UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MICHIGAN

WARRIOR SPORTS, INC.,

a Michigan corporation, Case No.

Plaintiff, Hon. 

v.

COMPLAINT

PERFORMANCE LACROSSE 

GROUP INC., d/b/a MAVERIK JURY TRIAL REQUESTED

LACROSSE, a Delaware corporation,

Defendant.

___________________________________________/

Plaintiff Warrior Sports, Inc. brings its Complaint against Defendant 

Performance Lacrosse Group Inc., d/b/a Maverik Lacrosse, stating as follows:

The Parties

1. Plaintiff Warrior Sports, Inc. (“Warrior”) is a Michigan corporation 

having its principal place of business in Warren, Michigan. Warrior is a sports 

equipment manufacturer that manufactures and sells, among other things, lacrosse 

heads.

2. Upon information and belief, Defendant Performance Lacrosse Group 

Inc., d/b/a Maverik Lacrosse (“Maverik”) is a Delaware corporation, with a 

principal place of business at 535 West 24th Street, 5th Floor, New York, New 

York 10011-1140. Maverik is also a sports equipment manufacturer who 

manufactures and sells, among other things, lacrosse heads.

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Jurisdiction and Venue

3. This is an action for patent infringement under the Patent Act, 35 

U.S.C. § 101 et seq.

4. This Court has subject matter jurisdiction under 28 U.S.C. §§ 1331 

and 1338(a), as this action arises under the patent laws of the United States.

5. Upon information and belief, Maverik makes, sells, and offers for sale 

lacrosse heads throughout the United States and has systematic and continuous 

dealings within this District.

6. Venue is proper in this District under 28 U.S.C. §§ 1391 and 1400.

Allegations and Claim for Relief

7. For many years, Warrior has continuously engaged in the 

development, manufacture, and sale of a wide variety of athletic products. As a 

result, Warrior quickly bypassed other manufacturers and has become one of the 

premiere sources of sports equipment. The athletic products at issue in this 

litigation are lacrosse heads.

8. Warrior has taken steps over the years to protect its innovative sports 

equipment, including lacrosse heads. In particular, Warrior is and has been the 

sole owner by assignment of all right, title, and interest in United States Design 

Patent No. D699798 (“the ‘798 Patent”), titled “Lacrosse Head,” issued February 

18, 2014. (Exhibit 1.)

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9. At all times relevant to this litigation, Warrior has executed 

appropriate patent marking in connection with products embodying the patented 

invention, thus providing notice of the ‘798 Patent.

10. Warrior is entitled to sue for past, present, and future infringement of 

the ‘798 Patent.

11. Maverik is in the business of manufacturing or having manufactured, 

offering to sell, selling or importing into the United States various lacrosse 

products, including lacrosse heads, in competition with major manufacturers, 

including Warrior.

12. Maverik has, without authority or license from Warrior, made, used, 

offered to sell, sold or imported into the United States lacrosse heads that are 

covered by the ‘798 Patent. The infringing lacrosse heads include, but are not 

limited to, the Tank lacrosse head. (Exhibit 2.)

13. Maverik sells the Tank lacrosse head throughout the United States and 

within this District. Specifically, but without limitation, Maverik’s website, 

maveriklacrosse.com, includes a dealer locator that identifies local retailers that 

market, offer to sell, and sell the Tank lacrosse head. These retailers include a 

number of online retailers, including Lacrosse Monkey (lacrossemonkey.com), 

LAX World (laxworld.com), Sport Stop (sportstop.com) and Universal Lacrosse 

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(universallacrosse.com), as well as other retailers that sell online and through 

physical stores, such as Dick’s Sporting Goods, a national sporting goods retailer.

14. Upon information and belief, Maverik expressly authorizes and 

continues to authorize the sale of the Tank lacrosse heads. 

COUNT I: Infringement of the ‘798 Patent by Maverik

15. Warrior incorporates by reference all preceding paragraphs.

16. Warrior is the owner by assignment of all right, title, and interest in 

and to the ‘798 Patent.

17. Maverik has been and still is making, using, offering to sell, selling or 

importing into the United States lacrosse heads, including, but not limited to, the 

Tank lacrosse head, which infringe the ‘798 Patent in violation of 35 U.S.C. § 

271(a).

18. Maverik’s continued infringement of the ‘798 Patent has damaged and 

will continue to damage Warrior. 

19. By reason of Maverik’s infringement of the ‘798 Patent, Warrior has 

been irreparably harmed, and unless and until Maverik is enjoined by this Court, 

Warrior will continue to suffer irreparable damage and injury for which it has no 

adequate remedy at law.

WHEREFORE, Warrior respectfully requests the following relief:

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A. Judgment that Maverik has infringed and actively induced others to 

infringe the ‘798 Patent;

B. A permanent injunction enjoining Maverik, its officers, employees, 

agents, and all others acting in concert with it or participating with it from further 

infringement and/or inducement of infringement of the ‘798 Patent;

C. An award of damages adequate to compensate Warrior for Maverik’s 

infringement, but in no event less than Warrior’s actual profits as provided under 

35 U.S.C. § 289 or a reasonable royalty under 35 U.S.C. § 284;

D. Enter an order awarding Warrior interest on the damages awarded and 

its costs pursuant to 35 U.S.C. §§ 284, 289; and, 

E. Award such other relief as the Court may deem appropriate and just 

under the circumstances.

DEMAND FOR JURY TRIAL

Warrior demands a trial by jury.

Respectfully submitted,

Dated: December 4, 2014 By: /s/ R. Michael Azzi

Douglas A. Dozeman (P35781)

Janet Ramsey (P63285)

Homayune Ghaussi (P63028)

R. Michael Azzi (P74508) 

Attorneys for Plaintiff Warrior Sports, Inc.

11757376.2

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