Case 8:18-cv Document 1 Filed 08/07/18 Page 1 of 26 Page ID #:1

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1 Case :-cv-0 Document Filed 0/0/ Page of Page ID #: 0 0 Michael K. Friedland (SBN, michael.friedland@knobbe.com Lauren Keller Katzenellenbogen (SBN,0 lauren.katzenellenbogen@knobbe.com Ali S. Razai (SBN, ali.razai@knobbe.com James F. Smith (SBN 0, KNOBBE, MARTENS, OLSON & BEAR, LLP 00 Main Street, Fourteenth Floor Irvine, CA Telephone: ( 0-00 Facsimile: ( 0-0 Attorneys for Plaintiff OAKLEY, INC. IN THE UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA OAKLEY, INC., a Washington corporation, v. Plaintiff, WHOLESALE IN MOTION GROUP INC. d/b/a ALL TIME TRADING CO. d/b/a BLUE STAR EMPIRE, a New York corporation, Defendant. Civil Action No. :-cv- COMPLAINT FOR PATENT INFRINGEMENT, COUNTERFEITING, TRADEMARK INFRINGEMENT, UNFAIR COMPETITION, AND FALSE DESIGNATION OF ORIGIN DEMAND FOR JURY TRIAL

2 Case :-cv-0 Document Filed 0/0/ Page of Page ID #: 0 0 Plaintiff Oakley, Inc. ( Oakley hereby complains of Wholesale In Motion Group Inc. d/b/a All Time Trading Co. d/b/a Blue Star Empire ( Defendant and alleges as follows: JURISDICTION AND VENUE. This Court has original subject matter jurisdiction over the claims in this action that relate to patent infringement, counterfeiting, trademark infringement, false designation of origin, and federal unfair competition pursuant to U.S.C. and, U.S.C. and, and U.S.C., (a,, and, as these claims arise under the laws of the United States. The Court has supplemental jurisdiction over the claims in this Complaint which arise under state statutory and common law pursuant to U.S.C. (a because the state law claims are so related to the federal claims that they form part of the same case or controversy and derive from a common nucleus of operative facts.. This Court has personal jurisdiction over Defendant because Defendant has a continuous, systematic, and substantial presence within this judicial district. For example, by selling and offering for sale infringing products in this judicial district, including but not limited to selling infringing products directly to consumers and/or retailers in this district and selling into the stream of commerce knowing such products would be sold in California and this district, Defendant s acts form a substantial part of the events or omissions giving rise to Oakley s claims. Oakley is informed and believes, and based thereon alleges, that Defendant owns and operates several warehouses in California. Specifically, Defendant states on its website ( that the bulk of our products are in our NJ or CA warehouses. Defendant s website goes on to identify several of its warehouses that are located in California, including, for example, Warehouse Nos.,, 0, 0,,, 0,,,, 00, --

3 Case :-cv-0 Document Filed 0/0/ Page of Page ID #: 0 0 0, 0, 0, and.. Oakley is informed and believes, and based thereon alleges, that venue is proper in this judicial district under U.S.C. (b and (d, and 00(b because Defendant has committed acts of infringement by selling and offering to sell infringing products in this district and Defendant has a regular and established place of business in this district. THE PARTIES. Plaintiff Oakley is a corporation organized and existing under the laws of the State of Washington, having its principal place of business at One Icon, Foothill Ranch, California 0.. Oakley is informed and believes, and thereon alleges, that Defendant Wholesale In Motion Group Inc. d/b/a All Time Trading Co. d/b/a Blue Star Empire is a corporation organized and existing under the laws of the State of New York, having its principal place of business at Avenue U, Brooklyn New York,. GENERAL ALLEGATIONS. Oakley is one of the world s most iconic brands. The company and its products, particularly in the realm of eyewear, are instantly and universally recognized for their innovative technology and distinctive style. Since its founding, Oakley s engineers and designers have worked continuously to bring new technology and breakthrough designs to the market.. Oakley has been actively engaged in the manufacture and sale of high quality eyewear since at least. Oakley is the manufacturer and retailer of several lines of eyewear that have enjoyed substantial success and are protected by various intellectual property rights owned by Oakley.. On July, 00, the United States Patent and Trademark Office ( USPTO duly and lawfully issued United States Design Patent No. D, (the D Patent, titled Eyeglasses. Oakley is the owner by assignment of --

4 Case :-cv-0 Document Filed 0/0/ Page of Page ID #: 0 0 all right, title, and interest in the D Patent. A true and correct copy of the D Patent is attached hereto as Exhibit.. On November, 00, the USPTO duly and lawfully issued United States Design Patent No. D, (the D Patent, titled Eyeglass Frame. Oakley is the owner by assignment of all right, title, and interest in the D Patent. A true and correct copy of the D Patent is attached hereto as Exhibit. 0. On December, 00, the USPTO duly and lawfully issued United States Design Patent No. D, (the D Patent, titled Eyeglass Components. Oakley is the owner by assignment of all right, title, and interest in the D Patent. A true and correct copy of the D Patent is attached hereto as Exhibit.. On July, 00, the USPTO duly and lawfully issued United States Design Patent No. D, (the D Patent, titled Eyeglass Frame. Oakley is the owner by assignment of all right, title, and interest in the D Patent. A true and correct copy of the D Patent is attached hereto as Exhibit.. On December, 00, the USPTO duly and lawfully issued United States Design Patent No. D, (the D Patent, titled Eyeglass Front. Oakley is the owner by assignment of all right, title, and interest in the D Patent. A true and correct copy of the D Patent is attached hereto as Exhibit.. On February, 00, the USPTO duly and lawfully issued United States Design Patent No. D, (the D Patent, titled Eyeglass and Eyeglass Front. Oakley is the owner by assignment of all right, title, and interest in the D Patent. A true and correct copy of the D Patent is attached hereto as Exhibit.. On March, 00, the USPTO duly and lawfully issued United --

5 Case :-cv-0 Document Filed 0/0/ Page of Page ID #: 0 0 States Design Patent No. D, (the D Patent, titled Eyeglass and Eyeglass Components. Oakley is the owner by assignment of all right, title, and interest in the D Patent. A true and correct copy of the D Patent is attached hereto as Exhibit.. On March, 00, the USPTO duly and lawfully issued United States Design Patent No. D,0 (the D0 Patent, titled Eyeglass and Eyeglass Components. Oakley is the owner by assignment of all right, title, and interest in the D0 Patent. A true and correct copy of the D0 Patent is attached hereto as Exhibit.. On February, 00, the USPTO duly and lawfully issued United States Design Patent No. D0,0 (the D0 Patent, titled Eyeglass and Eyeglass Components. Oakley is the owner by assignment of all right, title, and interest in the D0 Patent. A true and correct copy of the D0 Patent is attached hereto as Exhibit.. On March, 00, the USPTO duly and lawfully issued United States Design Patent No. D, (the D Patent, titled Eyeglass Front. Oakley is the owner by assignment of all right, title, and interest in the D Patent. A true and correct copy of the D Patent is attached hereto as Exhibit 0.. On June, 00, the USPTO duly and lawfully issued United States Design Patent No. D,0 (the D0 Patent, titled Eyeglass Component. Oakley is the owner by assignment of all right, title, and interest in the D0 Patent. A true and correct copy of the D0 Patent is attached hereto as Exhibit.. On May, 0, the USPTO duly and lawfully issued United States Design Patent No. D,0 (the D0 Patent, titled Eyeglass. Oakley is the owner by assignment of all right, title, and interest in the D0 Patent. A true and correct copy of the D0 Patent is attached hereto as Exhibit --

6 Case :-cv-0 Document Filed 0/0/ Page of Page ID #: Defendant makes, uses, sells, offers for sale, and/or imports into the United States eyewear that have infringed Oakley s patent rights, including the D, the D, the D, the D, the D, the D, the D, the D0, the D0, the D, the D0, and the D0 Patents (collectively, the Asserted Patents.. Defendant s acts complained of herein have caused Oakley to suffer irreparable injury to its business. -- Oakley will continue to suffer substantial loss and irreparable injury unless and until Defendant is enjoined from its wrongful actions complained of herein.. Oakley is informed and believes, and on that basis, alleges that Defendant s acts complained of herein are willful and deliberate. FIRST CLAIM FOR RELIEF (Patent Infringement ( U.S.C.. Oakley repeats and re-alleges the allegations of paragraphs - of this Complaint as if set forth fully herein.. This is a claim for patent infringement under U.S.C... Defendant, through its agents, employees, and/or servants has, and continues to, knowingly, intentionally, and willfully infringe the D Patent by making, using, selling, offering for sale, and/or importing eyewear having a design that would appear to an ordinary observer to be substantially similar to the claim of the D Patent, for example Defendant s SKU sunglass model as shown below. / / / / / / / / / / / /

7 Case :-cv-0 Document Filed 0/0/ Page of Page ID #: 0 0 Defendant s SKU Sunglass Model Oakley s D Patent. Defendant, through its agents, employees, and/or servants has, and continues to, knowingly, intentionally, and willfully infringe the D Patent by making, using, selling, offering for sale, and/or importing eyewear having a design that would appear to an ordinary observer to be substantially similar to the claim of the D Patent, for example Defendant s SKU sunglass model as shown below. Defendant s SKU Sunglass Model Oakley s D Patent. Defendant, through its agents, employees, and/or servants has, and continues to, knowingly, intentionally, and willfully infringe the D Patent by making, using, selling, offering for sale, and/or importing eyewear having a design that would appear to an ordinary observer to be substantially similar to the claim of the D Patent, for example Defendant s SKU,,,, and sunglass models as shown below. / / / --

8 Case :-cv-0 Document Filed 0/0/ Page of Page ID #: 0 0 Defendant s Oakley s D Patent Sunglass Models SKU SKU SKU SKU SKU. Defendant, through its agents, employees, and/or servants has, and continues to, knowingly, intentionally, and willfully infringe the D Patent by making, using, selling, offering for sale, and/or importing eyewear having a design that would appear to an ordinary observer to be substantially similar to --

9 Case :-cv-0 Document Filed 0/0/ Page of Page ID #: 0 0 the claim of the D Patent, for example, Defendant s SKU 0,, and 0 sunglass models as shown below. Defendant s Oakley s D Patent Sunglass Models SKU 0 SKU SKU 0. Defendant, through its agents, employees, and/or servants has, and continues to, knowingly, intentionally, and willfully infringe the D Patent by making, using, selling, offering for sale, and/or importing eyewear having a design that would appear to an ordinary observer to be substantially similar to the claim of the D Patent, for example, Defendant s SKU and sunglass models as shown below. / / / --

10 Case :-cv-0 Document Filed 0/0/ Page 0 of Page ID #:0 0 0 Defendant s Oakley s D Patent Sunglass Models SKU SKU 0. Defendant, through its agents, employees, and/or servants has, and continues to, knowingly, intentionally, and willfully infringe the D Patent by making, using, selling, offering for sale, and/or importing eyewear having a design that would appear to an ordinary observer to be substantially similar to the claim of the D Patent, for example Defendant s SKU 00 and 0 sunglass models as shown below. Defendant s Oakley s D Patent Sunglass Models SKU 00 --

11 Case :-cv-0 Document Filed 0/0/ Page of Page ID #: 0 0 SKU 0. Defendant, through its agents, employees, and/or servants has, and continues to, knowingly, intentionally, and willfully infringe the D Patent by making, using, selling, offering for sale, and/or importing eyewear having a design that would appear to an ordinary observer to be substantially similar to the claim of the D Patent, for example Defendant s SKU 0, 0, and 0 sunglass models as shown below. Defendant s Oakley s D Patent Sunglass Models SKU 0 SKU 0-0-

12 Case :-cv-0 Document Filed 0/0/ Page of Page ID #: 0 0 SKU: 0. Defendant, through its agents, employees, and/or servants has, and continues to, knowingly, intentionally, and willfully infringe the D0 Patent by making, using, selling, offering for sale, and/or importing eyewear having a design that would appear to an ordinary observer to be substantially similar to the claim of the D0 Patent, for example Defendant s SKU sunglass model as shown below. Defendant s SKU Sunglass Model Oakley s D0 Patent. Defendant, through its agents, employees, and/or servants has, and continues to, knowingly, intentionally, and willfully infringe the D0 Patent by making, using, selling, offering for sale, and/or importing eyewear having a design that would appear to an ordinary observer to be substantially similar to the claim of the D0 Patent, for example Defendant s SKU 0 sunglass model as shown below. / / / --

13 Case :-cv-0 Document Filed 0/0/ Page of Page ID #: 0 0 Defendant s Sunglass Models Oakley s D0 Patent SKU 0. Defendant, through its agents, employees, and/or servants has, and continues to, knowingly, intentionally, and willfully infringe the D Patent by making, using, selling, offering for sale, and/or importing eyewear having a design that would appear to an ordinary observer to be substantially similar to the claim of the D Patent, for example Defendant s SKU and 0 sunglass models as shown below. Defendant s Sunglass Models Oakley s D Patent SKU SKU 0. Defendant, through its agents, employees, and/or servants has, and continues to, knowingly, intentionally, and willfully infringe the D0 Patent by --

14 Case :-cv-0 Document Filed 0/0/ Page of Page ID #: 0 0 making, using, selling, offering for sale, and/or importing eyewear having a design that would appear to an ordinary observer to be substantially similar to the claim of the D0 Patent, for example Defendant s SKU 0 sunglass model as shown below. Defendant s Sunglass Models Oakley s D0 Patent SKU 0. Defendant, through its agents, employees, and/or servants has, and continues to, knowingly, intentionally, and willfully infringe the D0 Patent by making, using, selling, offering for sale, and/or importing eyewear having a design that would appear to an ordinary observer to be substantially similar to the claim of the D0 Patent, for example Defendant s SKU, 00,, 0, 0, 0, sunglass models as shown below. Defendant s Oakley s D0 Patent Sunglass Models SKU SKU 00 --

15 Case :-cv-0 Document Filed 0/0/ Page of Page ID #: 0 0 SKU SKU 0 SKU 0 SKU 0 SKU --

16 Case :-cv-0 Document Filed 0/0/ Page of Page ID #: 0 0. Defendant s acts of infringement of each of the Asserted Patents was undertaken without permission or license from Oakley. Oakley is informed and believes, and thereon alleges, that Defendant had actual knowledge of Oakley s rights in each of the Asserted Patents. Oakley and its iconic designs are well-known throughout the eyewear industry, and Defendant s infringing products are not only substantially similar to the patent(s each is alleged to infringe, each of the infringing products is an identical, or nearly identical, copy of Oakley s patented design. Accordingly, Defendant s actions constitute willful and intentional infringement of each of the Asserted Patents. Defendant infringed Oakley s patent rights with reckless disregard of Oakley s patent rights. Defendant knew, or it was so obvious that Defendant should have known, that its actions constitute infringement of each of the Asserted Patents. Defendant s acts of infringement of were not consistent with the standards of commerce for its industry.. As a direct and proximate result of Defendant s acts of infringement, Defendant has derived and received gains, profits, and advantages in an amount that is not presently known to Oakley.. Pursuant to U.S.C., Oakley is entitled to recover its reasonable attorneys fees for the necessity of bringing this claim. 0. Pursuant to U.S.C., Oakley is entitled to Defendant s total profits from Defendant s infringement of the Asserted Patents.. Due to Defendant s actions, constituting patent infringement, Oakley has suffered great and irreparable injury, for which Oakley has no adequate remedy at law.. Defendant will continue to infringe Oakley s patent rights to the great and irreparable injury of Oakley, unless and until Defendant is enjoined by this Court. / / / --

17 Case :-cv-0 Document Filed 0/0/ Page of Page ID #: 0 0 SECOND CLAIM FOR RELIEF (Counterfeiting and Trademark Infringement ( U.S.C.. Oakley repeats and re-alleges the allegations of paragraphs - of this Complaint as if set forth fully herein.. This is a claim for trademark infringement and counterfeiting arising under U.S.C... Oakley owns valid and enforceable registered trademarks for an ellipsoid O in connection with the sale of sunglasses, which are registered as U.S. Trademark Registration Nos.,, and,,0 (the Oakley Marks and depicted below. Oakley s Trademarks Trademark Reg. No.,, Trademark Reg. No.,,0. Each of U.S. Trademark Registration Nos.,, and,,0 has become incontestable through the filing of a declaration of incontestability with the USPTO.. As shown below, without Oakley s permission, Defendant is reproducing, counterfeiting, copying, or colorably imitating the Oakley Marks and applying such reproductions, counterfeits, copies, or colorable imitations to merchandise, labels, signs, prints, packages, wrappers, receptacles or advertisements intended to be used in commerce upon or in connection with the --

18 Case :-cv-0 Document Filed 0/0/ Page of Page ID #: 0 0 sale, offering for sale, distribution, advertising, and/or promotion of Defendant s products, which is likely to cause confusion, or to cause mistake, or to deceive. SKU 0 SKU 0. Defendant s wrongful acts as alleged in this Complaint constitute willful and intentional counterfeiting and infringement of the Oakley Marks. Defendant engaged in such activities with the intent to unfairly compete against Oakley, to trade upon Oakley s reputation and goodwill by causing confusion and mistake among customers and the public, and to deceive the public into believing that Defendant s products are associated with, sponsored by, originated from, or are approved by Oakley, when in truth and fact they are not.. Oakley is informed and believes, and thereon alleges, that Defendant had actual knowledge of Oakley s ownership and prior use of the Oakley Marks and willfully and maliciously violated Oakley s trademark rights under U.S.C. without Oakley s consent. --

19 Case :-cv-0 Document Filed 0/0/ Page of Page ID #: Oakley is informed and believes, and thereon alleges, that Defendant s infringement has been willful and deliberate, which renders this an exceptional case within the meaning of U.S.C... Oakley is informed and believes, and thereon alleges, that Defendant has derived and received, and will continue to derive and receive, gains, profits, and advantages from the use of the Oakley Marks in an amount that is not presently known to Oakley. By reason of Defendant s actions, constituting unauthorized use, counterfeiting, and infringement of the Oakley Marks, Oakley has been damaged and is entitled to monetary relief in an amount to be determined at trial.. Due to Defendant s actions, constituting unauthorized use, counterfeiting, and infringement of the Oakley Marks, Oakley has suffered and continues to suffer great and irreparable injury, for which Oakley has no adequate remedy at law. THIRD CLAIM FOR RELIEF (False Designation of Origin & Federal Unfair Competition ( U.S.C. (a. Oakley repeats and re-alleges the allegations of paragraphs - of this Complaint as if set forth fully herein.. This is a claim for unfair competition and false designation of origin arising under U.S.C. (a.. Long after Oakley s adoption and use of the Oakley Marks, Defendant began using, and continues to use, marks that are confusingly similar to the Oakley Marks without Oakley s consent in a manner that infringes upon Oakley s rights in violation of U.S.C. (a.. Defendant s use of the Oakley Marks without Oakley s consent constitutes a false designation of origin, false or misleading description of fact, or false or misleading representation of fact, which in commercial advertising or --

20 Case :-cv-0 Document Filed 0/0/ Page 0 of Page ID #:0 0 0 promotion, misrepresents the nature, characteristics, qualities, or geographic origin of his or her or another person s goods or commercial activities in violation of U.S.C. (a.. Such conduct by Defendant is likely to confuse, mislead, and deceive Defendant s customers, purchasers, and members of the public as to the origin of Defendant s goods or cause said persons to believe that Defendant and/or its products have been sponsored, approved, authorized, or licensed by Oakley or are in some way affiliated or connected with Oakley, when they are not, and constitutes unfair competition with Oakley.. Oakley is informed and believes, and thereon alleges, that Defendant s actions were undertaken willfully with full knowledge of the falsity of such designation of origin and false descriptions or representations.. Oakley is informed and believes, and thereon alleges, that Defendant has derived and received, and will continue to derive and receive, gains, profits, and advantages from Defendant s actions in an amount that is not presently known to Oakley. By reason of Defendant s actions, Oakley has been damaged and is entitled to monetary relief in an amount to be determined at trial. 0. Pursuant to U.S.C., Oakley is entitled to recover ( Defendant s profits, ( any damages sustained by Oakley, and ( the costs of the action. In assessing damages, the Court may enter judgment up to three times actual damages, and in awarding profits, the Court may in its discretion enter judgment for such sum as the court shall find to be just, according to the circumstances of the case. The Court may also award Oakley its reasonable attorneys fees for the necessity of bringing this claim.. Due to Defendant s actions, Oakley has suffered and continues to suffer great and irreparable injury, for which Oakley has no adequate remedy at law. --

21 Case :-cv-0 Document Filed 0/0/ Page of Page ID #: 0 0. Defendant will continue its false designation of origin, and unfair competition, unless and until Defendant is enjoined by this Court. FOURTH CLAIM FOR RELIEF (California Trademark Infringement. Oakley repeats and re-alleges the allegations of paragraphs - of this Complaint as if set forth fully herein.. Defendant s acts complained of herein constitute trademark infringement under California common law.. Defendant s acts complained of herein are willful and deliberate and committed with knowledge that Defendant s unauthorized use of the famous Oakley Marks causes a likelihood of confusion.. Oakley is informed and believes, and thereon alleges, that Defendant has derived and received and will continue to derive and receive, gains, profits and advantages from Defendant s trademark infringement in an amount that is not presently known to Oakley. By reason of Defendant s wrongful acts as alleged in this Complaint, Oakley has been damaged and is entitled to monetary relief in an amount to be determined at trial.. Due to Defendant s trademark infringement, Oakley has suffered and continues to suffer great and irreparable injury for which Oakley has no adequate remedy at law.. Defendant s willful acts of trademark infringement constitutes fraud, oppression, and malice. Accordingly, Oakley is entitled to exemplary damages. FIFTH CLAIM FOR RELIEF (California Unfair Competition. Oakley repeats and re-alleges the allegations of paragraphs - of this Complaint as if set forth fully herein. 0. This is a claim for unfair competition, arising under California -0-

22 Case :-cv-0 Document Filed 0/0/ Page of Page ID #: 0 0 Business & Professions Code 00, et seq. and California common law.. Defendant s acts of trademark infringement, false designation of origin, and trademark dilution complained of herein constitute unfair competition with Oakley under the common law and statutory laws of the State of California, particularly California Business & Professions Code 00 et seq.. Oakley is informed and believes, and thereon alleges, that Defendant has derived and received, and will continue to derive and receive, gains, profits and advantages from Defendant s unfair competition in an amount that is not presently known to Oakley.. By reason of Defendant s wrongful acts as alleged in this Complaint, Oakley has been damaged and is entitled to monetary relief in an amount to be determined at trial.. By its actions, Defendant has injured and violated the rights of Oakley and has irreparably injured Oakley, and such irreparable injury will continue unless Defendant is enjoined by this Court. WHEREFORE, Oakley prays for judgment in its favor against Defendant for the following relief: A. An Order adjudging Defendant to have willfully infringed the Asserted Patents under U.S.C. ; B. A preliminary and permanent injunction enjoining Defendant, its officers, directors, agents, servants, employees, attorneys, representatives, successors, and assigns, and those persons in active concert or participation with Defendant, from infringing the Asserted Patents in violation of U.S.C., including, for example, through the manufacture, use, sale, offer for sale, and/or importation into the United States of Defendant s SKU,,,,, 0,, 0,, 00, 0, 0, 0, 0,, 0,,, 00,, 0, --

23 Case :-cv-0 Document Filed 0/0/ Page of Page ID #: 0 0 0, 0, and sunglass models, and any products that are not colorably different form these products; C. That Defendant account for all gains, profits, and advantages derived by Defendant s infringement of the Asserted Patents in violation of U.S.C., and that Defendant pay to Oakley all damages suffered by Oakley and/or Defendant s total profit from such infringement pursuant to U.S.C. and ; D. That the Court find for Oakley and against Defendant on Oakley s claims of counterfeiting and trademark infringement under U.S.C.. E. That the Court find for Oakley and against Defendant on Oakley s claims of trademark infringement, unfair competition, false designation of origin and trademark dilution under U.S.C. ; F. That the Court find for Oakley and against Defendant on Oakley s claims of trademark infringement under California common law and unfair competition under California Business & Professions Code 00, et seq. and California common law; G. That the Court issue a preliminary and permanent injunction against Defendant, its agents, officers, directors, servants, employees, attorneys, representatives, successors, and assigns, and all persons, firms, or corporations in active concert or participation with Defendant, enjoining them from engaging in the following activities and from assisting or inducing, directly or indirectly, others to engage in the following activities:. manufacturing, importing, marketing, displaying, distributing, offering to sell, and/or selling Defendant s SKU 0 and 0 sunglass models shown above or any products that are not colorably different therefrom;. using the Oakley Marks, or any mark confusingly similar to the Oakley Marks; --

24 Case :-cv-0 Document Filed 0/0/ Page of Page ID #: 0 0. falsely designating the origin of Defendant s goods;. unfairly competing with Oakley in any manner whatsoever;. causing a likelihood of confusion or injuries to Oakley s business reputation; or,. manufacturing, importing, marketing, displaying, distributing, offering to sell, and/or selling any goods that infringe the Oakley Marks. H. That an accounting be ordered to determine Defendant s profits resulting from its counterfeiting, trademark infringement, false designation of origin, unfair competition, and trademark dilution that Oakley be awarded monetary relief under U.S.C., including:. all profits received by Defendant from sales and revenues of any kind made as a result of its infringing actions;. all damages sustained by Oakley as a result of Defendant s acts of trademark infringement, false designation of origin, and unfair competition; and,. the costs of this action; I. That such award to Oakley of damages and profits be trebled pursuant to U.S.C. ; J. An Order adjudging that this is an exceptional case; K. That, because of the exceptional nature of this case resulting from Defendant s deliberate infringing actions, this Court award to Oakley all reasonable attorneys fees, costs, and disbursements incurred as a result of this action, pursuant to U.S.C. and/or U.S.C. ; L. That Oakley be awarded statutory damages pursuant to U.S.C. (c for Defendant s counterfeiting, at Oakley s election before the entry of final judgment, together with prejudgment and post-judgment interest; --

25 Case :-cv-0 Document Filed 0/0/ Page of Page ID #: 0 0 M. That Oakley and Luxottica recover exemplary damages pursuant to California Civil Code. N. An Order for a trebling of damages to Oakley because of Defendant s willful patent infringement pursuant to U.S.C. ; O. An award of pre-judgment and post-judgment interest and costs of this action against Defendant; and, proper. P. Such other and further relief as this Court may deem just and Dated: August, 0 KNOBBE, MARTENS, OLSON & BEAR, LLP By: /s/ Lauren Keller Katzenellenbogen Michael K. Friedland Lauren Keller Katzenellenbogen Ali S. Razai James F. Smith Attorneys for Plaintiff OAKLEY, INC. --

26 Case :-cv-0 Document Filed 0/0/ Page of Page ID #: 0 0 triable. DEMAND FOR JURY TRIAL Plaintiff Oakley, Inc. hereby demands a trial by jury on all issues so Dated: August, 0 0 KNOBBE, MARTENS, OLSON & BEAR, LLP By: /s/ Lauren Keller Katzenellenbogen Michael K. Friedland Lauren Keller Katzenellenbogen Ali S. Razai James F. Smith Attorneys for Plaintiff OAKLEY, INC. --

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