Bridgestone v. OTR Wheel Eng'g - Complaint

FOR THE MIDDLE DISTRICT OF TENNESSEE
NASHVILLE DIVISION
Bridgestone Brands, LLC,
Bridgestone Americas Tire Operations, LLC,

Plaintiffs,
)
)
)
)
)
v.
OTR Wheel Engineering, Inc.,
)
)
)
Civil Action No: ---------
JURY TRIAL DEMANDED
----~D~e~fe~n~d~a~nt~_________________________)
COMPLAINT FOR TRADEMARK INFRINGEMENT,

DESIGN PATENT INFRINGEMENT, AND UNFAIR COMPETITION
Plaintiffs Bridgestone Brands, LLC and Bridgestone Americas Tire Operations, LLC
(individually and collectively "Bridgestone") by their undersigned attorneys, allege as follows,
upon actual knowledge with respect to themselves and their own acts and upon information and
belief as to all other matters.
NATURE OF THE ACTION
1.
This is a civil action for trademark infringement, design patent infringement, and
unfair competition under federal, state, and/or common law. Bridgestone seeks equitable and
monetary relief from Defendant OTR Wheel Engineering, Inc.'s unlawful promotion and sale of
tires that infringe the famous BRIDGESTONE and FIRESTONE marks/names and
Bridgestone's patented tread design. Among a vast universe of non-infringing marks to choose
from, Defendant selected the marks BLACKSTONE and ROADSTONE to mimic and trade off
the valuable goodwill long associated with the STONE-suffix marks/names BRIDGESTONE
and FIRESTONE. Making matters worse, Defendant also copied Bridgestone's patented tread
design for its knock-off BLACKSTONE tires. For these and other reasons, Bridgestone seeks to
4811 -2580-4577.2
Case 3:14-cv-02402 Document 1 Filed 12/29/14 Page 1 of 20 PageID #: 1
enjoin Defendant's unlawful conduct and to recover damages, Defendant's profits, attorneys'
fees, costs, and other relief.
PARTIES
2.
Plaintiff Bridgestone Brands, LLC is a Delaware I imited liability company with a
business address at 535 Maniot Drive, Nashville, Tennessee 37214.

3.
Plaintiff Bridgestone Americas Tire Operation, LLC is a Delaware limited
liability company with a business address at 535 Maniott Drive, Nashville, Tennessee 37214.
Bridgestone Americas Tire Operations, LLC is authorized to use the BRIDGESTONE and
FIRESTONE trademarks and names in the United States.
4.
Defendant OTR Wheel Engineering, Inc. is a Georgia corporation with an address
at 6 Riverside Industrial Park, P.O. Box 1853, Rome, GA 30162.

JURISDICTION AND VENUE
5.
This Court has jurisdiction over the subject matter of this action pursuant to 15
U.S.C. 1121; 35 U.S.C. 271, 281, and 289; and 28 U.S.C. 1331, 1338(a) and (b). The
Court has supplemental jurisdiction over Bridgestone's state-law claims pursuant to 28 U.S.C.
1367(a) because they are substantially related to its federal claims and arise out of the same
case or controversy.
6.
This Court has general personal jurisdiction over Defendant based on its
continuous and systematic contacts with Tennessee, including its distribution and sale of
products in Tennessee.
7.
This Court has specific personal jurisdiction over Defendant because it has
purposefully availed itself of the privilege of conducting business in Tennessee. Defendant
4811 -2580-4577.2
distributes and sells infringing BLACKSTONE tires in Tennessee (including Nashville,

Tennessee).
8.
Venue lies in this District pursuant to 28 U.S.C. 1391(b) and (c) and 1400(b)
because a substantial part of the events giving rise to Bridgestone' s claims have occurred and are
continuing to occur in this District and Bridgestone maintains its principal place of business in
this District.
BRIDGESTONE AND THE FAMOUS
BRIDGESTONE AND FIRESTONE TRADEMARKS/NAMES
9.
Bridgestone and its related and affiliated companies comprise the world's largest
tire and rubber company. Their products are sold in over 150 nations and territories around the
world.
10.
In 1988, Bridgestone's related company purchased The Firestone Tire & Rubber
Company, which was founded over a century ago by entrepreneur and innovator Harvey S.
Firestone. By 1900, with twelve employees and a single production facility in Akron, Ohio, The
Firestone Tire & Rubber Company produced its first tire. FIRESTONE tires quickly gained a
reputation for quality and performance; they were chosen by Henry Ford for the first massproduced cars in America and, shortly thereafter, drove to victory in the very first Indianapolis
500 car race.
11.
Today, Bridgestone develops, manufactures, and markets BRIDGESTONE and
FIRESTONE-branded tires for virtually every type of land vehicle, including tires for passenger,
light truck, commercial truck and bus, agriculture, and off-the-road vehicles.
4811 -2580-4577.2
12.
Bridgestone and its related companies presently have over 40 production facilities
in the Americas alone; produce and sell 50 million tires a year; operate over 2,200 directly
owned and operated retail outlets in North America; and employ nearly 45,000 people.
13.
Bridgestone has continuously used the BRIDGESTONE and FIRESTONE
trademarks/names in commerce in the United States since their respective first uses in 1967 and
1900.
14.
Through itself or licensees, the BRIDGESTONE and FIRESTONE marks/names
have been used in connection with various other tire and automotive products (e.g., road-safety
kits), services, accessories, and related goods (e.g., video games, models, and toys).
15.
Bridgestone Brands, LLC owns the FIRESTONE mark and the following valid
and subsisting incontestable U.S. federal trademark registrations for that mark (among others):
Mark
""*
rtrestone
FIRESTONE
rtrestone
Goods/Services
Reg. No.
Reg. Date
Rubber tires
0140804
03/2911921
Vehicle tires
and inner
tubes
therefor
1387468
03/25/1986
Vehicle tires
and inner
tubes
therefor
2464005
06/26/2001
Retail tire
and
automotive
store
services
1178631
11/1711981
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ftrestone
Automotive
repair and
maintenance
services
3173847
11/21/2006
ftrestone
Retail tire
store
services
3173840
11/21/2006
16.
The BRIDGESTONE mark is covered by the following incontestable U.S. federal
trademark registrations (among others):
Mark
Goods/Services
Reg. No.
Tires and
inner tubes
therefor
2607465
BRIDGESTONE
Tires
1342473
BRIDGES TONE
Tires
2886688
.lJR106ESTORE
Reg. Date
8113/2002
611811985
9/21/2004
BRIDGESTONE'S SALES AND PROMOTIONAL ACTIVITIES
17.
Over the years, Bridgestone has sold billions of dollars of tires branded with the
BRIDGESTONE and FIRESTONE marks in the U.S.

18.
Bridgestone's tires are sold through approximately 2,200 company-owned stores
and 10,000 independent wholesalers and retailers nationwide-ranging from major retailers such
as W AL-MART and SEARS to independent tire dealers. Bridges tone's tires have been featured
as original equipment on some of the world's top-selling cars and trucks, including those made
by BMW, Toyota, Nissan, General Motors, Chrysler, Daimler (Mercedes-Benz), Volkswagen,
Mazda, Subaru, and others.
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19.
Bridgestone spends tens of millions of dollars annually advertising, marketing,
and promoting the BRIDGESTONE and FIRESTONE marks/names through vittually every type
of digital, broadcast, and print media, including but not limited to print advertisements (e.g.,
magazines and newspapers), television and radio commercials, Internet advertising, social media,
billboards, brochures, catalogs, point-of-sale displays, sponsorships, trade shows, and
promotional items.
20.
For decades, the BRIDGESTONE and FIRESTONE marks/names and tires have
been promoted through nationally-distributed general-interest magazines such as Fortune,
People, Time, Sports Illustrated, Rolling Stone, Golf Digest, Men's Fitness, Men 's Health, Jet,
and Popular Mechanics, as well as major national newspapers such as the Wall Street Journal
and USA Today.
Additionally, Bridgestone's corporate-owned stores and independent tire
retailers regularly mn advettisements in local newspapers throughout the country promoting the
BRIDGESTONE and FIRESTONE marks and tires.
21.
The BRIDGESTONE and FIRESTONE marks/names have been regularly
featured in national and local television, cable, and radio advettisements.
Bridgestone's
television commercials have appeared on major network channels, including NBC, ABC, CBS,
and FOX channels. They have also aired on cable-television networks such as ESPN, MTV,
HGTV, TNN, TNT, VH1, FX, Comedy Central, Discovery Channel, The History Channel, and
Speed TV.
For example, in 2012 Bridgestone launched its successful "Time to Perfmm"
television advertising campaign, comprised of a series of commercials featuring high-profile

professional athletes (such as NFL players Troy Aikman, Deion Sanders, Matthew Stafford, and
Adam Vinetari; NBA players Tim Duncan and Steve Nash; NHL Player Drew Doughty;
women's soccer player Alex Morgan; pro bowler Kelly Kulick; and pro golfers Fred Couples,
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Matt Kuchar, and Hudson Swafford) and the BRIDGESTONE mark/name (representative
screenshots below).
22.
In 2012, Bridgestone also launched a nationwide television ad campaign (excerpts
shown below) promoting FIRESTONE tires and automotive maintenance services and featuring
the voice of well-known country music star Trace Adkins. This campaign has reached hundreds
of millions of viewers nationwide.
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23.
Starting in 2008, commercials featuring the BRIDGESTONE mark/name aired
during the Super Bowl-reaching over 100 million viewers each year. The 2011 Super Bowl
broadcast reached over 110 million viewers, breaking the record for the most-watched program
in U.S. television history.
The 2008 Super Bowl was the second most watched television
program in U.S. history when it aired.

24.
The BRIDGESTONE and FIRESTONE marks/names have further been promoted
through Bridgestone's sponsorship of a number of high-profile sports leagues, associations, and

events. For example, BRIDGESTONE tires are the Official Tire of the National Football League
(NFL), the National Hockey League (NHL), National Hockey League Players Association
(NHLPA), and the Professional Golfers Association (PGA) Tour. Bridgestone was the title
sponsor of the Super Bowl XLII, XLIII, and XLIV "Bridgestone Super Bowl Halftime Show"
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and currently sponsors the NHL Winter Classic (depicted below) and the World Golf
Championships-Bridgestone Invitational played at the Firestone Country Club in Akron, Ohio.
FIRESTONE is (and/or has been) the Official Tire of Major League Baseball, and Official Tire
of the Indy Racing League, IndyCar, and the Indianapolis 500. Moreover, Bridgestone has
signed on to be an Olympics partner/sponsor through 2024.
25.
The BRIDGESTONE and FIRESTONE marks/names have been promoted
through various highly followed and publicized racing events. In addition to Formula 1, the
BRIDGESTONE mark has been promoted through sponsorship of the Champ Car World Series
since 1996 and Formula D Drift Series racing. The FIRESTONE mark has been prominently
featured in connection with the Indy 500 race. From 1920 through 1966, Firestone won every
Indy 500 race-a record unmatched by any other tire manufacturer. The BRIDGESTONE
and/or FIRESTONE marks/names appear prominently on signage and other materials throughout
these events.
26.
In 2010, Nashville's sports and entertainment venue (depicted below) was
renamed BRIDGESTONE ARENA.
The BRIDGESTONE ARENA venue is home to the
Predators-Nashville's NHL hockey team. The venue has received several awards, including
481 1-2580-4577.2
9
the ACM (Academy of Country Music) Venue of the Year and the IEBD (International
Entertainment Buyers Association) Venue of the Year. It has also hosted high-profile events,
such as the third round of the 2012 NCAA Men's Basketball Tournament, 2011 Stanley Cup
Western Conference Quarterfinals and Semifinals, and the 45th Annual Country Music Awards.
27.
The BRIDGESTONE and FIRESTONE marks/names have also been promoted
online through various company websites, popular social-networking websites (including

FACEBOOK and TWITTER), and advertising placed on third-party websites.
28.
In addition to its own substantial advertising and promotional activities,
Bridgestone, its products, and it sponsored events receive a significant amount of unsolicited
media coverage, including on nationally broadcast television programs and in widely circulated
publications.
29.
As a result of the distinctive nature and inherent strength of the BRIDGESTONE
and FIRESTONE marks/names; widespread use, advertising, publicity, and promotion; and
billions of dollars of sales, the BRIDGESTONE and FIRESTONE marks/names have been well
known and famous since long before OTR began its infringing acts.
4811 -2580-4577.2
10
30.
In Bridgestone/Firestone North American Tire, LLC and BFS Brands, LLC v.
Silverstone Berhad, 2003 TIAB LEXIS 142, 28-29 (TIAB 2003), the Trademark Trial and
Appeal Board of the United States Patent and Trademark Office held that the FIRESTONE mark
is famous.
BRIDGESTONE'S DURAFORCE MH TIRES

31.
Within its expansive product line, Bridgestone offers various Off-The-Road
("OTR") tires for commercial, agricultural, and other applications.

32.
Bridgestone's "FIRESTONE DuraForce MH" tires (shown below) are among the
industry's leading tires for material-handler equipment.
BRIDGESTONE'S DESIGN PATENT

33.
On March 20, 2010, the United States Patent and Trademark Office (PTO) issued
U.S. Design Patent No. D612,800 ("the '800 patent") (attached as Exhibit A), titled "Tire
Tread," to inventors Paula R. Lundgren and Ronald W. Tatlock.
34.
Bridgestone is the owner of all right, title, and interest in and to the ' 800 patent by
assignment from inventors Paula R. Lundgren and Ronald W. Tatlock.

35.
The claimed design of the '800 patent is directed to tire tread, as shown in figures
1-10 and described in the accompanying figure descriptions (see Exhibit A).
4811 -2580-4577.2
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The '800 patent is valid.

OTR AND ITS WRONGFUL ACTIVITIES
36.
Like Bridgestone, Defendant is a tire company.
37.
With full knowledge of Bridgestone's famous BRIDGESTONE and FIRESTONE
marks/names, and with a vast universe of marks to choose from, Defendant selected two marks
with a -STONE suffix, namely, BLACKSTONE and ROADSTONE.
38.
Defendant's BLACKSTONE and ROADSTONE tires are intended for off-the-
road uses and applications.

39.
One of Defendant's BLACKSTONE tires uses the following tread design (shown
below next to Bridgestone' s patented tread design):

Infringing BLACKSTONE Tire
Bridgestone's Patented Tread Design
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12
Figure 5 of '800 patent

Rubbing o_f'BLACKSTONE tire tread
INJURY TO BRIDGESTONE AND THE PUBLIC
40.
Defendant's uses of the infringing marks BLACKSTONE and ROADSTONE
(collectively the "STONE Marks") and tread-pattern design are likely to cause confusion,
mistake, and deception as to the source or origin of the products advertised/offered under those
marks/design, and are likely to falsely suggest a sponsorship, connection, or association between
Defendant, its tires, and/or its commercial activities with Bridgestone.
41.
Defendant's actions described above are likely to dilute the distinctiveness and
value of Bridgestone's famous FIRESTONE mark.

42.
Defendant's unauthorized uses of the STONE Marks and tread-pattern design
have damaged and irreparably injured, and, if permitted to continue will further damage and
irreparably injure Bridgestone,
the BRIDGESTONE and FIRESTONE marks/names,
Bridgestone's patented design, Bridgestone's reputation and goodwill, and/or the public's
interest in being free from confusion.
4811-2580-4577.2
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43.
Defendant has acted knowingly, willfully, in reckless disregard of Bridgestone's
rights, and in bad faith, as evidenced in part by its obvious copying of the BRIDGESTONE and
FIRESTONE trademarks and names, and Bridges tone's tread design.
FIRST CLAIM FOR RELIEF
Trademark Infringement Under
Section 32(1) of the Lanham Act, 15 U.S.C. 1114(1)
44.
Bridgestone repeats and realleges each and every allegation set forth m
paragraphs 1 through 43 of this Complaint.

45.
Without Bridgestone's consent, Defendant used and continues to use in commerce
reproductions, copies, and colorable imitations of Bridgestone's registered FIRESTONE mark in

connection with the offering, distribution, and advertising of automotive services which is likely
to cause confusion, or to cause mistake, or to deceive, in violation of Section 32(1) of the
Lanham Act, 15 U.S.C. 1114(1).
SECOND CLAIM FOR RELIEF
Trademark Infringement, False Designation
of Origin, Passing Off, and Unfair Competition
Under Section 43(a) of the Lanham Act, 15 U.S.C. 1125(a)
46.
Bridgestone repeats and realleges each and every allegation set forth in

47.
Defendant's actions, as described above, are likely to cause confusion, or to cause
mistake, or to deceive as to the origin, sponsorship, or approval of Defendant, its products,

and/or its commercial activities by or with Bridgestone, and thus constitute trademark
infringement of the BRIDGESTONE and FIRESTONE marks, false designation of origin,
passing off, and unfair competition in violation of Section 43(a) of the Lanham Act, 15 U.S.C.
1125(a).
4811-2580-4577.2
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THIRD CLAIM FOR RELIEF

Trademark Dilution Under Section
43(c) of the Lanham Act, 15 U.S.C. 1125(c)
48.

49.
Bridgestone's FIRESTONE mark is famous, as that term is used in 15 U.S.C.
1125(c), and was famous prior to Defendant's first use of BLACKSTONE and ROADSTONE,
based on, among other things, the federal registration of Bridgestone's FIRESTONE mark and
the extensive nationwide use, advertising, promotion, and recognition of Bridgestone's
FIRESTONE mark.
50.
Defendant's actions, as described above, are likely to dilute the distinctive quality
of Bridgestone's famous FIRESTONE mark in violation of Section 43(c) of the Lanham Act, 15
U.S.C. 1125(c), as amended by the Trademark Dilution Revision Act of 2006.
FOURTH CLAIM FOR RELIEF
Design Patent Infringement of the '800 Patent
Under 35 U.S.C. 271, 289
51.
paragraphs 1 through 50 and of this Complaint.

52.
In the eye of the ordinary observer familiar with the relevant prior art, giving such
attention as a purchaser usually gives, the claimed design of the '800 patent and the tread of
Defendant's BLACKSTONE tire are substantially the same, such that the ordinary observer
would be deceived into believing that the tread design of Defendant's BLACKSTONE tire is
substantially the same as the design claimed in the '800 patent.
53.
In violation of 35 U.S.C. 271, Defendant has directly infringed the '800 patent
by making, offering for sale, selling, and/or importing BLACKSTONE tires in the United States.
4811 -2580-4577.2
15
54.
In violation of 35 U.S.C. 289, Defendant has directly infringed the '800 patent
by applying the patented design of the '800 patent, or a colorable imitation thereof, to an article
of manufacture, including BLACKSTONE tires, for the purpose of sale and/or by selling,
offering, or exposing for sale an article of manufacture, including BLACKSTONE tires, to which
the patented design of the '800 patent or a colorable imitation thereof has been applied.
FIFTH CLAIM FOR RELIEF
Common-Law Trademark Infringement and Unfair Competition
55.

56.
mistake, or to deceive as to the affiliation, connection, or association of Defendant with

Bridgestone, or as to the origin, sponsorship, or approval of Defendant, its products, and its
commercial activities by or with Bridgestone such that Defendant's acts constitute infringement
of Bridgestone's proprietary rights in the BRIDGESTONE and FIRESTONE marks/names,
misappropriation of Bridgestone' s goodwill in those marks, and unfair competition under
Tennessee common law.
SIXTH CLAIM FOR RELIEF
Unfair and Deceptive Trade Practices
Under the Tennessee Consumer Protection Act
57.

58.
mistake, or to deceive as to the origin, license, sponsorship, or approval of Defendant, its

products, and/or its commercial activities by or with Plaintiff and/or its related companies and
thus constitute unfair or deceptive practices in violation of the Tennessee Consumer Protection
4811 -2580-4577.2
16
Act, Tenn. Code Ann. 47-18-104.

SEVENTH CLAIM FOR RELIEF
Dilution under Tennessee Law
59.

60.
Bridgestone's FIRESTONE trademark is widely recognized by the general
consuming public in Tennessee as a designation of source for Bridgestone's services and

products.
61.
Through extensive use and promotion, Bridgestone's distinctive FIRESTONE
trademark is famous, as defined under Tenn. Code Ann. 47-25-513, and was famous before
Defendant's first use of FIRESTONE.
62.
Defendant's use of FIRESTONE, as described above, is likely to dilute the
distinctive quality of Bridgestone's FIRESTONE trademark, as defined under Tenn. Code Ann.
47-25-513.
JURY DEMAND
Pursuant to Fed. R. Civ. P. 38, Bridgestone respectfully demands a trial by jury on all
issues properly triable by a jury in this action.
PRAYER FOR RELIEF
WHEREFORE, Bridgestone 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 declaring that Defendant's use of the STONE Marks (BLACKSTONE
and ROADSTONE) violates Bridgestone's rights in the BRIDGESTONE and FIRESTONE
4811 -2580-4577.2
17
marks/names and constitutes infringement, dilution, and unfair competition under federal and/or
state law, as detailed above;
B.
An Order declaring that Defendant's use of Bridgestone' s patented tread-pattern
violates the '800 patent and constitutes infringement under federal law, as detailed above;
C.
A permanent injunction enjoining Defendant and its employees, agents, partners,
officers, directors, owners, shareholders, principals, subsidiaries, related companies, affiliates,

distributors, dealers, and all persons in active concert or participation with any of them:
1.
From using or registering the STONE Marks and any other marks or
names that are likely to be confused with the BRIDGESTONE or FIRESTONE marks, or
that are to likely dilute the FIRESTONE mark, including as or as part of a product name
or logo, company name or logo, trademark, service mark, trade name, business name,
fictitious name, slogan, tagline, domain name, e-mail address, URL, social-media name,
screen name, keyword, metatag, or other name or identifier;
2.
From making, importing, promoting, offering or exposing for sale, or
selling BLACKSTONE tires or any tire with tread design confusingly similar to the
claimed design of Bridgestone's '800 patent; and
3.
From representing by any means whatsoever, directly or indirectly, that
Defendant, any products or services offered by Defendant, or any activities undertaken by

Defendant, are associated or connected in any way with Bridgestone, sponsored or
authorized by Bridgestone, or otherwise affiliated with Bridgestone
D.
An Order directing Defendant to, within thirty (30) days after the entry of the
injunction, file with this Court and serve on Bridgestone' s attorneys a report in writing and under
4811 -2580-4577.2
18
oath setting forth in detail the manner and form in which Defendant has complied with the
injunction;
E.
An Order directing Defendant to immediately send to Bridgestone all products,
signage, advertisements, promotional materials, stationery, forms, and/or any other materials and
things that contain or bear the STONE Marks, any other marks or names that are likely to be
confused with the BRIDGESTONE or FIRESTONE marks and/or Bridgestone's patented tread
design, and/or that are likely to dilute the FIRESTONE mark;
F.
An Order requiring Defendant or any ISP used by Defendant to immediately
remove all uses of the STONE Marks, Bridgestone's patentented tread design, and products
bearing those marks and design from the www.otrwheel.com website and any other website(s)
owned or controlled by Defendant or a related entity or person;
G.
An Order requiring Defendant to account for and pay to Bridgestone any and all
profits arising from the foregoing acts, and increasing such profits, including trebling them, in
accordance with 15 U.S.C. 1117 and other applicable laws;
H.
An Order requiring Defendant to pay Bridgestone damages in an amount as yet
undetermined (and including prejudgment and post-judgment interest) caused by the foregoing
acts, and trebling such damages in accordance with 15 U.S.C. 1117,35 U.S.C. 284 or 289;
and other applicable laws;
I.
An Order requiring Defendant to pay Bridgestone punitive damages in an amount
to be detetmined due to the foregoing willful acts;

J.
An Order requiring Defendant to pay Bridgestone its costs and attorneys' fees in
this action pursuant to 15 U.S.C. 1117 and other applicable laws; and
K.
Other relief as the Court may deem appropriate.
4811 -2580-4577.2
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Respectfully submitted,
RobeliE:Bostoi1('fN13ad~. 9744)
Keith W. Randall (TN Bar No. 30313)
WALLER, LANSDEN, DORTCH & DAVIS, LLP
Nashville City Center
511 Union Street
Suite 2700
Nashville, TN 37219
(615) 244-6380 (phone)
(615) 244-6804 (fax)
bob. boston@wallerlaw.com
heather.hubbard@wallerlaw.com
Douglas A. Rettew (pro hac vice admission forthcoming)
Danny M. A wdeh (pro hac vice admission forthcoming)
Elizabeth D. Ferrill (pro hac vice admission forthcoming)
FINNEGAN, HENDERSON, FARABOW,
GARRETT & DUNNER, L.L.P.
901 New York Avenue N.W.
Washington, D.C. 20001 -4413
(202) 408-4000 (phone)
(202) 408-4400 (fax)
doug.rettew@finnegan.com
danny.awdeh@finnegan.com
elizabeth.ferrill@finnegan.com
Attorneys for Plaintiff
Bridgestone Americas Tire Operations, LLC
4811 -2580-4577.2
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111111111111111111111111111111111111111111111111111111111111111111111111111
USOOD612800S
EXHIBIT A
(12)
United States Design Patent
(lO)
Lundgren et al.
(45)
(54)
TIRE THK>\D
(75)
I.uveutors: Paula R. Lundgren. A.kro11, OH (US);

Ronald W. Tatlock, Tallmadge, OH
(US)
(73)
Assignee:
us 0612,800 s
** Mar. 30,2010
Patent No.:
Date of Patent:
0(>06,929 S '1' 12/2009 Song. ......................... 012579
Bridg:~stun~ Am~ rica~ Tir~ OpHatiun~,
cited by exmlliuer
Primary Exwniner-Stacia Cadmus

(7 4) Altom<')'. Agenl. or Firm-Thomas R. I(jngsbury
(57)
CLAIM
LLC
(*"')
Term:
(21)
AppL No.: 29/350,626
(22)
14
The ornnmeutal design for n tire trend, ns shown nnd

described.
Y~ar~
DESCRIPTION
I'ICr. I i:; a side perspective view of a tire tread showing our
uew design, it beiug, uuderstood thm tile trend panern is
repented tllroug,llout the circulllference of the tire tread, the
oppo:;itc side being the :;arne as that shown:
Nuh 20, 2009
Filed:
Related U.S. Application Data

(ri2)
Division of application No. 29/30:l.l2'1, flied on Feb.

1, 2008.
(51)
(52)
LOC(IJ)Cl ................................................... 12-15

U.S. Cl ...................................................... ))12/579
lli~ld uf Classification s~arch ........ l )'12/51 0 51:l.
D12/539, 543-545, 571,574, 578--580, 'J00-901;
152/209.1-2,209.8-209.18, 209.25-209.28
Sec application lilc for compldc search history.
(5~)
(56)
Rcfennccs Cited
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0457 .4~9
045~,S95
0481.990
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0529.434
0549,163
0571.942
0597.022
S
S
S
S
S
S
S
S
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11:199S Raus .........................

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52002 Warchol el. al. ............

* 5/2002 l<.ayman ....................
'1' 6/2002 l<.ayman ...... ..............
11:2003 Hanna .......................
7 2004 Rober! ......................
'1' J0/2006 J{cgallis ct al ..............
'1 S/2007 :\taus ct al .................
7 200S Song .........................
7 200') Pringirs ...................
012/57')
012'579
012/579
f) 12/57')
012/57')
0 12-'579
012'579
D12/.i7')
f) 12/579
012'579
012/579
012/.17')
012/.i7')
l'l(r. 2 is a front clevational view of the right side thereof. the

opposite side being identical thereof:
FICr. 3 i:; a :;ide clevational vicw of the right :;ide thereof;
FIG. 4 i:; a :;ide clevalional view of the kit :;ide thereof:
I'IG. S is an enlarged fragmental)' fnmt clcvational view
thereof:
I' IG. 6 is a side per:;pcctive view or a :;ceond embodiment. it
beiug 11uderstood thm tile tread pan em is repeated tllro11g,llout
the circtlmfereuce of the tire tread, the opposite side beiug, the
$amc a:; that shown;
FIG. 7 is n tront elevmiounl view of the right side tllereo; the

opposite side being ideuticnl thereof;
FIG. 8 is a side elevmiounl
\ie~>v
of the right side thereot;
FIG. 9 is a side elevmionnl view of the left side thereot; and,

FIG. 10 is nn eularged fragmeutary tront elevntional view
thereof.
I.u FIGS. 1-10, tile brokeuliues definiug, the sidewall, illller
head. and the peripheral boumlal)' between the claimed tire
tread and the sidewall depict envimnmcnlal :;ubjcd mallcr
tlmt forms uo part of the claimed design.
1 Claim, 10 Dra'l\ing Sheets
Case 3:14-cv-02402 Document 1-1 Filed 12/29/14 Page 1 of 11 PageID #: 21
U.S. Patent
Mar. 30~ 2010
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FIG-10
CIVIL COVER SHEET
JS 44 (Rev. 09/11)
The JS 44 civil coversheet and the infonmtion contained herein neither replace nor supplem:nt the filing and service of pleadngs or other papers as required by law, except as pvvideo
by local rules of court. This torm, approved by the Judicial Conference of the United States inSeptember 1974, is required for the use of the Clerk ofCburt for the purpose of tnitiatin
the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
I. (a) PLAINTIFFS
DEFENDANTS
BRIDGESTONE BRANDS, LLC, BRIDGESTONE AMERICAS TIRE

OPERATIONS
OTR Wheel Engineering, Inc.
(b) County of Residence of First Listed Plaintiff ..,D....a..,v"'id...,s..,o...n_.___ _ _ _ __
County of Residence of First Listed Defendant
(EXCEPT IN U.S. PLAINTIFF CASES)

NOTE:
Attorneys (If Known)
(C) Attorneys (F.iJ:m NattJe,.;lt!Jjress, and T'ii..ephone Nu.mer)
Wairer Lansaen uortcn lSt Dav1s, Llt-', 511 umon Street, Suite 2700,
Nashville, Tennessee 37219 (615) 244-6380
II. BASIS OF JURISDICTION
U.S. Government
Plaintiff
U.S. Government
Defendant
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
CONTRACT
V. ORIGIN
Original
Proceeding
Incorporated and Principal Place

of Business In Another State
Citizen or Subject of a
Foreign Nation
PRISONER PETITIONS
a 5 10 Motions to Vacate
Sentence
Habeas Corpus:
a 530 General
a 535 Death Penalty
a 540 Mandanms & Other
a 550 Civil Rights
a 555 Prison Condition
a 560 Civil Detainee
Conditions of
Confinement
2 Removed from
State Court
a
a
625 Dmg Related Seizure

of Property 2 I USC 881
690 Other
422 Appeal 28 USC !58

423 Withdrawal
28 usc !57
PROPERlY RICH I'S

820 Copyrights
830 Patent
) (840 Trademark
a
a
a
a
a
a
a
a
LABOR
7 10 Fair Labor Standards
Act
720 Labor/Mgmt. Relations
740 Railway Labor Act
751 Family and Medical
Leave Act
790 Other Labor Litigation
791 Empl. Ret. Inc.
Security Act
SOriA
a 861 HIA (!395ft)
a 862 Black Lung (923)
a 863 DIWC/DIWW (405(g))
0 864 SSID Title XVI
a 865 RSI (405(g))
a
a
a
a
a
FEDERAL TAX SUJTS

870 Taxes (U.S. Plaintiff
or Defendant)
8711RS- Third Party
26 usc 7609
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
a
375 False Claims Act

400 State Reapportionment
410 Antitrust
430 Banks and Banking
450 Commerce
460 Deportation
4 70 Racketeer Influenced and
Corrupt Organizations
480 Consumer Credit
490 Cable/Sat TV
850 Securities/Commodities/
Exchange
890 Other Statutory Actions
891 Agricultural Acts
893 Environmental Matters
895 Freedom of Infonnation
Act
896 Arbitration
899 Administrative Procedure
Act/Review or Appeal of
Agency Decision
950 Constitutionality of
State Statutes
IMMIGRATION
462 Naturalization Application
463 Habeas Corpus Alien Detainee
(Prisoner Petition)
465 Otl1er Immigration
Actions
.
0 4 Remstated or 0
Reopened
a
a
)(5
OTHER STAT OTES
BANKRUPTCY
FORFEITURE/PENAL1Y
PERSONAL INJURY
a 365 Personal Injury Product Liability
a 367 Health Care/
Pharmaceutical
Personal Injury
Product Liability
a 368 Asbestos Personal
Injury Product
Liability
PERSONAL PROPERTY
a 370 Other Fraud
a 371 Truth in Lending
a 380 Other Personal
Property Damage
a 385 Property Damage
Product Liability
and One Boxfor Defendant)

PTF
DEF
Incorporated or Principal Place
a 4 a 4
of Business In This State
DEF
a I
Citizen of Another State
(Place an "X" in One Box Only)

TORTS
(Place on "X " in One Box Only)
(For Diversity Cases On/)~

tiJI'F
Citizen of This State
~
Diversity
(Indicate Citizenship ofParties in Item III)
I I 0 Insurance
PERSONAL INJURY
I20 Marine
a 31 0 Airplane
I 30 Miller Act
a 315 Airplane Product
140 Negotiable Instrument
Liability
150 Recovery of Overpayment a 320 Assault, Libel &
& Enforcement of Judgment
Slander
151 Medicare Act
a 330 Federal Employers'
152 Recove1y of Defaulted
Liability
Student Loans
a 340 Marine
0 345 Marine Product
(Excl. Veterans)
153 Recovery of Overpayment
Liability
of Veteran's Benefits
a 350 Motor Vehicle
160 Stockholders' Suits
a 355 Motor Vehicle
190 Other Contract
Product Liability
195 Contract Product Liability a 360 Other Personal
196 Franchise
Injury
a 362 Personal Injury Med. Malp_ractice
REAL PROPERlY
CIVIL RIGHTS
210 Land Condemnation
a 440 Otl1er Civil Rights
220 Foreclosure
a 441 Voting
a 442 Employment
230 Rent Lease & Ejectment
240 To11s to Land
a 443 Housing/
245 Tort Product Liability
Accommodations
a 445 Alner. w/Disabilities.
290 All Other Real Property
Employment
a 446 Alner. w/Disabilities
Other
a 448 Education
~I
III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an "X" in one Boxfor Plaint!l
3 Federal Question
(US. Government Not a Party)
IV NATURE OF SUIT
L
(Place on 'X" In One Box OnM
_,_F_,_,Io. ,y,_,d,._________
(IN U.S. PLAINTIFF CASES ONLY)

IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.
Transferred from
5 another district
etition under federal, state and/or common Ia
VII. REQUESTED IN
COMPLAINT:
VIII. RELATED CASE(S)
IF ANY
CHECK YES only if demanded in complaint:

JURY DEMAND:
~Yes
0 No
(See lnstruci/ons):
DOCKET NUMBER
JUDGE
DATE
RECEIPT#
AMOUNT
APPLYING IFP
JUDGE
MAG. JUDGE
JS 44 Reverse (Rev. 09111)
INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44

Authority For Civil Cover Sheet
The JS 44 civil cover sheet and the information contained herein neither replaces nor supplerrents the filings and service of pleading or other papers as requin
by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the
use of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of Court for each civil
complaint filed. The attorney tiling a case should complete the form as follows:
I.
(a) Plaintiffs-Defendants. Enter narres (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a governrrent agency, use on
the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and then the official, giv
both name and title.
(b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the
time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land condemnatio
cases, the county of residence of the "defendant" is the location of the tract of land involved.)
(c) Attorneys. Enter the firm name, address, telephone number, and attorney of record. Ifthere are several attorneys, list them on an attachment, noting
in this section "(see attachment)".
II.
Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.CP., which requires thatjurisdictions be shown in pleadings. Place an "X" in on
of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.
United States plaintiff. (I) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.
United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box.
Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdicti on arises under the Constitution of the United States, an amendment to the
Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is aparty, the U.S. plaintiff or defendant code takes precedence, and bo
I or 2 should be marked.
Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the citizenship of
the different parties must be checked. (See Section III below; federal question actions take precedence over diversity cases.)
III.
Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversty of citizenship was indicated above. Mark this sect
for each principal party.
Nature of Suit. Place an "X" in the appropriate box. If the nature of suit cannot be determined, be sure the cause of action, in Section VI below, is
IV.
sufficient to enable the deputy clerk or the statistical clerks in the Administrative Office to determine the nature of suit. If the cause fits more than one nature o1
suit, select the most definitive.
V.
Origin . Place an "X" in one of the seven boxes.
Original Proceedings. (I) Cases which originate in the United States district courts.
Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28U.S.C., Section 1441. When the petitio
for removal is granted, check this box.
Remanded from Appellate Court. (3) Check this box for cases remanded to the district court for further action. Use the date of remand as the filing date.
Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date.
Transferred from Another District. (5) For cases transferred under Title 28 U.S.C. Section 1404(a). Do not use this for within district transfers or multidistrict
litigation transfers.
Multidistrict Litigation. (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C. Section 1407. When thi5
box is checked, do not check (5) above.
Appeal to District Judge from Magistrate Judgment. (7) Check this box for an appeal from a magistrate judge's decision.
VI.
Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause Do not cite jurisdictional statut
unless diversity.
Example:
U.S. Civil Statute: 47 USC 553
Brief Description: Unauthorized reception of cable service
VII.
Requested in Complaint. Class Action. Place an "X" in this box if you are filing a class action under Rule 23, F.R.Cv.P.
Demand. In this space enter the dollar amount (in thousands of dollars) being demanded or indicate other demand such as a preliminary injunction.
Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.
VIII. Related Cases. This section of the JS 44 is used to reference related pending cases, if any. If there are related pending cases, insert the docket number
and the corresponding judge names for such cases.
Date and Attorney Signature. Date and sign the civil cover sheet.

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FOR THE MIDDLE DISTRICT OF TENNESSEE

Bridgestone Brands, LLC,

Bridgestone Americas Tire Operations, LLC,

Civil Action No: ---------

JURY TRIAL DEMANDED

COMPLAINT FOR TRADEMARK INFRINGEMENT,

Case 3:14-cv-02402 Document 1 Filed 12/29/14 Page 1 of 20 PageID #: 1

Plaintiff Bridgestone Brands, LLC is a Delaware I imited liability company with a

business address at 535 Maniot Drive, Nashville, Tennessee 37214.

Plaintiff Bridgestone Americas Tire Operation, LLC is a Delaware limited

Defendant OTR Wheel Engineering, Inc. is a Georgia corporation with an address

at 6 Riverside Industrial Park, P.O. Box 1853, Rome, GA 30162.

purposefully availed itself of the privilege of conducting business in Tennessee. Defendant

Case 3:14-cv-02402 Document 1 Filed 12/29/14 Page 2 of 20 PageID #: 2

distributes and sells infringing BLACKSTONE tires in Tennessee (including Nashville,

Today, Bridgestone develops, manufactures, and markets BRIDGESTONE and

Case 3:14-cv-02402 Document 1 Filed 12/29/14 Page 3 of 20 PageID #: 3

Bridgestone has continuously used the BRIDGESTONE and FIRESTONE

Through itself or licensees, the BRIDGESTONE and FIRESTONE marks/names

Case 3:14-cv-02402 Document 1 Filed 12/29/14 Page 4 of 20 PageID #: 4

The BRIDGESTONE mark is covered by the following incontestable U.S. federal

trademark registrations (among others):

BRIDGESTONE'S SALES AND PROMOTIONAL ACTIVITIES

BRIDGESTONE and FIRESTONE marks in the U.S.

Bridgestone's tires are sold through approximately 2,200 company-owned stores

Bridgestone spends tens of millions of dollars annually advertising, marketing,

been promoted through nationally-distributed general-interest magazines such as Fortune,

Additionally, Bridgestone's corporate-owned stores and independent tire

The BRIDGESTONE and FIRESTONE marks/names have been regularly

featured in national and local television, cable, and radio advettisements.

For example, in 2012 Bridgestone launched its successful "Time to Perfmm"

television advertising campaign, comprised of a series of commercials featuring high-profile

Case 3:14-cv-02402 Document 1 Filed 12/29/14 Page 6 of 20 PageID #: 6

In 2012, Bridgestone also launched a nationwide television ad campaign (excerpts

Case 3:14-cv-02402 Document 1 Filed 12/29/14 Page 7 of 20 PageID #: 7

Starting in 2008, commercials featuring the BRIDGESTONE mark/name aired

program in U.S. history when it aired.

The BRIDGESTONE and FIRESTONE marks/names have further been promoted

through Bridgestone's sponsorship of a number of high-profile sports leagues, associations, and

Case 3:14-cv-02402 Document 1 Filed 12/29/14 Page 8 of 20 PageID #: 8

The BRIDGESTONE and FIRESTONE marks/names have been promoted

In 2010, Nashville's sports and entertainment venue (depicted below) was

renamed BRIDGESTONE ARENA.

The BRIDGESTONE ARENA venue is home to the

The BRIDGESTONE and FIRESTONE marks/names have also been promoted

online through various company websites, popular social-networking websites (including

In addition to its own substantial advertising and promotional activities,

As a result of the distinctive nature and inherent strength of the BRIDGESTONE

In Bridgestone/Firestone North American Tire, LLC and BFS Brands, LLC v.

BRIDGESTONE'S DURAFORCE MH TIRES

Within its expansive product line, Bridgestone offers various Off-The-Road

("OTR") tires for commercial, agricultural, and other applications.

industry's leading tires for material-handler equipment.

BRIDGESTONE'S DESIGN PATENT

assignment from inventors Paula R. Lundgren and Ronald W. Tatlock.

Case 3:14-cv-02402 Document 1 Filed 12/29/14 Page 11 of 20 PageID #: 11

The '800 patent is valid.

Like Bridgestone, Defendant is a tire company.

With full knowledge of Bridgestone's famous BRIDGESTONE and FIRESTONE

Defendant's BLACKSTONE and ROADSTONE tires are intended for off-the-

road uses and applications.

below next to Bridgestone' s patented tread design):

Bridgestone's Patented Tread Design

Case 3:14-cv-02402 Document 1 Filed 12/29/14 Page 12 of 20 PageID #: 12

Bridgestone v. OTR Wheel Eng'g - Complaint

Bridgestone v. OTR Wheel Eng'g - Complaint