Case 1:14-cv NLH-JS Document 1 Filed 08/26/14 Page 1 of 20 PageID: 1
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1 Case 114-cv NLH-JS Document 1 Filed 08/26/14 Page 1 of 20 PageID 1 FOX ROTHSCHILD LLP By Christopher R. Kinkade Christopher D. Olszyk Michael J. Leonard (Pro Hac Vice Application to be filed) Princeton Pike Corporate Center 997 Lenox Drive, Building 3 Lawrenceville, NJ Telephone (609) Facsimile (609) Attorneys for Plaintiff Seabrook House, Inc. IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY SEABROOK HOUSE, INC., Plaintiff, CIVIL ACTION NO. v. JURY TRIAL DEMANDED ELEMENTS BEHAVIORAL HEALTH, INC., and RECOVERY BRANDS, LLC, d/b/a Rehabs.com, d/b/a Drugabuse.com, d/b/a and 4rehabs.com Defendants. COMPLAINT FOR INJUNCTIVE RELIEF, DAMAGES AND JURY DEMAND (Document Filed Electronically) Plaintiff, Seabrook House, Inc., in its complaint against Defendants, Elements Behavioral Health, Inc. and Recovery Brands, LLC alleges and states as follows
2 Case 114-cv NLH-JS Document 1 Filed 08/26/14 Page 2 of 20 PageID 2 INTRODUCTION 1. This is an action at law and in equity, for the recovery of damages and injunctive relief, for Trademark Infringement and Unfair Competition arising under the Trademark Act of 1946, 15 U.S.C. 1051, et seq. ("Lanham Act") and the New Jersey Common and Statutory Law. 2. Defendants Elements Behavioral Health, Inc. and Recovery Brands, LLC ( Defendants ) have misappropriated and are using Plaintiff Seabrook House, Inc. s valuable service marks SEABROOK HOUSE and SEABROOK in the marketing, advertising, promotion, offering and rendering of services in the field of addiction treatment. Together, Defendants have developed a series of drug addiction treatment websites purportedly acting as searchable directories for those in need of treatment attempting to contact or locate named facilities and/or facilities in their area, yet unknown to the site visitors, these websites are paid advertisements for Defendant Elements, matching the search results by the visitor with a number that leads directly to a Defendant Elements-operated call center, which quickly diverts the prospective patient to one of the many Defendant Elements-owned facilities. Defendants rendering of this web of deceptive and misleading advertisements using the valuable SEABROOK HOUSE and SEABROOK trademarks (and many other third party competitor trademarks) for their own related and/or identical services, has, and is likely to continue to cause confusion and to deceive consumers and the public regarding their source. THE PARTIES 3. Plaintiff Seabrook House, Inc. (hereinafter Seabrook or Plaintiff ) is a corporation duly organized and existing under the laws of the State of New Jersey, and is located and doing business at 133 Polk Lane, Bridgeton, New Jersey
3 Case 114-cv NLH-JS Document 1 Filed 08/26/14 Page 3 of 20 PageID 3 4. Defendant Elements Behavioral Health, Inc. (hereinafter Elements ) is a corporation duly organized and existing under the laws of the State of Delaware, and doing business at various locations across the United States, with a headquarters at 5000 E. Spring, Street, Suite 650, Long Beach, California Defendant Recovery Brands, LLC (hereinafter Recovery Brands ) is a limited liability company duly organized and existing under the laws of the State of California, doing business at th Avenue, #401, San Diego, California JURISDICTION AND VENUE 6. This Court has jurisdiction over the subject matter of this action pursuant to 15 U.S.C (Trademark/Unfair Competition), 28 U.S.C (Federal Question Jurisdiction) and 1338 (Trademark). 7. This Court has supplemental jurisdiction over the non-federal claims pursuant to 28 U.S.C. 1338(b) and 1367(a), as they are part of the same case or controversy as the claims arising under the laws of the United States. 8. Venue is proper in this jurisdiction district pursuant to 28 U.S.C. 1391(b), because Defendants conduct substantial business and are subject to personal jurisdiction in this District. 9. This Court has personal jurisdiction over the Defendants because Defendants have offered and rendered services under infringing trademarks within this District, have engaged in acts or omissions within this District causing injury to Plaintiff, have engaged in acts or omissions outside of the State of New Jersey causing injury to Plaintiff within this District, and have otherwise made or established contact within this District sufficient to permit the exercise of personal jurisdiction. 3
4 Case 114-cv NLH-JS Document 1 Filed 08/26/14 Page 4 of 20 PageID 4 FACTUAL BACKGROUND PLAINTIFF SEABROOK AND THE SEABROOK TRADEMARKS 10. Plaintiff is a private and exclusive drug and alcohol treatment center and detoxification program headquartered in Bridgeton, New Jersey, with locations throughout New Jersey and Pennsylvania, offering addiction treatment services. 11. Since as early as 1974, Plaintiff has marketed and rendered its addiction treatment services throughout the United States. 12. Plaintiff is the owner of the common law trademark rights in SEABROOK and SEABROOK HOUSE (the SEABROOK Marks ), of which SEABROOK HOUSE is also the subject of Application Serial No. 86/371,204 (the SEABROOK HOUSE Application ), filed with the United States Patent and Trademark Office ( USPTO ) on August 19, 2014, for services described as addiction treatment services; rehabilitation for substance abuse patients (hereinafter Plaintiff s Services ). See attached Exhibit A (copy of SEABROOK HOUSE Application). 13. Plaintiff adopted and began using the SEABROOK Marks in interstate commerce at least as early as The SEABROOK Marks appear on virtually all Plaintiff marketing and advertising materials for Plaintiff s Services, including but not limited to being prominently displayed on Plaintiff s website located at Based on the distinctive character and nature of the SEABROOK Marks and the continuous and uninterrupted use of the SEABROOK Marks in interstate commerce, consumers have come to associate the SEABROOK Marks and services provided under the marks exclusively with Plaintiff. 15. Further, as a result of Plaintiff s highly distinctive and original SEABROOK Marks and years of superior service, Plaintiff has developed substantial and 4
5 Case 114-cv NLH-JS Document 1 Filed 08/26/14 Page 5 of 20 PageID 5 significant consumer recognition, trust, loyalty and goodwill in and to its SEABROOK Marks. Indeed, Plaintiff s establishment and maintenance of this public recognition, trust, loyalty and goodwill has been a significant factor in its financial growth and success. 16. Plaintiff has acquired strong common law rights in its SEABROOK Marks, based at least in part on its continuous and uninterrupted use of its SEABROOK Marks in commerce in connection with the advertising, sale and distribution of its services, among other things. Plaintiff s rights in its SEABROOK Marks are superior to any rights that Defendants may claim in and to the SEABROOK Marks or any mark that is confusingly similar thereto. 17. Plaintiff markets, promotes and advertises its addiction treatment services nationally and internationally to prospective patients looking for help treating alcohol and drug addiction problems. 18. Plaintiff employs the use of national marketing and internet-based advertising to promote its services under the SEABROOK Marks. 19. Plaintiff treats patients attracted from across the country and internationally, as it is not uncommon for patients to travel to a facility separate, and often a significant distance, from their home, family, friends and life in order to enroll in a facility known to offer highly successful treatment plans. DEFENDANT ELEMENTS 20. Defendant Elements is a direct competitor of Plaintiff, offering treatment and rehabilitation programs in drug and alcohol addiction, sex addiction, eating disorders, and mood and personality disorders. 21. Although headquartered in Long Beach, California, Defendant Elements offers treatment locations nationally in California, Pennsylvania, Utah, Florida, Texas, 5
6 Case 114-cv NLH-JS Document 1 Filed 08/26/14 Page 6 of 20 PageID 6 Tennessee, and Arizona, under such names as Clarity Way, Promises, Journey, Lucida, The Ranch, The Recovery Place, The Right Step and others. 22. Upon information and belief, Defendant Elements first offered its addiction treatment services in 2008 with the launch of its Promises locations. 23. Upon information and belief, much like Plaintiff, Defendant Elements draws customers/patients nationally, often as a result of national reputation and internet-based advertising to potential customers/patients seeking treatment for various addictions. 24. Defendant Elements also employs Regional Outreach Directors assigned to specific U.S. geographic territories, including multiple individuals covering both NJ, PA, and the Mid-Atlantic. According to content appearing on Defendant Elements web site at http// these individuals serve as a liaison during the admissions process, throughout the treatment period, and for the transition back to your [the patient s] practice. DEFENDANT RECOVERY BRANDS 25. Upon information and belief, Defendant Recovery Brands is an internet marketing company, focusing primarily on the addiction treatment industry. 26. As promoted on the Defendant Recovery Brands website ( its services include providing Internet directory sites and directory listings for treatment facilities, purportedly assisting consumers in finding the right treatment facility for their addiction treatment needs, as well as helpline support, and placing targeted advertisements on Defendant Recovery Brands family of addiction treatment sites. 27. Upon information and belief, Defendant Recovery Brands family of addiction treatment sites include, but are not limited to, ( Rehabs.com ) 6
7 Case 114-cv NLH-JS Document 1 Filed 08/26/14 Page 7 of 20 PageID 7 ( 4Rehabs.com ), ( DrugAbuse.com ), and ( Recovery.com ) (collectively the Recovery Brands Websites ), and likely many others, each offering similar directory, call center, and targeted advertising services for addiction treatment centers. 28. Upon information and belief, Defendant Elements and Defendant Recovery Brands are partners in operating the Recovery Brands Websites, providing addiction treatment center directory services, advertising Defendant Elements Promises centers, and working with Defendant Elements to operate call centers for each site. 29. Upon information and belief, the Recovery Brands Websites have all operated in a substantially similar manner since THE RECOVERY BRANDS WEBSITES Website Rehabs.com 30. Each of the Recovery Brands Websites present initially as a basic online directory, providing information about a wide variety of addiction treatment facilities nationally. 31. The Rehabs.com site, for example, offers a search function where one may insert their zip code and/or search for a particular name or location of a facility directly. See attached Exhibit B (Rehabs.com webpages). 32. When one inserts the name or location of a particular addiction treatment facility in the Rehabs.com search engine, a results page appears, identifying the location searched. When the term SEABROOK HOUSE is searched, a page describing the Seabrook House location and (until recently) a photograph of the facility is displayed. See Ex. B. 33. Above the directory results on Rehabs.com for SEABROOK HOUSE is a large sponsor advertisement for one of Defendant Elements Promises locations. See Ex. B. 7
8 Case 114-cv NLH-JS Document 1 Filed 08/26/14 Page 8 of 20 PageID In addition to providing a photo and address for the SEABROOK HOUSE location on Rehabs.com, a toll free number appears prominently across the header of the page and across the bottom of the page. See Ex. B. 35. Upon information and belief, the number, specifically is an answering service/call center for Defendant Elements. 36. Upon information and belief, when one calls the number identified on the search results page, an operator attempts to divert the potential customer/patient to a facility owned and operated by Elements, rather than the originally intended facility searched. 37. To date, Plaintiff has never received a referral nor been connected to a potential customer/patient as a result of an inquiry made for Seabrook House via Rehabs.com. 38. Only after further recent complaints by Plaintiff have Defendants incorporated a second click-through page, which now references an actual phone number for Plaintiff. 39. Upon information and belief, potential customer/patients of Plaintiff s Seabrook House facilities, who have used the Rehabs.com directory, have been diverted from Plaintiff to Defendant Elements and/or a third-party treatment center recommended by Defendant Elements. Website DrugAbuse.com 40. At the website for DrubAbuse.com, a similar referral process occurs wherein a visitor of DrugAbuse.com will identify the state where they are looking for a treatment center, followed by the town. Following the selection of a town, the website returns a list of results. See attached Exhibit C (Drugabuse.com webpages). 8
9 Case 114-cv NLH-JS Document 1 Filed 08/26/14 Page 9 of 20 PageID For example, a search and selection for the term SEABROOK on DrugAbuse.com, found under the New Jersey listings, will return a page stating Seabrook Drug Abuse Treatment Programs, and thereafter describe the services as If illicit or prescription drug dependence is negatively affecting your professional and personal life, Seabrook, NJ has a selection of excellent drug abuse programs to help you, your spouse or your child. Whether addicted to Antipsychotics, opiate drugs, pain medication or alcohol, we can help you connect with rehabilitation to get the perfect help available. You can even find exclusive or executive treatment in Seabrook to make rehabilitation as easy as possible. This paragraph is then followed by the phrase Seabrook House James Franc Mulligan, MD, followed by the actual address for Plaintiff s Seabrook House. See Ex. C. 42. However, appearing on the header of the webpage, and at the center of the listing/advertisement for the Seabrook location, is a toll free number, specifically for potential customer/patients to call. See Ex. C. 43. Upon information and belief, the number, specifically is an answering service/call center for Defendant Elements. 44. Moreover, when one then clicks on the link on DrugAbuse.com for Seabrook House James Franc Mulligan, MD, one is taken to a page stating Seabrook House Mulligan James Franc MD has not yet added their full program details. To learn more call them at the number above, or call 1 (800) to talk to a helpful advisor about your options for addiction treatment (emphasis added). See Ex. C. Upon information and belief, that number above is the same number for Defendant Elements call center. 45. Upon information and belief, when one calls the number identified on the DrugAbuse.com search results pages, an operator attempts to divert the potential customer/patient to a facility owned and operated by Elements, rather than the originally intended location searched. 9
10 Case 114-cv NLH-JS Document 1 Filed 08/26/14 Page 10 of 20 PageID To date, Plaintiff has never received a referral nor been connected to a potential customer/patient as a result of an inquiry made for Seabrook House via Drugabuse.com. 47. Upon information and belief, potential customer/patients of Plaintiff s Seabrook House facilities, who have used the DrugAbuse.com directory, have been diverted from Plaintiff to Defendant Elements and/or a third party treatment center recommended by Defendant Elements. Website 4Rehabs.com 48. At the website for 4Rehabs.com, a far more egregious process occurred wherein a visitor of 4Rehabs.com would enter the site and enter the name of the treatment center they were looking for in the search directory. The search then returned the desired location. 49. When one inserted the name SEABROOK HOUSE in the search page for 4Rehabs.com, a results page accurately identified Plaintiff s Seabrook House facilities located at Bridgeton, New Jersey (with address). 50. The 4Rehabs.com site would also replicate selected written content and photographic material taken directly from Plaintiff s website homepage, describing Plaintiff s services using the exact content from Plaintiff s website to promote its SEABROOK HOUSE branded services. 51. In lieu of providing a phone number for Plaintiff, however, a separate toll free number appeared prominently across the header of the page and directly after the copied SEABROOK HOUSE website content, stating Need Guidance? Call to speak with an expert. 10
11 Case 114-cv NLH-JS Document 1 Filed 08/26/14 Page 11 of 20 PageID The phone number is not a number owned, operated, or in any way affiliated with Plaintiff. 53. Upon information and belief, the phone number that appeared with the Seabrook House directory listing on 4Rehabs.com is an answering service/call center for Defendant Elements. 54. Upon information and belief, when one called the number identified on the search results page, an operator attempted to divert the potential customer/patient to a facility owned and operated by Elements, rather than the originally intended location searched. 55. To date, Plaintiff has never received a referral nor been connected to a potential customer/patient as a result of an inquiry made for Seabrook House via 4Rehabs.com. 56. Upon information and belief, potential customer/patients of Plaintiff s Seabrook House facilities, who have used the 4Rehabs.com directory, have been diverted from Plaintiff to Defendant Elements and/or a third party treatment center recommended by Defendant Elements. 57. After recent complaints by Plaintiff to Defendant Elements about its deceptive advertising/marketing on the 4Rehabs.com website, which upon information a new homepage now appears stating Maintenance Mode and preventing visitors from accessing any further functionality of the website. See Ex. D (current 4Rehabs.com current webpage). 58. Despite the recent Maintenance Mode home page, absent Court intervention requiring a reconfiguration of the deceptive advertising, Plaintiff stands to be continually harmed by any reversion back to the pre-august Rehabs.com site functionality. 11
12 Case 114-cv NLH-JS Document 1 Filed 08/26/14 Page 12 of 20 PageID 12 COUNT I FALSE DESIGNATION OF ORIGIN, PASSING OFF, AND UNFAIR COMPETITION (FEDERAL LANHAM ACT VIOLATION 15 U.S.C. 1125(A)) 59. Plaintiff repeats and realleges each and every allegation of paragraphs 1 through 58 as though fully set forth herein. 60. As a result of longstanding and extensive use in interstate commerce and wide recognition among the addiction treatment community, for addiction treatment-related facilities and services, Plaintiff s SEABROOK Marks have become distinctive as an indicator of the source of addiction treatment facilities and services. The public associates and identifies the SEABROOK Marks with Plaintiff. 61. Defendants conduct in the offering, promoting, marketing, advertising and/or rendering of competing services using identical and infringing trademarks SEABROOK and SEABROOK HOUSE in their marketing and advertising on their jointly operated directory sites such as DrugAbuse.com, Rehabs.com, and 4Rehabs.com constitutes false designation of origin or sponsorship of said services and tends to falsely represent that said services originate from Plaintiff or that Defendants have been sponsored, approved, or licensed by Plaintiff or is in some way affiliated or connected with Plaintiff, when they are not. 62. Defendants conduct is likely to confuse, mislead, and deceive the users/consumers of Defendants services, and members of the public as to the origin of said infringing services, or cause said persons to believe that those infringing services or Defendants have been sponsored, approved, authorized, or licensed by Plaintiff or is in some way affiliated or connected with Plaintiff, all in violation of 15 U.S.C. 1125(a). 63. Defendants activities as aforesaid constitute use in commerce of Plaintiff s SEABROOK Marks. 12
13 Case 114-cv NLH-JS Document 1 Filed 08/26/14 Page 13 of 20 PageID Defendants actions were and are done willfully with full knowledge of the falsity of such designations of origin and false description or representations, and with the express intent to cause confusion, mislead and deceive the purchasing/consuming public, to trade upon the high quality reputation of Plaintiff, and to improperly appropriate the valuable trademark/service mark rights of Plaintiff, all to the detriment of Plaintiff. 65. Defendants acts as aforesaid constitute false designation of origin, passing off, and unfair competition in connection with services rendered in interstate commerce, in violation of Section 43(a) of the Lanham Act, 15 U.S.C. 1125(a). 66. Defendants unauthorized use of marks confusingly similar to Plaintiff s SEABROOK Marks is greatly and irreparably damaging to Plaintiff in the form of (a) loss of income (ability to secure new patients/customers shopping for treatment facilities); (b) interference with Plaintiff s ability to exploit its own rights in the SEABROOK Mark; (c) confusion in the marketplace as to the duly authorized source of services rendered in conjunction with Plaintiff s SEABROOK Marks; and (d) impairment of the goodwill that Plaintiff has developed in the SEABROOK Marks, and, if Defendants unauthorized use is not enjoined, will continue to cause irreparable damage to the rights of Plaintiff in its SEABROOK Marks and to the respective business, reputation, and goodwill of Plaintiff. 67. Plaintiff has no adequate remedy at law, and if Defendants activities are not enjoined, Plaintiff will suffer irreparable harm and injury as a result thereof. 68. Plaintiff will be further harmed by the fact that it has no control over the quality of the services rendered by Defendants (both the treatment services offered by Defendant Elements and the marketing/advertising of those services as offered by both Defendants on the 13
14 Case 114-cv NLH-JS Document 1 Filed 08/26/14 Page 14 of 20 PageID 14 Recovery Brands Websites) and purchasers/consumers of those services may attribute to Plaintiff any dissatisfaction with the quality of Defendants services. 69. Defendants wrongful acts will continue unless enjoined by this Court. COUNT II STATE AND COMMON LAW TRADEMARK INFRINGEMENT 70. Plaintiff repeats and re-alleges each and every allegation of paragraphs 1 through 69 as though fully set forth herein. 71. Consumers have been and are likely to be confused by the similarity of Defendants use of the SEABROOK Marks in connection with the advertising, marketing, promotion, offer, and rendering of Defendant Elements services with those identical services offered under Plaintiff s SEABROOK Marks. 72. Defendants aforesaid acts constitute trademark/service mark infringement under the statutory and Common Law of New Jersey, including under N.J.S.A , as Defendants unauthorized use of the SEABROOK Marks in the advertisement, marketing, promotion, offer and rendering of its services to consumers residing in the State of New Jersey, is likely to cause confusion as to the source and origin of Defendants services. 73. The aforesaid acts of Defendants are greatly and irreparably damaging to Plaintiff and will continue to be greatly and irreparably damaging to Plaintiff unless enjoined by this Court, as a result of which Plaintiff is without an adequate remedy at law. COUNT III INTENTIONAL INTERFERENCE WITH PROSPECTIVE BUSINESS ADVANTAGE 74. Plaintiff repeats and re-alleges each and every allegation of paragraphs 1 through 73 as though fully set forth herein. 14
15 Case 114-cv NLH-JS Document 1 Filed 08/26/14 Page 15 of 20 PageID Upon information and belief, Defendants had knowledge of a prospective contractual relationship between customers/patients visiting the Recovery Brands Websites and Plaintiff. 76. Upon information and belief, Defendants intended to disrupt, harm and interfere with Plaintiff s relationship with these customers/patients by diverting them to Defendant Elements representatives and facilities via the use of the Recovery Brands Websites where competitor information could be viewed and additional Defendants-related and other services could be pitched. 77. Plaintiff never authorized such conduct by Defendants. 78. Plaintiff has been harmed by Defendants unauthorized conduct. COUNT IV CIVIL CONSPIRACY 79. Plaintiff repeats and re-alleges each and every allegation of paragraphs 1 through 78 as though fully set forth herein. 80. Each of the Defendants acted in concert with one another to misappropriate Plaintiff s SEABROOK Marks; to unfairly compete by use of advertising, promotion and marketing efforts on the Recovery Brands Websites, using Plaintiff s SEABROOK Marks to attract Plaintiff patients for enrollment, but thereafter divert them to competing Defendant Elements services, among other forms of culpable conduct. 81. Defendants, by reason and virtue of the conduct alleged herein, wrongfully and unlawfully acted in concert, and thus intentionally and deliberately conspired to misappropriate and infringe Plaintiff s SEABROOK Marks and divert patients from their intended facilities in order to prevent Plaintiff from rendering services and collecting fees. 82. As a direct and proximate result thereof, Plaintiff has suffered damages. 15
16 Case 114-cv NLH-JS Document 1 Filed 08/26/14 Page 16 of 20 PageID 16 PRAYER FOR RELIEF WHEREFORE, Plaintiff requests the following relief A. An Order preliminarily and permanently enjoining Defendants from (1) using the SEABROOK Marks and any other reproduction or imitation thereof in connection with offering or providing or any services not originating with Plaintiff or authorized in writing by Plaintiff; (2) from using the SEABROOK Marks and any other reproduction or imitation thereof in connection with offering or providing of any services in any manner likely to cause confusion, to cause a mistake or to deceive the relevant trade and/or the public; (3) using the SEABROOK Marks and any other reproduction or imitation thereof in connection with offering or providing of any services, including, but not limited to in any manner so as to dilute or tarnish the distinctive quality of such marks; (4) committing any acts which may cause visitors, potential customers/ patients, and/or the public to believe that Defendants services are identical to, related to, or are sponsored or authorized by Plaintiff; (5) committing any acts calculated to cause purchasers, potential purchasers, donors and/or the public to believe that Defendants are in any way related and/or affiliated with/to Plaintiff; (6) otherwise competing unfairly with Plaintiff in any manner; and (7) assisting, aiding, or abetting any other person or entity in engaging in or performing any of the activities prohibited by sub-paragraphs (1) through (6) herein above; B. An Order requiring Defendant Elements to provide a full accounting of any and all monies received from the placement of any patients in its facilities resulting from a search for 16
17 Case 114-cv NLH-JS Document 1 Filed 08/26/14 Page 17 of 20 PageID 17 SEABROOK or SEABROOK HOUSE and subsequent call on any of the Recovery Brands Websites; C. An Order requiring Defendant Recovery Brands to provide a full accounting of any and all monies received commissions or finder s fees from the placement of any patients in in Defendant Elements facilities resulting from a search for SEABROOK or SEABROOK HOUSE and subsequent call on any of the Recovery Brands Websites; D. Plaintiff be awarded damages in an amount to be determined at trial, including those pursuant to 15 U.S.C. 1117(a) for Defendants Trademark Infringement/Unfair Competition determined as (1) Defendants' profits, (2) any damages sustained by Plaintiff, and (3) the costs of the action (including, but not limited to expert witness fees), together with Prejudgment and Post-Judgment Interest; E. Plaintiff be awarded the greater of three times Defendants profits or three times any damages sustained by Plaintiff and prejudgment interest; F. That the Court find Defendants infringement activities qualify as Exceptional under 15 U.S.C. 1117(a); G. That Defendants be required to pay Plaintiff s costs of this action together with reasonable attorneys fees and disbursements; H. Plaintiff be awarded its actual damages and lost profits in an amount to be proven at trial; I. Defendants be required to post a Notice on the header of each of the Recovery Brands Websites prominently identifying the relationship between the Defendants and informing visitors and potential patients that this is a paid advertisements site promoting the services of 17
18 Case 114-cv NLH-JS Document 1 Filed 08/26/14 Page 18 of 20 PageID 18 Defendant Elements, and that calling the services will put the visitor in contact with the call center for Defendant Elements, not an independent third party; J. Defendants Elements and Recovery Brands be found jointly and separately liable for all damages awarded; K. All other and further relief as the Court may deem just and proper under the circumstances. JURY DEMAND Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Plaintiff hereby demands a trial by jury of all issues so triable. Dated August 26, 2014 Respectfully Submitted, /s/ Christopher D. Olszyk Jr. Christopher R. Kinkade, Esq. FOX ROTHSCHILD, LLP 997 Lenox Drive, Building 3 Lawrenceville, NJ Telephone (609) Facsimile (609) ckinkade@foxrothschild.com Christopher D. Olszyk, Jr. Michael J. Leonard* FOX ROTHSCHILD, LLP 2000 Market Street, 20 th Fl. Philadelphia, PA Telephone (215) Facsimile (215) colszyk@foxrothschild.com mleonard@foxrothschild.com *Pro Hac Vice Application to be filed Attorneys for Plaintiff Seabrook House, Inc. 18
19 Case 114-cv NLH-JS Document 1 Filed 08/26/14 Page 19 of 20 PageID 19 FOX ROTHSCHILD LLP By Christopher R. Kinkade Christopher D. Olszyk Michael J. Leonard (Pro Hac Vice Application to be filed) Princeton Pike Corporate Center 997 Lenox Drive, Building 3 Lawrenceville, NJ Telephone (609) Facsimile (609) Attorneys for Plaintiff Seabrook House, Inc. IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY SEABROOK HOUSE, INC., v. Plaintiff, ELEMENTS BEHAVIORAL HEALTH, INC., and RECOVERY BRANDS, LLC, d/b/a Rehabs.com, d/b/a Drugabuse.com, d/b/a and 4rehabs.com Defendants. CIVIL ACTION NO. L. CIV. R CERTIFICATION (Document Filed Electronically) Plaintiff Seabrook House, Inc., its undersigned counsel, hereby certifies pursuant to Local Civil Rule 11.2 that the matter in controversy in the present action is not the subject of any other action pending in any court, or of any other arbitration or administrative proceeding. 19
20 Case 114-cv NLH-JS Document 1 Filed 08/26/14 Page 20 of 20 PageID 20 Dated August 26, 2014 Respectfully Submitted, s/ Christopher D. Olszyk, Jr. Christopher R. Kinkade, Esq. FOX ROTHSCHILD, LLP 997 Lenox Drive, Building 3 Lawrenceville, NJ Telephone (609) Facsimile (609) ckinkade@foxrothschild.com Christopher D. Olszyk, Jr. Michael J. Leonard* FOX ROTHSCHILD, LLP 2000 Market Street, 20 th Fl. Philadelphia, PA Telephone (215) Facsimile (215) colszyk@foxrothschild.com mleonard@foxrothschild.com *Pro Hac Vice Application to be filed Attorneys for Plaintiff Seabrook House, Inc. 20
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