A Documented History of Offenses Committed Against Neoteric Hovercraft, Inc. by

Sotsenko Yaroslav (Vladimirovich)
Air Wing / Production Company “MSK" / 000 Aeroslava

27 Jan. 1999               As documented by www.whois.net, the Neoteric web site domain name NeotericHovercraft.com was registered
                                 on this date.

8 Oct. 1999                 The Neoteric web site is first indexed by the Internet Archive http://web.archive.org; therefore it was launched
                                 circa April-October 1999.

2000:

6 Mar. 2000                 As documented by www.whois.net, the Neoteric web site alternate domain name rescuehovercraft.com was
                                  registered on this date.

2004:

                                 Christy Hovercraft (LL Sirius), President Igor V. Lavrov, contracts as the licensed dealer/agent for Neoteric
                                 Hovercraft, Inc. in Russia.

2013:

22 Feb. 2013               Neoteric learns that airwing.ru, the website of Air Wing / Production Company “MSK” has pirated the patented
                                 Neoteric Hovertrek™ and is featuring their counterfeit copies for sale using the model name “Niaterek” – an
                                 illegal plagiarism of Neoteric’s trademarked company name . Air Wing has also illegally copied, without
                                 permission, photos and videos from the copyrighted Neoteric Hovercraft website.

                                  See http://airwing.ru/hovercrafts-models/four-seater-hovercraft-niaterek.html

                                 Air Wing has no connection with Neoteric Hovercraft, Inc. and is not authorized to sell Neoteric Hovercraft.

Mar. 2013                   Igor Lavrov of Christy Hovercraft, Neoteric’s licensed agent in Russia, informs Neoteric that a purchaser of an
                                 unauthorized pirated “Niaterek” hovercraft has filed a civil lawsuit against Air Wing / Production Company
                                 “MSK”. The plaintiff reveals that Air Wing stated they decided to call their hovercraft “Niaterek” because they
                                 thought this name would attract more customers who would associate it with “the famous American
                                 manufacturer.” The customer plans to pursue a criminal case against Air Wing for fraud.     

                                 Air Wing continues to publish ads containing plagiarized copyrighted material from both Neoteric Hovercraft,
                                 Inc. and Christy Hovercraft. These ads contain photographs owned by Neoteric Hovercraft, Inc. that were
                                 illegally plagiarized from the Neoteric website and do not represent the counterfeit hovercraft marketed by Air
                                 Wing.
           
12 Apr. 2013               Neoteric Hovercraft, Inc. serves Air Wing / Product Company “MSK” with a Cease and Desist Order. Air Wing
                                 does not reply and also does not comply with the Order.

                                 Air Wing has no authorization or any legal right to manufacture or market Neoteric Hovercraft.

24 May 2013               Gleb Danilov of Christy Hovercraft notifies Neoteric that Christy Hovercraft clients have informed him that Air
                                 Wing continues to illegally manufacture, market and sell pirated, counterfeit models of the patented Neoteric
                                 Hovertrek™ hovercraft. Danilov includes recent photographs of Air Wing’s assembly facility, located in
                                 Leningrad region.

3 June 2013                New advertisements for pirated, counterfeit Neoteric Hovertrek™ hovercraft appear on www.avito.ru. The
                                 advertisements were placed by an Air Wing director named Yaroslav and they use “Niaterek” as the model
                                 name – a modified version of Neoteric’s trademarked business name.

14 June 2013              Gleb Danilov of Christy Hovercraft reports the following to Neoteric, with extensive photographic
                                  documentation.
                       
                                  “We have received new information that “Boats and Yachts” (the oldest and biggest Russian maritime journal)
                                 published information on counterfeit products. Participants of the forum do not understand the situation with
                                 counterfeit products producer, and blame our company in defective products development and distribution.

                                 This information discredits us as the official representative of Neoteric Hovercraft, Inc. in Russia, as well as
                                 you. According to our information, the [counterfeit] Hovertrek™ has been bought by Novosibirsk Rescue
                                 Service and it did not meet their hopes and expectations. Then they turned to one of the local firms from
                                 Kemerovo for this Hovertrek fixing. The quality of manufacture and assembly of this Hovertrek was extremely
                                 ugly. The firm that was conducting the technical survey declined to help them when saw such a disgraceful
                                 assembly quality. We also have never seen such awful quality. In the attached files you can see some images
                                 downloaded from the forum.

                                 During the discussion at the forum, another member posted information that the same counterfeit products
                                 were delivered to him for repair. He also placed relevant photos. This [counterfeit] Hovertrek™ is in Rybinsk,
                                 Moscow region.

                                 Today we contacted the police and were recommended to write an official letter and prepare the necessary
                                 additional information about the illegal actions of the company Air Wing (MSK). They transfer these materials to
                                 the General Directorate Ministry of Internal Affairs of Russia in St. Petersburg.

17 June 2013              Neoteric learns that a video on YouTube at http://www.youtube.com/watch?v=9Cb3_PSluBI shows another
                                 illegal copy of the Neoteric Hovertrek™ being sold by Air Wing, featuring Neoteric’s patented reverse thrust
                                 buckets in operation.

6 Aug. 2013                A formal complaint against Air Wing / Production Company “MSK” / 000 Aeroslava was filed with the General
                                 Directorate Ministry of Internal Affairs of Russia.

                                 A client accusing Air Wing of fraud registered a claim of $47,548 against Air Wing / Production Company “MSK”
                                 / 000 Aeroslava in Russia.

2014:

26 Dec 2014               AirWing continues their illegal actions by posting a video on YouTube promoting their counterfeit hovercraft.
                                 Neoteric reports the video to all appropriate agencies …

                                 In December Neoteric also receives a photo of illegal copies of the Neoteric HoverTrek™ in production at AirWing's
                                 assembly facility in Russia:

2015:

12 Nov. 2015           AirWing continues to commit industrial/economic espionage and intellectual property theft against Neoteric by manufacturing
                              counterfeit copies of the Neoteric HoverTrek™. In addition, AirWing is using material copyrighted by Neoteric
                              to illegally market their pirated hovercraft as Neoteric products, evidenced by this video posted recently on YouTube …

                              AirWing has marketed their counterfeit hovercraft as the "Niaterek", the "AirWing/Neoteric" and most blatantly as the
                              trademarked "Neoteric HoverTrek". In a court action against them, AirWing directly admitted to committing intellectual
                              property theft, saying that they used these names because they would attract more customers who would associate
                              them with "the famous American manufacturer."