under Indiana Code § 35-43-5-2(b) as well as counterfeiting under Indiana Code § 35-43-5-2(a),pursuant to Indiana Code § 34-24-3-l.
Jurisdiction and Venue
Jurisdiction over the parties and subject matter
this action is proper in thisCourt pursuant to
U.S.C. § 1121 (actions arising under the Lanham Act), 28 U.S.C. § 1331(actions arising under the laws
the United States), 28 U.S.c.
citizenship between the parties), and § 1338(a) (actions arising under an Act
copyrights and trademarks). This Court has supplemental jurisdiction over the claims in thisComplaint that arise under state statutory and common law pursuant to
This Court has personal jurisdiction over the Defendants because they
businessand/or reside in the State
Venue is properly founded in this judicial district pursuant to 28 U.S.C.
1391(b) and (c) and 1400 (b) because Defendants reside in this District, may be found in thisDistrict, and/or a substantial part
the events giving rise to the claims in this action occurredwithin this District.
Plaintiff Coach, Inc. is a corporation duly organized and existing under the laws
Maryland, with its principal place
business in New York, New York.
Plaintiff Coach Services, Inc. is a corporation duly organized and existing underthe laws
Maryland with its principal place
business in Jacksonville, Florida.
Upon information and belief, Defendant Downtown Gift Shop is a domestic entityoperating a business under the assumed name Downtown Gift Shop at 713 West McKinley,Mishawaka, Indiana, and also has its principal place
business in Indiana.
case 3:13-cv-00591-JVB-CAN document 1 filed 06/13/13 page 2 of 22