1 Alan Jay Weil (SBN 63153

)
GAIMS WElL WEST LLtf
2 1875 Century Park East, 12 Floor
Los Angeles, California 90067-2513
3 Telephone: (310) 407-4526
FacsImile: (31Q) 277-2133
4 Email: ajweil@gwwe.com
5 Douglas A. Rettew (Pro Hac Vice atr:lication in process)
Julia Anne Matheson (SBN 214163
6 FINNEGAN, HENDERSON, FA BOW,
GARRETT & DUNNER, L.L.P.
7 901 New York Avenue, N.W.
Washington, DC 20001
8 Telephone: (202) 408.4000
FacsImile: (202) 408.4400
9 Email: doug.rettew@finnegan.com
Email: julia.matheson@finnegan.com
10
Attorneys for Comedy Playground, LLC
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UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
15
COMEDY PLAYGROUND, LLC, a
16 California limited liability company,
17
18
v.
Plaintiff,
NBCUNIVERSAL MEDIA, LLC, a
19 Delaware limited liability company,
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22
Defendant.
Case No.: 2:14-CIV-03110
COMPLAINT FOR FEDERAL
AND STATE TRADEMARK
INFRINGEMENT AND UNFAIR
COMPETITION
DEMAND FOR JURY TRIAL
23 Plaintiff Comedy Playground, LLC, by its undersigned attorneys, alleges as
24 follows, upon actual knowledge with respect to itself and its own acts, and upon
25 information and belief as to all other matters:
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1.
NATURE OF THE ACTION
This is a civil action for trademark infringement and unfair competition
28 under federal and state law.
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2. While this case involves comedy, it's no laughing matter. For over a
decade, Plaintiff Comedy Playground has creatively employed the medium of
comedy to train youth, business people, and senior citizens alike in the skills of
public performance, comic timing, self esteem, public speaking, team building, and
personal achievement. Designed to appeal to participants of all ages, ethnicities, and
cultural backgrounds, Comedy Playground' s programs have been implemented
regionally, nationally, and internationally, and enjoy a strong base of support among
parents, educators, and comedic professionals alike. Comedy Playground alumni
have gone on to professional entertainment careers, including the comedy club
circuit, television commercials, successful sitcoms, and feature films.
3. Ironically, despite Comedy Playground's longstanding nationwide
rights in the COMEDY PLAYGROUND name and mark, NBC has adopted the
identical name and mark for its own nationwide contest to identify fresh, comedic
talent for new television comedies to air on NBC television networks. The harm
caused by NBC's actions to Comedy Playground and its reputation is devastating and
irreversible. Even though NBC's contest has not yet formally begun, Comedy
Playground has already experienced multiple instances of actual confusion. If
permitted to continue, NBC's use of the COMEDY PLAYGROUND name and mark
will deceive the public about the relationship of the parties and effectively obliterate
Comedy Playground's hard earned reputation and goodwill.
THE PARTIES
4. Plaintiff Comedy Playground, LLC is a California limited liability
company with a principal place of business at 236 N. Catalina Avenue, Pasadena,
California 91106.
5. Defendant NBCUniversal Media, LLC is a Delaware limited liability
company, with a principal place of business at 30 Rockefeller Plaza New York, NY
27 10112.
28
2
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JURISDICTION AND VENUE
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6. This action arises under the federal Trademark Act, 15 U.S.C. §§ 1051,
3
et seq.
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7. This Court has jurisdiction over the subject matter of this action
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pursuant to 15 U.S.C. § 1121 and 28 U.S.C. §§ 1331 and 1338(a)-(b). This Court
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also has diversity jurisdiction under 28 U.S.C. § 1332 because Comedy Playground
and NBC reside in different states, namely, California and New York, respectively,
and the amount in controversy exceeds $75,000 exclusive of interest and costs. This
court has personal jurisdiction over Defendant, and venue is proper in the Central
District of California pursuant to 28 U.S.C. §§ 1391(b) and (c). Defendant is doing
business in this District, and a substantial portion of Defendant's unlawful activities
has taken place in this District.
COMEDY PLAYGROUND AND ITS FEDERALLY REGISTERED
"COMEDY PLAYGROUND" TRADEMARK
15 8. Founded in Los Angeles in 2002 at the McCadden Theater In
16 Hollywood, and offering on-going performances from the world-famous Hollywood
17 Improv since 2004, Comedy Playground is an entertainment company that provides
18 comedy seminars, classes, coaching, and performance opportunities in the field of
19 comedy.
20 9. Comedy Playground is run by professional comediennes; its founder
21 boasts such comedy credits as The Improv, The Comedy Store, Comedy Union, and
22 Laugh Factory, among dozens of other venues. Its student body spans all ages and
23 demographics, from teens, to corporations, to senior citizens. And its alumni have
24 gone on to the professional comedy club circuit as well as successful sitcoms and
25 feature films.
26 10. Comedy Playground has used COMEDY PLAYGROUND as both its
27 name and service mark since its inception in 2002.
28 11. Comedy Playground registered the "comedyplayground.com" domain
3
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name in October 2002, and has operated an active website at that location since its
launch. It has also maintained an active online presence across social media
channels including a Facebook page, communications on Twitter using the
"#comedyplayground" hashtag, and on Y ouTube both through general postings and
via its own channel.
- ",Up t/(omedypiayground.com p. I X - j HomeP.g. - Come,. x
Fil e Edit View favoriln Tools Help
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12. In the more than a decade since its launch, Comedy Playground has
been an active contributor to charitable causes, through its hosting and production of
live fund-raising events, and by bringing its special brand of humor and compassion
to charities including Children Affected by Aids, the Cancer Awareness Club, A
Place Called Home (a charity serving youth in South Central, LA), Legacy LA (a
community-based non-profit focused on youth development in East, LA), the Teak
Fellowship (a NYC-based community organization); and others.
4
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13. Comedy Playground has also dedicated significant time and resources
2
to youth in the Los Angeles area, offering on-site programs in local schools, and to
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disadvantaged inner-city and at-risk kids through local organizations such as the
4
Hollywood YMCA, the Hollywood Boys and Girls Club, Los Angeles Hollygrove,
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as well as extending scholarship opportunities to children working with inner-city
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community organizations.
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14. Over the years since its inception, numerous high-profile comedians
8
have contributed both their time and considerable talent to furthering Comedy
9
Playground's youth-based community and charitable efforts, both as supporters and
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guest speakers/artists.
15. Comedy Playground owns the following valid, subsisting federal
12
trademark registration for its COMEDY PLA YGROUND mark for its vanous
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entertainment and educational services, the details of which appear below:
Mark
COMEDY
PLAYGROUND
Reg. No.!
Reg. Date
3465170
July 15, 2008
Goods
EducatIOnal serVIces, namely,
conducting classes seminars and
workshops in of   stand
up comeay, wntmg, ImprOVIsatIOn and
performance and distrioution of course
material in connection therewith;
Educational services, namely,
conducting classes seminars and
workshops in fiel.d of   stand
up comeay, wntmg, ImprOVIsatIOn and
performance; Entertainment in the
nature of live comedy shows, including
stand up comedy, improvisational
comedy and sketch comedy;
Entertainment Services, namely,
providing a website featuring,
photographic, audio; video and prose
presentatIOns featunng comedy
workshops and performances;
Workshops and seminars in the field of
up comedy, writing,
ImprOVIsatIOn and performance.
5
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(A printout of this registration from the United States Patent and Trademark Office
online database is attached as Exhibit A.)
16. Comedy Playground' s registration for its COMEDY PLAYGROUND
mark constitutes prima facie evidence of the validity of that mark, of Comedy
Playground's ownership of that mark, and of Comedy Playground's exclusive right
to use that mark.
DEFENDANT AND ITS WRONGFUL ACTS
17. On April 8, 2014, NBC announced the launch of COMEDY
PLAYGROUND, "a contest intended to identify talent for the development of two
new television comedies for the NBC television network." NBC subsequently
launched a website devoted to the contest at www.nbccomedyplayground.com. A
page capture of that page is below:
file Edit View Favontes Took H ~ p
¥ C<> ~ colTlQdy playground ~ ' .. S..,ch - - 91 a Shore - jill - ~ Chod< - II Tronsiot. - AuIofili - comedy ployground
WELCOME
TO THE NBC COMEDY PLAYGROUND
00 you have a ground-breakinc comtdy idea? We're listeninll Oorcoalls to discover fresh,
comedic voices in an innovative, new way. Here's how it works:
lOn-AIr Wirm ....
Product Their Conwdi"
I
1 Di&itat Winner
Product'S His/Htr Conwdy
I .., I """'" l ............
6
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ShowPreml.m
on NBC
~
Showo.butlf,
Online
Signln ".
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18. Under its rules, COMEDY PLAYGROUND contestants submit
samples of their existing comedy work, sitcom pitch, and resume. After several
rounds of judging, an Advisory Board-comprised of "today's top names in
comedy"- will choose two on-air winners. From the remaining finalists, the public
will choose a "digital winner."
19. Each of the two on-aIr WInners will have his or her sitcom pitch
developed into a television show by NBC. And the digital winner will have his or
her sitcom pitch developed into a "Digital Program" for online broadcast.
20. According to NBC's website, the COMEDY PLAYGROUND contest
will formally launch on May 1, 2014 at 12:00 am EST and end "the date that the
Digital Winner is chosen." The submission period is due to run from May 1, 2014
through June 30, 2014.
21. Since its introduction of the contest on April 8, 2014, NBC's contest
has been the subject of numerous articles in the entertainment press and constant
coverage in the same social media channels used by Comedy Playground.
22. In the short time since its announcement, NBC's COMEDY
PLAYGROUND has already caused actual confusion with Comedy Playground.
Comedy Playground has received multiple communications through its website and
social media channels from consumers who mistakenly believe that Comedy
Playground is responsible for or involved with the NBC promotion.
23. Today, as a result of NBC's actions, consumers searching for Comedy
Playground on the Internet will be flooded with pages of listings of articles,
sponsored links, advertisements, and information, all about NBC' s contest.
7
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-J hnp:, comedyplayground.com I Home Paoe • Come." X
Sic J comedy playground
Suggested Sites
• ' I Search ' . I iii Share ' .A- Check ' II Translate' , AutoFili • comedy
About 31,600.000 results (0 33 seconds)
NBC Comedy Playground - NBCComedyPlayground.com
WWlY nbccomedyplayground coml 9
Make Your Big Idea The Next Comedy Hit on NBCI SUbmiSSionS Begin May 1
Comedy Playground: Home Page
comedyplayground com! 9
Comedy Playground IS a teen & pre· teen comedy program where you can dlSCoyer
create. and explore your own vOIce through the platform of comedy
NBC Creates 'Comedy Playground' Initiative to Launch Two .. ,
' V\WI hoiiylYoodreporter.com! .lnbe-creates·co • The Hollywood Reporter •
Apr 8. 2014 • Billed as a "grassroots l",hallYe: NBC Comedy Playground is a
nahonal campaign designed 10 give aspiring comedy wnters In the U S the
NBC Seeks TV Comedy Talent for New 'Playground' I Variety
vanery com! l do.not·post.nbc-comedy·playground·IOItlative-to-. • Vallety •
Apr 8, 2014 The Comedy Playground eifortls part of NBC Entertainment prexy
JenOlfer Salke's eifort 10 find creatrve ways to develop new matenal for the
Comedy Playground
,V\V\Y nbccomedyplayground com! •
Your big Idea could be the next big comedy hit on NBCI Submit onhne on May 1
NBC Comedy Playground Contest - How To Submit ..•
Mine comI2014/04/081nbc·comedy-conlest·playground-detallsl 9 NUne •
Apr 8,2014 NBC Comedy Playground Have a killer Idea for a new sitcom? NBC IS
all ears The network on Tuesday announced the launch of NBC
NBC asks viewers for better sitcom ideas I Inside TV I EW.com
Insldelv ew coml201"' .. lnbe-sotcom-cont • Enlertalnmenl Weekly •
by James H bbem 10 60 GoogI.,. ell s
Apr 8,2014 The Inlllahve. dubbed "NBC Comedy Playground: pledges to
reach beyond the ltadrtlonal talent labs of film schools and comedy clubs
by
NBC Creates Playground To Lure Comedy Writers Outside ...
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Apr 8,2014 NBC wants to find fresh COmedIC VOICes NBC's Entertalnmenl President
JenOlfer Salke today announced "NBC Comedy Playground " whICh
NBC Creates Comedy Playground to Discover New Talent «
grandand com/hollywood-prospectuslnbc-comedy·playgroundl •
Apr 9.2014 So the networt<s trying something new With NBC Comedy Playground
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Comedy Playground - Beverly Grove - Los Angeles, CA I Yelp
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WlWllIldleWlfe corn!   • Ind ,oows
Apr 8. 2014 Jenillfer Salke announced the InlllatlVe IItIed "NBC Comedy
Playground" at NBC Umversars Summer Press Day Tuesday evening The goal of .
Go gle >
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INJURY TO COMEDY PLAYGROUND AND THE PUBLIC
24. If not stopped, NBC's use of COMEDY PLAYGROUND is likely to
continue to cause confusion, mistake, and deception as to the source or origin of
NBC's contest, and is likely to falsely suggest a sponsorship, connection, license, or
association between NBC and/or its contest with Comedy Playground, thereby
injuring Comedy Playground, and the public.
25. NBC's actions are also likely to cause "reverse confusion," i.e., NBC
will so saturate the market with its COMEDY PLAYGROUND mark that Comedy
Playground's reputation and goodwill will be dwarfed and consumers will
erroneously believe that Comedy Playground's services emanate from or are
sponsored by NBC.
26. NBC's activities have caused, and unless immediately enjoined will
continue to cause, irreparable harm to Comedy Playground and its federally
registered COMEDY PLAYGROUND mark.
27. NBC' s activities have caused, and unless immediately enjoined will
continue to cause, irreparable harm to both Comedy Playground and consumers, who
have an interest in being free from confusion, mistake, and deception.
28. Comedy Playground has suffered actual damages to be proven at trial.
29. Comedy Playground has no adequate remedy at law.
FIRST CLAIM FOR RELIEF
Federal Trademark Infringement under
Section 32(1) of the Lanham Act, 15 U.S.C. § 1114(1)
23 30. Comedy Playground repeats and realleges each and every allegation set
24 forth in paragraphs 1 through 29 of this Complaint.
25 31. NBC is using in commerce Comedy Playground's registered
26 COMEDY PLAYGROUND trademark in connection with the sale, offer for sale,
27 distribution, and advertising of services in a manner that is likely to cause confusion,
28 or to cause mistake, or to deceive, in violation of Section 32(1) of the Lanham Act,
9
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15 U.S.C. § 1114(1).
2
SECOND CLAIM FOR RELIEF
3
Federal Trademark Infringement, False Designation of Origin,
Passing Off, and Unfair Competition under
Section 43(a)(1)(A) of the Lanham Act, 15 U.S.C. § 1125(a)(1)(A)
4
5 32. Comedy Playground repeats and realleges each and every allegation set
6 forth in paragraphs 1 through 31 of this Complaint.
7 33. NBC is using in 'commerce a word, term, name, and false designation
8 of origin that, in connection with its commercial activities, is likely to cause
9 confusion, or to cause mistake, or to deceive as to the affiliation, connection, or
10 association of NBC with Comedy Playground, or as to the origin, sponsorship, or
11 approval of NBC, its products, and its commercial activities by or with Comedy
12 Playground (or vice versa), in violation of Section 43(a)(1)(A) of the Lanham Act, 15
13 U.S.C. §1125(a)(1)(A).
14
15
THIRD CLAIM FOR RELIEF
Unfair Competition under California's Unfair Trade Practices Statute
Section 17200 et seq. of the Cal. Bus. & Prof. Code
16 34. Comedy Playground repeats and realleges each and every allegation set
17 forth in paragraphs 1 through 33 of this Complaint.
18 35. In connection with the sale and distribution of the infringing products,
19 NBC has engaged in unfair methods of competition, including unlawful, unfair,
20 and/or fraudulent acts or practices in the conduct of trade and commerce, and unfair,
21 deceptive, untrue, and/or misleading advertising, in violation of Section 17200 et seq.
22 of the Cal. Bus. & Prof. Code.
23
FOURTH CLAIM FOR RELIEF
Common Law Trademark Infringement and Unfair Competition
36. Comedy Playground repeats and realleges each and every allegation set
24
25
forth in paragraphs 1 through 35 of this Complaint.
26
37. NBC's activities described above constitute common law trademark
27
infringement and misappropriation of the goodwill associated with Comedy
28
Playground's COMEDY PLAYGROUND trademark, and constitute unfair
10
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competition in violation of California common law.
PRAYER FOR RELIEF
Comedy Playground requests that this Court enter judgment in its favor on
each and every claim for relief set forth above and award it relief including, but not
limited to, the following:
A. An Order holding that NBC's actions described above infringe and
dilute Comedy Playground's COMEDY PLAYGROUND trademark, and that NBC's
8
actions thus constitute federal and state trademark infringement and unfair
9
competition as detailed above.
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B. An Order preliminarily and permanently enjoining NBC, its employees,
agents, officers, directors, shareholders, subsidiaries, related companies, affiliates,
distributors, dealers, and all persons in active concert or participation with any of
them:
(1) From usmg the COMEDY PLAYGROUND mark, or any other
trademarks, trade names, logos, and other names or identifiers that are
confusingly similar to or dilutive of the COMEDY PLAYGROUND
mark, in any manner or form, with any products or services (or vice
versa).
(2) From representing or suggesting, by any means whatsoever, directly or
indirectly, that NBC, any products offered by NBC, or any activities
undertaken by NBC, are sponsored or approved by, or are associated,
affiliated, or connected with Comedy Playground in any way (or vice
versa).
C. An Order requiring NBC to deliver for destruction all products and
associated materials containing or referring to the infringing mark in its possession,
26
custody, or control,. or in the possessiOI!-, custody, or control of any of its agents or
27
representatives.
28
D. An Order requiring NBC to deliver for destruction all advertisements,
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promotional materials, labels, signs, pictures, and any other materials containing
infringing mark in its possession, custody, or control, or in the possession, custody,
or control of any of its agents or representatives.
E. An Order directing NBC to file with this Court and serve on Comedy
Playground's attorneys; within thirty (30) days after the date of entry of any
injunction, a report in writing and under oath setting forth in detail the manner and
form in which they have complied with this injunction.
F. An Order requiring NBC to account for and pay to Comedy Playground
any and all profits arising from NBC's unlawful acts and that such profits be
increased in accordance with 15 U.S.C. § 1117 and other applicable laws.
G. An Order requiring NBC to pay Comedy Playground damages in an
amount to be determined, and that such damages be trebled in accordance with 15
U.S.C. § 1117 and other applicable laws.
H. An Order requiring NBC to pay Comedy Playground its costs and
attorneys' fees in this action pursuant to 15 U.S.C. § 1117 and other applicable laws.
1. Any such other relief as the Court may deem appropriate.
18 Dated: April Z3, 2014
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By: ~ ~ ~ ~ ~   ____________ ___
ALAN JA ElL (SBN 63153)
GAIMS WElL WEST LLf
1875 Century Park East, It Floor
Los Angeles, California 90067-2513
Douglas A. Rettew (Pro Hac Vice in process)
Julia Anne Matheson (SBN 214163) -
FINNEGAN, HENDERSON, FAMBOW,
GARRETT & DUNNER, L.L.P.
901 New York Avenue, N.W.
Washington, DC 20001
12
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DEMAND FOR JURY TRIAL
1
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Plaintiff demands a jury trial on all claims and issues so triable.
4 Dated: April 13, 2014
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LLP
By: ~ ~ ~ ~ ~ ~ ____________ _
ALAN ~ ElL (SBN 63153)
GAIMS WElL WEST LLf
1875 Century Park East, It Floor
Los Angeles, California 90067-2513
Douglas A. Rettew (Pro Hac Vice in process)
Julia Anne Matheson (SBN 214163) -
FINNEGAN, HENDERSON, FARABOW,
GARRETT & DUNNER, L.L.P.
901 New York Avenue, N.W.
Washington, DC 20001
13
Case 2:14-cv-03110-MRP-MAN Document 1 Filed 04/23/14 Page 13 of 13 Page ID #:13
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