In Hazelquist v. Guchi Moochie Tackle Company, the U.S. Court of Appeals for the Federal Circuit held that an individual's Ch. 7 discharge did not operate as an injunction stopping a plaintiff from asserting a claim for a debt incurred after the date of discharge. On February 12, 2004, plaintiff Albert Hazelquist filed a complaint against defendants Ken Yamaguchi and Guchi Moochie Tackle Company, operated and owned solely by Mr. Yamaguchi, for infringement of a patent in the U.S. District Court for the Western District of Washington. On September 13, 2004, the District Court granted Hazelquist's motion for default judgment against corporate defendant Guchi Moochie. On September 28, 2004, Mr. Yamaguchi, individually, filed for Chapter 7 bankruptcy and the patent litigation was stayed pursuant to Section 362 of the Bankruptcy Code against him. The District Court that originally granted the motion for default judgment then denied the motion against the company because a judgement against Guchi Moochie would be "in substance" a judgement against Mr. Yamaguchi, which was stayed by the bankruptcy filing. On December 29, 2004, Mr. Yamaguchi obtained a discharge of his debts and the stay was lifted on April 15, 2005. On April 29, 2005, the District Court ordered Hazelquist to show cause why the case should not be dismissed. Hazelquist alleged that after the bankruptcy discharge, Mr. Yamaguchi continued to engage in infringing activities through the operator of his sole proprietorship. The District Court, citing Sect. 524(a) of the Bankruptcy Code which states that the discharge of a debtor's liabilities in bankruptcy "operates...against the commencement or continuation of an action...to collect, recover or offset any such debt as a personal liability of the debtor," dismissed Hazelquist's claims. The Court of Appeals found that a discharge in bankruptcy does not act as an injunction against a plaintiff asserting a claim for a debt incurred, or a cause of action that arose, after the date of bankruptcy discharge. The Court also noted that case law clearly states that each act of patent infringement gives rise to a separate cause of action. Thus, to the extent that Mr. Yamaguchi has engaged in infringing activities since the discharge, each of those activities gives rise to a cause of action that was not enjoined by Sect. 524 of the Bankruptcy Code. Thus, the plaintiff could pursue his claim against Mr. Yamaguchi even though the suit started before he filed bankruptcy. A different result would have occurred if Mr. Yamaguchi had stopped his payment infringing behavior once he filed bankruptcy. Ray