1 Megan Fouty FILED

Glowforge Inc. 2023 OCT 31 02:24 PM

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1938 Occidental Ave S, #C KING COUNTY
3 Seattle, WA 98134 SUPERIOR COURT CLERK
T: (855) 569-4878 E-FILED
4 E: [Link]@[Link] CASE #: 23-2-21287-8 SEA
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7 SUPERIOR COURT OF WASHINGTON

8 COUNTY OF KING
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GLOWFORGE INC., Case No.: ___________________
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Plaintiff,
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vs. COMPLAINT FOR DAMAGES,
13 INJUNCTIVE RELIEF, AND OTHER
14 JONATHAN GLEICH, individually and on RELIEF
behalf of his marital community,
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Defendant
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19 COMES NOW plaintiff, GLOWFORGE INC., and files this Complaint against

20 defendant, JONATHAN GLEICH, and for its causes of action would show the following:
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I. PARTIES, JURISDICTION, AND VENUE
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1.1. Plaintiff Glowforge Inc. (“Glowforge”) is a Delaware corporation with its
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principal place of business in Seattle, King County, Washington.

25 1.2. Defendant Jonathan Gleich ("Gleich") is an individual and member of a

26 marital community with residence in Nevada, but he has had purposeful minimum
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COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF, AND OTHER RELIEF - 1
 1 contacts with Washington, and this Complaint states causes of action and injuries
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arising from those contacts.
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1.3. This Court has jurisdiction over all causes of action stated in this Complaint,
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including under the provisions of chapter 7.40 RCW.
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6 1.4. Venue is proper because many of the events giving rise to this action

7 occurred in King County, Washington, and because Defendant has done and continues
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to do business in King County. RCW 4.12.020(3).
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II. FACTS
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2.1 Glowforge is a privately-held startup technology and manufacturing
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12 company. Glowforge designs and manufactures 3D laser printers and related products

13 and has had its principal place of business in Seattle since its incorporation in
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2014. Glowforge’s 3D laser printer products include the “Pro” and “Plus” model.
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2.2 Gleich is an individual and on information and belief is a member of a
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marital community who has become an unauthorized dealer of numerous previously-
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18 owned Glowforge Pro and Plus model printers. On information and belief, Gleich’s

19 business model is to misinform Glowforge customers and prospects that Glowforge’s

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products are unsafe, or that they have a factory defect, and then convinces people to
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sell him their units at a low price, sends them to Glowforge to be repaired or exchanged,
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and then resells them for a higher price. Gleich’s assertions regarding Glowforge’s
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24 products are knowingly false.

25 2.3 On information and belief, Glowforge has no records of Gleich ever having
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purchased a Glowforge machine from Glowforge.
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COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF, AND OTHER RELIEF - 2
 1 2.4 Gleich holds himself out to be a Glowforge activist, but he has no affiliation
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with Glowforge, he has no information, credentials, or partnership with Glowforge that
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would inform his statements, and his activism disseminates false claims that Glowforge
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products are “hazardous” and are associated with “potentially life-threatening issues” in
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6 order to garnish business for himself and appear to be an expert.

7 2.5 Gleich has posted numerous false allegations about Glowforge and its
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products on social media. The following are but two examples.
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2.5.1. In an October 2022 post on Facebook, Gleich falsely accused
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Glowforge of selling products with a “DANGEROUS high voltage factory defect.” This
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12 post is inaccurate and misleading, and generated numerous negative responses from

13 those relying on the false information, including inquiring whether Glowforge would
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issue a recall and reporting that the issue had been raised to the UK’s British Standards
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Institution, and has resulted in up to 12 false claims, citing the falsehoods described in
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this complaint and others Gleich has promulgated, through the Attorney General’s
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18 Office or other government agencies.

19 2.5.2. In a January 2023 post on Facebook, Gleich targeted Glowforge’s

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customers and prospects with false information that machines sold as new could be
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identified as actually refurbished by checking for a “metal strip under the glowforge that
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is held by 8 Phillips head screws, are (sic) the ones on the ends marked ‘red.’” This is
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24 patently false; new units that Glowforge produces have red markings on the screws.

25 2.6 While all of the claims through government agencies have been reviewed
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and dismissed or closed without investigation, Gleich’s false assertions about Glowforge
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and its products have caused Glowforge’s customers and prospects to decide to not
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COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF, AND OTHER RELIEF - 3
 1 purchase from Glowforge, to purchase from Glowforge’s competitors (including Gleich
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himself), and further disseminate the false assertions. Gleich has interfered with
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Glowforge’s business expectancy and taken time and resources away from Glowforge
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business.
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6 III. TORTIOUS INTERFERENCE WITH CONTRACT, BUSINESS

RELATIONSHIPS, AND BUSINESS EXPECTANCIES
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3.1 Glowforge realleages the allegations of all preceding paragraphs.
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9 3.2 At the time of the conduct at issue, Glowforge was a party to valid

10 contracts with customers.

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3.3 At the time of the conduct at issue, Glowforge had relationships and
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business expectancies with customers and prospects with the probability of future
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economic benefit for Glowforge.
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15 3.4 Gleich knew of the nature and existence of those contracts, business

16 relationships, and/or expectancies.

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3.5 Gleich intentionally and/or negligently interfered with Glowforge’s
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contracts, business relationships, and/or expectancies. Gleich intentionally induced or
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caused Glowforge’s customers to breach contracts with Glowforge.
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21 3.6 Gleich's interference was for an improper purpose or made by improper

22 means or both.
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3.7 Gleich's conduct in interfering with Glowforge’s contracts, business
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relationships, and/or expectancies was a proximate cause of damages to Glowforge.
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IV. DEFAMATION
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27 4.1 Glowforge realleages the allegations of all preceding paragraphs.

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COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF, AND OTHER RELIEF - 4
 1 4.2 Gleich published to third parties, including Glowforge’s customers and
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prospects, false statements about Glowforge claiming, among other things, that
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Glowforge’s products have a “DANGEROUS high voltage factory defect” and that
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Glowforge sells “refurbished” products advertised as “new” products.
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6 4.3 At the time that Gleich published these false statements to third parties, he

7 knew or should have known they were false.

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4.4 Gleich’s publication of the false statements was for an improper purpose
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or used improper means or both.
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4.5 The publication of false statements by Gleich about Glowforge was
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12 defamatory and was a proximate cause of damages to Glowforge.

13 V. INJUNCTIVE RELIEF
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5.1 Glowforge realleages the allegations of all preceding paragraphs.
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5.2 Gleich’s tortious conduct, as alleged above, has injured and continues to
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injure both Glowforge and its customers and prospects.
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18 5.3 Gleich's tortious conduct, as alleged above, has caused and continues to

19 cause irreparable harm to Glowforge’s reputation and goodwill in the 3D laser printer
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business community.
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5.4 Glowforge is entitled to have Gleich’s tortious conduct enjoined by a
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Temporary Restraining Order, a Preliminary Injunction, and/or a Permanent Injunction.
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24 VI. PRAYER FOR RELIEF

25 Plaintiff Glowforge Inc. requests that Judgment be entered against defendant

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Jonathan Gleich, individually and on behalf of his marital community, as follows:
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1. Awarding Glowforge damages in an amount to be determined.
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COMPLAINT FOR DAMAGES, INJUNCTIVE RELIEF, AND OTHER RELIEF - 5
 1 2. Awarding Glowforge its costs and attorneys' fees incurred in this
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action, including but not limited to statutory costs.
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3. Awarding injunctive relief restraining and enjoining Gleich from the
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conduct complained of in this action.
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6 4. Awarding Glowforge any additional or further relief which the Court

7 finds equitable or just.

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Dated this _31st_ day of October, 2023.
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/s/ Megan Fouty
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12 Megan Fouty, WSBA No. 41812

General Counsel, Glowforge Inc.
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