1 Plaintiff, JA T WHEELS, Inc. a California Corporation, dba STR Racing 2 (hereinafter Plaintiff'), hereby files this Complaint against Defendant JNC 3 WHEEL COLLECTION (hereinafter Defendant ), and DOES 1 to
and alleges 4
Plaintiff files this action to combat the willful sale
unlicensed and 7 counterfeit products (hereinafter Infringing Products ) bearing the 8 Plaintiff's exclusive Trademark and utilizing the Plaintiffs exclusive 9 design patents, and unauthorized use
Plaintiffs copyrighted 1
photographs. The Defendant
a corporation specializing in the research,
manufacture and sales
aftermarket automobile wheels.
Plaintiff seeks a Permanent Injunction, damages, costs, and attorneys' fees
as authorized by the Lanham Act, the patent laws
the United States,
Title 35, United States Code, California's common law, and California
Business Professions Code.
This Court has subject matter jurisdiction under
U.S.C. § 1338(a) (action arising under an Act
Congress relating to patents or trademarks).
On information and belief, Defendants are subject to personal jurisdiction
in the Central District
California (the District ), consistent with the
due process and the California Long Arm Statute, because
Defendants offer their products for sale in this District, have transacted 24 business in this District, have committed and/or induced acts
infringement in this District, and/or have placed infringing products into
INC. S COMPLAINT