Complaint-Christian Louboutin v. Yang, et al. (S.D.N.Y.

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Complaint-Christian Louboutin v. Yang, et al. (S.D.N.Y.
Case 1:10-cv-05475-BSJ
Document 1
Filed 07/19/2010
Page
1 of 38
JUDGE JONES,k.,,
Harley I. Lewin
McCarter & English, LLP
245 Park Avenue, 27th Floor
New York, NY 10167
Tel: (212) 609-6800
Fax: (212) 609-6921
.....---------Wri
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\R____a". . .,
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XL 1 g Z°1/
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
CASHIERS
CHRISTIAN LOUBOUTIN S.A. and
CHRISTIAN LOUBOUTIN,
Plaintiffs,
CIVIL ACTION NO.:
V.
COMPLAINT AND
KUO-HSIN YANG a/k/a SAM YANG a/k/a
STAN YANG; KIMERA INTERNATIONAL,:
INC. a/k/a LILIANA SHOES a/ka/ LILIANA
f/ka/ LILIANA FOOTWEAR; and LILIANA
a/k/a LILIANA SHOES f/k/a LILIANA
FOOTWEAR; and JOHN AND JANE DOES A-:
Z (UNIDENTIFIED); and XYZ COMPANIES 1-:
10
JURY DEMAND
(UNIDENTIFIED),
Defendants.
X
Plaintiffs, Christian Louboutin S.A. and Christian Louboutin (collectively, "Plaintiffs")
file this
Complaint and state as follows:
JURISDICTION AND VENUE
This is
1.
trademark
an
action for
injunctive
relief and
damages for trademark infringement,
counterfeiting, trademark dilution, unfair competition
arising under
Trademark
MEI 10032901v.1
the Trademark Act of 1946, 15 U.S.C.
Counterfeiting
Act of
and false
1051,
designation
et seq., as
of
amended
origin
by
the
1984, Public Law 98-473 (the "Lanham Act"), and for
Case 1:10-cv-05475-BSJ
trademark
Document 1
infringement, trademark dilution,
Filed 07/19/2010
and unfair
Page
competition under the
2 of 38
laws of the State of
California.
This Court has
2.
original jurisdiction
over
1116 and 1121. This Court has
1331, 1332 and 1338(a) and (b); and 15 U.S.C.
pursuant
the
to
principles
claims for trademark
supplemental jurisdiction
of
this action pursuant to 28 U.S.C.
1367
and 28 U.S.C.
infringement, trademark dilution, and
unfair
competition
jurisdiction
over
Plaintiffs'
under the laws of
the State of New York.
This Court has
3.
personal jurisdiction over Defendants
in that
they transact
business
in the State of New York and that Defendants' tortious conduct outside the State of New York
has caused
has its
injury
to
Plaintiff and Plaintiff s property in the State of New York, where Plaintiff
principal place of business in the United States.
Venue is proper in this district under 28 U.S.C.
4.
personal jurisdiction over Defendants
1391(c)
because this Court has
in this judicial district.
THE PARTIES
Plaintiff Christian Louboutin S.A. is
5.
the laws of France,
Paris,
West
France 75001
having
its
principal place
("Louboutin S.A.").
a
corporation, organized
of business at 19
de
rue
Plaintiff also maintains
a
and
existing
under
Jean-Jacques Rousseau,
showroom and office at 306
38th Street, New York, NY, USA.
Plaintiff Christian Louboutin is
6.
France with
Paragraphs
an
address at 1
5 and 6
MEI 10032901v.I
are
rue
an
Volney, Paris,
hereinafter identified
individual and
France 75002.
a
citizen of the country of
The Plaintiffs identified in
collectively as "Plaintiffs".
Document 1
Case 1:10-cv-05475-BSJ
Yang is
an
individual
residing
Mr.
Upon information and belief,
at 1204 John Reed
Yang
is the
owner
Li liana Shoes and Li liana, and
address and
an
formerly
known
conducting business
as
Yang a/k/a
Court, City of Industry, California 91745.
of Defendant Kimera International, Inc.
Liliana Footwear, is
at 17005
3 of 38
Sam
Upon information and belief, Defendant Kimera International, Inc.,
8.
having
Page
Upon information and belief, Defendant Kuo-Hsin Yang a/k/a
7.
Stan
Filed 07/19/2010
a
also known
California
as
corporation
Evergreen Place, Suite A, City of Industry,
California 91745.
Upon information and belief,
9.
known
Li liana Footwear, is
as
Kimera International, Inc. to
an
Li liana, also known
unincorporated
as
Li liana Shoes, and
fictitious
unregistered
and
import and distribute footwear, having
an
entity
formerly
used
by
address at 827 Lawson
Street, City of Industry, California 91748 and 17005 Evergreen Place, Suite A, City of Industry,
California 91745. The
referred to
as
parties identified
are
various individuals and entities
State of North Carolina and
through
California and
are
hereinafter
subject
to
amended to include the
(each
a
the
are
jurisdiction
are
name or names
"Doe" and
as
collectively
various JOHN DOES and
conducting business
at
various locations in the
mark for further distribution and sale
the United States, and
DOES and JANE DOES defendants
MEI 10032901v.I
9
elsewhere, including those individuals who purchased Defendants'
goods bearing Plaintiffs'
throughout
available
7
Upon information and belief, Defendants identified
JANE DOES
and
paragraphs
the "Li liana Defendants".
10.
counterfeit
in
this District
present in and/or doing business in the State of
of this Court.
not
through
presently
The identities of the various JOHN
known and the
Complaint
herein will be
of these individuals when such information becomes
collectively "Does").
Document 1
Case 1:10-cv-05475-BSJ
Upon information
11.
agents, servants, and employees
California and elsewhere,
bearing Plaintiffs' mark
United States, and
are
and belief, Defendants, the XYZ COMPANIES,
are
conducting
those entities that
including
purchased
for further distribution and sale
herein will be amended, if
appropriate,
Defendants' counterfeit
through this
District and
are not
goods
throughout the
presently
to
known and the
to include the names of the actual XYZ
becomes available
The
collectively, "Defendant Companies").
hereinafter
their
present in and/or doing business in the State of California and subject
Company Defendants when such information
and
through
business at various locations in the State of
the jurisdiction of this Court. The identities of such Defendants
Complaint
Page 4 of 38
Filed 07/19/2010
parties
(each
identified in
a
"Defendant
paragraphs
7
Company"
through
11
are
collectively referred to as the "Defendants".
BACKGROUND
PLAINTIFFS' TRADEMARKS AND PRODUCTS
In
12.
and
the first Christian Louboutin
opened
Louboutin
1991, Mr. Louboutin created the Christian Louboutin brand of women's shoes,
began using
a
lacquered
boutique
red sole
on
in Paris, France.
Beginning
in 1992, Mr.
the bottom of the Christian Louboutin brand
women's shoes.
Plaintiffs have
13.
owned
by Plaintiffs
recognizable
$3, 100
per
lacquered
sole and other trademarks
the red sole have become the most
synonomous with
The red sole and the
glamour, luxury and style.
sought-after
name
Plaintiffs' shoes
are
and
Christian
instantly
based upon their distinctive red sole. Plaintiffs' shoes cost in the range of $400 to
pair.
MEI 1003290Iv.1
bearing
brand of shoes in the U.S. and abroad.
are
recognizable
used the red
in connection with Plaintiffs' shoes since 1992.
Plaintiffs' shoes
14.
Louboutin
continuously
Document 1
Case 1:10-cv-05475-BSJ
Plaintiffs' shoes
15.
are worn
by
Filed 07/19/2010
numerous
famous
Page
5 of 38
celebrities, fashion designers, and
socialites, including Elizabeth Taylor, Oprah Winfrey, Halle Berry, Angelina Jo lie, Salma
Hayek,
Jennifer
Lopez, Sarah Jessica Parker, Diane
Monaco. Plaintiffs' shoes have been
"celebrity
shoe of choice".
Prestigious
as a
symbol
17.
"celebrity favorite shoe"
or
the
consistently topped
the
Brand Status Index and Plaintiffs' shoes have been named the
celebrity
in the
use
of the red sole has
luxury goods
market.
expanded
its
renown
The red sole trademark is
and
highly
of quality and status.
Mr. Louboutin is the
licensee of the entire
which is
the
Women's Shoes for each of the past three years.
enabled it to achieve
visible
commonly referred to as
Plaintiffs' continuous and broad
16.
Furstenberg, and Princess Caroline of
Shoes of Christian Louboutin S.A. have
Luxury Institute's annual Luxury
Most
von
owner
and Louboutin S.A. is the exclusive United States
right, title and interest in and to the Federally registered red
sole trademark,
the subject of U.S. Registration No. 3, 361, 597 (the "Red Sole Mark") and the trademark
CHRISTIAN LOUBOUTIN, among others, in connection with "women's
high fashion designer
footwear, in Class 25 (the "Louboutin Products") (collectively, "Plaintiffs' Marks"). A copy of
the Certificate of Registration for the Red Sole Mark is annexed hereto
of the Red Sole Mark
as
registered is shown below:
it
r
401;
MEI 10032901v.1
as
Exhibit A, and
a
copy
Document 1
Case 1:10-cv-05475-BSJ
18.
uncancelled.
validity
The
registration
The
registration
set
forth in Exhibit A is valid,
in connection with the
registration
ownership
rights
named therein, and
goods
subsisting, unrevoked,
facie
and
evidence of its
to use the Red Sole Mark in
commercially related goods.
The
in the Red Sole Mark.
Plaintiffs' Marks have achieved
of many years of continuous
use
of photographs of a
promotion
representative sample
annexed hereto
as
secondary meaning
in commerce,
usage and substantial investment in
are
right
6 of 38
of the Red Sole Mark constitutes constructive notice to Defendants of Plaintiffs'
of and exclusive
19.
Page
of the Red Sole Mark constitutes prima
and conclusive evidence of Plaintiffs' exclusive
commerce
Mark
Filed 07/19/2010
Exhibit B. A
enormous
in the
marketplace by
unsolicited press coverage,
of Louboutin Products
bearing the
of authentic Louboutin Products
photograph
of a
genuine
celebrity
marks.
bearing
virtue
Copies
the Red Sole
Louboutin Product is shown
immediately below:
Plaintiffs maintain strict
20.
Plaintiffs
quality
control standards for all Louboutin Products.
inspect and approve all genuine Louboutin Products prior to
All
21.
genuine
Louboutin Products
are
distributed
distribution and sale.
through
a
worldwide network of
authorized Louboutin dealers.
To
22.
promoting
date, Plaintiffs have invested significant time and effort advertising and
the Louboutin Products and the Red Sole Mark in the United States and
the World, and
MEI 10032901v.1
display
the Red Sole Mark in their
advertising
and
promotional
throughout
materials.
Document 1
Case 1:10-cv-05475-BSJ
Plaintiffs' shoes appear
numerous
wearing
magazines.
brand. As
with
models in
fashion shows and in fashion
bearing
7 of 38
spreads
are
photographed
the Red Sole Mark, constitutes unsolicited
widespread recognition
featured in
advertising
of the Red Sole Mark and the Christian Louboutin
result, Plaintiffs have enjoyed millions of dollars in sales of the Louboutin Products.
a
public,
numerous
Page
This, together with the legions of celebrities who
the Louboutin Products
that has resulted in
The
on
Filed 07/19/2010
customers, and the
products
of
luxury goods industry
Sole Mark
including
Plaintiffs' Marks,
United States but
come to
originate
reliability,
and
come
are
the greater
famous not
protection
only
within the
afforded marks with
such international distinction under both United States Law and International Treaties, such
the Paris Convention and the Trade-Related
Agreement"), both of which have
Aspects of Intellectual Property Rights (the
been entered into
to
with Plaintiffs.
its Red Sole Mark,
throughout the World, entitling it to
associate the Red Sole Mark
and
exceptional materials, style, workmanship
recognize that products bearing the Red
23.
have
by the United
as
"TRIPS
States.
DEFENDANTS' CONDUCT
Defendants have
24.
and
knowingly
willfully manufactured, imported, distributed,
offered for sale, and sold various counterfeit versions of the Louboutin Products, to wit: shoes
bearing the Red Sole Mark (the "Counterfeit Products")
Upon information and belief,
25.
the Liliana Defendants at all times relevant,
manufacture, import, advertise, promote, distribute and/or sell Counterfeit Products
resellers and
directly
Amazon.com and
listings
on
to
individual
flyjane.net.
Copies
of
a
via internet websites
representative sample
including,
third party
inter alia
of the Liliana Defendants'
Amazon.com, flyjane.net, polyvore.com and bootexplosion.com, offering the
Counterfeit Products for sale
MEI 10032901v.1
consumers
to
are
attached hereto
as
Exhibit C.
Document 1
Case 1:10-cv-05475-BSJ
a/k/a Scott Chan a/k/a
Carolina, who
was
(collectively,
looksgreat4ever,
an
doing business under
the
"E Shoe
www.eshoewarehouse.com
such
eBay
as
under the
Warehouse").
(the
name
individual and
name
E Shoe
a
Chantarungrsi
resident of the State of North
E Shoe Warehouse
as
Warehouse, through
"E Shoe Warehouse web
8 of 38
Page
The Li liana Defendants have sold Counterfeit Products to Suebsak
26.
Inc.
Filed 07/19/2010
site")
E Shoe Warehouse and under the
as
use
well
name
well
as
of
an
as on
S.G.
Internet
public
one
site,
auctions
looksgreat4ever,
the Counterfeit Products for sale. A copy of one of the Counterfeit Products obtained
Warehouse from
Trading,
by
offered
E Shoe
of the Defendants is shown below:
7arxotr than nom& to hogh
run
people (*ate select pow .ozr cortyntly,
lutttri
owl,
27.
On December
Shoe Ware House.
E Shoe
During
18, 2009, Plaintiffs executed
an ex
parte seizure order against E
that raid, Plaintiffs seized Counterfeit Products sold
by Defendants to
Warehouse, together with documents evidencing Defendants' sale of Counterfeit
Products to E Shoe Warehouse.
28.
least
name
one
style
Defendants, in
of shoe
"NITOINIMOI."
a
designed
further effort to increase
and
Plaintiffs'
produced by Plaintiffs,
genuine
have also
copied
which Plaintiffs sell under the
NITOINIMOI shoe appears below,
depiction of Defendants' counterfeit copies of this shoe:
MEI 10032901v.1
public confusion,
together
at
style
with
a
Document 1
Case 1:10-cv-05475-BSJ
Filed 07/19/2010
Page
9 of 38
1:
N
E Shoe Warehouse
Plaintiffs' Authentic "NITOINIMOI" Shoe
Counterfeit Product
Li liana Defendants'
Counterfeit Product
Upon information and belief, Defendants intentionally
29.
and
knowingly infringe the
Red Sole Mark and allude to Plaintiffs and the Louboutin Products in
Counterfeit Products in
an
effort to trade upon Plaintiffs'
advertising
their
will and the cachet associated
good
with Plaintiffs' Products.
The Counterfeit Products
30.
manufacture, inspect,
Products for sale
for sale,
or
sell
license from
or
or
package
are not
genuine
Louboutin Products. Plaintiffs did not
the Counterfeit Products, and did not approve the Counterfeit
distribution. Defendants
products bearing
are not
authorized
the Red Sole Mark.
to
Defendants, without authorization
or
Plaintiffs, have used the Red Sole Mark in connection with Defendants'
advertisement, offer for sale, and sale of the Counterfeit Products.
ME 1 10032901v.1
manufacture, distribute, offer
Document 1
Case 1:10-cv-05475-BSJ
they
sell
relevant, Defendants
At all times
31.
are not
Filed 07/19/2010
were
and
10 of 38
that the Counterfeit Products
genuine Louboutin Products.
The Li liana Defendants conduct business
32.
are aware
Page
using
aliases
including
Li liana, Li liana
Shoes and Li liana Footwear. Since at least 2006, the Li liana Defendants have been
the sale of shoes via the Internet.
Upon
engaged
in
information and belief, at all times relevant herein, the
Li liana Defendants have used the domain
<www.lilianashoes.com> to host the email
name
address, [email protected], which the Li liana Defendants'
use
to
do their business in
Counterfeit Products.
At all times relevant
33.
wholesale the Counterfeit Products
herein, the Liliana Defendants have regularly sold
throughout
the United States,
including
in
particular
at
in this
District.
Upon information
34.
Defendants have in their
which
they
are
offering
and belief,
possession
as
of the date of this
Complaint,
the Li liana
Counterfeit Products, the amount of which is unknown,
for sale and for which
they
are
accepting special
orders from wholesale
buyers.
35.
and
Upon information
belief, the Li liana Defendants
Counterfeit Products at 17005 Evergreen Place, Suite A,
Lawson
are
storing their inventory
City of Industry, California 91745,
of
827
Street, City of Industry, California 91748, and/or other locations under the Liliana
Defendants' control.
36.
Defendants'
use
marketing, distribution, offering
confusion, mistake,
MEI 10032901v.1
or
to
of Plaintiffs' Marks
for
deceive.
on or
in connection with the
advertising,
sale, and sale of the Counterfeit Products is likely
to cause
Document 1
Case 1:10-cv-05475-BSJ
Defendants'
37.
use
of the Red Sole Mark
marketing, distribution, offering
irreparable
Filed 07/19/2010
11 of 38
Page
in connection with the
on or
advertising,
for sale, and sale of the Counterfeit Products is
causing
harm to Plaintiffs.
COUNT ONE
FEDERAL TRADEMARK COUNTERFEITING AND INFRINGEMENT
(15 U.S.C. 1114)
38.
of this
Plaintiffs repeat and
Complaint as
39.
re-allege
the
the United States and
goodwill
throughout
arbitrary, and
the world
have become
are
of the business associated with it in
of great and incalculable value,
universally associated
in the
products of the very highest quality and reputation finding their source
40.
Upon information and belief,
having knowledge
foregoing paragraphs
if fully set forth herein.
Plaintiffs' Red Sole Mark and the
distinctive and
of each of the
allegations
a
prior rights
mark which is
highly
mind with the
in Plaintiffs
without Plaintiffs' authorization
of Plaintiffs' well-known and
that Defendants' Counterfeit Products bear
public
are
in the Red Sole
confusingly
or
consent, and
Mark, and the fact
similar to the Red Sole
the Counterfeit
Mark, Defendants have manufactured, distributed, offered for sale and/or sold
Products to the
consuming public in direct competition with Plaintiffs'
Products, in or affecting interstate
41.
Defendants'
use
commerce.
of copies
and
or
simulations of the Red Sole Mark is
deception
and is
causing confusion, mistake
origin
of the Counterfeit Products, and is
among the
likely
to
likely
deceive the
public
are
into
to cause
to
the
believing
the
general purchasing public
Counterfeit Products being sold by Defendants originate from,
MEI 10032901v.1
sale of genuine Louboutin
as
associated with,
or
are
Document 1
Case 1:10-cv-05475-BSJ
otherwise authorized
goodwill
by Plaintiffs, all
to the
Filed 07/19/2010
12 of 38
Page
damage and detriment of Plaintiffs' reputations,
and sales.
Plaintiffs have
42.
no
adequate remedy
Plaintiffs will continue to suffer
enjoined,
at law
irreparable
and, if Defendants' activities
harm and
injury
to
their
are
not
and
goodwill
reputations.
COUNT TWO
FALSE DESIGNATION OF ORIGIN AND UNFAIR COMPETITION
(15 U.S.C. 1125(a))
Plaintiffs repeat and
43.
of this
Complaint as
such,
nature
are
allegations
of each of the
cause
as
to
the
by Defendants
the Louboutin Products sold and offered for sale
confusion to the
general pubic
the
are
of the
same
by Plaintiffs and,
as
general purchasing public.
By misappropriating and using
falsely describe
foregoing paragraphs
if fully set forth herein.
and type
likely to
45.
a
the
The Counterfeit Products sold and offered for sale
44.
general
re-allege
origin
likelihood of confusion among ultimate
the Red Sole Mark, Defendants
and
source
purchasers
as
misrepresent
and
of the Counterfeit Products and create
to
both the
source
and
sponsorship
of
such merchandise.
Defendants' unlawful, unauthorized and unlicensed manufacture, distribution,
46.
offer
sale, and/or sale of the Counterfeit Products
for
misrepresentations
Plaintiffs, all
47.
U.S.C.
to
Defendants'
were
express
created, authorized
or
and
implied
approved by
profit and Plaintiffs' great damage and injury.
Defendants' aforesaid acts
1125(a),
MEI 10032901v.1
that the Counterfeit •Products
creates
in that Defendants'
use
are
in violation of
43(a) of the Lanham Act,
of the Red Sole Mark, in connection with their
15
goods
Document 1
Case 1:10-cv-05475-BSJ
and services, in interstate
commerce
Filed 07/19/2010
constitutes
a
Page
of
designation
false
13 of 38
origin
and unfair
competition.
48.
enjoined,
Plaintiffs have
no
adequate remedy
at law
irreparable
Plaintiffs will continue to suffer
and, if Defendants' activities
harm and
injury
to
their
are not
goodwill
and
reputations.
COUNT THREE
FEDERAL TRADEMARK DILUTION
(15 U.S.C. 1125 (C))
49.
of this
Plaintiffs repeat and
Complaint as
50.
the
re-allege
of each of the
allegations
foregoing paragraphs
if fully set forth herein.
Plaintiffs' Red Sole Mark is
the Lanham Act, 15 U.S.C.
1125(c) and
a
meaning
"famous mark" within the
was a
famous mark
prior
to
of
43(c) of
Defendants' conduct
as
alleged herein.
51.
Defendants' manufacture, distribution, offer for sale, and/or sale in
the Counterfeit Products is
and
was
likely to and does
done with the willful intent to trade
dilute the distinctive
on
Plaintiffs'
quality
reputations
commerce
of
of the Red Sole Mark,
and/or to
cause
dilution of
the Red Sole Mark.
52.
Defendants' unauthorized
Counterfeit Products
was
rights
under
MEI 1003290Iv.1
was
not
Defendants' aforesaid acts
43(c)
of the Red Sole Mark
done with notice and full
distribution, sale and/or offer for sale
53.
use
authorized
are
in
of the Lanham Act, 15 U.S.C.
on or
knowledge
or
licensed
knowing
1125(c).
in connection with the
that such manufacture,
by Plaintiffs.
and willful violation of Plaintiffs'
Document 1
Case 1:10-cv-05475-BSJ
Plaintiffs have
54.
no
adequate remedy
will continue to suffer
enjoined,
irreparable
Filed 07/19/2010
at law
harm and
Page
14 of 38
and, if Defendants' activities
injury
Plaintiffs'
to
are
goodwill
not
and
reputations.
COUNT FOUR
TRADEMARK INFRINGEMENT UNDER NEW YORK COMMON LAW
Plaintiffs repeat and
55.
of this
Complaint as
if fully set forth herein.
Defendants have, without authorization from Plaintiffs, used the Red Sole Mark
56.
to
reallege the allegations of each of the foregoing paragraphs
advertise, distribute, sell and offer to sell Counterfeit Products.
Defendants' acts
57.
deception to
consumers as to
as
alleged herein are likely to cause confusion, mistake,
the affiliation, connection,
Plaintiffs, and as to the origin, sponsorship,
registration for its
59.
of Defendants'
registration for its Red
infringed
Sole Mark
(i)
and continues to
with full
of Plaintiffs' federal
common
law.
conduct is intentional, malicious, and
infringe Plaintiffs federal trademark
knowledge that Plaintiffs
right to use its federal trademark, (ii) with the
confusion and mistake and to deceive, and
goods by Plaintiffs.
infringements
Red Sole Mark in violation of California
Upon information and belief, Defendants'
wanton in that Defendants
exclusive
approval
association of Defendants with
Defendants' unauthorized acts constitute direct
58.
trademark
or
or
and
owns
intention of causing
and has the
a
likelihood of
(iii) with the intention of eliminating competition
from Plaintiffs.
60.
Plaintiffs have suffered,
are
suffering,
injury for which Plaintiffs has no adequate remedy
at
and will continue to suffer
law. Plaintiffs therefore
preliminary and permanent injunction against Defendants'
MEI 10032901v.1
further
irreparable
are
entitled to
infringing conduct.
a
Case 1:10-cv-05475-BSJ
Document 1
Filed 07/19/2010
15 of 38
Page
COUNT FIVE
TRADEMARK DILUTION UNDER NEW YORK LAW
61.
of this
Plaintiffs repeat and
Complaint as
62.
and
reputation,
of each of the
allegations
Plaintiffs' Red Sole Mark is
as a
widely recognized by the general consuming public
designation of source
Defendants' acts
as
of the
goods of Plaintiffs.
alleged herein are likely to
and dilute the distinctive
quality of the
intended these acts to dilute the Red Sole Mark, and
cause
Absent
injunctive relief,
injure Plaintiffs'
Plaintiffs have
are
business and
common
no means
dilution of Plaintiffs' famous Red Sole Mark. Plaintiffs
prohibiting Defendants from continuing
injury to Plaintiffs'
business
Red Sole Mark. Defendants knew and
Defendants' acts constitute trademark dilution under New York
64.
foregoing paragraphs
if fully set forth herein.
of the State of New York
63.
the
reallege
reputation.
law.
by which to control
therefore entitled to
such acts of dilution and unfair
Defendants'
injunctive relief
competition.
COUNT SIX
UNFAIR COMPETITION UNDER NEW YORK LAW
65.
of this
Plaintiffs repeat and reallege the
Complaint as
66.
false
be
As
a
as
alleged above constitute
advertising under New York law,
impairment of the recognition of the Red
67.
of each of the
foregoing paragraphs
if fully set forth herein.
The actions of Defendants
competition and
allegations
common
law unfair
and have caused and will
Sole Mark, and diminution of the value thereof.
result of the actions of Defendants, Plaintiffs have been and will continue to
seriously and irreparably damaged unless Defendants are enjoined from
the
use
designations or representations which result in common law unfair competition
MEI 1003290Iv.1
cause
of false
with Plaintiffs.
Document 1
Case 1:10-cv-05475-BSJ
Filed 07/19/2010
16 of 38
Page
PRAYER FOR RELIEF
Wherefore, Plaintiffs pray that Defendants be cited
that Plaintiffs receive the
judgment,
following relief:
employees, attorneys,
That Defendants, their officers, agents, servants,
1.
acting for, with, by, through
persons
to appear in this case, and upon final
and restrained, at first
enjoined
under them be
or
and all
preliminarily during the pendency of this action and, thereafter, permanently:
from
a)
Mark,
or
any other mark which
deception,
product
using
or
mistake
on or
emanating
not
in any
so
manner
any of Plaintiffs'
resembles said trademark
in connection with the
from Plaintiffs,
or
not
Marks, including the Red Sole
likely
to be
as
advertising, offering
authorized
by Plaintiffs
to cause
for sale,
to
or
confusion,
sale of any
be sold in connection
with each of the Red Sole Mark;
from
b)
product
as
and for
or
from
products
approved by,
supervision
of Plaintiffs and
enabling
not
others to sell
or
pass off any
products,
or
not
Plaintiffs'
approved by
produced
Plaintiffs for sale under any of
including the Red Sole Mark;
c)
Defendants'
or
products produced by Plaintiffs,
under the control and
Plaintiffs' Marks,
passing off, inducing,
or
are
committing
any acts calculated to
those sold under the control and
connected with,
or
guaranteed by,
cause
supervision
or
purchasers
to
of Plaintiffs,
produced
believe that
or
sponsored
under the control and
supervision of Plaintiffs;
d)
Red Sole Mark and
e)
MEI 10032901v.1
from further
diluting
and
infringing
any of Plaintiffs'
Marks, including the
damaging Plaintiffs' goodwill;
from otherwise
competing unfairly with Plaintiffs
in any manner; and
Case 1:10-cv-05475-BSJ
from
of, in
any manner,
or
Filed 07/19/2010
shipping, delivering, distributing, returning
or
any mark
persons in active concert
associations
confusingly
or
otherwise
restrained and
temporarily
stocks
with them, and any banks,
participation
or
agencies
enjoined
from
Defendant that files with the Court and
Defendant's assets
having
a
authorized
by
including
the
serves
savings
and loan
or
or
otherwise, shall
secreting
any money,
of the Court, except
prior approval
upon Plaintiffs' counsel:
value of two thousand dollars
and any
which engage in the transfer of real
transferring, disposing of,
other assets of Defendants, without
or
nor
disposing
employees, attorneys,
service
property, who receive actual notice of the Court's order, by personal
be
17 of 38
similar thereto;
other financial institutions,
or
or
offered for sale, and which bear any of Plaintiffs' Marks,
That Defendants, their officers, agents, servants,
2.
Page
products or inventory not manufactured by or for Plaintiffs,
Plaintiffs to be sold
Red Sole Mark,
Document 1
($2, 000)
or
(1)
an
as
to
a
accounting of that
more, and the location and
Plaintiffs (such
identity thereof; and (2) uncontradicted documentary proof accepted by
not to be
acceptance
Defendant's
unreasonably withheld)
that
particular
in which
case
those
counterfeiting activities,
assets
particular
not
are
proceeds
of that
assets shall be released to
that Defendant.
That
3.
immediately
required
up to Plaintiffs any and all
prints, packages,
materials in the
including
Defendants be
wrappers,
upon
MEI 10032901v.I
to
deliver
and other
matter,
promotional,
under their control
bearing
any of Plaintiffs'
possession of Defendants
not
Complaint
pouches, receptacles, advertising
the Red Sole Mark, alone
or
of this
products, guarantees, circulars, price lists, labels, signs,
or
or
in combination with any other words,
connection with the advertising, offering for sale
Plaintiffs,
service
or
sale of
products
made under the authorization and control of Plaintiffs.
not
or
Marks,
used in
emanating
from
Document 1
Case 1:10-cv-05475-BSJ
supply
Plaintiffs with
a
distributed and/or sold
Mark,
or
complete
any of Plaintiffs'
products not authorized by Plaintiffs to be
Complaint
and to whom
to
they
Marks, including the Red Sole
sold in connection with said mark.
upon service of this
required immediately
That Defendants be
5.
they purchased
list of entities from whom
products falsely bearing
18 of 38
Page
upon service of this
required immediately
That Defendants be
4.
Filed 07/19/2010
deliver up for destruction their entire inventory of Counterfeit Products
bearing
Complaint
to
any of Plaintiffs'
Marks, including the Red Sole Mark.
That Defendants, within
6.
entry thereof upon it, be required
under oath
1
setting forth
to
in detail the
with notice of
thirty (30) days after service of judgment
file with the Court and
manner
serve
upon Plaintiffs
in which Defendants have
complied
a
written report
with
paragraphs
through 5, supra.
Defendants
damages
by
for
reason
profits
of Defendants' unlawful acts herein
alleged and,
that the amount of
infringement of Plaintiffs' registered trademark
That Plaintiffs be awarded actual
punitive damages
9.
mark
in
an
of
an
15 U.S.C.
damages
a
sum
not
amount to be proven at trial and
$2, 000, 000
including pre-judgment interest,
That Plaintiffs be awarded interest,
11.
That Plaintiffs be awarded reasonable
the Court may deem
in the amount of
per
1117(c).
10.
MEI 10032901v.I
by
law.
damages
That Plaintiffs be awarded statutory
as
be increased
amount to be proven at trial.
infringed pursuant to
further relief
by
to Plaintiffs
exceeding three times the amount thereof as provided by
8.
realized
over
That Defendants account for and pay
7.
attorneys'
equitable including,
on
all
sums.
fees and have such other and
but not limited to, any relief set forth
Case 1:10-cv-05475-BSJ
under
Document 1
Filed 07/19/2010
Page
34-39 of the 1946 Trademark Act and California Bus. & Prof. Code
19 of 38
14247, 14250,
17500, 17535, 17200 and 17203.
12.
That Plaintiffs have such other and further relief
as
the Court deems
proper.
Dated: New York, New York
July 19, 2010
McCARTEIC & ENGLISH,
By:
Harley
I.
245 Park Avenue, 27th Floor
New York, NY 10167
Tel:
Fax:
(212) 609-6800
(212) 609-6921
Attorneys for Plaintiffs
Christian Louboutin S.A.
And Christian Louboutin
MEI 1003290Iv.1
just
and
Case 1:10-cv-05475-BSJ
Document 1
Filed 07/19/2010
Page
20 of 38
JURY DEMAND
Plainiiffs
demand
Procedure for all issues
a
so
jury trial pursuant to
Rule
38(b)
of the Federal Rules of Civil
triable.
Mc(-2ARTER & ENG LI '.H, LLP
Dated: New York, New York
July 19,
2010
By:
(4-
arley4.
win
245 Park Avenue, 27th Floor
York, NY 10167-0001
Tel: (212) 609-6800
New
Fax:
(212) 609-6921
Attorneys for Plaintiffs
Christian Louboutin S.A.
And Christian Louboutin
MEI 1003290Iv.1
Case 1:10-cv-05475-BSJ
Document 1
Filed 07/19/2010
EXHIBIT A
Page
21 of 38
Case 1:10-cv-05475-BSJ
Document 1
Filed 07/19/2010
Page
22 of 38
Int. CI.: 25
Prior U.S. as.: 22 and 39
United States Patent and Trademark Office
Reg. No. 3,361,597
Registered
Jan. 1, 2008
TRADEMARK
PRINCIPAL REGISTER
-*/0
t
11
I
CHRISTIAN LOUBOUTIN (FRANCE INDIVI-
DUAL)
24 RUE VICTOR
MASSE
PARIS, FRANCE 75009
FOR: WOMEN'S HIGH FASHION DESIGNER
FOOTWEAR, IN CLASS 25 (US. CLS. 22 AND 39).
FIRST USE 0-04992; IN COMMERCE 0-04992.
TEE mows) RED Ls/ARE CLAIMED As A
FEATURE OF THE MARX.
THE MARK CONSISTS OF A LACQUERED RED
SOLE ON FOOTWEAR. THE DOTTED LINES ARE
NOT PART OF ME MARK BUT ARE INTENDED
ONLY TO SHOW PLACEMENT OF ME MARK
SEC
SER. NO. 77-141,789, FILED 3-27-2007.
NORA BUCHANAN WILL, EXAMINING ATTORNEY
Case 1:10-cv-05475-BSJ
Document 1
Filed 07/19/2010
EXHIBIT B
Page
23 of 38
Case 1:10-cv-05475-BSJ
Christian Louboutin official web site.
Document 1
Filed 07/19/2010
Page
24 of 38
Luxury french shoe and bag designer.
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Christian Louboutin official web site. Luxury french shoe and
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25 of 38
bag designer.
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Filed 07/19/2010
Page
26 of 38
bag designer.
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12/14/2009
Case 1:10-cv-05475-BSJ
Christian Louboutin official web site.
Document 1
Filed 07/19/2010
Page
28 of 38
Luxury french shoe and bag designer.
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Case 1:10-cv-05475-BSJ
Document 1
Filed 07/19/2010
EXHIBIT C
Page
29 of 38
Li liana JONES
Document 1
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Stroppy criss-cross faux leather
European-inspired rounded toe
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4' heel on 1' hidden platform
Zpper on inner leg
enlarge them
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Wild Rose
Stewn
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Nmsdiatenwi.ogfaUiwrdesF yaut u2s0peab:olOot :oteoafdcod nceisdhaberyan cLteirla ntoad agisnyre adotgyu it.
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GLAM ROCK at its finest! New for Fall 2009, the Jones by Li liana is edgy with great curb
appeal. The round toe
a look of confidence and great
style. Use this boot to add character to any outfi
Li liana JONES Strappy Booties
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Leatherette
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Suede finish closed toe bootie. Leatherette straps across front. Back zipper closure. Heel
height: 4.75 inches. Women's whole & half sizes. All Man Made Material. Imported.
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Suede finish closed toe bootie. Leatherette straps across front. Back
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