You are on page 1of 12

1

7 IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON


IN AND FOR THE COUNTY OF KING
8
BLACK SPOT LLC d/b/a THE KRAKEN BAR
9
& LOUNGE (a Washington limited liability Civil Action No.
10 company based in King County, WA).
COMPLAINT FOR:
Plaintiff,
11
1) TRADEMARK INFRINGEMENT
12 v. 2) DECLARATORY JUDGMENT
3) UNJUST ENRICHMENT
13
SEATTLE HOCKEY PARTNERS LLC (a 4) CONSUMER PROTECTION ACT
14 Delaware limited liability company based in King VIOLATION
County, WA) 5) CONVERSION
15 6) TORTIOUS INTERFERENCE
Defendant.
16

17 The Plaintiffs, Black Spot LLC d/b/a The Kraken Bar & Lounge a Washington limited
18 liability company (hereinafter “The Kraken Bar”) alleges the following facts and states the
19 following causes of action:
20 PARTIES
21 1. The Kraken Bar is a limited liability company under the laws of the State of
22 Washington, authorized to do business in the State of Washington and having a principal place of
23 business at 5252 University Way NE Seattle, WA 98105. Each member of The Kraken Bar is a
24 citizen of Washington State.
25 2. Defendant, Seattle Hockey Partners LLC (“SHP”) is a limited liability company
26 organized under the laws of Delaware and doing business in King County from its company
27
COMPLAINT FOR TRADEMARK INFRINGEMENT, DECLARATORY
JUDGMENT, UNJUST ENRICHMENT, CONSUMER PROTECTION
VIOLATION, CONVERSION, AND TORTIOUS INTERFERENCE - 1
1 headquarters located at 16 W Harrison Street, Seattle, WA 98119-4121. On information and
2 believe, at least one of the members of SHP is a citizen of Washington State.
3 JURISDICTION AND VENUE
4 3. This Court has jurisdiction over the parties and over the subject matter of this
5 dispute and venue is proper in this court pursuant to RCW 4.12.025 as the matters giving rise to
6 this complaint occurred in King County, all parties transact business in King County, and all parties
7 have an office for the transaction of business in King County.
8 FACTS
9 (The Kraken Bar’s History and Brand Awareness)
10 4. The Kraken Bar was founded in 2011 by Katherine (“Kat”) and Daniel Colley along
11 with William Knupp. The Kraken Bar is one of Seattle’s foremost “dive bars,” known throughout
12 the region as a place where one can get an affordable meal and drinks and watch live punk-rock
13 and metal shows of national and international renown.
14 5. Development has changed retail and restaurant services in many Seattle
15 neighborhoods, including the University District. The Kraken Bar remains one of the few dive bars
16 left in the neighborhood and region. Its patrons are loyal. Many cannot stand the thought of losing
17 The Kraken Bar to a corporate-sponsored bar, devoid of personality and consumed by an investor
18 mandate to extract premium prices.
19 6. Over the years, The Kraken Bar has hosted some of world’s most memorable punk-
20 rock and metal acts, including Get Dead, Iron Chic, Bad Cop/Bad Cop, Spanish Love Songs,
21 PEARS, Mike Herrera (MxPx), Noi!se, Brendan Kelly, Hudson Falcons, HIMSA, The Vibrators
22 (UK), and The Drowns, to name a few. The Kraken Bar has also hosted prominent local acts, many
23 of whom now enjoy national and international notoriety, including Kids on Fire, Ol’ Doris, Street
24 Jail, Heck Yes, Three Fingers, Mangy, The Subjunctives, Four Lights, Cosgrove, Skelator, and
25 more.
26 7. The Colleys are husband and wife. They met in 2006 and fell in love at The Kraken
27 Bar when the establishment was known as the “Galway Arms.” The Galway Arms was an Irish-
COMPLAINT FOR TRADEMARK INFRINGEMENT, DECLARATORY
JUDGMENT, UNJUST ENRICHMENT, CONSUMER PROTECTION
VIOLATION, CONVERSION, AND TORTIOUS INTERFERENCE - 2
1 themed pub and by 2006, both Daniel Colley and William Knupp had worked there for some time.
2 Mr. Knupp started working at the Galway Arms in 1999 and Mr. Colley was hired in 2003.
3 8. By the middle of 2011, the Galway Arms, like so many other small Seattle bars,
4 was set to close. Rather than lose their beloved local bar and music venue, the Colleys, who were
5 then engaged to be married, and Mr. Knupp, pooled their life-savings to lease the space. On New
6 Year’s Eve, 2011, they opened The Kraken Bar to dozens of rabid punk-rockers who collectively
7 welcomed 2012 to the discordant melodies of the punk band Success.
8 9. Through consistent and continuous operation since 2011, The Kraken Bar built a
9 reputation among patrons, bands, and promoters of live music, particularly those within the metal
10 and punk-rock scene.
11 10. The Kraken Bar is consistently mentioned by local media as one of Seattle’s top
12 bars and music venues, including by The Stranger and King5 News.
13 11. In October 2018, King5’s Evening Magazine featured The Kraken Bar as a “Five-
14 Star Dive Bar,” including interviews from patrons, an explanation about The Kraken Bar’s history,
15 the origin of The Kraken Bar’s name, and the bar’s affiliation with Seattle’s lively punk-rock and
16 metal scenes. (See https://www.king5.com/article/news/the-kraken-bar-lounge-five-star-dive-
17 bars/281-607772708; see also https://www.youtube.com/watch?v=yRmC2Cu8TJs.)
18 12. The Kraken Bar is consistently rated highly by patrons in terms of atmosphere,
19 service, quality, and price. One reviewer on Yelp had this to say about The Kraken Bar: “This is
20 absolutely one of my favorite places in Seattle. I’ve been going here for years. They have great
21 food, great staff, great shows, and a killer pinball room! What’s not to love?? Not to mention the
22 owners are caring and attentive. I’d absolutely recommend this place.”
23 13. The Kraken Bar advertises and markets its services on social media, including on
24 Facebook, Pinterest, and Instagram. (See Facebook: https://www.facebook.com/KrakenBarSeattle
25 Pinterest: https://www.instagram.com/explore/tags/krakenseattle/ Instagram: the.kraken.seattle
26 and #krakenseattle.)
27
COMPLAINT FOR TRADEMARK INFRINGEMENT, DECLARATORY
JUDGMENT, UNJUST ENRICHMENT, CONSUMER PROTECTION
VIOLATION, CONVERSION, AND TORTIOUS INTERFERENCE - 3
1 14. Over the years The Kraken Bar has sold approximately $3.5M in food, drinks,
2 merchandise, arcade and related services and invested financially to promote and improve its name
3 and marks. The Kraken Bar’s owners have also invested hundreds of hours in sweat-equity to build
4 a viable business around the name and brand.
5 15. The names and marks used by The Kraken Bar over the years include THE
6 KRAKEN, THE KRAKEN BAR, THE KRAKEN BAR & LOUNGE, THE KRAKEN BAR AND
7 LOUNGE, KRAKEN BAR AND LOUNGE, #KRAKENSEATTLE and similar names and marks,
8 all including the dominant word “kraken” (collectively referred to herein as “The Kraken Bar
9 Trademarks”).
10 16. Owner Daniel Colley came up with the idea to build a business and name around
11 the word “kraken” in 2011 based on his accumulation of nautical- and pirate-themed articles used
12 to decorate the establishment and since that time, the word “kraken” has permeated every aspect
13 of the bar’s signage, advertising, and marketing.
14 17. Since 2011, The Kraken Bar Trademarks have become associated with The Kraken
15 Bar’s high-quality bar, restaurant, and live-entertainment services. Additionally, The Kraken Bar
16 Trademarks have been used by The Kraken Bar to promote its good and services on apparel and
17 consumer goods, including without limitation, t-shirts, baseball tees, tank tops, sweatshirts,
18 stickers, buttons, and the like.
19 18. Since 2011, The Kraken Bar Trademarks have served as a symbol of The Kraken
20 Bar’s goods and services and as such, they are used by The Kraken Bar to identify the source of
21 The Kraken Bar’s goods and services.
22 (Infringing Uses of The Kraken Bar Trademarks by SHP)
23 19. In the middle of a global pandemic, on or around July 23, 2020, when The Kraken
24 Bar (like most other bars and live-music venues around the world) was struggling to stay alive,
25 SHP announced that it would name its new, billionaire-backed NHL expansion hockey team, “The
26 Seattle Kraken.” Almost immediately, The Kraken Bar felt threatened by SHP’s announcement
27
COMPLAINT FOR TRADEMARK INFRINGEMENT, DECLARATORY
JUDGMENT, UNJUST ENRICHMENT, CONSUMER PROTECTION
VIOLATION, CONVERSION, AND TORTIOUS INTERFERENCE - 4
1 given the disparity in size and resources between SHP and The Kraken Bar, but it was unclear at
2 the time whether there was anything The Kraken Bar could or should do.
3 20. Shortly after SHP announced that it would call its new hockey team “The Seattle
4 Kraken,” The Kraken Bar observed new patrons visiting the bar in hockey-themed attire and
5 suggesting that The Kraken Bar could or would become their new “hockey bar.”
6 21. That The Kraken Bar would or should become a “hockey bar” or a sports bar of
7 any kind was anathema to The Kraken Bar and its regular patrons. The Kraken Bar’s regular
8 patrons frequented the bar precisely because it was a dive-bar, associated with affordable food and
9 drinks as well as cutting edge live music performances by well-known punk and metal bands.
10 22. What at first appeared to be a mere annoyance in July 2020, SHP’s use and adoption
11 of the name “The Seattle Kraken” became a genuine source for consumer confusion when SHP
12 flooded the market with kraken-themed advertising, direct-to-consumer marketing, and
13 merchandise starting in late 2020 and increasing in intensity throughout the first quarter of 2021.
14 At this time, The Kraken Bar started observing instances of actual consumer confusion by
15 customers or potential customers who genuinely believed that The Kraken Bar was associated with
16 or sponsored by SHP.
17 23. The Kraken Bar noticed that its social media and internet presence had lost
18 significant ground to SHP and that company’s blitzkrieg advertising campaigns. Where a Seattle
19 internet or social media search for The Kraken Bar once listed The Kraken Bar at the top of any
20 list of search results, The Kraken Bar had now dropped precipitously to a location only the most
21 dutiful or mindful consumer could find. Additionally, errant social media posts of hockey fans clad
22 with SHP-sponsored merchandise began appearing online in association with The Kraken Bar
23 Trademarks, such as #KRAKENSEATTLE.
24 24. Then, on April 8, 2020, SHP made an announcement sure to ruin The Kraken Bar
25 and its near decade-old, cherished image and reputation as one of Seattle’s last dive bars: SHP
26 announced that it was opening “The Kraken Bar & Grill” at SHP’s $80 million Northgate training
27 facility, about three miles away from The Kraken Bar.
COMPLAINT FOR TRADEMARK INFRINGEMENT, DECLARATORY
JUDGMENT, UNJUST ENRICHMENT, CONSUMER PROTECTION
VIOLATION, CONVERSION, AND TORTIOUS INTERFERENCE - 5
1 25. SHP’s planned 4,600 square-foot “Kraken Bar & Grill” will seat 300 and will
2 overlook the team’s two main rinks, including the main sheet of ice used by the team. The new bar
3 plans 17 TVs inside, with views of the 15’ x 25’ LED screen at the end of the main rink. Its walls
4 will be adorned with retro hockey jerseys. The planned bar will also have a “private events section”
5 where up to 40 VIPs can dine while watching the team practice.
6 26. SHP has already extensively marketed and advertised “The Kraken Bar & Grill”
7 and plans to open as soon as Labor Day, 2021. SHP’s new bar will be run by well-known Seattle
8 restaurateur, Mick McHugh, who promises on “making the Kraken Bar & Grill as popular with
9 Hockey fans as F.X. McRory’s was with supporters of other Seattle teams.” (Seattle Times, April
10 19, 2021.) McHugh is reportedly “busy thinking up ideas for the restaurant — such as live on-air
11 shows hosted remotely there by KJR-AM (950), the team’s partner — and how to keep fans
12 coming in.” (Id.)
13 27. SHP’s pre-launch advertising for The Kraken Bar & Grill has already damaged The
14 Kraken Bar by calling into question The Kraken Bar’s ability to maintain its Seattle, punk-rock,
15 dive-bar image among existing patrons and music-promoters and portends certain doom for The
16 Kraken Bar’s image going forward.
17 CAUSES OF ACTION
18 Count One: Common Law Trademark Infringement
19 28. Plaintiffs incorporate all factual allegations in the previous paragraphs as if set forth
20 herein.
21 29. The Kraken Bar Trademarks are entitled to protection because they are inherently
22 distinctive of The Kraken Bar’s goods and services and because they were used by The Kraken
23 Bar before SHP adopted a confusingly similar name in July 2020.
24 30. The use by SHP of the names and marks “The Kraken Bar & Grill” and “The Seattle
25 Kraken” in association with bar and restaurant services, live entertainment services, and related
26 merchandise such as apparel, including hats, shirts, hoodies, and similar merchandise, has caused,
27 and/or is likely to cause confusion, mistake, and deception among consumers.
COMPLAINT FOR TRADEMARK INFRINGEMENT, DECLARATORY
JUDGMENT, UNJUST ENRICHMENT, CONSUMER PROTECTION
VIOLATION, CONVERSION, AND TORTIOUS INTERFERENCE - 6
1 31. On information and belief, SHP adopted the names and marks “The Kraken Bar &
2 Grill” and “The Seattle Kraken” knowing about The Kraken Bar’s trademark rights and knowing
3 that SHP’s extensive use of the names and marks “The Kraken Bar & Grill” and “The Seattle
4 Kraken” would have devastating impacts on The Kraken Bar’s reputation and image as one of
5 Seattle’s last dive bars.
6 32. Immediate corrective action must be taken by SHP to protect The Kraken Bar’s
7 valuable reputation as one of Seattle’s last dive bars, including but not limited to ceasing all use
8 of the name and mark “The Kraken Bar & Grill” or any other name for SHP’s planned restaurant
9 incorporating the word “kraken” as well as compensating The Kraken Bar for past and future
10 damage done by SHP’s decision to adopt, use, and extensively promote the mark “The Seattle
11 Kraken.”
12 33. SHP’s use of the names and marks “The Kraken Bar & Grill” and “The Seattle
13 Kraken” have damaged The Kraken Bar in an amount to be proven at trial and shall include an
14 amount of money necessary for corrective advertising so that The Kraken Bar may reclaim its
15 reputation as one of Seattle’s last dive bars.
16 34. Unless enjoined by this Court, SHP’s planned opening of “The Kraken Bar & Grill”
17 will irreparably harm The Kraken Bar’s image and reputation as one of Seattle’s last dive bars.
18 35. Unless enjoined by this Court, SHP’s continued use of the name and mark “The
19 Seattle Kraken” in association with restaurant, live entertainment services, and related
20 merchandise, will irreparably harm The Kraken Bar’s image and reputation as one of Seattle’s last
21 dive bars.
22 36. SHP’s adoption of names and marks confusingly similar to The Kraken Bar
23 Trademarks has caused damage to The Kraken Bar at least equivalent to the amount of money
24 necessary to engage in corrective advertising and at least equivalent to the amount of past revenue
25 associated with The Kraken Bar Trademarks, which amount equals approximately $3.5 million
26 and is a good and reasonable approximation of the lost goodwill associated with The Kraken Bar
27 Trademarks.
COMPLAINT FOR TRADEMARK INFRINGEMENT, DECLARATORY
JUDGMENT, UNJUST ENRICHMENT, CONSUMER PROTECTION
VIOLATION, CONVERSION, AND TORTIOUS INTERFERENCE - 7
1 Count Two: Declaratory Judgment
2 37. Plaintiffs incorporate all factual allegations in the previous paragraphs as if set forth
3 herein.
4 38. An actual and justiciable controversy exists between SHP and The Kraken Bar
5 concerning rights to the name and marks “The Kraken Bar & Grill,” “The Seattle Kraken,” and
6 any other names and marks incorporating the word “kraken.” Specifically, a controversy exists as
7 to harm that will be caused by SHP’s planned use of those names in association with restaurant
8 and live entertainment services as well as on related merchandise promoting SHP’s restaurant and
9 live entertainment services.
10 39. Given the existing controversy regarding SHP’s planned use of the name and marks
11 “The Kraken Bar & Grill,” “The Seattle Kraken,” and any other names and marks incorporating
12 the word “kraken” in association with restaurant and live entertainment services as well as on
13 related merchandise promoting SHP’s restaurant and live entertainment services, the Court should
14 declare the rights of the parties and propose limitations on SHP’s planned use in a manner that
15 protects the image and reputation of The Kraken Bar as one of Seattle’s last dive bars pursuant to
16 RCW § 7.24.010 et. seq.
17 40. On information and belief, SHP’s planned use of “The Kraken Bar & Grill,” “The
18 Seattle Kraken,” and any other names and mark incorporating the word “kraken” in association
19 with restaurant and live entertainment services as well as on related merchandise promoting SHP’s
20 restaurant and live entertainment services is likely to cause confusion among consumers and
21 should be enjoined by this Court.
22 Count Three: Unjust Enrichment
23 41. Plaintiffs incorporate all factual allegations in the previous paragraphs as if set forth
24 herein.
25 42. SHP has obtained a benefit from the use of names and mark confusingly similar to
26 The Kraken Bar Trademarks and SHP’s use of these names and marks has caused harm to The
27 Kraken Bar. On information and belief, SHP knew about The Kraken Bar Trademarks, were
COMPLAINT FOR TRADEMARK INFRINGEMENT, DECLARATORY
JUDGMENT, UNJUST ENRICHMENT, CONSUMER PROTECTION
VIOLATION, CONVERSION, AND TORTIOUS INTERFERENCE - 8
1 willfully blind about the existence of The Kraken Bar Trademarks, or should have known about
2 The Kraken Bar Trademarks had SHP exercised reasonable diligence to investigate prior users.
3 43. Under the circumstances of this case, given the harm caused by SHP, the knowledge
4 they had of The Kraken Bar Trademarks or should have had about The Kraken Bar Trademarks,
5 and the benefits obtained by SHP through the use of names and marks confusingly similar to The
6 Kraken Bar Trademarks, it would be unjust to allow SHP to retain any benefits proximately caused
7 by SHP’s use of names and marks confusingly similar to The Kraken Bar Trademarks.
8 Count Four: Consumer Protection Act Violation
9 44. Plaintiffs incorporate all factual allegations in the previous paragraphs as if set forth
10 herein.
11 45. SHP’s adoption of names and marks confusingly similar to The Kraken Bar
12 Trademarks is a deceptive act or practice within the meaning of RCW § 19.86.020. The deceptive
13 act or practice by SHP occurred in trade or commerce and it impacts the public interest by causing
14 confusion among consumers.
15 46. SHP’s adoption of names and marks confusingly similar to The Kraken Bar
16 Trademarks has caused damage to The Kraken Bar in the form of damaged reputation and
17 confusion in the marketplace.
18 47. SHP’s adoption of names and marks confusingly similar to The Kraken Bar
19 Trademarks has caused damage to The Kraken Bar at least equivalent to the amount of money
20 necessary to engage in corrective advertising and at least equivalent to the amount of past revenue
21 associated with The Kraken Bar Trademarks, which amount equals approximately $3.5 million
22 and is a good and reasonable approximation of the lost goodwill associated with The Kraken Bar
23 Trademarks.
24 48. On information and belief, SHP’s CPA violation as alleged herein was knowing
25 and willful and without regard to the harm caused to The Kraken Bar.
26 //
27 //
COMPLAINT FOR TRADEMARK INFRINGEMENT, DECLARATORY
JUDGMENT, UNJUST ENRICHMENT, CONSUMER PROTECTION
VIOLATION, CONVERSION, AND TORTIOUS INTERFERENCE - 9
1 Count Five: Common Law Conversion
2 49. Plaintiffs incorporate all factual allegations in the previous paragraphs as if set forth
3 herein.
4 50. The Kraken Bar owns valuable intellectual property rights in and to The Kraken
5 Bar Trademarks based on The Kraken Bar’s consistent and long-term use of The Kraken Bar
6 Trademarks since well before SHP adopted confusingly similar names and marks including the
7 word “kraken.”
8 51. SHP’s adoption of names and marks confusingly similar to The Kraken Bar
9 Trademarks, with knowledge of The Kraken Bar Trademarks, or under circumstances reasonably
10 required by law to charge SHP with constructive knowledge of The Kraken Bar Trademarks, and
11 with intent to exercise control or dominion over The Kraken Bar Trademarks, was a wrongful and
12 intentional act by SHP, which deprived The Kraken Bar from full use and enjoyment of The
13 Kraken Bar Trademarks.
14 52. SHP’s adoption of names and marks confusingly similar to The Kraken Bar
15 Trademarks has caused damage to The Kraken Bar at least equivalent to the amount of money
16 necessary to engage in corrective advertising and at least equivalent to the amount of past revenue
17 associated with The Kraken Bar Trademarks, which amount equals approximately $3.5 million
18 and is a good and reasonable approximation of the lost goodwill associated with The Kraken Bar
19 Trademarks.
20 Count Six: Tortious Interference
21 53. Plaintiffs incorporate all factual allegations in the previous paragraphs as if set forth
22 herein.
23 54. The Kraken Bar has or had a valid economic expectancy in further use and
24 enjoyment of The Kraken Bar Trademarks. As alleged herein, the Kraken Bar Trademarks had
25 become known by patrons, booking agents, and music performers and served as a reliable indicator
26 and valuable sales tool based on accumulated goodwill since 2011 worth approximately $3.5
27 million in terms of past revenue associated with The Kraken Bar Trademarks.
COMPLAINT FOR TRADEMARK INFRINGEMENT, DECLARATORY
JUDGMENT, UNJUST ENRICHMENT, CONSUMER PROTECTION
VIOLATION, CONVERSION, AND TORTIOUS INTERFERENCE - 10
1 55. SHP intentionally interfered with The Kraken Bar’s valid expectation of future
2 revenue associated with planned operations in association with The Kraken Bar Trademarks.
3 56. SHP’s interference was wrongful and willful as alleged herein.
4 57. SHP’s adoption of names and marks confusingly similar to The Kraken Bar
5 Trademarks has caused damage to The Kraken Bar at least equivalent to the amount of money
6 necessary to engage in corrective advertising and at least equivalent to the amount of past revenue
7 associated with The Kraken Bar Trademarks, which amount equals approximately $3.5 million
8 and is a good and reasonable approximation of the lost goodwill associated with The Kraken Bar
9 Trademarks.
10 WHEREFORE, The Kraken Bar prays for judgment as follows:
11 A. Judgment against SHP and against any other party acting in concert with SHP in an
12 amount necessary to engage in corrective advertising and at least equivalent to the amount of past
13 revenue associated with The Kraken Bar Trademarks, which amount equals approximately $3.5
14 million and is a good and reasonable approximation of the lost goodwill associated with The
15 Kraken Bar Trademarks;
16 B. Injunctive relief in the form of an order prohibiting SHP and any other party acting
17 in concert with SHP from using names and marks confusingly similar to The Kraken Bar
18 Trademarks, which injunctive relief should include immediate corrective action by SHP and any
19 other party working in concert with SHP to protect The Kraken Bar’s valuable reputation as one
20 of Seattle’s last dive bars, including but not limited to ceasing all use of the names and marks “The
21 Kraken Bar & Grill,” “The Seattle Kraken,” and any other names and marks incorporating the
22 word “kraken” which are confusingly similar to The Kraken Bar Trademarks when used in
23 association with bar and restaurant services, live entertainment services, and related merchandise
24 such as apparel, including hats, shirts, hoodies, pint-glasses, and similar merchandise;
25 C. Judgment against SHP and any other party acting in concert with SHP, awarding
26 The Kraken Bar its reasonable attorney’s fees and costs pursuant to RCW 19.86.090 or any other
27 applicable law or rule;
COMPLAINT FOR TRADEMARK INFRINGEMENT, DECLARATORY
JUDGMENT, UNJUST ENRICHMENT, CONSUMER PROTECTION
VIOLATION, CONVERSION, AND TORTIOUS INTERFERENCE - 11
1 D. Judgment against SHP and any other party acting in concert with SHP, awarding
2 The Kraken Bar enhanced or treble damages to deter future instances of willful or intentional
3 misconduct;
4 E. Judgment against SHP and any other party acting in concert with SHP, awarding
5 The Kraken Bar pre-judgment and post-judgment interest; and
6 F. Such other and further relief that the Court deems just and proper
7 DATED this 22nd day of April, 2021.
8
PLLC
LOWE GRAHAM JONES
9
10 s/Mark P. Walters
Mark P. Walters, WSBA No. 30819
11 Walters@LoweGrahamJones.com
LOWE GRAHAM JONES PLLC
12 701 Fifth Avenue, Suite 4800
Seattle, Washington 98104
13 T: 206.381.3300
14 F: 206.381.3301

15 Attorneys for Plaintiff Black Spot LLC d/b/a


The Kraken Bar & Lounge
16

17

18

19

20

21

22

23

24

25

26
27
COMPLAINT FOR TRADEMARK INFRINGEMENT, DECLARATORY
JUDGMENT, UNJUST ENRICHMENT, CONSUMER PROTECTION
VIOLATION, CONVERSION, AND TORTIOUS INTERFERENCE - 12