Plaintiffs’ Original Complaint Page 3 of the United States—specifically, 15 U.S.C. §§ 1116, 1117, 1119, and 1125, which relate to trademarks—and pursuant to the principles of supplemental jurisdiction under 28 U.S.C. § 1367. 8.
Venue is proper in this District pursuant to 28 U.S.C. § 1391(b)(1), because both of the Defendants are residents of this District. 9.
CPII and SPCP (“Plaintiffs”) are informed and believe, and on that basis allege, that at all times relevant hereto, RCII and RB Restaurants (“Defendants”) and other unidentified parties were the owners, shareholders, agents, servants, employees, partners or co-venturers of each other, and in doing the acts alleged herein, each was acting within the course and scope of such ownership, control, agency, service, employment, partnership or venture. 10.
Plaintiffs are informed and believe, and on that basis allege, that the Defendants identified as DOES 1-50 are in some manner legally responsible for the damages and/or other things alleged herein. Plaintiffs are currently unaware of the true names and/or capacities of DOES 1-50 and, therefore, sue them in a fictitious manner. Plaintiffs will amend their Complaint upon ascertaining their identities.
CPII is the owner of all right, title, and interest, including all copyright, trademark, service mark, and other intellectual property rights in and to the Picture (the “Property IP”). SPCP is CPII’s exclusive licensor of the Property IP. (CPII and SPCP are, at times, collectively referred to herein as “Columbia Pictures”). 12.
Columbia Pictures, a division of Sony Pictures Entertainment Inc. (a leading motion picture studio), develops, produces, and distributes motion pictures and other entertainment products throughout the world. Columbia Pictures has released scores of highly successful motion pictures, including the
Men in Black
franchises, the three
Case 4:14-cv-00559 Document 1 Filed in TXSD on 03/06/14 Page 3 of 81