Case 1:14-cv NLH-JS Document 1 Filed 08/26/14 Page 1 of 20 PageID: 1

Save this PDF as:
 WORD  PNG  TXT  JPG

Size: px
Start display at page:

Download "Case 1:14-cv-05365-NLH-JS Document 1 Filed 08/26/14 Page 1 of 20 PageID: 1"

Transcription

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) Christopher D. Olszyk, Jr. Michael J. Leonard* FOX ROTHSCHILD, LLP 2000 Market Street, 20 th Fl. Philadelphia, PA Telephone (215) Facsimile (215) *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) Christopher D. Olszyk, Jr. Michael J. Leonard* FOX ROTHSCHILD, LLP 2000 Market Street, 20 th Fl. Philadelphia, PA Telephone (215) Facsimile (215) *Pro Hac Vice Application to be filed Attorneys for Plaintiff Seabrook House, Inc. 20

CASE 0:12-cv-02397-RHK-TNL Document 1 Filed 09/14/12 Page 1 of 13 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA ) ) ) ) ) ) ) ) ) ) ) )

CASE 0:12-cv-02397-RHK-TNL Document 1 Filed 09/14/12 Page 1 of 13 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA ) ) ) ) ) ) ) ) ) ) ) ) CASE 0:12-cv-02397-RHK-TNL Document 1 Filed 09/14/12 Page 1 of 13 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA QUALITY BICYCLE PRODUCTS, INC. v. Plaintiff, BIKEBARON, LLC SINCLAIR IMPORTS, LLC and

More information

Case 3:14-cv-01824-M Document 1 Filed 05/19/14 Page 1 of 9 PageID 1

Case 3:14-cv-01824-M Document 1 Filed 05/19/14 Page 1 of 9 PageID 1 Case 3:14-cv-01824-M Document 1 Filed 05/19/14 Page 1 of 9 PageID 1 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION BEST LITTLE PROMOHOUSE IN TEXAS LLC, Plaintiffs,

More information

Case4:15-cv-04219-DMR Document1 Filed09/16/15 Page1 of 11

Case4:15-cv-04219-DMR Document1 Filed09/16/15 Page1 of 11 Case:-cv-0-DMR Document Filed0// Page of MICHAEL G. RHODES () (rhodesmg@cooley.com) California Street, th Floor San Francisco, CA Telephone: Facsimile: BRENDAN J. HUGHES (pro hac vice to be filed) (bhughes@cooley.com)

More information

Case 1:14-cv-12193-WGY Document 1 Filed 05/16/14 Page 1 of 9 UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS COMPLAINT AND JURY DEMAND

Case 1:14-cv-12193-WGY Document 1 Filed 05/16/14 Page 1 of 9 UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS COMPLAINT AND JURY DEMAND Case 1:14-cv-12193-WGY Document 1 Filed 05/16/14 Page 1 of 9 UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS PRIVATE BUSINESS JETS, L.L.C. Plaintiff, v. Civil Action No. PRVT, Inc. Defendant. COMPLAINT

More information

IN THE UNITED STATES DISTRICT COURT FOR NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

IN THE UNITED STATES DISTRICT COURT FOR NORTHERN DISTRICT OF TEXAS DALLAS DIVISION IN THE UNITED STATES DISTRICT COURT FOR NORTHERN DISTRICT OF TEXAS DALLAS DIVISION JPM NETWORKS, LLC, ) d/b/a KWIKBOOST ) ) Plaintiff, ) ) v. ) Civil Action No. ) 3:14-cv-1507 JCM FIRST VENTURE, LLC )

More information

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE Case :-cv-00-tsz Document Filed 0// Page of 0 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE 0 EVAN CONKLIN PLUMBING AND HEATING INC., a Washington corporation d/b/a SEATTLE PLUMBING

More information

Trademark Infringement Complaint. No. Plaintiff, by and through its attorneys,, I. PARTIES

Trademark Infringement Complaint. No. Plaintiff, by and through its attorneys,, I. PARTIES Trademark Infringement Complaint [Name/Address] Attorneys for Plaintiff UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF WASHINGTON ALPHA, INC., a Washington corporation, v. Plaintiff, MR, DELTA

More information

Case5:15-cv-02579-NC Document1 Filed06/10/15 Page1 of 8

Case5:15-cv-02579-NC Document1 Filed06/10/15 Page1 of 8 Case:-cv-0-NC Document Filed0// Page of KALPANA SRINIVASAN (0) ksrinivasan@susmangodfrey.com OLEG ELKHUNOVICH () oelkhunovich@susmangodfrey.com SUSMAN GODFREY L.L.P. 0 Avenue of the Stars, Suite 0 Los

More information

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY DEFENDANT S ANSWER

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY DEFENDANT S ANSWER Case 1:14-cv-05919-JEI-KMW Document 19 Filed 02/13/15 Page 1 of 11 PageID: 84 Frank L. Corrado, Esquire Attorney ID No. 022221983 BARRY, CORRADO & GRASSI, PC 2700 Pacific Avenue Wildwood, NJ 08260 (609)

More information

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE MOBILE TRANSFORMATION LLC, Plaintiff, v. Civil Case No. A&E TELEVISION NETWORKS, LLC JURY TRIAL DEMANDED Defendant. COMPLAINT Plaintiff

More information

IN THE UNITED STATES DISTRICT COURT DISTRICT OF SOUTH CAROLINA GREENVILLE DIVISION

IN THE UNITED STATES DISTRICT COURT DISTRICT OF SOUTH CAROLINA GREENVILLE DIVISION IN THE UNITED STATES DISTRICT COURT DISTRICT OF SOUTH CAROLINA GREENVILLE DIVISION ZIPIT WIRELESS INC., Plaintiff, v. BLACKBERRY LIMITED F/K/A RESEARCH IN MOTION LIMITED and BLACKBERRY CORPORATION f/k/a

More information

Case 1:14-cv-00946-BNB Document 1 Filed 04/02/14 USDC Colorado Page 1 of 13 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Case 1:14-cv-00946-BNB Document 1 Filed 04/02/14 USDC Colorado Page 1 of 13 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Case 1:14-cv-00946-BNB Document 1 Filed 04/02/14 USDC Colorado Page 1 of 13 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. HUGEDOMAINS.COM, LLC, a Colorado limited liability

More information

Case 1:14-cv-01362-UNA Document 1 Filed 10/31/14 Page 1 of 9 PageID #: 1 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

Case 1:14-cv-01362-UNA Document 1 Filed 10/31/14 Page 1 of 9 PageID #: 1 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE Case 1:14-cv-01362-UNA Document 1 Filed 10/31/14 Page 1 of 9 PageID #: 1 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ENDEAVOR MESHTECH, INC., Plaintiff, v. SCHNEIDER ELECTRIC USA, INC., Civil

More information

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION COMPLAINT AND DEMAND FOR JURY TRIAL

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION COMPLAINT AND DEMAND FOR JURY TRIAL Case 8:12-cv-01479-JDW-MAP Document 1 Filed 07/03/12 Page 1 of 31 PageID 1 PODS ENTERPRISES, INC., UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION vs. Plaintiff, Case No. U-HAUL

More information

Case 2:14-cv Document 1 Filed 09/12/14 Page 1 of 13 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS. v. ) Civil Action No.

Case 2:14-cv Document 1 Filed 09/12/14 Page 1 of 13 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS. v. ) Civil Action No. Case 2:14-cv-02461 Document 1 Filed 09/12/14 Page 1 of 13 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS ADVANCED BASEBALL ACADEMY, LLC ) ) Plaintiff, ) ) v. ) Civil Action No. ) GOOGLE,

More information

1 2 3 4 5 [ATTORNEY NAME] (ATTORNEY STATE BAR NUMBER) [ATTORNEY EMAIL ADDRESS] [LAW FIRM NAME] [LAW FIRM STREET ADDRESS] [LAW FIRM CITY/STATE/ZIP CODE] [LAW FIRM TELEPHONE NUMBER] [LAW FIRM FAX NUMBER]

More information

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEVADA

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEVADA PHILIP M. BALLIF Nevada Bar # 2650 DURHAM, JONES & PINEGAR. P.C. 10785 W. Twain Avenue, Suite 200 Las Vegas, Nevada 89135 Telephone: (702 870-6060 Facsimile: (702 870-6090 Email: pballif@djplaw.com JOHN

More information

Case 1:10-cv-00168-JBS -KMW Document 1 Filed 01/12/10 Page 1 of 21 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY

Case 1:10-cv-00168-JBS -KMW Document 1 Filed 01/12/10 Page 1 of 21 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY Case 1:10-cv-00168-JBS -KMW Document 1 Filed 01/12/10 Page 1 of 21 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY SMART VENT INC., : : Plaintiff, : CIVIL ACTION NO.: : : : USA FLOODAIR VENTS,

More information

IN THE UNITED STATES DISTRICT COURT IN AND FOR THE DISTRICT OF UTAH, CENTRAL DIVISION

IN THE UNITED STATES DISTRICT COURT IN AND FOR THE DISTRICT OF UTAH, CENTRAL DIVISION Andrew W. Stavros (8615) Austin B. Egan (13203) STAVROS LAW P.C. 11693 South 700 East, Suite 200 Draper, Utah 84020 Tel: (801) 758.7604 Fax: (801) 893.3573 Email: andy@stavroslaw.com austin@stavroslaw.com

More information

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE. Plaintiff Endeavor MeshTech, Inc. ( Plaintiff or Endeavor ), by and through its

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE. Plaintiff Endeavor MeshTech, Inc. ( Plaintiff or Endeavor ), by and through its UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ENDEAVOR MESHTECH, INC., Plaintiff, v. ACLARA TECHNOLOGIES LLC, Civil Action No. ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT JURY TRIAL DEMANDED

More information

GOODIX TECHNOLOGY INC., SHENZHEN HUIDING TECHNOLOGY CO., LTD. A/K/A SHENZHEN GOODIX TECHNOLOGY CO., LTD., and

GOODIX TECHNOLOGY INC., SHENZHEN HUIDING TECHNOLOGY CO., LTD. A/K/A SHENZHEN GOODIX TECHNOLOGY CO., LTD., and 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 AKIN GUMP STRAUSS HAUER & FELD LLP Cono A. Carrano (pro hac vice to be filed) Email: ccarrano@akingump.com David C. Vondle (Bar

More information

Case 1:16-cv-00320-CBA-PK Document 1 Filed 01/21/16 Page 1 of 8 PageID #: 1 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NEW YORK

Case 1:16-cv-00320-CBA-PK Document 1 Filed 01/21/16 Page 1 of 8 PageID #: 1 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NEW YORK Case 116-cv-00320-CBA-PK Document 1 Filed 01/21/16 Page 1 of 8 PageID # 1 Frank J. Martinez (FJM-2149) THE MARTINEZ GROUP PLLC 55 Washington Street, Suite 253-C Brooklyn, New York 11201 718.797.2341 Telephone

More information

Case 3:15-cv-01953-MO Document 1 Filed 10/16/15 Page 1 of 8

Case 3:15-cv-01953-MO Document 1 Filed 10/16/15 Page 1 of 8 Case 3:15-cv-01953-MO Document 1 Filed 10/16/15 Page 1 of 8 Brenna K. Legaard, OSB #001658 Email: blegaard@schwabe.com SCHWABE, WILLIAMSON & WYATT, P.C. 1211 SW 5th Avenue, Suite 1900 Portland, OR 97204

More information

UNITED STATES DISTRICT COURT DISTRICT OF DELAWARE

UNITED STATES DISTRICT COURT DISTRICT OF DELAWARE UNITED STATES DISTRICT COURT DISTRICT OF DELAWARE DERMAFOCUS LLC, a Delaware limited liability company, v. Plaintiff, ULTHERA, INC., a Delaware corporation. Civil Action No: DEMAND FOR JURY TRIAL Defendant.

More information

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION RPOST HOLDINGS, INC., RPOST COMMUNICATIONS LIMITED, and RMAIL LIMITED, CIVIL ACTION NO. Plaintiffs, v. ADOBE SYSTEMS

More information

Plaintiff Carol Parker ( Plaintiff ), residing at 32 Coleman Way, Jackson, NJ 08527, by her undersigned counsel, alleges the following upon personal

Plaintiff Carol Parker ( Plaintiff ), residing at 32 Coleman Way, Jackson, NJ 08527, by her undersigned counsel, alleges the following upon personal UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY CAROL PARKER, on behalf of herself and all others similarly situated, v. Plaintiff, PARADE ENTERPRISES, LLC, No. 3:14-CV-08084-MAS-DEA AMENDED COMPLAINT

More information

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA HI LIMITED PARTNERSHIP, a Florida limited partnership; HOOTERS OF AMERICA, LLC, a Georgia limited liability company, Plaintiffs,

More information

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION Case 2:12-cv-00604-MHS-CMC Document 1 Filed 09/18/12 Page 1 of 16 PageID #: 1 CAPITAL SECURITY SYSTEMS, INC., IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION Plaintiff,

More information

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION Case :0-cv-0-VRW Document Filed 0/0/0 Page of FRITZ CLAPP (Cal. Bar No. ) Attorney at Law 0 Foothill Boulevard Oakland, California 0 Telephone: () - Facsimile: () - E-mail: Attorney

More information

Case 2:06-cv-15766-JF-SDP Document 69 Filed 02/25/2008 Page 1 of 15

Case 2:06-cv-15766-JF-SDP Document 69 Filed 02/25/2008 Page 1 of 15 Case 2:06-cv-15766-JF-SDP Document 69 Filed 02/25/2008 Page 1 of 15 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION FEDERAL TRADE COMMISSION, Plaintiff, v. MAZZONI

More information

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ORIGINAL COMPLAINT FOR PATENT INFRINGEMENT UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE imtx STRATEGIC, LLC, Plaintiff, v. APPLE INC., Civil Action No. JURY TRIAL DEMANDED Defendant. Plaintiff imtx Strategic, LLC ( Plaintiff or imtx

More information

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE ) ) ) ) ) ) ) ) ) ) ) ) ) )

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE ) ) ) ) ) ) ) ) ) ) ) ) ) ) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MICROSOFT CORPORATION, a Washington Corporation v. Plaintiff, SALESFORCE.COM, INC., a Delaware Corporation Defendants. UNITED STATES DISTRICT

More information

Case 9:13-cv-81058-RNS Document 1 Entered on FLSD Docket 10/17/2013 Page 1 of 15 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

Case 9:13-cv-81058-RNS Document 1 Entered on FLSD Docket 10/17/2013 Page 1 of 15 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case 9:13-cv-81058-RNS Document 1 Entered on FLSD Docket 10/17/2013 Page 1 of 15 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA STEINGER & ISCOE, P.A. D/B/A STEINGER, ISCOE AND GREENE,

More information

Case 2:12-cv-07481-SRC-CLW Document 1 Filed 12/06/12 Page 1 of 13 PageID: 1 UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

Case 2:12-cv-07481-SRC-CLW Document 1 Filed 12/06/12 Page 1 of 13 PageID: 1 UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY Case 2:12-cv-07481-SRC-CLW Document 1 Filed 12/06/12 Page 1 of 13 PageID: 1 Michael D. Camarinos, Esq. Mavroudis, Rizzo & Guarino, LLC Attorneys at Law 690 Kinderkamack Road Oradell, New Jersey 07649 Telephone:

More information

Case 2:15-cv-00456 Document 1 Filed 01/29/15 Page 1 of 14 PageID #: 1

Case 2:15-cv-00456 Document 1 Filed 01/29/15 Page 1 of 14 PageID #: 1 Case 2:15-cv-00456 Document 1 Filed 01/29/15 Page 1 of 14 PageID #: 1 Saul B. Shapiro Robert W. Lehrburger Travis J. Tu PATTERSON BELKNAP WEBB & TYLER LLP 1133 Avenue of the Americas New York, New York

More information

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION DR. LAKSHMI ARUNACHALAM, IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION Plaintiff, Civil Action No: v. VICTORIA S SECRET DIRECT BRAND MANAGEMENT, LLC, JURY TRIAL

More information

UNITED STATES DISTRICT COURT DISTRICT OF OREGON PORTLAND DIVISION

UNITED STATES DISTRICT COURT DISTRICT OF OREGON PORTLAND DIVISION Peter E. Heuser, OSB # 811281 Email pheuser@schwabe.com Devon Zastrow Newman, OSB #014627 Email dnewman@schwabe.com Telephone: 503.222.9981 Facsimile: 503.796.2900 Sean G. Gallagher, pro hac vice pending

More information

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS LUFKIN DIVISION. v. Case No. COMPLAINT AND JURY DEMAND

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS LUFKIN DIVISION. v. Case No. COMPLAINT AND JURY DEMAND IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS LUFKIN DIVISION ALLURE ENERGY, INC., a Delaware corporation, Plaintiff, v. Case No. NEST LABS, INC., a Delaware corporation, GREEN

More information

DISTRICT CT COURT, CITY AND COUNTY OF DENVER, STATE OF COLORADO Case No.. 96-CV-4693

DISTRICT CT COURT, CITY AND COUNTY OF DENVER, STATE OF COLORADO Case No.. 96-CV-4693 DISTRICT CT COURT, CITY AND COUNTY OF DENVER, STATE OF COLORADO Case No.. 96-CV-4693 ORDER FOR PRELIMINARY INJUNCTION ROBERT LEWIS, STOREFRONTS IN CYBERSPACE, a Colorado limited liability company, and

More information

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA LYNCHBURG (CHARLOTTESVILLE) DIVISION. Plaintiff, Case No. v.

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA LYNCHBURG (CHARLOTTESVILLE) DIVISION. Plaintiff, Case No. v. IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA LYNCHBURG (CHARLOTTESVILLE) DIVISION UNIVERSITY OF VIRGINIA PATENT FOUNDATION Plaintiff, Case No. v. HAMILTON COMPANY AND HAMILTON

More information

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE VERINT SYSTEMS INC. and VERINT AMERICAS INC. Civil Action No. Plaintiffs, JURY TRIAL DEMANDED v. CALLCOPY INC. Defendant. COMPLAINT Plaintiffs,

More information

AMENDED CLASS ACTION COMPLAINT

AMENDED CLASS ACTION COMPLAINT IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA. KIM WALLANT and LOUIS BOREK, on behalf of themselves and all others similarly situated, vs. Plaintiffs, FREEDOM

More information

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA Case:-cv-0 Document Filed0// Page of 0 0 LAKESHORE LAW CENTER Jeffrey Wilens, Esq. (State Bar No. 0 0 Yorba Linda Blvd., Suite 0-0 Yorba Linda, CA --0 --0 (fax jeff@lakeshorelaw.org Attorney and Plaintiff

More information

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ) ) ) ) ) ) ) ) ) ) COMPLAINT THE PARTIES

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ) ) ) ) ) ) ) ) ) ) COMPLAINT THE PARTIES IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE AEROSCOUT, LTD. and AEROSCOUT, INC., v. CENTRAK INC., Plaintiffs, Defendant. C.A. No. JURY TRIAL DEMANDED COMPLAINT Plaintiffs AeroScout,

More information

Case 3:14-cv-00929-AWT Document 1 Filed 06/26/14 Page 1 of 5 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT

Case 3:14-cv-00929-AWT Document 1 Filed 06/26/14 Page 1 of 5 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT Case 3:14-cv-00929-AWT Document 1 Filed 06/26/14 Page 1 of 5 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT ZIPLINK, INC., Plaintiff, Civil Action No. v. VERIZON COMMUNICATIONS, INC., JURY

More information

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA FEDERAL TRADE COMMISSION, Plaintiff, Civil Action No. v. WEBVIPER, LLC; d/b/a Yellow Web Services; and TIGERHAWK, LLC; d/b/a Yellow

More information

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION Case 4:13-cv-00594 Document 1 Filed in TXSD on 03/06/13 Page 1 of 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION FEDERAL TRADE COMMISSION, Plaintiff, v. Civ. No.: VERMA HOLDINGS,

More information

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA 1 1 1 1 1 0 1 Luke L. Dauchot (SBN Nimalka R. Wickramasekera (SBN Benjamin A. Herbert (SBN South Hope Street Los Angeles, California 001 Telephone: (1 0-00 Facsimile: (1 0-00 Attorneys for Plaintiff, v.

More information

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY FEDERAL TRADE COMMISSION and JOHN J. HOFFMAN, Acting Attorney General of the State of New Jersey, and STEVE C. LEE, Acting Director of the New

More information

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA SEDNA AIRE USA INC., a Florida Corporation, and JAMES P. HAMMOND, an individual, v. Plaintiffs, Case No. JURY TRIAL REQUESTED ECO SOLAR TECHNOLOGIES,

More information

) CIVIL NO. v. ) WORLD CLASS NETWORK, INC., ) a Nevada corporation; ) COMPLAINT FOR ) RELIEF. DANIEL R. DIMACALE, an individual; )

) CIVIL NO. v. ) WORLD CLASS NETWORK, INC., ) a Nevada corporation; ) COMPLAINT FOR ) RELIEF. DANIEL R. DIMACALE, an individual; ) 1 1 1 1 1 1 1 0 1 STEPHEN CALKINS General Counsel ANN I. JONES RAYMOND E. McKOWN Federal Trade Commission 100 Wilshire Blvd., Suite Los Angeles, California 00 ( -00 JOHN ANDREW SINGER Federal Trade Commission

More information

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION ) FEDERAL TRADE COMMISSION, ) ) Plaintiff, ) ) v. ) ) Civil No. CONTROLSCAN, INC., ) a corporation, ) ) Defendant. ) ) COMPLAINT

More information

Case 1:12-cv-00939-RPM Document 1 Filed 04/09/12 USDC Colorado Page 1 of 10 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Case 1:12-cv-00939-RPM Document 1 Filed 04/09/12 USDC Colorado Page 1 of 10 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Case 1:12-cv-00939-RPM Document 1 Filed 04/09/12 USDC Colorado Page 1 of 10 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO NEOMEDIA TECHNOLOGIES, INC., Plaintiff, v. SPYDERLYNK, LLC.

More information

COUNTERCLAIM AGAINST PLAINTIFF ECOSMART, LLC AND THIRD PARTY COMPLAINT AGAINST CARLOS ANTONIO CABRERA

COUNTERCLAIM AGAINST PLAINTIFF ECOSMART, LLC AND THIRD PARTY COMPLAINT AGAINST CARLOS ANTONIO CABRERA Case 1:12-cv-20231-JAL Document 4 Entered on FLSD Docket 01/23/2012 Page 1 of 18 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA ECOSMART US, LLC a Florida Limited Liability Company,

More information

Case 6:15-cv-00145-JRG-KNM Document 1 Filed 02/25/15 Page 1 of 12 PageID #: 1

Case 6:15-cv-00145-JRG-KNM Document 1 Filed 02/25/15 Page 1 of 12 PageID #: 1 Case 6:15-cv-00145-JRG-KNM Document 1 Filed 02/25/15 Page 1 of 12 PageID #: 1 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION SMARTFLASH LLC, and SMARTFLASH TECHNOLOGIES

More information

UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS. ) IATRIC SYSTEMS, INC., ) ) ) Civil Action No. 1:14-cv-13121 ) v. ) ) FAIRWARNING, INC.

UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS. ) IATRIC SYSTEMS, INC., ) ) ) Civil Action No. 1:14-cv-13121 ) v. ) ) FAIRWARNING, INC. UNITED STATES DISTRICT COURT DISTRICT OF MASSACHUSETTS IATRIC SYSTEMS, INC., Plaintiff, Civil Action No. 1:14-cv-13121 v. FAIRWARNING, INC., JURY TRIAL DEMANDED Defendant. COMPLAINT Iatric Systems, Inc.

More information

Case 3:15-cv-05082-JRC Document 1 Filed 02/09/15 Page 1 of 10

Case 3:15-cv-05082-JRC Document 1 Filed 02/09/15 Page 1 of 10 Case :-cv-00-jrc Document Filed 0/0/ Page of 0 0 TEFERI BIKILA, an individual, v. Plaintiff, VIBRAM USA INC., a Delaware corporation, Defendant. UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON

More information

Case 1:13-cv-00034-UNA Document 1 Filed 01/04/13 Page 1 of 11 PageID #: 1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

Case 1:13-cv-00034-UNA Document 1 Filed 01/04/13 Page 1 of 11 PageID #: 1 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE Case 1:13-cv-00034-UNA Document 1 Filed 01/04/13 Page 1 of 11 PageID #: 1 STEELHEAD LICENSING LLC, IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE v. Plaintiff, AT&T, INC., and AT&T MOBILITY

More information

Case5:15-cv-00404-HRL Document1 Filed01/28/15 Page1 of 12

Case5:15-cv-00404-HRL Document1 Filed01/28/15 Page1 of 12 Case:-cv-000-HRL Document Filed0// Page of 0 ERIC DONEY, #0 edoney@donahue.com JULIE E. HOFER, # jhofer@donahue.com ANDREW S. MACKAY, #0 amackay@donahue.com DONAHUE FITZGERALD LLP Harrison Street, th Floor

More information

Case5:12-cv-00630-LHK Document261 Filed08/31/12 Page1 of 15. Attorneys for Plaintiff and Counterclaim Defendant Apple Inc.

Case5:12-cv-00630-LHK Document261 Filed08/31/12 Page1 of 15. Attorneys for Plaintiff and Counterclaim Defendant Apple Inc. Case:-cv-000-LHK Document Filed0// Page of JOSH A. KREVITT (CA SBN ) jkrevitt@gibsondunn.com H. MARK LYON (CA SBN ) mlyon@gibsondunn.com GIBSON, DUNN & CRUTCHER LLP Page Mill Road Palo Alto, CA 0- Telephone:

More information

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA Case :-cv-000-jah -CAB Document Filed 0// Page of 0 Joshua B. Swigart, Esq. (SBN: ) josh@westcoastlitigation.com Robert L. Hyde, Esq. (SBN: ) bob@westcoastlitigation.com Hyde & Swigart Camino Del Rio South,

More information

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF ARIZONA David W. Lincicum (California Bar No. 223566) Burke W. Kappler (D.C. Bar No. 471936) Federal Trade Commission 600 Pennsylvania Avenue, N.W. Mail Stop NJ-8122 Washington, D.C. 20580 dlincicum@ftc.gov bkappler@ftc.gov

More information

Case 1:14-cv-01414-RBW Document 21 Filed 01/29/15 Page 1 of 15 UNITED STATES DISTRICT COURT DISTRICT OF COLUMBIA

Case 1:14-cv-01414-RBW Document 21 Filed 01/29/15 Page 1 of 15 UNITED STATES DISTRICT COURT DISTRICT OF COLUMBIA Case 1:14-cv-01414-RBW Document 21 Filed 01/29/15 Page 1 of 15 UNITED STATES DISTRICT COURT DISTRICT OF COLUMBIA FEDERAL TRADE COMMISSION, 600 Pennsylvania Ave NW Washington, DC 20580, Plaintiff, v. Case

More information

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ) ) ) ) ) ) ) ) ) ) COMPLAINT

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ) ) ) ) ) ) ) ) ) ) COMPLAINT IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ARBITRON INC., v. Plaintiff, SAGA COMMUNICATIONS, INC. and LAKEFRONT COMMUNICATIONS LLC, Defendants. C.A. No. COMPLAINT Plaintiff, Arbitron

More information

: : : : : : : : Plaintiffs, HOLLY SCHEPISI, NEIL McPHERSON, KEVIN DRAGAN, and

: : : : : : : : Plaintiffs, HOLLY SCHEPISI, NEIL McPHERSON, KEVIN DRAGAN, and SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK --------------------------------------------------------------------x HOLLY SCHEPISI, NEIL McPHERSON, KEVIN DRAGAN, BRETT HICKEY, AEGIS ALABAMA

More information

Case 1:10-cv-10494-WGY Document 1 Filed 03/23/10 Page 1 of 7 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS

Case 1:10-cv-10494-WGY Document 1 Filed 03/23/10 Page 1 of 7 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS Case 1:10-cv-10494-WGY Document 1 Filed 03/23/10 Page 1 of 7 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS KONINKLIJKE PHILIPS ELECTRONICS N.V. AND PHILIPS SOLID-STATE LIGHTING SOLUTIONS,

More information

Case 9:15-cv-80366-JIC Document 1 Entered on FLSD Docket 03/19/2015 Page 1 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA. Case No.

Case 9:15-cv-80366-JIC Document 1 Entered on FLSD Docket 03/19/2015 Page 1 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA. Case No. Case 9:15-cv-80366-JIC Document 1 Entered on FLSD Docket 03/19/2015 Page 1 of 7 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA ARRIVAL STAR, SA, and MELVINO TECHNOLOGIES LIMITED, Case No.: v.

More information

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION. v. JURY DEMANDED COMPLAINT THE PARTIES

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION. v. JURY DEMANDED COMPLAINT THE PARTIES IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION PRINTERON INC., Plaintiff, CIVIL ACTION NO. 4:13-CV-3025 v. JURY DEMANDED BREEZYPRINT CORPORATION and U.S. HOSPITALITY

More information

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA BLACK & HAMILL LLP Bradford J. Black (SBN 1) bblack@bchllp.com Andrew G. Hamill (SBN 1) ahamill@bchllp.com Embarcadero Street, Suite 00 San Francisco, California 1 Telephone: --0 Facsimile: -- DESMARAIS

More information

Case 3:15-cv-08128-MLC-LHG Document 1 Filed 11/17/15 Page 1 of 7 PageID: 1

Case 3:15-cv-08128-MLC-LHG Document 1 Filed 11/17/15 Page 1 of 7 PageID: 1 Case 315-cv-08128-MLC-LHG Document 1 Filed 11/17/15 Page 1 of 7 PageID 1 William L. Mentlik Roy H. Wepner Stephen F. Roth Aaron S. Eckenthal LERNER, DAVID, LITTENBERG, KRUMHOLZ & MENTLIK, LLP 600 South

More information

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA DEBRA WONG YANG United States Attorney GARY PLESSMAN Assistant United States Attorney Chief, Civil Fraud Section California State Bar No. 1 Room 1, Federal Building 00 North Los Angeles Street Los Angeles,

More information

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA 1 1 1 1 Sterling A. Brennan (CA State Bar No. 01) E-Mail: sbrennan@mabr.com Tyson K. Hottinger (CA State Bar No. 1) E-Mail: thottinger@mabr.com MASCHOFF BRENNAN LAYCOCK GILMORE ISRAELSEN & WRIGHT, PLLC

More information

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS TYLER DIVISION

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS TYLER DIVISION UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS TYLER DIVISION ACQIS LLC, Plaintiff, COMPLAINT FOR PATENT INFRINGEMENT v. INTERNATIONAL BUSINESS MACHINES CORP., Case No. 6:11-CV-546 Jury Trial Demanded

More information

IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON IN AND FOR THE COUNTY OF KING. No. Plaintiff, Defendants. COMPLAINT I. SUMMARY

IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON IN AND FOR THE COUNTY OF KING. No. Plaintiff, Defendants. COMPLAINT I. SUMMARY FILED APR 0 PM 1: 1 KING COUNTY SUPERIOR COURT CLERK E-FILED CASE NUMBER: --0- SEA IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON IN AND FOR THE COUNTY OF KING AMAZON.COM, INC., a Delaware corporation,

More information

Case 1:15-cv-05819-PGG Document 1 Filed 07/24/15 Page 1 of 18 COMPLAINT

Case 1:15-cv-05819-PGG Document 1 Filed 07/24/15 Page 1 of 18 COMPLAINT Case 1:15-cv-05819-PGG Document 1 Filed 07/24/15 Page 1 of 18 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK PARAMOUNT PICTURES CORPORATION; WARNER BROS. ENTERTAINMENT INC.; TWENTIETH CENTURY

More information

GOOGLE's ADWORDS PROGRAM

GOOGLE's ADWORDS PROGRAM Page 1 of 6 LANHAM ACT CASE INVOLVED GOOGLE's ADWORDS PROGRAM AND KEYWORD META TAGS COURT GRANTED DEFENDANT's MOTION TO DISMISS A federal district court granted defendant's motion to dismiss plaintiff's

More information

Case: 1:16-cv-03312 Document #: 1 Filed: 03/15/16 Page 1 of 11 PageID #:1

Case: 1:16-cv-03312 Document #: 1 Filed: 03/15/16 Page 1 of 11 PageID #:1 Case: 1:16-cv-03312 Document #: 1 Filed: 03/15/16 Page 1 of 11 PageID #:1 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION DISH NETWORK L.L.C., a Colorado limited

More information

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA 1 1 1 1 1 1 1 1 0 1 LAW OFFICES OF RONALD A. MARRON RONALD A. MARRON (SBN 10) ron@consumersadvocates.com ALEXIS WOOD (SBN 000) alexis@consumersadvocates.com KAS GALLUCCI (SBN 0) kas@consumersadvocates.com

More information

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS TYLER DIVISION

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS TYLER DIVISION UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS TYLER DIVISION KLAUSNER TECHNOLOGIES, INC., a New York corporation, Plaintiff, vs. ORACLE CORPORATION, a Delaware corporation; HEWLETT-PACKARD COMPANY,

More information

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS CORPUS CHRISTI DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS CORPUS CHRISTI DIVISION IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF TEXAS CORPUS CHRISTI DIVISION GENERAL ELECTRIC COMPANY, Plaintiff, v. Civil Action No. MITSUBISHI HEAVY INDUSTRIES, LTD., MITSUBISHI HEAVY

More information

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION Case 6:10-cv-00557 Document 1 Filed 10/21/10 Page 1 of 19 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION TRANSDATA, INC., Plaintiff, CIVIL ACTION NO. v. 6:10-cv-557

More information

Case 1:15-cv-03199-MHC Document 1 Filed 09/11/15 Page 1 of 12 ORIGH~~AL

Case 1:15-cv-03199-MHC Document 1 Filed 09/11/15 Page 1 of 12 ORIGH~~AL Case 1:15-cv-03199-MHC Document 1 Filed 09/11/15 Page 1 of 12 ORIGH~~AL EXECSUMMITS, LLC, v. Plaintiff, IN THE UNITED STATES DISTRICT COURT FILEDINCLERK'Sorn NORTHERN DISTRICT OF GEORGIA u.s.o.c. -A~nCE

More information

Case 6:12-cv-00799 Document 1 Filed 10/22/12 Page 1 of 14 PageID #: 1

Case 6:12-cv-00799 Document 1 Filed 10/22/12 Page 1 of 14 PageID #: 1 Case 6:12-cv-00799 Document 1 Filed 10/22/12 Page 1 of 14 PageID #: 1 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION INVENSYS SYSTEMS, INC. Plaintiff, C.A. No.: v.

More information

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION ) ) ) ) ) ) ) ) ) ) ) COMPLAINT FOR DAMAGES

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION ) ) ) ) ) ) ) ) ) ) ) COMPLAINT FOR DAMAGES IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION WAYNE WILLIAMS, on behalf of himself and all others similarly situated, v. Plaintiff, PROTECT SECURITY, LLC. Defendant.

More information

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA AMENDED COMPLAINT I. INTRODUCTION

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA AMENDED COMPLAINT I. INTRODUCTION Case 3:08-cv-01939-JMM Document 12 Filed 03/18/2009 Page 1 of 8 IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA v. Plaintiff, Docket 3:08-cv-01939-JMM (JUDGE JAMES M. MUNLEY)

More information

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION FUTUREVISION.COM, LLC, Plaintiff, v. TIME WARNER CABLE, INC., TIME WARNER CABLE, LLC, CEQUEL COMMUNICATIONS, LLC DBA

More information

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS MARSHALL DIVISION

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS MARSHALL DIVISION UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS MARSHALL DIVISION C-CATION TECHNOLOGIES, LLC, v. Plaintiff, Case No. 2:14-cv-59 TIME WARNER CABLE INC., TIME WARNER CABLE ENTERPRISES LLC, TIME WARNER

More information

Case3:15-cv-03986-JCS Document1 Filed09/01/15 Page1 of 11 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

Case3:15-cv-03986-JCS Document1 Filed09/01/15 Page1 of 11 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA Case:-cv-0-JCS Document Filed0/0/ Page of KRONENBERGER ROSENFELD, LLP Karl S. Kronenberger (Bar No. ) Jeffrey M. Rosenfeld (Bar No. ) Ansel J. Halliburton (Bar No. 0) 0 Post Street, Suite 0 San Francisco,

More information

Case3:11-cv-00043-RS Document34 Filed07/28/11 Page1 of 8

Case3:11-cv-00043-RS Document34 Filed07/28/11 Page1 of 8 Case:-cv-000-RS Document Filed0// Page of 0 0 Sean Reis (SBN 00 sreis@edelson.com EDELSON MCGUIRE, LLP 00 Tomas Street, Suite 00 Rancho Santa Margarita, California Telephone: ( - Facsimile: ( - Michael

More information

Case 6:15-cv-00059 Document 1 Filed 01/20/15 Page 1 of 9 PageID #: 1

Case 6:15-cv-00059 Document 1 Filed 01/20/15 Page 1 of 9 PageID #: 1 Case 6:15-cv-00059 Document 1 Filed 01/20/15 Page 1 of 9 PageID #: 1 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION INTELLECTUAL VENTURES II LLC, Plaintiff, v. Case

More information

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN FRANCISCO UNLIMITED JURISDICTION

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SAN FRANCISCO UNLIMITED JURISDICTION JAMES C. STURDEVANT (SBN 94551 JESPER I. RASMUSSEN (SBN 121001 THE STURDEVANT LAW FIRM A Professional Corporation 475 Sansome Street, Suite 1750 San Francisco, California 94111 Telephone: (415 477-2410

More information

Case 2:14-cv-01131-AJS Document 1 Filed 08/22/14 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA

Case 2:14-cv-01131-AJS Document 1 Filed 08/22/14 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA Case 2:14-cv-01131-AJS Document 1 Filed 08/22/14 Page 1 of 11 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA INTELLECTUAL VENTURES I LLC and INTELLECTUAL VENTURES II LLC v.

More information

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEVADA

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEVADA Case 2:06-cv-00132-KJD-LRL Document 1 Filed 02/03/2006 Page 1 of 10 Louis V. Traeger California State Bar No. 38714 ltraeger@cftc.gov William P. Janulis IL ARDC No. 1326449 Rosemary Hollinger IL ARDC No.

More information

CAUSE NO. PLAINTIFF S ORIGINAL PETITION, APPLICATION FOR EX PARTE TEMPORARY RESTRAINING ORDER, AND TEMPORARY AND PERMANENT INJUNCTION

CAUSE NO. PLAINTIFF S ORIGINAL PETITION, APPLICATION FOR EX PARTE TEMPORARY RESTRAINING ORDER, AND TEMPORARY AND PERMANENT INJUNCTION CAUSE NO. STATE OF TEXAS, IN THE DISTRICT COURT OF Plaintiff v. HARRIS COUNTY, TEXAS JACOB R. HORN; BENTON RAWLON BARBER (A.K.A. RANDY BARBER); d/b/a 1 DAY ROOF; ROOF ALL TEXAS; JUDICIAL DISTRICT ROOFTEAMS

More information

IN THE UNITED STATE DISTRICT COURT FOR THE DISTRICT OF DELAWARE. v. ) C.A. No.

IN THE UNITED STATE DISTRICT COURT FOR THE DISTRICT OF DELAWARE. v. ) C.A. No. IN THE UNITED STATE DISTRICT COURT FOR THE DISTRICT OF DELAWARE M2M SOLUTIONS LLC, ) a Delaware limited liability company, ) ) Plaintiff, ) ) v. ) C.A. No. ) ENFORA, INC., a Delaware corporation, ) JURY

More information

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.:

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: Case 1:10-cv-24283-PCH Document 1 Entered on FLSD Docket 12/01/2010 Page 1 of 16 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: STEVO DESIGN, INC., a Florida corporation, v. Plaintiff,

More information

No. Plaintiff Kelvin Bledsoe ( Plaintiff ), by his undersigned counsel, brings claims

No. Plaintiff Kelvin Bledsoe ( Plaintiff ), by his undersigned counsel, brings claims UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK KELVIN BLEDSOE, Plaintiff, v. SAAQIN, INC., No. COMPLAINT FOR VIOLATION OF FAIR LABOR STANDARDS ACT JURY TRIAL DEMANDED Defendant. Plaintiff Kelvin

More information

Case 1:15-cv-13004-GAO Document 1 Filed 07/23/15 Page 1 of 7 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS

Case 1:15-cv-13004-GAO Document 1 Filed 07/23/15 Page 1 of 7 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS Case 1:15-cv-13004-GAO Document 1 Filed 07/23/15 Page 1 of 7 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MASSACHUSETTS KEITH MATHEWS On behalf of himself and Others similarly situated Plaintiff, Case

More information

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NORTH CAROLINA Charlotte Division Civil Action No.

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NORTH CAROLINA Charlotte Division Civil Action No. UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NORTH CAROLINA Charlotte Division Civil Action No. x BENJAMIN E. DAVIS and CLASS ACTION COMPLAINT ROBERTO F. GARCIA, Plaintiffs, DEMAND FOR JURY TRIAL vs.

More information

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION Case 1:14-cv-01516-WSD Document 1 Filed 05/19/14 Page 1 of 19 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION CAPITAL SECURITY SYSTEMS, INC. v. Plaintiff, NCR

More information