马尼托瓦克(MANITOWOC CRANES)对三一(SANY)的起诉状(郑律师搜集和整理).docxVIP

IN THE UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF WISCONSINGREEN BAY DIVISION ___________________________________________________________________MANITOWOC CRANES, LLCPlaintiff,-vs- SANY AMERICA, INC. and SANY HEAVY INDUSTRY CO., LTDDefendants.JURY TRIAL DEMANDED___________________________________________________________________COMPLAINT FOR PATENT INFRINGEMENT AND MISAPPROPRIATION OFTRADE SECRETS AND JURY DEMAND___________________________________________________________________Plaintiff, Manitowoc Cranes, LLC (Manitowoc Cranes) alleges the following:PARTIES1.Manitowoc Cranes is a Wisconsin limited liability company with its headquarters at 2401South 30th Street, Manitowoc, WI 54221-0070.2. Upon information and belief, Defendant Sany America, Inc. (Sany America) is aDelaware corporation with its headquarters at 318 Cooper Circle, Peachtree City, GA 30269.3. Upon information and belief, Defendant Sany Heavy Industry Co., Ltd. (Sany HeavyIndustry) is a Chinese Corporation with its headquarters at Sany Industry Town, Economic and Technological Development Zone, Changsha, Hunan Province, China.4. Upon information and belief, Defendant Sany America has done and continues to do business in the State of Wisconsin, including the Eastern District, by, among other things, committing acts, either by itself or through intermediaries, that constitute misappropriation of thetrade secrets of Manitowoc Cranes. The Sany SCC8500, which includes trade secretsmisappropriated from Manitowoc Cranes, was designed, in part, in this District. Upon information and belief, Mr. John Lanning, formerly of Manitowoc Cranes, worked out of his home in this Districtto design the SCC8500. Upon information and belief, Mr. Lanning had frequent communicationwith employees of Sany America and Sany Heavy Industry from this District while designing theSCC8500. Mr. Lanning resides at 2908 North County Road H, Reedsville, Wisconsin 54230.5. Upon information and belief, Defendant Sany Heavy Indust