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Carter Complaint Part 1 (061810)

Carter Complaint Part 1 (061810)

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Published by: jose_duran4969 on Jun 24, 2010
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10/27/2011

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trademark protection, when they refer to a provider of goods or services, and

Plaintiff “Rick Ross” was a provider of goods, illegal drugs, and drug dealer

services, during his period of involvement in unlawful commerce, and the

“public” knows he was associated with drug activities in the past, and

Defendants capitalized on the “RICK ROSS” name‟s value in the Black, urban

Case 2:10-cv-04528-PA -RZ Document 1 Filed 06/18/10 Page 28 of 43

crime, law enforcement and rap music culture, and profited off Plaintiff‟s name

while he was in prison, to unjustly enrich themselves, and William Roberts, in

commerce and in rap music, but Defendants‟ unlawful actions caused confusion

in the minds of the “public”, as to Defendant Roberts‟ past affiliation with

Plaintiff, when in fact no affiliation existed between Plaintiff and Defendant, and

thus Defendants confused the “public”, and intentionally deceived the public

about his correction officer past.

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