Appendix B for

Managing Intellectual Property Litigation

by Lee Carl Bromberg
Bromberg & Sunstein LLP
Boston, Massachusetts
May 21, 1997

Protecting Intellectual Property Assets
MCLE, Inc. 1997, 1995

Appendix B

United States District Court District of Massachusetts

________________________________
                                )
                                )
STORAGE SYSTEMS, INC.           )
      Plaintiff,                )
                                )
                                )        Civil Action No.
v.                              )              95-CV-9964
                                )
                                )
PACEMAKER FURNITURE, INC.,      )
      Defendant.                )
                                )
________________________________)

COMPLAINT AND JURY DEMAND

Plaintiff, for its Complaint against defendant, states as follows:

1. Plaintiff Storage Systems, Inc. is a Delaware corporation with principal offices in South Boston, Massachusetts.

2. Upon information and belief, defendant Pacemaker Furniture, Inc. is a Massachusetts corporation with principal offices in Waltham, Massachusetts.

3 This is a civil action arising under the patent laws of the United States, Title 35, United States Code. The Court has jurisdiction under 28 U.S.C. sec. 1338 and 35 U.S.C. sec. 271. Venue is proper under 28 U.S.C. 1391(c) and 1400(b).

4. On September 6, 1990, U.S. Patent No. 5,001,783 was lawfully issued for an invention entitled QUICK ASSEMBLY STEEL SHELVING. Storage Systems, Inc. is the owner of this patent.

5. Defendant has infringed U.S. Patent No. 5,001,783 by making, using and/or selling quick assembly steel shelving in the District of Massachusetts and elsewhere in the United States. Defendant will continue to infringe unless enjoined by this Court.

WHEREFORE, Storage Systems, Inc. demands judgment as follows:

A. Preliminary and final injunctions against continued infringement;

B. Monetary damages adequate to compensate for the infringement;

C. Treble damages resulting from defendant's willful and deliberate infringement,

D. Reasonable attorneys' fees pursuant to 35 U.S.C. sec. 285;

E. An assessment of interest and costs; and

F. Such other and further relief as this Court deems just and proper.

JURY DEMAND

Storage Systems, Inc. demands a trial by jury.

Dated: March 10, 1997 Bromberg & Sunstein LLP

_______________________
Lee Carl Bromberg
125 Summer Street
Boston, MA 02110-1618
(617) 443-9292
Attorneys for Plaintiff

_______________________
United States District Judge

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