the events or omissions giving rise
the claims herein occurred in thisDistrict and, upon information and belief, important and relevant records are located in thisDistrict.
Pursuant to Local Rule 3-2(b), venue
proper in this Division because asubstantial part
the events or omissions giving rise to the claims occurred in this Division andthe intellectual property at issue is owned by Pendleton and thus resides in this Division.
Pendleton owns numerous federal registrations issued by the U.S. Patent andTrademark Office ("USPTO") for the trademark PENDLETON for use on a variety
Registration Nos. 3,574,742, 3,555,536, 3,574,743, 3,568,773, 3,718,175,3,297,528, 3,049,323, 2,951,453, 1,980,970, 2,059,665, 1,218,445, 913,742, and 514,710attached as Exhibits 1-13, incorporated herein and made a part hereof. Pendleton also ownsnumerous federal registrations for marks containing the term PENDLETON, includingPENDLETON COLORPLA
Reg. No. 3,680,928; PENDLETON ESTATE VINEYARDS
WINERY, Reg. No. 3,662,604; PENDLETON ECO-WISE WOOL, Reg. No. 3,638,636;PENDLETON HOME, Reg. No. 2,713,136; PENDLETON HOME COLLECTION, Reg.No. 2,717,244; PENDLETON ORIGINALS, Reg. No. 2,276,567; PENDLETON ORIGINALSBORN IN OREGON, Reg. No. 2,395,884;
WESTER WEAR BY PENDLETON, Reg.No. 2,276,748; PENDLETON STUDIO, Reg. No. 2,117,014; BEAVER STATE BYPENDLETON, Reg. No. 1,814,471; COUNTRY CLOTHES BY PENDLETON, Reg.No. 800,729; WARRANTED TO BE A PENDLETON PENDLETON WOOLEN MILLSPORTLAND, OREGON SINCE 1863, Reg. No. 2,053,150; WARRANTED TO BE A"PENDLETON" PENDLETON WOOLEN MILLS PORTLAND, OREGON, Reg.Nos. 777,919, 777,908, and 663,602; SIR PENDLETON, Reg. No. 715,837; and PENDLETON49'ER, Reg. No. 666,627. Collectively, the PENDLETON trademarks are referred to herein asthe "PENDLETON Marks."PAGE 3 -COMPLAINT
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