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Gillette Company v. Javitch Canfield Group d/b/a JCG Collection et. al.

Gillette Company v. Javitch Canfield Group d/b/a JCG Collection et. al.

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Published by PriorSmart
Official Complaint for Patent Infringement in Civil Action No. 1:14-cv-00089-MRB: The Gillette Company v. Javitch Canfield Group d/b/a JCG Collection et. al. Filed in U.S. District Court for the Southern District of Ohio, the Hon. Michael R. Barrett presiding. See http://news.priorsmart.com/-l9Qt for more info.
Official Complaint for Patent Infringement in Civil Action No. 1:14-cv-00089-MRB: The Gillette Company v. Javitch Canfield Group d/b/a JCG Collection et. al. Filed in U.S. District Court for the Southern District of Ohio, the Hon. Michael R. Barrett presiding. See http://news.priorsmart.com/-l9Qt for more info.

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Published by: PriorSmart on Jan 31, 2014
Copyright:Public Domain

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05/23/2014

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IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO WESTERN DIVISION THE GILLETTE COMPANY, One Gillette Park, Boston, MA 20127 Plaintiff, vs. Javitch Canfield Group, d/b/a JCG Collection One Market Street, Suite 500 San Francisco, CA 94105 and Mark Javitch 1800 Washington St. #716 San Francisco, CA 94109 and Daniel Canfield 888 O’Farrell St. #E602 San Francisco, CA 94109 and PNL Ventures 13926 W. 89
th
 St. Lenexa, KS 66215 and Unknown John Doe(s), Unknown Jane Doe(s). Defendants. ) ) ) ) ) ) ) ) ) ))))) ) ) )))) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Civil Action No.: 1:14-cv-89 Unassigned DEMAND FOR JURY TRIAL
 
2
COMPLAINT FOR DESIGN PATENT INFRINGEMENT
COMES NOW Plaintiff, The Gillette Company, (hereinafter “Gillette”), by and through its attorneys, and for its complaint against Defendants Javitch Canfield Group, d/b/a JCG Collection, Mark Javitch as an individual, Daniel Canfield as an individual, and other unknown John Doe and Jane Doe defendants associated with Javitch Canfield Group (hereinafter, collectively, “JCG Defendants”), and PNL Ventures, and unknown John Doe and Jane Doe Defendants associated with PNL Ventures (hereinafter, collectively, “PNL Defendants”), alleges that:
NATURE OF THE CASE
1.
 
This action arises from the manufacture, distribution, sale, and/or offer for sale of razor  blades, razor cartridges, shaving blade units, dispensers for razor cartridges, and razor containers by the JCG Defendants and PNL Defendants, that violate the patented design rights of Gillette. The razor blade products at issue in this case intentionally imitate and directly copy the valuable, unique and distinctive ornamental distinctive and non-functional design of and containers for Gillette’s Mach® 3 razor blade cartridges, thereby infringing Gillette’s design patent rights in violation of the Patent Act, 35 U.S.C.§271
et seq.
 
THE PARTIES
2.
 
The Gillette Company is a corporation licensed in the state of Delaware, with its principal  place of business at One Gillette Park, Boston, Massachusetts, 20127 and is a wholly-owned subsidiary of The Procter & Gamble Company (hereinafter P&G), a corporation licensed in the state of Ohio. Gillette’s Corporate Disclosure Statement is filed
 
3 concurrently with this Complaint, as required by Rule 7.1 of the Federal Rules of Civil Procedure. 3.
 
Upon information and belief, Defendants Mark Javitch and Daniel Canfield own and operate Javitch Canfield Group, d/b/a JCG Collection, as an unincorporated entity, in conjunction with each other and/or in conjunction with other unknown Defendants John Doe(s) and/or Jane Doe(s), with its principal place of business located at One Market Street, Suite 500, San Francisco, CA 94105. 4.
 
Upon information and belief, Defendant Mark Javitch is a resident of California, with a last known address of 1800 Washington St. #716, San Francisco, CA 94109. 5.
 
Upon information and belief, Defendant Daniel Canfield is a resident of California, with a last known address at 888 O’Farrell St., #E602, San Francisco, CA 94109. 6.
 
Upon information and belief, one or more Defendants John Doe(s) and/or Jane Doe(s) (whose names and addresses are unknown) are individuals who at all times relevant hereto were owners, employees, agents, and/or representatives of Javitch Canfield Group. 7.
 
Upon information and belief, PNL Ventures is an unincorporated entity with its principal  place of business located at 13926 W. 89
th
 St., Lenexa, KS66215. 8.
 
The true names and capacities, whether individual, corporate, associate or otherwise, of Defendants sued herein as John Does and Jane Does are presently unknown to Gillette, who therefore sues said Defendants by such fictitious names. Gillette will seek leave to amend this Complaint to allege the true names of such John Does and Jane Does when the same have been ascertained. Upon information and belief, Gillette alleges that each of the fictitiously named Defendants participated in some or all of the acts alleged in this Complaint.

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