IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION EMERSON ELECTRIC CO.

Plaintiff, v. SOURCEONE PLUS, INC. d/b/a SOP GREEN KLEAN, d/b/a gk VAC BAGS, Defendant.

Civil Action No. __________________

JURY TRIAL

ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT Plaintiff Emerson Electric Co. (EMERSON ELECTRIC), by and through its undersigned attorneys, files this Original Complaint against defendant SOURCEONE PLUS, INC., d/b/a SOP GREEN CLEAN, and d/b/a GK VAC BAGS (SOURCEONE) demanding a jury trial and alleging as follows:

I. THE PARTIES 1. Plaintiff Emerson Electric Co. (EMERSON ELECTRIC) is organized under the

laws of the state of Missouri, and has its principal place of business at 8000 West Florissant Avenue, St. Louis, MO 63136-8506. 2. Upon information and belief, defendant SourceOne Plus, Inc. (SOURCEONE)

is organized under the laws of Illinois and has its principal place of business at 796 Tek Drive, Suite 300, Crystal Lake, IL 60014.

II. JURISDICTION AND VENUE 3. This is an action for patent infringement of U.S. Patent No. 8,206,482 (the 482

Patent, Exhibit A), under the patent laws of the United States, Title 35 of the United States Code, including (but not limited to) 35 U.S.C. 271. 4. This Court has subject matter jurisdiction over EMERSON ELECTRICs claims

pursuant to 28 U.S.C. 1331 and 1338(a). 5. This Court has personal jurisdiction over SOURCEONE because SOURCEONE

has done and is doing substantial business in this judicial district, both generally and with respect to the allegations in this Complaint, and SOURCEONE has committed one or more acts of infringement in this district. 6. Venue is proper in this district under 28 U.S.C. 1391(b)-(c) and 1400(b)

because SOURCEONE has its principal place of business in this district, has regularly conducted business in this District and has committed, and is continuing to commit, acts of patent infringement in this District by making, using, importing, selling, or offering to sell vacuum filters that infringe EMERSON ELECTRICs patent.

III. THE PATENT-IN-SUIT 7. On June 26, 2012, United States Patent No. 8,206,482 B2 (the 482 Patent),

entitled VACUUM APPLIANCE FILTER ASSEMBLIES AND ASSOCIATED VACUUM SYSTEMS (Exhibit A), was duly and legally issued. The face page of the 482 Patent is reprinted below.

8.

EMERSON ELECTRIC owns through assignment from the inventors all rights,

title, and interest in and to the 482 Patent and has the right to sue and recover for past, present, and future infringement. 9. EMERSON ELECTRIC has complied with the marking requirements of 35 U.S.C.

287(a) at all relevant times.

IV. SOURCE ONES INFRINGING ACTIVITIES 10. SOURCEONE manufactures or has another party manufacture one or more

models or types of vacuum filters, a representative example of which is shown below (hereafter Accused Vacuum Filters).

SOURCEONE FILTER

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At least some of the Accused Vacuum Filters have the indicia SOP GK molded

into the black rubber cap, which, upon information and belief, refers to SourceOne Plus GreenKlean. 12. SOURCEONE sells and offers for sale the Accused Vacuum Filters through more

than one Internet retailer or reseller, including Totalvac.com and UnoClean, and may sell and offer for sale the Accused Vacuum Filters through one or more brick and mortar stores. 13. Each sale of a SOURCEONE Accused Vacuum Filter displaces a sale of a

patented EMERSON ELECTRIC vacuum filter. 14. Upon information and belief, SOURCEONE has sold and continues to sell at

least a portion of the Accused Vacuum Filters at a price significantly less than that of a patented EMERSON ELECTRIC vacuum filter. This contention will likely have evidentiary support after

a reasonable opportunity for further investigation or discovery. 15. SOURCEONEs infringement of the 482 Patent is causing and will continue to

cause irreparable harm to EMERSON ELECTRIC unless stopped by this Court.

COUNT 1 INFRINGEMENT OF THE 482 PATENT 16. 17. EMERSON ELECTRIC incorporates paragraphs 1-15 as if fully set forth herein. Upon information and belief, SOURCEONE manufactures or has another

manufacture for it one or more type or model of Accused Vacuum Filter that are used, sold, offered for sale and/or imported into the United States. 18. Upon information and belief, each of the Accused Vacuum Filters infringes one or

more claim in the 482 Patent, literally or under the doctrine of equivalents. 19. ELECTRIC. SOURCEONEs acts of infringement have caused harm to EMERSON

V. PRAYER FOR RELIEF

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Plaintiff requests that the Court enter judgment in its favor against defendant

SOURCEONE, and that the Court grant Plaintiff the following relief: A. Enter a preliminary injunction preventing SOURCEONE from infringing the 482

Patent during the pendency of this action; B. Enter judgment that SOURCEONE has infringed, actively induced others to

infringe, and/or contributorily infringed one or more claim of the 482 patent; C. Award EMERSON ELECTRIC damages in an amount sufficient to compensate

EMERSON ELECTRIC for SOURCEONEs infringement, active infringement of others infringement, and/or contributory infringement of the Patents-in-Suit, but not less than a reasonable royalty; D. 284; E. Enter a permanent injunction enjoining SOURCEONE, its officers, directors, Award EMERSON ELECTRIC pre-judgment interest pursuant to 35 U.S.C.

servants, managers, employees, agents, attorneys, successors and assignees, and all persons in active concert or participation with any of them, from further acts of infringement of the 482 patent, pursuant to 35 U.S.C. 283; F. Declare this case exceptional under 35 U.S.C. 285 and award EMERSON

ELECTRIC its reasonable attorneys fees, expenses, and costs incurred in prosecuting this action; and G. Grant EMERSON ELECTIC such other and further relief as this Court may deem

just and proper.

IV. JURY DEMAND

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Plaintiff hereby requests a trial by jury pursuant to Rule 38 of the Federal Rules

of Civil Procedure.

Dated: August 8, 2012

Respectfully submitted,

/s/ Thomas A. Vickers Thomas A. Vickers Thomas A. Vickers IL State Bar No. 6226288 E-mail: tvickers@vaneklaw.com Jeffrey R. Moran IL State Bar No. 6283573 E-mail: jmoran@vaneklaw.com Vanek, Vickers & Masini, P.C. 111 S. Wacker Drive, Suite 4050 Chicago, Illinois 60606 (312) 224-1500 Telephone (312) 224-1510 Facsimile Albert B. Deaver, Jr. TX State Bar No. 05703800 adeaver@smd-iplaw.com Robert J. McAughan, Jr. TX State Bar No. 00786096 bmcaughan@smd-iplaw.com Sutton McAughan Deaver PLLC Three Riverway, Suite 900 Houston, Texas 77056 (713) 800-5700 (telephone) (713) 800-5699 Attorneys for Plaintiff