COMPLAINT FOR DAMAGES
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Suite 102, McKinney, Texas. 4.
Plaintiff alleges, on information and belief, that Defendant MD5 TECHNOLOGIES (“Defendant MD5,” collectively “Defendants”), is now and was at the time of the filing of this Complaint, a business entity of unknown status that is a subsidiary of Defendant STU and is also owned by Defendant MATTSON, doing business at the address of 194 Industrial Boulevard, Suite 102, McKinney, Texas. 5.
Defendants conduct business in the jurisdiction of the United States District Court for the Central District of California by offering counterfeits goods for sale in Los Angeles, California, that infringes on Plaintiff’s registered trademarks, copyright, and patent. 6.
The true names and capacities, whether individual, corporate, associate or otherwise, of Defendants herein named as DOES 1-10, inclusive, are unknown to Plaintiff. Plaintiff therefore sues said Defendants by such fictitious names. When the true names and capacities of said Defendants have been ascertained, Plaintiff will amend this pleading accordingly. 7.
Plaintiff further alleges that Defendants, and DOES 1-10, inclusive, sued herein by fictitious names are jointly, severally and concurrently liable and responsible with the named Defendant upon the causes of action hereinafter set forth. 8.
Plaintiff is informed and believes and thereon alleges that at all times mentioned herein Defendants, and DOES 1-10, inclusive, and each of them, were the agents, servants and employees of every other Defendant and the acts of each defendant, as alleged herein, were performed within the course and scope of that agency, service or employment.
This Court has Federal subject matter jurisdiction over this matter pursuant to 28 U.S.C.
§§ 1331 and 1338(a) and (b), in that the case arises out of
Case 2:14-cv-06465-ODW-PLA Document 1 Filed 08/18/14 Page 3 of 23 Page ID #:3