best chairs complaint

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA

EVANSVILLE DIVISION

BEST CHAIRS INCORPORATED, ) ) Plaintiff ) Case No. 3:14-cv-00067 ) ) Hon. v. ) ) FACTORY DIRECT WHOLESALE, LLC ) ) Defendant ) )

VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL

Best Chairs Incorporated (“Plaintiff” or “Best Chairs”), by counsel, for its complaint

against Defendant Factory Direct Wholesale, LLC (“Defendant”), alleges the following, upon

actual knowledge with respect to itself and its own acts, and upon information and belief as to all

other matters:

NATURE OF THE ACTION

1. This is an action for injunctive relief, to recover damages, and to obtain other

appropriate relief from Defendant for counterfeiting, trademark infringement, false advertising,

false designation of origin, and unfair competition under federal, state, and common law.

2. Best Chairs is a well-known, nationally recognized, and respected furniture

company that has been in operation since 1962, using “Best Chairs” in its corporate name, trade

name, and trademarks. Best Chairs is the owner of certain rights in the BEST CHAIRS

Trademarks (defined below) in the United States for use in connection with chairs and other

furniture products.

Case 3:14-cv-00067-RLY-WGH Document 1 Filed 05/07/14 of 20 PageID #: 1

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3. Defendant, without the authorization of Best Chairs, uses the designations

BESTCHAIR and BEST CHAIR as a trademark and brand name for a line of chairs and other

furniture products sold nationwide. Defendant also engages in other marketing and advertising

practices that falsely associate Defendant with Best Chairs.

PARTIES, JURISDICTION, AND VENUE

4. Best Chairs is a corporation formed under the laws of the State of Indiana on

October 2, 1962, with its principal place of business in Ferdinand, Dubois County, Indiana.

5. Best Chairs owns certain rights in the BEST CHAIRS Trademarks (defined

below) in the United States for use in connection with chairs and other furniture products.

6. Defendant is a limited liability company formed under the laws of the State of

Georgia on January 19, 2005, with its principal place of business in Duluth, Georgia.

7. Defendant distributes and sells durable goods, including chairs and furniture

products, and Defendant, without the authorization of Best Chairs, unlawfully uses the

designations BESTCHAIR and BEST CHAIR as a trademark and brand name for a line of chairs

and other furniture products sold nationwide, and unlawfully uses such designations to market

and sell such products.

8. Best Chairs and Defendant are competitors with respect to the marketing, selling,

and distributing of chairs and other furniture products.

9. This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C.

§1331 and §1338 because Best Chairs’ claims against Defendant arise primarily out of the

federal Lanham Act (15 U.S.C. §1051, et seq.).

10. Pursuant to 28 U.S.C. §1367, this Court may properly exercise supplemental

jurisdiction over Best Chairs’ state law claims against Defendant because they are so related to

the federal claims that they form part of the same case and controversy.


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11. This Court has personal jurisdiction over Defendant. Defendant has minimum

contacts with Indiana, events giving rise to the causes of action alleged herein occurred and are

occurring in this District, Best Chairs has suffered damage in this jurisdiction, and upon

information and belief, Defendant regularly conducts business activities in Indiana.

12. Venue is appropriate in this Court and in this division pursuant to 28 U.S.C.

§1391 because a substantial part of the events or omissions giving rise to the claim have occurred

in this judicial district.

FACTUAL BACKGROUND

A. Best Chairs and the BEST CHAIRS Trademarks

13. Best Chairs is a well-known, nationally recognized, and respected furniture

company that has been in operation since 1962. Best Chairs has done business as “Best Chairs

Incorporated,” “Best Chairs Inc.,” or “Best Chairs” since that time.

14. “Best Chairs Incorporated,” “Best Chairs Inc.,” and “Best Chairs” are used and

have been used as company names, trade names, as common law trademarks, for more than 50

years, and have been included in trademarks registrations for nearly 30 years.

15. Best Chairs owns and uses a family of trade names and trademarks that

incorporate the element “BEST,” including, without limitation, BEST CHAIRS, BEST

CHAIRS INC. & Design, BEST HOME FURNISHINGS, THE POWER OF BEST, and

BEST-MAX (collectively, the “BEST CHAIRS Trademarks”).

16. Best Chairs owns the following United States trademark registrations which

incorporate the element “BEST”:

Mark Serial No. Reg. No.

Goods Key Dates

BEST CHAIRS INC. & Design

International Class 20:

First Use: October 1962


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Serial No. 73/534,333 Reg. No. 1,421,085

Chairs Filing Date: April 26, 1985 Registration Date: December 16, 1986

BEST HOME FURNISHINGS Serial No. 76/538,283 Reg. No. 2,871,238

International Class 20: Furniture

Filing Date: August 19, 2003 First Use: November 3, 2003 Registration Date: August 10, 2004

THE POWER OF BEST Serial No. 77/818,610 Reg. No. 3,839,150

International Class 20: Furniture

Filing Date: September 2, 2009 First Use: October 1, 2009 Registration Date: August 24, 2010

BEST-MAX Serial No. 77/232,709 Reg. No. 3,531,915

International Class 20: Chair cushions; Cushions; Cushions; Living room furniture; Recliners; Seats

Filing Date: July 18, 2007 First Use: September 1, 2007 Registration Date: November 11, 2008

Copies of the registration certificates for the above-referenced U.S. trademark registrations are

attached to this Complaint as Exhibit A.

17. The foregoing U.S. trademark registrations are valid and subsisting and in good

standing.

18. Best Chairs owns the following United States trademark applications which

incorporate the element “BEST”:

Mark Serial No. Reg. No.

Goods Key Dates

BEST & Design

Serial No. 86/172,267

International Class 20: Furniture; residential furniture

First Use: November 3, 2003 Filing Date: January 22, 2014


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BEST HOSPITALITY Serial No. 86/171,991

International Class 20: Furniture; hospitality and institutional furniture

Filing Date: January 22, 2014

THE POWER OF BEST & Design

Serial No. 86/171,087

International Class 20: Furniture; residential furniture

First Use: October 1, 2009 Filing Date: January 21, 2014

Copies of the United States Patent and Trademark Office’s online summary for the above-

referenced U.S. trademark applications are also attached as Exhibit A.

19. Best Chairs uses its BEST CHAIRS Trademarks in connection with its chairs and

furniture products, affixed to tags, labels, and packaging for its chairs and furniture products, and

to advertise and sell its products throughout the United States.

20. The following are examples of Best Chairs’ use of its BEST CHAIRS Trademarks

as affixed to hangtags for its chairs and other furniture products:


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21. Best Chairs uses its BEST CHAIRS Trademarks, and promotes its products

offered under those marks, on its website located at www.besthf.com.

22. Best Chairs has expended substantial sums of money in advertising and

promoting its products under the BEST CHAIRS Trademarks, such that the public recognizes

Best Chairs as the source of chairs and other furniture products offered under those marks.

23. By virtue of these efforts, the longstanding use of the BEST CHAIRS

Trademarks, and the quality of Best Chairs’ products, the BEST CHAIRS Trademarks have

acquired valuable goodwill in the marketplace.

24. Based on these and other efforts, the public has come to know the BEST CHAIRS

Trademarks, and recognizes that chairs and other furniture products offered under those marks

originate with Best Chairs.

B. Defendant’s Conduct

25. Defendant, a distributor and seller of durable goods, ships and sells chairs and

other furniture products throughout the United States, both through brick-and-mortar retail stores

and through online retailers.

26. Defendant uses the BESTCHAIR and BEST CHAIR designations as a trademark

and brand name for a line of chairs and other furniture products.


http://www.besthf.com/

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27. Upon information and belief, Defendant imports its BESTCHAIR / BEST CHAIR

line of chairs and furniture products from a manufacturer in China for distribution and sale in the

United States. Those products are warehoused in facilities in California and Georgia, and are

shipped directly from those warehouses to consumers.

28. Upon information and belief, Defendant’s Chinese manufacturer operates under

the name “BestChair,” but has acquired no rights to use, or license the use of, the “BestChair”

designation in the United States.

29. Upon information and belief, without Best Chairs’ authorization, Defendant or a

related or predecessor entity made some use of the BESTCHAIR and BEST CHAIR

designations as a trade name in the United States roughly four years ago.

30. Upon information and belief, Defendant promotes and sells its BESTCHAIR /

BEST CHAIR line of chairs and furniture products on the Internet, including through the highly

interactive websites of online retailers such as Amazon.com and Rakuten.com.

31. As set forth in Exhibit B, Defendant’s products are promoted and sold on

Rakuten.com under the brand name “BestChair” and Defendant is listed as the “Marketplace

Seller” for those products.

32. As set forth in Exhibit B, Defendant’s products are promoted and sold on

Amazon.com under the brand name “BestChair.”

33. As set forth in Exhibit B, Defendant’s products are promoted on the website

eDealinfo.com under the brand name “BestChair.”

34. The screen shot from eDealinfo.com, as set forth in Exhibit B, provides an

example of Defendant’s products being promoted on the same web page as Best Chairs’

products.


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35. On March 26, 2014, Defendant filed a United States trademark application for the

mark BESTCHAIR (Serial No. 86/232,975), which covers the goods of “Chairs; Deck chairs;

Dining chairs; Office chairs; Reclining chairs,” and claims a first use date of January 12, 2010.

A copy of the United States Patent and Trademark Office’s online summary for the above-

referenced U.S. trademark application is attached as Exhibit C.

36. Defendant submitted the following examples of its current use of the mark along

with its above-reference U.S. trademark application, which, upon information and belief, are

images of the BESTCHAIR and BEST CHAIR designations used as trademarks on packaging

for Defendant’s products.

37. Defendant has no right to use the BEST CHAIRS Trademarks, and use of the

BESTCHAIR and BEST CHAIR mark and brand name by Defendant is without the

authorization of Best Chairs.

38. Such use by Defendant of the BESTCHAIR and BEST CHAIR mark and brand

name in marketing and advertisements is material to consumer decisions to purchase the

products being advertised.


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39. Upon information and belief, Defendant accepts orders from and ships its

BESTCHAIR / BEST CHAIR products to customers throughout the United States, including

those located in Indiana.

40. Upon information and belief, Defendant ships its BESTCHAIR / BEST CHAIR

products in packaging that is affixed with labels bearing the BESTCHAIR or BEST CHAIR

mark.

C. Interaction Between the Parties

41. Approximately two years ago, Best Chairs learned of a party named “Cavalier

Wholesale” purporting to sell product on Amazon “by “BESTCHAIR.” Best Chairs advised

Amazon of the matter, and Best Chair believed the issue to be resolved.

42. On January 6, 2014, Best Chairs received notification from Tri-State Better

Business Bureau, Inc. that a complaint was lodged against Best Chairs by a consumer mistakenly

believing a defective office chair he purchased on Rakuten.com was manufactured by Best

Chair. Upon investigation, it was discovered that the BESTCHAIR product which was the

subject of the complaint was purchased was from Defendant.

43. Based on information only recently acquired, Best Chairs now believes the party

named Cavalier Wholesale and Defendant to be the same entity, under common control, or

otherwise related.

44. Moreover, this customer complained that he not only purchased a chair that

experienced a catastrophic (and presumably dangerous) failure shortly after its purchase, but he

was also treated poorly by a customer support representative (presumably an agent of Defendant)

who he contacted to document his complaint.


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45. In his documented complaint, that customer requested that Defendant issue a

refund, credit, replacement parts, or a replacement product, but was advised by a customer

support representative that his concerns would not be rectified.

46. Not long after learning of this actual consumer confusion in the marketplace, Best

Chairs, through counsel, sent Defendant a written letter on January 16, 2014 outlining Best

Chairs’ rights in the BEST CHAIRS Trademarks, expressing its concern that Defendant’s use of

the BESTCHAIR mark is likely to cause consumer confusion, and requesting that Defendant

refrain from using the BESTCHAIR designation in such a manner.

47. In response, Defendant sent a letter to Best Chairs’ counsel on January 24, 2014

suggesting that it could not find evidence of Best Chairs use of the BEST CHAIRS Trademarks

and otherwise indicating that it would take no steps to prevent consumer confusion.

48. On March 10, 2014, Best Chairs, through its counsel, again notified Defendant of

Best Chairs’ rights in the BEST CHAIRS Trademarks, of Best Chairs’ longstanding use of the

“Best Chairs” designation and mark, and of actual confusion in the marketplace as a result of

Defendant’s use of the BESTCHAIR mark. Best Chairs also repeated its request that Defendant

refrain from any infringing conduct.

49. On or around March 20, 2014, Best Chairs received a message from a

representative of Amazon.com requesting information on behalf of a customer regarding a

warranty for chairs purchased from a seller from Amazon’s website. The purchased products

were those of Defendant, not Best Chairs, which further confirmed that consumers and retailers

were experiencing actual confusion in the marketplace.


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50. Receiving no response to its March 10, 2014 letter, Best Chairs’ counsel sent one

final letter to Defendant on April 9, 2014 reiterating Best Chairs’ concerns and highlighting

further instances of actual confusion.

51. In response correspondence dated April 13, 2014, Defendant repeated its position

that it would not refrain from infringing behavior.

52. Upon information and believe, Best Chairs recently learned that Defendant has

received a failing score by the Better Business Bureau of Metro Atlanta, Athens & NE Georgia

due to its failure to respond to customer complaints filed against it, and such complaints included

those concerning Defendant’s advertising and sale practices, its product delivery practices, it

product guarantee and warranty practices, and issues related directly to its products.

D. Plaintiff Best Chairs’ Concerns 53. Defendant’s use of the BESTCHAIR and BEST CHAIR mark and brand name

has a substantial likelihood of causing confusion and mistake by consumers as to the source of

Defendant’s products.

54. Defendant’s use of the BESTCHAIR and BEST CHAIR mark and brand name

also has a substantial likelihood of causing confusion and mistake by consumers as to the

affiliation, connection, or association of Defendant with Best Chairs, and/or as to the sponsorship

or approval of Defendant’s products and commercial activities by Best Chairs.

55. Defendant’s use of the BESTCHAIR and BEST CHAIR mark and designation

has in fact caused actual confusion, as evidenced in part by customer complaints about

Defendant and its products that were mistakenly directed to Best Chairs, as well as inquiries by

consumers and online retailers of Defendant’s products and warranty information for such

products that were mistakenly directed to Best Chairs.


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56. Defendant’s unsatisfactory business practices and low-quality products have and

will negatively impact Best Chairs’ goodwill and business reputation largely due to Defendant’s

use of the BESTCHAIR and BEST CHAIR mark.

57. Upon information and belief, Defendant intentionally attempts to pass off its

products as products branded with the BEST CHAIRS Trademarks, and trade off of the goodwill

associated with the BEST CHAIRS Trademarks.

58. Upon information and belief, the conduct of Defendant alleged in this Complaint

is willful and intentional.

59. As the owner of the BEST CHAIRS Trademarks for chairs and other furniture

products, Best Chairs will suffer irreparable harm unless Defendant is enjoined from selling

counterfeit BESTCHAIR and BEST CHAIR branded products, mislabeling its products and their

packaging with the BESTCHAIR and BEST CHAIR mark, infringing upon the BEST CHAIRS

Trademarks, using false and misleading statements and representations of fact in its

advertisements, and otherwise engaging in unfair competition.

60. Defendant’s actions as alleged herein have caused, and will continue to cause,

harm to Best Chairs, its business, reputation, and goodwill, for which there is no adequate legal

remedy.

61. The hardship on Best Chairs in the absence of an injunction outweighs the

hardship, if any, to Defendant from being enjoined from continuing its unlawful conduct.

62. The public interest will not be disserved by entry of an injunction against

Defendant’s unlawful actions.

COUNT I – FEDERAL TRADEMARK COUNTERFEITING

63. Best Chairs incorporates by reference paragraphs 1 through 61 as set forth above.


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64. Defendant advertises, sells, and ships to consumers chairs and other furniture

products wrapped in packaging that has affixed to it the BESTCHAIR or BEST CHAIR mark (or

a reproduction, counterfeit, colorable imitation, or copy thereof), or a spurious designation that is

identical with, or substantially indistinguishable from one or more of the federally registered

BEST CHAIRS Trademarks.

65. Such conduct by Defendant is without the authorization of Best Chairs, and is

intentional, willful, and with actual knowledge of the rights Best Chairs has in the BEST

CHAIRS Trademarks.

66. Defendant’s acts constitute unlawful counterfeiting in violation of 15 U.S.C.

§§1114 and 1116.

67. Best Chairs has been damaged as a result of Defendant’s conduct.

68. Best Chairs is entitled to injunctive and other relief as requested below.

COUNT II –TRADEMARK INFRINGEMENT OF FEDERALLY REGISTERED TRADEMARKS 15 U.S.C. §1114


70. The BEST CHAIRS Trademarks are owned and used by Best Chairs, and several

are federally registered, as described previously.

71. Defendant uses the BESTCHAIR and BEST CHAIR trademark and brand name

when marketing and selling its chairs and other furniture products.

72. Such conduct by Defendant is substantially likely to cause public confusion and

mistake as to the source of Defendant’s products, as to the affiliation, connection, or association

of Defendant with Best Chairs, and/or as to the sponsorship or approval of Defendant’s products

or commercial activities by Best Chairs.


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CHAIRS Trademarks.

74. Defendant’s acts constitute trademark infringement in violation of 15 U.S.C.

§1114.



COUNT III –UNFAIR COMPETITION, FALSE ADVERTISING, FALSE DESIGNATION OF ORIGIN AND INFRINGEMENT UNDER 15 U.S.C. §1125


78. Best Chairs has rights in the company name, trade name and trademarks using

BEST and BEST CHAIRS in connection with chairs and other furniture products throughout the

United States.

79. Defendant’s use of BESTCHAIR and BEST CHAIR as a trade name and

trademark in the marketing and selling chairs and other furniture products is likely to cause

public confusion and mistake as to the source of Defendant’s products, as to the affiliation,

connection, or association of Defendant with Best Chairs, and/or as to the sponsorship or

approval of Defendant’s products or commercial activities by Best Chairs. Defendant uses the

BESTCHAIR and BESTCHAIR trademark in its commercial advertising or promotion.

80. Because Defendant’s products are not the products of Best Chairs and Defendant

is not otherwise authorized to use any of the BEST CHAIRS Trademarks, such conduct by

Defendant constitutes a false designation of origin, a false or misleading description of fact,

and/or a false or misleading representation of fact which misrepresents the nature, characteristics,

or qualities of Defendant’s products or commercial activities.


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81. Defendant’s conduct is without the authorization of Best Chairs, and is, upon

information and belief, intentional and willful, and is with actual knowledge of the rights Best

Chairs has in the BEST CHAIRS Trademarks.

82. Defendant’s acts constitute infringement, false advertising, false designation of

origin, and unfair competition all in violation of 15 U.S.C. §1125.

COUNT V – UNFAIR COMPETITION UNDER INDIANA STATE LAW


84. Best Chairs owns, and has established trademark rights in Indiana to, its company

name, trade name, and BEST CHAIRS Trademarks.

85. Defendant uses the BESTCHAIR and BEST CHAIR trademark and other related

indicia in connection with its chairs and other furniture products, on packaging for those

products, and when marketing and selling such products.

86. Such conduct by Defendant is substantially likely to cause public confusion and

mistake as to the source of Defendant’s products, as to the affiliation, connection, or association

of Defendant with Best Chairs, and/or as to the sponsorship or approval of Defendant’s products

or commercial activities by Best Chairs.



CHAIRS Trademarks.

88. By infringing upon the BEST CHAIRS Trademarks and using the same and/or

confusingly similar marks and other indicia to derive benefit, Defendant is unfairly trading upon

and misappropriating for its own benefit the valuable goodwill, reputation, publicity, and

business opportunities of Best Chairs.


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89. Defendant’s acts constitute trademark infringement and unfair competition under

the common law and the statutes of the State of Indiana.



COUNT VI – CIVIL ACTION UNDER THE INDIANA CRIME VICTIMS ACT


93. Pursuant to the Indiana Crime Victims Act, Indiana Code §34-24-3-1, a person

that suffers a pecuniary loss as a result of a violation of Ind. Code §35-43, et seq. may bring a

civil action against the person who caused the loss for treble damages, the costs of the action,

and reasonable attorneys’ fees.

94. Defendant has encumbered or otherwise exerted unauthorized control over one or

more of the BEST CHAIRS Trademarks, and such conduct by Defendant was done knowingly or

intentionally, was done with the intent to deprive Best Chairs of the value or use of one or more

of the BEST CHAIRS Trademarks or products offered thereunder, and was done without the

authorization of Best Chairs in violation of Ind. Code §35-43-4-3.

95. Defendant has, with the intent to defraud, misrepresented the quality of its

products in violation of Ind. Code §35-43-5-3(6).

96. Defendant has disseminated to the public an advertisement that it knows is false,

misleading, or deceptive, with intent to promote the purchase or sale of its products in violation

of Ind. Code §35-43-5-3(9).

97. Defendant has made or uttered written instruments, such as chairs and other

furniture products, and packaging for such products, in such a manner that it purports to have

been made by the authority of Best Chairs, and such conduct was done knowingly or


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intentionally and was done without the authorization of Best Chairs in violation of Ind. Code

§35-43-5-2.

PRAYER FOR DAMAGES AND INJUNCTIVE RELIEF

WHEREFORE, Best Chairs prays for all appropriate relief, including, without limitation:

A. That Defendant, and its affiliates, officers, directors, employees, agents,

representatives, and all persons acting or claiming to act on its behalf or under its direction or

authority, and all persons or entities acting in concert or participation therewith, be preliminarily

and permanently enjoined from: (i) the conduct described herein; (ii) using or authorizing others

to use the BESTCHAIR trademark or brand name, the BEST CHAIR trademark or brand name,

or the BEST CHAIRS Trademarks, or any confusingly similar mark or colorable imitation

thereof, in connection with the marketing, sale, or distribution of any goods or services offered

by it; (iii) performing any act which can or is likely to lead members of the public to believe that

any good or service marketed, sold, or distributed by it is in any manner associated or connected

with Best Chairs, or is sold, manufactured, licensed, sponsored, endorsed, or authorized by Best

Chairs; and (iv) otherwise taking any action likely to cause confusion, mistake, or deception on

the part of the public as to the connection, affiliation, or other association of goods or services of

Defendant with the goods or services of Best Chairs;

B. That Defendant, and its affiliates, officers, directors, employees, agents,

representatives, and all persons acting or claiming to act on its behalf or under its direction or

authority, and all persons or entities acting in concert or participation therewith, be preliminarily

and permanently enjoined from engaging in unfair competition against Best Chairs;

C. For an order awarding damages sustained by Best Chairs, and the costs incurred

by Best Chairs in this action, and/or based upon Defendant’s profits associated with the sale of

the goods or services that bear, have been offered under, or were used in connection with the


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BESTCHAIR trademark or brand name, the BEST CHAIR trademark or brand name, or the

BEST CHAIRS Trademarks, in an amount up to three times the amount of actual damages;

D. For an order that Defendant bear the cost of any rehabilitative advertising to

correct the damages done to the BEST CHAIR Trademarks;

E. For an order awarding punitive or enhanced damages, as well as court costs and

attorneys’ fees, for Defendant’s willful and egregious conduct;

F. For an order directing Defendant to provide a full written accounting of all goods

and services that bear, have been offered under, or were used in connection with the

BESTCHAIR trademark or brand name, the BEST CHAIR trademark or brand name, or the

BEST CHAIRS Trademarks, sold by Defendant or its affiliates;

G. For an order directing Defendant to destroy, alter, and/or deliver to Best Chairs all

materials, including, without limitation, labels, packaging, signs, prints, advertisements,

prototype plans, and similar items, in its possession or under its control that bear, are offered

under, or are used in connection with the BESTCHAIR trademark or brand name, BEST CHAIR

trademark or brand name, or the BEST CHAIRS Trademarks, or any mark confusingly similar

thereto;

H. For an order directing each Defendant to file with this Court, and serve upon Best

Chairs’ counsel within thirty (30) days after entry of such judgment, a written report under oath,

setting forth in detail the manner and form in which Defendant has complied with such

judgment;

I. For an award of interest, including prejudgment interest; and

J. For such other relief as the Court may deem just and proper, including, without

limitation, an order requiring corrective action to minimize damage or to alleviate consumer


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confusion, along with other relief available to Best Chairs under 15 U.S.C. §1117 and Indiana

Code §34-24-3-1.

JURY DEMAND

Best Chairs, pursuant to Rule 38 of the Federal Rules of Civil Procedure, does hereby

demand a trial by jury.

BINGHAM GREENEBAUM DOLL LLP

/s/ Amy B. Berge Amy B. Berge Joseph R. Dages 101 South Fifth Street 3500 National City Tower Louisville, Kentucky 40202 (502) 587-3707 (502) 540-2268 (facsimile) [email protected] [email protected] Attorneys for Best Chairs Incorporated

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