douglas v keno trademark complaint

8/3/2019 Douglas v Keno Trademark Complaint

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Thomas Freedman, OSB No. 080697Email: [email protected] LAW LLC312 NW 10th Avenue, Suite 201Portland, OR 97209Phone: 503.467.7256Cowlsellor Plaint(ff FILEllOS OC T '1113:4SUSOC-(J!P

UNITED STATES DISTRICT COURTDISTRICT OF OREGON -- PORTLAND DIVISION

CHRISTOPHER DOUGLAS, CV'11 1204 BRPlaintiff:

-against- COMPLAINTLEIGH KENO; LESLIE KENO, andTHEODORE ALEXENDAR USA, INC.,

Jury Trial DemandedDefendants.

Plaintift: as and for his complaint, alleges as follows:NATURE OF THE ACTION

I. This is a complaint for trademark infringement, unfair competition, and falsedescription arising under *43 of the Lanham Act (15 U.S.C. 1125(a)), to r violations ofOregon's Unlawful Trade Practices Act (ORS 646.605 - 646.656), and to r related common law

claims.JURISDICTION & VENUE

2. This Court has original subject matter jurisdiction over this action pursuant to 28U.S.C. 1331, 1338(a) and 15 U.S.c. 1121.

Thomas Freedman, OSB No. 080697PEARL LAW LLC312NW IOthAvcSte201, P0l11and,OR 97209503A67.7256I [email protected]

Page 1 of 11 Complaint

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3. This Court has related claim jurisdiction over the state law claims pursuant to 28U.S.C. 1338(b) and 28 U.S.C. 1367.

4. Venue is proper in this Court pursuant to 28 U.S.C. 1391. THE PARTIES

5. Plaintiff is a natural person and a resident of the state of Oregon.6. Defendant Leigh Keno is natural person and, upon information and b e l i e t ~ a

resident of the state ofNew York.7. Detendant Leslie Keno is natural person and, upon information and beliet: a

resident of the state ofNew York.8. Defendant Theodore Alexander USA, Inc. is a North Carolina corporation.

FACTUAL ALLEGATIONSA. Plaintiff's Unique Design - The Flipper Screen

9. Plaintitf is an accomplished and award-winning independent furniture designer.10. In 2003, plaintitf designed the Flipper Screen, one of his most unique and

distinctive pieces. An image ofthe Flipper Screen is annexed hereto as Exhibit A.II. The Flipper Screen won Best in Category for Furniture at the 2004 Portland

Design Festival, and was featured by Cooper-Hewitt in the coveted Design Triennial Show.12. Plaintiff featured the Flipper Screen at the International Contemporary Furniture

Fair in 2004, 2005, and 2006.13. In the mid-2000's, due to its distinctive and award-winning design, plaintiffs

Flipper Screen was teatured in numerous design magazines and periodicals, including DH'ell,Interior DeSign, Oregon Home, Chicago Tribune, New York Magazine, as well as TItlEMagazine's "Design 100" list of 2007, and a hardbound design publication published by GraphisThomas Freedman, OSH No. 080697 Page 2 of 11PEARL LAW LLC Complaint312NW 10th Ave Sle201. POItlanu.OR 97209503.467.7256 \ lhomaS@ prllaw.com

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International Journal of Visual Communication.14. In addition, during this timeframe, the Flipper Screen was featured on blogs ,

television shows, was used by the erstwhile Marshall Field's department store in Chicago inconnection with fashion displays, and was carried by Sam Flax Art Supplies tlagship store inNew York City.B. Defendants' Infringing and Unlawful Conduct - the Peekaboo!

15. Defendants Leigh and Leslie Keno, known as the Keno Brothers, have achievednational and international celebrity and fame as antique and furniture appraisers, and have cohosted several television shows, including a reality show on the Fox network called BuriedTreasure.

16. The Keno Brothers' television shows are broadcast in Oregon, and the KenoBrothers travel to many states, including Oregon, as part of their shows and to discuss theiralleged furniture designs.

17. Defendant Theodore Alexander USA, Inc. ("Theodore Alexander") is one of theleading furniture manufacturers in the world, and manufactures and sells furniture throughout theUnited States, including in Oregon.

18. In or about 2010, Theodore Alexander launched a furniture line entitled "KenoBros. Furniture."

19. The "Keno Bros. Furniture" line was allegedly designed by defendants LeighKeno and Leslie Keno, in an attempt to capitalize on the reality-TV stardom of the KenoBrothers' name.

20. The "Keno Bros. Furniture" line is manufactured by Theodore Alexander.21. The "Keno Bros. Furniture" line includes a piece entitled the "Peekaboo!," which,

Thomas 'Freedman, OSS No. 080697PEARL LAW LLC312NW lOlhAveSle201.POItland. OR 97209503.467.7256 [email protected]


mailto:[email protected]:[email protected]:[email protected]:[email protected]


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like all pieces in the "Keno Bros. Furniture" line, was allegedly designed by defendants LeighKeno and Leslie Keno. An image of the Peekaboo! is annexed hereto as Exhibit B.

22. The Peekaboo '! is an unauthorized copy and direct knock-otf of plaintiffs FlipperScreen, unlawfully marketed and held out as a "Keno Bros. Furniture" original design, allegedlydesigned by defendants Leigh and Leslie Keno.

23. The Peekaboo! directly copies the distinctive look and feel, unique design, totalimage and overall appearance, visual characteristics, and other non-functional qualities andfeatures of plaintiffs Flipper Screen.

24. Defendants, in promoting, advertising, marketing, using, and selling thePeekaboo!, have caused actual and potential confusion as to the creation, origin, and design ofplaint iffs Flipper Screen.

25. Defendants willfully infringed plaintiffs rights under state and federal law.26. Plaintiff sent defendants a cease and desist letter dated August 10, 2011.

Defendants received the letter, willfully ignored it, and thereafter have continued to promote,market and sell the PeekabooL

27. Defendants have damaged pla intiffs reputation and business integrity as anindependent furniture designer by unlawfully knocking otT his most revered design without anycredit or explanation, and falsely associating it with defendants' reality-show furniture line.

28. As a direct, proximate and toreseeable result of defendants' infringement andunlawful conduct, plaintitfhas suffered extensive monetary damages, lost protits, irreparableharm to his business and reputation, loss of goodwill, and other future and current damages, forwhich there is no adequate remedy at law.

Thomas freedman. OSB No. 080697PEARL LA W LLC312 NW 1Otll Ave Stc 20 I, POl1land, OR '17209503.-l67.7256 [email protected]


mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]


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FIRST CAUSE OF ACTION (Trademark Infringement - Trade Dress - Lanham Act 43)

29. Plaintiff restates and realleges the allegations contained in the preceding

paragraphs and incorporates the same by reference as if fuUy set forth herein.30. Defendants have reproduced, copied and imitated the Flipper Screen's unique

trade dress in designing the Peekaboo! in a manner that is confusingly similar to the distinctivetrade dress of the Flipper Screen.

31. Defendants' adoption and use of the Flipper Screen trade dress constitutes tradedress infringement and deliberate and willful violations of 15 U.S.c. 1 125(a) of the LanhamAct.

32. Defendants' trade dress infringement, unless enjoined by this Court, will continueto cause plaintiff to sustain irreparable damage, loss of goodwill, and injury for which plaintiffhas no adequate remedy at law.

33. Defendants' trade dress infringement is likely to cause confusion, mistake anddeception of the public as to the identity and origin of plaintiffs Flipper Screen, causingirreparable harm to plaintiff and his reputation for which there is no adequate remedy at law.

34. As a direct, proximate and foreseeable result of defendants' trade dressinfringement and unlawful conduct, plaintiff has suffered extensive monetary damages, lostprofits, irreparable harm to his business and reputation, loss of goodwill, and other current andfuture damages, and defendants are liable to plaintiff for damages and injunctive relief under theLanham Act.

SECOND CAUSE OF ACTION(Unfair Competition -- Lanham Act 43)

35. Plaintiff restates and realleges the allegations contained in the preceding

Thomas Freedman, OSS No. 080697PEARL LA W LLC311 NW 10th Ave Ste 101, Pottlnnd , OR 97209503.467.7256 1 [email protected]


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paragraphs and incorporates the same by reference as if fully set forth herein.36. Defendants' promotion, marketing, advertising and selling of the Peekaboo! is in

direct competition with and an unlawful passing off of plaintiffs Flipper Screen and constitutesunfair competition under 15 U.S.c. 1125(a) of the Lanham Act.

37. Defendant's use, promotion, marketing, advertising and selling of the Peekaboo!is likely to cause confusion, mistake, and deception among consumers.

38. Defendant's unfair competition has caused and will continue to cause damage toplaintitf, and is causing irreparable harm to plaintitf for which there is no adequate remedy atlaw.

39. As a direct, proximate and foreseeable result of defendants' trade dressinfringement and unlawful conduct, plaintitfhas sutfered extensive monetary damages, lostprofits, irreparable harm to his business and reputation, loss of goodwill, and other current andfuture damages, and defendants are liable to plaintiff for damages and injunctive relief under theLanham Act.

THIRD CAUSE OF ACTION (False Description - Lanham Act 43)

40. Plainti ff restates and rea lieges the allegations contained in the precedingparagraphs and incorporates the same by reference as if fully set f011h herein.

41. Defendants' Peekaboo! is such a colorable imitation and copy of plaintiffsFlipper Screen established in the market that defendants' use thereof is likely to create confusion,cause mistake, or deceive consumers as to the affiliation, connection or association betweenplaintiffs Flipper Screen and the Peekaboo!, and/or to deceive consumers as to the origin,sponsorship or approval of the Peekaboo! by plaintitf.

42. Defendant's use and marketing of the Peekaboo! comprises a false description orThomas Freedman, OSB No. 080697 Page 6 of I IPEARL LA W LLC Complaint312 NW 10th Ave Ste 201 , P0111and , OR 97209503.467.7256 1homaS@ prllaw.com

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representation of business or products under 15 U.S.c. II25(a) of the Lanham Act.43. As a direct, proximate and foreseeable result of defendants' false description and

unlawful conduct, plaintiff suffered extensive monetary damages, lost profits, irreparable harm tohis business and reputation, loss of goodwill, and other current and future damages, anddefendants are liable to plaintiff for damages and injunctive relief under the Lanham Act.

FOURTH CAUSE OF ACTION (Violations of Oregon Unlawful Trade Practices Act)

(ORS 646.605 to 646.656) 44. Plaintiff restates and realleges the allegations contained in the preceding

paragraphs and incorporates the same by reference as if fully set forth herein.45. As set forth with particularity supra, defendants' conduct violates Oregon's

Unfair Trade Practices Act, ORS 646.605 to 646.656 (the "UTPA").46. Among other things, defendants, in the course of their business, vocation or

occupation: (i) caused likelihood of confusion or misunderstanding as to the source,sponsorship, approval, or certification of the Flipper Screen; (ii) caused likelihood of confusionor misunderstanding as to affiliation, connection, or association with, or certification by, plaintiffof the Peekaboo!; (iii) passed otfplaintiff's Flipper Screen as their own original design andgoods; (iv) used deceptive representations in connection with the Peekaboo!; (v) represented thatthe Peekaboo! has sponsorship, approval, characteristics, or qualities that it does not have; and(vi) engaged in other unfair or deceptive conduct in trade or commerce.

47. Defendants' conduct was willful and intentional.48. As a direct, proximate and foreseeable result of defendants' unlawful trade

practices, plaintitfhas suffered extensive economic, noneconomic and irreparable damages,which continue to accrue.

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49. In addition, under the UTPA, plaintiff is entitled to recover reasonable attorney'sfees, see ORS 646.638(3), and punitive damages, see ORS 646.638(1).

FIFTH CAUSE OF ACTION (Injury to Business Reputation - Common Law)

50. Plaintiff restates and realleges the allegations contained in the precedingparagraphs and incorporate the same by reference as if fully set forth herein.

51. Defendants' promotion, use, marketing, advertising and sales of the Peekaboo!injures and creates a likelihood of injury to plaintiffs business reputation.

52. Consumers and persons encountering the Peekaboo! will believe that plaintiff, awell-respected and award-winning independent furniture designer, is affiliated with or related toor has the approval of defendants, and any adverse reaction by the public to defendants, and thequality of their products, including the reality-show affiliation of the "Keno Bros. Furniture"line, will injure the business reputation and integrity of plaintiff and the goodwill he enjoys inconnection with the Flipper Screen.

53. As a direct, proximate and foreseeable result of defendants' unlawful conduct,plaintiff has suffered extensive monetary damages, lost profits, irreparable harm to his businessand reputation, loss of goodwill, and other current and future damages.

SIXTH CAUSE OF ACTION(Common Law Trade Dress and Unfair Competition)54. Plaintiff restates and realleges the allegations contained in the preceding

paragraphs and incorporates the same by reference as if fully set forth herein.55. Defendants have reproduced, copied and imitated the Flipper Screen trade dress in

marketing, advertising, promoting, and selling the Peekaboo! in a manner that is confusinglysimilar to the distinctive trade dress of the Flipper Screen, and unfairly competed with plaintiff in

Thomas Freedman, OSB No. 080697 Page 8 of 11PEARL LA W LLC Complaint312 NW 10th Avt: Ste 20 I. POI1land, OR 97209303.467.72561 t h o m a s p r l l a w . ~ o m

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the marketplace.56. Defendants' actions constitute common law trade dress infringement and unfair

competition.57. Defendants' trade dress infringement and unfair competition, unless enjoined by

this Court, will continue to cause plaintiff to sustain irreparable damage, loss of goodwill, andinjury for which plaintiff has no adequate remedy at law .

58 . As a direct, proximate and foreseeable result of defendants' unlawful conduct,plaintiff has suffered extensive monetary damages, lost profits, irreparable harm to his businessand reputation, loss of goodwill, and other current and future damages.

JURY DEMAND59. Plaintiff demands a trial by jury on all claims so triable.WHEREFORE, plaintiff demands judgment against defendants as follows:

1. That defendants, their agents, officers, employees, representatives, successors,assigns, attorneys, and all other persons acting for, with, by, through or under authority fromdefendants, be preliminarily and permanently enjoined from:

(a) promoting, advertising, marketing or selling the Peekaboo!, orany colorable imitation thereof;(b) using any trademark or promoting, advertising, marketing orselling any product that imitates or is confusingly similar to theFlipper Screen, or that is likely to cause confusion, mistake,

deception, or public misunderstanding as to the origin of theFlipper Screen or its connectedness to defendants; and

(c) from otherwise competing unfairly with plaintiff in any maImer;2. That defendants be required to deli ver up to plaintiff for destruction all

versions of the Peekaboo! and all containers, labels, signs , prints, packages, catalogs,

Thomas Freedman, OSB No. 080697PEARL LAW LLC312 NW 10th Avt: Stt: 201 . POItland. OR 972{)9503.467.72561 thoma: l!,prllaw.com

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circulars, advertising, marketing or promotional materials, or the like, in their possession,custody or control concerning the Peekaboo l;

3. That defendants be required to file and serve within thirty (30) days afterentry of the injunction a report in writing under oath pursuant to 15 U.S.C. 1116(a)setting forth in detail the manner and fonn in which defendants have complied with theinjunction;

4. That defendants be required to account to plainti ff for any and all profits,gains, savings and advantages derived by them from the illegal acts complained of herein,including all sales of the Peekabool;

5. That defendants be held liable for damages sutfered by plaintiff resultingfrom the acts alleged herein in an amount to be detennined at trial;

6. For treble damages pursuant to 15 U.S.c. 1117;7. For punitive damages to the fullest extent available under applicable law,

including pursuant to ORS 646.638(] );8. For attorney's fees to the fullest extent available under applicable law, including

pursuant to 15 U.S.C. 1117 and ORS 646.638(3);9. For costs, disbursements, prevailing party fees, enhanced prevailing party fees,

and statutory interest to the fullest extent available under applicable law;10. That the Court declare this to be an exceptional case under the Lanham Act and

awarding enhanced damages thereunder to the fullest extent available;11. That the Court award plainti ff any other remedy to which he is entitled under

15 U.S.C. 1116 and 1117 or under state law; and

Thomas Freedman, OSB No. 080697PEARL LAW LLC3\1NW 10th AveSte 201, POItland,OR 97209503.467.7256 Il ho [email protected]

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12. For such other and further relief as the Court may deem just, equitable and proper.Dated: October 6,2011 Respectfully submitted,

P ~ L C B . 1/fi2

-------------Thomas FreedmanOSB No. 080697Attorney jor Plaintiff

Thomas Freedman. OSB No. 080697PEARL LAW LLC312 NW 10th Ave Ste 201. Portland, OR 97209503.467.72561 thomaS@ prllaw.com

Pag!! 11 of 11 Complaint

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F " f p. per Screen 5 P d d n d lsolutions to mdximize liVing spoce

In r or 0 Ig 3D VI u I n Colo

design solutions toMaximize yourLiving Space Available in Maple or Walnut Staino Delivery: 8-12 weekso Standard size is 3 panels. Addit ional panels can be Q added.

It 24 " - - + {'1

SR cesolutions to mdxlmize l iving sPdce ' /531 Docific High


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THEODO ALEXANDER

Keno Bros.

Peekaboo!KEN03201Hyedua Veneer Fiddle Back Sycamore Veneer Vertically Rotating Circular Panels.W 721Jz x 0 1 x H 86Y- inches

Material(s) Sycamore, HyeduaCollection Keno Bros.Style Modem ClassicCategory Free Standing AccessoriesType Screens

EXHIBIT _g.__PAGE I OFL



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----- ----- --------

""JS 44 (Rev_ 12107) CIVIL COVER SHEETTh e JS 44 civil cover sheet an d the infonnution contained herein neither replace no r supplement the t l l ingand service of pleadings or other papers as required by law, except as provideby local rules of court This fonn, approved by th e Judicial Conterenceot the United States in September 1974, is required tor the us e of the Clerk of Court tor the purpose ofmitiatinthe civil docket sheet (SEE INSTRUCTIONS ON THE REVERSE O f THE fORM.)I. (a) P L A IN T IF F S D E F E N D A N T S

C h r i s t o p h e r D o u g l a s Le i g h K e n o , Ltv,,, andfZr14Ale1:Jlter U S A , l n c .(b ) County of Residence of First Listed Plaintiff .;.M;..:.;:;u"lt:;.n;.::o;.;m.:.;.:a::.;.h'---____ _ County o f Residence of First Listed Defendant

(EXCEPT IN U_S_ PLAINTIFF CASES) (IN U$ . PLAINTIFF CASES ONL Y )-I(-'-, 7111-=t:4YUS C-QRP NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THEFILED06 U-' '- - v LAND INVOL VED_

(c) Attorney's (Finn Name. Address, and Telephone Number) Attorneys i1fKnown)T h o m a s F r e e d m a n , P e a r l L a w L L C3 1 2 NW 1 0 t h A v e , Po r t l an d , OR 9 7 2 0 9 5 0 3 . 4 6 7 . 7 2 5 6

II. B A S I S O F J U R I S D I C T I O N (Place an "X" in One Bo., Only) III. C I T I Z E N S H I P O F P R I N C I P A L PARTIES(Placean"X" in One Bodor Plaintif(For Diversity Cases Only) and One Box for Defendant)o I U.S. Gover nment llII 3 Federal Question PTf DEF PTf DEFPlainritT I U-S_ Government Not a Party) Citizen ofThis State 0 I o I Incorporated or Principal Place 0 4 0 4

of Business In This Stateo 2 U.S, Government o 4 Diversity Citizen of Anorher State o 2 Incorporated alld Principal Place o 5

Defe",!.1nt of Business In Another State([ndicate Citizenship of Parties in Item III)Citizen or Subject of a o 3 o J Foreign Nation o 6 0 6

Forei!!n CountIV N A T U R E O F S U I T (PIace an "x" in 0 ne Box Only) CONTRACT TORTS FORFEITURE/PENALIT BANKRUPl ;Y OTHER STATUTES o 110 Insurance PERSONAL IN,IURY PERSONAL INJURY o 610 Agriculture o 422 Appeal 28 USC 158 0 400 State Reapportionmento 120 Marine 0 310 Airplane 0 362 Personal Injury o 620 Other Food & Drug o 423 Withdrawal 0 410 Amitrusto DO Miller Act a 315 Airplane Product Med. Malpractice a 625 Drug Related Seizure 28 USC 157 0 430 Banks and Bankingo 140 Negotia ble Instrument Liability 0 365 Personal Injury - of Property 21 USC 881 0 450 Commerceo 150 Recovery of Overpayment 0 320 Assault, Libel & Product Liability o 630 Liquor Laws PROPERTY RIGHTS 0 460 Deportation& Enforcementof Judgment Slander 0 368 Asbestos Personal o 640 RK & Truck 0 820 Copyrights 0 470 Racketeer Influenced and0 151 Medicare Act 0 330 Federal Employers' Injury Product o 650 Airline Regs. 0 830 Patent Corrupt Organ zationso 152 Recovery 0 f Defaulted Liability Liability ::J 660 Occupational :l!I 840 Trademark 0 480 Consumer Credit

Student Loans 0 340 Marine PERSONAL PROPERTY Safety/Health 0 490 Cable/Sat TV (ExcL Veterans) 0 345 Marine Product 0 370 Other Fraud o 690 Other 0 810 Selective Service o 153 Recovery of Overpayment Liability 0 371 Truth in Lending .ABOR SOCIAL SI':(,[ RI 'Y '- ::J 850 Securities/Commodities!of Veteran' s Benefit'; 0 350 Motor Vehicle 0 380 Other Personal o 7 I0 Fair Labor Standards o 861 HIA (13951'1) Exchangeo 160 Stockholders' Suits 0 355 Motor Vehicle Property Damage Act o 862 Black Lung (923) 0 875 Customer Challengeo 190 Other C cntract Product Liability 0 385 Property Damage o no LaborlMgmt. Relations o 86] D1WC/DIWW (405(g)) 12 USC ]4100 195 Contract Product Liability 0 360 Other Personal Product Liability o 7] 0 LaborlMgmt.Reporting o 864 SSID Title XVI 0 890 Other Statutory Actionso 196 Franchise Injury & Disclosure Act o 865 RSI (405(gj) 0 891 Agricultural ActsREAL PROPERTY CI TIONS o 740 Railway Labor Act FEDERAL TAX SUITS 0 892 Economic Stabilization Ac-::J 210 Land Condemnation a 441 Voting 0 510 Motions to Vacate o 790 Other Labor Litigation o 870 TaKes (U-S_ Plaintiff 0 893 Environmental Matterso 220 Foreclosure 1'J 442 Employment Sentence o 791 EmpL Ret. Inc. or Defendant) 0 894 Energy Allocation Acto 230 Rent Lease & Ejectment a 443 1'lousin!Y' Ibbeas Corpus: Security Act o 871 IRS-Third Party 0 895 Freedom of Infonnation:J 240 Torts to Land Accommodations 0 530 General 26 USC 7609 Acto 245 Tort Product Liability 0 444 Wellare 0 535 Death Penalty IMMIGRATION 0 900Appeal of Fee Delenninatioo 290 A I Other Real Property 0 445 Amer. w/Disabilities- 0 540 Mandamus & Other o 462 Naturalization Application Under Equal Access

Employment 0 550 Civil Rights o 463 Habeas Corpus- to Justice 0 446 Amer. w/Disabilities - 0 555 Prison Condition Alien Detainee 'J 950 Constitutional ity 0 f Other o 465 Other Immigration Stare Statutes0 440 Other Civil Rights Actions

V. O R I G I N (Place an "X " in One Box Only) Appeal to Districo I Original o 2 Removed from 0 3 Remanded from o 4 Reinstated or 0 5 Transferred trom 0 6 Multidistrict CJ 7 Judge tromMagistrate. Reopened another dlstnct . Litigalions eetl Jud entroceeding State Court Appellate CourtV I. C A U S E O F A C T I O N Brief description of cause:T r a d e d r e s s i n t r i n g em en t , u n t a l r co m p et i t i o n , f a l s e d escr ip t i o n , a n d r e la ted s t a t e la w c l a i m sVII. R E Q U E S T E D IN o CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YE S only if detronded in complaint:

C O M P L A I N T : UNDER F.R.C.P. 23 1 , 5 0 0 , 0 0 0 , 0 0 JURY DEMAND: >If Ye s 0 NoVII I . R E L A T E D C A S E ( S ) (See instructionsl: IF ANY DOCKET NUMBERDATE10/06/2011

FOR OFFICE lJSE ONL YRECEIPT #_____ ANIOUNT_______ _ APPL YlNG IFP JUDGE MAG. JUDGE

Case 3:11-cv-01204-BR Document 1-1 Filed 10/06/11 Page 1 of 1 Page ID#: 14

douglas v keno trademark complaint

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