Bikeyoke-Complaint - ogbikeworks.com

UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF VIRGINIA

ALEXANDRIA DIVISION

Paul Gallagher, Plaintiff,

Cranking Solutions Co., Ltd. (羯奇有限公司), Jacky Hou (侯健志), Stefan Sack, BikeYoke GmbH, Dr. Andreas Geissler, Maucher Jenkins LLP, Rosenberg, Klein & Lee, Trend International Patent & Trademark Office (銓德國際專利商標事務所), Ke Guozhen (柯國貞), Martin Moravcik

Defendants.

Case No. ____________

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF

PRELIMINARY STATEMENT

This case arises from an extraordinary act of international misconduct involving forgery, fraud, and conspiracy to misappropriate a U.S. citizen’s intellectual property. Defendants span multiple countries and acted in coordination to file fraudulent patent applications, exploit confidential data, and deprive Plaintiff of rightful ownership. This action seeks to hold each party accountable.

NECESSITY OF LEGAL ACTION

As of the date of this filing, Defendants have refused to formally relinquish their fraudulent claims to Plaintiff’s intellectual property. This continued silence, despite Plaintiff’s written termination of all business dealings and repeated demands for a retraction, has placed Plaintiff in an untenable position. Plaintiff is now unable to move forward with commercializing the invention, as prospective customers and partners have expressed concern over potential legal entanglements. While Plaintiff has no doubt regarding his sole ownership of the invention, the existence of a publicly filed patent application bearing his name and listing Defendants as assignees creates confusion and reputational risk. Plaintiff is therefore left with no choice but to pursue legal action to clarify ownership, protect his rights, and remove any remaining doubt for current and future stakeholders.

SECTION 1: INTRODUCTION

This is an action for damages and injunctive relief arising from a coordinated and deliberate conspiracy to misappropriate Plaintiff’s intellectual property through fraud, forgery, breach of contract, and other unlawful acts, including the filing of a fraudulent patent application in the United States using a forged Power of Attorney.
Defendants knowingly participated in a scheme to steal ownership of Plaintiff’s intellectual property and deprive him of financial compensation for years of development work, in violation of federal and state law.

SECTION 2: JURISDICTION AND VENUE

This Court has subject matter jurisdiction under 28 U.S.C. § 1331 (federal question), 28 U.S.C. § 1338(a) (patents), and 28 U.S.C. § 1367(a) (supplemental jurisdiction for related state law claims), as this action arises under the patent laws of the United States and involves fraud on the United States Patent and Trademark Office (USPTO).

Venue is proper in this district under 28 U.S.C. § 1391(b)(2) because a substantial part of the events giving rise to this claim occurred within the jurisdiction of this Court, including the submission of forged and fraudulent documents to the USPTO by U.S.-based counsel acting on behalf of foreign parties.

Plaintiff is a U.S. citizen and has, at all relevant times, operated through U.S.-based business entities, including Cell Cycling LLC, which was named in the original development agreement with Defendants, and OG Bikeworks, the successor entity currently developing and commercializing the invention at issue. The misconduct alleged herein caused direct harm to Plaintiff and to both U.S. companies.

Defendants BikeYoke GmbH and Cranking Solutions Co., Ltd. (羯奇有限公司) regularly conduct business in the United States, advertise their products to U.S. consumers, and derive substantial revenue from U.S.-based customers. These Defendants knowingly directed commercial and legal activity toward the United States, including the unauthorized prosecution of intellectual property before the USPTO.

Defendants Sack and BikeYoke GmbH have marketed and sold products under the “BikeYoke” trademark into the United States, including through online platforms and at trade events. The trademark is registered with the USPTO under the name of co-defendant Cranking Solutions, owned by Jacky Hou, and its use directly supports U.S. sales of the disputed invention. These activities establish purposeful availment of the U.S. market and subject Defendants Sack and BikeYoke GmbH to the jurisdiction of this Court.

Defendant Jacky Hou, through Cranking Solutions Co., Ltd., is the registered owner of the “BikeYoke” trademark with the United States Patent and Trademark Office (USPTO), under serial number 87897772. This registration was explicitly obtained to support the sale and marketing of products in the United States. The original development agreement also named “BikeYoke” as a contracting party, and the invention at issue was always intended for international sale, including in the U.S. market. This constitutes clear, purposeful availment of U.S. laws, jurisdiction, and commercial benefits.

Plaintiff further alleges that the use of the “BikeYoke” trademark in U.S. commerce constitutes a fraudulent trademark structure. While Jacky Hou holds the registration, the mark is actively used by Stefan Sack and BikeYoke GmbH to promote and introduce the disputed product in the U.S. market without lawful ownership of the underlying intellectual property. This misuse of a registered U.S. trademark to support unauthorized commercialization efforts strengthens personal jurisdiction, supports claims for injunctive relief and damages, and may expose the registration to cancellation.

Defendant Rosenberg, Klein & Lee is a domestic law firm that served as attorney of record for the disputed patent application and filed a forged Power of Attorney with the USPTO on behalf of foreign clients, directly participating in the alleged misconduct.

Defendant Maucher Jenkins LLP is an international intellectual property law firm that regularly engages in patent prosecution before the USPTO. Upon information and belief, the firm employs multiple attorneys registered with the USPTO and has acted as the correspondent or filing agent in numerous U.S. patent applications, including but not limited to Application No. 35/502,777, as confirmed by USPTO records. Its business model includes representing foreign clients in connection with U.S. intellectual property matters and coordinating with domestic counsel to submit official documents. These actions constitute continuous and systematic engagement with U.S. legal structures and subject Maucher Jenkins LLP to the jurisdiction of this Court under Burger King Corp. v. Rudzewicz, 471 U.S. 462 (1985), and Calder v. Jones, 465 U.S. 783 (1984).

This Court has personal jurisdiction over Defendant Dr. Andreas Geißler pursuant to Fed. R. Civ. P. 4(k)(2), as the claims arise under federal law, and Dr. Geißler purposefully directed his activities at the United States by advising clients engaged in the submission of a forged Power of Attorney to the United States Patent and Trademark Office. His actions contributed directly to the fraud upon the USPTO and the misappropriation of Plaintiff’s intellectual property. Exercising jurisdiction over Dr. Geißler is consistent with due process and necessary to address his role in the underlying misconduct.

Defendant Trend Patent & Trademark Office (銓德國際專利商標事務所) is a Taiwanese patent agent that regularly transmits patent application materials and supporting documents to the USPTO through U.S.-based law firms. Trend acted as intermediary in this matter by forwarding a forged Power of Attorney to Rosenberg, Klein & Lee for official submission to the USPTO. Upon information and belief, Trend’s services include regular handling of documents destined for U.S. patent filings, constituting a business practice directed toward the United States. Its involvement in transmitting fraudulent materials to a U.S. federal agency that directly harmed a U.S. citizen supports personal jurisdiction under Calder v. Jones and related authorities.

Defendant Martin Moravcik is a citizen of the Czech Republic who participated in the formation and execution of the original development agreement with Plaintiff, a U.S. citizen, and a U.S.-based company. Upon information and belief, he continues to have involvement with Cranking Solutions and/or related commercial activities targeting the U.S. market under the BikeYoke trademark. Accordingly, he is subject to jurisdiction for his role in the joint venture and the resulting misconduct.

This Court has supplemental jurisdiction over all related claims pursuant to 28 U.S.C. § 1367, including those arising from acts occurring outside the United States, where such acts are part of a continuous scheme originating from a contractual relationship governed in part by U.S. law.

Although the Taiwan patent application filed with the Taiwan Intellectual Property Office (TIPO) does not fall under this Court’s direct territorial jurisdiction, it arises directly out of the same contractual relationship, business dealings, and fraudulent conduct that underpin the claims related to the U.S. patent filing. The parties’ original Intellectual Property and Manufacturing Agreement, which governed the development, ownership, and licensing of the subject matter at issue, was negotiated, executed, and partially governed under U.S. law. As such, Defendants’ actions relating to the Taiwan patent constitute breaches of contract, bad faith, and fraud that fall within the scope of this Court’s jurisdiction.

SECTION 3: PARTIES

Plaintiff Paul Gallagher is a United States citizen and the sole inventor and rightful owner of the wireless dropper post technology at issue in this action. Plaintiff has operated through two U.S.-based business entities relevant to this matter: Cell Cycling LLC, the entity named in the original development agreement, and OG Bikeworks, the successor company currently responsible for development and commercialization of the invention.
Defendant Jacky Hou (侯健志) is a Taiwanese national and principal of Cranking Solutions Co., Ltd. (羯奇有限公司). He is the individual responsible for submitting forged documents to secure control over Plaintiff’s intellectual property.
Defendant Stefan Sack is a German national and co-founder of BikeYoke GmbH. Despite knowing or having reason to know of the unauthorized patent filings involving Plaintiff’s intellectual property, Sack continued to market and distribute products in the United States under the “BikeYoke” brand. This brand is registered as a U.S. trademark under the name of Defendant Jacky Hou, and its use in commerce by Sack and BikeYoke GmbH further establishes their direct connection to the misappropriated intellectual property at issue in this action
Defendant Cranking Solutions Co., Ltd. (羯奇有限公司) is a Taiwan-based corporation formed by Jacky Hou for the purpose of developing and commercializing Plaintiff’s invention. Cranking Solutions manufactures the base dropper post hardware that was the target for the wireless actuator, and is the actual production entity behind the products marketed by BikeYoke GmbH. The company participated in filing unauthorized patent applications without Plaintiff’s consent.
Defendant BikeYoke GmbH is a German-registered company that markets bicycle components under the “BikeYoke” brand. Although frequently perceived as a German manufacturer, BikeYoke’s dropper post products are in fact produced by Cranking Solutions in Taiwan. BikeYoke GmbH sought to benefit from Plaintiff’s technology while avoiding contractual obligations and proper compensation.
Defendant Dr. Andreas Geissler is a German attorney employed by Maucher Jenkins LLP, a multinational law firm. He directly engaged in a legal campaign against Plaintiff while Plaintiff’s intellectual property was being unlawfully prosecuted before the USPTO.
Defendant Maucher Jenkins LLP is an international intellectual property law firm with offices throughout Europe and Asia. Upon information and belief, the firm employs attorneys registered with the USPTO and regularly conducts U.S. patent prosecution on behalf of foreign clients.
Defendant Rosenberg, Klein & Lee is a U.S.-based patent law firm that acted as the attorney of record in connection with the disputed U.S. patent application. The firm submitted forged and unauthorized documents to the USPTO on behalf of its foreign clients.
Defendant Trend Patent & Trademark Office (銓德國際專利商標事務所) is a Taiwan-based patent agent that acted as intermediary in transmitting a forged Power of Attorney to Rosenberg, Klein & Lee for filing with the USPTO.
Defendant Martin Moravcik is a citizen of the Czech Republic and co-signer of the original 2021 development agreement between Plaintiff and Cranking Solutions Co., Ltd. His exact level of involvement in subsequent events is currently unknown.

SECTION 4: FACTUAL BACKGROUND AND TIMELINE

Plaintiff is the sole inventor of a wireless-actuated bicycle seatpost (dropper post) system involving novel hardware, firmware, and mechanical components developed over years of independent work.

On April 13, 2021, Plaintiff entered into a written development agreement with Defendants Jacky Hou and Martin Moravcik, acting on behalf of Cranking Solutions Co., Ltd., to adapt the Plaintiff’s proprietary technology for commercialization through BikeYoke GmbH, founded by Defendant Stefan Sack. This agreement, signed by Hou and Moravcik, clearly established that all intellectual property (IP) related to the device would remain the exclusive property of the Plaintiff.

No monetary compensation for development was provided to Plaintiff under this agreement. Plaintiff undertook all development work at his own expense and risk, relying entirely on the good faith representations of Defendants and the expectation of future revenue through licensing and manufacturing partnerships. Over the course of this collaboration, Plaintiff invested more than 3,000 hours of skilled labor and over $100,000 USD in out-of-pocket expenses.

On July 26, 2023, Plaintiff filed a provisional patent application with the USPTO to protect the core invention. This provisional listed Defendants Hou and Sack as co-applicants solely as a preliminary protective measure. A statement was included noting that ownership would be clarified at the time of the formal utility filing. The purpose of this approach was to preserve patent rights during the ongoing commercial discussions—not to transfer or assign intellectual property. This provisional was filed in good faith and with full transparency toward the parties involved. Unfortunately, Defendants later used that act of good faith as an opportunity to seize control of the intellectual property. Rather than entering into a formal agreement to clarify inventorship and ownership as initially planned, they acted unilaterally—filing unauthorized patent applications, attempting to remove Plaintiff as assignee, and forging documentation to gain full control over the invention.

In August 2023, due to the Defendants’ ongoing difficulties in executing the technology, Plaintiff relocated his business operations to Taiwan to directly support the Defendants’ development needs and facilitate efficient collaboration. This relocation was made mainly at Plaintiff’s significant expense and reflected his full commitment to the project and to the Defendants’ success.

However, shortly after relocating, Plaintiff was forced to leave the country due to a procedural visa issue that arose from incorrect instructions provided by Defendant Hou. This abrupt disruption caused significant personal, health and professional hardship, yet Plaintiff continued supporting the Defendants remotely while attempting to reestablish legal presence in the region.

In late 2023 to early 2024, after Plaintiff was forced to leave Taiwan due to the aforementioned visa issue, he granted Power of Attorney (POA) to Defendant Hou in good faith, authorizing him to manage the administrative wind-down of Plaintiff’s Taiwanese business while Plaintiff was under a one-year reentry ban. Plaintiff later discovered that Defendant Hou had used this POA to facilitate approximately 3 million NTD in fraudulent invoices through the company. Defendant Hou claimed these invoices were fabricated to simulate business activity needed to qualify Plaintiff for a work visa, but this plan was either recklessly incompetent or designed for ulterior motives. The fabricated transactions created significant legal and financial risk for Plaintiff, ultimately forcing him to dissolve his company to avoid liability.

While this event occurred outside U.S. jurisdiction, it provides important context. This incident demonstrates Defendant Hou’s prior pattern of deception, misuse of legal authority, and willingness to falsify official documentation for personal or business gain. It also contextualizes Plaintiff’s later decision to withdraw from the relationship.

On April 8, 2024, one week before the expiration of the original agreement, Plaintiff drafted and submitted a new proposed agreement titled “Intellectual Property and Manufacturing Agreement” to Defendants Hou and Sack on April 4, 2024. This agreement reiterated that all IP and proprietary materials were solely owned by the Plaintiff. Stefan confirmed by phone that he read it, and said would review it with Jacky. Then they went silent about the contract. Clearly, they were already planning the theft..

Despite repeated assurances and promises to formalize a new agreement, Defendants delayed and ultimately refused to sign any binding contract. During this period, they continued to request proprietary technical materials and development updates from Plaintiff, creating the false impression that negotiations were ongoing and the business relationship was intact.

On July 23, 2024, Plaintiff received a FedEx package from Defendants containing product samples for testing, along with pre-filled patent-related documents, including a Power of Attorney and an Assignment Deed. Plaintiff was not informed of this package in advance. Upon receipt, Plaintiff immediately notified Defendants Hou, Sack, and Trend Patent Office that they did not have his permission to file any patents and reiterated that a utility patent application covering the invention had already been filed by Plaintiff in April 2024.

However, unbeknownst to Plaintiff, Defendants had already filed two patent applications on the same day, July 23, 2024—one with the United States Patent and Trademark Office (USPTO), and one with the Taiwan Intellectual Property Office (TIPO). These filings were made despite the fact that Plaintiff had not signed, nor authorized the submission of, the Assignment Deed, the Inventor Declaration, or the Power of Attorney. Plaintiff is in possession of the unsigned Assignment Deed bearing only the signatures of Hou and Sack. He retains all original, unexecuted documents, including the unsigned PTO/AIA/82A (Power of Attorney) form and declaration, confirming that no valid authorization had been granted for these filings.

The most plausible explanation for failing to contact Plaintiff is that the parties involved were deliberately attempting to conceal the patent filing from him. RKL’s decision to proceed without even a basic verification step—particularly after USPTO notification—constitutes not only gross negligence, but active facilitation of a broader scheme to exclude Plaintiff from his own invention. This omission directly enabled the filing of fraudulent documents and furthered a willful effort to misappropriate Plaintiff’s intellectual property.

In a further breach of legal and ethical duties, the USPTO filing record confirms that Morton J. Rosenberg, a registered patent attorney at Rosenberg, Klein & Lee, digitally signed and submitted a Power of Attorney transmittal form on Plaintiff’s behalf on July 23, 2024—without ever receiving a valid Power of Attorney from Plaintiff. Notably, neither Mr. Rosenberg nor anyone from his firm made any effort whatsoever to confirm Plaintiff’s identity, consent, or participation prior to making these representations to the USPTO. The firm proceeded without so much as a verification email or phone call to the named inventor, despite the seriousness of the submission and the fact that Plaintiff was not previously a client of record.

This action was taken under penalty of perjury, despite the absence of any legal authority to represent Plaintiff before the USPTO. Mr. Rosenberg’s conduct constituted a clear violation of his duty of candor under 37 C.F.R. § 11.18(b)(2)(i) and the requirements governing attorney representation under 37 C.F.R. § 1.32(a).

Had Plaintiff been notified by RKL or any party of the fraudulent filing of the patent application on July 23, 2024, Plaintiff would have immediately terminated all business relations with the Defendants and filed for injunctive relief to prevent further misappropriation of his intellectual property. Instead, Defendants, with the cooperation of their attorneys, filed the application without Plaintiff’s knowledge or consent, depriving him of the opportunity to protect his rights and triggering months of delay, damage, and exposure.

On July 23, 2025, the following fraudulent filings occurred claiming ownership of Plaintiff’s invention:

U.S. Patent Application No. 18/780,830, filed with the United States Patent and Trademark Office (USPTO);
Taiwan Patent Application, filed with the Taiwan Intellectual Property Office (TIPO).

Both filings were made without Plaintiff’s signed declaration, Power of Attorney, or any valid assignment. These actions constituted willful fraud on the USPTO and a direct violation of Plaintiff’s intellectual property rights. Notably, the patent applications filed by Defendants not only included adaptations developed during the collaboration, but also incorporated core intellectual property and proprietary inventions that Plaintiff had developed independently, prior to any engagement with Defendants. These filings further disclosed confidential trade secrets and technical details that were never intended for public release, in direct violation of the trust placed in the Defendants and without any authorization from Plaintiff. No written agreement, assignment, or consideration was ever exchanged to authorize the transfer of Plaintiff’s intellectual property. It is inconceivable that any rational party would donate four years of labor, over $100,000 in funding, and proprietary designs to Defendants without a signed agreement or mutual commercial benefit.

On July 24, 2024, after receiving those unsigned documents by FedEx, Plaintiff immediately informed Hou and Sack, and Trend, that I had already filed a utility patent for the IP and they do not have my permission to file further patents. Jack, the representative of Trend, acknowledged my request in writing.

On July 24, 2024, the day after the patent application was filed, Trend instructed Rosenberg, Klein & Lee (RKL) to abandon the application. RKL responded that the application had already been filed and could not be withdrawn without proper documentation. The context surrounding this request raises serious concerns. Although it is theoretically possible that Defendants were attempting to retract an improperly filed application, their subsequent conduct—including submitting a forged Power of Attorney, removing Plaintiff from the inventorship record, and continuing to prosecute the same invention in Taiwan—strongly suggests a different and far more troubling motive. It is far more likely that Defendants intended to discard the original application so that a new, “clean” version could be filed—one that excluded Plaintiff entirely from inventorship and ownership. This theory is further supported by the fact that Defendants allowed the Taiwan patent application to proceed to grant, despite Plaintiff’s written objection and lack of authorization. The continued prosecution of the Taiwan application reveals a clear intent to retain exclusive control of Plaintiff’s intellectual property, regardless of its legal or contractual origins.

On August 8, 2024, Rosenberg, Klein & Lee filed a petition to abandon the patent application using an electronic signature from attorney Morton J. Rosenberg, submitted under the false presumption that he had valid Power of Attorney authorization from Plaintiff. This filing, like the others, was made without Plaintiff’s consent or signed authorization. The USPTO subsequently rejected the petition due to the absence of a proper signature, confirming that the required legal authority had never been established.

The USPTO’s rejection of the August 8, 2024 petition to abandon—filed by Morton Rosenberg—confirms that his submission was procedurally invalid and legally unauthorized. If such actions were common or acceptable under USPTO practice, the petition would have been processed without objection. Instead, the agency flagged the deficiency, providing official confirmation that Mr. Rosenberg acted outside the bounds of permissible representation.

On August 13, 2024, After their initial attempt to abandon the application was rejected by the USPTO on, due to the lack of a valid Power of Attorney, Defendant Rosenberg, Klein & Lee became fully aware that Plaintiff’s signature and authorization were required. At that point, RKL had a clear and straightforward remedy: contact the named inventor—whose identity and contact information were readily available—and request the necessary signature. However, no such effort was made.

Between August 23 and September 6, 2024, Defendant Stefan Sack contacted Plaintiff no less than seven times to request that additional prototypes be shipped to Taiwan. At the time, Plaintiff declined to send more units, noting that several working samples were already in Defendants’ possession and additional modifications were needed.

However, viewed in hindsight and in the context of the subsequent forged Power of Attorney, Plaintiff now questions whether these persistent requests were part of an effort to generate a FedEx shipment record or tracking number from Plaintiff to Defendants, which could later be used to falsely suggest cooperation or consent. Such a record could have been leveraged to support or justify the submission of unauthorized documents—including the forged POA that would eventually appear months later.

On September 19, 2024, after months of delay and refusals to enter into a new signed contract, Plaintiff sent a written ultimatum to Defendants Hou and Sack, stating that he would terminate all cooperation and withdraw entirely from the project if they did not enter into a formal agreement by October 1, 2024.

On the same day, September 19, 2024, Defendants submitted the forged Power of Attorney (POA) to Trend Patent & Trademark Office (銓德國際專利商標事務所), bearing Plaintiff’s falsified signature. Trend then transmitted the forged POA to Rosenberg, Klein & Lee (RKL), who later filed it with the USPTO.

On October 20, 2024, having received no meaningful response to his ultimatum from September 19, and growing increasingly suspicious that something was wrong, Plaintiff terminated all cooperation with Defendants Hou and Sack. He formally demanded the return of all confidential samples and the deletion of proprietary files and trade secrets. These demands were ignored, and have still not been complied with as of the submission of this complaint.

On October 24, 2024, Rosenberg, Klein & Lee received a new Power of Attorney document from Trend Patent Office. This document contained a forged signature purporting to be that of Plaintiff, who never executed, authorized, or saw the document prior to its submission. Despite the document’s critical importance—and the fact that earlier submissions by RKL had been filed immediately upon receipt—RKL waited nearly one month before submitting the forged Power of Attorney to the USPTO on November 18, 2024. It was accepted by the USPTO on November 22, 2024. This unexplained delay is notable. RKL has provided no justification for the gap between receipt and submission. Given the urgency with which they handled all prior filings, the delay suggests that RKL may have been aware of the questionable nature of the document and proceeded only after internal deliberation—or under pressure from their client.

Additionally, in the same communication, Trend informed RKL that they would be contacted by “a German attorney.” This individual could only have been Dr. Andreas Geissler, who subsequently began representing Defendants and aggressively asserted ownership claims over Plaintiff’s IP. This sequence of events indicates a deliberate shift from an improperly filed joint application to a carefully orchestrated effort to wrest full control of the invention from Plaintiff, involving multiple parties across jurisdictions.

On October 25, 2024, RKL submitted the forged POA to the USPTO. This forged document was accepted and processed by the USPTO without Plaintiff’s knowledge.

That same day, October 25, 2024, Plaintiff received the first in a series of threatening legal communications from Defendant Dr. Andreas Geissler, acting on behalf of Cranking Solutions, BikeYoke GmbH and its affiliates. These threats were made despite the fact that Geissler, Sack, and Hou had already acted to usurp Plaintiff’s ownership of the invention through a fraudulent filing.

On November 8, 2024, Plaintiff received a second letter from Dr. Andreas Geissler, acting as legal counsel for Defendants. In this correspondence, Dr. Geissler rejected all suggestions of licensing and instead asserted that his clients were fully entitled to Plaintiff’s intellectual property. Despite this assertion, he offered Plaintiff a nominal license of $5 per unit for only two years—an offer so low it effectively acknowledged the legitimacy of Plaintiff’s rights while simultaneously attempting to pressure him into surrendering them.

On November 18, 2024, Rosenberg, Klein & Lee (“RKL”) received a formal request from Trend Patent & Trademark Office to remove Plaintiff entirely from the U.S. patent application, both as inventor and as assignee. Although RKL noted that inventor removal was unnecessary, they nonetheless proceeded to strip Plaintiff of assignee status. This act was performed in the context of an active inventorship dispute, and without any consent or formal reassignment from Plaintiff. It effectively completed the unlawful transfer of Plaintiff’s intellectual property, and further evidences RKL’s direct participation in the prosecution of a patent rooted in fraud.

RKL’s own correspondence confirms that the firm was not merely filing materials but was actively advising Trend on matters of inventorship and assignment. Their assertion that Plaintiff need not be removed as inventor is a tacit admission that they were aware of his role—and that they nonetheless proceeded with stripping him of his assignee status without consent or inquiry. This constitutes clear professional negligence and demonstrates a failure to perform even the most basic verification required under USPTO ethical rules.

November 27, 2024, RKL received additional instructions from Trend to add Stefan Sack as an inventor and noted that a German attorney (Presumably Dr. Geissler) would be contacting them. This confirms that both Sack and Geissler were aware of the patent’s existence by that date and actively participated in its prosecution, while failing to inform Plaintiff of its existence.

At all times prior to the filing, Plaintiff had clearly informed Defendants that no IP filings or disclosures were permitted without his explicit written consent. Despite this, Defendants attempted to eliminate Plaintiff’s ownership through forged documentation while continuing to request confidential information and samples to further their own commercial objectives.

On March 13, 2025, After discovering the fraud, Plaintiff issued cease-and-desist communications and filed formal complaints with the USPTO and the U.S. Department of Justice.

On March 13, 2025, following the discovery of the forged Power of Attorney submitted in November 2024, Plaintiff contacted Dr. Andreas Geissler to confront him about the fraudulent document. In response, Dr. Geissler issued a highly evasive statement, asserting only that “We were not involved in the preparation of that patent.” Notably, Dr. Geissler did not deny awareness of the patent’s existence, nor did he deny knowledge of the forged POA, its submission, or the removal of Plaintiff from the application.

In the context of his earlier communications—where he aggressively asserted ownership on behalf of his clients, offered licensing terms, and threatened legal action against Plaintiff—this carefully worded statement appears to be a deliberate attempt to distance himself from potential liability while avoiding a direct lie. It further supports the inference that Dr. Geissler was aware of the fraudulent filing, and was continuing to represent and act on behalf of clients engaged in ongoing misconduct.

SECTION 5: TREND’S KNOWLEDGE AND DIRECT PARTICIPATION IN FRAUDULENT FILING

On July 24, 2024, Plaintiff sent a direct message to Trend’s agent, 施文銓 (Jack), stating: “I want to inform you that I have already filed several Utility patents with the USPTO regarding this project. They were filed in March, 2024. Therefore, you should not file further patents that infringe on my priority dates.” Trend confirmed receipt of this message the same day. Despite this clear and documented notice of Plaintiff’s inventorship and prior filings, Trend did not inform Plaintiff of the U.S. or Taiwan patent applications it had already submitted one day earlier, on July 23, 2024. Instead, they later provided a forged Power of Attorney in Plaintiff’s name to the United States Patent and Trademark Office.

This message, and Trend’s acknowledgment of it, constitutes indisputable evidence that Trend had actual knowledge of Plaintiff’s intellectual property rights prior to submitting any Power of Attorney or assignment forms. Trend’s failure to notify Plaintiff of the filing, its subsequent transmission of a forged document, and its role in instructing RKL to remove Plaintiff as assignee and inventor establish its direct participation in a deliberate and calculated scheme to misappropriate Plaintiff’s intellectual property. These actions constitute not only civil fraud but likely violate multiple provisions of Taiwanese law, including criminal statutes related to document forgery and intellectual property fraud. Plaintiff reserves the right to pursue civil and criminal remedies in Taiwan.

Rosenberg, Klein & Lee’s letter of March 25, 2025 — submitted in response to Plaintiff’s allegations — contains multiple contradictions and materially inconsistent statements regarding the patent filing timeline, applicant structure, and assignment chain. For example, while Paragraph 5 claims that both Plaintiff and Cranking Solutions were listed as applicants on July 8, Paragraph 12 states that Stefan Sack was to become the “new applicant” via a second assignment. These representations are irreconcilable and do not align with the USPTO records or the documents known to Plaintiff. The inconsistencies appear to reflect either a deliberate effort to obscure the firm’s actions or a serious failure of internal process and recordkeeping — neither of which can excuse the firm’s role in processing a forged and unauthorized filing.

Furthermore, Trend’s conduct calls into question the integrity of all other patent filings it has submitted through Rosenberg, Klein & Lee. Given that Trend knowingly submitted a forged POA and attempted to remove a rightful inventor in contradiction of documented evidence, every other filing originating from Trend now warrants scrutiny. Plaintiff respectfully requests that this matter be referred to the United States Patent and Trademark Office Office of Enrollment and Discipline (USPTO OED) for further investigation and that a formal audit be initiated of all Trend-originated applications submitted to the USPTO through Rosenberg, Klein & Lee.
SECTION 6: CAUSES OF ACTION