BLAKELY LAW GROUP

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PLAINTIFF’S COMPLAINT FOR DAMAGES AND EQUITABLE RELIEF

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Brent H. Blakely (SBN 157292) [email protected] Cindy Chan (SBN 247495) [email protected] BLAKELY LAW GROUP 1334 Parkview Avenue, Suite 280 Manhattan Beach, California 90266 Telephone: (310) 546-7400 Facsimile: (310) 546-7401 Attorneys for Plaintiff Michael Kors, L.L.C.

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

MICHAEL KORS, L.L.C., a Delaware Limited Liability Corporation, Plaintiff, vs. M R ENTERPRISES, an unknown business entity; DEEPAK NARULA, an individual; DOES 1-10, inclusive, Defendants.

)))))))))))))))))))))))))))

CASE NO. PLAINTIFF’S COMPLAINT FOR DAMAGES AND EQUITABLE RELIEF 1. FEDERAL TRADE DRESS

INFRINGEMENT;

2. FEDERAL TRADEMARK INFRINGEMENT OF UNREGISTERED MARK;

3. COMMON LAW TRADEMARK INFRINGEMENT;

4. UNFAIR COMPETITION IN VIOLATION OF CA BUS. & PROF. CODE § 17200, et seq.;

5. COMMON LAW UNFAIR COMPETITION

JURY TRIAL DEMANDED

Plaintiff Michael Kors, L.L.C. for its claims against Defendants M R

Enterprises, Deepak Narual and DOES 1-10, respectfully alleges as follows:

Case 2:17-cv-01052 Document 1 Filed 02/09/17 Page 1 of 16 Page ID #:1

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JURISDICTION AND VENUE

1. Plaintiff files this action against Defendants for: (1) federal trade dress

infringement; (2) federal trademark infringement of an unregistered trademark; (3)

California common law trademark infringement; (4) California statutory unfair

competition; and (5) California common law unfair competition.

2. The common law claims in this action arise out of the same nucleus of

operative facts as the substantial federal law claims to which they are joined. This

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

1331, 28 U.S.C. §§ 1338(a) and 1338(b), and 15 U.S.C. §§ 1064, 1119, 1125 and

under the principles of pendent jurisdiction pursuant to 28 U.S.C. § 1367.

3. This Court has personal jurisdiction over Defendants because Defendants

are incorporated, domiciled, and/or conduct business within this judicial district.

4. This action arises out of wrongful acts, including advertising, offering for

sale, selling and distributing products by Defendants within this judicial district.

Venue is proper in this district pursuant to 28 U.S.C. §1391 because the claims

asserted arise in this district.

THE PARTIES

5. Plaintiff Michael Kors, L.L.C. (“Michael Kors”) is a limited liability

corporation duly organized and existing under the laws of the state of Delaware,

having an office and principle place of business at 11 West 42nd

Street, New York,

New York 10036. Michael Kors is a luxury lifestyle brand with a presence in over 85

countries. Michael Kors has developed significant and valuable intellectual property

rights in its Michael Kors brands.

6. Upon information and belief, Defendant M R Enterprises is an unknown

business entity with an office and principal place of business at 500 Lakewood Center

Mall, Lakewood, California 90712.


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7. Upon information and belief, Defendant Deepak Narula is an individual

residing in this judicial district and is an owner, officer, director, and/or managing

agent of M R Enterprises.

8. Plaintiff is unaware of the names and true capacities of Defendants,

whether individual, corporate and/or partnership entities, named herein as DOES 1

through 10, inclusive, and therefore sues them by their fictitious names. Plaintiff will

seek leave to amend this complaint when their true names and capacities are

ascertained. Plaintiff is informed and believes and based thereon alleges that said

Defendants and DOES 1 through 10, inclusive, are in some manner responsible for the

wrongs alleged herein, and that at all times referenced each was the agent and servant

of the other Defendants and was acting within the course and scope of said agency and

employment.

9. Plaintiff is informed and believe, and based thereon allege, that at all

relevant times herein, Defendants and DOES 1 through 10, inclusive, knew or

reasonably should have known of the acts and behavior alleged herein and the damages

caused thereby, and by their inaction ratified and encouraged such acts and behavior.

Plaintiff further alleges that Defendants and DOES 1 through 10, inclusive, have a

non-delegable duty to prevent or cause such acts and the behavior described herein,

which duty Defendants and DOES 1 though 10, inclusive, failed and/or refused to

perform.

ALLEGATIONS COMMON TO ALL CAUSES OF ACTION

A. The MICHAEL KORS Brands, the MK Common Law Trademark,

and the MK Trade Dress

10. Michael Kors is a famous and valuable global luxury lifestyle brand

launched in 1981 by award-winning designer Michael Kors. The company has

evolved from an American luxury sportswear house to a global accessories, footwear

and apparel company with a presence in nearly 100 countries.


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11. Michael Kors offers two primary collections: the Michael Kors collection

and the MICHAEL Michael Kors collection (together, the “Michael Kors Products”).

12. The Michael Kors collection was first introduced in 1981 and reflects the

pinnacle of luxury. The Michael Kors collection is carried in Michael Kors retail

stores and in some of the finest luxury department stores in the world, including, but

not limited to Nordstrom, Saks Fifth Avenue and Neiman Marcus. This collection

consists of accessories, including handbags and small leather goods (many of which

are made from high quality leathers and other exotic skins), footwear and apparel.

13. The MICHAEL Michael Kors collection, an accessible luxury collection,

was first introduced in 2004. This collection focuses on handbags and accessories, but

also includes footwear and apparel. The MICHAEL Michael Kors collection is carried

in Michael Kors lifestyle stores and in leading department stores throughout the world.

14. There are currently more than 270 Michael Kors stores located throughout

the United States, including within this judicial district, carrying Michael Kors

Products.

15. The MICHAEL Michael Kors Collection includes, inter alia, women’s

handbags and accessories utilizing the MK Common Law Trademark, which consists

of the block letter “M” connected to the block letter “K” as shown below:

16. The MK Common Law Trademark was first used by Michael Kors in

interstate commerce at least as early as 2003 and is inherently distinctive, non-

functional and exclusively owned and used by Michael Kors. As the result of

significant sales and the expenditure of millions of dollars in multi-media advertising

and promotion by Michael Kors, in the United States and throughout the world as part

of a long term and carefully planned marketing program, the MK Common Law

Trademark serves to identify Michael Kors to the consuming public as the source of


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merchandise including, without limitation, women’s accessories, on which the MK

Common Law Trademark is displayed. Consumers directly associate the MK Common

Law Trademark with Michael Kors, the MICHAEL Michael Kors Collection, and with

merchandise of the highest quality. As such, the MK Common Law Trademark, in

addition to being inherently distinctive and non-functional, has developed strong

secondary meaning and is of inestimable value to Michael Kors.

17. The MICHAEL Michael Kors collection of handbags and accessories is

widely recognized for the “MK Trade Dress,” which features the MK Common Law

Trademark in repetitious horizontal rows as shown below:

18. The MK Trade Dress was an original design by Michael Kors and the

elements thereof are nonfunctional and its distinctive quality has achieved a high

degree of consumer recognition and secondary meaning since its introduction in or

around 2007.

19. The MK Trade Dress serves to identify Michael Kors as the source of its

merchandise including, without limitation, women’s accessories such as, inter alia,

handbags, swing packs, clutches, purses, totes and satchels.

20. Michael Kors has spent substantial time, effort, and money in designing,

developing, advertising, promoting, and marketing Michael Kors Products featuring


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the MK Trade Dress and MK Common Law Trademark. Michael Kors’s efforts have

been successful and Michael Kors has sold a substantial amount of Michael Kors

Products bearing the MK Trade Dress and MK Common Law Trademark.

21. Due to Michael Kors and its predecessors’ long use, extensive sales, and

significant advertising and promotional activities, the MK Trade Dress and MK

Common Law Trademark have achieved widespread acceptance and recognition

among the consuming public and the trade throughout the United States. The arbitrary

and distinctive MK Trade Dress and MK Common Law Trademark identify Michael

Kors as the source/origin of the goods on which it appears.

B. Defendants’ Infringing Activities

22. Upon information and belief, Michael Kors herein avers and alleges that

Defendant M R Enterprises owns and operates a retail store at Lakewood Center Mall

located 500 Lakewood Center Mall, Lakewood, California 90712.

23. Michael Kors recently discovered the advertisement, marketing, offering

for sale, and/or sale of handbags and related products from said M R Enterprises’ retail

store that bear designs confusingly similar to Michael Kors’s MK Trade Dress and MK

Common Law Trademark (“Infringing Products”):

MICHAEL Michael Kors® Product

Defendants’ Infringing Products


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24. Upon information and belief, Defendant Deepak Narula is an owner,

officer, and/or managing agent of M R Enterprises and is the active, moving, conscious

force behind the infringing activities alleged herein.

25. Michael Kors is informed and believes and herein alleges that Defendants

are competitors and have copied Michael Kors’s MK Trade Dress and MK Common

Law Trademark in an effort to exploit Michael Kors’s reputation in the market.

26. Michael Kors has not granted a license or any other form of permission to

Defendants with respect to any of its trademarks, trade dresses, or other intellectual

property.

27. Michael Kors is informed and believes and herein alleges that Defendants

have acted in bad faith and that Defendants’ acts have misled and confused and were

intended to cause confusion, or to cause mistake, or to deceive as to the affiliation,

connection, or association of Defendants’ Infringing Products with Michael Kors, or as

to the origin, sponsorship, or approval of Defendants’ Infringing Products by Michael

Kors.

FIRST CLAIM FOR RELIEF

(Trade Dress Infringement - 15 U.S.C. § 1125(a))

28. Michael Kors incorporates herein by reference the averments of the

preceding paragraphs as though fully set forth herein.

29. The MK Trade Dress was an original design by Michael Kors and the

elements thereof are nonfunctional and their distinctive quality has achieved a high

degree of consumer recognition and secondary meaning nationwide.

30. Through many years of use in interstate commerce, Michael Kors has

established common law trademark protection for its inherently distinctive and non-

functional MK Trade Dress used on Michael Kors’s women’s accessories in the

MICHAEL Michael Kors Collection including, inter alia, handbags, swing packs,

clutches, purses, totes and satchels.


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31. Merchandise utilizing Michael Kors’s MK Trade Dress has a unique

“look,” which distinguishes it from other women’s accessories, and puts potential

second comers and users of confusingly similar trade dress, such as found on

Defendants’ Infringing Products, on notice as to Michael Kors’s exclusive and

protected trade dress rights in connection with, inter alia, women’s accessories.

Women’s accessories bearing Michael Kors’s MK Trade Dress have achieved

substantial sales, and favorable consumer and trade acceptance, both in the United

States and throughout the world. In addition to being inherently distinctive, the MK

Trade Dress has acquired secondary meaning and has become a strong indicator of

Michael Kors, and the MICHAEL Michael Kors Collection, as a source of goods

bearing such trade dress.

32. As a direct result of the continuous and exclusive use of the MK Trade

Dress in interstate commerce, Michael Kors has established significant good will and

consumer expectation regarding the high quality and source of Michael Kors’s

merchandise including, inter alia, women’s accessories, displaying the MK Trade

Dress.

33. Michael Kors has dedicated substantial monetary expenditures and

resources to support its MICHAEL Michael Kors line, bearing the MK Trade Dress, by

way of extensive advertising and promotional efforts through diverse media in the

United States as well as internationally.

34. The Infringing Products produced, distributed, advertised and offered for

sale by Defendants bear nearly identical reproductions of the MK Trade Dress, such as

to cause a likelihood of confusion as to the source, sponsorship or approval by Michael

Kors of Defendants’ products. Indeed, use of the block letters “M” and “K” in the

manner shown on Defendants’ Infringing Products creates a high likelihood of

consumer confusion amongst consumers, which is especially damaging to the good

will established in the MK Trade Dress and Michael Kors’s reputation for high quality

luxury products.


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35. Defendants’ use of the MK Trade Dress is without Michael Kors’s

permission or authority and in total disregard of Michael Kors’s rights to control its

intellectual property.

36. Defendants’ use of the MK Trade Dress is likely to lead to and result in

confusion, mistake or deception, and is likely to cause the public to believe that

Defendants’ products are produced, sponsored, authorized, or licensed by or that are

otherwise connected or affiliated with Michael Kors, all to the detriment of Michael

Kors.

37. Michael Kors has no adequate remedy at law.

38. In light of the foregoing, Michael Kors is entitled to injunctive relief

prohibiting Defendants from using Michael Kors’s MK Trade Dress, or any designs

confusingly similar thereto, and to recover all damages, including attorneys’ fees, that

Michael Kors has sustained and will sustain, and all gains, profits and advantages

obtained by Defendants as a result of their infringing acts alleged above in an amount

not yet known, as well as the costs of this action.

SECOND CLAIM FOR RELIEF

(Trademark Infringement of an Unregistered Trademark - 15 U.S.C. § 1125 (a))



40. The MK Common Law Trademark is an arbitrary mark and its distinctive

quality has achieved a high degree of consumer recognition and secondary meaning

nationwide.

41. Through many years of use in interstate commerce, Michael Kors has

established common law trademark protection for its inherently distinctive MK

Common Law Trademark used on Michael Kors’s women’s accessories in the

MICHAEL Michael Kors Collection including, inter alia, handbags, swing packs,

clutches, purses, totes and satchels.


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42. As a direct result of the continuous and exclusive use of the MK Common

Law Trademark in interstate commerce, Michael Kors has established significant good

will and consumer expectation regarding the high quality and source of Michael Kors’s

merchandise including, inter alia, women’s accessories, displaying said mark.

43. Michael Kors has dedicated substantial monetary expenditures and

resources to support its MICHAEL Michael Kors line, bearing the MK Common Law

Trademark, by way of extensive advertising and promotional efforts through diverse

media in the United States as well as internationally.

44. The Infringing Products produced, distributed, advertised and offered for

sale by Defendants bear nearly identical reproductions of the MK Common Law

Trademark, such as to cause a likelihood of confusion as to the source, sponsorship or

approval by Michael Kors of Defendants’ products. Indeed, use of the block letters

“M” and “K” in the manner shown on Defendants’ Infringing Products creates a high

likelihood of consumer confusion amongst consumers, which is especially damaging to

the good will established in the MK Common Law Trademark and Michael Kors’s

reputation for high quality luxury products.

45. Defendants’ use of the MK Common Law Trademark is without Michael

Kors’s permission or authority and in total disregard of Michael Kors’s rights to

control its intellectual property.

46. Defendants’ use of the MK Common Law Trademark is likely to lead to

and result in confusion, mistake or deception, and is likely to cause the public to

believe that Defendants’ products are produced, sponsored, authorized, or licensed by

or that are otherwise connected or affiliated with Michael Kors, all to the detriment of

Michael Kors.

47. Michael Kors has no adequate remedy at law.


prohibiting Defendants from using Michael Kors’s MK Common Law Trademark, or

any designs confusingly similar thereto, and to recover all damages, including


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attorneys’ fees, that Michael Kors has sustained and will sustain, and all gains, profits

and advantages obtained by Defendants as a result of their infringing acts alleged

above in an amount not yet known, as well as the costs of this action.

THIRD CLAIM FOR RELIEF

(Common Law Trademark Infringement)



50. The MK Block Trade Dress and MK Common Law Trademark have

achieved a high degree of consumer recognition and secondary meaning nationwide

and within the state of California.

51. Defendants’ infringement of the MK Trade Dress and MK Common Law

Trademark constitutes common law trade dress and trademark infringement in

violation of the common law of the state of California.

52. By virtue of the acts complained of herein, Defendants have caused a

likelihood of confusion among the purchasing public in this Judicial District and

elsewhere, in its unauthorized use of the MK Trade Dress and MK Common Law

Trademark on its own products.

53. Defendants’ acts are willful, deliberate, and intended to confuse the public

and to injure Michael Kors.

54. Michael Kors has no adequate remedy at law to compensate it fully for

the damages that have been caused and which will continue to be caused by

Defendants’ infringing conduct, unless they are enjoined by this Court.

55. The conduct herein complained of was extreme, outrageous, and was

inflicted on Michael Kors in reckless disregard of Michael Kors’s rights. Said conduct

was despicable and harmful to Michael Kors and as such supports an award of

exemplary and punitive damages in an amount sufficient to punish and make an

example of Defendants, and to deter them from similar such conduct in the future.


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prohibiting Defendants from infringing the MK Block Trade Dress and MK Common

Law Trademark, or any designs confusingly similar thereto, and to recover all

damages, including attorneys’ fees, that Michael Kors has sustained and will sustain,

and all gains, profits and advantages obtained by Defendants as a result of their

infringing acts alleged above in an amount not yet known, and the costs of this action.

FOURTH CLAIM FOR RELIEF

(Unfair Competition California Unfair Business Practices Act, Cal. Bus. & Prof.

Code, § 17200, et. seq. as to All Defendants)



58. Defendants’ appropriation, adoption and use of the MK Block Trade

Dress and MK Common Law Trademark in connection with the sale and offering for

sale of handbags and related products is likely to confuse or mislead consumers into

believing that Defendants’ goods are authorized, licensed, affiliated, sponsored, and/or

approved by Michael Kors, thus constituting a violation of the California Unfair

Business Practices Act, Cal. Bus. & Prof. Code, § 17200, et. seq.

59. The deceptive, unfair and fraudulent practices set forth herein have been

undertaken with knowledge by Defendants willfully with the intention of causing harm

to Michael Kors and for the calculated purpose of misappropriating Michael Kors’s

goodwill and business reputation.

60. Defendants’ use of Michael Kors’s MK Block Trade Dress and MK

Common Law Trademark has deprived Michael Kors of the right to control the use of

its intellectual property.

61. As a direct and proximate result of Defendants’ unlawful infringement,

Michael Kors has suffered damages and will continue to suffer damages in an amount

that is not presently ascertainable but will be proven at trial. Michael Kors is entitled to


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all available relief provided for in California Unfair Business Practices Act, Cal. Bus.

& Prof. Code, § 17200, et. seq. including permanent injunctive relief.

FIFTH CLAIM FOR RELIEF

(Unfair Competition Under California Common Law As to All Defendants)



63. Defendants’ infringement of the MK Block Trade Dress and MK

Common Law Trademark constitutes unfair competition in violation of the common

law of the state of California.

64. Defendants are competitors of Michael Kors and have copied Michael

Kors’s MK Block Trade Dress and MK Common Law Trademark in an effort to

exploit Michael Kors’s reputation in the market.

65. Defendants’ infringing acts were intended to capitalize on Michael Kors’s

goodwill associated with the MK Block Trade Dress and MK Common Law

Trademark for Defendants’ own pecuniary gain. Michael Kors has expended

substantial time, resources and effort to obtain an excellent reputation for the Michael

Kors Products. As a result of Michael Kors’s efforts, Defendants are now unjustly

enriched and are benefiting from property rights that rightfully belong to Michael

Kors.

66. Defendants’ acts are willful, deliberate, and intended to confuse the public

and to injure Michael Kors.

67. Michael Kors has no adequate remedy at law to compensate it fully for

the damages that have been caused and which will continue to be caused by

Defendants’ infringing conduct, unless they are enjoined by this Court.

68. The conduct herein complained of was extreme, outrageous, and was

inflicted on Michael Kors in reckless disregard of Michael Kors’ rights. Said conduct

was despicable and harmful to Michael Kors and as such supports an award of


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exemplary and punitive damages in an amount sufficient to punish and make an

example of Defendants, and to deter them from similar such conduct in the future.


prohibiting Defendants from infringing the MK Block Trade Dress and MK Common

Law Trademark, or any designs confusingly similar thereto, and to recover all

damages, including attorneys’ fees, that Michael Kors has sustained and will sustain,

and all gains, profits and advantages obtained by Defendants as a result of their

infringing acts alleged above in an amount not yet known, and the costs of this action.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff Michael Kors, L.L.C. respectfully prays that this

Court enter judgment in its favor and against Defendants as follows:

1. A Judgment that Defendants have infringed Michael Kors’s MK Trade

Dress and MK Common Law Trademark and that said infringement was willful;

2. An order granting permanent injunctive relief restraining and enjoining

Defendants, their agents, servants, employees, officers, associates, attorneys, and all

persons acting by, through, or in concert with any of them from infringing upon

Michael Kors’s MK Trade Dress and MK Common Law Trademark, including, but not

limited to:

a. manufacturing, importing, advertising, marketing, promoting,

supplying, distributing, offering for sale, or selling the Infringing Products or any other

products which bear Michael Kors’s MK Block Trade Trade Dress and MK Common

Law Trademark or any designs confusingly similar thereto;

b. engaging in any other activity constituting unfair competition with

Michael Kors, or acts and practices that deceive consumers, the public, and/or trade,

including without limitation, the use of designations and design elements used or

owned by or associated with Michael Kors; and

c. committing any other act which falsely represents or which has the

effect of falsely representing that the goods and services of Defendants are licensed by,


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authorized by, offered by, produced by, sponsored by, or in any other way associated

with Michael Kors;

3. Ordering Defendants to recall from any distributors and retailers and to

deliver to Michael Kors for destruction or other disposition all remaining inventory of

all Infringing Products and related items, including all advertisements, promotional

and marketing materials therefore, as well as means of making same;

4. Ordering Defendants to file with this Court and serve on Michael Kors

within thirty (30) days after entry of the injunction a report in writing, under oath

setting forth in detail the manner and form in which Defendants have complied with

the injunction;

5. Ordering an accounting by Defendants of all gains, profits and advantages

derived from their wrongful acts pursuant to 15 U.S.C. § 1117(a);

6. Awarding Michael Kors all of Defendants’ profits and all damages

sustained by Michael Kors as a result of Defendants’ wrongful acts, and such other

compensatory damages as the Court determines to be fair and appropriate;

7. Awarding enhanced damages in the Court’s discretion as a result of

Defendants’ willful infringement;

8. Finding that this is an exceptional case under 15 U.S.C. § 1117 and

awarding attorneys’ fees there under;

9. Awarding applicable interest, costs, disbursements and attorneys’ fees;

10. Awarding Michael Kors punitive damages in connection with its claims

under California state and common law; and

11. Such other relief as may be just and proper.

Dated: February 9, 2017 BLAKELY LAW GROUP

By: /s/ Cindy Chan___________ Brent H. Blakely Cindy Chan Attorneys for Plaintiff Michael Kors, L.L.C.


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DEMAND FOR JURY TRIAL

Pursuant to Rule 38(b) of the Federal Rules of Civil Procedure, Plaintiff Michael

Kors, L.L.C. hereby demands a trial by jury as to all claims in this litigation.

Dated: February 9, 2017 BLAKELY LAW GROUP

By: /s/ Cindy Chan___________ Brent H. Blakely Cindy Chan Attorneys for Plaintiff Michael Kors, L.L.C.


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