EXHIBIT 1

Case: 1:18-cv-00323-SJD-KLL Doc #: 1-1 Filed: 05/09/18 Page: 1 of 4 PAGEID #: 11
Hitchcock" Evert

March 8,2018

NoLimits Enterprises lnc.

c/o Jonathan Dandrow

3721 Ashworth Drive, Unit D

Cincinnati, Ohio 45208

Vio Federal Express

Re: NoLimits' lnfrinaement of Escort's Potents ond Cobrq's Reoistered Trodemorks

Dear Mr. Dandrow:

By way of introduction, this firm represents Escort lnc. ("Escort") and Cobra Electronics Corporation

("Cobra") in certain intellectual property matters. lt has recently come to our attention that NoLimits

Enterprises lnc. ("NoLimits") has infringed and is currently infringing multiple claims of U.S. Patent No.

RE39,038, U.S. Patent No. RE40,653, and U.S. Patent No. 7,576,679, all of which are owned by Escort.

NoLimits is likewise infringing U.S. Registration No. 4,999,769 for AUTOCITY@ and U.5. Registration No.

2,136,176 for LASEREYE@, which are owned by Cobra. The purpose ofthis letter to make it clear in no

uncertain terms that NoLimits' infringement must immediately cease and NoLimits must compensate both

Escort and Cobra appropriately and completely. lf NoLimits fails to cooperate in redressing its infringement,

our clients will have no choice but to commence litigation to protect their valuable intellectual property

rights.

Patent lnfringement

At the outset, it is our understanding that NoLimits reached out to Escort just prior to the 2018

Consumer Electronics Show (CES) held between January 9th and l.2th. The reason NoLimits reached out is that

it learned that Escort had filed a lawsuit against Uniden as a result of Uniden's infringement of U.S. Patent

No. RE39,038, U.S. Patent No. RE40,653, and U.S. Patent No.7,576,679.|t is clearto us that NoLimits

contacted Escort because NoLimits recognized that it was infringing the same patents. Specifically, NoLimits'

Radenso Pro M detector and Radenso XP detector each have the same types offeatures that form the basis

of Escort's infringement claims in the Uniden litigation.

For example, Escort's patented features include the following: (1) GPS anti-falsing; (2) known

frequency anti-falsing; (3) mute button controls; and (4) capability for users to control alerts based on speed

and location. The Radenso Pro M listing touts these exact features:

Using GPS, the Pro M remembers common folse olerts olong your regularly driven routes so

you never hove to listen to the some false olert twice. Simply press dnd hold o single button

to odd o GPS lockout. Additionol fedtures include outomatic muting below o user-selected

speed ond outomotic sensitivity odjustment bosed on current speed.

It is no wonder, then, that Nolimits became concerned when it learned of the claims against Uniden. That it

subsequently ignored its infringement rather than takes steps to remedy it is decidedly less understandable.

As you are likely aware, the validity of Escort's U.5. Patent No. RE39,038 and U.S. Patent No. RE40,653

patents have been tested in both litigation and reexamination. The claims that NoLimits is infringing emerged

from reexamination unchanged. NoLimits simply has no viable defense.

On that subject, to the extent Nolimits believes it is protected by the patent license to its

manufacturer, B&M Merchandise LLC ("8&M"), it is wrong. The license grants B&M the right to practice the

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HrrcHcocK EvERT LLP

March 8,2018

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claims of U.S. Patent No. RE39,038 and U.S. Patent No. RE40,653 solely for products sold under the

trodemorks or trode nomes of B&M. B&M's trademarks and trade names, of course, do not include the

RADENSOo trademark. Indeed, the license to B&M expressly prohibits it from making products for another

party for sale under that party's trademarks. The B&M license thus offers NoLimits no defense.

Moreover, the B&M license does not include U.S. Patent No. 7,576,679 (the'679 patent). The claims

of the '679 patent relate to location-based alert suppression, user marks of false alerts, and incorporating a

min|-USB jack for interface with a computer. Based u pon the description of the advertised features of the

Radenso XP and the Radenso Pro M, both radar detectors contain this patented functionality.

Not only has NoLimits infringed Escort's patents, it almost certainly has committed willful

infringement. For example, Nolimits has publicly stated that the Radenso Pro M was first offered for sale in

the US in late January-well after Nolimits reached out to Escort about the Uniden lawsuit. This strongly

sug8ests that Nolimits pressed ahead with releasing the Radenso Pro M with actual knowledge that it

infringed the'679 patent-or, in other words, committed willful patent infringement.

We trust that NoLimits is prepared to remedy its infringement. Otherwise, it must prepare for

litigation.

Trademark lnfringement

NoLimits must also remedy its trademark infringement. The same models that infringe Escort's

patents-the Radenso xP and the Radenso Pro M-also infringe Cobra's AUTOCITYo and LASEREYE@

trademarks. LASEREYEo has been registered in the United States since 1998 and is incontestable. AUTOCITY@

has been registered since July 2016 and has a priority date of May 2015-well before the Radenso XP was

released on the market.

NoLimits is using marks identical to Cobra's AUTOC|wo and LASEREYE@ trademarks for the identical

goods in violation of 15 U.S.C. 5 1114. This entitles Cobra to recover NoLimits'profits as well as its damages

and attorneys' fees.

Actions Necessarv to Avoid Litisation

ln order to avoid escalation of this matter, Nolimits must take immediate action to remedy both its

patent and trademark infringement. Escort and Cobra demand that NoLimits:

1. lmmediately cease all sales in the United States of the Radenso Pro M detector and the Radenso XP

radar detectors, as well as any other radar/laser detector that infringes on U.S. Patent No. RE39,038,

U.S. Patent No. RE40,553, and/or U.S. Patent No.7 ,576,679;

2. Recall all infringing radar and laser detectors from any retailer or other third-party reseller who

currently stocks the infringing products;

3. Cancel all customer orders for infringing products that have not been shipped;

4. Provide Escort with an accounting of infringing units in process at Nolimits'supplier(s), in transit to

Nolimits from its supplier(s), and in NoLimits' custody or control;

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H|TcHcocx EVERT LLP

March 8, 2018

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5. ldentlfy all sales of infringing radar and laser detectors in the United States, specifically stating:

a. Whether the sale was directly to a consumer or to a retailer or other third-party reseller;

b. The identity of the retailers or other third-party resellers to whom the infringing products

were sold;

c. The date(s) of such sales;

d. All revenue NoLimits received from such sales; and

e. The price at which the products were offered to consumers;

6. Agree to pay Escort both a reasonable royalty for each infringing product sold and its attorneys'fees;

7. lmmediately cease all use of AUTOCITY@ as a trademark, trade name, service mark, and source

identifier;

8. lmmediately cease all use of LASEREYEo as a trademark, trade name, service mark, and source

identifier;

9. Replace all printed materials bearing the AUTOCITYo and LASEREYEo trademarks with content that

does not infringe Cobra's trademarks;

10. Replace all digital, print, television, outdoor, or other type of signage or advertisement with content

that does not infringe Cobra's trademarks; and

11. Pay Cobra a reasonable license fee for past use of the AUTOCITYo and LASEREYEo trademarks and its

attorneys'fees.

The foregoing proposed settlement terms represent NoLimits' best-case scenario for resolving this matter. If

Escort and Cobra are forced to obtain a court judgment after protracted litigation, NoLimits is at great risk of

paying substantial attorneys'fees-Escort's, Cobra's, and its own-along with damages.

Please forward your written response to me no later than March 19. lf you are represented by

counsel in this matter, please provide this correspondence to counselfor response.

cc: Chris Cowger - Cedor Electronics Holdings Corp.

Elisabeth A. Evert, Esq. - Hitchcock Evert LLp

John T. Tower, Esq. - Hitchcock Evert LLp

Sincerely yours,

1t--

Megan M. O'Laughlin

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