federally registered trademark CRAVE BAKE SHOP for pastry and dessert shops does notinfringe, dilute, or otherwise violate the rights
defendant Crave, LLC ("CLLC'').Alternatively, Bake Shop asks for a declaration that CLLC is estopped from asserting trademarkinfringement and
claims against Bake Shop.
2. Bake Shop is an Oregon limited liability company with its principal place
business at 460 Fifth Street, Lake Oswego;Oregon 97034.
CLLC is a California limited liability company with its principal place
business at 368 Richland Avenue, San Francisco, California 94110.
JURISDICTION AND VENUE
This Court has jurisdiction
this civil action under the DeclaratoryJudgments Act,
2201 and 2201, and theLanham Act,
U.S.C. § 1125(a)
Venue is proper in this Court under 28 U.S.C. § 1391 because CLLC sellsgoods in this district, and has contacted and sent the correspondence that created the presentdispute
Bake Shop in this district, with a substantial part
the events or omissions giving riseto the claim to be adjudicated in this action occurring in this district.
CLAIM FOR RELIEF(Declaratory Judgment
Since 2009, Bake Shop has been baking and selling gluten-free artisan-crafted cakes, cupcakes, cookies, cinnamon rolls, and other pastries using the trademark CRAVEBAKE SHOP. Bake Shop has enjoyed substantial success
acclaim, appearing on the FoodNetwork's national television show
in 2010, 2011, and 2012, winning thePage 2
Complaint for Declaratory Judgment
ATTORNEYS AT LAWTELEPHONE: (503)
U.S. BANCORP TOWER
S.W. FIFTH AVENUEPORTLAND, OREGON 97204
Case 3:13-cv-00392-BR Document 1 Filed 03/07/13 Page 2 of 8 Page ID#: 2