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While this case involves comedy,
no laughing matter. For over a decade, Plaintiff Comedy Playground has creatively employed the medium
comedy to train youth, business people, and senior citizens alike in the skills
public performance, comic timing,
esteem, public speaking, team building, and personal achievement. Designed to appeal to participants
all ages, ethnicities, and cultural backgrounds, Comedy Playground s programs
ve been implemented
regionally, nationally, and internationally, and enjoy a strong base
support among parents, educators, and comedic professionals alike. Comedy Playground alumni have gone on to professional entertainment careers, including the comedy club circuit, television co
ercials, successful sitcoms, and feature films.
Ironically, despite Comedy Playground s longstanding nationwide rights in the
PLAYGROUND name and mark, NBC has adopted the identical name and
r its own nationwide contest to identify fresh, comedic
talent for new televisi
comedies to air on
television networks. The harm
actions to Comedy Playground and its reputation is devastating and irreversible.
contest has not yet formally begun, Comedy
s already experienced multiple instances of actual confusion.
permitted to continue,
the COMEDY PLAYGROUND name and
will deceive the public about the relationship
the parties and effectively obliterate Comedy Playground s hard earned reputation and goodwill.
Plaintiff Comedy Playground, LLC is a California limited liability company with a principal place
business at 236 N. Catalina Avenue, Pasadena, California 91106.
Defendant NBCUniversal Media, LLC is a Delaware limited liability com
ny, with a principal place of business at 30 Rockefeller Plaza New York,
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Case 2:14-cv-03110-MRP-MAN Document 1 Filed 04/23/14 Page 2 of 13 Page ID #:2