCK WERKS purchased a sample of

Defendant DRAGONFLY’s accused 6.5” FLIP-OUT Batwing windshield from

Defendant DRAGONFLY’s staff in Sturgis, South Dakota, on or about August 12,

2017. A true and accurate copy of the receipt for said purchase is attached hereto

as Exhibit 2.

20. Defendant DRAGONFLY’s 6.5” FLIP-OUT Batwing windshield

infringes Plaintiffs’ ‘275 Patent.

21. Table 1 below compares the design in the ‘275 Patent to Defendant

DRAGONFLY’s 6.5” FLIP-OUT Batwing windshield. The column on the left

reproduces each of the figures in the ‘275 Patent. The column on the right shows a

corresponding photograph of Defendants’ 6.5” FLIP-OUT Batwing windshield that

Plaintiffs’ representative purchased from Defendants in Sturgis, South Dakota, on

August 12, 2017.

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Table 1

PLAINTIFFS’ DRAGONFLY’S 6.5” FLIP-OUT

U.S. PAT. NO. 586,275 BATWING WINDSHIELD

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PLAINTIFFS’ DRAGONFLY’S 6.5” FLIP-OUT

U.S. PAT. NO. 586,275 BATWING WINDSHIELD

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22. As noted above, Plaintiff KLOCK WERKS markets and sells a

commercial embodiment of the ‘275 Patent, which it (and others) refer to as the

6.5” FLARE® Windshield for batwing fairings or for FLH model Harley-Davidson

motorcycles.

23. Also as noted above, Defendants previously were authorized dealers

of Plaintiff KLOCK WERKS commercial embodiment of the ‘275 Patent, i.e., the

6.5” FLARE® windshield for batwing fairings. See, e.g., Exhibit 3 hereto, which is

a true and accurate copy of an internet archive screenshot of Defendants’

www.dragonflycycleconcepts.com website from August 11, 2015, obtained from

https://web.archive.org/web/20150811031809/http://www.dragonflycycleconcepts.

com:80/store/productlist.php?category=5&secondary=38 on or about March 5,

2018, and which shows Defendant DRAGONFLY offering Plaintiff KLOCK

WERKS’ 6.5” FLARE® windshield for sale in “light tint,” “black,” and “dark

smoke” color options.

24. Table 2 below further demonstrates that Defendant DRAGONFLY’s

6.5” FLIP-OUT Batwing windshield is virtually indistinguishable from Plaintiff

KLOCK WERKS’ patented design and its commercial embodiment thereof. The

left column of Table 2 shows Plaintiff KLOCK WERKS’ 6.5” FLARE®

windshield, while the column on the right shows Defendant DRAGONFLY’s

accused 6.5” FLIP-OUT Batwing windshield.

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Table 2

KLOCK WERKS’ DRAGONFLY’S 6.5” FLIP-OUT

6.5” FLARE® WINDSHIELD BATWING WINDSHIELD

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KLOCK WERKS’ DRAGONFLY’S 6.5” FLIP-OUT

6.5” FLARE® WINDSHIELD BATWING WINDSHIELD

25. Defendants knew, or reasonably should have known, of the existence

of the ‘275 Patent before they designed and released the 6.5” FLIP-OUT Batwing

windshield including, but not limited to, through Defendant DRAGONFLY’s

longstanding sales of Plaintiff KLOCK WERKS’ commercial embodiment of the

‘275 Patent.

26. Upon information and belief, Defendants’ acts of infringement have

been willful and in disregard for the ‘275 Patent, and without any reasonable basis

for believing that Defendants had the right to engage in the infringing conduct.

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27. As a result of the actions by Defendants, Plaintiff KLOCK WERKS

has suffered actual and irreparable harm in terms of prior and continued financial

loss, as well as significant harm to its goodwill within the motorcycle industry and

its ability to control the use and commercial exploitation of its patented design.

28. The harm occasioned by Defendants’ infringement of the ‘275 Patent

will continue unless this Court enjoins said infringement.

29. Defendants’ copying of KLOCK WERKS’ 6.5” FLARE® windshield

is not an isolated incident. As noted above, in addition to the ‘275 Patent, Plaintiff

BRIAN KLOCK is the named inventor on several design patents that cover other

models of FLARE® windshields that Plaintiff KLOCK WERKS manufactures and

sells. These patents include U.S. Patent Nos. D586,274; D626,046; D632,235; and

D633,018.

30. Plaintiff KLOCK WERKS is the exclusive licensee for each of these

patents, and offers commercial embodiments thereof for 1996-2013 Harley-

Davidson FLH/“batwing” fairing applications in 3.5”, 8.5”, and 11.5”

configurations. For 2014 and later model Harley-Davidson FLH/“batwing”

fairings, KLOCK WERKS manufactures and sells FLARE® windshields in 5” and

8.5” sizes.

31. In addition to the product accused herein, Defendants advertise and

offer for sale FLIP-OUT windshields for 1996-2013 FLH/“batwing” fairing

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applications in 4”, 8.5”, and 11.5” configurations, and, in 5” and 8.5” sizes for the

2014 and newer models.

32. Plaintiff KLOCK WERKS also offers FLARE® windshields for

Harley-Davidson FLT/Road Glide model motorcycles, which are also protected by

design patents owned by Plaintiff BRIAN KLOCK and licensed exclusively to

Plaintiff KLOCK WERKS.

33. Defendants are offering FLIP-OUT windshields for 1998-2013

Harley-Davidson Road Glide motorcycles in 8” and 10” sizes, both of which

Plaintiff KLOCK WERKS has offered for many years.

34. For the 2015 and newer Harley-Davidson Road Glide models,

Defendants have copied KLOCK WERKS’ 9” and 14” styles and sizes.

35. Photographs of Defendants’ line of FLIP-OUT windshields are

attached hereto as Exhibit 4.

36. Upon information and belief, one or more of Defendants’ models of

FLIP-OUT windshields referenced in the foregoing paragraphs infringes one or

more of Plaintiffs’ design patents identified in Paragraph 26 above.1

1
Plaintiffs are still investigating Defendants’ additional models and sizes and,
accordingly, are not currently accusing those products of infringing any of
Plaintiffs’ patents. Plaintiffs’ claim here relates only to Defendants’ 6.5” FLIP-
OUT Batwing windshield’s infringement of Plaintiffs’ ‘275 Patent. Plaintiffs
respectfully reserve the right to amend this Complaint to assert additional claims of
infringement related to Defendants’ other FLIP-OUT models and sizes.
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COUNT ONE (PATENT INFRINGEMENT)

37. Plaintiff KLOCK WERKS repeats and realleges the paragraphs

above, as if fully set forth here.

38. Upon information and belief, Defendants have been, and are,

infringing the ‘275 Patent by making, using, selling, and offering for sale in the

United States, and/or importing into the United States, including within this

judicial district, windshields embodying the design of the ‘275 Patent, in violation

of 35 U.S.C. § 271(a).

39. Defendants have not licensed the ‘275 Patent or otherwise obtained

permission from Plaintiff KLOCK WERKS to manufacture products embodying

the design claimed in the ‘275 Patent.

40. Defendants’ infringement has been, and continues to be, knowing,

intentional, and willful.

41. Defendants’ acts of infringement of the ‘275 Patent complained of

herein have caused, and will continue to cause, Plaintiffs damages for which

Plaintiffs are entitled to compensation pursuant to 35 U.S.C. § 284.

42. Defendants’ acts of infringement of the ‘275 Patent complained of

herein have caused and will continue to cause Plaintiffs immediate and irreparable

harm unless such infringing activities are enjoined by this Court pursuant to 35

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U.S.C. § 283. Plaintiffs have no adequate remedy at law for Defendants’ acts of

infringement.

43. This case is exceptional and, therefore, Plaintiffs are entitled to an

award of attorneys’ fees pursuant to 35 U.S.C. § 285.

PRAYER FOR RELIEF

WHEREFORE, Plaintiffs request judgment against Defendants as follows:

1. Adjudging that Defendants have infringed the ‘275 Patent, jointly and

severally, in violation of 35 U.S.C. § 271(a);

2. Granting an injunction permanently enjoining Defendant KEVIN

MICHAEL MARTIN and Defendant DRAGONFLY, as well as its owners,

employees, agents, officers, directors, attorneys, successors, affiliates, subsidiaries

and assigns, and all of those in active concert and participation with any of the

foregoing persons or entities from infringing, contributing to the infringement of,

and/or inducing infringement of the ‘275 Patent;

3. Ordering Defendants to account to Plaintiff KLOCK WERKS and pay

damages adequate to compensate Plaintiff KLOCK WERKS for Defendants’

infringement of the ‘275 Patent, with pre-judgment and post-judgment interest and

costs, pursuant to 35 U.S.C. § 284;

4. Ordering that Defendants pay increased damages of up to three times

the actual amount assessed, pursuant to 35 U.S.C. § 284;

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5. Declaring this case exceptional and awarding Plaintiff KLOCK

WERKS its reasonable attorneys’ fees, pursuant to 35 U.S.C. § 285; and

6. Awarding such other and further legal and equitable relief as this

Court deems just and proper.

Dated: April 9, 2018 Respectfully Submitted,

/s/ Richard J. Rylance, II

Richard J. Rylance, II (SD Bar No. 3911)
John S. Theeler (SD Bar No. 1697)
MorganTheeler LLP
1718 North Sanborn Boulevard
Mitchell, SD 57301
rjrylance@morgantheeler.com
jtheeler@morgantheeler.com
Tel: (605) 996-5588
Fax: (605) 996-6129

Counsel for Plaintiff

Kustom Cycles, Inc., dba Klock Werks

OF COUNSEL:

T. Earl LeVere (Ohio Bar No. 0063515)

Ice Miller LLP
250 West Street
Columbus, OH 43215
Email: Earl.LeVere@IceMiller.com
Tel: (614) 462-1095
Fax: (614) 228-4847

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DEMAND FOR JURY TRIAL

Plaintiffs hereby respectfully request a trial by jury on all issues asserted by

any party in this action that are so triable.

/s/ Richard J. Rylance, II

Richard J. Rylance, II

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EXHIBIT 1

U.S. Patent No. D586,275

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EXHIBIT 2

Invoice for Accused Product

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Dragonfly Cycle Concepts Invoice

1301 E Orangethorpe Ave, Ste. O
Fullerton, CA 92831 Date Invoice #
714-742-6858
Sales@DragonflyCycleConcep% 8/12/2017 26317

is

Eugene Slater
12541 Lochmeadows Drive
DaIls, TX 75244
903-353-5050

Salesman Year/Model of Bike Est. Ship Date Email

Smitty 8/12/2017 slater.g.gene@gmail.com

Item Description Qty Rate. Amount

12652-17 98-13 Dark Tint 6.5" Batwing Windshield 1 149.95 149.95T
"FLIP-OUT"
MISC Cash and carry 0.00 0.00T

Q--'

Subtotal $149.95
ALL RETURNS ARE SUBJECT TO TERMS OF WARRANTY
AGREEMENT ON REVERSE SIDE OF THIS INVOICE Sales Tax (8.0%) $12.00

Payments/Credits -$161.95
Visit Us on Facebook for Exclusive Deals and New
Products! Balance Due Moo
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EXHIBIT 3

Archive Screen Captures of

Dragonfly Cycle Concepts’
Website

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CO\5795993.1
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EXHIBIT 4

Defendants’ Other
“Flip-Out” Products

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