The first claim alleged deals with the infringement of the ’481 Patent. There are two claims for relief laid down by the Plaintiff.
As a direct and proximate result of such actions, Dr Tankovich has suffered, and continues to suffer, injury in fact and has lost money, property, and/or goodwill.” Tankovich’s confidential and proprietary information. Candela has engaged, and continues to engage, in unfair or unlawful business practices in California by breaching the NDAs and improperly misappropriating Dr. The Plaintiff also alleged that, “Candela had actual notice of the ’481 Patent prior to the filing of the lawsuit, or, alternatively, by the filing of this lawsuit, yet, in spite of such notice, continued to willfully engage in infringing acts, which were egregious. Cndela has indirectly infringed and is indirectly infringing at least claims 1, 2, 4, 6, 7, 8, and 9 of the ʼ481 Patent by inducing end-users of the Accused Product in the United States to directly infringe in violation of 35 U.S.C.
The Plaintiff further alleged that, “Candela has directly infringed and is directly infringing at least claims 1, 2, 4, 6, 7, 8, and 9 of the ʼ481 Patent by making, importing, using (including for testing or demonstrations), offering for sale, and/or selling the Accused Product in the United States all in violation of 35 U.S.C.
CANDELA MEDICAL SKIN
“Accused Products” refers collectively to the Candela Frax Pro and Nordlys laser skin treatment devices.” The report was entitled “MultiFrax Laser System for Facial Rejuvenation Preliminary Evaluation” and was authored by Shlomo Assa (hereinafter “Evaluation Report”). Tankovich with a 20-page report summarizing the results of its testing of Dr. and one on behalf of Paradigm Medical Technologies Corporation. Tankovich entered into two Mutual Non-Disclosure Agreements with Candela that were effective as of J(the “NDAs”), one on behalf of Stemedica Cell Technologies, Inc. Tankovich’s new and patented laser skin treatment designs. Tankovich, a prolific inventor in the field of medical laser applications, by deliberately misappropriating Dr. Candela, a multi-million-dollar international corporation, took advantage of and betrayed Dr. In their complaint, the Plaintiff alleged that, “This case is about more than a patent for a laser skin treatment device – it is a classic David versus Goliath story. 10,675,481 (the “’481 Patent” or the “Asserted Patent”) owned by the Plaintiff. The Plaintiff filed this complaint for the alleged infringement of United States Patent No. District Court in the Central District of California with Judge Autumn D. Tankovich” or “Plaintiff”), represented by Olga Berson of Morgan Lewis and Bockius LLP, filed an intellectual property lawsuit against Candela Medical, Inc., formerly known as Candela Corporation, (“Candela”), seeking declaratory and injunctive relief along with damages for Candela’s alleged infringement of the United States Patent owned by the Plaintiff. On November 29, 2021, Nikolai Tankovich, MD, PhD (“Dr.
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