manufactured by hand in Hanover, Pennsylvania through a highly technical and precise systemof 77 steps. As a result of this rigorous process, the Navy Chair® is three times as strong as steeland is built to last for 150 years. The Navy Chair® is sold at retail for approximately $450.3.
Restoration Hardware’s “Naval Chair” line of chairs and stools are blatant, cheapknockoffs of the Emeco Navy® product line. By giving its chairs and stools the confusinglysimilar “Naval Chair” name and describing them as an “update of an armed forces classic,”Restoration Hardware misleadingly suggests that, like the Emeco Navy Chair®, its products areAmerican-made. On information and belief, they are manufactured in China for a fraction of thecost, and are not the result of the extensive and precise manufacturing process that ensures thehigh quality of the Navy Chair® collection. The “Naval Chair” presently sells at retail for $129.4.
Restoration Hardware has stated, euphemistically, that “[a]t our core we are notdesigners, rather we are curators and composers of inspired design and experiences.”
In fact,Restoration Hardware is not a “curator” or “composer” of others’ “inspired designs”; it is acounterfeiter of them. In advance of its upcoming IPO, Restoration Hardware’s publicly-announced revenue-surging strategy is built upon “[e]xternally discover[ing] and curat[ing]”
designs, which decreases production lead times and costs.
Having been sued for copyingmore than half a dozen times in the past decade, Restoration Hardware’s current activities are partof an established practice of infringing others’ designs and trademarks for financial gain.5.
The irreparable harm caused by Restoration Hardware’s willful and manifestinfringement to Emeco’s reputation and significant goodwill is massive, incomparable to thatcaused by a typical, small-time counterfeiter. Restoration Hardware is hijacking and exploitingEmeco’s brand image and iconic designs. As an established company, consumers are highlylikely to believe that the products Restoration Hardware sells are genuine, legitimate articles, notcheap counterfeits made overseas. Emeco brings this action to halt that harm and protect itsexclusive rights. Emeco further is entitled to its actual damages, to Restoration Hardware’s illicitprofits, to statutory damages, and/or exemplary damages as a result of this unlawful conduct.