2.Plaintiff Cummins Inc. is a corporation organized and existing under the laws of the State of Indiana with a principal place of business at 500 Jackson Street, Columbus, Indiana47201.3.
On information and belief, Defendant T’Shirt Factory is a business with several
operating locations in or around Indianapolis, Indiana, including kiosks at Greenwood Park Mall(1251U.S. Highway 31, Greenwood, IN 46142) and at Castleton Mall (6020 E. 82nd St,
Indianapolis, IN 46250). Defendant T’Shirt Factory’s business includes the sale of t
-shirts,sweatshirts, and other apparel with logos affixed or printed thereon.4.On informationand belief, DefendantShamir Harutyunyan, an individual, is aresident of the State of Florida with an address of 136 Seagrass Way, Panama City Beach,Florida 32407.Defendant Shamir Harutyunyan is an owner, agent, and/or officer of Defendant
T’Shirt Factory and has recently reserved the business entity name “T
Shirt Factory” with the
Indiana Secretary of State. On information and belief,Harutyunyanwas personally aware of,and authorized, approved, ratified, participated in, and instigated the wrongfulconduct alleged inthis Complaint.5.On information and belief, Defendant Freedom Custom Z is a business with atleast one operating location in Bloomington, Indiana
a kiosk at the College Mall (2894 E. 3rdSt, Bloomington, IN 47401). Defendant Freedom Cus
tom Z’s business includes the sale of t
-shirts, sweatshirts, and other apparel with logos affixed or printed thereon.6.
Cummins is ignorant of the true names of defendant Does 1 through 10 (“DoeDefendants”), inclusive, and therefore sues those defendants by
such fictitious names. Oninformation and belief, Doe Defendants are responsible for the acts alleged in this Complaint.
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