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FW: M.T.H. Dealer Newsletter, June 14, 2006



Title: Message
FYI -- addendum to MTH's earlier email.
 
 
 
Craig Berry
The Collectible Caboose
store: (512) 259-9494
mobile: (512) 657-3128
-----Original Message-----
From: MTH Electric Trains [mailto:sales@mth-railking.com]
Sent: Wednesday, June 14, 2006 2:49 PM
To: Craig
Subject: M.T.H. Dealer Newsletter, June 14, 2006

June 14, 2006 - As announced yesterday, June 13, 2006, M.T.H. Electric Trains filed suit against Lionel for patent infringement. Yesterday's press release indicated that a timeline would be released today detailing the dispute's history between M.T.H. and Lionel.

The following timeline illustrates the developments of patent infringement issues between M.T.H. Electric Trains and Lionel over the past four years. Under each date we have included a link to a PDF document that contains either actual correspondence between M.T.H. and Lionel counsel or court documents pertaining to the actual issue.

Consumers interested in understanding in more detail the actual events between the two firms, as they occurred, will find this information far more helpful than a press release designed to put the firm's best foot forward. With this information, consumers will be able to see both company's tactics and concerns so that one can draw a more balanced impression of what has been occurring in our industry.

It is our hope that when such information is digested, M.T.H.'s actions will be better understood.

June 21, 2002 - Lionel files a complaint against M.T.H. for falsely advertising its DCS System. In the complaint exhibit D is an affidavit by Lou Kovach (developer of TMCC I and TMCC 2) who Lionel had examine M.T.H.'s DCS System. At that time Lionel could have added to the complaint any Patent Infringement claims it may have had against M.T.H.

September 4, 2002 - Lionel sends M.T.H. a letter claiming DCS infringes TMCC patents. Lionel demands that M.T.H. immediately cease and desist from selling any more DCS Systems.

September 13, 2002 - M.T.H. responds to Lionel's claim that Lionel owned the concept of "remotely controlling model trains" by sending Lionel prior art of a remote control system built by Marklin.

September 20, 2002 - Lionel asks M.T.H. to sent proof of the Marklin System.

October 3, 2002 - M.T.H. sends Lionel the Marklin brochures that predate Lionel's Patent application.

October 15, 2002 - Lionel or its attorneys can't find the dates on the Marklin brochures (which show the technology predates Lionel's patents) and ask M.T.H. to provide the definite dated material.

October 28, 2002 - M.T.H. informs Lionel where to look on the brochures to find the dates of August 1980 and January 1991 which demonstrate how the Marklin technology predates Lionel's patent claims.

November 13, 2002 - Lionel asks M.T.H. for any additional prior art that invalidates Lionel's patent claims.

January 30, 2003 - Lionel drops it baseless suit against M.T.H. for its false advertising claims relating to M.T.H.'s DCS System.

September 18, 2003 - Lionel sends M.T.H. a sends to tell them that they are still investigating if M.T.H.'s DCS System is infringing its patents one year after the original letters were exchanged.

September 26, 2003 - M.T.H. responds to Lionel's letter with a suggestion to Lionel that it review all the prior art M.T.H. cites in its DCS Patents.

September 29, 2003 - M.T.H. sends Lionel a letter pointing out its infringement of M.T.H.'s registered trademark "Ives", the use of the QSI HO Board that incorporates 1 scale mph increments for speed control, and M.T.H.'s microprocessor controlled Synchronized Puffing Smoke feature.

October 10, 2003 - Lionel responds to M.T.H.'s letter by agreeing not to use the Ives name in its next catalog and to investigate M.T.H.'s claims of infringement.

October 27, 2003 - M.T.H. responds to Lionel_s October 10th letter.

November 19, 2003 - Lionel responds to M.T.H. claiming that a Lionel B&A Hudson steam locomotive features synchronized puffing smoke which predates M.T.H.'s synchronized puffing smoke patent.

December 3, 2003 - M.T.H. responds to Lionel's claim that its B&A Hudson is prior art by pointing out that the "puffing" action is achieved with a crude "mechanical apparatus" and thus does not qualify as prior art to M.T.H.'s microprocessor based method of achieving its synchronized puffing smoke action.

December 4, 2003 - M.T.H. sends Lionel a copy of M.T.H.'s just-issued US Patent #6,655,640 covering synchronization of smoke and sound effects.

February 20, 2004 - M.T.H. writes Lionel after getting a copy of Lionel's newly issued patent for its so called Smart Smoke system, which is exactly what M.T.H. had designed and put out in the market prior to Lionel filing its patent application. While Lionel was arguing that M.T.H.'s synchronized smoke system was not patentable as evidenced by their belief that the Lionel B&A Hudson qualified as prior art, Lionel's own lawyers which had filed a patent application for the exact same invention.

As of June 14, 2006, Lionel has never responded to M.T.H.'s Letter concerning the synchronized smoke system.

December 27, 2004 - M.T.H. writes Lionel once again to introduce Lionel's new lawyers and management team of Lionel_s continued violation of M.T.H.'s Synchronization Smoke Patent, Speed Control Patent and use of M.T.H.'s registered trademark of Ives. M.T.H. offers to settle all disputes with no monetary damages to Lionel if Lionel agrees to stop using M.T.H.'s Intellectual Property.

As of June 14, 2006, Lionel has never answered M.T.H.'s letter and continues to display no regard for M.T.H.'s intellectual property. If Lionel had prior art to M.T.H.'s patent, at the least, one would have expected them to at least say they did.

November 7, 2005 - Lionel sends M.T.H. another threat that M.T.H. is violating Lionel patents in an attempt to leverage M.T.H. into settling all its claims against Lionel.

Note: portions of the letter contain redacted information not pertaining to the patent infringement issues discussed in this timeline.

December 5, 2005 - M.T.H. responds to Lionel's threat that their request is unfounded and contains baseless claims of patent infringement on M.T.H.'s part.

Note: portions of the letter contain redacted information not pertaining to the patent infringement issues discussed in this timeline.

May 31, 2006 - Lionel files a motion under Bankruptcy Rule 2004 to conduct discovery to determine whether to object to M.T.H.'s Patent Infringement Claim.

June 13, 2006 - M.T.H. files suit against Lionel for patent infringement.

June 13, 2006 - M.T.H. objects to Lionels discovery using Bankrupty Rule 2004.

Naturally we would prefer that none of the above events ever had taken place. Indeed, the information shows that we have tried in the past to terminate these actions upon Lionel's agreement. Alas, no such cooperation has occurred and in some cases, outright silence has been Lionel's preferred response.

Regardless of Lionel's stance today, M.T.H. continues to prefer that, at the very least, the actions of the past few weeks be terminated on both sides until after the Sixth Circuit Court of Appeals rules in the theft of trade secrets case. Standing down these actions until then is the very least our two firms can do to illustrate to the marketplace of our commitment to the industry and our customers.