sillage v. kenrose perfumes - complaint
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THOMAS J. SPEISS, III (SBN 200949) [email protected]
JUSTIN KLAEB (SBN 254035)[email protected]
STRADLING YOCCA CARLSON & RAUTH, P.C.100 Wilshire Blvd., Suite 400Santa Monica, California 90401Telephone: (424) 214-7042Facsimile: (424) 214-7010
Attorneys for Plaintiff Sillage, LLC
UNITED STATES DISTRICT COURT
FOR THE CENTRAL DISTRICT OF CALIFOR
SILLAGE, LLC, a Ca orn aLimited Liability Company,
Plaintiff,
vs.
KENROSE PERFUMES, INC.D/B/A EUROPERFUMES, a NewYork Corporation;
FRAGRANCENET.COM, INC., aDelaware Corporation; and, LAPEER BEAUTY, L.P., a CaliforniaLimited Partnership.
Defendants.
CASE NO.: 8:14-cv-20
COMPLAINT FOR:
1. PATENT INFRINGUNDER 35 U.S.C.
2. TRADEMARK INFUNDER 15 U.S.C.
3.
TRADE DRESS INUNDER 15 U.S.C.
4.
UNFAIR COMPETCALIFORNIA BUPROFESSIONS CO
JURY TRIAL DEMAND
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Plaintiff Sillage, LLC (Sillage) by and through its attorne
alleges as follows:
PARTIES
1. Sillage is engaged in the business of creating and pro
artisanal fragrances to its consumers. In addition to the scents the
is known for presenting its perfumes in embellished bottles and fl
now, and was at all times herein mentioned, a California limited l
duly organized and existing under the laws of the State of Califor
principal place of business at 660 Newport Center Drive, Suite 66
Newport Beach, California 92660.
2. On information and belief, Defendant Kenrose Perfu
Europerfumes (Europerfumes) is a corporation duly organized
under the laws of the State of New York, with its principal place o
60 Honeck Street, Englewood, New Jersey 07631.
3. On information and belief, Defendant FragranceNet.
corporation duly organized and existing under the laws of the Sta
with its principal place of business at 104 Parkway South Drive, H
New York 11788 (FragranceNet).
4.
On information and belief, Defendant La Peer Beaut
limited partnership duly organized and existing under the laws of
California, with its principal place of business at 8950 W. Olymp
Suite 113, Beverly Hills, California 90211 (La Peer Beauty; an
with Europerfumes and FragranceNet, Defendants).
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6. This Court has personal jurisdiction over Europerfum
Europerfumes is doing and has done substantial business in this ju
and has committed acts of patent and trademark infringement, and
complained of herein, in this judicial district.
7.
This Court has personal jurisdiction over FragranceN
FragranceNet is doing and has done substantial business in this ju
has committed acts of patent and trademark infringement, and oth
complained of herein, in this judicial district.
8. This Court has personal jurisdiction over La Peer Be
La Peer Beauty is doing and has done substantial business in this
and further has committed acts of patent and trademark infringem
acts complained of herein, in this judicial district.
9.
Venue is proper in this judicial district pursuant to 28
(b)-(c) and 1400(b). The acts and transactions complained of her
conceived, carried out, made effective, and had an effect within th
California and within this Judicial District.
FACTUAL ALLEGATIONS
Patent Ownership
10.
On November 12, 2013, U.S. Patent No. D693,224 (
entitled Display Bottle was duly and legally issued to Nicole M
inventor. A true and correct copy of the 224 patent is attached to
as Ex. A and incorporated herein by reference. The 224 patent i
force.
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12. At least as early as February 1, 2014, Nicole Mather
and 503 patents to Sillage. Sillage is the exclusive licensee of th
title, and interest in and to the 224 and 503 patents, including al
the 224 and 503 patents and recover for infringement. True and
the assignment documents are attached hereto as Exs. Cand D.
13.
As more fully laid out below, Defendants have been
infringing the 224 patent and 503 patent in this judicial district a
selling and distributing products which infringe Sillages patents.
Trademark Ownership
14. On May 10, 2012, Sillage filed an intent-to-use trade
for its CHERRY GARDEN mark, which was assigned U.S. Trade
Application No. 85/622,278. CHERRY GARDEN is the name o
perfumes from the House of Sillage line.
15.
On April 2, 2013, the CHERRY GARDEN mark pub
opposition in the USPTOs Official Gazette. No oppositions wer
16.
On November 5, 2013, Sillages CHERRY GARDE
issued as U.S. Trademark Registration No. 4,429,539. Sillage be
CHERRY GARDEN mark in United States commerce in March 2
constructive date of first use for the CHERRY GARDEN mark in
commerce is May 10, 2012. A copy of the registration for the CH
GARDEN mark is attached as Ex. E and incorporated herein by r
17.
Sillage has expended significant time, energy and ex
CHERRY GARDEN, including but not limited to tradeshow atten
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global marketplace as identifying Sillage as the source of origin f
marketed and provided in connection therewith.
Trade Dress Ownership
19. In or about November 2011, Sillage introduced TIAR
fragrance from its House of Sillage line of perfumes. TIARA is p
transparent hand-polished, flat-bottom, ridged-edge cupcake-shap
which is about two (2) inches in diameter and includes a bottle
with jewelry, crystals, and other dcor. Sillages other bottle desi
same cupcake-shaped bottle as well as other cut stones and dcor
20. Each subsequent fragrance in the House of Sillage lin
in a transparent cupcake-shaped bottle and included its own uniqu
cap.
21.
Sillages bottles and caps attracted the attention of cr
consumers alike and quickly became a hallmark of the Sillage bra
used and promoted its trade dress sufficiently to form an associati
consumers to denote Sillage as the source of the products.
Sillage Markets and Distributes Unique Perfume Pr
22. On April 28, 2010, Sillage was formed. On or about
November 3, 2011, Sillage began to market its TIARA perfume i
commerce. TIARA was marketed and sold in a cupcake-inspired
Since this time, Sillage has expanded and continues to expand its
line in the United States to include the marketing and sale of eigh
perfumes. The majority of these perfumes are marketed in a Sign
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reference, Sillages cupcake-inspired bottle and the limited editio
CHERRY GARDEN bottle and cap are shown below.
24.
With sales internationally, including in the United St
United Arab Emirates, and the European Union, Sillage has estab
significant reputation by the sale of its TIARA, CHERRY GARD
perfume brands.
25. Sillage uses only high quality ingredients in its perfu
Similarly, Sillage uses only high quality materials in its decorativ
26. Sillage has established a reputation and earned signif
its business of producing luxury crafted fragrances developed in cthe finest perfumers in the business, including the legendary Fran
Sillage also works with premium jeweler Swarowski to design fin
ornate flacons and bottles.
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31. Sillage has expended significant time, energy, and ex
its unique House of Sillage line, and in particular the bottle design
cover, including but not limited to tradeshow attendance, intervie
online marketing campaigns, couture events, advertising, and mar
32.
Based on Sillages extensive use and promotion of it
bottle and decorative cover, the dress has become distinctive and
United States and global marketplace as identifying Sillage as the
for the products marketed and provided in connection therewith.
Defendants Market and Sell Perfume in Cupcake-Shaped
Decorative Caps
33. At least as early as March 25, 2013 which is abou
months after Sillage first introduced its cupcake-inspired perfume
United States commerce Histoires de Parfums LLC d/b/a Alic
(A&P), which is a Defendant in the related case, Sillage, LLC v
de Parfums, LLC, et al., Case No. 14-cv-00172-CAS-RNB (C.D.
Alice & Peter Action), and Europerfumes, working together, in
perfumes which were, and continue to be, presented in a cheap kn
of Sillages cupcake-inspired perfume bottles. This line of A&P
marketed and sold in a cupcake-shaped bottle and decorative cap
Parfum). A sample of the Infringing Parfum, e.g., A&Ps Cher
perfume, is depicted below.
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34. The Infringing Parfums cupcake-shaped bottles mim
and inventions claimed in Sillages patents and trade dress.
35. The Infringing Parfums caps are generally dome-sh
an A&P charm, rhinestone jewelry, and/or other dcor.
36.
The Infringing Parfum and the perfumes marketed an
are the only two brands in the world that market and sell perfume
inspired bottle.
37. Upon information and belief, Europerfumes is the N
distributor for the A&P perfume, and has marketed and/or sold ab
of the A&P perfume throughout North America.
38. Upon information and belief, Europerfumes received
infringing activities at least as early as May 1, 2014. Upon inform
Europerfumes acquired such knowledge from Moshe Yhudai, the
Scent-Sation LA, which is a Defendant in the related Alice & Pet
attested to by both Mr. Yhudai, and Vicken Arslanian, the proprie
Europerfumes, as part of their deposition testimony taken in the
Alice & Peter Action.
39. Upon information and belief, Europerfumes markete
A&P perfume to FragranceNet on the following dates and in the f
amounts,
MONTH QUANTITY
April-April 2014
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40. Upon information and belief, Europerfumes markete
750 units of the A&P perfume after it received notice of its infrin
including selling at least sixty-three (63) units to FragranceNet
willful patent infringer.
41.
Upon information and belief, FragranceNet purchase
ninety-six (96) units of A&Ps Cheery Cherry perfume from Eu
42.
Upon information and belief, FragranceNet markets
variations of the Infringing Parfum: Blood Orange, Cherry Cherr
Showy Toffee, and Wicked Berry. Upon information and belief,
continue to be marketed and sold through www.FragranceNet.com
below,
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SeeEx. Ffor a copy of the webpage print-outs showing Fragranc
and sale of the Alice & Peter perfume.
43. Upon information and belief, Europerfumes markete
A&P perfume to La Peer Beauty on the following dates, in the fo
MONTH QUANTITY
November 2013
December 2013
July 2014
TOTAL
44. Upon information and belief, Europerfumes markete
six (6) units of the A&P perfume to La Peer Beauty after Europer
of its infringing activities.
45. Upon information and belief, La Peer Beauty purcha
fifteen (15) units of A&Ps Cheery Cherry perfume from Europ
46.
Upon information and belief, La Peer Beauty market
A&P perfume it purchased from Europerfumes in United States c
beginning such marketing and sale at least as early as November
FIRST CLAIM FOR RELIEF
(Infringement of U.S. Patent No. D693,224)
47. Sillage hereby re-alleges and incorporates by referen
allegations from paragraphs 1 through 46 hereof as if fully stated
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and/or importing into the U.S. the Infringing Parfum products wh
claimed design recited in the 224 patent.
50. On information and belief, Defendants will continue
224 patent unless enjoined by this Court.
51.
Sillage has been, and will continue to be, damaged a
harmed by the actions of Defendants, which will continue unless
enjoined by this Court.
52. On information and belief, the infringement of the 2
Defendants has been willful.
SECOND CLAIM FOR RELIEF
(Infringement of U.S. Patent No. D658,503)
53.
Sillage hereby re-alleges and incorporates by referen
allegations from paragraphs 1 through 52 hereof as if fully stated
54.
Sillage is the sole owner of the entire right, title, and
503 patent.
55.
Defendants have infringed the 503 patent under Sec
Title 35 of the U.S. Code by making, selling, and/or offering for s
and/or importing into the U.S. the Infringing Parfum products wh
claimed design recited in the 503 patent.
56.
On information and belief, Defendants will continue
503 patent unless enjoined by this Court.
57.
Sillage has been, and will continue to be, damaged a
harmed by the actions of Defendants, which will continue unless
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THIRD CLAIM FOR RELIEF
(Infringement of Federally Registered Trademark (Lanham
59. Sillage hereby re-alleges and incorporates by referen
allegations from paragraphs 1 through 58 hereof as if fully stated
60.
By virtue of Defendants conduct, Defendants have u
a spurious term in connection with the advertising, marketing and
perfume products in interstate commerce, which mark is identifie
Cherry, and which imitates Sillages CHERRY GARDEN mark
61. Sillage and A&P make perfume products and, accord
Sillage and A&P market their products to the same or similar clas
62. As a result of Defendants conduct, there is a strong
confusion, mistake, or deception, and many persons familiar with
CHERRY GARDEN mark, its reputations, dress, and favorable g
likely to purchase Defendants Infringing Parfum goods in the mi
such goods are offered or authorized by Sillage.
63.
Defendants actions have been and are willful, unfair
deceptive, in that they tend to mislead, deceive, and confuse, and
have the result of misleading, deceiving, and confusing the public
Defendants and/or their goods are affiliated with, sponsored, or co
Sillage.
64.
The foregoing actions of Defendants constitute trade
infringement by inducing the erroneous belief that Defendants an
are in some manner affiliated with, originate from, or are sponsor
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deprived of gains and profits which otherwise would have inured
such unlawful actions.
66. Sillage has no adequate remedy at law for the injurie
Count. The injuries are, in part, intangible in nature and not capa
measured or valued in terms of money damages. Further, the inju
continuing nature and will continue to be suffered so long as Defe
their wrongful conduct.
67. Notwithstanding the difficulty of fully ascertaining t
damage to Sillage caused by Defendants wrongful conduct, Defe
has resulted in irreparable, direct, and proximate damages to Silla
entitled to injunctive relief under 15 U.S.C. 1116(a).
FOURTH CLAIM FOR RELIEF
(Trade Dress Infringement (Lanham Act 43))
68.
Sillage hereby re-alleges and incorporates by referen
allegations from paragraphs 1 through 67 hereof as if fully stated
69.
This claim arises under Section 43(a) of the Lanham
amended, 15 U.S.C. 1125(a). Defendants unauthorized use an
continued use in interstate commerce of Sillages trade dress cons
word, term, name, symbol, or device, or any combination thereof
designation of origin, false or misleading description of fact, or fa
representation of fact, that has caused and is likely to cause confu
deception (a) as to the characteristics, qualities, or origin of the In
(b) as to an affiliation, connection, or association between Sillage
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71. Upon information and belief, Defendants have intent
falsely designated the origin of their goods by adopting and using
is substantially the same as the Sillages trade dress for its goods
from Sillages reputation by confusing the public as to the source
sponsorship or approval of Defendants goods, with the intention
misleading the public at large, and of wrongfully trading on the g
reputation of Sillage.
72. The activities of Defendants complained of herein ha
unless enjoined, will continue to cause substantial and irreparable
its business reputation and its goodwill, for which Sillage is witho
remedy at law. Such activities have also caused Sillage monetary
including, but not limited to, the loss of profits in an amount not y
73.
Further, the injury is of a continuing nature and will
suffered so long as Defendants continue their wrongful conduct.
the difficulty of fully ascertaining the value of the damage to Silla
Defendants wrongful conduct, Defendants conduct has resulted
direct and proximate damages to Sillage and Sillage is entitled to
under 15 U.S.C. 1116(a).
FIFTH CLAIM FOR RELIEF
(Unfair Competition under Cal. Bus. & Prof. Code 172
74.
Sillage hereby re-alleges and incorporates by referen
allegations from paragraphs 1 through 73 hereof as if fully stated
75. Sillage is informed and believes, and on that basis al
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76. The foregoing acts of Defendants have caused and w
cause injury to Sillage by depriving it of sales of its genuine perfu
business reputation, and by passing off Defendants goods as Sill
violation of the common law of the State of California.
77.
Defendants acts have caused and will continue to ca
harm and damage to Sillage, and have caused and will continue to
monetary damage in an amount not yet determined, for which Sil
its actual damages, Defendants profits, as well as attorneys fees
78. Defendants infringement of Sillages intellectual pr
herein constitutes unlawful, unfair or fraudulent business act[s] o
unfair, deceptive, untrue or misleading advertising within the me
California Business and Professions Code 17200.
79.
As a consequence of Defendants actions, Sillage is e
injunctive relief and an order that Defendants disgorge all profits
manufacture, use, display, or sale of infringing goods.
PRAYER FOR RELIEF
WHEREFORE, Plaintiff Sillage prays for the following rel
A. Judgment in favor of Sillage that Defendants have in
and 503 patents and that Defendants infringement of the 224 an
was willful;
B.
A permanent injunction enjoining Defendants, their
agents, servants, affiliates, employees, divisions, branches, subsid
and all others in active concert or privity therewith from direct, in
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D. That the Court enter judgment that Defendants unau
the mark Cherry Cherry, in association with the Infringing Parf
violation of the Lanham Act, 15 U.S.C. 1115(a);
E. That Defendants be required to immediately change
Cherry Cherry mark;
F.
That Defendants conduct serves to unfairly compete
under the common law of the State of California;
G. That the Court award judgment in favor of Sillage in
determined at trial, but in no event less than Defendants profits o
Products;
H. An award of Sillages costs and attorneys fees as all
and,
I.
For such other and further relief as the Court may de
proper.
DATED: December 23, 2014 STRADLING YOCCA CA& RAUTH, P.C.
By:Thomas J. Speiss, IIIAttorneys for Plaintiff
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JURY DEMAND
Sillage hereby demands a trial by jury pursuant to Rule 38
Rules of Civil Procedure on each cause of action asserted in its C
triable by jury.
DATED: Decem er 23, 2014
STRADLING YOCCA CA& RAUTH, P.C.
By:Thomas J. Speiss, IIIAttorneys for Plaintiff
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