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Published by Tom Curtis

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Published by: Tom Curtis on Aug 16, 2012
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10/09/2013

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UNITED STATES DISTRICT COURTEASTERN DISTRICT OF MICHIGANREBELLION DEVELOPMENTS LIMITED,CHRISTOPHER KINGSLEY and JASONKINGSLEY,
Plaintiffs,
v.STARDOCK ENTERTAINMENT, INC. andIRONCLAD GAMES CORPORATION.
Defendants.
Case No. _____________ JURY TRIAL DEMANDED
COMPLAINT
 
Plaintiffs Rebellion Developments Limited, Christopher Kingsley and Jason Kingsley
(collectively, “Rebellion” or “Plaintiffs”) allege against defendants
Stardock Entertainment, Inc.and
Ironclad Games Corporation (collectively, “Ironclad” or “Defendants”) as follows:
 
JURISDICTION AND VENUE
1.
 
This is an action for the infringement of a registered trademark and unfair competition arising under the Lanham Act, 15 USC §1051
et seq.
and various statutes of theState of Michigan. This Court has jurisdiction of this action under 15 USC §1121, 28 USC§1331, 28 USC §1338, and 28 USC §1367.2.
 
Venue is proper in this district under 28 USC §1391, this being a judicial districtwhere Defendant Stardock Entertainment, Inc. is doing business and in which a substantial partof the events giving rise to the causes of action occurred.
2:12-cv-12805-VAR-MJH Doc # 1 Filed 06/26/12 Pg 1 of 14 Pg ID 1
 
2
THE PARTIES
 3.
 
Plaintiff Rebellion Developments Limited is a company organized and existingunder the laws of England and Wales, having its principal place of business at Riverside House,Osney Mede, Oxford, OX2 0ES, United Kingdom.4.
 
Plaintiffs Christopher Kingsley and Jason Kingsley are individuals and citizens of the United Kingdom, with a business address of Riverside House, Osney Mede, Oxford, OX20ES, United Kingdom.5.
 
Upon information and belief, Defendant Stardock Entertainment, Inc. is acorporation organized and existing under the laws of the State of Michigan, having their  principal place of business at 15090 Beck Rd., Plymouth, Michigan 48170.6.
 
Upon information and belief, Defendant Ironclad Games Corporation is acorporation organized and existing under the laws of Canada, having its principal place of  business at 5172 Kingsway, Suite 340, Burnaby, British Colombia, Canada V5H 2E8.
PLAINTIFFS AND THE
REBELLION
MARK 
 7.
 
In 1991, Christopher Kingsley and Jason Kingsley founded RebellionDevelopments Limited, which has become and is now a well-known British computer gamescompany.8.
 
Since 1991, Rebellion has developed more than forty computer games, includingthe awarding wining title
Sniper Elite,
and well-known games such as
 Aliens vs. Predator, Star Wars Battlefront: Renegade Squadron
,
 Judge Dredd: Dredd vs. Death
, and
The Simpsons Game
.Many of said games feature futuristic science fiction scenarios.
2:12-cv-12805-VAR-MJH Doc # 1 Filed 06/26/12 Pg 2 of 14 Pg ID 2
 
39.
 
Rebellion’s
 branded games are sold and distributed through-out the world,including in the United States and the State of Michigan, to be played on PCs and most, if notevery, major gaming console, including but not limited to SONY PLAYSTATION, XBOX, andthe Wii.10.
 
 Nearly every game sold throughout the world, including within the United Statesand the State of Michigan, developed by Rebellion, bears the house mark REBELLION. Arepresentative sample is displayed below:11.
 
In addition to their common law rights, Christopher Kingsley and Jason Kingsleyown the U.S. trade/service mark registration of REBELLION, Reg. No. 2845116
(“the ‘116registration”), for among other things, “entertainment and amusement machines and apparatus,
namely, video games and electronic games; discs, optical discs, silicon chips, microchips,electronic circuits all encoded with computer programs for video games and all for use with theaforesaid games apparatus; musical sound recordings, program memory cartridges for electronic
2:12-cv-12805-VAR-MJH Doc # 1 Filed 06/26/12 Pg 3 of 14 Pg ID 3

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