UNITED STATES DISTRICT COURT DISTRICT of OREGON Portland
Case 3:13-cv-00662-HZ Document 23 Filed 12/06/13 Page 1 of 58 Page ID#: 6150 0 0 Robert M. Lyden ProSe 18261 S.W. Fallatin Loop Aloha, OR 97007 E-mail: robertlyden @comcast.net 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 I 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 Case 3:13-cv-00662-HZ Document 23 Filed 12/06/13 Page 2 of 58 Page ID#: 6151 c 0 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.
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