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IN THE UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF TEXAS 

SHERMAN DIVISION 

TAJM, LLC d/b/a MIKE LAWS 

PERFORMANCE 

Plaintiff, 

v. 

SUNSET PERFORMANCE ENGINES, 

L.L.C. 

Defendant. 

Civil Action No. 4: 23-cv-1066 

JURY TRIAL REQUESTED 

COMPLAINT FOR PATENT INFRINGEMENT 

Plaintiff TAJM, LLC d/b/a Mike Laws Performance (“Laws Performance” or “Plaintiff”) 

files this Complaint for utility patent and design patent infringement under 35 U.S.C. § 271 

against Sunset Performance Engines, L.L.C. (“Sunset” or “Defendant”), and alleges as follows: 

NATURE OF THE ACTION 

1. This is an action for patent infringement, arising from Sunset’s infringement of 

utility and design patents owned by Laws Performance, as set forth below. 

PARTIES 

2. Laws Performance is a limited liability company organized and existing under the 

laws of the State of Florida, and maintains its principal place of business at 944 Deltona Blvd. 

5421, Deltona, Florida 32725. 

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3. On information and belief, Sunset is a limited liability company organized and 

existing under the laws of the State of Texas, and maintains a place of business at 27633 W. U.S. 

Highway 82, Sherman, Texas, 75092. 

4. On information and belief, Defendant’s Registered Agent for service of process is 

Spencer B. Benson, at 2901 Overland Trail Suite 150, Sherman, Texas 75092. 

JURISDICTION AND VENUE 

5. Plaintiff’s causes of action arise under the Patent Act, 35 U.S.C. §§ 101 et seq. 

Accordingly, this Court has subject matter jurisdiction over this case under 28 U.S.C. §§ 1331, 

1338 and 1367. 

6. This Court has personal jurisdiction over Defendant. Defendant is formed in and 

has its principal place of business in the State of Texas and within this district and division, 

including at its principal address at 2901 Overland Trail Suite 150, Sherman, Texas 75092. 

7. Venue is proper in this Court pursuant to 28 U.S.C. §1400 because Defendant 

resides and may be found in this district and a substantial part of the events giving rise to the 

causes of action occurred within this district and division. 

FACTUAL BACKGROUND 

8. Laws Performance is the owner by assignment of United States Design Patent 

D748,149, entitled “Carburetor” (the '149 Patent). 

9. The ‘149 Patent issued on January 26, 2016 from patent application serial number 

29/476,105, filed by inventor James M. Laws on December 11, 2013. A true and correct copy of 

the ‘149 Patent is attached hereto as Exhibit A. 

10. The ‘149 Patent is directed to the shape of a carburetor body, as shown in Figures 

1-8 thereof. 

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11. The unique and novel carburetor body design shown in and claimed by the ‘149 

Patent incorporates dual openings. The carburetor body is designed to be mounted to a dualblade throttle body in a primary and secondary arrangement. A carburetor of this type is often 

referred to as a “twin blade” carburetor. 

12. The ’149 Patent was assigned to Plaintiff Laws Performance by nature of an 

assignment executed on or about July 13, 2015 and recorded with the U.S. Patent and Trademark 

Office on or about July 21, 2015. 

13. The ‘149 Patent is valid and enforceable in all respects. 

14. Laws Performance is the owner by assignment of United States Utility Patent 

10,036,357, entitled “Fuel Jet Tube and Related Methods” (the '357 Patent). 

15. The ‘357 Patent issued on July 31, 2018 from patent application serial number 

14/824,844, filed by inventor James M. Laws on August 12, 2015. A true and correct copy of the 

‘357 Patent is attached hereto as Exhibit B. 

16. The claims of the ‘357 Patent are directed to various embodiments of a “fuel tube 

system.” The claimed fuel tube systems comprise multiple tube portions adjacent to one another, 

each such tube portion having an outer diameter. 

17. The ‘357 Patent was assigned to Plaintiff Laws Performance by nature of an 

assignment executed on or about September 23, 2015 and recorded with the U.S. Patent and 

Trademark Office on or about September 24, 2015. 

18. The ‘357 Patent is valid and enforceable in all respects. 

19. Upon information and belief, Sunset makes, uses, offers for sale and/or sells 

racing engines. 

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20. Upon information and belief, Sunset uses, offers for sale and/or sells racing 

carburetors. 

21. Upon information and belief, Sunset uses, offers for sale and/or sells fuel jet tubes 

for racing carburetors. 

22. On information and belief, Sunset promotes its racing engines and carburetors via 

its website, traditional media outlets and social media accounts, including but not limited to 

Facebook, Instagram and YouTube. 

23. Upon information and belief, Sunset has been using, offering for sale and/or 

selling carburetors and fuel jet tubes sourced from Get’M Performance Products LLC, of 

Alvaton, Kentucky (“Get’M Carburetors”). 

24. Upon information and belief, Sunset has also been making, using, offering for 

sale and/or selling engines incorporating Get’M Carburetors. 

25. Upon information and belief, Sunset has also been using, offering for sale and/or 

selling fuel jet tubes sourced from Get’M Performance Products LLC (“Get’M Fuel Jet Tubes”). 

26. Upon information and belief, at least a portion of the Get’M Carburetors used, 

offered for sale and/or sold by Sunset incorporate a twin-blade style carburetor body that 

infringes the claim of the ‘149 Patent. 

27. Upon information and belief, at least a portion of the Get’M Carburetors used, 

offered for sale and/or sold by Sunset incorporate fuel jet tubes that infringe at least one claim of 

the ‘357 Patent. 

28. Upon information and belief, some or all of the Get’M Fuel Jet Tubes used, 

offered for sale and/or sold by Sunset infringe one or more claims of the ‘357 Patent. 

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COUNT I: 

INFRINGEMENT OF UNITED STATES DESIGN PATENT D748,149 

UNDER 35 U.S.C. § 271 

29. Laws Performance incorporates by reference the allegations of the preceding 

paragraphs as if fully set forth herein. 

30. On information and belief, Sunset has made, used, offered for sale and/or sold 

engines and/or carburetors incorporating one or more inventions claimed under U.S. Design 

Patent D148,149. 

31. The making, using, offering for sale and selling of engines and/or carburetors 

incorporating the claimed inventions of the ‘149 Patent has been done without the license or 

permission of Laws Performance, and thus constitutes patent infringement under 35 U.S.C. 271. 

32. Upon information and belief, Sunset’s infringement of the ‘149 Patent has been 

conducted with knowledge of the ‘149 Patent and has been done deliberately and willfully. 

33. Laws Performance is entitled to appropriate remedies for Sunset’s infringement of 

the ‘149 Patent. 

COUNT II: 

INFRINGEMENT OF UNITED STATES UTILITY PATENT 10,036,357 

UNDER 35 U.S.C. § 271 

34. Laws Performance incorporates by reference the allegations of the preceding 

paragraphs as if fully set forth herein. 

35. On information and belief, Sunset has made, used, offered for sale and/or sold 

engines, carburetors and/or fuel jet tubes incorporating one or more inventions claimed under 

U.S. Utility Patent 10,036,357. 

36. The making, using, offering for sale and/or selling of engines, carburetors and/or 

fuel jet tubes incorporating the claimed inventions of the ‘357 Patent has been done without the 

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license or permission of Laws Performance, and thus constitutes patent infringement under 35 

U.S.C. 271. 

37. Upon information and belief, Sunset’s infringement of the ‘357 Patent has been 

conducted with knowledge of the ‘357 Patent and has been done deliberately and willfully. 

38. Laws Performance is entitled to appropriate remedies for Sunset’s infringement of 

the ‘357 Patent. 

DEMAND FOR JURY TRIAL 

39. Laws Performance hereby demands a trial by jury for all claims so triable. 

PRAYER FOR RELIEF 

WHEREFORE, Laws Performance respectfully requests that this Court enter judgment in 

its favor as follows: 

a. A judgment in favor of Laws Performance that Defendant has infringed the ‘149 

Patent;

b. A judgment in favor of Laws Performance that Defendant has infringed the ‘357 

Patent;

c. A permanent injunction enjoining Defendant and its officers, directors, agents, 

servants, affiliates, employees, divisions, branches, subsidiaries, parents, and all 

others acting in active concert therewith, from infringement of the ‘149 Patent; 

d. A permanent injunction enjoining Defendant and its officers, directors, agents, 

servants, affiliates, employees, divisions, branches, subsidiaries, parents, and all 

others acting in active concert therewith, from infringement of the ‘357 Patent; 

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e. A judgment and order requiring Defendant to pay Plaintiff its damages, costs, 

expenses, and pre-judgment and post-judgment interest for Defendant’s 

infringement of the ‘149 Patent as provided under 35 U.S.C. § 284; 

f. A judgment and order requiring Defendant to pay Plaintiff its damages, costs, 

expenses, and pre-judgment and post-judgment interest for Defendant’s 

infringement of the ‘357 Patent as provided under 35 U.S.C. § 284;

g. An award to Plaintiff for enhanced damages resulting from the knowing and 

deliberate nature of Defendant’s prohibited conduct with notice being made at 

least as early as the service date of this complaint, as provided under 35 U.S.C. § 

284;

h. A judgment and order finding that this is an exceptional case within the meaning 

of 35 U.S.C. § 285 and awarding to Plaintiff its reasonable attorneys’ fees; 

i. A judgement and order requiring Defendant to disgorge all profits on engines 

infringing the ‘149 Patent as provided in 35 U.S.C. § 289; and 

j. Any and all other relief to which Plaintiff may show itself to be entitled. 

Dated: December 4, 2023 Respectfully submitted, 

/s/ Kenneth T. Emanuelson

Kenneth T. Emanuelson 

THE EMANUELSON FIRM, P.C. 

17304 Preston Road, Suite 800 

Dallas, Texas 75252 

Phone: 469-363-5808 

Ken@Emanuelson.us 

ATTORNEY FOR PLAINTIFF TAJM, LLC 

d/b/a MIKE LAWS PERFORMANCE 

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