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Brian Lichtenberg v. Alex & Chloe - Complaint

Brian Lichtenberg v. Alex & Chloe - Complaint

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Published by slburstein
Brian Lichtenberg v. Alex & Chloe - Complaint
Brian Lichtenberg v. Alex & Chloe - Complaint

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Published by: slburstein on Sep 23, 2013
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10/24/2014

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Case 2:13-cv-06837-DDP-PJW Document 1 Filed 09/17/13 Page 1 of 43 Page ID #:56
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DAVID GRAZIANI, ESQ., (SBN#276009)The Law Offices
of
David Graziani, P
C.
10880 Wilshire Blvd., Suite
1101
Los Angeles, CA 90024Telephone: (310) 935-4088Facsimile: (310) 935-4076RONALD D. TYM, ESQ. (SBN#195339)The TymFirm7120 Carlson Circle, #263Canoga Park, CA 91303Telephone: (818) 836-1428Facsimile: (818) 337-2026
FILED
r;;:~~R~:~J
CENTRA/.
[}!STRICT
OF
CALIFORNiA
V
DEWY
Attorneys for Plaintiffs, Brian Lichtenberg, LLC andBrian LichtenbergUNITED STATES
DISTRICT COURT
CENTRAL DISTRICT
OF
ALIFORNIA
·
BR~AN
~Ic;H!EN~E~.G,
LLC, a Case No.
ll
v
3
-068
3
~b('Jf
Cahforma hm1ted hab1hty company; and
(··
n
"\
BRIAN LICHTENBERG,
an
individual,
COMPLAINT FOR:
p
AJ
~
)
1.UNREGISTERED TRADEMARK
INFRINGEMENT,
TRADE DRESS
INFRINGEMENT,
AND FALSEDESIGNATION
OF
ORIGIN
UNDER
SECTION
43(a)
OF THE
LANHAMACT,
15
U.S.C. § 1125(a),
AND
TRADEMARK
DILUTION UNDER
SECTION
43(c)
OF THE
LANHAMACT,
15
U.S.C. §1125(c);
Plaintiffs,vs.ALEX
&
CHLOE, INC., a Californiacorporation; CHRISTOPHER WALTERLICHTENBERG, an individual;MARKED SHOWROOM, LLC, aCalifornia limited liability company;JACQUELINE YI, an individual; TUTRAN,
an
individual; KYLE MOCKETT,
an
individual; KA YTEE ENRIGHT, anindividual,Defendants.2. VIOLATION
OF
CALIFORNIA
UNIFORM
TRADE SECRETS ACT,
CAL. CIV. CODE §3426
ET
SEQ.;
3. VIOLATION
OF
CALIFORNIAUNFAIR
COMPETITION
ACT,
CAL.BUS.
&
PROF.
C
17200,ET.
SEQ.;
4. INTENTIONAL
INTERFERENCE
WITH
PROSPECTIVEECONOMIC
RELATIONS;5. INTENTIONAL INTERFERENCE
WITH
CONTRACTUAL RELATIONS6. DEFAMATION,
LIBEL
ANDSLANDER;
and
7.
COMMON
COUNT
1
COMPLAINT
 
Case 2:13-cv-06837-DDP-PJW Document 1 Filed 09/17/13 Page 2 of 43 Page ID #:57
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Plaintiffs BRIAN LICHTENBERG, LLC and BRIAN LICHTENBERG (hereinafter"Plaintiffs"), by their attorneys,
as
and for their complaint against Defendants ALEX & CHLOE,INC., a California corporation; CHRISTOPHER WALTER LICHTENBERG; MARKEDSHOWROOM, LLC, a California limited liability company; JACQUELINE YI,
an
individual; TUTRAN,
an
individual; KYLE MOCKETT,
an
individual; KAYTEE ENRIGHT, an individual,allege
as
follows:
I.
PARTIES
1.
Plaintiff BRIAN LICHTENBERG, LLC is, and at all times mentioned herein was, aCalifornia limited liability company with its principal place
of
business located
in
the City
of
LosAngeles, Los Angeles County, California. Brian Lichtenberg, LLC is referred to herein as "BRIANLICHTENBERG, LLC."2.Plaintiff BRIAN LICHTENBERG
is an
individual residing
in
the city
of
LosAngeles, Los Angeles County, California. Brian Lichtenberg is referred to herein as "BRIANLICHTENBERG."3.Defendant ALEX & CHLOE, INC., is, and at all times mentioned herein was, aCalifornia corporation having its principal place
of
business in the County
of
Los Angeles,California. Alex & Chloe, Inc.
is
referred to herein
as
"A&C."4.Defendant CHRISTOPHER W. LICHTENBERG
is
an individual residing in the city
20
of
Long Beach, Los Angeles County, California. Christopher W. Lichtenberg
is
referred to herein
21
as "CWL." On information and belief, CWL
is
a shareholder or the sole shareholder, and/or
22
president, director, officer and/or principal
of
A&C.
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5.
Defendant MARKED SHOWROOM, LLC
is
a California limited liability company,and on information and belief its principal place
of
business is located in the City
of
Los Angeles,Los Angeles County, California. Marked Showroom, LLC is referred to herein
as
"MARKED."6.On information and belief, Defendant JACQUELINE YI is
an
individual living,residing and/or working in the City
of
Los Angeles, Los Angeles County, California.JACQUELINE YI
is
referred to herein
as
"YI". On information and belief, YI
is
a shareholder or
2
COMPLAINT
 
Case 2:13-cv-06837-DDP-PJW Document 1 Filed 09/17/13 Page 3 of 43 Page ID #:58
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the sole shareholder, and/or president, director, officer and/or principal,
or
employee
of
MARKED.7.On information and belief, Defendant TU TRAN is an individual living, residingand/or working in the City
of
Los Angeles, Los Angeles County, California. TU TRAN is referredto herein
as
"TRAN
."
On information and belief TRAN is a shareholder or the sole shareholder,and/or president, director, officer and/or principal, or employee
of
MARKED.8. On information and belief, Defendant KYLE MOCKETT is
an
individual living,residing and/or working
in
the City
of
Los Angeles, Los Angeles County, California. KYLEMOCKETT is referred to herein
as
"MOCKETT." On information and belief MOCKETT is
an
agent or employee
of
A&C and/or CWL.
9.
On information and belief, Defendant KA YTEE ENRIGHT is
an
individual living,residing and/or working
in
the City
of
Los Angeles, Los Angeles County, California. KA YTEEENRIGHT
is
referred to herein
as
"ENRIGHT." On information and belief ENRIGHT is
an
agent
or
employee
of
A&C and/or CWL.10.A&C., CWL, MARKED, YI, TRAN, MOCKETT AND ENRIGHT are sometimesreferred to herein, collectively,
as
the "Defendants".
11.
A&C, CWL, ENRIGHT and MOCKETT are sometimes referred to herein,
18
collectively,
as
the "A&C Defendants."
19
12.MARKED,
YI
and TRAN are sometimes referred to herein, collectively,
as
the
2
o
"MARKED Defendants."
21
II.JURISDICTION AND VENUE
22
13.This Court has original subject matter jurisdiction over the federal law claims
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(TRADEMARK INFRINGEMENT, TRADE DRESS INFRINGEMENT, and FALSE
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DESCRIPTION/DESIGNATION AND TRADEMARK DILUTION) pursuant to 28 U.S.C. §§1331and 1338(a) and
15
U.S.C. §§1121, 1125(a) and 1125(c). This Court has related claim jurisdictionover the state law claims pursuant to 28 U.S.C. § 1338(b) and 28 U.S.C. § 1367.
14.
This Court has personal jurisdiction over the entity Defendants because suchDefendants maintain their principal place
of
business
in
the State
of
California. This Court has
3COMPLAINT

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