e. Upon information and belief, City, having knowledge of RFF’s trademarks, hasoffered for sale and/or otherwise used in interstate commerce, trash cans, streetsigns, license plate covers, website content, vehicles, business cards, park benches, and brochures, among other items, bearing the RFF trademarks andconfusingly similar alternatives thereof.f. City uses the THE RED FLANNEL TOWN mark and the correspondingcircular logo on service identifying items such as business cards and websites thatare identical to the service identifying items on which RFF uses its trademarks.g. To the extent any actual and/or implied license existed between RFF and City,such license has been terminated.h. Accordingly, City is infringing and unfairly benefiting for its use of RFF’strademarks, and in doing so is diluting the RFF’s marks.3. Claimant alleges the following items of damage and seeks recovery for them:a. Preliminarily and permanently enjoining and restraining City and its respectiveofficers, agents, servants, employees, and attorneys, and those persons in activeconcert or participation with City from using the THE RED FLANNEL TOWNmark and the corresponding THE RED FLANNEL TOWN circular logo, or anymark that is confusingly or deceptively similar to RFF’s trademarks, either aloneor in conjunction with other words or symbols, as part of any trademark, servicemark, logo, trade name, corporate name, assumed name, domain name, or inrelation to any services advertised or provided by City, or in any other manner. b. Directing City, pursuant to 15 U.S.C. § 1118, to destroy all literature, signs,labels, prints, packages, wrappers, containers, advertising materials, Internetcontent, stationary, business cards, park benches, vehicles and any other items intheir possession or control which contain the infringing designation THE REDFLANNEL TOWN, or any term confusingly or deceptively similar to RFF’strademarks, either alone or in combination with other words or symbols.c. Awarding RFF all damages permitted by 15 U.S.C. § 1117, including attorney'sfees and trebled damages.d. Awarding RFF all profits, gains, benefits, and advantages derived by City fromits unjust enrichment and other conduct as alleged herein.e. Awarding RFF exemplary and/or punitive damages by reason of City’s willful,intentional, and malicious acts.f. Awarding RFF such further relief as the Court deems just and proper.