infirst healthcare v. cocoa cough - trademark complaint.pdf

8/10/2019 Infirst Healthcare v. Cocoa Cough - trademark complaint.pdf

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IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF DELAWARE

INFIRST HEALTHCARE LIMITED, ))

Plaintiff, ))v. )

)COCOA COUGH, )

)Defendant. )

C.A. No. 14-1059-LPS/CJB

JURY TRIAL DEMANDED

AMENDED COMPLAINT

Plaintiff Infirst Healthcare Limited ("Infirst" or "Plaintiff ') complains of Defendant

Cocoa Cough (or "Defendant") as follows:

NATURE OF LAWSUIT

1. This action is for (i) patent infringement of federally issued patents in violation

of the United States, Title 35 of the United States Patent Act, 35 U.S.C. 271(a)-(c); (ii) false

advertising and false representation, and unfair competition in violation of Section 43(a) of the

United States Trademark Act, 15 U.S.C. 1125(a); (iii) consumer fraud in violation of the

Delaware Consumer Fraud Act, 6 Del. 2531; (iv) deceptive trade practices in violation of the

Delaware Consumer Fraud Act, 6 Del. 2532; and (v) related claims of common law unfair

competition, false advertisement, trade libel, injury to business reputation, and unjust enrichment

under Delaware law.

THE PARTIES

2. Infirst is a company incorporated under the laws of England and Wales with

company number 08077285.

3. On information and belief, Defendant Cocoa Cough has a principal place of

Case 1:14-cv-01059-LPS-CJB Document 7 Filed 11/20/14 Page 1 of 23 PageID #: 32


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business at 492 South 1440 West, Provo, Utah, 84601. On information and belief, its principal

officers are Mr. Taylor Stauss and Mr. Bren Ty McRae.

JURISDICTION AND VENUE

4. This is an action for patent infringement arising under the patent laws of the

United States of America, Title 35 U.S.C. 1, et seq., unfair competition and false advertising

arising under the trademark laws of the United States of America, Title 15 U.S.C. 1, et seq.,

and the Delaware Deceptive Trade Practices Act, Del. Code Ann. Tit. 6 2531, et seq., and for

unfair competition, false advertising, trade libel and unjust enrichment under the common law of

Delaware.5. This Court has subject matter jurisdiction over the claims herein pursuant to 15

U.S.C. 1121 and 28 U.S.C. 1331 and 1338(a), and supplemental jurisdiction over claims

herein arising under the statutory and common law of the State of Delaware pursuant to 28

U.S.C. 1367(a) because the state law claims are so related to the federal claims that they form

part of the same case or controversy.

6. This Court has personal jurisdiction over Defendant Cocoa Cough because

Defendant Cocoa Cough has done, and continues to do business within this judicial district

related to the unlawful activities at issue in this Amended Complaint, because the acts

complained of herein have been directly and specifically intended to cause harm to Infirst within

this judicial district and because the harm suffered by Infirst within this judicial district flows

directly from such business conducted by Defendant.

7. Venue in this judicial district is proper under 28 U.S.C. 1391(b), (c) and/or

1400(b) in that a substantial part of the events giving rise to the claims herein have taken place

and may still be taking place in this judicial district.



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FACTS COMMON TO ALL COUNTS

8. Infirst operates a pharmaceutical company which makes, sells, and offers for

sale a line of cough and cold suppressing products for children under the brand name Dr.

Cocoa .

9. Dr. Cocoa Non-Drowsy Cough comprises cocoa, which contains the

chocolate flavoring ingredient theobromine, and the active ingredient Dextromethorphan with 1)

a recommended dose of 7.5 mg of Dextromethorphan every 6-8 hours for children ages 4 to

under 6 years of age and a maximum daily dose of 30 mg; 2) a recommended dose of 15 mg of

Dextromethorphan every 6-8 hours for children ages 6 to under 12 years of age and a maximumdaily dose of 60 mg; and 3) a recommended dose of 30 mg of Dextromethorphan every 6-8 hours

for children ages 12 to under 13 years of age and a maximum daily dose of 120 mg.

10. Dr. Cocoa Daytime Cough and Cold comprises cocoa, which contains the

chocolate flavoring ingredient theobromine, and the active ingredient Dextromethorphan with 1)

a recommended dose of 5 mg of Dextromethorphan every 4 hours for children ages 4 to under 6

years of age and a maximum daily dose of 30 mg; 2) a recommended dose of 10 mg of

Dextromethorphan every 4 hours for children ages 6 to under 12 years of age and a maximum

daily dose of 60 mg; and 3) a recommended dose of 20 mg of Dextromethorphan every 4 hours

for children ages 12 to under 13 years of age and a maximum daily dose of 120 mg.

11. Efforts to develop the Dr. Cocoa line of cough and cold suppressing products

commenced in 2010. The total cost of this development program is substantial and includes

significant costs of manufacturing product, conducting clinical trials, licensing royalties, and

patenting and trademark procurement and maintenance costs.

12. Marketing support for the Dr. Cocoa line of cough and cold suppressing



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products in the United States commenced in 2013 and to date the total amount spent is in excess

of $1.2 million.

13. Commercial sales into the retail trade of the Dr. Cocoa line of cough and cold

suppressing products in the United States in 2014 currently stands at more than 300,000 units

with a unit price of $8.99.

14. Dextromethorphan was approved by the Federal Drug Administration (FDA) in

1958 as an over-the-counter antitussive agent and can be sold directly to a consumer without a

prescription from a healthcare professional because the FDA has deemed that Dextromethorphan

is safe and effective for use by a consumer without the need of a physician's care.15. The marketing of cough suppressing products for children is a highly

competitive market that is extremely dependent on brand loyalty, such that damage to the

reputation of a brand can directly cause a loss of customers.

16. Defendant makes, sells, and offers for sale a line of cough suppressing products

for children under the brand name Cocoa Cough .

17. Incorporated into Cocoa Cough is cocoa, which contains the chocolate

flavoring ingredient theobromine, in admixture with inert, solid, or liquid carriers, additives

and/or auxiliary agents.

18. Upon information and belief, Defendant regularly advertises, promotes, offers

its cough suppressing products for sale, and otherwise regularly transacts business in the United

State of America, including within the State of Delaware through its website

www.cocoacough.com. The unit price for its cough suppressing product is $8.99.

19. On information and belief, Defendant further advertises and promotes its cough

suppressing products on a website blog called The Supplemental Blog at



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thesupplementblog.com/2014/03/14/cocoa-cough-vs-dr-cocoa, where it provides a comparison of

its cough suppressing products for children with Infirsts Dr. Cocoa cough and cold suppressing

products and makes statements that are intended to mislead a potential customer into buying

Cocoa Cough instead of Dr. Cocoa .

DEFENDANT'S ACTS OF PATENT INFRINGEMENT

20. Infirst is the owner, by assignment, of U.S. Patent No. 6,348,470 (the '470

Patent) issued February 19, 2002 and entitled "Antitussive Compositions" (copy attached as

EXHIBIT A). Infirst owns all right, title, and interest in, and has standing to sue for

infringement of the '470 Patent.21. The '470 Patent is directed to methods of stimulating mucociliary clearance to

alleviate irritable cough in a person by administering an effective amount of theobromine and/or

one of its salts optionally in admixture with inert, solid, or liquid carriers, additives and auxiliary

agents. Such method is used to treat cough.

22. The '470 Patent was properly and duly issued by the United States Patent and

Trademark Office and is presumed to be valid.

23. On August 18, 2014, Infirst, through counsel, notified Mr. Taylor Stauss and Mr.

Bren Ty McRae of Cocoa Cough via certified U.S. Mail and email of Infirst's patent. This letter

listed the '470 Patent as well as its Canadian counterpart covering cough suppressing products

comprising theobromine. This letter is attached as EXHIBIT B.

24. This letter also notified Defendant that one or more claims of the '470 Patent can

be found to read on the Cocoa Cough line of cough suppressing products made, sold, offered

for sale and used by Defendant.

25. As a result, Defendant has been on notice of the '470 Patent and acted despite an



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objectively high likelihood that its actions constituted infringement of Infirst's valid patents. At

least for this reason, Cocoa Cough' s infringement is believed to be willful.

26. On August 19, 2014, Defendant responded to Infirsts August 18, 2014 letter

denying its product infringe of the '470 Patent. This letter is attached as EXHIBIT C.

27. On October 5, 2014, Infirst, through counsel, notified Mr. Bren Ty McRae of

Cocoa Cough via certified U.S. Mail and email that the rationale used for its non-infringement

analysis had no legal basis and that Defendants Cocoa Cough line of cough suppressing

products infringed the '470 Patent. This letter is attached as EXHIBIT D. At least for this

reason, Cocoa Cough' s infringement is believed to be willful.28. On October 7, 2014, Defendant responded to Infirsts October 5, 2014 letter

stating that it had no intention to discontinue the sale of Cocoa Cough. This letter is attached as

EXHIBIT E.

29. Defendant has been and is infringing the '470 Patent under 35 U.S.C. 271(a) by

making, using, offering for sale, and selling the Cocoa Cough line of cough suppressing

products covered by one or more claims of the '470 Patent.

30. The Cocoa Cough line of cough suppressing products made, offered for sale,

and sold by Defendant to third parties (i.e., the customers of Defendant) enable such third parties

to practice and make use of Cocoa Cough line of cough suppressing products. By providing

such products to customers along with the directions and training to allow such customers to

perform, practice and utilize the cough suppressing products, Defendant induces such customers

and third parties to practice the methods disclosed and claimed in '470 Patent and thereby cause

such customers and third parties to directly infringe one or more claims of at least the '470

Patent. Such products have been provided by Defendant with the knowledge that use of the



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Cocoa Cough line of cough suppressing products as intended and instructed by Defendant

would result in infringement of the '470 Patent.

31. As of July 25, 2014, Defendant has been offering for sale the Cocoa Cough

line of cough suppressing products using at least the website www.cocoacough.com hosted either

in the United States, Canada, or both. A print screen indicating these offers for sale is attached

as EXHIBIT F.

32. The Cocoa Cough line of cough suppressing products made, sold and

offered for sale by Defendant are specially adapted for use in practicing the methods disclosed

and claimed in the '470 Patent and can only be used to practice methods disclosed and claimed inthe '470 Patent. As such, the Cocoa Cough line of cough suppressing products made, sold and

offered for sale by Defendant are specially adapted for use in practicing the methods disclosed

and claimed in the '470 Patent and have no substantial non-infringing use. Defendant has made,

sold and offered for sale the Cocoa Cough line of cough suppressing products with knowledge

of the '470 Patent and with knowledge that the Cocoa Cough line of cough suppressing

products are specially adapted for use in practicing the method claimed by the '470 Patent and

have no substantial noninfringing use.

33. Defendant has been and is contributorily infringing the '470 Patent under 35

U.S.C. 271(c) by offering to sell or selling within the United States or importing into the

United States the Cocoa Cough line of cough suppressing products, or at least one component

thereof, which constitute a material part of the invention recited in the Claims of the '470 Patent,

knowing the same to be especially made or especially adapted for use in an infringement of such

patent.



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DEFENDANT'S ACTS OF UNFAIR COMPETION AND FALSE ADVERTISING

34. Infirst is the owner, by assignment, of U.S. Trademark Application 85/700,783

(783 Application) for the literal word mark DR. COCOA for goods and services pertaining to

pharmaceutical preparations for the treatment of respiratory cough, cold and pain relief,

containing cocoa and having a cocoa flavor (IC 005. US 006 018 044 046 051 052). A statement

of use was filed and accepted with the US Patent and Trademark Office on October 27, 2014.

35. Infirst is the owner, by assignment, of U.S. Trademark Application 85/892,150

(150 Application) for the stylized word mark DR. COCOA for goods and services pertaining to

pharmaceutical preparations for the treatment of respiratory cough, cold and pain relief,containing cocoa and having a cocoa flavor (IC 005. US 006 018 044 046 051 052). A statement

of use was filed and accepted with the US Patent and Trademark Office on September 2, 2014.

36. Infirst owns all right, title, and interest in, and has standing to sue for

infringement, unfair competition, and false advertising of the 783 and 150 trademark

applications.

37. In advertising, promoting and offering to sell its Cocoa Cough line of cough

suppressing products, Defendant has been and as is maintaining The Supplemental Blog that is

devoted principally to denigrating the safety and efficacy of Infirsts Dr. Cocoa line of cough

and cold suppressing products through the use of false and completely unsubstantiated

allegations and claims.

38. In advertising, promoting and offering to sell its Cocoa Cough line of cough

suppressing products, Defendant has made numerous false and misleading representations

concerning Infirsts Dr. Cocoa line of cough and cold suppressing products, including the

following:



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a. Defendants mislead and continue to mislead consumers into thinking that

a side-by-side comparison was conducted when Defendants state

Two Companies have released a chocolate flavored cough syrup. Which

one works better? Here is how they stack up.

b. Defendants mislead and continue to mislead consumers into thinking that

Cocoa Cough is a clinically effective cough medication useful in treating cough in

children with the statements

Cocoa Cough is new for 2013 and is the first cough syrup to be flavored

with chocolate. Its main ingredients include cocoa powder, theobromine,and buckwheat honey. Cocoa Cough is an all-natural anytime formula

that is safe for children 1 years old and up. It uses clinically proven

ingredients that are recommended for coughs. Cocoa Cough is a very

well thought out all-natural cough syrup and is available online at

cocoacough.com. It is perfect for the whole family.

c. Defendants make unsubstantiated statement regarding the effectiveness of

cocoa powder in comparison to codeine with the statements

Pure Cocoa Powder: 100% cocoa powder recently has been shown to be

33% more effective than codeine for coughs in some clinical studies. It is

also a safe natural alternative to codeine.

d. Defendants mislead and continue to mislead consumers into thinking that

dextromethorphan is generally not recommended for the treatment of cough with the

statements

Dr. Cocoa is a new cough syrup for 2014 and its [sic] main ingredient is



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dextromethorphan and Cocoa. Some people respond well to

dextromethorphan but it is generally not recommended since there are

more natural alternatives out there that are more effective such as

buckwheat honey which is found in Cocoa Cough.

e. Defendants mislead and continue to mislead consumers into thinking that

Infirsts Dr. Cocoa line of cough and cold suppressing products are unhealthy and

not safe for children with the statement

The one major complaint about Dr. Cocoa is that it does not contain

anything healthy besides cocoa powder.f. Defendants mislead and confuse and continue to mislead and confuse

consumers into thinking that its Cocoa Cough line of cough suppressing products

is superior to Infirsts Dr. Cocoa line of cough and cold suppressing products

containing the FDA approved API dextromethorphan, but then state

Disclaimer: Cocoa Cough is 100% natural and does not claim to treat or

cure any types of disease. It is a dietary supplement that may relieve

cough symptoms.

39. The unambiguous message and necessary implication conveyed by Defendants

misrepresentation is that Infirsts Dr. Cocoa line of cough and cold suppressing products is

unhealthy, unsafe, ineffective and exceedingly inferior to Defendants Cocoa Cough line of

cough suppressing products.

40. On October 5, 2014, Infirst, through counsel, notified Mr. Bren Ty McRae of

Cocoa Cough via certified U.S. Mail and email that Cocoa Coughs posting or publishing of the

comparison article on the website blog called The Supplemental Blog at



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thesupplementblog.com/2014/03/14/cocoa-cough-vs-dr-cocoa constituted, among other things,

false advertising and false representation, and unfair competition in violation of Section 43(a) of

the United States Trademark Act, 15 U.S.C. 1125(a) and requested immediate removal of this

posting. This letter is attached as EXHIBIT D.

41. On October 7, 2014, Defendant responded to Infirsts October 5, 2014 letter

stating that the Defendant had no intention of removing the post from thesupplementblog.com.

This letter is attached as EXHIBIT E.

42. Upon information and belief, Defendants foregoing representations are

materially false and misleading.43. Upon information and belief, Defendants foregoing representations are

unsubstantiated and, upon information and belief, Defendant does not possess scientific evidence

to support the above representations challenging the safety and efficacy of dextromethorphan or

proving the superior efficacy of cocoa powder over codeine in suppressing cough.

44. Upon information and belief, Defendants false and misleading representations

directed against Infirst and its Dr. Cocoa line of cough and cold suppressing products were

willful and malicious and with a deliberate intent to mislead consumers and cause injury to

Infirst.

45. Upon information and belief, Defendants false and misleading representations

directed against Infirst and its Dr. Cocoa line of cough and cold suppressing products were

willful and malicious and intended to injure and trade upon the reputation of Infirst and its

products and thereby cause harm to Infirst.

46. Upon information and belief, Defendants false and misleading statements as

aforementioned have directly injured Infirst, its reputation, and its goodwill, and, upon



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information and belief, have caused lost sales.

COUNT I

Direct Patent Infringement

47. Infirst restates and incorporates by reference paragraphs 1 through 33 above as

if fully re-stated herein.

48. Defendant's activities and actions as-alleged in at least paragraphs 1-30 above

constitute direct infringement of the '470 Patent in violation of 35 U.S.C. 27l(a). For reasons

stated in at least paragraphs 23-28 above, such direct infringement by Defendant is believed to be

willful.49. Defendant's direct infringement, has injured and will continue to injure Infirst

unless and until the Court enters an injunction prohibiting further infringement and, specifically,

enjoining further manufacture, use, importation, sale and/or offer for sale of products or

technologies that fall within the scope of the '470 Patent claims.

COUNT II

Induced Patent Infringement

50. Infirst restates and incorporates by reference paragraphs 1 through 33 above as

if fully re-stated herein.

51. Defendant's activities and actions as alleged in at least paragraphs 1-30 and 32

above constitute induced infringement of the '470 Patent in violation of 35 U.S.C. 271(b). For

reasons stated in at least paragraphs 23-28 above, such induced infringement by Defendant is

believed to be willful.

52. Defendant's induced infringement, has injured and will continue to injure Infirst

unless and until the Court enters an injunction prohibiting further infringement and, specifically,



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enjoining further manufacture, use, importation, sale and/or offer for sale of products or

technologies that fall within the scope of the '470 Patent claims.

COUNT III

Contributory Patent Infringement

53. Infirst restates and incorporates by reference paragraphs 1 through 33 above as if

fully re-stated herein.

54. Defendant's activities and actions as alleged in at least paragraphs 1-30 and 33

above constitute contributory infringement of the '470 Patent in violation of 35 U.S.C. 27l(c).

For reasons stated in at least paragraphs 23-28 above, such contributory infringement byDefendant is believed to be willful.

55. Defendant's contributory infringement, has injured and will continue to injure

Infirst unless and until the Court enters an injunction prohibiting further infringement and,

specifically, enjoining further manufacture, use, importation, sale and/or offer for sale of

products or technologies that fall within the scope of the '470 Patent claims.

COUNT IV

Unfair Competition and False Advertising

56. Infirst restates and incorporates by reference paragraphs 1 through 19 and 34-46

above as if fully re-stated herein.

57. Upon information and belief, Defendant has knowingly disparaged Infirsts

goods, services, and business by false and/or misleading advertising and promotional statements,

and by misleading representations of fact and has knowingly created consumer confusion,

consumer mistake or misunderstanding, and/or deceived or mislead consumers about Infirsts

goods, services, and business.



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58. Defendants false and misleading advertising and promotional statements and

misrepresentations of fact regarding Infirsts goods, services, and business are material to

consumer purchasing decisions and constitute unfair competition and false advertising in

violation of 15 U.S.C. 1125(a).

59. Defendants conduct has been and continues to be intentional and willful.

60. As a direct and proximate result of Defendants conduct, Infirst has suffered

great and irreparable injury, and unless such conduct is enjoined, Infirst will continue to suffer

great and irreparable injury.

61. Infirst has no adequate remedy at law.

62. Infirst is entitled to a preliminary and permanent injunction against Defendant,

as well as other remedies available at law, including but not limited to compensatory damages,

treble damages, statutory damages, disgorgement, costs, and attorneys fees.

COUNT V

Consumer Fraud



64. The State of Delaware has an important interest in ensuring that persons and

entities doing business with Delaware residents comply with Delaware law and the false and

misleading statements of Defendant implicate the public interest.







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consumer purchasing decisions and constitute unlawful deceptive trade practices in violation of

Delaware Consumer Fraud Act, 6 Del. 2532.



great and irreparable injury, and unless such conduct is enjoined, Infirst will continue to suffer great and irreparable injury.





COUNT VII

Common Law Unfair Competition










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consumer purchasing decisions and constitute unfair competition in violation of the common law

of Delaware.


83. As a direct and proximate result of Defendants conduct Infirst has suffered great

and irreparable injury, and unless such conduct is enjoined, Infirst will continue to suffer great

and irreparable injury.





COUNT VIII

Common Law False Advertisement












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consumer purchasing decisions and constitute false advertising in violation of the common law

of Delaware.







as well as other remedies available at law, including but not limited to compensatory damages,treble damages, statutory damages, disgorgement, costs, and attorneys fees.

COUNT IX

Common Law Trade Libel










consumer purchasing decisions and constitute trade libel in violation of the common law of

Delaware.



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great and irreparable injury, and unless such conduct is enjoined, plaintiff will continue to suffer






COUNT X

Common Law Injury to Business Reputation










consumer purchasing decisions and constitute injury to business reputation in violation of the

common law of Delaware.





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COUNT XI

Common Law Unjust Enrichment










consumer purchasing decisions and constitute unjust enrichment in violation of the common law

of Delaware.







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PRAYER FOR RELIEF

WHEREFORE, Infirst asks this Court to enter judgment against Defendants and against

its subsidiaries, affiliates, agents, servants, employees and all persons in active concert or

participation with them, granting the following relief:

A. A declaration, adjudgment or decree that Defendants aforesaid acts

constitute direct, contributory, and/or inducement of infringement of Infirsts '470 Patent in

violation of 35 U.S.C. 271(a)-(c); false advertising and false representation, and unfair

competition in violation of 15 U.S.C. 1125(a); consumer fraud in violation of the Delaware

Consumer Fraud Act, 6 Del. 2531; deceptive trade practices in violation of the Delaware

Consumer Fraud Act, 6 Del. 2532; and unfair competition, false advertisement, trade libel,

injury to business reputation, and unjust enrichment under the common law of the State of

Delaware;

B. An award of damages adequate to compensate Infirst for the

infringement that has occurred, together with prejudgment interest from the date infringement of

the '470 Patent began;

C. An award of increased damages as permitted under 35 U.S.C. 284;

D. A finding that this case is exceptional and an award to Infirst of its

attorneys' fees and costs as may be appropriate under 35 U.S.C. 285;

E. A grant of preliminary and permanent injunctions enjoining further



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infringement, inducement and contributory infringement of the '470 Patent;

F. A grant of preliminary and permanent injunctions enjoining Defendant

from making false or misleading statements concerning Infirst or its Dr. Cocoa line of cough

and cold suppressing products;

G. A grant of preliminary and permanent injunctions enjoining Defendant

from profiting from Infirsts mark or name;

H. A grant of preliminary and permanent injunctions enjoining Defendant

from competing unfairly with Infirst or trading upon the goodwill of Infirst;

I. A grant of preliminary and permanent injunctions enjoining Defendant

from publishing the comparison article on the website blog called The Supplemental Blog at

thesupplementblog.com/2014/03/14/cocoa-cough-vs-dr-cocoa or otherwise posting or displaying

such material at any other website or in any other media;

J. An award of treble damages as provided by law;

K. An award of exemplary damages as provided by law;

L. An award of reasonable attorney fees and costs for this action as

provided by law;

M. Pre-judgment interest calculated from the time of the first occurrence of

any infringing activity through and until entry of judgment;

N. Post-judgment interest calculated from entry of a final judgment in this

matter until such time as the final judgment is fully satisfied; and

O. Such other and further relief as this Court or a jury may deem proper and

just.



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JURY DEMAND

Pursuant to Federal Rule of Civil Procedure 38(b), Infirst demands a trial by jury on all

issues presented in this Amended Complaint.

OF COUNSEL:

Peter D. WeinsteinONE3 IP MANAGEMENT, P.C.1560-1 Newbury Rd, #327 Newbury Park, CA 91320

(805) 499-7305Dean G. StathakisONE3 IP MANAGEMENT5405 Alton Parkway, Suite 5A, 764Irvine, CA 92604(949) 954-7988

Dated: November 20, 20141173012

POTTER ANDERSON & CORROON LLP

By: /s/ Philip A. Rovner Philip A. Rovner (#3215)Jonathan A. Choa (#5319)Hercules PlazaP.O. Box 951

Wilmington, DE 19899(302) 984-6000 [email protected] [email protected]

Attorneys for Plaintiff InFirst Healthcare Limited


infirst healthcare v. cocoa cough - trademark complaint.pdf

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