complaint wiggle butt inn v plan b enterprises

8/3/2019 Complaint Wiggle Butt Inn v Plan B Enterprises

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UNITED STATES DISTRICT COI-IRTMIDDLE DISTRICT OF FLORIDA(Fort Myers Division)Case NoTHE WIGGLEBUTT INN, INC

plaintiff,VPLAN B ENTERPRISES, LLC dIbIAWIGGLEBUTT DOGHOUSE,

defendant.COMPLAINT

The Wigglebutt Inn, Inc., a dog boarding and dog daycare services facility, brings thisaction against Plan B Enterprises,LLC, dlblaWigglebutt Doghouse, for trademark infringementand dilution under the United States Trademark Act, l5 U.S.C. $$ 1051 , et seq. (the LanhamAct), the Florida Trademark Act, Florida Statutes, $$ 495.001 , et seq., and federal and Floridacommon law.

The Wigglebutt Inn recently learned that V/igglebutt Doghouse was operating a businessproviding essentially identical services of dog boarding and dog daycare and using theconfusingly similar business name'Wigglebutt Doghouse. Despite The Wigglebutt Inn's effortsto protect its valuable trademark, including its cease and desist letter to the defendant,Wigglebutt Doghouse continues to misuse the mark to defraud the public. The'Wigglebutt Innhas no choice but to seek relief from this Court to put an end to the ineparable harm thatWigglebutt Doghouse is causing.

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Parties and Persons1. The Wigglebutt Inn, Inc., is organized and existing under Florida law with its

principal place of business at 5400 Jaeger Road, Naples, Florida 34109. The Wigglebutt Inn isthe sole owner of U.S. Trademark Reg. No. 3,795,703.

2. On information and belief, Plan B Enterprises,LLC, dlblaWigglebutt Doghouse("Wigglebutt Doghouse"), is organized and existing under Indiana law with its principal place ofbusiness at 8455 Moller Road Suite 500, Indianapolis, Indiana 46268.

Jurisdiction and Venue3. This Court has federal question jurisdiction and diversity jurisdiction under 28U.S.C. $$ 1331, 1338, and 1367(a). This Court has personal jurisdiction over WigglebuttDoghouse given that its website containing infringements-www.Wigelebutt4gghpu isaccessible in Florida, the intentional torls are directed at Florida, and the harm is felt specificallyin Florida.

4. Venue is this District is founded on 28 U.S.C. $ 1391(b) (2). The WigglebuttInn's place of business is also within this judicial district.

FACTUAL BACKGROUNDThe Wigglebutt Inn Trademark

5. The Wigglebutt Inn is a boarding and daycare facility for dogs in Naples, Florida.The Wigglebutt Inn owns all right, title, and interest in The Wigglebutt Inn@ mark which wasregistered with the United States Patent and Trademark Office on June I,2010 and bearsregistration number 3,795,703. See C. Grieve Decl. Ex. A.r The 'Wigglebutt Inn also registered

I Sxhibit references to "C. Grieve Decl. Ex. " refer to the Declaration of Catherine C. Grieve dated December 2,20 I l, filed contemporaneously with and in support of this Complaint.

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The Wigglebutt Inn trademark in the State of Florida (document number T11000001130). See CGrieve Decl. Ex. B.

6. The V/igglebutt Inn@ mark was first used in commerce in September 2009 andhas been in continuous use in commerce since September 2009.

7. The Wigglebutt Inn has been involved in extensive adverlising and promotion ofThe Wigglebutt Inn@ mark since September 2009. That advertising and promotion hasestablished recognition and goodwill towards The V/igglebutt Inn@ mark among members of thepurchasing public,

8. As a result of The V/igglebutt Inn's widespread and continuous use andpromotion, The Wigglebutt Inn@ mark has become distinctive and widely known.

9. The Wigglebutt Inn@ mark serves to distinguish The Wigglebutt Inn's qualitydog daycare and dog boarding services from those of others. Thus, The V/igglebutt Inn@ markrepresents and embodies the enviable reputation and valuable goodwill of The Wigglebutt Innamong members of the purchasing public.

10. There is substantial public demand for the goods and services offered by TheWigglebutt Inn in connection with its valuable The V/igglebutt Inn@ mark. As a result, thegoodwill generated by The Wigglebutt Inn@ mark, and the right to manufacture, sell, anddistribute services and products bearing that mark, are valuable commercial property rights.

The Defendant's Infrinsins Conduct11. On information and belief, in or about September 2010, Wigglebutt Doghouse

began to use the phrase "V/igglebutt Doghouse." Vy'igglebutt Doghouse uses the phrase"Wigglebutt Doghouse" as the business name for its dog boarding and dog daycare facility andas its domain name- www.wi g glebuttdo ghguse. com.

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12. In or about June 2011, incidents of actual confusion began to occur between TheWigglebutt Inn's lawful use of its valuable The V/igglebutt Inn@ mark and WigglebuttDoghouse's unlawful use of a confusingly similar phrase in connection with similar services.

13. On or about June24,20lI, The Wigglebutt Inn advised Wigglebutt Doghouse ofthe registered The Wigglebutt Inn@ mark and instructed the Wigglebutt Doghouse to cease anddesist from infringing upon The V/igglebutt Inn's mark. See C. Grieve Decl. Ex. C.

14. Despite The V/igglebutt Inn's demands that Wigglebutt Doghouse cease anddesist in the use of any marks confusingly similar to The'Wigglebutt Inn's registered TheWigglebutt Inn@ mark, Wigglebutt Doghouse continues to do so.

1 5. Upon information and beliefl, the activities of V/igglebutt Doghouse that arecomplained of here constitute willful and intentional infringement of The Wigglebutt Inn'sfederally registered trademark, are in total disregard of The Wigglebutt Inn's rights, and, werecommenced and have continued in spite of 'Wigglebutt Doghouse's actual knowledge that the use

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of any mark confusingly similar to The Wigglebutt Inn@ mark, was and is in directcontravention of The Wigglebutt Inn's rights.

16. Wigglebutt Doghouse's use of a mark confusingly similar to The WigglebuttInn@ mark has been without The V/igglebutt Inn's consent, will cause and has caused confusionto the purchasing public.

17. As a result of Wigglebutt Doghouse's actions, The Wigglebutt Inn has noadequate remedy at law, and is suffering irreparable harm to its business, reputation, andgoodwill as a result of the acts of Wigglebutt Doghouse.

18. Unless enjoined,'Wigglebutt Doghouse's conduct is likely to continue to dilutethe distinctive quality of The'Wigglebutt Inn@ mark and injure The Wigglebutt Inn's itsbusiness, reputation, and goodwill.

19. The Wigglebutt Inn has engaged Rivero Mestre LLP ("RM") as its counsel toprosecute this action, and it is obligated to pay RM's reasonable legal fees and costs in doing so.

COUNT I - FEDERAL TRADEMARK INFRINGEMENTVIOLATION OF THE LANHAM ACT (ls U.S.C. 51114)20. The Wigglebutt Irur realleges paragraphs 1 through l9 as though stated here.21. Wigglebutt Doghouse's unauthorized use of the term "Wigglebutt Doghouse,"

colorably imitates and constitutes trademark infringement of The Wigglebutt Inn@ mark.22. Wigglebutt Doghouse's conduct is also likely to cause confusion and mistake in

the minds of members of the purchasing public as to the source of the services and goods offeredin connection with The Wigglebutt Inn@ matk, in violation of 15 U.S.C. $11la(a) and (b).

23. On information and belief, 'Wigglebutt Doghouse's acts of trademarkinfringement were committed with the intent to cause confusion and mistake and to deceive.

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24. By reason of Wigglebutt Doghouse's infringing acts as alleged here, TheWigglebutt Inn has suffered, and will continu to suffer, irreparable damage to its business,reputation, and goodwill.25. The Wigglebutt Inn will continue to be irreparably harmed by its inability tocontrol Wigglebutt Doghouse's actions and by the resulting confusion and deception of membersof the purchasing public from those actions.

COUNT IIVIOLATION OF THE LANHAM ACT (ls U.S.C. $ 112s)26. The Wigglebutt Inn realleges paragraphs 1 through 19 as though stated here.27. The use of imitations and counterfeits of The Wigglebutt Inn's trademarks by

'Wigglebutt Doghouse as described above, constitutes a false designation of origin and a falsedescription or representation ofservices in that such use wrongly and falsely designates servicesdeveloped, promoted and distributed by'Wigglebutt Doghouse as originating from or connectedwith The'Wigglebutt Inn, and constitutes false descriptions or representations in interstatecommerce and also constitutes unfair competition.

28. For these reasons, Wigglebutt Doghouse has violated and is continuing to violate15 U.S.C. $ 1125, and The Wigglebutt Inn is entitled to permanent injunctive relief, attorneys'fees, and costs as provided in 15 U.S.C. $ 1 1 17(a).

29. The V/igglebutt Inn has no adequate remedy law, and is suffering irreparableharm as a result of Wigglebutt Doghouse's acts.

COUNT IIIVIOLATION OF SETION 495.131, FLORIDA STATUTES

30. The Wigglebutt Inn realleges paragraphs 1 through 19 as though stated here.

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31. This Count arises under Section 495,131, Florida Statutes ("Infringement"). The'Wigglebutt Inn seeks a permanent injunction.

32. Wigglebutt Doghouse's unauthorized use, promotion, advertising, reproduction,and sale of services bearing imitations of The Wigglebutt Inn's trademarks, have confused,misled and deceived, and also threaten, tends and are likely to confuse, mislead, and deceive thetrade and consuming public into mistakenly believing that the services promoted, sold, anddistributed by Wigglebutt Doghouse are The Wigglebutt Inn-branded services tbat areauthorized, sponsored, approved, or vouched for by The Wigglebutt Inn.

33. Wigglebutt Doghouse's trademark infringement has caused irreparable harm andimmediate injury to The Wigglebutt Inn, including injury to its reputation and dilution of thedistinctive quality of The Wigglebutt Inn's trademarks.

34. V/igglebutt Doghouse has infringed and continues to infringe The WigglebuttInn's trademark with knowledge of The Wigglebutt Inn's statutory and common law rights inThe Wigglebutt Inn's trademark and with knowledge that the services promoted, distributed, andsold by V/igglebutt Doghouse is likely to and is intended to cause confusion, deception, andmistake among the consuming public and trade as to the true origin of such items.

35. Wigglebutt Doghouse has engaged in the conduct described above without TheWigglebutt Inn's consent.

36. For these reasons, Wigglebutt Doghouse has violated and continues to violateSection 495.131, Florida Statutes, and The V/igglebutt Inn is entitled to preliminary andpermanent injunctive relief, attorney's fees, and costs.

37. The Wigglebutt Inn has no adequate remedy at law.

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COUNT IVVIOLATION OF SECTION 495.151, FLORTDA STATUTES38. The V/igglebutt Inn realleges paragraphs I through 19 as though stated here.39. This Count arises under Section 495,151, Florida Statutes ("Injury to Business

Reputation; Dilution"). The Wigglebutt Inn seeks a permanent injunction.40. 'Wigglebutt Doghouse's use of The Wigglebutt Inn's trademark, to which The

Wigglebutt Inn has exclusive rights, will damage The Wigglebutt Inn's business reputation anddilute the distinctive quality of its identification with its high quality products, all to TheWigglebutt Inn's irreparable harm.

41. For these reasons, Wigglebutt Doghouse has violated and continues to violateSection 495.151, Florida Statutes, and The Wigglebutt Inn is entitled to permanent injunctiverelief, attorney's fees, and costs.

42. The V/igglebutt Inn has no adequate remedy at law.PRAYER FOR RELIEF

WHEREFORE, The Wigglebutt Inn demands that this Court enter an order:l. Permanently enjoining and restraining 'Wigglebutt Doghouse, its principals,

agents, servants, employees, attorneys, representatives, successors and assigns, and all persons,entities, firms, and corporations acting in privity, concert, or participation with it, from:

(a) directly or indirectly infringing The Wigglebutt Inn@ mark in any manner;(b) using in any way The Wigglebutt Inn@ mark, or any reproduction,counterfeit, copy, or colorable imitation of The Wigglebutt Inn@ mark, including,but not limited to, the use of the term "Vy'igglebutt," "Wiggle Butt," and "Wiggle-Butt" as to any item including, but not limited to its business name, corporatename, company name, Internet domain name or website;

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(c) engaging in any conduct that tends to falsely represent, or is likely toconfuse, mislead, or deceive members of the purchasing public to believe, thatWigglebutt Doghouse is in some way connected, affrliated, sponsored, approved,or licensed by The V/igglebutt Inn;(d) otherwise competing unfairly with The Wigglebutt Inn in any manner, orinterfering with The V/igglebutt Inn's rights in, or use of, the The WigglebuttInn@ mark; and(e) diluting and infringing The Wigglebutt Inn @ mark or damaging TheV/igglebutt Inn's business, reputation, or goodwill.

2. Requiring Wigglebutt Doghouse to deliver to The Wigglebutt Inn for destruction,all products, packages, labels, catalogs, tags, brochures, cards, advertisements, signs, displays,literature stationery, promotional material, and all other items in its possession or under itscontrol, bearing the name The'Wigglebutt Doghouse;

3. Requiring Wigglebutt Doghouse to account for and to pay to The V/igglebutt Innall of V/igglebutt Doghouse's profits, gains and advantages resulting from The WigglebuttDoghouse's wrongful conduct;

4. Awarding The Wigglebutt Inn actual damages sustained by V/igglebuttDoghouse's trademark infringement, and in view of the flagrant and deliberate charucler of suchinfringement, assessment of treble damages and The V/igglebutt Inn's attorney's fees and costs;and

5. Awarding The Wigglebutt Inn such other and further relief as the Court maydeem just and proper under the circumstances, together with the costs and disbursements whichCarnival has incurred in connection with this action.

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DEMAND FOR JURY TRIALThe Wigglebutt Inn demands trial by jury as to all issues so triable as a matter of right,

Dated: Decmber 5,20II. Respectfully submitted,RIVERO MESTRE LLPAttorneys for The Wigglebutt Inn2525 Ponce de Leon BoulevardSuite 1000Miami, Florida 33134Telephone: 305-445-2500Facsimile: 305 -445 -2505Email : cgrieve@riveromestre. com

By: /s/ Catherine GrieveCatherine GrieveFla. Bar No.129363

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C 2 11 00686 UA DNF D t 2 Fil d 12/06/11 P 1 f 13 P ID 13


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UNITED STATES DISTRICT COTJRTMIDDLE DISTRICT OF FI,ORIDA(Fort Meyers Division)Case No.

THE V/IGGLEBUTT INN, INCplaintiff,

VPLAN B ENTERPRISES, LLC dIbIAV/IGGLEBUTT DOGHOUSE,

defendant.

DECLARATION OF CATHERINE C. GRIEVEI, Catherine C. Grieve, make the following declaration in support of The V/igglebutt Inn,

Inc.'s Complaint and requested relief of a Permanent Injunction:1. I am acitizen of the United States and reside in Miami-Dade County, Florida. I

am over 18 years of age, and I give this declaration on my own personal knowledge.2, I am an attorney at Rivero Mestre LLP.3. The 'Wigglebutt Inn is a boarding and daycare facility for dogs in Naples, Florida.4. At present, The V/igglebutt Inn owns all right, title, and interest in The

'Wigglebutt Inn@ mark which was registered with the United States Patent and Trademark Officeon June 7,2010 and bears registration number 3,795,703. A printout of the proof of registration,available from the United State's Patent and Trademark Office's Trademark Electronic SearchSystem, is attached as Exhibit A.


Case 2:11 cv 00686 UA DNF Document 2 Filed 12/06/11 Page 2 of 13 PageID 14


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5. The Wigglebutt Inn also registered The Wigglebutt Inn trademark in the State ofFlorida (document number T11000001 130). A copy of the Florida Department of State Divisionof Corporations' website printout for this registration is attached as Exhibit B.

6. On or about J:une24,20Il, The Wigglebutt Inn advised Wigglebutt Doghouse ofthe registered The Wigglebutt Inn@ mark and instructed the Wigglebutt Doghouse to cease anddesist from infringing upon The Wigglebutt Inn's mark. A copy of the certified letter sent asnotice to'Wigglebutt Doghouse is attached as Exhibit C.

Under 28 United States Code, Section 1746(2),I declare under penalty of perjury underthe laws of the United States of America that the foregoing is true and correct.

Dated: December 2,2011

CATHERINE GRIEVE

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Exhibit A




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Word MarkGoods and ServicesStandard CharactersClaimedMark Drawing CodeSerial NumberFiling DateGurrent Filing BasisOriginal Filing BasisPublished forOppositionRegistration NumberRegistration DateOwnerAttorney of RecordType of MarkRegisterLive/Dead lndicator

THE WIGGLEBUTT INNlC 043. US 100 101. G & S: Pet boarding and daycare services for dogsFIRST USE: 20090909. FIRST USE lN COMMERCE: 20091009

(4) STANDARD CHARACTER MARK77846318October 12,20091A1AMarch 16, 20103795703June 1,2010(REGISTRANT)The Wigglebutt lnn, lnc. CORPORATION FLORIDA Suite 35400 Jaeger Road Naples FLORIDA 34109Christopher A. MitchellSERVICE MARKPRINCIPALLIVE

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Exhibit B

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www,sunbiz.org - Department of State h@ : //www,surbiz.orglscripts/cordet. exe?action:DETFIL&inqdoc-.,.Case 2:11-cv-00686-UA-DNF Document 2 Filed 12/06/11 Page 6 of 13 PageID 18


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Contact Us E-Filing Services Document Searches Forms HelpomePrevious on ListNo Events

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Return To List Entity Name Searchi'--'.-lr_sqbm!Detail by Entity NameTrademarkTHE WIGGLEBUTT INNFrlrn lnformationDocument Number T11000001130Date Filed 1111012011Expiration Date 1111012016First Used in Florida 0710112009First Used Anywhere 0710112009Status ACTIVEMark Used ln Connection WithDOG DAY CARE AND DOG BOARDING, DOG BATHSOwnersName & AddressPAUL, GEORGE S561 NEAPOLITAN I.ANEMPLES FL 34103Type/ClasssM-004300 00000000000 00000000000 00000000000 0000000000000000000000 00000000000 00000000000 00000000000 0000000000000000000000 00000000000 00000000000 00000000000 0000000000000000000000 00000000000 00000000000 00000000000 00000000000Gross ReferenceNo Cross ReferenceDocumentNo images are available for this filingNote: This is not official record. See documents if question or conflict.Previous on ListNo Events

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Exhibit C



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),tXDRESSOETZEL222 SOUTH MAIN STREETAKRON, OH 44308330.376.2700 MArN330.376.4577 F^[email protected] ralaw comA LEGAL PROFESSIONAL ASSOCIATION

Iune24,20llVIA CERTIFIED MAILRETURN RECEIPT REOUESTEDSUBJECT TO FEDER,AL RULE OF EVIDENCE 408Wigglebutt Doghouse8455 Moller RoadSuite 500Indianapolis, IN 46268Re: THE WIGGLEBUTT INN, U.S. Trademark Reg. No. 3,795,103Dear Sir or Madam:

I represent The Wigglebutt Inn, Inc. ("Wigglebutt Inn"), owner of the valuable THEV/IGGLEBUTT INN trademark and U.S. Trademark Registration No. 3,195,703 for that samemark, as referenced above. My client's THE V/IGGLEBUTT INN trademark is used andregistered for use in the U.S. in connection with "pet boarding and daycare services for dogs".The details of U.S. Trademark Reg. No. 3,195,703 for THE WIGGLEBUTT INN are attachedhereto as Attachment A, for your reference. In addition to trademark rights throughout the U.S.conferred by ownership of U.S. Trademark Reg. No. 3,J95]03, Wigglebutt Inn has also gainedwell-established common law rights in THE WIGGLEBUTT INN as a result of its continuousand extensive use of that trademark in commerce in the United States since September 2009.

Wigglebutt Inn has recently learned that you are operating a business which providesboarding and daycare services for dogs under a WIGGLEBUTT DOGHOUSE trademark andbusiness name, and that you are using a wigglebuttdoghouse.com domain name for the samepurposes. See Wigglebutt Doghouse Web Page Print-Out attached hereto as Attachment B.

Wigglebutt Inn believes that your use of WIGGLEBUTT DOGHOUSE is confusinglysimilar to its THE WIGGLEBUTT INN trademark and business name. Specifically, your use ofWIGGLEBUTT DOGHOUSE as a trademark, business name, and domain name is likely to leadconsumers and others to believe that you are associated or affiliated with or sponsored orendorsed by Wigglebutt Inn, when in fact no such association, affiliation, sponsorship orendorsement exists.Although your mark and name include the term "DOGHOUSE" rather than "INN", thisdifference would likely be insufficient to differentiate your trademark and name from those of

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June24,20llPage 3

The demands made in this letter shall not waive or prejudice any rights or remedies thatV/igglebutt Inn may have in respect to the subject matter hereof, all of which rights and remediesare expressly reserved. Wigglebutt Inn hopes to resolve this matter amicably, and thanks you inadvance for your timely response to this letter.

Very truly yours,ROETZEL & ANDRESS, LPA

Suzanne K. Ketler

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June24,2017Page 4TTACHMENT

Trademarks > Trademark Electronic Search System (TESS)IESS was last updated on Wed Jun 22 04:35:46 EDT 2011

iease logout when you are done to reiease system resources allocaied for youRecord 1 out of 1Logout

Word MarkGoods and ServicesStandard CharactersClaimedMark Drawing CodeSerial NumberFiling DateCurrent Filing BasisOriginal Filing BasisPublished forOppositionRegistration NumberRegistration Date

- - LEtsI I Use the :'EacK" utton ot thelnternet Browser to return o IESS)THE lAIGGLEBUTT IhTN

THE WIGGLEBUTT INNlC 043. US 100 101 . G & S: Pet boarding and daycare services for dogs. FIRST USE20090909. FIRST USE lN COMMERCE:20091009

(4) STANDARD CHARACTER MARK77846318October 12,20091A1AMarch 16,20103795703June 1,2010

1753537 v 01 \ 123541.0004l'753140 v 0l \ 123541.0004

United States Patent and Trademark OfficeHome Site Index Search FAQ Glossary Guides Contacts eBusiness eBizalerts News Help

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June 24,2011Page 5OwnerAttorney of RecordType of MarkRegisterLive/Dead lndicator

(REGISTRANT)The Wigglebutt lnn, lnc. CORPORATION FLORIDA Suite 3 5400Jaeger Road Naples FLORIDA 34109Christopher A. MitchellSERVICE MARKPRINCIPALLIVE

I.HOME I SITE INDEXI SEARCH I EBUSTNESS I HELP IPRIVACY POLICYfitFst{orE I'iff/Usn sTflUcTt,Ro FnEtrl-oI?$Url(!lv:.it.Jlcr SEARCH OG ToP IIELF

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June24,2017Page 6

ATTACHMENT B

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complaint wiggle butt inn v plan b enterprises

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