UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF OHIO
Inzer Advance Designs, Inc. :
124 W. Tyler St. : CIVIL CASE NO. 25-171
Longview, TX 75606 Plaintiff, :
:
v. : AMICUS CURIAE
:
April Mathis d/b/a Mathis Enterprises :
1850 Union Hill Rd. : DEFENDANT SUPPORTED
Peebles, OH 45660 Defendant. :
JUDICIAL NOTICE REGARDING CM/ECF STATUS, SERVICE OF
FILINGS, POTENTIAL AMICUS BRIEF DEFICIENCY, AND
REDUNDANT DUPLICATES CONCURRENT WITH MOTION PROPER ON
CM/ECF AND AMICUS BRIEF IN SUPPORT OF DEFENDANT, APRIL MATHIS
COMES NOW, Gordon Wayne Watts, pro se amicus curiae, and respectfully submits this Judicial Notice and Concurrent Motions in support of Defendant April Mathis. The undersigned is not a lawyer and proceeds pro se / pro per.
JUDICIAL NOTICE
1. CM/ECF Rejection: The undersigned gives judicial notice that his request for NextGen CM/ECF electronic filing registration (Account No. 2956898, Transaction ID 37600, submitted 06/26/2025 16:16:55 CDT) was rejected, as notified via email on 06/27/2025 (Exhibit-A), due to the requirement of judicial authorization for pro se litigants, which was not identified for Case No. 25-171.
2. Service of Filings: The undersigned gives judicial notice that all parties and the Court were served by (a) postal mail (Exhibit-B) on June 26, 2025, to 100 East Fifth Street, Cincinnati, OH 45202 , and Judge Chambers (Exhibit-C), (b) email on June 27, 2025, at 12:25 PM and 2:48 PM EDT to addresses including Clerks_Office@ohsd.uscourts.gov and AMathis01@gmail.com (Exhibit-D), and (c) public posting on the undersigned’s web-ring GordonWatts.com, GordonWayneWatts.com, and powerlifting communities, as detailed in the Certificate of Service (Exhibit-E). On Monday, June 30, 2025 at 12:23 PM EDT, the clerk's office acknowledged Watts' filing by email, and replied that “Please be advised that
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the clerk’s office does not accept filings by email,” inviting Amicus, Watts to submit his filings “in writing, via mail or hand-delivery, to any of the three seats of Court.” (Exhibit F) The undersigned will do so, while including email copy as a courtesy, even if not required.
3. Oversight on Amicus Motion: The undersigned gives judicial notice that his amicus brief, filed via mail on June 26, 2025, lacked an explicit and separate motion for leave, due to a misunderstanding of Local Rule 7.1.1(a). The undersigned interpreted the rule’s allowance of disclosures for amici as implicit permission to file, omitting a formal motion.
4. Clerk Inconsistencies: The undersigned gives judicial notice that two different clerks provided conflicting information: the Cincinnati clerk (513-564-7500) on Friday, June 20, 2025, at 12:50 PM EDT, stated amicus briefs are prohibited period and “the only way you to file is if you're a party to the case,” while a different clerk (614-719-3000), in a follow-up phone call on Friday, June 27, 2025, at 3:24 PM EDT, in the Columbus, Ohio branch, indicated a judge would decide with or without consent. This confusion contributed to the undersigned’s error, though ignorance of the law is no excuse.
5. Redundant Duplicates: The undersigned gives judicial notice that two copies each of the disclosure statement and amicus brief were mailed on June 26, 2025, to the Clerk and Judge Chambers, totaling four copies. The undersigned suggests, in the interest of judicial efficiency (e.g., SD Ohio Local Rule 1.1 promoting streamlined proceedings), that only one copy of each be filed, with duplicates disregarded.
MOTIONS
6. Motion to Disregard CM/ECF Request: The undersigned respectfully moves the Court to disregard his CM/ECF registration request (Account No. 2956898), as it was submitted to expedite filing but is unnecessary if print copies are accepted. The undersigned relies on mailed submissions and seeks no further electronic filing privilege without judicial authorization.
7. Motion proper for Acceptance of Amicus Brief: The undersigned respectfully moves
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the Court to accept his amicus brief filed on June 26, 2025, in support of Defendant April Mathis, and – for arguments in support of the instant motion – to incorporate all support within the “four corners” of the brief (pp. 1-9) as if fully set forth herein. The undersigned notes that if the Court sua sponte infers a motion from the amicus brief and accepts it, then this motion may be moot. The amicus brief addresses patent validity (35 U.S.C. §§ 101, 102, 103, 112), case law (Diamond v. Chakrabarty, 447 U.S. 303 (1980); KSR Int’l Co. v. Teleflex Inc., 550 U.S. 398 (2007)), and Mathis’s defenses (pp. 3-9), supported by the undersigned’s experience (Watts's Amicus, pp. 1-2, Exhibits D-I) and Mathis’s need (pp. 2-3).
DISCUSSION
The undersigned is informed that Plaintiff John Inzer has moved the Court to (a) strike Defendant’s response, (b) dismiss the case, and/or (c) refer the case for mediation/arbitration, per the clerk’s recollection on June 27, 2025 – and as confirmed by a quick scan of the last entry on the docket. However, both parties have publicly requested a jury trial, a matter of record. The undersigned suggests: (a) Summary judgment may not be viable due to the jury trial demand, per Fed. R. Civ. P. 56, unless both parties stipulate. (b) The Court accept this filing and make it available to the jury, enhancing their understanding of patent issues. (c) The Court encourage settlement if both parties agree. As neither party has responded to the undersigned’s consent request , e.g., his email dated 06/27/2025, 2:49 PM EDT (Exhibit-G), the undersigned requests the Court direct Inzer and Mathis to respond with a yes/no answer to the request for consent and address the legal points raised (pp. 3-9).
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CERTIFICATE OF SERVICE
I certify that on this 2ND day of July 2025 the foregoing document (“JUDICIAL NOTICE REGARDING CM/ECF STATUS, SERVICE OF FILINGS, POTENTIAL AMICUS BRIEF DEFICIENCY, AND REDUNDANT DUPLICATES CONCURRENT WITH MOTION PROPER ON CM/ECF AND AMICUS BRIEF IN SUPPORT OF DEFENDANT, APRIL MATHIS”) was served on all parties or their counsel of record through the CM/ECF system if they are registered users (if CM/ECF is available to me) and/or, if they are not, by placing a true and correct copy in the United States mail, postage prepaid – and/or via a private carrier (such as FedEx or UPS), depending on which carrier has congruent business hours – to their address of record. I further certify that I'm serving all parties and This Honourable Court by four (4) methods: (1.) USPS mail and/or via a private carrier (such as FedEx or UPS), depending on which carrier has congruent business hours, (2.) e-mail, (3.) CM/ECF (if possible), and via (4.) public posting on my web-ring and in prominent online powerlifting communities in alignment with the subject-matter of this lawsuit involving John Inzer and April Mathis, two prominent powerlifters known for breaking numerous world records throughout their respective careers. Service List:
United States District Court, Southern District, Office of the Clerk
Joseph P. Kinneary U.S. Courthouse, Room 121
85 Marconi Boulevard, Columbus, Ohio 43215
Phone: 614-719-3000 (Columbus) ; Phone: (513) 564-7500 (Cincinnati)
Phone: 513-564-7522 (Jury)
Office Hours: 9:00-4:00 Monday-Friday
Email: Clerks_Office@ohsd.uscourts.gov ; Email: ohsd_cinjury@ohsd.uscourts.gov
Assigned Judge: Hon. Jeffery P. Hopkins, (513) 564-7540
Courtroom Deputy: Karli Colyer, Phone: (513) 564-7541
Potter Stewart U.S. Courthouse, Room 810, 100 East Fifth Street, Cincinnati, OH 45202
Inzer Advance Designs, Inc., 124 W. Tyler St., Longview, TX 75606
Dinsmore & Shohl LLP, 255 E. Fifth St. # 1900, Cincinnati, OH 45202
(513) 977-8246 phone / (513) 977-8141 fax / Oleg.Khariton@dinsmore.com
Mark D. Schneider (Michigan Bar No. P55253, pending admission pro hac vice)
Dinsmore & Shohl LLP, 755 W. Big Beaver Rd. # 1900, Troy, MI 48084
(248) 203-1615 phone / (248) 647-5210 fax / Mark.Schneider@Dinsmore.com
April Mathis d/b/a Mathis Enterprises / AMathis01@gmail.com
1850 Union Hill Rd., Peebles, OH 45660
Dated: Wednesday, July 02, 2025 Respectfully Submitted,
/s/ _Gordon Wayne Watts_ (electronic) /s/ ________________________ (physical)
Gordon Wayne Watts, Amicus Curiae, 2046 Pleasant Acre Drive, Plant City, FL 33566-7511 Official URL's: https://ContractWithAmerica2.com ; Gordon@ContractWithAmerica2.com
http://GordonWatts.com / http://GordonWayneWatts.com
(863) 687-6141 phone / (863) 688-9880 text / Gww1210@GMail.com
LAYMAN OF THE LAW: Gordon Wayne Watts, PRO SE / PRO PER
[*] Mr. Watts, acting as his own counsel, is not a lawyer.
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INDEX TO THE EXHIBITS
Instrument Docket / Tab#
CM/ECF Rejection Exhibit-A
Service of Filings (Postal Mail) Exhibit-B
Service of Filings (Court and Judge's Chambers) Exhibit-C
Service of Filings (email) Exhibit-D
Public Posting of filings Exhibit-E
Clerk's acknowledgment of Amicus's email filing Exhibit-F
Consent request sent to parties by email Exhibit-G
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