Best Chairs Complaint

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF INDIANA

EVANSVILLE DIVISION

BEST CHAIRS INCORPORATED, )
)
Plaintiff ) Case No. 3:14-cv-00067
)
) Hon.
v. )
)
FACTORY DIRECT WHOLESALE, LLC )
)
Defendant )
)

VERIFIED COMPLAINT AND DEMAND FOR JURY TRIAL
Best Chairs Incorporated (Plaintiff or Best Chairs), by counsel, for its complaint
against Defendant Factory Direct Wholesale, LLC (Defendant), alleges the following, upon
actual knowledge with respect to itself and its own acts, and upon information and belief as to all
other matters:
NATURE OF THE ACTION
1. This is an action for injunctive relief, to recover damages, and to obtain other
appropriate relief from Defendant for counterfeiting, trademark infringement, false advertising,
false designation of origin, and unfair competition under federal, state, and common law.
2. Best Chairs is a well-known, nationally recognized, and respected furniture
company that has been in operation since 1962, using Best Chairs in its corporate name, trade
name, and trademarks. Best Chairs is the owner of certain rights in the BEST CHAIRS
Trademarks (defined below) in the United States for use in connection with chairs and other
furniture products.
Case 3:14-cv-00067-RLY-WGH Document 1 Filed 05/07/14 Page 1 of 20 PageID #: 1
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3. Defendant, without the authorization of Best Chairs, uses the designations
BESTCHAIR and BEST CHAIR as a trademark and brand name for a line of chairs and other
furniture products sold nationwide. Defendant also engages in other marketing and advertising
practices that falsely associate Defendant with Best Chairs.
PARTIES, JURISDICTION, AND VENUE
4. Best Chairs is a corporation formed under the laws of the State of Indiana on
October 2, 1962, with its principal place of business in Ferdinand, Dubois County, Indiana.
5. Best Chairs owns certain rights in the BEST CHAIRS Trademarks (defined
below) in the United States for use in connection with chairs and other furniture products.
6. Defendant is a limited liability company formed under the laws of the State of
Georgia on J anuary 19, 2005, with its principal place of business in Duluth, Georgia.
7. Defendant distributes and sells durable goods, including chairs and furniture
products, and Defendant, without the authorization of Best Chairs, unlawfully uses the
designations BESTCHAIR and BEST CHAIR as a trademark and brand name for a line of chairs
and other furniture products sold nationwide, and unlawfully uses such designations to market
and sell such products.
8. Best Chairs and Defendant are competitors with respect to the marketing, selling,
and distributing of chairs and other furniture products.
9. This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C.
1331 and 1338 because Best Chairs claims against Defendant arise primarily out of the
federal Lanham Act (15 U.S.C. 1051, et seq.).
10. Pursuant to 28 U.S.C. 1367, this Court may properly exercise supplemental
jurisdiction over Best Chairs state law claims against Defendant because they are so related to
the federal claims that they form part of the same case and controversy.
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11. This Court has personal jurisdiction over Defendant. Defendant has minimum
contacts with Indiana, events giving rise to the causes of action alleged herein occurred and are
occurring in this District, Best Chairs has suffered damage in this jurisdiction, and upon
information and belief, Defendant regularly conducts business activities in Indiana.
12. Venue is appropriate in this Court and in this division pursuant to 28 U.S.C.
1391 because a substantial part of the events or omissions giving rise to the claim have occurred
in this judicial district.
FACTUAL BACKGROUND
A. Best Chairs and the BEST CHAIRS Trademarks

13. Best Chairs is a well-known, nationally recognized, and respected furniture
company that has been in operation since 1962. Best Chairs has done business as Best Chairs
Incorporated, Best Chairs Inc., or Best Chairs since that time.
14. Best Chairs Incorporated, Best Chairs Inc., and Best Chairs are used and
have been used as company names, trade names, as common law trademarks, for more than 50
years, and have been included in trademarks registrations for nearly 30 years.
15. Best Chairs owns and uses a family of trade names and trademarks that
incorporate the element BEST, including, without limitation, BEST CHAIRS, BEST
CHAIRS INC. & Design, BEST HOME FURNISHINGS, THE POWER OF BEST, and
BEST-MAX (collectively, the BEST CHAIRS Trademarks).
16. Best Chairs owns the following United States trademark registrations which
incorporate the element BEST:
Mark
Serial No.
Reg. No.
Goods Key Dates
BEST CHAIRS INC. & Design

International Class 20:

First Use:
October 1962
4

Serial No. 73/534,333
Reg. No. 1,421,085
Chairs
Filing Date:
April 26, 1985

Registration Date:
December 16, 1986
BEST HOME FURNISHINGS

Serial No. 76/538,283
Reg. No. 2,871,238

Furniture
Filing Date:
August 19, 2003

First Use:
November 3, 2003

Registration Date:
August 10, 2004
THE POWER OF BEST

Serial No. 77/818,610
Reg. No. 3,839,150

Furniture
Filing Date:
September 2, 2009

First Use:
October 1, 2009

Registration Date:
August 24, 2010
BEST-MAX

Serial No. 77/232,709
Reg. No. 3,531,915

Chair cushions; Cushions; Cushions;
Living room furniture; Recliners;
Seats
Filing Date:
J uly 18, 2007

First Use:
September 1, 2007

Registration Date:
November 11, 2008

Copies of the registration certificates for the above-referenced U.S. trademark registrations are
attached to this Complaint as Exhibit A.
17. The foregoing U.S. trademark registrations are valid and subsisting and in good
standing.
18. Best Chairs owns the following United States trademark applications which
incorporate the element BEST:
Mark
Serial No.
Reg. No.
Goods Key Dates
BEST & Design

Serial No. 86/172,267

Furniture; residential furniture
First Use:
November 3, 2003

Filing Date:
J anuary 22, 2014
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BEST HOSPITALITY

Serial No. 86/171,991

Furniture; hospitality and
institutional furniture
Filing Date:
J anuary 22, 2014
THE POWER OF BEST & Design

Serial No. 86/171,087

Furniture; residential furniture
First Use:
October 1, 2009

Filing Date:
J anuary 21, 2014

Copies of the United States Patent and Trademark Offices online summary for the above-
referenced U.S. trademark applications are also attached as Exhibit A.
19. Best Chairs uses its BEST CHAIRS Trademarks in connection with its chairs and
furniture products, affixed to tags, labels, and packaging for its chairs and furniture products, and
to advertise and sell its products throughout the United States.
20. The following are examples of Best Chairs use of its BEST CHAIRS Trademarks
as affixed to hangtags for its chairs and other furniture products:

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21. Best Chairs uses its BEST CHAIRS Trademarks, and promotes its products
offered under those marks, on its website located at www.besthf.com.
22. Best Chairs has expended substantial sums of money in advertising and
promoting its products under the BEST CHAIRS Trademarks, such that the public recognizes
Best Chairs as the source of chairs and other furniture products offered under those marks.
23. By virtue of these efforts, the longstanding use of the BEST CHAIRS
Trademarks, and the quality of Best Chairs products, the BEST CHAIRS Trademarks have
acquired valuable goodwill in the marketplace.
24. Based on these and other efforts, the public has come to know the BEST CHAIRS
Trademarks, and recognizes that chairs and other furniture products offered under those marks
originate with Best Chairs.
B. Defendants Conduct

25. Defendant, a distributor and seller of durable goods, ships and sells chairs and
other furniture products throughout the United States, both through brick-and-mortar retail stores
and through online retailers.
26. Defendant uses the BESTCHAIR and BEST CHAIR designations as a trademark
and brand name for a line of chairs and other furniture products.
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27. Upon information and belief, Defendant imports its BESTCHAIR / BEST CHAIR
line of chairs and furniture products from a manufacturer in China for distribution and sale in the
United States. Those products are warehoused in facilities in California and Georgia, and are
shipped directly from those warehouses to consumers.
28. Upon information and belief, Defendants Chinese manufacturer operates under
the name BestChair, but has acquired no rights to use, or license the use of, the BestChair
designation in the United States.
29. Upon information and belief, without Best Chairs authorization, Defendant or a
related or predecessor entity made some use of the BESTCHAIR and BEST CHAIR
designations as a trade name in the United States roughly four years ago.
30. Upon information and belief, Defendant promotes and sells its BESTCHAIR /
BEST CHAIR line of chairs and furniture products on the Internet, including through the highly
interactive websites of online retailers such as Amazon.com and Rakuten.com.
31. As set forth in Exhibit B, Defendants products are promoted and sold on
Rakuten.com under the brand name BestChair and Defendant is listed as the Marketplace
Seller for those products.
32. As set forth in Exhibit B, Defendants products are promoted and sold on
Amazon.com under the brand name BestChair.
33. As set forth in Exhibit B, Defendants products are promoted on the website
eDealinfo.com under the brand name BestChair.
34. The screen shot from eDealinfo.com, as set forth in Exhibit B, provides an
example of Defendants products being promoted on the same web page as Best Chairs
products.
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35. On March 26, 2014, Defendant filed a United States trademark application for the
mark BESTCHAIR (Serial No. 86/232,975), which covers the goods of Chairs; Deck chairs;
Dining chairs; Office chairs; Reclining chairs, and claims a first use date of J anuary 12, 2010.
A copy of the United States Patent and Trademark Offices online summary for the above-
referenced U.S. trademark application is attached as Exhibit C.
36. Defendant submitted the following examples of its current use of the mark along
with its above-reference U.S. trademark application, which, upon information and belief, are
images of the BESTCHAIR and BEST CHAIR designations used as trademarks on packaging
for Defendants products.

37. Defendant has no right to use the BEST CHAIRS Trademarks, and use of the
BESTCHAIR and BEST CHAIR mark and brand name by Defendant is without the
authorization of Best Chairs.
38. Such use by Defendant of the BESTCHAIR and BEST CHAIR mark and brand
name in marketing and advertisements is material to consumer decisions to purchase the
products being advertised.
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39. Upon information and belief, Defendant accepts orders from and ships its
BESTCHAIR / BEST CHAIR products to customers throughout the United States, including
those located in Indiana.
40. Upon information and belief, Defendant ships its BESTCHAIR / BEST CHAIR
products in packaging that is affixed with labels bearing the BESTCHAIR or BEST CHAIR
mark.
C. Interaction Between the Parties

41. Approximately two years ago, Best Chairs learned of a party named Cavalier
Wholesale purporting to sell product on Amazon by BESTCHAIR. Best Chairs advised
Amazon of the matter, and Best Chair believed the issue to be resolved.
42. On J anuary 6, 2014, Best Chairs received notification from Tri-State Better
Business Bureau, Inc. that a complaint was lodged against Best Chairs by a consumer mistakenly
believing a defective office chair he purchased on Rakuten.com was manufactured by Best
Chair. Upon investigation, it was discovered that the BESTCHAIR product which was the
subject of the complaint was purchased was from Defendant.
43. Based on information only recently acquired, Best Chairs now believes the party
named Cavalier Wholesale and Defendant to be the same entity, under common control, or
otherwise related.
44. Moreover, this customer complained that he not only purchased a chair that
experienced a catastrophic (and presumably dangerous) failure shortly after its purchase, but he
was also treated poorly by a customer support representative (presumably an agent of Defendant)
who he contacted to document his complaint.
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45. In his documented complaint, that customer requested that Defendant issue a
refund, credit, replacement parts, or a replacement product, but was advised by a customer
support representative that his concerns would not be rectified.
46. Not long after learning of this actual consumer confusion in the marketplace, Best
Chairs, through counsel, sent Defendant a written letter on J anuary 16, 2014 outlining Best
Chairs rights in the BEST CHAIRS Trademarks, expressing its concern that Defendants use of
the BESTCHAIR mark is likely to cause consumer confusion, and requesting that Defendant
refrain from using the BESTCHAIR designation in such a manner.
47. In response, Defendant sent a letter to Best Chairs counsel on J anuary 24, 2014
suggesting that it could not find evidence of Best Chairs use of the BEST CHAIRS Trademarks
and otherwise indicating that it would take no steps to prevent consumer confusion.
48. On March 10, 2014, Best Chairs, through its counsel, again notified Defendant of
Best Chairs rights in the BEST CHAIRS Trademarks, of Best Chairs longstanding use of the
Best Chairs designation and mark, and of actual confusion in the marketplace as a result of
Defendants use of the BESTCHAIR mark. Best Chairs also repeated its request that Defendant
refrain from any infringing conduct.
49. On or around March 20, 2014, Best Chairs received a message from a
representative of Amazon.com requesting information on behalf of a customer regarding a
warranty for chairs purchased from a seller from Amazons website. The purchased products
were those of Defendant, not Best Chairs, which further confirmed that consumers and retailers
were experiencing actual confusion in the marketplace.
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50. Receiving no response to its March 10, 2014 letter, Best Chairs counsel sent one
final letter to Defendant on April 9, 2014 reiterating Best Chairs concerns and highlighting
further instances of actual confusion.
51. In response correspondence dated April 13, 2014, Defendant repeated its position
that it would not refrain from infringing behavior.
52. Upon information and believe, Best Chairs recently learned that Defendant has
received a failing score by the Better Business Bureau of Metro Atlanta, Athens & NE Georgia
due to its failure to respond to customer complaints filed against it, and such complaints included
those concerning Defendants advertising and sale practices, its product delivery practices, it
product guarantee and warranty practices, and issues related directly to its products.
D. Plaintiff Best Chairs Concerns

53. Defendants use of the BESTCHAIR and BEST CHAIR mark and brand name
has a substantial likelihood of causing confusion and mistake by consumers as to the source of
Defendants products.
54. Defendants use of the BESTCHAIR and BEST CHAIR mark and brand name
also has a substantial likelihood of causing confusion and mistake by consumers as to the
affiliation, connection, or association of Defendant with Best Chairs, and/or as to the sponsorship
or approval of Defendants products and commercial activities by Best Chairs.
55. Defendants use of the BESTCHAIR and BEST CHAIR mark and designation
has in fact caused actual confusion, as evidenced in part by customer complaints about
Defendant and its products that were mistakenly directed to Best Chairs, as well as inquiries by
consumers and online retailers of Defendants products and warranty information for such
products that were mistakenly directed to Best Chairs.
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56. Defendants unsatisfactory business practices and low-quality products have and
will negatively impact Best Chairs goodwill and business reputation largely due to Defendants
use of the BESTCHAIR and BEST CHAIR mark.
57. Upon information and belief, Defendant intentionally attempts to pass off its
products as products branded with the BEST CHAIRS Trademarks, and trade off of the goodwill
associated with the BEST CHAIRS Trademarks.
58. Upon information and belief, the conduct of Defendant alleged in this Complaint
is willful and intentional.
59. As the owner of the BEST CHAIRS Trademarks for chairs and other furniture
products, Best Chairs will suffer irreparable harm unless Defendant is enjoined from selling
counterfeit BESTCHAIR and BEST CHAIR branded products, mislabeling its products and their
packaging with the BESTCHAIR and BEST CHAIR mark, infringing upon the BEST CHAIRS
Trademarks, using false and misleading statements and representations of fact in its
advertisements, and otherwise engaging in unfair competition.
60. Defendants actions as alleged herein have caused, and will continue to cause,
harm to Best Chairs, its business, reputation, and goodwill, for which there is no adequate legal
remedy.

61. The hardship on Best Chairs in the absence of an injunction outweighs the
hardship, if any, to Defendant from being enjoined from continuing its unlawful conduct.
62. The public interest will not be disserved by entry of an injunction against
Defendants unlawful actions.
COUNT I FEDERAL TRADEMARK COUNTERFEITING
63. Best Chairs incorporates by reference paragraphs 1 through 61 as set forth above.
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64. Defendant advertises, sells, and ships to consumers chairs and other furniture
products wrapped in packaging that has affixed to it the BESTCHAIR or BEST CHAIR mark (or
a reproduction, counterfeit, colorable imitation, or copy thereof), or a spurious designation that is
identical with, or substantially indistinguishable from one or more of the federally registered
BEST CHAIRS Trademarks.
65. Such conduct by Defendant is without the authorization of Best Chairs, and is
intentional, willful, and with actual knowledge of the rights Best Chairs has in the BEST
CHAIRS Trademarks.
66. Defendants acts constitute unlawful counterfeiting in violation of 15 U.S.C.
1114 and 1116.
67. Best Chairs has been damaged as a result of Defendants conduct.
68. Best Chairs is entitled to injunctive and other relief as requested below.
COUNT II TRADEMARK INFRINGEMENT OF FEDERALLY REGISTERED
TRADEMARKS 15 U.S.C. 1114
70. The BEST CHAIRS Trademarks are owned and used by Best Chairs, and several
are federally registered, as described previously.
71. Defendant uses the BESTCHAIR and BEST CHAIR trademark and brand name
when marketing and selling its chairs and other furniture products.
72. Such conduct by Defendant is substantially likely to cause public confusion and
mistake as to the source of Defendants products, as to the affiliation, connection, or association
of Defendant with Best Chairs, and/or as to the sponsorship or approval of Defendants products
or commercial activities by Best Chairs.
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CHAIRS Trademarks.
74. Defendants acts constitute trademark infringement in violation of 15 U.S.C.
1114.
COUNT III UNFAIR COMPETITION, FALSE ADVERTISING, FALSE
DESIGNATION OF ORIGIN AND INFRINGEMENT UNDER 15 U.S.C. 1125
78. Best Chairs has rights in the company name, trade name and trademarks using
BEST and BEST CHAIRS in connection with chairs and other furniture products throughout the
United States.
79. Defendants use of BESTCHAIR and BEST CHAIR as a trade name and
trademark in the marketing and selling chairs and other furniture products is likely to cause
public confusion and mistake as to the source of Defendants products, as to the affiliation,
connection, or association of Defendant with Best Chairs, and/or as to the sponsorship or
approval of Defendants products or commercial activities by Best Chairs. Defendant uses the
BESTCHAIR and BESTCHAIR trademark in its commercial advertising or promotion.
80. Because Defendants products are not the products of Best Chairs and Defendant
is not otherwise authorized to use any of the BEST CHAIRS Trademarks, such conduct by
Defendant constitutes a false designation of origin, a false or misleading description of fact,
and/or a false or misleading representation of fact which misrepresents the nature, characteristics,
or qualities of Defendants products or commercial activities.
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81. Defendants conduct is without the authorization of Best Chairs, and is, upon
information and belief, intentional and willful, and is with actual knowledge of the rights Best
Chairs has in the BEST CHAIRS Trademarks.
82. Defendants acts constitute infringement, false advertising, false designation of
origin, and unfair competition all in violation of 15 U.S.C. 1125.
COUNT V UNFAIR COMPETITION UNDER INDIANA STATE LAW
84. Best Chairs owns, and has established trademark rights in Indiana to, its company
name, trade name, and BEST CHAIRS Trademarks.
85. Defendant uses the BESTCHAIR and BEST CHAIR trademark and other related
indicia in connection with its chairs and other furniture products, on packaging for those
products, and when marketing and selling such products.
86. Such conduct by Defendant is substantially likely to cause public confusion and
mistake as to the source of Defendants products, as to the affiliation, connection, or association
of Defendant with Best Chairs, and/or as to the sponsorship or approval of Defendants products
or commercial activities by Best Chairs.
CHAIRS Trademarks.
88. By infringing upon the BEST CHAIRS Trademarks and using the same and/or
confusingly similar marks and other indicia to derive benefit, Defendant is unfairly trading upon
and misappropriating for its own benefit the valuable goodwill, reputation, publicity, and
business opportunities of Best Chairs.
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89. Defendants acts constitute trademark infringement and unfair competition under
the common law and the statutes of the State of Indiana.
COUNT VI CIVIL ACTION UNDER THE INDIANA CRIME VICTIMS ACT
93. Pursuant to the Indiana Crime Victims Act, Indiana Code 34-24-3-1, a person
that suffers a pecuniary loss as a result of a violation of Ind. Code 35-43, et seq. may bring a
civil action against the person who caused the loss for treble damages, the costs of the action,
and reasonable attorneys fees.
94. Defendant has encumbered or otherwise exerted unauthorized control over one or
more of the BEST CHAIRS Trademarks, and such conduct by Defendant was done knowingly or
intentionally, was done with the intent to deprive Best Chairs of the value or use of one or more
of the BEST CHAIRS Trademarks or products offered thereunder, and was done without the
authorization of Best Chairs in violation of Ind. Code 35-43-4-3.
95. Defendant has, with the intent to defraud, misrepresented the quality of its
products in violation of Ind. Code 35-43-5-3(6).
96. Defendant has disseminated to the public an advertisement that it knows is false,
misleading, or deceptive, with intent to promote the purchase or sale of its products in violation
of Ind. Code 35-43-5-3(9).
97. Defendant has made or uttered written instruments, such as chairs and other
furniture products, and packaging for such products, in such a manner that it purports to have
been made by the authority of Best Chairs, and such conduct was done knowingly or
17
intentionally and was done without the authorization of Best Chairs in violation of Ind. Code
35-43-5-2.
PRAYER FOR DAMAGES AND INJUNCTIVE RELIEF
WHEREFORE, Best Chairs prays for all appropriate relief, including, without limitation:
A. That Defendant, and its affiliates, officers, directors, employees, agents,
representatives, and all persons acting or claiming to act on its behalf or under its direction or
authority, and all persons or entities acting in concert or participation therewith, be preliminarily
and permanently enjoined from: (i) the conduct described herein; (ii) using or authorizing others
to use the BESTCHAIR trademark or brand name, the BEST CHAIR trademark or brand name,
or the BEST CHAIRS Trademarks, or any confusingly similar mark or colorable imitation
thereof, in connection with the marketing, sale, or distribution of any goods or services offered
by it; (iii) performing any act which can or is likely to lead members of the public to believe that
any good or service marketed, sold, or distributed by it is in any manner associated or connected
with Best Chairs, or is sold, manufactured, licensed, sponsored, endorsed, or authorized by Best
Chairs; and (iv) otherwise taking any action likely to cause confusion, mistake, or deception on
the part of the public as to the connection, affiliation, or other association of goods or services of
Defendant with the goods or services of Best Chairs;
B. That Defendant, and its affiliates, officers, directors, employees, agents,
representatives, and all persons acting or claiming to act on its behalf or under its direction or
authority, and all persons or entities acting in concert or participation therewith, be preliminarily
and permanently enjoined from engaging in unfair competition against Best Chairs;
C. For an order awarding damages sustained by Best Chairs, and the costs incurred
by Best Chairs in this action, and/or based upon Defendants profits associated with the sale of
the goods or services that bear, have been offered under, or were used in connection with the
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BESTCHAIR trademark or brand name, the BEST CHAIR trademark or brand name, or the
BEST CHAIRS Trademarks, in an amount up to three times the amount of actual damages;
D. For an order that Defendant bear the cost of any rehabilitative advertising to
correct the damages done to the BEST CHAIR Trademarks;
E. For an order awarding punitive or enhanced damages, as well as court costs and
attorneys fees, for Defendants willful and egregious conduct;
F. For an order directing Defendant to provide a full written accounting of all goods
and services that bear, have been offered under, or were used in connection with the
BESTCHAIR trademark or brand name, the BEST CHAIR trademark or brand name, or the
BEST CHAIRS Trademarks, sold by Defendant or its affiliates;
G. For an order directing Defendant to destroy, alter, and/or deliver to Best Chairs all
materials, including, without limitation, labels, packaging, signs, prints, advertisements,
prototype plans, and similar items, in its possession or under its control that bear, are offered
under, or are used in connection with the BESTCHAIR trademark or brand name, BEST CHAIR
trademark or brand name, or the BEST CHAIRS Trademarks, or any mark confusingly similar
thereto;
H. For an order directing each Defendant to file with this Court, and serve upon Best
Chairs counsel within thirty (30) days after entry of such judgment, a written report under oath,
setting forth in detail the manner and form in which Defendant has complied with such
judgment;
I. For an award of interest, including prejudgment interest; and
J . For such other relief as the Court may deem just and proper, including, without
limitation, an order requiring corrective action to minimize damage or to alleviate consumer
19
confusion, along with other relief available to Best Chairs under 15 U.S.C. 1117 and Indiana
Code 34-24-3-1.
JURY DEMAND
Best Chairs, pursuant to Rule 38 of the Federal Rules of Civil Procedure, does hereby
demand a trial by jury.
BINGHAM GREENEBAUM DOLL LLP
/s/ Amy B. Berge
Amy B. Berge
J oseph R. Dages
101 South Fifth Street
3500 National City Tower
Louisville, Kentucky 40202
(502) 587-3707
(502) 540-2268 (facsimile)
aberge@bgdlegal.com
jdages@bgdlegal.com
Attorneys for Best Chairs Incorporated

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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF INDIANA

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