Case 2:21-cv-01968-GMN-VCF Document 1 Filed 10/26/21 Page 1 of 13

1 JAMES D. BOYLE, ESQ. (NBN 08384)

E-mail: jboyle@nevadafirm.com
2 JOANNA M. MYERS, ESQ. (NBN 12048)
E-mail: jmyers@nevadafirm.com
3
HOLLEY DRIGGS
4 400 South Fourth Street, Third Floor
Las Vegas, Nevada 89101
5 Telephone: 702/791-0308
Facsimile: 702/791-1912
6
Attorneys for Plaintiffs William L. Salviano
7
and Geneta Salviano, d/b/a Stinky Cigar
8
UNITED STATES DISTRICT COURT
9
DISTRICT OF NEVADA
10
WILLIAM L. SALVIANO, an individual d/b/a Case No.:
11 Stinky Cigar; GENETA SALVIANO, an
individual, d/b/a Stinky Cigar,
12 COMPLAINT
Plaintiffs,
13 v.
14
PRESTIGE IMPORT GROUP INC., a Florida
15 corporation; 1ST CLASS CIGAR HUMIDORS
INC., a Florida corporation,
16
Defendants.
17

18 Plaintiffs William L. Salviano and Geneta Salviano, doing business as Stinky Cigar

19 (collectively, “Stinky Cigar” or “Plaintiffs”), for their complaint against Defendants Prestige

20 Import Group Inc. (“P.I.G.”) and 1st Class Cigar Humidors Inc. (“1st Class Cigar”) (collectively,

21 with P.I.G., the “Defendants”), hereby allege and complain as follows:

22 PARTIES

23 1. William L. Salviano is an individual doing business as Stinky Cigar, having a

24 principal business address located in Clark County, Nevada.

25 2. Geneta Salviano is an individual doing business as Stinky Cigar, having a principal

26 business address located in Clark County, Nevada.

27 3. On information and belief, Prestige Import Group Inc. is a corporation organized

28 under the laws of the state of Florida, with a principal place of business located at 1800 S.
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1 Powerline Road, Deerfield Beach, Florida 33442.

2 4. On information and belief, 1st Class Cigar Humidors Inc is a corporation organized

3 under the laws of the state of Florida, with a principal place of business located at 7049 NW 71

4 Terrace, Parkland, Florida 33067.

5 JURISDICTION AND VENUE

6 5. The Court has subject matter jurisdiction over this action under 28 U.S.C. § 1331

7 (federal question jurisdiction), 28 U.S.C. § 1338(a) (jurisdiction over trademark), 28 U.S.C.

8 § 1338(b) (unfair competition claim joined with a substantial and related claim under the

9 trademark laws), and 15 U.S.C. § 1121(a), because this action arises under the Lanham Act, 15
10 U.S.C. §§ 1051, et seq. The Court also has supplemental jurisdiction over the claims arising out of

11 state law pursuant to 28 U.S.C. §§ 1338(b) and 1367 because the state law claims arise out of the

12 same operative facts as the federal claims.

13 6. This Court has personal jurisdiction over Defendants because Defendants sell and

14 offer for sale goods under the Infringing Marks (as defined below), and otherwise conduct business

15 in this district, and have engaged in tortious conduct resulting in injury to Plaintiffs in this district.

16 7. Venue in this district is proper pursuant to 28 U.S.C. § 1391(b) because, among

17 other reasons, Defendants have, and continue to, transact business within this district and offer for

18 sale in this district goods and services in a manner that infringes Plaintiffs’ trademark rights. In

19 addition, Plaintiffs have suffered harm in this district and a substantial part of the events or

20 omissions giving rise to the claims asserted herein occurred in this district.

21 FACTS COMMON TO ALL CLAIMS

22 STINKY CIGAR’S STINKY® MARKS

23 8. Stinky Cigar was founded by William and Geneta Salviano in 2004.

24 9. That same year, Stinky Cigar first began offering its uniquely designed cigar

25 ashtrays under the trademarks STINKY® and STINKY CIGAR® (collectively, with the Stinky

26 Cigar Trade Dress (as defined below), the “STINKY® Marks”).

27 10. Almost immediately, Stinky Cigar’s original STINKY® ashtray gained popularity

28 and significant market success. Initial shipments of the original STINKY® ashtray design sold out

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1 quickly. Based on the huge popularity of the original design, Stinky Cigar soon began offering

2 additional ashtray models under its STINKY® brand, all of which share the highly distinct and

3 recognizable design of the original STINKY® ashtray (“Stinky Cigar Trade Dress”).

4 11. Contributing to the distinctive appearance and appeal of the STINKY® ashtray is

5 its unique deep bowl shape and inventive “stirrups,”1 which make STINKY® ashtrays highly

6 recognizable to consumers as originating from Stinky Cigar.

7 12. Over the past 17 years, STINKY® branded ashtrays have become well-known to

8 cigar enthusiasts throughout the world. STINKY® branded ashtrays are immediately recognizable

9 to consumers and have won awards and received numerous accolades. For example, in 2015 the
10 STINKY® ashtray won first place in the “Outstanding Art” category at the 2015 Cigar Trophy

11 Awards, honoring the “best designed ashtray ever”—an award presented by the Cigar Journal, a

12 leading cigar industry magazine publication.

13 13. Stinky Cigar was also recognized by the Cigar Rights of America in July 2014 and

14 was named the CRA Ambassador for the State of Nevada for tireless work on behalf of the cigar

15 industry, consumers and retail tobacconist’s community of Nevada and across the nation.

16 14. STINKY® branded ashtrays have been featured in dozens of third-party magazine

17 articles and are the subject of numerous consumer and industry reviews.

18 15. Stinky Cigar’s STINKY® ashtrays have become so popular among cigar

19 aficionados, the mere addition of new colors to the STINKY® ashtray product line is considered

20 newsworthy, and featured in unsolicited third-party cigar industry news publications, which has

21 further contributed to consumers’ widespread recognition of Stinky Cigar’s STINKY® Marks.

22 16. As a result, Stinky Cigar’s STINKY® ashtrays have become extremely well known

23 and respected among consumers, who have come to associate Stinky Cigar’s trademarks, logos,

24 and trade dress of the STINKY® ashtrays as exclusively associated with and originating from

25 Stinky Cigar.

26 ///

27

28 1
The term “stirrup” is a term coined by Stinky Cigar to identify its unique cigar ashtray rests.
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1 17. Stinky Cigar continues to promote and advertise its STINKY® ashtray product

2 lines, which has expanded to include five (5) separate product lines featuring over fifty (50) colors

3 and finishes—all of which incorporate the highly distinctive Stinky Cigar Trade Dress.

4 18. Stinky Cigar has also used the STINKY® Marks extensively on the Internet and

5 through Social Media mediums, and through such mediums the marks have developed a strong

6 Internet and Social Media presence and recognition by consumers who use such mediums. Stinky

7 Cigar maintains a retail website using the <stinkycigar.com> domain name. In addition to owning

8 and operating its STINKY® website at www.stinkycigar.com, Stinky Cigar uses its STINKY®

9 Marks extensively on the Internet through the social networking sites YouTube
10 (www.youtube.com/user/StinkyCigarAshtray), Instagram (www.instagram.com/stinkycigar/),

11 Twitter (www.twitter.com/StinkyCigar), and Facebook (www.facebook.com/Stinky-Cigar-

12 Ashtrays).

13 19. Stinky Cigar has expended considerable time, effort, and money promoting and

14 advertising its STINKY® ashtrays, further contributing to the recognition and success of the

15 STINKY® Marks.

16 20. As a result of Stinky Cigar’s extensive use, marketing, branding, and promotion of

17 its STINKY® Marks and STINKY® branded line of products, the STINKY® Marks have become

18 recognized by consumers, enjoying substantial recognition, goodwill, and exclusive association

19 with Stinky Cigar. The consuming public distinguishes Stinky Cigar’s line of products from those

20 of others who offer the same or similar goods and services on the basis of its STINKY® Marks.

21 21. Stinky Cigar’s ownership of the STINKY® and STINKY CIGAR® marks is

22 evidenced by the following United States Trademark Registrations:

23 Mark Reg. No. Reg. Date Goods & Services

24
STINKY February
4900209 Class 34: Ashtrays comprised primarily of metal
25 CIGAR 16, 2016

26 Class 25: Shirts; T-shirts

Class 34: Ashtrays; ashtrays for smokers; ashtrays
May 29,
27 4216864 for smokers made of non-precious metals; ashtrays
2012
for smokers made of precious metals; ashtrays of
28 precious metal; ashtrays, not of precious metal;

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1 smokers’ articles, namely, cigar glue; smokers’

articles, namely, cigar storage tubes; smokers’
2 articles, namely, outdoor cigar and cigarette
disposal units; smokers’ articles, namely, outdoor
3
receptacles for cigar and cigarette ash and waste
4

5 (collectively, the “STINKY® Marks”).

6 22. Stinky Cigar’s federal registration Nos. 4216864 and 4900209 have become

7 incontestable within the meaning of Section 15 of the Lanham Act, 15 U.S.C. § 1065, and

8 constitute conclusive evidence that the recited marks are valid, and that Stinky Cigar is entitled to

9 exclusive use of the recited marks in commerce throughout the United States for the goods

10 identified therein.

11 23. Stinky Cigar also own the following pending applications for the Stinky Cigar

12 Trade Dress with the United States Patent and Trademark Office (“USPTO”):

13 Mark Ser. No. Filing Date Goods & Services

14

15 January 26,
90490007 Class 34: Ashtrays
2021
16

17
January 26,
18 90490000 Class 34: Ashtrays
2021
19

20 DEFENDANTS’ INFRINGEMENT OF THE STINKY® MARKS

21 24. Defendants are wholesale distributors and retailers of cigar-related products.

22 25. On information and belief, Defendants are affiliated companies, with Defendant

23 P.I.G. primarily conducting Defendants’ wholesale activities, and Defendant 1st Class Cigars

24 acting as Defendants’ retail outlet selling direct to consumers.

25 26. On information and belief, Defendants distribute their goods through the websites

26 located at www.prestigeimportgroup.com and www.1stclasshumidors.com.

27 27. Between approximately 2005 and June 2020, Defendants were authorized

28 distributors and retail sellers of authentic STINKY® ashtrays, during which time Defendants

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1 conducted business with Stinky Cigar in Nevada and/or with Stinky Cigar’s wholesale distributor

2 in Westin, Florida.

3 28. For over fifteen (15) years, Defendants sold authentic STINKY® ashtrays to

4 retailers and direct to consumers through various channels of trade, including, but not limited to,

5 by means of Defendants’ websites.

6 29. On information and belief, Defendants received their last shipment of authorized

7 STINKY® ashtrays in or around June 2020.

8 30. Shortly thereafter, and as Defendants’ stock of authentic STINKY® ashtrays

9 depleted, Defendants began manufacturing and selling imitation/knock-off ashtrays (“Infringing

10 Goods”) that incorporated the distinctive and well-known Stinky Cigar Trade Dress.

11 31. Defendants sold the Infringing Goods on Defendants’ websites and through other

12 large third-party commercial websites, including, but not limited to, Amazon.com and eBay.com.

13 32. In conjunction with the distribution and sale of the Infringing Goods, Defendants

14 knowingly, willfully, and unlawfully used Stinky Cigar’s registered STINKY® mark and the

15 distinctive Stinky Trade Dress (collectively, “Infringing Marks”) to intentionally direct consumers

16 to Defendants’ websites for the Infringing Goods.

17 33. Specifically, Defendants used the STINKY® Marks in product descriptions for the

18 Infringing Goods and in website descriptions and metadata, which intentionally diverted Internet

19 traffic to the Infringing Goods. Defendants also used images of authentic STINKY® ashtrays in

20 website listings, which linked to URLs displaying the Infringing Goods for sale. Additionally,

21 Defendants’ online retail listings for the Infringing Goods contained consumer reviews for

22 authentic STINKY® ashtrays. All such actions by Defendants were knowingly and purposeful,

23 with the intent to deceive consumers into believing that they were purchasing authentic STINKY®

24 ashtrays when they were not.

25 34. All such uses by Defendants of Stinky Cigar’s registered STINKY® mark and the

26 distinctive Stinky Trade Dress were unauthorized and unapproved by Plaintiffs.

27 35. On information and belief, consumers purchased the Infringing Goods, mistakenly

28 believing they were authentic STINKY® ashtrays.

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1 36. Based on Defendants’ prior fifteen-year relationship with Stinky Cigar, it is

2 apparent that Defendants’ adoption and use of the Infringing Marks was in done knowingly and in

3 bad faith with the intent of capitalizing on Stinky Cigar’s goodwill and the well-known nature of

4 the STINKY® Marks and Stinky Trade Dress. Accordingly, Defendants’ infringement of the

5 STINKY® Marks is intentional and willful.

6 37. Defendants’ adoption and first use of the Infringing Marks in connection with

7 identical products as those of Stinky Cigar, occurred long after Stinky Cigar’s first use and/or

8 registration of the STINKY® Marks.

9 38. At the time of Defendants’ adoption and first use of the Infringing Marks,
10 Defendants were well-aware of Stinky Cigar’s superior rights in the STINKY® Marks and knew

11 or should have known that the unauthorized use of the Infringing Marks constituted violations of

12 Stinky Cigar’s rights, title and interest in and to the STINKY® Marks.

13 39. Defendants’ use of the Infringing Marks and sale of the Infringing Goods is likely

14 to cause confusion, mistake, and deception of consumers as to the source, quality, and nature of

15 Defendants’ goods, thereby proximately causing injury to Stinky Cigar and its trademark rights.

16 40. On information and belief, Defendants’ sale of the Infringing Goods and

17 unauthorized use of the Infringing Marks has caused, and will continue to cause, actual confusion

18 among consumers.

19 41. Defendants’ wrongful actions as alleged herein have caused damages to Plaintiff

20 and irreparable injury to Plaintiffs’ business, reputation, and goodwill, for which Plaintiffs are

21 entitled to recover damages and obtain injunctive relief.

22 FIRST CLAIM FOR RELIEF

23 (TRADEMARK INFRINGEMENT PURSUANT TO 15 U.S.C. §§ 1114 AND 1115)

24 42. Stinky Cigar incorporates the allegations set forth in each of the preceding

25 paragraphs as if fully set forth herein.

26 43. Defendants’ Infringing Marks are identical and/or confusingly similar to Stinky

27 Cigar’s STINKY® Marks.

28 ///

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1 44. Defendants’ use in commerce of the Infringing Marks constitutes a reproduction,

2 copying, counterfeiting, and colorable imitation of Stinky Cigar’s registered STINKY® Marks, in

3 such a manner as is likely to cause confusion, to cause mistake, and/or to deceive consumers.

4 45. On information and belief, Defendants’ use in commerce of the Infringing Marks

5 has caused actual confusion amongst the consuming public.

6 46. Defendants are using a mark that is the same and/or confusingly similar to the

7 STINKY® Marks in connection with the sale, offering for sale, or advertising of goods and

8 services in a manner that is likely to cause confusion or mistake, or to deceive customers as to an

9 affiliation, connection, or association with Stinky Cigar, or as to the origin, sponsorship, or

10 approval of Defendants’ goods, services, or commercial activity by Stinky Cigar.

11 47. Defendants’ use of the Infringing Marks and/or a mark(s) confusingly similar to the

12 STINKY® Marks, was intentional and willfully done with the knowledge that Stinky Cigar owns

13 and has used, and continues to use, its STINKY® Marks.

14 48. Defendants’ use of the Infringing Marks is unauthorized.

15 49. Stinky Cigar has no control over the quality of Defendants’ Infringing Goods and,

16 because of the source confusion engendered by Defendants’ willful trademark infringement,

17 Stinky Cigar’s valuable goodwill in and to its STINKY® Marks has been, and continues to be,

18 significantly harmed.

19 50. Defendants’ activities constitute willful and deliberate infringement of STINKY®

20 Marks in violation of the Lanham Act, 15 U.S.C. § 1114(1). Accordingly, Stinky Cigar is entitled

21 to recover Defendants’ profits, together with Stinky Cigar’s damages, increased monetary

22 recoveries as provided by the Lanham Act, as well as costs of the action and reasonable attorneys’

23 fees pursuant to Section 35(a) of the Lanham Act, 15 U.S.C. § 1117(a).

24 51. As a direct and proximate result of Defendants’ infringement, Stinky Cigar has

25 suffered, and will continue to suffer, monetary damages and irreparable injury to its business,

26 reputation, and goodwill.

27 52. Defendants’ activities have caused, and will continue to cause, irreparable harm to

28 Stinky Cigar for which Stinky Cigar has no adequate remedy at law. Accordingly, Stinky Cigar

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1 is entitled to preliminary and permanent injunctive relief pursuant to 15 U.S.C. § 1116(a), and to

2 an order under 15 U.S.C. § 1118 and other operation of law impounding all goods and other

3 materials in Defendants’ possession, custody, or control that bear the Infringing Marks.

4 53. Stinky Cigar also is entitled to, in addition to the other remedies described herein,

5 the cost of corrective advertising and a reasonable royalty as a result of Defendants’ infringement

6 of Stinky Cigar’s STINKY® trademarks.

7 SECOND CLAIM FOR RELIEF

8 (UNFAIR COMPETITION, FALSE DESIGNATION OF ORIGIN, AND FALSE ADVERTISING

PURSUANT TO 15 U.S.C. § 1125)
9
54. Stinky Cigar incorporates the allegations set forth in each of the preceding
10
paragraphs as if fully set forth herein.
11
55. Stinky Cigar’s STINKY® Marks, including, without limitation, the Stinky Trade
12
Dress, are distinctive and have acquired secondary meaning in the eyes of the public.
13
56. The Stinky Cigar Trade Dress is nonfunctional, and the overall appearance of
14
STINKY® branded ashtrays is immediately recognized by consumers as exclusively associated
15
with and originating from Stinky Cigar.
16
57. Defendants’ use of the STINKY® Marks, including, without limitation, the Stinky
17
Trade Dress, is likely to cause confusion, mistake, and/or to deceive the consuming public as to
18
the affiliation, connection, and/or association between Stinky Cigar’s STINKY® branded goods
19
and Defendants’ Infringing Goods.
20
58. On information and belief, at all times relevant to this action, including at the time
21
Defendants first adopted and began using the Infringing Marks without authorization, Defendants
22
knew of Stinky Cigar’s prior adoption and widespread commercial use of its STINKY® Marks,
23
including, without limitation, the Stinky Trade Dress, and knew of the valuable goodwill and
24
reputation acquired by Stinky Cigar in connection with its marks and products. Defendants’
25
infringement, unfair competition, and false designation of is therefore knowing, willful, and
26
deliberate.
27
///
28

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1 59. As a direct and proximate result of Defendants’ infringement, Stinky Cigar has

2 suffered, and will continue to suffer, monetary damages and irreparable injury to its business,

3 reputation, and goodwill.

4 60. Defendants’ activities have caused and will continue to cause irreparable harm to

5 Stinky Cigar for which Stinky Cigar has no adequate remedy at law.

6 61. As a result of Defendants’ intentional and unauthorized use of the STINKY®

7 Marks, Stinky Cigar is entitled to injunctive relief.

8 62. As a direct and proximate result of Defendant’s intentional and unauthorized use of

9 the STINKY® Marks, Stinky Cigar has been compelled to retain counsel to enforce its trademark
10 rights and prosecute this action, for which Stinky Cigar should recover attorneys’ fees and costs

11 pursuant to 15 U.S.C. § 1117.

12 THIRD CLAIM FOR RELIEF

13 (UNFAIR COMPETITION UNDER STATE LAW)

14 63. Stinky Cigar incorporates the allegations set forth in each of the preceding
15 paragraphs as if fully set forth herein.
16 64. Defendants’ unauthorized use in commerce of the Infringing Marks as alleged
17 herein is likely to deceive consumers as to the origin, source, sponsorship, or affiliation of
18 Defendants’ services, and is likely to cause consumers to believe, contrary to fact, that Defendants’
19 services are sold, authorized, endorsed, or sponsored by Stinky Cigar, or that Defendants are in
20 some way affiliated with or sponsored by Stinky Cigar. Defendants’ conduct therefore constitutes
21 trademark infringement, use of a false designation of origin and misleading description and
22 representation of fact in violation of Nevada common law.
23 65. Upon information and belief, Defendants have committed the foregoing acts of
24 infringement with full knowledge of Stinky Cigar’s prior rights in the STINKY® Marks and with
25 the willful intent to cause confusion and trade on Stinky Cigar’s goodwill.
26 66. Defendants’ conduct is causing immediate and irreparable harm and injury to
27 Stinky Cigar, and to its goodwill and reputation, and will continue to both damage Stinky Cigar
28 and confuse the public unless enjoined by this court. Stinky Cigar has no adequate remedy at law.

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1 67. As the direct and proximate result of Defendant’s conduct, Stinky Cigar has

2 suffered, and will continue to suffer, monetary damages and irreparable injury to its business,

3 reputation, and goodwill.

4 68. As a direct and proximate result of Defendants’ infringement, Stinky Cigar has been

5 compelled to retain counsel to enforce its trademark rights and prosecute this action.

6 PRAYER FOR RELIEF

7 WHEREFORE, Stinky Cigar prays for entry of a judgment ordering and declaring:

8 1. That, preliminarily pending trial of this action and permanently thereafter,

9 Defendants and their agents, servants, employees, successors, licensees and assignees, and all
10 persons, firms, entities, partners, or corporations in active concert or participation with Defendants,

11 are preliminarily and thereafter permanently enjoined from doing, threatening, or attempting to do

12 or causing to be done, either directly or indirectly, by any means, method or device, any of the

13 following acts:

14 (a) Directly or indirectly infringing, using, or displaying the STINKY® Marks,

15 or any mark confusingly similar thereto, including but not limited to the Infringing Marks, in any

16 manner or for any purpose, including, but not limited to, in advertising, promoting, producing,

17 distributing, selling, offering for sale, or giving away any services or products which infringe, use,

18 or display STINKY® Marks, or any marks confusingly similar thereto;

19 (b) Using any term that is likely to be confused with Stinky Cigar’s STINKY®

20 Marks;

21 (c) Falsely representing, misleading, or deceiving consumers into believing that

22 services or products advertised, promoted, produced, distributed, sold, or offered by sale by

23 Defendants originate from Stinky Cigar, or are sponsored, approved, licensed by, or associated

24 with Stinky Cigar, or that Defendants or their services or products are in some way associated or

25 affiliated with Stinky Cigar or its STINKY® branded goods;

26 (d) Committing any other acts calculated to or that do unfairly compete with

27 Stinky Cigar in any manner;

28 (e) Filing or maintaining any business license, d/b/a, or similar document using

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1 the STINKY® Marks or any mark confusingly similar thereto; and

2 (f) Registering, using, or trafficking in any trade name or domain name

3 containing or consisting of the STINKY® Marks or any mark confusingly similar thereto;

4 2. That Defendants be required to account for all profits derived by Defendants from

5 their trade, infringing conduct, unfair practices and competition, and for an order of restitution of

6 the entire amount of those profits, in amounts to be proven at trial;

7 3. That, in addition to being ordered to pay the lost profits attributable to the infringing

8 conduct complained of herein, Defendants also be ordered to pay their infringing profits as

9 monetary damages and reasonable royalties, to be increased by the Court by such amount as the
10 Court deems to be just, together with Stinky Cigar’s damages, all of which, according to the

11 circumstances of this case, should be increased and trebled as provided by law, including 15 U.S.C.

12 § 1117;

13 4. That Defendants be ordered to pay exemplary or punitive damages to the extent

14 available under and according to 15 U.S.C. § 1117 and other operation of law;

15 5. That Defendants be ordered to pay all of Stinky Cigar’s attorneys’ fees, costs, and

16 disbursements incurred in this suit, in bringing this action for the legal enforcement of its trademark

17 rights, and in connection with all efforts to stop Defendant’ trademark infringement, counterfeiting

18 and unfair competition, pursuant to 15 U.S.C. § 1117 and other operation of law;

19 6. That an Order issue from this Court instructing the United States Marshals Service

20 or other law enforcement agency to impound all goods and other materials in Defendants’

21 possession, custody, or control that bear the Infringing Marks, pursuant to 15 U.S.C. § 1118 and

22 other operation of law;

23 7. That Defendants be ordered to pay prejudgment and post-judgment interest

24 according to law;

25 8. That Defendants be ordered to pay the costs of any and all corrective advertising;

26 and

27 ///

28 ///

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1 9. For all such other, further, and different relief that this Court deems just and proper.

2 DATED: October 26, 2021.

3 HOLLEY DRIGGS

4 /s/ Joanna M. Myers, Esq.

JAMES D. BOYLE, ESQ. (NBN 08384)
5 JOANNA M. MYERS, ESQ. (NBN 12048)
6 400 South Fourth Street, Third Floor
Las Vegas, Nevada 89101
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Attorneys for Plaintiffs William L. Salviano
8 and Geneta Salviano d/b/a Stinky Cigar
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