FILED. Case 2:13-cv ADS-WDW IN Document CLERK'S OfFtSE 1 Filed 03/07/13 Page 1 of 97 PageID #: 1. t';;;,l C 7,013

Transcription

1 FILED Case 2:13-cv ADS-WDW IN Document CLERK'S OfFtSE 1 Filed 03/07/13 Page 1 of 97 PageID #: 1 US DISTRICT eo\i~ r ",Q,N,Y t';;;,l C 7,013 * UNITED STATES DISTRICT l::onsilsland OFFICE EASTERN DISTRICT OF NEW YORK -J( EKORNES ASA, and EKORNES, INC. Plaintiffs, CV against- AMAZON. COM, INC., FACTORY DIRECT WHOLESALE, LLC d/b/a CA V ALlER WHOLESALE and BUY.COM, INC. d/b/a RAKUTEN.COM SHOPPING Defendants J( COMPLAINT JURY TRIAL DEMANDED SPATT, J. Civil Action Nt WAEC 1 M.J. Plaintiffs, EKORNES ASA, and EKORNES, INC. (hereinafter referred to as "EKORNES"), by their undersigned attorneys as and for its complaint against AMAZON.COM, INC. (hereinafter "AMAZON"), FACTORY DIRECT WHOLESALE, LLC doing business as CA VALIER WHOLESALE (hereinafter "FACTORY DIRECT") and BUY.COM, INC. doing business as RAKUTEN.COM SHOPPING (hereinafter "BUY.COM") allege as follows: JURISDICTION I. This is an action for injunctive relief, compensatory damages, punitive damage, attorney's fees and other appropriate relief arising under the trademark laws of the United States, the laws of unfair competition and the common law of the State of New York. 2. The action is brought pursuant to: (a) Section 32(1) of the Lanham Act, 15 U.S.C. 1114(1), relating to the

2 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 2 of 97 PageID #: 2 reproduction, counterfeiting, copying or colorable imitation of a registered mark in connection with the sale, distribution or advertising of good or services; (b) Section 43(a) of the Lanham Act, 15 U.S.c. 1125(a), relating to the use in commerce of words or symbols tending to falsely describe or designate the source of goods or services; and (c) The common law of the State of New York. 3. This Court has jurisdiction with respect to the claims set forth herein based upon: (a) Sections 1331 and 1338(a) of Title 28, United States Code and Section 39 ofthe Lanham Act, 15 U.S.C. 1121, which grants this Court original jurisdiction over actions for trademark infringement and unfair competition under the Lanham Act 43(a), 15 U.S.C (a) without regard to amount in controversy or diversity of citizenship of the parties; (b) Section 1338 of the Title 28 of the United States Code, which grants this Court original jurisdiction over actions for unfair competition when joined with a substantial and related claim under the trademark laws; and (c) Section 1367 of Title 28 of the United States Code, which grants this Court supplemental jurisdiction over all other claims which are so related to claims in this action over which this Court has original jurisdiction that they form part of the same case or controversy under Article III ofthe United States Constitution. VENUE 4. Venue is proper in this district pursuant to 28 U.S.c (b) and (c). -2-

3 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 3 of 97 PageID #: 3 THE PARTIES 5. Plaintiff EKORNES ASA is a corporation organized under the laws of the Kingdom of Norway, and having a place of business at Ekornes ASA, N-6222, Ikornnes, Norway. Plaintiff EKORNES, INC. is a corporation organized under the laws of the State of New York, and having a place of business at 615 Pierce Street, Somerset, New Jersey EKORNES is engaged in the business of manufacturing and selling numerous types of high-quality furniture to authorized distributors and retailers which in turn sell the furniture to the purchasing public. In this regard, EKORNES expends great sums of money and great effort in training, advertising, promotion and maintenance of its high quality products for the United States market and throughout the world. 7. Upon information and belief, defendant, AMAZON is a corporation organized under the laws of the State of Delaware, and has its principal place of business at 410 Terry Avenue North, Seattle, Washington Upon information and belief, AMAZON operates an interactive internet retail operation at 9. Upon information and belief, AMAZON is doing business in the Eastern District of New York and has committed tortious acts, including without limitation, unfair competition and trademark infringement, as more fully set forth herein, within the Eastern District of New York, and is subject to the jurisdiction of this Court. -3-

4 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 4 of 97 PageID #: Upon information and belief, defendant, FACTORY DIRECT is a limited liability company organized under the laws of the State of Georgia, and has its principal place of business at 2351 Button Gwinnett Drive, Suite 800, Doraville, Georgia II. Upon information and belief, FACTORY DIRECT is doing business as CA V ALlER WHOLESALE. 12. Upon information and belief, FACTORY DIRECT is an internet retailer engaged in the sale of consumer products, including furniture. 13. Upon information and belief, FACTORY DIRECT doing business as CAVALIER advertises and sells products on the interactive internet website Upon information and belief, FACTORY DIRECT is doing business in the Eastern District of New York and has committed tortious acts, including without limitation, unfair competition and trademark inmngement, as more fully set forth herein, within the Eastern District of New York, and is subject to the jurisdiction of this Court. 15. Upon information and belief, defendant, BUY.COM is a corporation organized under the laws of the State of Delaware, and has its principal place of business at 85 Enterprise Suite 100, Aliso Viejo, California Upon information and belief, BUY.COM is doing business as RAKUTEN.COM -4-

5 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 5 of 97 PageID #: 5 SHOPPING. 17. Upon information and belief, BUY.COM operates an interactive internet retail operation at Upon information and belief, BUY.COM is doing business in the Eastern District of New York and has committed tortious acts, including without limitation, unfair competition and trademark infringement, as more fully set forth herein, within the Eastern District of New York, and is subject to the jurisdiction ofthis Court. SUBSTANCE OF THE ACTION THE EKORNES MARKS AND TRADE DRESS 19. This case involves an attempt by AMAZON, who sells its products in similar channels of trade as EKORNES, to unfairly compete by advertising a reclining chair under the name "Stressless" which infringes the trademark interests of EKORNES. This case further involves an attempt by AMAZON, FACTORY DIRECT and BUY.COM who also sell their products in similar channels of trade as EKORNES, to unfairly compete by selling and offering for sale a knock-off of the EKORNES STRESSLESS recliner chair and ottoman with the "hourglass" base design that serves as an exclusive identifier of these chairs throughout the world. 20. Plaintiffs EKORNES are engaged in the business of manufacturing and selling numerous types of high-quality reclining chairs to distributors and retailers which in turn sell the -5-

6 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 6 of 97 PageID #: 6 chairs to the purchasing public. 21. Since 1971, and long prior to the acts of AMAZON, FACTORY DIRECT and BUY.COM complained of herein, plaintiffs, EKORNES have continually used the name STRESSLESS as a trademark for and designation of origin of its high quality furniture marketed in the United States. 22. PlaintiffEKORNES ASA is the owner of three federal trademark registrations for the trademark STRESSLESS. 23. PlaintiffEKORNES' trademark STRESSLESS is registered in the U.S. Patent and Trademark Office under U.S. Trademark Registration No , registered January 18,1983, on a first-use in commerce of January 1, 1971, in International Class 20, for furniture- namely adjustable chairs. A copy of the registration as well as a current print-out from the U.S. Patent and Trademark Office Website Database is annexed hereto as Exhibit A. 24. PlaintiffEKORNES' trademark STRESSLESS is registered in the U.S. Patent and Trademark Office under U.S. Trademark Registration No , registered June 8, 1999, on a first-use in commerce of December 31,1997, in International Class 20, for furniture, sofas, chairs, easy-chairs with footstool; mattresses; pillows; beds; bedboards. A copy of the registration as well as a current print-out from the U.S. Patent and Trademark Office Website Database is annexed hereto as Exhibit B. -6-

7 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 7 of 97 PageID #: Each of the tradernarks referenced in paragraphs 23 and 24 above, has attained incontestable status under Section IS of the Lanham Act (15 U.S.C. 1065), which is conclusive evidence of the validity of the registered marks, the registration of the marks, EKORNES' ownership of the marks and EKORNES' exclusive right to use the marks with the designated goods. 26. PlaintiffEKORNES' trademark and service mark STRESSLESS + Design is registered in the U.S. Patent and Trademark Office under U.S. Trademark Registration No , registered January 8, 2008, on a first-use in commerce of January 31,2002, in International Class 20, for furniture, chairs, seats, recliner chairs, recliner chairs with footstools, and in International Class 35, for retail outlet and store services in the field of furniture and furnishings. A copy of the registration as well as a current print-out from the U.S. Patent and Trademark Office Website Database is annexed hereto as Exhibit C. 27. Since 1981 and long prior to the acts of AMAZON, FACTORY DIRECT and BUY.COM complained of herein, EKORNES has manufactured and marketed in the United States under the STRESSLESS trademark a chair and other furniture which has a distinctively shaped and designed "hourglass" base design. 28. Plaintiff EKORNES ASA is the owner by assignment of two federal trademark registrations relating to the distinctly shaped and designed "hourglass" base of its STRESSLESS brand furniture. 29. EKORNES ASA's U.S. Trademark Registration No was registered -7-

8 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 8 of 97 PageID #: 8 in the U.S. Patent and Trademark Office on July 17, 2001, on a first-use in commerce of May 1981, in International Class 20, for chairs and ottomans. A copy of this registration as well as a current print-out from the U.S. Patent and Trademark Office Website Database is annexed hereto as Exhibit D. 30. EKORNES ASA's U.S. Trademark Registration No was registered in the U.S. Patent and Trademark Office on June 12, 2001, on a first-use in commerce of May 1981, in International Class 20, for chairs. A copy of this registration as well as a current print-out from the U.S. Patent and Trademark Office Website Database is annexed hereto as Exhibit E. 31. Each of the trademarks referenced in paragraphs 29 and 30 above, have attained incontestable status under Section 15 of the Lanham Act (15 U.S.C. 1065), which is conclusive evidence of the validity of the registered marks, the registration of the marks, EKORNES' ownership of the marks and EKORNES' exclusive right to use the marks with the designated goods. 32. The style and design of the base of the STRESSLESS brand chair is arbitrary, fanciful, non-functional and distinctive, and serves to distinguish EKORNES' chairs from those sold by competitors. 33. The STRESSLESS brand chair, with its distinctively shaped "hourglass" base design, is promoted in the United States by EKORNES, by a costly national advertising campaign and by additional promotional activities, which, in order to make the STRESSLESS brand chair more desirable to the public and to the retail stores, heavily emphasize the STRESSLESS trademark and -8-

9 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 9 of 97 PageID #: 9 the distinctive configuration of the "hourglass" chair base design which is marketed under the STRESSLESS trademark. 34. The chairs and ottomans bearing the STRESSLESS trademark and having the distinctive "hourglass" chair base design, with its distinctive configuration, are popular in the United States and enjoy good will and an excellent reputation among the buying public because EKORNES has done the following: (a) Designed the configuration ofthe "hourglass" chair base design to be distinctive among all other chair base configurations; (b) Promoted, at great cost and effort, the distinctive configuration as being elegant and as being distinctive and of high quality and long duration; (c) Encouraged, through great cost and effort, authorized retailers to promote and advertise the STRESSLESS trademark and chair marketed under the STRESSLESS trademark as being distinctive, elegant, of high quality and oflong duration. The result of the efforts described above is that the STRESSLESS brand chair is presently in high demand and is thus a valuable property ofekornes. 35. EKORNES has enforced its trademarks and trade dress. Attached as Exhibit F hereto is a copy of a consent judgment from the Federal District Court for the Eastern District of New York in Civil Action No The consent judgment was entered into after a decision granting a preliminary injunction in favor ofekornes on its "hourglass" base design that serves as an exclusive identifier ofthese chairs throughout the world. -9-

10 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 10 of 97 PageID #: EKORNES has expended substantial funds in connection with the advertisement and promotion of furniture bearing the STRESSLESS" marks and embodying the STRESSLESS" brand "hourglass" base design in order to establish these marks and trade dress in the minds of consumers as a source of high-quality furniture products. 37. The advertising and promotion of the STRESSLESS" marks and the configuration of the "hourglass" chair base design have caused the public and retailers to associate these marks and the configuration of the "hourglass" chair base design with the name EKORNES. The STRESSLESS" marks and the configuration of the "hourglass" chair base design are also associated by the public and retailers with a reputation in quality designed furniture. The STRESSLESS"marks and the configuration of the "hourglass" chair base design have developed a secondary meaning to the public and to retailers which associate the distinctive STRESSLESS" marks and the configuration of the "hourglass" chair base design with EKORNES. The STRESSLESS" marks and the configuration of the "hourglass" chair base design have come to stand as a symbol of EKORNES, to indicate the source of their products, to serve as a public guarantee of origin and quality, and to represent the substantial goodwill and reputation of EKORNES for high quality products and services. AMAZON'S ACTS 38. Defendant AMAZON sells its products in similar channels of trade as EKORNES' reclining chairs. 39. Recently, AMAZON caused advertisements for "Acme Piece Lauralyn Stressless Chair and Ottoman, Ivory"; "Stressless Style Black Top Grain Leather Recliner and -10-

11 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 11 of 97 PageID #: 11 Ottoman"; "Acme Piece Lauralyn Stressless Chair and Ottoman, Espresso Finish"; "Stressless Style Stone Top Grain Leather Recliner and Ottoman"; "Acme Piece Leesa Stressless Chair and Ottoman, Blaclf'; "Stressless Style Chestnut Top Grain Leather Recliner and Ottoman"; "Espresso PU Chair and Ottoman Set Stressless - Leo "; "2pcs Lauralyn Ivory Finish Stressless Chair and Ottoman" and "Leather Recline Office Chair Relax Sofa wi Ottoman 03" to be published on its website A copy of printouts of said advertisements is annexed hereto as Exhibit G. 41. The chairs and ottomans depicted in the advertisements annexed hereto as Exhibit G are not EKORNES furniture. 42. AMAZON is not a licensee of EKORNES and is not authorized by EKORNES to use EKORNES' STRESSLESS trademark when applied to recliner chairs and ottomans or to use the distinctly shaped and designed "hourglass" base ofekornes' STRESSLESS brand furniture. 43. Upon information and belief, AMAZON intentionally copied the STRESSLESS trademark and the distinctly shaped and designed "hourglass" base ofekornes' STRESSLESS brand furniture in order to wrongfully misappropriate the good will, reputation and valuable distinctive image ofthe STRESSLESS trademark and STRESSLESS chair, in order to falsely pass off their chairs and ottomans as genuine STRESSLESS furniture and in order to confuse the public into believing that their chairs were genuine STRESSLESS chairs. Upon information and -11-

12 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 12 of 97 PageID #: 12 belief, Defendant AMAZON has wilfully, intentionally and with malice attempted to misappropriate the property rights of EKORNES and to deceive and defraud the buying public. 44. Promptly upon learning of AMAZON'S unauthorized use ofthe STRESSLESS trademark, EKORNES demanded in writing on December 14, 2012 that AMAZON immediately cease using this trademark in its advertising. 45. Upon receiving no response from AMAZON to its December 14, 2012 correspondence and upon learning of additional infringing advertisements on the website amazon.com, EKORNES again demanded in writing by letter dated January 3,2013 that AMAZON immediately cease using the STRESSLESS trademark in its advertising. 46. Following its January 3,2013 letter, EKORNES learned of an additional advertisement on the website amazon. com which advertisement infringed EKORNES' trade dress and trademark rights in the "hourglass" base ofekornes' STRESSLESS brand furniture. 47. On January 29, 2013, EKORNES wrote to AMAZON demanding that AMAZON provide its immediate assurance that AMAZON would not be manufacturing, making further offers for sale, selling or delivering the chairs and ottomans having the distinctly shaped and designed "hourglass" base ofekornes' STRESSLESS brand furniture in the United States and demanding that AMAZON immediately remove these chairs and ottomans from all advertisements and other promotional material reaching the United States. -12-

13 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 13 of 97 PageID #: On information and belief, AMAZON continues to use the STRESSLESS trademark to advertise, promote and sell its chairs and ottomans and continues to advertise, promote and sell chairs and ottomans having the distinctly shaped and designed "hourglass" base of EKORNES' STRESSLESS brand furniture. 49. To date, AMAZON has provided no assurance that it will cease its unauthorized use of the STRESSLESS trademark or the distinctly shaped and designed "hourglass" base of EKORNES' STRESSLESS brand furniture. 50. The unauthorized use of the STRESSLESS trademark and the distinctly shaped and designed "hourglass" base ofekornes' STRESSLESS brand furniture by AMAZON has caused and continues to cause the public to confuse the chair of AMAZON with genuine EKORNES STRESSLESS products. It has caused plaintiffs EKORNES to lose profits, to lose good will and to lose control of the valuable reputation and good will associated with the STRESSLESS trademark and the distinctly shaped and designed "hourglass" base of EKORNES' STRESSLESS brand furniture. Plaintiffs EKORNES will be irreparably damaged by continued loss of profits, loss of good will and loss of control over the reputation of the STRESSLESS trademark and the distinctly shaped and designed "hourglass" base ofekornes' STRESSLESS brand furniture unless AMAZON is prevented from continuing its unauthorized misappropriation of EKORNES' trademarks and trade dress. 51. The acts of AMAZON set out above constitute a false designation of the origin, -13-

14 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 14 of 97 PageID #: 14 sponsorship and chain of distribution of such goods and a false description ofthose goods; all of which amounts to unfair competition and violation of EKORNES' trademark rights by defendant in violation of the Lanham Act, 15 U.S.c. 1125(a). FACTORY DIRECT'S ACTS 52. Defendant FACTORY DIRECT sells its products in similar channels of trade as EKORNES' reclining chairs. 53. Recently, FACTORY DIRECT doing business as CAVALIER WHOLESALE caused an advertisement for a "Leather Recline Office Chair Relax Sofa wi Ottoman 03" to be published on the website FACTORY DIRECT has also caused an advertisement for "Leather Recline Office Chair Relax Sofa wi Ottoman 03" to be published on the website FACTORY DIRECT has also published an advertisement for a "New PU Leather Recline Office Chair Desk Task Relax Sofa wi Free Ottoman 03" on the website as Exhibit H. 54. A copy of printouts of the advertisements referenced in paragraph 53 is annexed hereto 55. The chairs and ottomans depicted in the advertisements annexed hereto as Exhibit H are not EKORNES furniture. 56. FACTORY DIRECT is not a licensee of EKORNES and is not authorized by -14-

15 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 15 of 97 PageID #: 15 EKORNES to use the distinctly shaped and designed "hourglass" base of EKORNES' STRESSLESS" brand furniture. 57. Upon information and belief, FACTORY DIRECT intentionally copied the distinctly shaped and designed "hourglass" base ofekornes' STRESSLESS" brand furniture in order to wrongfully misappropriate the good will, reputation and valuable distinctive image of the STRESSLESS" chair, in order to falsely pass off their chairs and ottomans as genuine STRESSLESS" furniture and in order to confuse the public into believing that their chairs were genuine STRESSLESS" chairs. Upon information and belief, Defendant, FACTORY DIRECT has wilfully, intentionally and with malice attempted to misappropriate the property rights ofekornes and to deceive and defraud the buying public. 58. Promptly upon learning of FACTORY DIRECTS's unauthorized use of the distinctly shaped and designed "hourglass" base of EKORNES' STRESSLESS" brand furniture, EKORNES wrote to CAVALIER WHOLESALE on February 4,2013 demanding that they immediately assure EKORNES that they would not be manufacturing, making further offers for sale, selling or delivering these chairs and ottomans in the United States and that they immediately remove these chairs and ottomans from all advertisements and other promotional material reaching the United States. 59. On February 7,2013, EKORNES forwarded a copy of its February 4,2013 cease and desist letter directed to CAVALIER WHOLESALE via to FACTORY DIRECT. -15-

16 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 16 of 97 PageID #: On information and belief, FACTORY DIRECT continues to advertise, promote and sell chairs and ottomans having the distinctly shaped and designed "hourglass" base of EKORNES' STRESSLESS brand furniture. 61. To date, FACTORY DIRECT has provided no assurances that it will cease its unauthorized use ofthe distinctly shaped and designed "hourglass" base of EKORNES' STRESSLESS brand furniture. 62. The unauthorized use of the distinctly shaped and designed "hourglass" base of EKORNES' STRESSLESS brand furniture by FACTORY DIRECT has caused and continues to cause the public to confuse the chair of FACTORY DIRECT with genuine EKORNES STRESSLESS products. It has caused plaintiffs EKORNES to lose profits, to lose good will and to lose control of the valuable reputation and good will associated with the distinctly shaped and designed "hourglass" base of EKORNES' STRESSLESS brand furniture. PlaintiffS EKORNES will be irreparably damaged by continued loss of profits, loss of good will and loss of control over the reputation of the distinctly shaped and designed "hourglass" base ofekornes' STRESSLESS brand furniture unless FACTORY DIRECT is prevented from continuing its unauthorized misappropriation of EKORNES, trademarks and trade dress. 63. The acts of FACTORY DIRECT set out above constitute a false designation of the origin, sponsorship and chain of distribution of such goods and a false description of those goods; all of which amounts to unfair competition and violation ofekornes' trademark rights by defendant in violation of the Lanham Act, 15 U.S.c. 1125(a). -16-

17 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 17 of 97 PageID #: 17 BUY.COM'S ACTS 64. Defendant BUY.COM sells its products in similar channels of trade as EKORNES' reclining chairs. 65. Recently, BUY.COM doing business as RAKUTEN.COM SHOPPING caused an advertisement for a "Leather Recline Office Chair Relax Sofa w/ottoman 03" to be published on the website as Exhibit A copy of a printout of the advertisement referenced in paragraph 65 is annexed hereto 67. The chair and ottoman depicted in the advertisement annexed hereto as Exhibit I are not EKORNES furniture. 68. BUY.COM is not a licensee of EKORNES and is not authorized by EKORNES to use the distinctly shaped and designed "hourglass" base ofekornes' STRESSLESS" brand furniture. 69. Upon information and belief, BUY.COM intentionally copied the distinctly shaped and designed "hourglass" base of EKORNES' STRESSLESS" brand furniture in order to wrongfully misappropriate the good will, reputation and valuable distinctive image of the STRESSLESS" chair, in order to falsely pass off their chairs and ottomans as genuine STRESSLESS" furniture and in order to confuse the public into believing that their chairs were genuine STRESSLESS" chairs. Upon information and belief, Defendant BUY.COM has wilfully, intentionally and with malice -17-

18 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 18 of 97 PageID #: 18 attempted to misappropriate the property rights of EKORNES and to deceive and defraud the buying public. 70. Promptly upon learning ofbuy.com's unauthorized use of the distinctly shaped and designed "hourglass" base ofekornes' STRESSLESS brand furniture, EKORNES wrote to BUY.COM on February 13, 2013 demanding that they immediately assure EKORNES that they would not be manufacturing, making further offers for sale, selling or delivering these chairs and ottomans in the United States and that they immediately remove these chairs and ottomans from all advertisements and other promotional material reaching the United States. 71. On information and belief, BUY.COM continues to advertise, promote and sell chairs and ottomans having the distinctly shaped and designed "hourglass" base of EKORNES' STRESSLESS brand furniture. 72. To date, BUY.COM has provided no assurances that it will cease its unauthorized use of the distinctly shaped and designed "hourglass" base ofekornes' STRESSLESS brand furniture. 73. The unauthorized use of the distinctly shaped and designed "hourglass" base of EKORNES' STRESSLESS brand furniture by BUY.COM has caused and continues to cause the public to confuse the chair of FACTORY DIRECT with genuine EKORNES STRESSLESS products. It has caused plaintiffs EKORNES to lose profits, to lose good will and to lose control of the valuable reputation and good will associated with the distinctly shaped and designed "hourglass" -18-

19 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 19 of 97 PageID #: 19 base ofekornes' STRESSLESS brand furniture. Plaintiffs EKORNES will be irreparably damaged by continued loss of profits, loss of good will and loss of control over the reputation of the distinctly shaped and designed "hourglass" base ofekornes' STRESSLESS brand furniture unless BUY.COM is prevented from continuing its unauthorized misappropriation ofekornes' trademarks and trade dress. 74. The acts ofbuy.com set out above constitute a false designation of the origin, sponsorship and chain of distribution of such goods and a false description of those goods; all of which amounts to unfair competition and violation ofekornes' trademark rights by defendant in violation of the Lanham Act, 15 U.S.C. 1125(a). FIRST CLAIM FOR RELIEF FEDERAL TRADEMARK INFRINGEMENT (15 U.S.C. 1114) 75. EKORNES realleges each and every allegation set forth in paragraph 1 through 74 above, as if fully set forth herein. 76. AMAZON has recently begun to use the identical STRESSLESS name and mark as is used by EKORNES and the distinctly shaped and designed "hourglass" base ofekornes' STRESSLESS brand furniture in connection with their business and the advertising, promotion and sale of its chairs and ottomans. 77. FACTORY DIRECT has recently begun to use the distinctly shaped and designed -19-

20 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 20 of 97 PageID #: 20 "hourglass" base of EKORNES' STRESSLESS brand furniture in connection with their business and the advertising, promotion and sale of its chairs and ottomans. 78. BUY.COM has recently begun to use the distinctly shaped and designed "hourglass" base ofekornes' STRESSLESS brand furniture in connection with their business and the advertising, promotion and sale of its chairs and ottomans. 79. AMAZON has thereby created a likelihood of confusion, deception or mistake, as to the source, sponsorship or origin of STRESSLESS goods. 80. FACTORY DIRECT has thereby created a likelihood of confusion, deception or mistake, as to the source, sponsorship or origin of STRESSLESS goods. 81. BUY.COM has thereby created a likelihood of confusion, deception or mistake, as to the source, sponsorship or origin of STRESSLESS goods 82. Confusion, deception and mistake will increase if AMAZON is permitted to continue its unauthorized misappropriation of the EKORNES STRESSLESS trademark and the distinctly shaped and designed "hourglass" base of EKORNES, STRESSLESS brand furniture. 83. Confusion, deception and mistake will increase if FACTORY DIRECT is permitted to continue its unauthorized misappropriation of the distinctly shaped and designed "hourglass" base of EKORNES' STRESSLESS brand furniture. -20-

21 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 21 of 97 PageID #: Confusion, deception and mistake will increase if BUY.COM is permitted to continue its unauthorized misappropriation of the distinctly shaped and designed "hourglass" base of EKORNES' STRESSLESS brand furniture. 85. On information and belief, AMAZON has adopted the name and designation "STRESSLESS" and the distinctly shaped and designed "hourglass" base ofekornes' STRESSLESS brand furniture with knowledge ofekornes' prior use of the same, and has hereby infringed EKORNES' marks, falsely designated the origin of AMAZON'S chairs and ottomans, has done so willfully or with wanton disregard for EKORNES' rights, and will continue to do so unless enjoined. 86. On information and belief, FACTORY DIRECT has adopted the distinctly shaped and designed "hourglass" base ofekornes' STRESSLESS brand furniture with knowledge of EKORNES' prior use of the same, and has hereby infringed EKORNES' marks, falsely designated the origin of FACTORY DIRECT's chairs and ottomans, has done so willfully or with wanton disregard for EKORNES' rights, and will continue to do so unless enjoined. 87. On information and belief, BUY. COM has adopted the distinctly shaped and designed "hourglass" base ofekornes' STRESSLESS brand furniture with knowledge of EKORNES' prior use of the same, and has hereby infringed EKORNES' marks, falsely designated the origin of BUY. COM's chairs and ottomans, has done so willfully or with wanton disregard for EKORNES' rights, and will continue to do so unless enjoined. -21-

22 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 22 of 97 PageID #: EKORNES has been damaged and is likely to be further damaged by AMAZON's infringing acts and use of false designation of origin, and that damage will be irreparable unless AMAZON's aforesaid conduct is enjoined. 89. EKORNES has been damaged and is likely to be further damaged by FACTORY DIRECT's infringing acts and use offalse designation of origin, and that damage will be irreparable unless FACTORY DIRECT's aforesaid conduct is enjoined. 90. EKORNES has been damaged and is likely to be further damaged by BUY.COM's infringing acts and use of false designation of origin, and that damage will be irreparable unless FACTORY DIRECT's aforesaid conduct is enjoined. SECOND CLAIM FOR RELIEF FEDERAL UNFAIR COMPETITION (15 U.S.C. 1125(a)) 91. EKORNES realleges each and every allegation set forth in paragraphs I through 90 above, as if fully set forth herein. 92. AMAZON'S use of the identical STRESSLESS mark as is used by EKORNES and the distinctly shaped and designed "hourglass" base of EKORNES' STRESSLESS brand furniture in connection with the advertising, promotion and sale of chairs and ottomans that are similar to, or competitive with those offered by EKORNES, but that are not under EKORNES' control or management, constitutes unfair competition. -22-

23 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 23 of 97 PageID #: FACTORY DIRECT's use of the distinctly shaped and designed "hourglass" base of EKORNES' STRESSLESS'" brand furniture in connection with the advertising, promotion and sale of chairs and ottomans that are similar to, or competitive with those offered by EKORNES, but that are not under EKORNES' control or management, constitutes unfair competition. 94. BUY.COM's use of the distinctly shaped and designed "hourglass" base of EKORNES' STRESSLESS'" brand furniture in connection with the advertising, promotion and sale of chairs and ottomans that are similar to, or competitive with those offered by EKORNES, but that are not under EKORNES' control or management, constitutes unfair competition. 95. AMAZON's acts constitute the use of a false designation of origin and a false representation that its goods are EKORNES' goods, or are endorsed, sponsored, authorized, licensed by or otherwise connected with EKORNES and their quality assured thereby. 96. FACTORY DIRECT's acts constitute the use ofa false designation of origin and a false representation that its goods are EKORNES' goods, or are endorsed, sponsored, authorized, licensed by or otherwise connected with EKORNES and their quality assured thereby. 97. BUY.COM's s acts constitute the use of a false designation of origin and a false representation that its goods are EKORNES' goods, or are endorsed, sponsored, authorized, licensed by or otherwise connected with EKORNES and their quality assured thereby. -23-

24 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 24 of 97 PageID #: AMAZON'S use of the identical STRESSLESS name and mark as is used by EKORNES and the distinctly shaped and designed "hourglass" base ofekornes' STRESSLESS brand furniture is likely to cause confusion and mistake and to deceive consumers regarding the source of origin of AMAZON'S products. 99. FACTORY DIRECT's use of the distinctly shaped and designed "hourglass" base of EKORNES' STRESSLESS brand furniture is likely to cause confusion and mistake and to deceive consumers regarding the source of origin of FACTORY DIRECT's products BUY.COM's use of the distinctly shaped and designed "hourglass" base of EKORNES' STRESSLESS brand furniture is likely to cause confusion and mistake and to deceive consumers regarding the source of origin of BUY.COM's products. 1125(a) AMAZON'S acts are in violation of Section 43(a) of the Lanham Act, 15 U.S.C FACTORY DIRECT's acts are in violation of Section 43(a) of the Lanham Act, 15 U.S.C. 1125(a) (a) BUY.COM's acts are in violation of Section 43(a) of the Lanham Act, 15 U.S.C AMAZON'S conduct has caused and will continue to cause irreparable injury to -24-

25 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 25 of 97 PageID #: 25 EKORNES unless enjoined by this Court. EKORNES has no adequate remedy at law FACTORY DIRECT's conduct has caused and will continue to cause irreparable injury to EKORNES unless enjoined by this Court. EKORNES has no adequate remedy at law BUY.COM's conduct has caused and will continue to cause irreparable injury to EKORNES unless enjoined by this Court. EKORNES has no adequate remedy at law. THIRD CLAIM FOR RELIEF COMMON LAW UNFAIR COMPETITION 107. EKORNES realleges each and every allegation set forth in paragraph I through 106 above, as if fully set forth herein AMAZON'S use ofekornes' STRESSLESS name and mark and the distinctly shaped and designed "hourglass" base of EKORNES' STRESSLESS brand furniture in connection with AMAZON'S business and advertising, promotion and sale of chairs and ottomans is likely to confuse the public as to the origin, source, sponsorship or quality of AMAZON'S chairs and ottomans and is likely to mislead persons to believe that AMAZON'S business and products are authorized by or affiliated with EKORNES FACTORY DIRECT's use of the distinctly shaped and designed "hourglass" base of -25-

26 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 26 of 97 PageID #: 26 EKORNES' STRESSLESS" brand furniture in connection with FACTORY DIRECT's business and advertising, promotion and sale of chairs and ottomans is likely to confuse the public as to the origin, source, sponsorship or quality of FACTORY DIRECT's chairs and ottomans and is likely to mislead persons to believe that FACTORY DIRECT's business and products are authorized by or affiliated with EKORNES BUY.COM's use of the distinctly shaped and designed "hourglass" base of EKORNES' STRESSLESS" brand furniture in connection with BUY.COM's's business and advertising, promotion and sale of chairs and ottomans is likely to confuse the public as to the origin, source, sponsorship or quality ofbuy.com's chairs and ottomans and is likely to mislead persons to believe that BUY.COM's business and products are authorized by or affiliated with EKORNES. Ill. Upon information and belief AMAZON's use ofekornes' STRESSLESS" name and mark and the distinctly shaped and designed "hourglass" base ofekornes' STRESSLESS" brand furniture was and is with full knowledge ofekornes' prior use of the same and with full knowledge of the substantial reputation and good will associated with EKORNES and its STRESSLESS" name and mark and the distinctly shaped and designed "hourglass" base of EKORNES' STRESSLESS" brand furniture, and with full knowledge that AMAZON has no prior rights to the same. By appropriating the good will ofekornes' widely known and successful STRESSLESS" name and mark and the distinctly shaped and designed "hourglass" base of EKORNES' STRESSLESS" brand furniture, AMAZON unjustly enrich themselves and damage EKORNES. -26-

27 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 27 of 97 PageID #: Upon information and belief FACTORY DIRECT's use of the distinctly shaped and designed "hourglass" base of EKORNES' STRESSLESS'" brand furniture was and is with full knowledge ofekornes' prior use of the same and with full knowledge ofthe substantial reputation and good will associated with the distinctly shaped and designed "hourglass" base of EKORNES' STRESSLESS'" brand furniture, and with full knowledge that FACTORY DIRECT has no prior rights to the same. By appropriating the good will of the widely known and successful distinctly shaped and designed "hourglass" base ofekornes' STRESSLESS'" brand furniture, FACTORY DIRECT unjustly enrich themselves and damage EKORNES Upon information and belief BUY.COM's use of the distinctly shaped and designed "hourglass" base ofekornes' STRESSLESS'" brand furniture was and is with full knowledge ofekornes' prior use of the same and with full knowledge of the substantial reputation and good will associated with the distinctly shaped and designed "hourglass" base of EKORNES' STRESSLESS'" brand furniture, and with full knowledge that BUY.COM has no prior rights to the same. By appropriating the good will of the widely known and successful distinctly shaped and designed "hourglass" base ofekornes' STRESSLESS'" brand furniture, BUY.COM unjustly enrich themselves and damage EKORNES AMAZON'S conduct constitutes common law unfair competition with EKORNES which will cause irreparable injury to EKORNES' good will and reputation unless enjoined by this Court FACTORY DIRECT's conduct constitutes common law unfair competition with -27-

28 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 28 of 97 PageID #: 28 EKORNES which will cause irreparable injury to EKORNES' good will and reputation unless enjoined by this Court BUY.COM's conduct constitutes common law unfair competition with EKORNES which will cause irreparable injury to EKORNES' good will and reputation unless enjoined by this Court. FOURTH CLAIM FOR RELIEF COMMON LAW TRADEMARK INFRINGEMENT 117. EKORNES realleges each and every allegation set forth in paragraphs 1 through 116 above, as of fully set forth herein The unauthorized use ofekornes' STRESSLESS" name and mark and the distinctly shaped and designed "hourglass" base ofekornes' STRESSLESS" brand furniture name and mark in connection with AMAZON's business and advertising, promotion and sale of chairs and ottomans constitutes common law trademark infringement The unauthorized use of the distinctly shaped and designed "hourglass" base of EKORNES' STRESSLESS" brand furniture in connection with FACTORY DIRECT's business and advertising, promotion and sale of chairs and ottomans constitutes common law trademark infringement. -28-

29 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 29 of 97 PageID #: The unauthorized use of the distinctly shaped and designed "hourglass" base of EKORNES' STRESSLESS" brand furniture in connection with BUY.COM's business and advertising, promotion and sale of chairs and ottomans constitutes common law trademark infringement. WHEREFORE, EKORNES demand judgment against AMAZON as follows: A. That AMAZON, its officers, directors, principals, agents, dealers, servants, employees, successors and assigns, and all others in active concert or parties in privity with AMAZON, be enjoined during the pendency of this action and permanently thereafter from: (i) importing, selling, distributing for resale or otherwise dealing in chairs and ottomans having bases identical to, or confusingly similar in configuration to, the STRESSLESS" distinctive "hourglass" chair base design and/or which use the STRESSLESS" marks or confusingly similar variations of those marks; (ii) infringing the rights of EKORNES in the STRESSLESS" marks and distinctive "hourglass" chair base design, and (iii) marketing any product with the STRESSLESS" marks or any confusingly similar variations of those marks, and the distinctive "hourglass" chair base design. B. That AMAZON be required to pay EKORNES such damages as have been sustained by EKORNES in consequence of AMAZON's unauthorized promotion and sale of products bearing the STRESSLESS" marks and embodying the STRESSLESS" brand "hourglass" base design and unauthorized use of the STRESSLESS" marks and the distinctly shaped and designed "hourglass" -29-

30 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 30 of 97 PageID #: 30 base of EKORNES' STRESSLESS brand furniture, which damages shall be proved at trial. C. That AMAZON be required to account to EKORNES for all profits made by AMAZON by reason of AMAZON's unauthorized promotion and sale of products bearing the STRESSLESS marks and embodying the STRESSLESS brand "hourglass" base design and unauthorized use of the STRESSLESS marks and the distinctly shaped and designed "hourglass" base of EKORNES' STRESSLESS brand furniture. D. That all products bearing the STRESSLESS marks and embodying the STRESSLESS brand "hourglass" base design and all advertising, marketing and all promotional material and packaging including the STRESSLESS marks in AMAZON's possession or under its control be impounded and destroyed. E. Directing that AMAZON file with the Court and serve upon EKORNES' counsel within thirty (30) days after entry of judgment a report in writing under oath, setting forth in detail the manner and form in which AMAZON has complied with the above. F. Awarding EKORNES such damages as it has sustained or will sustain by reason of AMAZON's acts of unfair competition and trademark infringement, all gains, profits and advantages derived by AMAZON from such conduct, and, pursuant to 15 U.S.c. 1117, an amount up to three times the amount of such actual damages sustained as a result of AMAZON's violation of the Lanham Act. -30-

31 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 31 of 97 PageID #: 31 G. Awarding EKORNES exemplary and punitive damages to deter any future willful infringement as the Court finds appropriate. H. Awarding EKORNES its costs and disbursements incurred in this action, including its reasonable attorneys' fees. I. Awarding EKORNES interest, including prejudgment interest, on the foregoing sums. proper. J. Awarding EKORNES such other and further relief as the Court may deem just and WHEREFORE, EKORNES demand judgment against FACTORY DIRECT as follows: A. That FACTORY DIRECT, its officers, directors, principals, agents, dealers, servants, employees, successors and assigns, and all others in active concert or parties in privity with FACTORY DIRECT, be enjoined during the pendency of this action and permanently thereafter from: (i) importing, selling, distributing for resale or otherwise dealing in chairs and ottomans having bases identical to, or confusingly similar in configuration to the STRESSLESS distinctive "hourglass" chair base design; (ii) infringing the rights of EKORNES in the distinctive "hourglass" chair base design, and (iii) marketing any product with the distinctive "hourglass" chair base design. -31-

32 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 32 of 97 PageID #: 32 B. That FACTORY DIRECT be required to pay EKORNES such damages as have been sustained by EKORNES in consequence of FACTORY DIRECT's unauthorized promotion and sale of products embodying the STRESSLESS brand "hourglass" base design and unauthorized use of the distinctly shaped and designed "hourglass" base of EKORNES' STRESSLESS brand furniture, which damages shall be proved at trial. C. That FACTORY DIRECT be required to account to EKORNES for all profits made by FACTORY DIRECT by reason of FACTORY DIRECT's unauthorized promotion and sale of products embodying the STRESSLESS brand "hourglass" base design and unauthorized use of the distinctly shaped and designed "hourglass" base of EKORNES' STRESSLESS brand furniture. D. That all products embodying the STRESSLESS brand "hourglass" base design and all advertising, marketing and all promotional material for and packaging for products embodying the STRESSLESS brand "hourglass" base design in FACTORY DIRECT's possession or under its control be impounded and destroyed. E. Directing that FACTORY DIRECT file with the Court and serve upon EKORNES' counsel within thirty (30) days after entry of judgment a report in writing under oath, setting forth in detail the manner and form in which FACTORY DIRECT has complied with the above. F. Awarding EKORNES such damages as it has sustained or will sustain by reason of FACTORY DIRECT's acts of unfair competition and trademark infringement, all gains, profits and -32-

33 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 33 of 97 PageID #: 33 advantages derived by FACTORY DIRECT from such conduct, and, pursuant to 15 U.S.c. 1117, an amount up to three times the amount of such actual damages sustained as a result of FACTORY DIRECT's violation of the Lanham Act. G. Awarding EKORNES exemplary and punitive damages to deter any future willful infringement as the Court finds appropriate. H. Awarding EKORNES its costs and disbursements incurred in this action, including its reasonable attorneys' fees. I. Awarding EKORNES interest, including prejudgment interest, on the foregoing sums. proper. J. Awarding EKORNES such other and further relief as the Court may deem just and WHEREFORE, EKORNES demand judgment against BUY.COM as follows: A. That BUY.COM, its officers, directors, principals, agents, dealers, servants, employees, successors and assigns, and all others in active concert or parties in privity with BUY.COM, be enjoined during the pendency of this action and permanently thereafter from: (i) importing, selling, distributing for resale or otherwise dealing in chairs and ottomans having bases identical to, or confusingly similar in configuration to the STRESSLESS distinctive "hourglass" chair base design; -33-

34 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 34 of 97 PageID #: 34 (ii) infringing the rights of EKORNES in the distinctive "hourglass" chair base design, and (iii) marketing any product with the distinctive "hourglass" chair base design. B. That BUY.COM be required to pay EKORNES such damages as have been sustained by EKORNES in consequence ofbuy.com's unauthorized promotion and sale of products embodying the STRESSLESS brand "hourglass" base design and unauthorized use of the distinctly shaped and designed "hourglass" base of EKORNES' STRESSLESS brand furniture, which damages shall be proved at trial. C. That BUY.COM be required to account to EKORNES for all profits made by BUY.COM by reason ofbuy.com's unauthorized promotion and sale of products embodying the STRESSLESS brand "hourglass" base design and unauthorized use of the distinctly shaped and designed "hourglass" base ofekornes' STRESSLESS brand furniture. D. That all products embodying the STRESSLESS brand "hourglass" base design and all advertising, marketing and all promotional material for and packaging for products embodying the STRESSLESS brand "hourglass" base design in BUY.COM's possession or under its control be impounded and destroyed. E. Directing that BUY.COM file with the Court and serve upon EKORNES' counsel within thirty (30) days after entry of judgment a report in writing under oath, setting forth in detail the manner and form in which BUY.COM has complied with the above. -34-

35 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 35 of 97 PageID #: 35 F. Awarding EKORNES such damages as it has sustained or will sustain by reason of BUY.COM's acts of unfair competition and trademark infringement, all gains, profits and advantages derived by BUY.COM from such conduct, and, pursuant to IS U.S.C. 1117, an amount up to three times the amount of such actual damages sustained as a result ofbuy.com's violation ofthe Lanham Act. G. Awarding EKORNES exemplary and punitive damages to deter any future willful infringement as the Court finds appropriate. H. Awarding EKORNES its costs and disbursements incurred in this action, including its reasonable attorneys' fees. 1. Awarding EKORNES interest, including prejudgment interest, on the foregoing sums. proper. J. Awarding EKORNES such other and further relief as the Court may deem just and -35-

36 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 36 of 97 PageID #: 36 DEMAND FOR JURY TRIAL Plaintiffs hereby demand a trial by jury of all issues triable of right by a jury. Dated: March 7, 2013 By: Fred 'ck J. Dorchak (FD 3006) '---tmward J. Callaghan (EC 6244) 1077 Northern Boulevard Roslyn, New York Tel: Fax: Attorneys for plaintiffs EKORNES ASA and EKORNES, INC. -36-

37 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 37 of 97 PageID #: 37 EXHIBIT A

38 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 38 of 97 PageID #: 38 1-'. Int. Cl.: 20 Prior U.S. Cl.: 32 United States Patent and Trademark Office Reg. No. 1,224,287 Registered JEll, 18, 1983 TRADEMA.RK Principal Register STRESSLESS J. E. Ekor!ies Fabrikker A/S (Norway COipora.ion) lkornes, NorWE)' N 6122 FOT: FURKITURE-NAMELY, ADJUSTABLE CHAIRS. in CLASS 20 (U,S, C), 32), Fi:-sl1!Se hn. 1, lsil; in commerce 3"...'1. 1, 19i1. Ser. No. :;47,369, flled Jan. 27, LA.RRY BAUMAN, Ex,minir:g Attorr.ey

39 Trademark Electronic Search System (TESS) Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 39 of 97 PageID Page #: I of2 39 IIP\ United States Patent and Trademark Office.." Home I Site Index I Search I FAQ I Glossarv I Guidesl Contacts I ebusiness I ebiz alerts I News I Help Trademarks> Trademark Electronic Search System (TESS) TESS was last updated on Wed Jan 1605:02:46 EST 2013 _ -- - Please logout when you are done to release system resources allocated for you. Record 1 out of 1 lsdr return to TESS) ( Use the "Back" button of the Internet Browser to Typed Drawing Word Mark STRESSLESS Goods and IC 020. US 032. G & S: Furniture-Namely. Adjustable Chairs. FIRST USE: FIRST Services USE IN COMMERCE: Mark Drawing Code (1) TYPED DRAWING Serial Number Filing Date January 27, 1982 Current Basis 1A Original Filing Basis Published for Opposition Registration Number Registration Date 1A October 26, January 18, 1983 Owner (REGISTRANT) J. E. Ekomes Fabrikker AlS CORPORATION NORWAY Ikornes NORWAY N (LAST LISTED OWNER) EKORNES ASA UNKNOWN BY MERGER, BY CHANGE OF NAME, BY MERGER NORWAY N-6222IKORNNES NORWAY Assignment ASSIGNMENT RECORDED Recorded Attorney of Record MICHAEL J HUGHES Type of Mark TRADEMARK Register PRINCIPAL Affidavit Text SECT 15. SECT 8 (6-YR). SECTION 8(10-YR) Renewal 1ST RENEWAL Live/Dead Indicator LIVE

40 Trademark Case 2:13-cv ADS-WDW Electronic Search System (TESS) Document 1 Filed 03/07/13 Page 40 of 97 PageID Page 2 #: of2 40,.HOME I SITE INDEX I SEARCH I ebusiness I HELP I PRIVACY POLICY

41 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 41 of 97 PageID #: 41 EXHIBIT B

42 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 42 of 97 PageID #: 42 b Int. CJ.: 2.0 Prior U.S. CIs.: 2., 13, 22, 25,32, and SO United States Patent and Trademark Office Reg. No. 2,251,731 Registered June 8, ly99 TRA.D E!V1ARK PRINCIP AL REGISTER STRESSLESS l. E- EKORl'ES AS (NORWAY COMPANy) ; IKORNNES, NOR WAY FOR, FURNITURE, SOFAS, CHAIRS, EASY CHAIRS WITH FOOTSTOOL; MATIRESSES; PILLOWS; BEDS; BEDBOARDS, IN CLASS 20 (U.S. CLS. 2, 13, 22, 25, 32 AND 50). FIRST USE ;71; IN COMMERCE PRIORITY CLAIMED UNDER SEC. 4-4(D) ON ;lorway APPLICATION NO. I 9161l4!l, FILED , REG.' NO , EXPIREs ~1. OWNER OF U.S. REG. NO. 1,224,281. SN ,221, F1LED GLENN CLARK, EXAMiNING ATIORNEY

43 Trademark Electronic Search System (TESS) Page 1 of2 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 43 of 97 PageID #: 43 ~ United States Patent and Trademark Office.., Home I Site Index I Search I FAQ I Glossary I Guides I Contacts I ebusiness I ebiz alerts I News I Help Trademarks> Trademark Electronic Search System (TESS) - Please logout when you are done to release system resources allocated for you. TESS was last updated on Wed Jan 1605:02:46 EST 2013 _ Record 1 out of 1 TSDH return to TESS) ( Use the "Back" button of the Internet Browser to Typed Drawing Word Mark Goods and Services Mark Drawing Code Serial Number Filing Date Current Basis Original Filing Basis Published for Opposition Registration Number Registration Date Owner Assignment Recorded Attorney of Record Priority Date Prior Registrations Type of Mark Register Affidavit Text Renewal STRESSLESS IC 020. US G & S: furniture, sofas, chairs, easychairs with footstool; [mattresses; pillows; beds; bedboards]. FIRST USE: FIRST USE IN COMMERCE: (1) TYPED DRAWING January 23, A;44E 16;44D December 1, June 8,1999 (REGISTRANT) J. E. EKORNES AS COMPANY NORWAY N-6222 Ikornnes NORWAY (LAST LISTED OWNER) EKORNES ASA FOREIGN ENTITY NORWAY N-6222 IKORNNES NORWAY ASSIGNMENT RECORDED MICHAEL J HUGHES November 15, TRADEMARK PRINCIPAL SECT 15. SECT 8 (6-YR). SECTION 8(10-YR) ST RENEWAL :jz9rdj.3.1 1/16/2013

44 Tmdemark Case 2:13-cv ADS-WDW Electronic Search System (TESS) Document 1 Filed 03/07/13 Page 44 of 97 PageID Page 2 #: of2 44 Live/Dead Indicator LIVE I.HOME I SITE INDEXI SEARCH I.BUSINESS I HELP I PRIVACY POLICY uspto.gov lbinlshowfield?f=doc&state=4008 :jz9rdj /2013

45 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 45 of 97 PageID #: 45 EXHIBIT C

46 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 46 of 97 PageID #: 46 Int. CIs.: 20 and 35 Prior U.S. Cls.: 2, 13, 22, 25, 32, 50, 100,101 and 102 United States Patent and Trademark Office Reg. No. 3,365,565 Registered Jan. 8\ 2008 TRADEM.ARK SERVICE \1ARK PRINCIPAL REGISTER EKORKES ASA (NORWAY CORPORATION) N-6222 IKOR.""N"S, NORWAY FOR: FUFJ-<TTURE, CHAIRS, SEATS, RECLINER CHAL~, RECLIKER CHAIRS WITH FOOTSTOOLS, IN CLASS 10 (U.S. CLS. 2, 13, 22, 25, 32 Ah"D 50). FIRST USE ; IN COMMERCE FOR: RETAIL OUTLET Al'<"D STORE SER\~CES IN THE mld OF FllRl'-<TTURE A.1\"D FURNISH INGS, IN CLASS 35 (U.S. CLS. 100,101 AJ'o,'D 102). FIRST USE ; IN COMMERCE PRlORITY CLAIMED UJ'o,"DER SEC. 44(D) OK NORWAY APPLICATION NO FILED , REG. NO , DATED 6-1'9-2003, EX PIRES O\VNER OF U.S. REG. NOS. 1,224,287!1...1\"D 2,251,731. SER. NO ,167, FILED L!J'o,"DA POWELL, EXAMIN"ING ATTOFJ-<"EY

47 Trademark Case 2:13-cv ADS-WDW Electronic Search System (TESS) Document 1 Filed 03/07/13 Page 47 of 97 PageID Page I #: of2 47 &\ United States Patent and Trademark Office \I!Il' Home I Site Index I Search I FAQ I Glossary I Guides I Contacts I ebusiness I ebiz alerts I News I Help Trademarks> Trademark Electronic Search System (TESS) TESS was last updated on Wed Jan 1605:02:46 EST 2013 Please logout when you are done to release system resources allocated for you. Record 1 out of 1 TSDR i\ssigu st.:ltus TTAIl Status return to TESS) ( Use the "Back" button of the Internet Browser to Slresr/ess Word Mark Goods and Services STRESSLESS IC 020. US G & S: Furniture, chairs, seats, recliner chairs, recliner chairs with footstools. FIRST USE: FIRST USE IN COMMERCE: Mark Drawing Code Design Search Code Trademark Search Facility Classification Code IC 035. US G & S: Retail outlet and store services in the field of furniture and furnishings. FIRST USE: FIRST USE IN COMMERCE: (3) DESIGN PLUS WORDS, LETTERS, AND/OR NUMBERS Triangles that are completely or partially shaded Triangles with one or more curved sides Miscellaneous designs with overall triangular shape; Triangular shape (miscellaneous overall shape) SHAPES-MISC Miscellaneous shaped designs SHAPES-TRIANGLES Triangular shaped designs and marks including incomplete triangles Serial Number Filing Date December 22, 2002 Current Basis 1A;44E Original Filing Basis 1 B;44D Published for Opposition June 21, 2005 Registration Number Registration Date January 8,

48 Trademark Case 2:13-cv ADS-WDW Electronic Search System (TESS) Document 1 Filed 03/07/13 Page 48 of 97 PageID Page #: 2 of2 48 Owner Attorney of Record Priority Date Prior Registrations Type of Mark Register Live/Dead Indicator (REGISTRANn EKORNES ASA CORPORATION NORWAY N-6222 Ikornnes NORWAY MICHAEL J HUGHES November 12, ; TRADEMARK. SERVICE MARK PRINCIPAL LIVE -- I.HOME I SITE INDEXI SEARCH I ebusiness I HELP I PRIVACY POLICY /2013

49 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 49 of 97 PageID #: 49 EXHIBIT D

50 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 50 of 97 PageID #: 50 Int. 0.: 20 Prior U.S. CIs.: 2, 13, 22, 25, 32 and 50 United States Patent and Trademark Office Reg. No. 2,468,790 Registered July 17, 2001 \ \ TRADEMARK PRINCIPAL REGISTER EKORNES, INC (NEW JERSEY CORPORATION) 500 MEMORIAL DRIVE SOMERSET, NJ FOR: CHAIRS AND OTIOMANS, IN CLASS 20 (U,S. CLS. 2, 13, 22, 25, 32 AND 50). FIRST USE ; IN COMMERCE THE BROKEN LINES ARE NOT A FEATURE OF THE MARK AND ARE NOT CLAIMED AS PART OF lliemark. THE MARK CONSISIS OF A CIRCULAR WOO DEN BASE IN THE FORM OF AN ANNULAR RING HAVING A PAIR OF SPACED APART UPRIGHTS WHICH CONl\' CT ON DIAMETRICALLY OPPO SITE SIDES TO THE INSIDE SURFACE OF THE BASE RING AND CURVE UPWARD IN THE SHAPE OF AN HOURGLASS OR WINE GLASS, TO PRO VIDE A PAIR OF SPACE!)"APART, VERTICALLY EXTEl'-.'DING UPRIGHTS FOR SUPPORTING THE CHAIR. SEC.2(F). SER. NO ,672, FILED RODNEY DICKINSON, EXAMINING ATIORNEY

51 i-ademark Electronic Search System (TESS) Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 51 of 97 PageID #: 51 ~ United States Patent and Trademark Office 'SI Home I Site Index I Search I FAQ I Glossary I Guides I Contacts I ebusiness I ebiz alerts I News I Help Trademarks> Trademark Electronic Search System (TESS) TESS was last updated on Mon Feb 4 05:02:46 EST 2013 Record 1 out of TSDR ASSIGII status TTA8status return to TESS) ( Use the "Back" button of the Internet Browser to Goods and Services IC 020. US G & S: CHAIRS AND OTTOMANS. FIRST USE: FIRST USE IN COMMERCE: Mark Drawing (2) DESIGN ONLY Code Design Search Arm chairs; Bar stools; Bean bag chairs; Booster chairs, baby; Chairs, (bean bag, desk, Code dining, folding, high, rocking, chaise lounge); High chairs; Ottomans; Rocking chairs; Step stools; Stools Serial Number Filing Date January 19, 1999 Current Basis 1A Original Filing 1A Basis Published for April 24, 2001 OPPosition Registration Number Reg istration Date Owner July 17,2001 (REGISTRANT) EKORNES, INC CORPORATION NEW JERSEY 500 Memorial Drive Somerset NEW JERSEY Asslgnment Recorded Attorney of Record (LAST LISTED OWNER) EKORNES ASA COMPANY NORWAY N6222, Ikornnes NORWAY ASSIGNMENT RECORDED Michael J. Hug hes

52 rademark Electronic Search System (TESS) uspto.gov!bini showfi el d?f=doc&5tate=4009: l2yn Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 52 of 97 PageID #: 52 Description of Mark Type of Mark Register Affidavit Text Renewal LlvelDead Indicator The mark consists of a circular wooden base in the form of an annular ring having a pair of spaced-apart uprights which connect on d'lametrically opposite sides to the inside surface of the base ring and curve upward in the shape of an hourglass or wine glass, to provide a pair of spaced-apart, vertically-extending uprights for supporting the chair. The broken lines are not a feature of the mark and are not claimed as part of the mark. TRADEMARK PRINCIPAL-2(F) SECT 15. SECT 8 (6-YR). SECTION 8(10-YR) ST RENEWAL LIVE I.HOME I SITE INDEX I SEARCH I ebusiness I HELP I PRIVACYPOL1CY

53 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 53 of 97 PageID #: 53 EXHIBIT E

54 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 54 of 97 PageID #: 54 Int. 0.: 20 Prior U.S. Cis.: 2, 13, 22, 25, 32 and 50 United States Patent and Trademark Office Reg. No. 2,459,034 Registered June 12, 2001 TRADEMARK PRINCl'P AL REGISTER EKORNES, INC. (NEW JERSEY CORPORATION) SOO MEMORIAL DRIVE SOMERSET, NJ FOR: ciiairs, IN CLASS 20 (U.S. CLS. 2,13,22,25, 32 AND SO). FIRST USE ; IN COMMERCE THE MARk CONSISTS OF A ROUND BASE WIlli nvo CURVED LINES OR LEGS RISING INTO THE BOTfOM OF TIiE CUSHIONED SEAT OF A CHAIR. A KNOB ATfACHED TO THE SIDE OF THE CHAJR SEAT CUSHION, AND A METAL BAR ATfACHED ON ONE END TO THE ARMREST OF THE CHAIR AND AT THE OTHER El'-.'D TO THE CHAIR LEGS. THE DOTfED LINES SHOWN IN THE DRAWING ARE USED ONLY TO SHOW THE POSmON OF APPLICANrS MARK ON A FINISHED PRODUCT. THE BROKEN LIl'-.'ES ARE NOT A FEATURE OF THE MARK AND ARE NOT CLAIMED AS PART OF THE MARK. SEC 2(F). SER. NO ,649, FILED RODNEY DlCKJNSON, EXAMINING ATTORNEY

55 rademark Electronic Search System (TESS) uspto. goy!bin! showfield?f=doc&state=4009: 12"n Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 55 of 97 PageID #: 55 ~ United States Patent and Trademark Office 'e Home I Site Index ISearch I FAQ I Glossary I Guides I Contacts I ebusiness I eblz alerts I News I Help Trademarks> Trademark Electronic Search System (TESS) TESS was last updated on Mon Feb 4 05:02:46 EST 2013 'A.4lL1~:' L41!1I1""M~.i i \.L, g~~t] Please logout when you are done to release system resources allocated for you. Record 1 out of TSDR I ASstGtl status TTABstatus return to TESS) ( Use the "Back" button of the Internet Browser to Goods and Services Mark Drawing Code Design Search Code IC 020. US G & S: CHAIRS. FIRST USE: FIRST USE IN COMMERCE: (2) DESIGN ONLY Serial Number Arm chairs; Bar stools; Bean bag chairs; Booster chairs, baby; Chairs, (bean bag, desk, dining, folding, high, rocking, chaise lounge); High chairs; Ottomans; Rocking chairs; Step stools; Stools Filing Date March 18, 1999 Current Basis 1A Original Filing 1A Basis Published for M h arc, Opposition Registration Number Registration Date Owner June 12, 2001 (REGISTRANT) EKORNES, INC. CORPORATION NEW JERSEY 500 Memorial Drive Somerset NEW JERSEY Assignment Recorded Attorney of Record (LAST LISTED OWNER) Ekornes ASA CORPORATION NORWAY N-6222, Ikomnes NORWAY ASSIGNMENT RECORDED Michael J. Hughes

56 rademark Electronic Search System (TESS) : 12)' Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 56 of 97 PageID #: 56 Description of The mark consists of a round base with two curved lines or legs rising into the bottom of the cush'loned Mark seat of a chair, a knob attached to the side of the chair seat cushion, and a metal bar attached on one end to the armrest of the chair and althe other end to the chair legs. The dotted lines shown in the drawing are used only to show the position of Applicant's mark on a finished product. The broken lines are not a feature of the mark and are not claimed as part of the mark. Type of Mark Register TRADEMARK PRINCIPAL-2(F) Affidavit Text SECT 15. SECT 8 (6-YR). SECTION 8(1 O-YR) Renewal Live/Dead Indicator 1 ST RENEWAL LIVE I.HOME 1 SITE INDEX I SEARCH I ebusiness 1 HELP I PR/VACYPOLICY

57 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 57 of 97 PageID #: 57 EXHIBIT F

58 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 58 of 97 PageID #: 58 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK x EKORNES ASA AND EKORNES, INC.. FIt.: 10 D IN CLERK'S OFFICE U.S. DISTll,\Gl COURT, co,ny, " LONG 19!,A!.J:J OFnr;E... ;,s * SEP f' 0 '!9~(; '* vs. PlainliflS, Civil Action No (JM)(ARL) I FURNITURE BRANDS INTERNATIONAL, INC., LANE FURNITURE INDUSTRIES, lnc., AND ACTION INDUSTRIES, INC. Defendants x FINAL CO'NSENT JUDGMENT AND PERMANENT I'NJUNCTlON -/' This case having col11e on to be heard upon the application of the parties hereto, and Plaintiffs and Defendants having agreed upon a basis for settlement of the matters averred in the Complaint and having agreed that a Final Consent Judgment and Permanent Injunction in the form herein be entered, it is hereby ORDERED, ADJUDGED AND DECREED as lollows: 1. This Court has jurisdiction over the subject matter of this action, it arising under the Trademark Laws orthe United States, 15 U.s.C. ~ II25(a), et seq., and Defendants hereby consent to the jurisdiction and venue orlhis Court, solely lor the purpose of til is case. Any other findings with respect to corpora Ie stntus and pe,.,;onal jurisdictioll are hereby withdrawn.. This Court hereby retainsjurisdictioll orthis malter. The Court retains jurisdiction over any and all claims arising out of the settlement agreement. C~,\VIHOOW'!>\I'IO~ II'\EI"'II'~. H'~,I": '.,.. ~," J"'I~"'.1II1." Ikl ATTACHMENT B

59 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 59 of 97 PageID #: This Finnl Consent Judgment and Permanent Injunction is a substitute for the July 6, 1999 Preliminary Injunction and Memorandum of Decision. 3. Plaintifts warrmlt that they are the exclusive owner OfCel1flin trade dress embodied in their STRESSLESS" recliner chairs in Ihe Ibrlll 01" an hourglass bent wood base and black control knobs on each side, which Ihe COUf'! has found 10 be infringed by Ihe Defendants' Leather Rest recliners in the COlin's Decision of July 6, 1999, The Court also found that PlaintitTs' hourglass design was inherently distinctive, 4. Defend8l1ts acknowledge that their manutact"re and sale or their Leather Rest chairs, which contain an hourglass design and black knob, infringe the Plaintitl's' Trade Dress design of the STRESSLESS" chair. 5, Defendants acknowledge that the use of 'plain tift's' Trademark STRESSLESS'" constitutes Trademark inti'inge01ent ofplaii1tifl's' incontestable Trademark Reg, No. 1,224,287 for the sale of recliner chairs. 6. Defendants, their agents, servants, employees and all persoll's who act ill concen with, or under the control ot~ ownership oc or at1iliution with Defendants, are permanently enjoined from infringing Plaintitl's' Trade Dress and the Trademark STRESSLESS'" in the United States and throughout the world, including b,llt not limited to mai1ut'acturing, marketing, advenising and selling furniture using Plaintitfs' Trade Dress, or Plaintitr's' incol1testnble Tradenwk STRESSLESS", or any colorably similar designs Or words thereot:'in connection with furniture products and services relnted thereto. 7. Defendants will destroy all advertisements, lelterheads, packaging, and any other like materials relating to Plainlit1S' Trade Dress and Plaint;"tTs' incontestable TI'ademark STRESSLESS", 2 ATTACHMENT B

60 1 I I Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 60 of 97 PageID #: _ Defenda"t Action shall withdraw its North Carolina la\"suit against Plaintiffs, Civil Action No. I :99CV00268, as SOOIl as possible with prejudice. and shall instruct its European attorneys that a settlement has been reached with the Plaintit1"s, and to withdraw with prejudice all European legal actions with the PlaintitTs. Likewise, Plaintit1"s shall withdraw their European actions and submit to the applicable European courts suitable stipulations that settle the European cases. The pal1ies shall also withdraw with prejudice the Appeal of the July 6, 1999 Preliminary Injunction and tvienlorandum of Decision pending in the U.S. Court of Appeals for the Second Circuit, Docket No Remaining terms are set tanh ill the Cltlached ('c)i!fhlul7fio/.)'etllelllf.!111 Agrr:f!meI11, which shall be held under seal by the C011l The COUI1 finds that no just reason for delay exists and directs entry of this Final Consent Judgment and Permanent Injunction. which dismisses their actioll, with prejudice, and thereby disposes of all matters in issue in this case. Dated: Uniondale, New York. September,?", 1999 SO ORDERED: 3 ATTACHMENT B

61 J l Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 61 of 97 PageID #: I I i I Injunction: We hereby consent to the entry of the foregoing Final Consent Judgment and Permanent Dated: Garden City, NY September LQ, 1999 NIXON PEABODY LLP 990 Stewart Avenue Garden City, New York By:/f -1A::F ohn F. Bolton, Esq. Attorneys for Defendants Dated: Roslyn, NY September /Q, 1999 COLLARD & ROE, P.C Northern Boulevard Roslyn, New York BY: ~S!.~~~~_ Alison C. Collard Attorneys for Plaintiffs 1 I 4 ATTACHMENTB

62 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 62 of 97 PageID #: 62 EXHIBIT G

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66 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 66 of 97 PageID #: 66 Amazon,com: Stressless Style Black Top Grain Leather Recliner and Ottoman: Home,.. Page 3 of 3 other customers suggested thelle Items I ~u..lfi\ by William Sinunu 25..Iw!llA.ut11 regm $0.25 SlIggnted bv 1 wltomer (;,n 14 \/SId" npw f'ro!ll t59,94 5uggeslld by 1 customer Customer Questions & Answers Look for Similar ltem!l by category Hqme & Kltchftn > ~ :> LIving Boom Furniture > ~ > ftgqjnm Feedback, If you need help or have a question for Customer Service, Q!llps1...Wl:. ~ Would you like to ~udhgk..mu.1ilii.rh. or tell US 8bQu~~? ~ Is there any other feedback you would like to provide? Click hel'e Y()\Ir ROGont History (V/bal'! th!s1) Gl'It1Q Know U" C1'lI"8&ra lnva:stor RalBUonB PraM Rel!*llWs I'l1'1UZOfl I:IIld Our PIS10t Amazon in ills Communlt)' Mnk... MooCly w1th lffl SoU on Ama:lon Become an Affi~a\e! Advanb09 Your Products Indeptlndt.'J1Ilr Publish with Ua ~ S09 au l.ot 1)(1 Holp You Your J\cc()lmt Shipplrq Rates 8. PoliciM Amazon Prlrna R~llurns Am Easy MiV\3{.]e Yoyr Kindle Halp ama~on.com '--_..,' "'boboo~!l.,~[_~ S.T~<lM~:..o AnIGJ.Iri.OIl.1 G!'''''L'''.:.II~11 ~ '~;/f(ltt, NMzcnSIIPPiY f""'n."",!ro<l~wl>l,!,';{:'nl,tol!)u;"iii> i\ri!illdnwri>8gnlco&.4m.iilo!\'o\t!tli~g ".hlho <'<.,.I/II:.It (;""J M".~.','OIl1;""'~"1 <:"'ll"i).... i>!ii \1\.. "1..,,, PI,,,. 1>"""",,1'$ """" 1;-><;."li<>I>o1 ~ ;U.. p"",*,~ """I.",&u..,,,t, l3olut~ljar.com r...;,;,.r... d ~~~:~I)' r.:'i'i~'1i'} \"V~'I<i",",,~, C.n!3(1iSi*'AI,,,,,~,,,~,,,,,,,,I'l ~~Ea,. DilpeNI.I1Om ~.~f't.:"[r.,,, W:Ig.CDIl'I ~2 r.',"~:(" Df'ReYluw r'i!.&1!'ll<>\t>(l'oro ~' Wnr..'lOuo') OIlQb '~I''''' IiI... ijh, ".'"\ "".. ''''''.Fungloo.cQIn fl... ;/t\p.,"""~~... ~""~, 1'! ll"""'~~"'h., ""llt~ly ~C'IIo~r'li'l~ ".II>a;. WOo, Yoya,COflI,'-J_'G"""~ ""... rr P... z.,pfl<ll..,...,~,~ c~,~ Ie." l'i' ~) :~'''.. r.~,t~<\ ('~"'f'" MYHA81T Gtlopbtlp P'i'v~"'~.,rn.:.~ ()ft'~j''''!l'i!i<j'"r ~"q. f' ~.r..,. 6J~""" Ylno,,,,,m Can.r.am """'.PI>.,,~ I"",."", r.1""~" ":'J,""I"~,f'.~ -' (... t\~,,.,}... ~ GORp,COIII '1.H".i;",,\~,<$ H "''';'''~I.. ''';' Cc.nlllUons or U~" PrMlcyNoli(:& 1t\IGror.t,rJIlroI:IAd~ '~1~'liJ.~,?. /IJ'U,(IIt ",,,,,lin,:, I;lf~'.I!I',IO<\" 1/3/2013

67 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 67 of 97 PageID #: 67 Amazon. com: Acme Piece Lauralyn Stressless Chair and Ottoman, Espresso... Page 1 of 4 - Shop by Department stressless 'lo I'IIII!,\. Sign 11) Your Acc()Unt Join Prim!) o cu, "'.h List Acme Plece Lauralyn Stressless Chair and Ottoman, Espresso Finish byawfi Prlct;.: $ (Ul/IIP01N' "vic"> I (0) In stock. Processing tak.es an additional days fer orders from this seller. Ships from and,old by Hom, and UlllOq. lauralyn oolloatlon 81tllSsieu chair Blld ouomm..,.. Mlldu 01 pol)'\1'11chanejpvc, IrOl'l frame palnt9d Inal~ with wooden base.. S~II~h round base ICI both ottoman and chair AI/dahl.. I1l1J1preslo 1ir11sh Chalrmeasu'et 31-1ength by 2a.lnehwktlh by 41- helgh~ oltorm.n meiliunn 19-1ength by le...,dlh by 17-helghl Q""n'.ltv: ,',,,,, $,,~::"'l In stock. Proc.ung takm ~n lki<ttlon~1 4 til S d!l\'$, Sold by Homa.nd Living :a!w1j.!j. to tum on " l Cllcic ordorlng. More Buying Choices Amszon.oom $ J."" R~' "'1'" ).): filet... 11' S"I'''' ~Iorr'" lli>ippl"g. Qr.llll!t a...n.ut from $ Customers Whu Viewed This Item Also Viewed Page 1 of6 AQ1'IO PIece LlIIlJrlllyn StN,m Choir olld O\tOmllll, 1y0f)' $ Mac Motkln Chllf" MndII12 PlIICO Roeilnerwllh MQ~\J Olleman Modus MI~w wilt! Wlllnul.. (22J $ Moo M(}~Cln ChIlil'1 ModII12 Ploeo Rlldlnt!I with Mlilching Ottomon $I!ddIq, LI!Ia~1Elf with PacQl'l FlltIM $ m AaTl!J Pieco L()IlslI S\lo&5IAS~ Chllir o~ OUotn'I/l, BI~ct; $ LGati'lGr NOIWfI{lian ErOOI\<wnic $r.\llnt!i/l8vhln Loul'(l(l Reclining (:fllll\r Fjords 215 Mukla\ 5mB'. (].) $1, Product Detall9 Product Dimensions: 31.5:w; 23.6:w; 21.3 Inches; 114 pounds Shipping Weightr pounds (Yl~.ml.lml.n.g...ratttllllllJ)Qlkla~) Shipping I Currently, Item can be shipped only within the U.S. Shipping Advlsorv: This Item must be shipped separately from oth@rltemsln your order. Additional shipping charges will not apply. ASIN: B006U3AXXO Item model number: Average Customer Rev1ewl (l.sllrumer reylew) A.mazon Best Seller. R.ankl #153,838 In Home & Kitchen (See Top loo In Home &; Kltcll ll) Old we miss any rele... ant features for this product7 Icll.Jw..wbilt.W.q~ Would you like to give feedback on 100PgM or tm1...u.lbbwltj! lower prlce7 Product Description dp/b006u3axx /2013

68 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 68 of 97 PageID #: 68 Amazon.com: Acme Piece Lauralyn Stressless Chair and Ottoman, Espresso... Page 2 of 4 A vel)' relaxing WilY to work and stay In the office with this Espresso polyurethane leather chair and ottoman set. With stylish round base for both ottoman lind chi!llr. functionality and style rolled Into one. Durable construction. Made of polyurethane/pvc, Iron Frllme painted Inside with wooden base. Chair measures 31-length by 2a-lnch width by 41 helght. ottoman mei!l5ures 19-1ength by 19-wldth by 17-helght. Made In china. This product weighs 114-pound. Product Ads from External Webs:ltos (~) Mac Motion 84 Swivel Recliner with Ottoman In Nubuck Bonded Leather $ Fr Shlppklll I..'!WlU1U!Ikw Mocha Mlcroflbel' Swivel Recliner Wltll Ottoman Gll) $ Fr.. Shipping.=- SEI Bny HIli Taupe Leather Redlner Bnd Ottomnn UP1332RC ~ $ l'rga Shipping 01ft«ll1ltx llle Coaster Swivel Donded Leather Match Leisure Chair Md ottoman Se... (lj $ Willi Sh!pplng!:;YDlA!LW, Mocha 7151 Series MlcroHiler Swivel Recliner and ottoman $ 't'ge.5hlpplng.'l(!).!lI.!!.a!U..IdUlI.WZ;'&l... Adyerti... lu'l'p Customers Viewing Thill! Page May So Interested In These SponsQred Links (~) lkimloff!rjal Site 111 Create a New living Room To Suit Your Style At A Great Price. KlD.E!..lr.!..Eilll.1lli!I (!?1 America's ill Solid Wood Dining Room Available at Accent all the Home NY ~...J..lI~lI1!1 ~ Explore StTessless Chairs. Get Answers Now on Ask.com. See ii prublam With thllsii advllrtfliements? ~ Available Warranti.es for This Item I., ~5:t -: swrtguard 5~Year furniture pmte!j1~ ($2.QQ~$ l~l~~~ Smar1:Guard 3-Year fyrnll.1!.rjl.e.r..ql:~ ($200-$299.. $21.99 $14.99 CUstomer Reviews (1) o o o o Moat Holpful Cuetomor Reviews Sha(t'J yow" th,~uljhis 1'11111 olh,')!" clist(li1wtr& 'Nilla n cllalomel leview Wlilght Watchers Online Is I.t flexible wetght kjs$ So it fit into my b\'isy 1itP. perf~tly. -Ml!ry 1 (" 1 ~'I'>.1~f.JI,p<l m!) r(l~"i\l rtl',111.,., I~!U! Nh:::u Chair C~,Jn'iI'J'!f 16,2017 By I(lWlnlllh (3flly. Sf 113/2013

69 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 69 of 97 PageID #: 69 Amazon.com: Acme Piece Lauralyn Stressless Chair and Ottoman, Espresso ". Page 3 of 4 I bought thl, CIlairfOf my lovoly wife, Ilnd $hg I think ii's pretty comforll.lblo, bull tmlnk tho chair ill oliula allon for a 1Ijj( foot guy (I fi.joll1ln my knggs v(llcm I silmd up from ttlll Chalr).l1lf) wife lovas It lhougfl, and Ulal's all ttwl oourll-;!i SOQrch Customer RevIew. III Ontv lurch this producl'l,,,,,ie,,, 0, Soo the customer rovlow Looking for "strt~ssle!!ls" Produd$? Other customers suggested these Item" Ib..c...~ by William Sinunu ~5 \lard '" OBI! from $0.25 SlJOOIltod by 1 Cl.Istomer (ll }.i..i!w.a!.ill~'r\lm $59.94 SIIggasted by t customer Custom~r QUHtions & AnSW9nl1" See nil 2 qu~isuom~ eglft This Item ~!l!:!..l!l!!!!i Instant Dellveryl iii gift card sugljbst1ng this Item Flexible Gifting Cholcesl They can choose this, or pick from millions of other Items. ~!ij~(!w..,," Look for Similar Items by category HQrne & Kitchen> fl.u.n!tu..rft > b!yi.n..q Room Furniture> QllQmW _._----_.._ _._--_._.._ Feedbadc If you need help or have B question for Customer Service, S<2..!!!ru<.ty.@. ~ Would you like to give feedback on!magss or tell Uri.. bout <I lower Drlc:e? I, Is thllrt!! any other feedback you would like to provide? ~t: Horne mid Llvlnq privacy Statement Home and I.Mno Shipping InFormaUoll Home and l!ylng Retums & Exchi'JIlges Your Racent History (Wl1~l" thlsn Get to Know Uf; MosKIl MQnllY with U~ I.ot Ull Hulp '(QU dpib006u3 AXX... 1/3/2013

70 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 70 of 97 PageID #: 70 Amazon.com: Acme Piece Lauralyn Stressless Chair and Ottoman, Espresso... Page 4 of 4 ewe61's Invostor Halatloll!! Pr!!oGS HBlfloSe&.AmllWn and OUr Ploml Amamn irl Iho Community Sell 0/1 AmQ7.Dll B ieomo all A1nllllto Adv~rll.e YOl,lf PmducL, tndepmdantly Publil.lh with Us I Sea all Your Actl(lunt St~pping Ralos t. Pullelas Am~lron Primtl R~urll' No, Easy M~lrlaga Your l(indlol Hl:>lp.,..., ama~on.com CBI1i1da Chi1a FruoCII GornUillY I\.1ty JPIffiIl Spalu ljni!~d Klllodom Abllllooku bffle"(.jo,.r..""'~'-"'; CIMleSP*'CQ 1~:iI'i".""';',": I,!~j~ ~"'l' iim/rl:nulooiii ;JIi'''!A~I~'al(,>,..".. (~~I DiUpBfS.OXIRI "'''':<1<',,"1 ~"I... c.~,. WlIjJ.com ~~!"~:;~~'Ilrrt i\m.iltoql)uprjly E<""'~-II-'1. 1".1.;:;11",.. ;,,,,,,,'r;;'''i''iii~''''' Ol"flElview O~fi" "''''~''''''I'h. WRrehPUllij <~"'.'l(> C""'('l"'~; AmD1onVlklbGuIv\cU.$ AIl1ll7.0I,W!rUIOSI : ;r.,illi';';' ':'filpll(.;tcll & l:"'"d;:;',... "~,.""~..".p... Fobn~ ~i~~~'ii()o"'a"o Woo, IMOb '~"..., N ~.,:otht:<i!'" Yoyo.\lUI"I\ <;"t,,'"'''''''' "1-01'1'1'1' "... <:"." fu"ii> h~1.i>i ~F~. ("r' ASlII'IA" C:lo'IItN",~{ "~"... " Ju"gle$.(IlITl i~:wo,,"'" "'0.'',. Zar>lJOU ~"~"f-t. c,,'~"'~ A"d\l)I~ ;)~-""'~".~.<'U ;'lu,u:., M'iHAOn' '>Po,.t,".. i,,,,- t'miii'<'~;i;~ V1,w.l'\I)!I\ ~ "')V'..'I ~'i./.'<iv" ;r.",~ aailljl~(lu!."jm ~1'le!'tI'1 f'!'la,~'r '''''''''''''' Shoplxlp!}'U ~.~"T ' l"ihi'[~8,, j, Coso.mlll ~ "&-:','~~~~:~1~"" [loot: D~pf)"tJtV 1:(... ;.,. Iv.ti, 1'-"1 [;.'... ~Wr"'~..:.I', 1/3/2013

71 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 71 of 97 PageID #: 71 Amazon.com: Stressless Style Stone Top Grain Leather Recliner and Ottoman: Home... Page 1 ofj Sh<lpby Department stressless 00 ~1I0.SI!il'tlll Your Account o Cart...,' L1at Stressless Style Stone Top Grain Leather Recliner and Ottoman by"""""!!j!l$.1~!ill.21,1!'tl!itlij1!1wn I (0) $ t<., ~""~,*"., tnl~ A,,,,,n,,,b'e ;1~ o'j.u~rfl<'lr wli!bsllo Whole 11I f\.lrnlturo Broker. _~iw(lw.'~ijii$ii~ PriCP.: $449,00 Product Ads from external websites (~~!z) Ships from lind sold by Wh.Ql~:.I!W_Il;:!'!'m 1l1:PMti 5t!~ it prclllll~m,... with an P.xt'!1111'!1 wf.l\y.i:,te Qffer' l&.t ort~" dllplaylrog tnq AmaoDfl PIYI'Mntl badga let you know you can p...,. uslno VOIIr Amalon cr.dantlal, an lhe Scll"'$ 511Q, WId ~. Q ~"Iled ~e. WVOll'Bd b}'\he~~~ s;'rodn1t Mil; (UIWl..llUl) ~ Share your O~. t..!lr.ustoi1'lru'~~ Customers Who Viewed This Item AI90 Viewed Page 1 of 2 '1\... ~l!~) Moe MotJon Chain Modul :!. PIoe$ RoellrwJr with t.ultchlnlj Ollomon Mocha Mlcru/lbur with Wllnut... (22) $ Mac Mr.lticn Chail"l Mod1Jl2- Ploco Roc(h'lOl' With Mnk:hlnll OItoman SlKldlB Leather wlttl PeciYlFmO\ll m $ Mac MoUm1!l2 82 SethU Microfiber E!SO ROciln()r and Olomlll"l $ l.elllhiij NOI\Wgill1l F.rgonomk; Scmdiru~vlllll LOUl\(l8 Rf.lCliring Chair Fjords 215 Mlidall Smal.. (', 51, MIlt: Ml)llun Ch"ffl MOOfJI2 PIoCII Reclinal with Mpldlh;,l C)ttoman Ellllck li!litllorwllh Wtllnut. (22) $ Product Ads from External Web$ltes ~J.J:ttll Spon9'ored Content 13/20 13

72 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 72 of 97 PageID #: 72 Amazon.com: Stressless Style Stone Top Grain Leather Recliner and Ottoman: Home ". Page 2 of 3 Stressless Style Bli!lck lop Grain Leather Recliner and Ottol11<1n $ ree Shipping ~!.m.ll. 'rglwu! 54L H103CTC Mac Motion Chell's Cobbles\one l.eather RodlfUlr and Ottoman SWivel Recliner with Set In Chocolat() Otto... Mlcroflber (ll) $ $1, fr_shlpplng + Free Shipping ~ Mt!!l!.\lIit~v.tlJl!l Mac Motion 52 Series IAllth(1r Mat!:h Recliner Chair $ '1'8. Shlpplno ~1!ll!..lI.lJlS, Mac Motion 81fJ Serl{~s Sage Softskin Pndd(lfJ Mlcroflber Hecliner CoO. $: Froa Shipping 'lw.u.1ru;. See it problem with these ~dyelrtl5emlilflts?.~~.~.s_.i!-!l~ Product Details ASINI B0069CTXSS Average Customer Review: :e:~12..m' W1tlhl~!!l Amazon Best Sellers Rank: '2,260,423 In Home & Kitchen (ii Top 100 In!!QOlf:_UU&tl!m.) Old we miss Bny relevant features for this product? Iru!.JLU!ib.Dt~1HruL Would you like to give fuedhads 011 In'lilDH or mill:!i...!tl2qut it IowQr prlco? Product l>el51c:;rlption The top grain "Marlo Stone" Stressless Style Leather Swivel Recliner Chair and ottoman Set by stanley Chair feamres a stylish contemporary base. Turning on a 360 degree swivel base, this luxurious chair has been meticulously designed for the ultimate In comfort and support, whether sitting or reclining. The easy patented latch release mechanism allows the chair to recline back with Infinite positive locking positions. Ergonomically designed, the chair provides corl'llct lumbar and head support In all positions. Featuring a style similar to Ekomes Stressless Recliners at the fraction of the price, Stanley Chalr's trend setting design Is extremely comfortablel Please Note; The main Image on this listing In temporary. CU9tomers Viewing This Page May Be Interested in These Spcmsored U"ks (~r!uh!!!1l lkea Official Sito &:I Create a New Uvlng Room To Suit Your Style At A Great Price. KInCaid EurnltlG rfi!'i America's 11 Solid Wood Dilling Room Available at Accent on the Home NY StrgP!!I,,!!, Chain! t'1i Explore Stressless Chairs. Get Answers Now on Ask.com. SlIa a proljlfim with thase Idve.r1;lsIIments1 ~ Cust.omer Rovlews "~t 1' J &tar 2:.1111' l:.t,v Shaw ytlllr IhQyg!1t~ with olin" t'u~iol''li3 ~~-~:~;~jj~}!m~i,j!~tt~i ama~on.com ~<"( Millions of items shipped free Looking fo.- "stre55iess" Produ..:t,? Other customers suggested these Items: dp/b 0069CTXSS/r... 1/3/2013

73 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 73 of 97 PageID #: 73 Amazon.com: Stressless Style Stone Top Grain Leather Recliner and Ottoman: Home... Page 3 of 3 The Sweet! 100 by WIlliam Sinunu?~ '.. 0'" ",.. from,0.15 SUlJgestad by 1 wflomer III 1i.J~ frql" $Sg.9~ Su~u...ted by ll;\lltomor Customer QUf>stions & Answers Look for Similar Items by Category J:W[!lIJL~l )0.Eill:I!Itllm, _..-._-- Feedback.. If yotj need help or have a question for customer Service, Sgntgst!Ii, Would yotl like to ~.mlj;t~jmgm or tgllyu.ilqj.lt.ijgwer prlc,?.. Is there any other feedback you Would like to provide? Click hora Your R8C(mt History (WMI:'$ thl.n) Get to Kn<JW Us Curaors Irw~()r RalFltk'llls PAIn ReleliSelt Amlil..on aj1d O~II" Planet Amazon'" Ihe Community Make Ml)floY' with Us Soil on Amaz<1I'I Become an Millato Adlf8rtille 'tout Products Indepandan~jI Publish wiln U! I SaelIll let Ufi H",lp You Your Ae<:ounl Shipplno Riltall & Policies ArnlrlOn Prirne RellXllS he EOf>Y MAnaga Y\lUr Kinala lielp Ab&900k, "... ~?--, ~'",t""".. ""l1n'{<l'llo~1 ';..~.t\ J,..,IIt:~.,I\ "'~II" c.-.. An\lW)llSUPllly a",...'...,rl...!n!i' <'<~"''''''('" ''''''~''''6 AlTltll"!l~bS6N1r.ll.~,l,ITIlIZOl1'MWIUII A.~bll'" J"~"':.!oo -::"',"':.11"' ~ ':0"'1'""0,,',,..,...""~... ~, W ~"" I "~"..\".,... ""rllblfj L-.~~I"'.. >I,','""!l.... 6G~\lIyfI<Ir'''''nl """:-"J&"""t,. 1,,,,-..,,,,; auu~ Dllpnftllll'l Il~'ri' '...,'!' r"", r',,_~~ y "'~';,l.,,,,, C"Q!eSpac:u '... I ""!"'t.'i'~ ~""~u.. DllpUI~.wm ""~''''1 ~~'TI~,fM" (lj'r/;yioyo ll'ji.., "W~"1'''I'''1 FQblkI IMDU J~lI\llfloll cnm '... ':'I"''''~ M~""'4. r, 'l~u~.:... ~'" ~K'>II'~'Ii ',!;.. ~l.'~... " ",J..,. MYHAarr Pl'''~:~,".ttl'",,,, r",.. "I"~' -,.. ~ G110pbl'p i)~'?1'" I-~",~,n 11...«1. Snap ~nm I'. lll> i:...".~t.',.'".~,~ <.\"~,~, WIlfMtlln E '''"1'"T.(I,,,,,,,~,,,-,>,, WlIi1INII,~eOuls (11'"".f;G. r..,",,,,,*,..,or Yoyo.ctlI1l ZIIP~1 ",,"'H ~"IC"". "'''"''Pr ~"."u :':)'<101,. ~ 0-w,',,,, "!' r., ~111~~ "",",.-.~. '''''0''''' Vlne.com 1,w':rJ"":I '",:o..!'nt.,~." CII.~n_Cf"Inl!.~-~...,.,. ~"''''1~ 'r...,rt"'''lii' 'ON 113/2013

74 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 74 of 97 PageID #: 74 Amazon,com: Acme Piece Leesa Stressless Chair and Ottoman, Black: Hom." Page 1 of 4 SllOp by Departlnent Slllll'lh stressless (~o Hullo. Sly" In Your Aec:ount JUIIl Primo o C,rt Acme Plece Leesa Stressless Chair and Ottoman, Black by AQ1fi.t&.l.~'!I!M thkltal!! I (0) F.,.ICO: $ In stock. Processing takes an adclitl0l11114 tc 5 days for onlers 'rom this saller. Ships from end sold by Ham' Inri liylng, ~ rrom $ Laau collbc~an &\ni8$ 1818 chiilr and ottoman sel Mada of polyure1hane1pvc, Iron rramo palotlld Inside with woodllrl b8fl1l Stylish rvuml blue lor IXlth olloman End chair Available In!;jack c:oiqr Chair memuf!!! 31-1englh by 20-lnch wldtl by 38- heigh!; olloman maaaure. 18-length by 17-wldth by l6-heighl Q.IIMIUt'l: I, ~I"" {;II"'!I'.". 111 rt~~k. Prox;esslllg taku an addltloi\lli" to 5 days, Sold by Homa ~nd Uvlnlj Si1m..!!1 til tllm tm " l-(:uck ord~rr"". Nara Buylllljl Choh;;ell Amazon.com $ <1;1'11 ~~,~ I'";''''''' n:l~e.. tlh 311~"r 5~",~!)IIwv<n!J,~!r< BHFlJmlsh~ $2BS.99 $1... 1"~: ti"qi~"' Customers Who Viewed This Item Also Viewed Page 1 of 7 AcmtI PI_ L~l.Iflllyl\ strl!lsilaas Chllir IlIld Ottomlll\, Ivory $3101,99 MIIC MOIl<m Ct"liil'5 Modl/li! PlII(:O Rud~lln VllTtl MIIIChln\! Dlloman Mucha MiCronllllr with 'MIkltlt... $ (22) $ Aan~ PillCO Laul"lIlyn 61re$l11ISM Chair Qfld Ollomon, Espresso FlnI,h (1' Mac Chain~ Modt)l2. PIoco Rqcltnar... Uh Mold"ltn<;l OUomlll1 Saddle Laathlilr wuil P~call FrHrne $ (7) Mae Mot'l"ll"\ Chnlr.i MOOQI2 Plu<;:o R(lclhlrWith MIl1d1Ing OttO(lIan i:ilaq; Len\lulr wiit1 Mllrlo!., (S, $742.5<1 Product Details Product Dimensions:.31.~ x 26 x 17.5 Inches ; 114 pounds Shipping Welghtl114.2 pounds 0l.letL.ahllmlllg mtes gnd JllltIgCI) Shipping: CUrrently, Item can be shipped only within the U.S. Shipping Advisory: This Item must be shipped separately from other Items In your order. AddItional shipping charges not apply. ASIN: BOO6UlAZSQ Item model numberr Averaga Customer Review:.I&!tl~Q~l'L\.hl.:l..ll~l Old we miss any relevant features for this product? n~!.lul~.!!it.lt!!unli.k!l. Would you like to ~~Gk.2~. or le.u..ylili.!.qli_ljl.!ft~!~.lr.w? Product Delill:riptiQn Piece-Leesa -Stressless-Ottoman! dp/b006u3 AZ5Q/re.., 113/2013

75 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 75 of 97 PageID #: 75 Amazon.com: Acme Piece Leesa Stressless Chair and Ottoman, Black: Hom... Page 2 of 4 A very relaxing way to work and stay In the office with this leesa black polyurethilone leather chair and ottoman set. With stvllsh round base for both ottoman and chair. functionality and style rolled Into one. Durable construction. Made of polyurethane/pvc, Iron Frame painted Inside with wooden base, Chair measures 31-length by 28-lnci1 width by 3B-helght. Ottoman measures lb-length by 17-wldth by 16-helght. Made In china, This product weighs US-pound. Product Ads from Exterl'lal Websitee (~) St~ssleSS style Black nip Grain leather Recllnel' and Ottoman $ "" fro, Shlpplrlg ~1t!!.1!!Jl:!1 l!ll!l!!w! StreSSless Style Stone Top Grain Leather Recliner and attom.. n $ "" Fr Shipping """"'" ~!l...!ii...f.~.l'ill!l1m S4lQ332103TI103CTC Mal: Motloll Esper Cobblestone leather Cobblestone Leather SwIVel Recliner with Recliner and Ottomlln otto... (ll) (W $1,047,00 $ Fl'ee Shlppln, ;. ftee Shipping 6r!nIl!OWS!!lll!!.f!!21l... MacMotion Model #819 Le6ther Recliner lind ottoman (Z) $599,00 +!'ree Shipping DIIMoount Lyuthflr '""""'-"" Customers Viewing This P090 May 8e Interested In These Sponsored Links (Wh~t'$lhls7) ekot DIY fumiw.r..i dj!i IKEA onida! Sito ;gl Furniture for Your Comfort Call Today for Discount Prlclngl Create a New Uvlng Room To Suit Your StylI! At A Great Price. US/living Room AmerlCll's #1 Solid Wood Dlnln9 Room AvaIlable Itt Accent on the Home NY See II problem wltil these advertlsemel'lts7 1&l..II:l...Im. AvoUuble Warranties for This Item I $21.99 $14.99 Customer Reviews There are 00 customer rerillws yel St"'1(~. ~ow 1t\\I'.I~j'h\,.~ ",th otmi,-"stom()($. m. ;)CiISIOmllfofwlllw_ _.. _.. '::-,,"-,.

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78 AmalOn.com: Stressless Style Chestnut Top Grain Leather Recliner an... hnp:llwww.amalon.comistressless-chestnut-leather-recliner-ottoma... Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 78 of 97 PageID #: 78 Join Prime Your Amazon,com Today's Deals Gift Cards Sell Help Shop by Department Search I-bme & Kitchen stressless style chestnut Go Hello. Sign in Your Account Join Prime o c Home & Kitchen Best Sellers MarkdO'Mls Kitchen & Dining Appliances Bedding & Bath Furniture & Decor Patio & Garden Kids' I-bne Store Gift IdE Stressless Style Chestnut Top Grain Leather Recliner and Ottoman by stanl.ei< Be the Rrg to revjew this Item Have one to sell? Currently unavailable. We don't know when or if this item will be back in stock. Welcome Style into Your Home See the new Furniture and Decor storefront, with product selectio from Abbysoo! lying, South Shore,.B.E.SL and Enitial 1 abo Share yow own c"stomer Images Customers Viewing This Page May Be Interested in These Sponsored Links rwb"'stbl>') Upgrade with Stressless rl:l For a short time, receive a free leather upgrade with your purchase. Bassett Furniture Stressless Furniture ~ Home, Wood, Leather, & More! 30 Day Delivery--Find Your Store Find Fast Facts, References and More on Ask.com. Get Answers Now! See a problem with these advertisements? Let us know Product Details ASIN: BOOS3YMSP6 Average Customer Review: Be the first to review this item Did we miss any relevant features for this product? Tell ys what we missed. Would you like to give feedback on images or tell us about a lower price? Product Description The top grain "Mario Chestnut" Stressless Style Leather Swivel Recliner and Ottoman Set by Stanley Chair features a stylish contemporary base. Turning on a 360 degree swivel base, this luxurious chair has been meticulously designed for the ultimate comfort and support, whether sitting or reclining. The easy patented latch release mechanism allows the chair to recline back infinite positive locking positions. Ergonomically designed, the chair provides correct lumbar and head support in all positions. Featuring a style similar to Ekornes Stressless Recliners at the fraction of the price, Stanley Chair's trend setting design is extremely comfortable! Product Ads from External Websites (What's this?) Sponsored C, 10f3 3/5/20135:17 PM

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82 Amawn.com: Espresso PU Chair and Ottoman Set Stressless - Leo dp/... Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 82 of 97 PageID #: 82 3 star 2 star 1 star Write a customer review Hundreds of, Free Songs Play 011 the Web. Android,..,.rld Kindle FIre Advertisement Customer Questions & Answers Be the first to ask a question that you have. Ask Typical questions asked about products: Is the item disable? - Is this item easy to use? - What are the dimensions of this item? Look for Similar Items by Category Office Products> Office Furniture & Lighting Feedback.. If you need help or have a question for Customer Service, contact us... Would you like to give feedback on images or tell us about a lower price?., Is there any other feedback you would like to provide? Click here Your Recent History (What's this?) Recently Viewed Hems \tr Stressless Style Chestnut Top... Stanley Continue Shopping: Top Sellers Page 1 of 17 Wait for You J. Lynn (173) Kindle Edition $0.99 Never Too Far (Fallen Too Far) Abbl Glines (1,157) Kindle Edition $ f3 3/5/20135:20 PM

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87 tj Amazon.com: Leather Recline Office Chair Relax Sofa w/oltoman OJ: Home fl Kilchen. Mozilla Flrerox Be tel< j)ow """", 1\1<* ~ j ~... ;.",;'L OfflceChM.. G g~x..._._.. _r"j,,_::::,~,~~~~,~t~'~~'~~;;"='~:i~,~:~ _~~I::.'~;~~.I~~~~~.:::!~~~~:$~_!:-:=~~::;~.~6':_'~~ld=1 ;s~,.., ~ 'F'j~:~r=8 27w.~~,\' <:: '13- I': 11- Gr -I; 0. am~r [,-~; amazon Your Amazon.com Today's Deals Gift Cards Help ~'J611l"rnlle Snop by Herro. ScI<Ju ill Join Wish Dep.. rtment... Se..llch HDrn.:: 3.!-,rtch",, stressless Your H(lme & Kil'cheu Best SeUefs Markdovvns KHchen 8. Di'lng Appliances Bedcing 8. Bath Furnlure & Decor Patio 8 Garden Iflds' Home store Gift Ide6s """I ~1rj ~.. See ;.11 2 customer jmjlges Sh;'nI 'lour own customs! jmi9ri!' Customers Who Viewed fhis Item Also Viewed Leather Recline Office Chair Relax Sofa w/ottoman 03 by SestChair *.**/0': Gil (?Q elldomer revie... s) I f~lin I (5) Price' $ In Stock. Ships from and sold by Cayalier Wholesale, ~ from $ Seat Size: 20"CW) x 20"(0) Seat height 1 r Ottoman Size: 19"(L} x 16"(0) Back size: 23'(:«) x 29"{H), much 'Wider and taller Weight Umlt: 250LB Account. Prime '" We... - List More Buying Choices Rowland Direct Wholesale ' 't':044-:: ;:t;!ppu'\l ~ from $148.88!ijlii!;/ Ha\'e one to sell? l"5e-lion-aimlon j Share Gil" m ~. Page 1 of 12, start "',,-. r."ii "., ",.pc - ~ ( '11 L:.JII'~_' -'.;:~J~<:II'Y )t.~~='n(o~.,~yr... IiiIII ~ t</:vcj ).1 I 1: Co Alii :1 l :w j ~ Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 87 of 97 PageID #: 87

88 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 88 of 97 PageID #: 88 EXHIBIT H

89 f) Amazon,com: l ealher Recline Olficc Chair IlCldX SOld wfotlomd" 0]: Home U Kilchen MO/illa fircfox:!':=--:: ~-_i 'X I'Jo tdt \!ow -. ~ l'jhooi Jpok ~ 1 _ """,_.;...offlo~o;";r Lfl +- ~1' \,,., ;,t.anazon.com/! ~I, t 1',-. u: ". "['.,' '. m ' 'Ir";h.'I>,1':if'iE ul~'i,ijllf 'If,.. f'''~1 I J,'\o~_"!! '_"II'!- I "'''17"., ".. '.-,1_,-. ;,.t,.;-,. C';,m' ;to ~ Or. f '".maior i'_will I I; J 11+0 amazon Your Amazon,corn loday's Deals Git! Cards Help ~11(>i., t'ihue Shop by Hello. SI'J1l1H Join Wish Dep3mnent... Se.wch n_ll,... ~ f',r,d ".,,'" stressless Your Hom& & Klehetl &em Selers Markclowns IU:chcn 8. Drrog,l,ppMnccs Bcdcklg 8. Both F\.Wf'lIt. e.\ Decor PIlIbo & Gerdel1 KleIs' Home store OIfildeas Leather Recline Office Chair Relax Sofa w/ottoman 03,. i~.,' i_~ ~ s... II 2 cuitorne.,mages <;hil,e \lour o... n customer Imiogili Customers yy'ho Viewed fhis Item Also Viewed by~ nr-aji}':!v!(?q<;u5tpooerreyi.;ws) I f":'uuj(s) PW" $ In Stock. Ships from ~nd sold by Cavalier Wholeule. 2...nc.!! from $ Seat 812e: 2f1'CNI x 2f1'(O) Seat height t.,. Ottoman Size: 19"(l) x 16"(0) Back size: 23"(w,Ix 29"(H), much 'HIder and taller Weight UmH: 250LB Account... Prime... '"WC~rt... Ust... Hare Bu"... Chalc Rowland Direct Wholesale '199, ""1.. 7 ''''rl''''') ~from $ It:;WiijIiiI Have one to sell7 I s"iaii~zon.l ~SI)YIiI Page 1 of 12 oj r' " ". _~-" '::start C!llr,~.J' t','~:,~-:( :!;'rr~"r nu"'''- ~ ~'< 1.f1]-;"'.'''' r-r ll,-""n1 t!.1 I Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 89 of 97 PageID #: 89

90 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 90 of 97 PageID #: 90 Factory Direct Wholesale Leather Recline Office ChaIr Relax Sofa... ea ther~ rec I i ne~o ill c e-cjmir.. Stol'e [nfo 511 are Store Welcome to 0Rakuten Shopping HOME BAGS CONSUMER ELECTRONICS HeALTH & BeAUTY HOME & OUTDOOR OFFICE SUPPUES PET SUPPLIES SPORTS CATEGORY LEATHER RECLINE OFFICE CHAIR RELAX SOFA W/OTTOMAN 03 BABY BAGS CONSUMER ELE<:TI\ONICS (9)!WIlli/Write Review EARN lss SUPER POINTSI Li>:;t pric:,,: ~ You Save S()%,Plioo: $ FREE SHIPPING Tot,,1 Pl"ice: $ HEA LTH III BEAUTY QLWmTY HOME III OUTDOOR OFFiCE SUPPLIES Seller Rating: 4.52 ollt of 5 Seller RetUn! Polity PET5UPPUES SPORTS TOYS Condition: Brand Now In Stock: Usually 5hlp~ In 1-2 business days TODAY'S DEAL 2 Photo(s) 59! all ~~!~ Product Summary Keurlg" PltltInum Brewing System, B70 Coffee Maker (1 (up) Manufacturer: B~5tChi3II' Mfg PartY: OC-l103 Rilkl.lten.com SIIIH UPC~ 814B IIPC 14: Sea more in Offi<;e (;halr!7 Comfo~table, 50ft PU leather uphols\ery with ample padding, 011 /lnd water reslstence. Wide arm rests Premium hardwood base! for both chair and ottoman360 degree SWivel for the chalr.cllalr rl!(.!line up to 150 degreewelght limit: 250LElSeat Size: 20-(W)){ 20"(D)5eat height: 17"!lack slze~ 23"(W) J( 2~"(H), much wider and tallcrottoman SIze: 19"(L) x 16"(0) HOME APPLIANCES Product Attributes Assembly lqvq'~ Color Class: fumlture Material: Office ChIllr Type: AS5Cml)led Blilck Le<lther Executive Loll : L 7 PM

91 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 91 of 97 PageID #: 91 7aC lol'y, Dlrect Wholesale - About Llt.btml StlOP Owner Company Info feedback Shipping Returns Customer Service CATEGORY Bags Compute~s Consumer Ele(tronks Healtll & Beauty Home & Outdoor Office 5lJpplies PetSupplies At Factory Direcl Wholesale, we boljovo lilat you have lila nghllo enjoy quality products wfthcut pn~lnq' for tlla prsmium prices. For this reason, we speclalilb in setting Iligh quality produclsat a ffsolfon of the cost of roost (stail chains. We niter fasl and convenient liiimce whlc.h eno~ for morlt limo spent doing wtlalbvar you wanl. At Faolery Direpl WholesalE:!, we taka ovary moosure to B(lSU(& thst our cu!lloft1'lr~ lire sousfted. Best Prices: Ely avoiding fl'l!1ny of!hit big brllnds rnarl\eling and pllckaijlng costs, we deliver Ihe SO/TlC! quatlty producls I1t 11 fracuon of the cost. Reliable ShIpping: You gel your product when you need It. W~ ship \IIa Fei1ex or UPS which hos an llverolge trolnsl! lime of 2 \0 5 buslne$s day:::. but Ciln be dell'lyed due 10 wealher condluons or 58curUy Issues. Quality Products: 5po~ts.Allor clir Items come with II JO.Da.y rr.oney bl'lc:k [iul'lrl'lntea, 1100 llavli been chos~n frem \1<1110\11> reputable msmlfac\urers. Our products ate a10a tesled lor qllol1lty as&urill'loo purposes (LJlllsteCi, CE, Ell, elc). We lrustlhat YOIl will have a nl1ppy ellperlence when shopping wllh usl We!lpprec!ate YOllr buslnessl Our contact inlorlt1i\loo By slandard mall: Factory Direct """"0IesaI8, llc 2855 N Berkeley lake Rd Duluth. GA By phono: (between 9 a.m. and 6 ~.m, eastern lime lone) Refund, Returns and Cancellation Policies: Kellrig Platinum Brewing System, B70 Coffee Maker (1 Cup) r-'rir.~:~~ I! Is bo.lyer's responsibility to ship Ihe Item back In tho orlglnsl comiuon OIt buye~s cosl, under no circumslflllce will we pay the shipping back!lems dtllnll{led In-transit end/of factory derects will be repelrsd or replaced. If YOli WOllld like LIS to send you replacement set, ple.. se aend U,e orlglnst one bnck at YOllr CQst. UnuSOd/not-daslred can be retu(fled within 7 (lays from tlla dola of purc:hosl). Used I~eturns are not accepted L1ndar!lny circumsltlrlcos, Qllan Just one single lise. lhts is tile only woy WI! can guarantee ellary ilemwg ship alit i9 brand naw and (lollar u$od. HOM~ APPLIANCES 20[2 2/6/201311:44AM

92 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 92 of 97 PageID #: 92 FactoJ'~ Direct Viholesale - About lit. html Get Super POlntsl Hello. Sign Inl MY Account I:::!..!:IIl Store Info Share Store Search by Keyword or Iteml! This Stor'e Welcome to ORakuten shopping ~ lof2 2/G/ :44 AM

93 Leather Recline Office Chair Relax Som ht1p:llwww.mctorydirectwholesales.comlrecline-office-chair-p/oc-l103.htrn HEALTH AND BEAUTY COMPANY INFO About Us Blog Returns Shipping Site Help I FAQ :Yl~:'"~. Click here for more details Home I About Us I My Account I View Cart I Help OFFICE SERIES PET CENTER SPECIALTY ITEMS SPORTS AND FITNESS Home> Office Series> Office Chair> New PU Leather Recline Office Chair Desk Task Relax Sofa wlfree Ottoman 03 DeSCription 1~, large~"photo',1, Emaii.~.Frl~n.CI ' ~ Alternative Views: lr'lrtr: List Price: $ OUf Price: $ Savings: $89.00 '. This t>em qu.i~ie' Ibr FItI!E SHIPI'lNG' Product Code: OG "'~"I1lI~lE!!IDil!!'I'li;I'::'S~!~~ilP,lifliHii1mlfr'''!'' "1 '. ~p,~~~:t~jwili~ li!m8~~nl!';i:'~1 ~::'::!::L:~ Choose Your Color Colo.. : I Black i Features: Comfortable.. soft PU leather upholstery with ample padding, oil and water reslstence. Wide arm rests Premium hardwood base for both chair and ottoman HOME DECOR CATTF Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 93 of 97 PageID #: 93 10f :51 PM

94 Leather Recline Office Chair Relax Sofa h!tp:!! 360 degree swivel for the chair Chair recline up to 150 degree Weight limit 250LB Dimension: Seat Size: 20"(W) x 20"(0) Seat height 15" Back size: 23"(W) x 29"(H), much wider and taller Ottoman Size: 19"(L) x 16"(0) Features Comfortable, soft PU leather upholstery with ample padding, oil and water resistence. Wide arm rests Premium hardwood base for both chair and ottoman 360 degree swivel for the chair. Chair recline up to 150 degree Weight Limit 250LB Seat Size: 20"(W) x 20"(0) Seat height 17" Back size: 23"(W) x 29"(H), much wider and taller Ottoman Size: 19"(L) X 16"(0) Related Items Computer leather Ergonomic Office Chair Set. Price: $ Computer Leather Ergonomic Office Chair Sale Price: $ New PU Leather Baseball Chair and Ottoman Set Sale Price: $139.99,,~ :~~~~.. ~; ~"."" \,~~) Leather Executive Office Desk Chair Sale Price: $ Office Chiar Sale Price: $49.99 ~ Basketball Chair Sofa and Ottoman Set Sale Price: $ Salon waiting Chair Sale Price: $ '" OfficeChiar Sale Price: $49.99 Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 94 of 97 PageID #: 94 20D 2illl2013 3:51 PM

95 leather Recline Office Chair Relax Sofu Share your knowledge of this product. Be the first to write a review}) 1Il!"'!"'!'!?"~.?'~.. ~:_~..!'!~'!'!'!'!"'!'!'!~."_~'!'!l'cibji\wiiw1iuii!!ll~ ~... ~ ~.. ~._~. ~_~-!.. ~. ~... ~..!'_~.~..!"!_,_,,~ =... 2Z.±-!'!!!!!'7?! ::1;7'. FIIiiifiI'.. X ~... ~. iiii. flu!!~ttfi4!,!.'. *! SIGN UP FOR OUR NEWSLETTER: COMPANY SHOPPING SERVICES MY ACCOUNT CUSTOMER SERVICE enter address About Us FAO:s Track My Order Contact Us Privacy 8: Security Product Index My Account Site Help Legal Statement Category Index Shopping Cart Become an Affiliate Copyright 2013 Factory Oirect Wholesale, LLC All Rights Reserved. Ecommerce Web Site Design by Volusion. Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 95 of 97 PageID #: 95 I j 300 2/ll/2013 3:51 PM

96 ~ Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 96 of 97 PageID #: 96 EXHIBIT I

97 1';:) Rakulen.com. Lealhcr Itecline Office Chair l~elilx Sofa wlottoman OJ. Mozilla Fire-fo)( E.'e E.a ~...,. ~ ~, Jpds tjoip io...;,~~:~~~;,;.offkecr... ~I+I... + '":i- H'""N,raiwten.comip, j j.li"",,rhc-',c-un".,)f,:". r:t-'~'i fd~ -~'jr,", ','" 0tt';'i,,, (,3!'::2(;11.. ~O<;. htrnl Or QfW<UiE;-_.. _- :;;'~iil + riii:i,led ~ I]. ~. ORakuten.com Shopping '~Buy.com D-t-als Computet. CllQthiMIl, IS Offir:e 'h'",~ Jo"tlr_ GJrFl 'j(. e. 1m- f'. * Get Super Points Hello, SigIlli"! My Account...!:!ft!.Il IE ~ ~.tt WELCOME! Click to feirln WM ~~ 0 i ~I'I" ;,: s~, 'd I' t,,' iaic8tegories ~l"" YOUR'"\ 0 '" -4 _~ ~_. J iii CART. T": Wintl', VI*'0 SOClkti, wurr1~ o,t:~ G.mca Mv... u MJ!'~ 1- Homt:1 1I~.1th4 ToywlH.by SjUlrtll& HOUllchold ijeluty Hags. Great prices, better experience CUCK TO EXPA.."J!) 0 We're now ORakuten.com Shoppmg andsuperpolnts~1 OffICE SUPPLIES ~ OFFICE FURNITURE. OfFICE CHAIRS Leather Recline Office Chair Relax Sofa w/ottoman 03,... ir_ I Read/Write hview(s) ***~ list Price: ~ (Save 50%) Today $ '_M,.S",p;", EARN 185 RAKUTEN SUPER POINTS ~'.".,,..', tr-..;:) (olltliti(lu: In ~ock: Brandl'Jew U!'u<lII'1 Ships m 1 to 2 buslnes5 dd~, BaJa.-~~~.. :- * Add to Wisblist Save for iater Sh" 110_!on.w. ) ~+: J 'U'"'', CiA.d;; to cart Ships from/sold by Foctpry Direct Wholesalfl WItt'. thia Seller RatiOQ: ****~ Se!larR!!b!rn p,msv Case 2:13-cv ADS-WDW Document 1 Filed 03/07/13 Page 97 of 97 PageID #: 97