Robert M. Lyden Pro Se 18261 S.W. Fallatin Loop Aloha, OR 97007 E-mail:
[email protected] Phone: (971) 219-1200 UNITED STATES DISTRICT COURT DISTRICT OF OREGON Portland Division ROBERT M. LYDEN, Case No. 3:13-CV-00662-HZ an individual, Plaintiff, SECOND AMENDED COMPLAINT FOR: v. PATENT INFRINGEMENT; CONVERSION; NIKE, INC., FRAUD; AND, an Oregon Corporation, and UNFAIR COMPETITION, BUSINESS, AND TRADE PRACTICES / RICO MARK PARKER, CEO of Nike, Inc., An Individual, and PHILLIP KNIGHT, Co-Founder of Nike, Inc., and Principle Shareholder, An Individual, Defendants. DEMAND FOR JURY TRIAL For his complaint against Nike, Inc., Plaintiff Robert M. Lyden (“Plaintiff” or “Lyden”), states and alleges, as follows: NATURE OF THE CASE 1. This is a patent infringement lawsuit brought under the patent laws of the United States, including 35 U.S.C. §§ 271, 281, 283-85. 2. In addition, this is an unfair competition and unlawful business, trade practices lawsuit arising under common law, and including ORS § 646.607, 646.608, and 646.638, but also ORS § 166.720, RICO. THE PARTIES 3. Robert M. Lyden is a private individual having a residence at 18261 S.W. Fallatin Loop, Aloha, Oregon 97007, in the United States. 4. Nike, Inc. is a corporation organized under the laws of the State of Oregon, having its World Headquarters and principle place of business at One Bowerman Drive, Beaverton, Oregon 97005, in the United States. 5. Mr. Mark Parker is the CEO of Nike, Inc., and an individual whose principle place of employment is Nike, Inc. located at One Bowerman Drive, Beaverton, Oregon 97005, in the United States, and a resident of the greater metropolitan area of Portland, Oregon.