registered and common-law trademarks associated with its retail grocery chain and its products.
Upon information and belief, Defendant Michael Norman Hallatt is anindividual residing in Vancouver, British Columbia, Canada, with a mailing address of 2348 West 4th Avenue, Vancouver, British Columbia, Canada V6K 1P2.
Upon information and belief, Michael Norman Hallatt does business or hasdone business as Pirate Joe’s and/or Transilvania Trading.
Upon information and belief, Pirate Joe’s is a company based in Vancouver,British Columbia, Canada, with a principal place of business at 2348 West 4th Avenue,Vancouver, British Columbia, Canada V6K 1P2.
Upon information and belief, Transilvania Trading is a company based inVancouver, British Columbia, Canada, with a principal place of business at 3474 WestBroadway, Vancouver, British Columbia, Canada V6R 2B3.
Trader Joe’s is ignorant of the true names and capacities of the defendantssued herein under the fictitious names DOES 1 through 10 inclusive. Trader Joe’s will seek leave of court to amend this complaint to allege such names and capacities when they areascertained. Trader Joe’s is informed and believes, and based thereon alleges, that each of the fictitiously named DOE defendants is responsible in some manner for the wrongfulconduct alleged herein. Trader Joe’s further alleges that each defendant acted in concertwith, as agent or representative for, or at the request or on the behalf of one or more of thedefendants identified in paragraphs 2-5 above.
JURISDICTION AND VENUE
This action asserts claims arising under the Lanham Act, 15 U.S.C. §§1114(1), 1125(a) and 1125(c). This Court has federal question jurisdiction over theseclaims pursuant to 15 U.S.C. § 1121, and 28 U.S.C. §§ 1331, 1338(a) and 1338(b). ThisCourt also has subject matter jurisdiction over Trader Joe’s state law claims pursuant to the
COMPLAINT – Page 2
818 STEWART STREET, SUITE 1400SEATTLE WASHINGTON 98101 T 206.516.3800 F 206.516.3888
Case 2:13-cv-00768 Document 1 Filed 05/01/13 Page 2 of 24