BDI v. Walgreens - Complaint

8/13/2019 BDI v. Walgreens - Complaint

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IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF NORTH CAROLINA

WESTERN DIVISION

BUYER’S DIRECT INC., )

)Plaintiff, )

)

v. ) Case No.)

WALGREEN CO., ) Plaintiff Demands Trial by Jury

)

Defendant. ))

COMPLAINT

Plaintiff Buyer’s Direct Inc. (“BDI”) brings this action against Walgreen Co.

(“Walgreens” or “Defendant”) for infringing BDI’s design patent and misappropriating

snoozies!®

trade dress, causing consumer confusion, and engaging in unfair competition.

Because Defendant sold or offered for sale products infringing BDI’s patent, copied its trade

dress, confused consumers and engaged in unfair competition (and continues to do so), BDI

seeks damages, an accounting, the imposition of a constructive trust upon Defendant’s illegal

profits and injunctive relief.

THE PARTIES

1. BDI is a North Carolina corporation with its principal place of business in Wilson, North

Carolina.

2. Walgreens is an Illinois corporation with its principal place of business and principal

office at 300 Wilmot Road MS #3301, Deerfield, IL 60015, and may be served with

process through its registered agent, Corporation Service Company, 327 Hillsborough St.,

Raleigh, NC 27603.

5:13-cv-819

Case 5:13-cv-00819-FL Document 1 Filed 11/26/13 Page 1 of 12



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JURISDICTION AND VENUE

3. This is an action for design patent infringement under 35 U.S.C. § 271, trade dress

infringement and unfair competition under § 43(a) of the Trademark Act of 1946, as

amended (the “Lanham Act”), and unfair competition under North Carolina statutory and

common law.

4. This Court has jurisdiction over the subject matter of this action pursuant to 28 U.S.C.

§§ 1331 and 1338, and 15 U.S.C. § 1121. Because the state law claims are so related to

BDI’s claims under federal law that they form part of the same case or controversy and

derive from a common nucleus of operational facts, this Court has supplemental

jurisdiction over BDI’s claims based on state law pursuant to 28 U.S.C. § 1367(a).

5. This Court has personal jurisdiction over Walgreens because it (a) has sold infringing

products and committed unfair competition in the state of North Carolina, within the

Eastern District of North Carolina; (b) has purposefully directed its activities toward the

state of North Carolina; and (c) has established systematic and continuous contacts with

the state of North Carolina, including maintaining retail stores in the Eastern District of

North Carolina.

6. Venue is proper in this District pursuant to 28 U.S.C. §§ 1391 and 1400 because

Walgreens has sold and offered to sell infringing products in this District, and Walgreens

has a sufficient connection with the Eastern District of North Carolina to make venue

proper in this District, all as alleged in this Complaint.

BACKGROUND

7. BDI is a supplier of retail products, including the patented foot-covering known as

“snoozies!®” in the United States and in particular, North Carolina. BDI has achieved




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market success for snoozies!®

because of the distinctive and unique design of the

snoozies!® product.

8. Since the fall of 2008, snoozies!® have been offered for sale in many retail outlets and

specialty retailers throughout North Carolina and in a number of different states.

9. BDI has promoted and advertised snoozies!®

products in various trade publications and at

trade shows that publicize and promote the sale of such retail soft goods.

10. On August 18, 2009, United States Design Patent No. D598,183 (the “’183 Patent”),

directed to the ornamental appearance of a slipper, was duly and legally issued by the

United States Patent and Trademark Office. A copy of the ’183 Patent is attached as

Exhibit A.

11. On December 22, 2009, Marshall P. Bank, the sole inventor of the ’183 Patent, assigned

all rights in the ’183 Patent to BDI. Since that date, BDI has been, and still is, the owner

of the ’183 Patent.

12. BDI is the exclusive authorized manufacturer and distributor of products embodying the

design of the ’183 Patent in the retail market in the United States.

BDI’S CONTACT WITH WALGREENS AND WALGREENS’ INFRINGEMENT

13. In September of 2011, representatives from Walgreens and BDI began communicating

about selling snoozies!®

in Walgreens stores.

14. At that time, BDI provided Walgreens with written notice that BDI is the owner of the

’183 Patent and that the ’183 Patent covers the snoozies!® line of products.

15. In January of 2012, representatives from BDI and Walgreens engaged in further

discussions regarding the sale of snoozies!®

in Walgreens stores. In addition, BDI




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provided Walgreens with samples of snoozies!®

and reiterated BDI’s ownership of the

’183 Patent.

16. After several months of discussion, Walgreens unexpectedly informed BDI that it would

not purchase snoozies!®

for sale in Walgreens stores.

17. In January of 2013, representatives from BDI and Walgreens met again to discuss selling

snoozies!® in Walgreens stores. BDI again provided Walgreens with samples of

snoozies!®.

18. In or about March of 2013, Walgreens contacted BDI and expressed both a readiness and

an intent to draft purchase orders for snoozies!

®

.

19. Thereafter, however, Walgreens did not submit any orders for snoozies!®

, and instead

ceased all communication with BDI. BDI’s attempts to contact Walgreens went

unanswered.

20. In October, 2013, BDI learned that Walgreens was using, selling, and offering for sale in

interstate commerce a retail slipper product called “Slipper Grips.” Slipper Grips are

slippers that infringe BDI’s patent and trade dress rights.

21. Notwithstanding its knowledge of the ’183 Patent and the infringement, Walgreens

continues to use, sell, or offer for sale Slipper Grips, thereby intentionally infringing the

’183 Patent and BDI’s trade dress.

22. The purpose of this action, inter alia, is to cause Walgreens to cease and desist in offering

Slipper Grips for sale and distribution and to enjoin Walgreens from continuing to offer

the infringing product for sale at any Walgreens store.




5

COUNT 1

(INFRINGEMENT OF U.S. PATENT NO. D598,183)

23. BDI repeats and reincorporates by reference the allegations set forth in paragraphs 1

through 22, inclusive.

24. Defendant is and has been infringing the ’183 Patent by using, selling, and/or offering to

sell a product called “Slipper Grips.”

25. As a direct result of Defendant’s infringement of the ’183 Patent, BDI has suffered

irreparable injury and monetary damages. If Defendant’s infringement is not permanently

enjoined, BDI will continue to suffer irreparable injury and monetary damages.

26. Upon information and belief, Defendant’s infringement of the ’183 Patent is intentional,

willful, and wanton under 35 U.S.C. § 284, and makes this an exceptional case under 35

U.S.C. § 285.

COUNT II

(TRADE DRESS INFRINGMENT)



28. BDI’s snoozies!®

have a distinctive, immediately recognizable and non-functional overall

look and feel that constitutes protectable trade dress that distinguishes BDI’s foot-

coverings from those of competitors. The foot-coverings, which are presented outside of

packaging, are made of a soft, malleable material on both the top and bottom portions of

the foot-covering, the soft, malleable top portion is formed into a wide, rounded covering

over the top of the foot that extends over the toes, and a protrusion of fleece material

extends out from and floats above the foot entry of the foot-covering. An annotated

image of BDI’s snoozies!® highlighting the above-described features is shown below.




6

Protrusion of fleece material extends out from

and floats above the foot entry

Soft, malleable material on both the

top and bottom portions of the foot-covering

Soft malleable top portion formed

into a wide, rounded covering overthe top of the foot that extends overthe toes




7

29. BDI invested significant time, money and effort in developing snoozies!®

foot-coverings,

resulting in significant commercial success and public recognition of its distinctive

design, appearance and trade dress.

30. As a result of BDI’s advertising and promotion of snoozies!® foot-coverings by itself and

others, the trade and purchasing public have come to associate the distinctive trade dress

of snoozies!® with a single producer or source. Accordingly, the snoozies!

® trade dress

has acquired secondary meaning in the marketplace as to the origin of the product.

31. The distinctive trade dress of snoozies!®

is non-functional and ornamental.

32. Defendant has sold or offered for sale, and continues to sell or offer for sale “Slipper

Grips,” which copy and are confusingly similar in appearance to the trade dress of

snoozies!®, and therefore are likely to deceive and confuse the purchasing public as to the

source or origin of “Slipper Grips” in violation of 15 U.S.C. § 1125(a).

33. Defendant has engaged in wrongful conduct with the willful purpose of misleading,

deceiving or confusing customers and the public as to the origin and authority of the

“Slipper Grips,” thereby trading on BDI’s goodwill, reputation and creative designs.

34. Defendant’s conduct constitutes willful infringement of BDI’s protectable trade dress,

making this an exceptional case within the meaning of 15 U.S.C. § 1117.

35. Defendant’s infringing activity has caused BDI irreparable injury and monetary damages.




8

36. If Defendant’s infringements are not permanently enjoined, BDI will continue to suffer

irreparable injury and monetary damages.

37. BDI has no adequate remedy at law for Defendant’s wrongful conduct because (a) BDI’s

unique snoozies!® design patent and trade dress have no readily determined market value;

(b) Defendant’s sale and offers for sale of the imitation slipper design constitutes such

harm that BDI cannot be made whole by any monetary award alone; and (c) Defendant’s

wrongful conduct is continuing, notwithstanding its knowledge of the established trade

dress.

COUNT IIIUNFAIR AND DECEPTIVE TRADE PRACTICES UNDER NORTH CAROLINA

LAW – N.C. GEN STAT 75-1.1



39. BDI is based in North Carolina and is therefore entitled to the protections afforded under

the laws of the State of North Carolina.

40. BDI invested significant money and effort in advertising and promoting its snoozies!®

foot-coverings and as a result, snoozies!® are associated with BDI by the trade and

purchasing public.

41. The acts and conduct of Defendant as alleged above constitute unfair methods of

competition and unfair or deceptive acts or practices in or affecting North Carolina

commerce, as defined by N.C. Gen. Stat. § 75-1.1.

42. As a direct and proximate result of Defendant’s conduct, BDI has suffered and will

continue to suffer substantial pecuniary damages, including but not limited to losses and




9

damages in an amount to be determined at trial. Defendant’s conduct justifies an award of

treble damages pursuant to N.C. Gen. Stat. § 75-16.

43. Because much of the damage suffered by BDI as a result of Defendant’s conduct is and

will be irreparable, for which BDI has no adequate remedy at law, BDI is further entitled

to preliminary and permanent injunctive relief.

44. Defendant has willfully engaged in the acts and practices alleged in this Complaint. For

these reasons, BDI is further entitled to recover attorneys’ fees from Defendant under

N.C. Gen. Stat. § 75-16.1(1).

COUNT IVNORTH CAROLINA COMMON LAW

UNFAIR COMPETITION

45. BDI realleges and incorporates by reference, each and every allegation set forth in

Paragraphs 1 through 44, inclusive.

46. The acts and conduct of Defendant set forth above constitutes unfair competition in North

Carolina at common law.

47. BDI, as a result of such conduct, has suffered and will continue to suffer losses and

damages in an amount to be determined at trial.

48. As much of the damage covered by Defendant’s conduct is and will be irreparable, for

which BDI has no adequate remedy at law, BDI is further entitled to preliminary and

permanent injunctive relief.

COUNT V

FOR IMPOSITION OF A CONSTRUCTIVE TRUST UPON THE ILLEGAL

PROFITS OF DEFENDANT

49. BDI realleges, and incorporates by this reference, each and every allegation set forth in

paragraphs 1 through 48, inclusive.




10

50. Defendant’s conduct constitutes deceptive and wrongful conduct in the nature of passing

off the infringing materials as genuine BDI snoozies!® foot-coverings.

51. By virtue of its wrongful conduct, Defendant has illegally received money and profits

that rightfully belong to BDI.

52. Upon information and belief, Defendant holds the illegally received money and profits in

the form of bank accounts, real property, or personal property that can be located and

traced.

53. Defendant holds the money and profits it has illegally received as constructive trustee for

the benefit of BDI.

COUNT VI

ACCOUNTING AGAINST DEFENDANT

54. BDI realleges, and incorporates by this reference, each and every allegation set forth in

paragraphs 1 through 53, inclusive.

55. BDI is entitled, pursuant to 35 U.S.C. § 284, to recover any and all profits of Defendant

that are attributable to its acts of infringement.

56. BDI is entitled, pursuant to 35 U.S.C. § 284, to actual damages sustained by virtue of

Defendant’s acts of infringement.

57. The specific amount of money due from Defendant to BDI is unknown to BDI and

cannot be ascertained without a detailed accounting by Defendant of the precise number

of units of infringing material offered for distribution and distributed by Defendant.




11

PRAYER FOR RELIEF

WHEREFORE, BDI prays that this Court enter a judgment as follows:

1. That the Court enter an order declaring that Defendant hold in trust, as constructive

trustee for the benefit of BDI, its illegal profits obtained from its distribution of infringing

slippers, and requiring Defendant to provide BDI a full and complete accounting of all

amounts due and owing to BDI as a result of Defendant’s illegal activities.

2. That the Court order Defendant to pay BDI’s general, special, actual, and statutory

damages as follows:

a.

BDI’s damages and Defendant’s profits pursuant to 17 U.S.C. § 504(b), or in the

alternative, enhanced statutory damages pursuant to 17 U.S.C. § 504(c)(2), for

Defendant’s willful infringement;

b. BDI’s damages and Defendant’s profits pursuant to 15 U.S.C. § 1117(a), trebled

pursuant to 15 U.S.C. § 1117(b) for Defendant’s willful violation of BDI’s trade

dress or, in the alternative, statutory damages pursuant to 15 U.S.C. § 1117(c) for

each infringing product;

and

c. BDI’s damages and Defendant’s profits pursuant to North Carolina common law;

3. That the Court order Defendant to pay to BDI both the costs of this action and the

reasonable attorneys’ fees incurred by it in prosecuting this action; and

4. That the Court grant to BDI such other and additional relief as is just and proper,

including a permanent injunction pursuant to 35 U.S.C. § 283 and 15 U.S.C. § 1116.




12

JURY DEMAND

BDI demands a trial by jury on all issues.

November 26, 2013 Respectfully submitted,

/s/ Alex J. Hagan

Alex J. Hagan, Esq. (NC State Bar No. 19037)

ELLIS & WINTERS LLPPost Office Box 33550

Raleigh, NC 27636

Telephone: (919) 865-7000

Facsimile: (919) 865-7010Email: [email protected]

Local Civil Rule 83.1 Counsel

Andrew S. Chamberlin, Esq. (NC State Bar No. 17369)ELLIS & WINTERS LLP

333 N. Greene Street, Suite 200Greensboro, NC 27401

Telephone: (336) 217-4193

Facsimile: (336) 217-4198

Email: [email protected]

Local Civil Rule 83.1 Counsel

Andrew M. Ollis (VA State Bar No. 39051)

Tia D. Fenton (VA State Bar No. 70078)

Special Notices of Appearance ForthcomingOBLON, SPIVAK , MCCLELLAND,

MAIER & NEUSTADT, L.L.P

1940 Duke Street

Alexandria, VA 22314Telephone: (703) 413-3000

Facsimile: (703) 413-2220

Email: [email protected]




EXHIBIT A

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S 44 (Rev. 12/12) CIVIL COVER SHEETThe JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except

rovided 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 theurpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)

. (a) PLAINTIFFS DEFENDANTS

(b) County of Residence of First Listed Plaintiff County of Residence of First Listed Defendant

(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)

NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OFTHE TRACT OF LAND INVOLVED.

(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)

I. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for

(For Diversity Cases Only) and One Box for Defendant

’ 1 U.S. Government ’ 3 Federal Question PTF DEF PTF D

Plaintiff (U.S. Government Not a Party) Citizen of This State ’ 1 ’ 1 Incorporated or Principal Place ’ 4

of Business In This State

’ 2 U.S. Government ’ 4 Diversity Citizen of Another State ’ 2 ’ 2 Incorporated and Principal Place ’ 5

Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State

Citizen or Subject of a ’ 3 ’ 3 Foreign Nation ’ 6

Foreign Country

V. NATURE OF SUIT (Place an “X” in One Box Only)CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES

’ 110 Insurance PERSONAL INJURY PERSONAL INJURY ’ 625 Drug Related Seizure ’ 422 Appeal 28 USC 158 ’ 375 False Claims Act

’ 120 Marine ’ 310 Airplane ’ 365 Personal Injury - of Property 21 USC 881 ’ 423 Withdrawal ’ 400 State Reapportionm

’ 130 Miller Act ’ 315 Airplane Product Product Liability ’ 690 Other 28 USC 157 ’ 410 Antitrust

’ 140 Negotiable Instrument Liability ’ 367 Health Care/ ’ 430 Banks and Banking

’ 150 Recovery of Overpayment ’ 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS ’ 450 Commerce

& Enforcement of Judgment Slander Personal Injury ’ 820 Copyrights ’ 460 Deportation

’ 151 Medicare Act ’ 330 Federal Employers’ Product Liabi lity ’ 830 Patent ’ 470 Racketeer Influence

’ 152 Recovery of Defaulted Liability ’ 368 Asbestos Personal ’ 840 Trademark Corrupt Organizatio

Student Loans ’ 340 Marine Injury Product ’ 480 Consumer Credit

(Excludes Veterans) ’ 345 Marine Product Liability LABOR SOCIAL SECURITY ’ 490 Cable/Sat TV

’ 153 Recovery of Overpayment Liability PERSONAL PROPERTY ’ 710 Fair Labor Standards ’ 861 HIA (1395ff) ’ 850 Securities/Commod

of Veteran’s Benefits ’ 350 Motor Vehicle ’ 370 Other Fraud Act ’ 862 Black Lung (923) Exchange

’ 160 Stockholders’ Suits ’ 355 Motor Vehicle ’ 371 Truth in Lending ’ 720 Labor/Management ’ 863 DIWC/DIWW (405(g)) ’ 890 Other Statutory Acti

’ 190 Other Contract Product Liability ’ 380 Other Personal Relations ’ 864 SSID Title XVI ’ 891 Agricultural Acts

’ 195 Contract Product Liability ’ 360 Other Personal Property Damage ’ 740 Railway Labor Act ’ 865 RSI (405(g)) ’ 893 Environmental Matt

’ 196 Franchise Injury ’ 385 Property Damage ’ 751 Family and Medical ’ 895 Freedom of Informa

’ 362 Personal Injury - Product Liability Leave Act Act Medical Malpractice ’ 790 Other Labor Litigation ’ 896 Arbitration

REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS ’ 791 Employee Retirement FEDERAL TAX SUITS ’ 899 Administrative Proc

’ 210 Land Condemnation ’ 440 Other Civil Rights Habeas Corpus: Income Security Act ’ 870 Taxes (U.S. Plaintiff Act/Review or Appe

’ 220 Foreclosure ’ 441 Voting ’ 463 Alien Detainee or Defendant) Agency Decision

’ 230 Rent Lease & Ejectment ’ 442 Employment ’ 510 Motions to Vacate ’ 871 IRS—Third Party ’ 950 Constitutionality of

’ 240 Torts to Land ’ 443 Housing/ Sentence 26 USC 7609 State Statutes

’ 245 Tort Product Liability Accommodations ’ 530 General

’ 290 All Other Real Property ’ 445 Amer. w/Disabilities - ’ 535 Death Penalty IMMIGRATION

Employment Other: ’ 462 Naturalization Application’ 446 Amer. w/Disabilities - ’ 540 Mandamus & Other ’ 465 Other Immigration

Other ’ 550 Civil Rights Actions

’ 448 Education ’ 555 Prison Condition

’ 560 Civil Detainee -

Conditions of

Confinement

V. ORIGIN (Place an “X” in One Box Only)

’ 1 OriginalProceeding

’ 2 Removed fromState Court

’ 3 Remanded fromAppellate Court

’ 4 Reinstated or Reopened

’ 5 Transferred fromAnother District(specify)

’ 6 MultidistrictLitigation

VI. CAUSE OF ACTION

Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):

Brief description of cause:

VII. REQUESTED INCOMPLAINT:

’ CHECK IF THIS IS A CLASS ACTIONUNDER RULE 23, F.R.Cv.P.

DEMAND $ CHECK YES only if demanded in complaint

JURY DEMAND: ’ Yes ’ No

VIII. RELATED CASE(S)IF ANY

(See instructions):JUDGE DOCKET NUMBER

DATE SIGNATURE OF ATTORNEY OF RECORD

FOR OFFICE USE ONLY

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGECase 5:13-cv-00819-FL Document 1-2 Filed 11/26/13 Page 1 of 2

BUYER'S DIRECT INC.

Alex J. Hagan, Ellis & Winters LLP,P.O. Box 33550, Raleigh, NC 27636

WALGREEN CO.

35 U.S.C. 271

Action for design patent infringement, trade dress infringement and unfair competition.

1/26/2013 /s/ Alex J. Hagan, Rule 83.1 counsel

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JS 44 Reverse (Rev. 12/12)

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 supplements the filings and service of pleading or other papers as

required 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 o

Court for each civil complaint filed. The attorney filing a case should complete the form as follows:

I.(a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, us

only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency andthen the official, giving both name and title.

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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 lan

condemnation 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. If there are several attorneys, list them on an attachment, no

in this section "(see attachment)".

II. Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions be shown in pleadings. Place an

in one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.

United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here

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Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendm

to the Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code tak

precedence, and box 1 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; NOTE: federal question actions take precedence over diversitycases.)

III. Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark

section for each principal party.

IV. 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

sufficient to enable the deputy clerk or the statistical clerk(s) in the Administrative Office to determine the nature of suit. If the cause fits more th

one nature of suit, select the most definitive.

V. Origin. Place an "X" in one of the six boxes.

Original Proceedings. (1) Cases which originate in the United States district courts.

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When this box is checked, do not check (5) above.

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Demand. In this space enter the actual dollar amount 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.

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numbers and the corresponding judge names for such cases.

Date and Attorney Signature. Date and sign the civil cover sheet.




5:13-cv-819




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BDI v. Walgreens - Complaint