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JS 44C/SDNYREV. 4/2012
CIVIL COVER SHEET
The JS-44 civil cover sheet and the information contained herein neither replace norOTPplement tfieTilin? and serviipleadings or other papers as required by law, except as provided by local rules of court. This form, approved t?Judicial Conference of the United States in September 1974, is required for use of the Clerk of Court for the purpose ofinitiating the civil docket sheet.
417 oPLAINTIFFS
CROWN AWARDS, INC.
DEFENDANTS
TROPHY DEPOT, INC., JAMES O'BOYLE and HOWARD BECKER
ATTORNEYS (FIRM NAME,ADDRESS, AND TELEPHONE NUMBERRichard Lehv, Esq., Emily Weiss, Esq.FROSS ZELNICK LEHRMAN & ZISSU, P.C.866 U.N. Plaza, New York, NY 10017, Tel: (212) 813-5900
ATTORNEYS (IF KNOWN) FEB 18201*CAUSEOF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE ABRIEF STATEMENT OFCAUSE)Claimsfor copyrightinfringemenfunder tiecbon 108 ofthe UnitedStates CopyngntAct of 1976, as amended (the "Copyright Act"), 17 U.S.C. 106; unfaircompetitionunder Section43(a) of the United States TrademarkActof 1946, as amended (the "Lanham Act"), 15 U.S.C. 1125(a);trademark infringement under Section 32(1)ofthe LanhamAct, 15 U.S.C. 1114(1);false advertising under Section 43(a)(1)(B)of the Lanham Act, 15 U.S.C. 1125(a)(1)(B); and related claims under NewYork's statutory and common law.
Has thisora similar case been previously filed inSDNY at any time?No |x] Yes Judge Previously AssignedIf yes,was thiscase Vol. | | Invol. | | Dismissed. No Q Yes Q If yes,give date & Case No.IS THIS AN INTERNATIONAL ARBITRATION CASE? No
(PLACEAN [x] IN ONE BOX ONLY)TORTS
Yes D
NATURE OF SUIT
ACTIONS UNDER STATUTES
CONTRACT PERSONAL INJURY PERSONAL INJURY FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
[ 1110 INSURANCE U310 AIRPLANE [ ]362 PERSONAL INJURY - [ ]610 AGRICULTURE [ ]422 APPEAL [ J400 STATE[ 1120 MARINE []315 AIRPLANE PRODUCT MED MALPRACTICE [ ]620 OTHER FOOD & 28 USC 158 REAPPORTIONMENT[ M30 MILLER ACT LIABILITY [ ]365 PERSONAL INJURY DRUG [ ]423 WITHDRAWAL [ ]410 ANTITRUST[ ]140 NEGOTIABLE [ ]320 ASSAULT, LIBEL & PRODUCT LIABILITY [ ]625 DRUG RELATED 28 USC 157 [ ]430 BANKS & BANKING
INSTRUMENT SLANDER [ ]368 ASBESTOS PERSONAL SEIZURE OF [ ]450 COMMERCE[ ]150 RECOVERY OF [ ]330 FEDERAL INJURY PRODUCT PROPERTY [ ]460 DEPORTATION
OVERPAYMENT & EMPLOYERS' LIABILITY 21 USC 881 PROPERTY RIGHTS I I 470 RACKETEER INFLUENFORCEMENT LIABILITY [ )630 LIQUOR LAWS ENCED & CORRUPTOF JUDGMENT [ ]340 MARINE PERSONAL PROPERTY [ I 640 RR & TRUCK P
(PLACEAN x IN ONE BOX ONLY)
H 1 Original 2 Removed fromProceeding state Court
I [ 3. all parties represented
| I b. At least oneparty is pro se.
ORIGIN
3 Remanded LZI 4 Reinstated orfrom ReopenedAppellateCourt
| I 5 Transferred from r_| 6 Multidistrict(Specify District) Litigation
II 7 Appeal toDistrictJudge fromMagistrate JudgeJudgment
(PLACEAN x IN ONEBOXONLY) BASIS OF JURISDICTION 1 U.S. PLAINTIFF Q2 U.S. DEFENDANT M 3 FEDERAL QUESTION Q4 DIVERSITY
(U.S. NOT A PARTY)
IF DIVERSITY, INDICATECITIZENSHIP BELOW.(28 USC 1322, 1441)
CITIZENSHIP OF PRINCIPAL PARTIES (FOR DIVERSITY CASES ONLY)(Place an [X] in one box for Plaintiff and one box for Defendant)
CITIZEN OF THIS STATE
CITIZEN OF ANOTHER STATE
PTF DEF1 1 CITIZEN OR SUBJECT OF A
FOREIGN COUNTRY
INCORPORATED or PRINCIPAL PLACEOF BUSINESS IN THIS STATE
PTF DEF PTF DEF13 3 INCORPORATED and PRINCIPAL PLACE 5 5
OF BUSINESS IN ANOTHER STATE
4 4 FOREIGN NATION 6 6
PLAINTIFF(S) ADDRESS(ES) AND COUNTY(IES)
Crown Awards, Inc.9 Skyline DriveHawthorne, New York 10532Westchester County
DEFENDANT(S) ADDRESS(ES) AND COUNTY(IES)Trophy Depot, Inc.171 Rodeo DriveEdgewood, New York 11717Suffolk County
James O'BoyleTrophy Depot, Inc.171 Rodeo DriveEdgewood, New York 11717Suffolk County
Howard BeckerTrophy Depot, Inc.171 Rodeo DriveEdgewood, New York 11717Suffolk County
DEFENDANT(S) ADDRESS UNKNOWNREPRESENTATION IS HEREBY MADE THAT, AT THIS TIME, I HAVE BEEN UNABLE, WITH REASONABLE DILIGENCE, TO ASCERTAIN THE
RESIDENCE ADDRESSES OF THE FOLLOWING DEFENDANTS:
Checkone: THIS ACTION SHOULD BEASSIGNED TO: WHITE PLAINS [X] MANHATTAN(DO NOT check either box ifthis a PRISONER PETITION/PRISONER CIVIL RIGHTS COMPLAINT.)
DATE 02/18/2015 SIGNATURE OFATTORNEY/DF RECJBRD
RECEIPT* Richard Z. Lehv
Magistrate Judge is to be designated by the Clerk of the Court. "T';
Magistrate Judge
Ruby J. Krajick, Clerk of Court by Deputy Clerk, DATED
UNITED STATES DISTRICT COURT (NEW YORK SOUTHERN)
ADMITTED TO PRACTICE IN THIS DISTRICTNO -7
y, ^X YES (DATE ADMITTED Mo. JAttorney Bar Code # [email protected]
"' l. kl
is so Designated.
Richard Lehv ([email protected])Emily Weiss ([email protected])FROSS ZELNICK LEHRMAN & ZISSU, P.C.866 United Nations PlazaNew York, New York 10017Tel: (212)813-5900Attorneysfor Plaintiff
UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF NEW YORK
15 '"> 1178
CROWN AWARDS, INC.,
Plaintiff,v.
TROPHY DEPOT, INC.; JAMES O'BOYLE; andHOWARD BECKER,
Defendants.
Civil Action No.
Plaintiff, Crown Awards, Inc., by its attorneys, Fross Zelnick Lehrman & Zissu, P.C, for
its Complaint against Defendants, Trophy Depot, Inc., James O'Boyle, and Howard Becker,
alleges as follows:
SUBSTANCE OF THE ACTION
1. This is an action for blatant and willful copyright infringement and unfaircompetition on a massive scale.
2. Plaintiff designs, manufactures, and sells trophies, medals, and other awards for
sports competitions and other activities and events. Founded in 1978, Plaintiff started as a single
storefront in Brooklyn, and grew into the largest retailer of awards in the country. Plaintiff has its
own staff of designers, who create original designs for an enormous variety of medals, trophies,
and other awards for sporting events and other competitions and occasions.
{F1617946.9 1
3. Defendants, unable or unwilling to design their own trophies, medals, and awards,
have adopted a predatory and unlawful business model, consisting of intentional and wholesale
copying of Plaintiffs products and business. Indeed, whenever Plaintiff releases a new design or
adds a new feature to its website, no matter how idiosyncratic or unusual, Defendants shortly
thereafter do the exact same thing. For example, just last month Plaintiff introduced its newprices, and several weeks later Defendants' website started to show the exact same pricing.
4. Defendants know that their conduct is unlawful, having been enjoined by a federalcourt in 2005 from infringing the copyright in Plaintiffs catalog and ordered to pay Plaintiff
nearly half a million dollars. Despite these penalties and the court's description of Defendants'
conduct as "disturbing," Defendants were undeterred, and they have expanded their infringing
activities to include:
Copying entire lines of products designed by Plaintiff, consisting of hundreds of
individual items. The following are several examples:
Plaintiffs Copyrighted Designs Defendants' Infringing Copies
{F1617946.9 )
J3L
-^ -
{F1617946.9}
Copying the component parts of awards, such as Mylar inserts and neck ribbons,
which can be combined with thousands of medals and other awards. The following
are several examples of inserts copied by Defendants that can be placed on trophies,
medals, and plaques, thereby making the finished trophy or award an infringing work:
Plaintiff's Copyrighted Designs Defendants' Infringing Copies
{F1617946.9 |
TY*
{F1617946.9 }
(F1617946.9 (
The following are four examples of ribbons copied by Defendants that can be
attached to medals, thereby making the finished medal an infringing work:
PlaintifPs Copyrighted Designs Defendants' Infringing Copies
Copying the exact look and feel of Plaintiffs "Trophy Builder" for custom design of
trophies and other awards:
Plaintiff's Copyrighted Design
GrMntfMmnls kssksh -- *
_ Mr T*.y*ur Tiepjhyt
*> B# s
Sgn up to f*o*tai vuMmtm ofhral* [rwJutiii hh| WM-M i*
o
(F1617946.9)
Defendants' Infringing Copy
10-12 Inch Traditional Trophies on Martte 8
;\V.
I'
i
Copying the exact look and feel of Plaintiff s "Engraving Engine" for custom
engraving of awards:
Plaintiffs Copyrighted Design Defendants' Infringing Copy
CwteMPhrMi Si
* >ll 5^r.Q jj /\
\ )_*
Pioi:
(F1617946.9 134
68. As further example of Defendants' willful and blatant copying, shown below are
trophy cups offered by both Plaintiff and Defendants:
Plaintiffs Copyrighted Designs Defendants' Infringing Copies
69. The cups on both Plaintiffs and Defendant's trophies are identical: parallel grooves
encircle the cup underneath a wavy rim, with S-shaped handles that have similar design details.
The bases also are the same. In addition, each sport is represented by the same sculptureboth
soccer cups are adorned with a cleated shoe resting against a soccer ball, and both basketball
cups are adorned with a basketball next to a hoop.
(F1617946.9)35
70. Another example is Defendants' 3D laser crystal blocks, which are nearly identical
to the 3D laser crystal blocks offered by Plaintiff:
Plaintiffs Copyrighted Designs Defendants' Infringing Copies
'mine**msm
|i:'**
{F1617946.9)36
I .
71. The similarities between Plaintiffs and Defendants' awards do not end there. Like
Plaintiff, Defendants offer inserts for use in connection with many different types of awards,
such as trophies, medals, and plaques. Many of Defendants' inserts are substantially similar to
Plaintiffs inserts, as shown below:
Plaintiffs Copyrighted Designs Defendants' Infringing Copies
{F1617946.9 )37
T^m >^%^i ph
w
(F1617946.9)38
(F16I7946.9 }39
SKII
{F1617946.9 |40
{F1617946.9|41
72. Finally, many of Defendants' medal neck ribbons are substantially similar to those
designed, created, and copyrighted by Plaintiff. Each of Defendants' neck ribbons can be
attached to any of its medals. Thus, Defendants' infringing neck ribbons can be paired with any
ofthe medals that Defendants offer for sale. One example of Defendants' blatant copying of
Plaintiffs neck ribbon is their year neck ribbon. In 2014, Plaintiff released a new neck ribbon,
which displayed the year vertically, as shown below. Prior to 2014, Plaintiff, like every other
awards retailer, including Defendants, displayed the year horizontally on its neck ribbons. This
year, however, Defendants released a new neck ribbon with the year displayed vertically, as
shown below. Defendants immediately copied Plaintiffs protected neck ribbon.
{F1617946.9 )42
Plaintiffs Copyrighted Design Defendants' Infringing Copy
73. Defendants' copying of other neck ribbons of Plaintiff is shown below:
Plaintiffs Copyrighted Designs Defendants' Infringing Copies
{F1617946.9 143
RIBBON CLOSE UP
{F1617946.9} 44
&V4
%
{F1617946.9 [45
74. The above are just several examples of Defendants' practice of intentionally copyingPlaintiffs protected awards, inserts, and ribbons, and manufacturing and offering for sale such
copies in violation of Plaintiff s exclusive rights under the copyright law. Attached as Exhibit Qare more examples of Plaintiff s awards, inserts, and ribbons shown side-by-side with
Defendants' infringing awards, inserts, and neck ribbons.
2. Defendants' Infringing Product Lines
75. Defendants have offered for sale and sold product lines that reflect a selection,
coordination, and arrangement that is substantially similar to Plaintiffs. Defendants have
intentionally copied Plaintiffs selection, coordination, and arrangement in its product lines.
76. For example, both Plaintiff and Defendants offer a line of 3D laser crystal blocks, as
shown below:
{F1617946.9I46
Plaintiffs Copyrighted Line Defendants' Infringing Line
VH sAti' !
u,4fSk I
1 I% "i*
77. Defendants have selected the same activities for their 3D laser crystal product line as
Plaintiff. Moreover, Defendants use an image for each activity that is substantially similar to the
image used by Plaintiff for the same activity. Thus, this copying represents the exact same
selection, coordination and arrangement as on Plaintiffs website and is conclusive evidence of
willful infringement.
78. Defendants also have copied Plaintiffs crystal awards. Plaintiffs crystal awards
come in various shapes, all of which were selected, coordinated, and arranged by Plaintiff to
(F1617946.9!47
create the crystal product line. As shown below, ofthe thousands of shapes available,
Defendants offer for sale a crystal product line that uses the same shapes as Plaintiffs line:
Plaintiffs Copyrighted Line Defendants' Infringing Line
^^^
'"HI
(FI6I7946.9)48
{F16I7946.9 }
/Lifii
i
49
79. These are just some examples ofthe substantial similarity resulting fromDefendants' willful copying of Plaintiffs selection, coordination, and arrangement in its product
lines. Attached as Exhibit R are more examples of Plaintiff s protected product lines shown
side-by-side with Defendants' infringing product lines.
3. Defendants' Infringing Website
80. The overall look and feel of Defendants' website is substantially similar to that of
Plaintiffs website. Moreover, Defendants' website incorporates the elements that make up
Plaintiffs Website Trade Dress, thereby making consumer confusion likely. Attached as Exhibit
S hereto are several pages from Plaintiffs website side-by-side with the equivalent pages from
Defendants' website.
81. As shown in Exhibit S, the similarities between the websites can been seen on many
pages, including the homepages, the pages showing a category of awards (such as trophies ormedals), the individual product pages, the "About Us" pages, the catalog order form pages, thepolicy pages, and the pages showing the various activities and occasions for which awards can be
purchased. For example, just as Plaintiff uses two search boxes in on its website (one at the topright and the other below the first at the left margin), Defendants use two search boxes on theirwebsite (one at the top right and the other below the first on the left.) There is no need for awebsite to have two search boxes on the home page and few other websites have two.
Defendants appear to have used two search boxes simply because they slavishly copy whatever
Plaintiff does.
82. Similarly, Defendants' home page shows its main categories of products in four
columns, just like Plaintiffs home page. And when the customer clicks on one of those productcategories on either website, the customer is taken to a page that shows the individual products in
the category in a nearly identical four-column array, and both websites have links to product
subcategories in the left margin. The similarities are so close that, if the customer has both web
{F1617946.9 |50
pages open at the same time, it is hard to tell which one the customer is looking at any given
moment.
83. There are numerous other similarities in the text on the website. For example,
Plaintiffs history on its website has a photograph of its facility and says, "Crown Awards is
America's leading supplier ofawards for corporate businesses and youth sports. Founded by
Chuck Weisenfeld in 1978, Crown started as from a single store front operation in Brooklyn,
New York and blossomed into the largest retailer of awards in the country... . Crown started its
business as a small trophy shop and has grown to our current 250,000 square foot facility in
Hawthorne, New York." Copying that, Defendants include a photograph of their facility and the
following statements, "From our humble beginnings as a small trophy shop in Queens, NY toone ofthe largest trophy & award suppliers in the world.... 2011: Trophy Depot expands and
Moves again to Edgewood, NY to a beautiful 51,000 sq. ft. facility, with a staff of over 120
people."
84. These similarities between the parties' respective websites are the result of
Defendants' intentional copying of Plaintiff s website.
4. Defendants' Infringing Customization Programs
85. Plaintiffs Trophy Builder and Engraving Engine are unique to Plaintiff. While
many of Plaintiffs competitors also offer customization options, none, except Defendants,
present and display their customization programs using the same visual design for the user
interface. The unique look and feel ofthe Trophy Builder and Engraving Engine is the result of
Plaintiffs investment of time and resources into their development. A team of employees with
knowledge of website and database development determined what type of user interfaces would
provide the customer with an easy and positive experience customizing awards on Plaintiffs
website, and then that team set out to create such designs.
86. Defendants, like Plaintiff, provide customers the option of building their own awards
and engraving personalized text onto awards. The overall look and feel of Defendants' awards
51
builder and engraving programs is substantially similar to that of Plaintiff s Trophy Builder and
Engraving Engine, respectively. Attached as Exhibit T are pages showing Plaintiffs Trophy
Builder and Engraving Engine side-by-side with Defendants' infringing customization user
interface. As shown in this exhibit, a customer who uses Defendants' customization program
encounters the same user interface as a customer who uses Plaintiffs Trophy Builder and
Engraving Engine.
87. Defendants intentionally copied Plaintiffs Trophy Builder and Engraving Engine.
Such copying allowed Defendants to freeload off of Plaintiff by saving time, money, and effort
in developing their own customization designs.
5. Defendants' Use ofIdentical Price Break Displays
88. Attached as Exhibit U are pages showing Plaintiffs 2014 and 2015 price breaks
compared with Defendants' 2014 and 2015 price breaks. As shown in this exhibit, Defendants
display price breaks and prices per unit within each break that are virtually identical to the
designs created by Plaintiff. Thus, Defendants' selection, coordination, and arrangement of its
price breaks and prices, as well as the overall look and feel of their presentation, are substantially
similar to the look and feel of Plaintiffs displays.
89. Defendants intentionally copied the selection, coordination, and arrangement of
Plaintiffs price breaks and the overall look and feel of Plaintiff s presentation of its pricing
information. As evidence of such intentional copying, on January 15, 2015, Plaintiff updated its
price breaks, and shortly thereafter, Defendants came out with the same revised price breaks.
See Ex. U (2015 price breaks).
6. Defendants' Infringing Blue Packaging
90. Like Plaintiff, Defendants' awards are packaged in blue boxes. Attached as Exhibit
V are images showing Plaintiffs presentation packaging and Defendants' presentation packaging
side-by-side. As shown in these images, Defendants' packaging incorporates all ofthe elements
{F1617946.9 |52
of Plaintiffs Packaging Trade Dressboth rectangular boxes are royal blue with a satin interior,
and the companies' logos are printed in gold on both.
91. Such similarities are the result of a deliberate attempt by Defendants to attract
customers by using the goodwill in Plaintiffs Packaging Trade Dress.
7. Defendants' False Advertising
92. Defendants prominently advertise on their website that they offer "Same-day
Shipping" on engraved trophies and medals if such awards are ordered before 4:00 P.M. on
business days. See homepage of Defendants' website showing same-day shipping
advertisement, attached hereto as Exhibit W. Buried within Defendants' website, however, is
fine-print text that states that same-day shipping is not available in April, May, June, or October.
See screenshot of Defendants' website showing shipping policies, attached hereto as Exhibit X.
Defendants do not remove the same-day shipping advertisement from their website during those
months. Attached as Exhibit Y hereto is a screenshot from Defendants' website showing the
same-day shipping advertisement prominently featured on their website in June, one ofthe
months in which same-day shipping is not offered. Thus, the "Same-Day Shipping" claim is
blatantly false.
93. Plaintiff has an interest in making sure that consumers are not deceived as to
Defendants' ability to provide same-day shipping. As a result of Defendants' misrepresentation
that they offer "Same-day Shipping," consumers are more likely to purchase awards from
Defendants than if Defendants did not claim to offer that benefit to consumers.
94. Plaintiff has invested heavily in being able to offer same-day shipping to its
customers. Efforts taken by Plaintiff include building a large warehouse, carrying massive
inventories, and hiring many employees to fulfill orders, all of which have required exerting
significant time and resources.
95. The only reason that Defendants claim to offer same-day shipping is that Plaintiff
offers it. Defendants added the same-day shipping advertisement to their site immediately after
{FI617946.9)53
Plaintiff began to advertise it. Thus, Defendants' misrepresentation is a deliberately deceptive
attempt to misrepresent their ability to provide same-day shipping to compete unfairly with
Plaintiff.
96. Defendants' conduct is intended to mislead consumers. Defendants lure consumers
to their site on the promise of same-day shipping when they know that they are not able to
deliver on such a promise. In fact, Defendants even allow customers to place orders for
thousands of pieces of obscure items, promising same-day shipping on such obscure items,
despite having knowledge that they could not possibly provide same-day shipping on these
products because they do not have them in stock. On information and belief, Defendants call
such customers the next day informing them that the promised same-day shipping cannot be
honored. Such bait-and-switch tactics are misleading to consumers.
8. Defendants' Use of "CrownAwards "as Keyword
97. On information and belief, Defendants have purchased "Crown Awards" as a
keyword on Google's search engine. As a result, a Google search for "Crown Awards" yields a
paid advertisement for Trophy Depot. See Exhibit Z attached hereto, showing paid
advertisement for Trophy Depot resulting from Google search for "Crown Awards."
98. On information and belief, Defendants have purchased the "Crown Awards"
keyword to confuse and deceive consumers about the affiliation, connection, or association
between Defendants and Plaintiff, or as to Plaintiffs sponsorship or approval of Defendants'
goods, services, or commercial activities.
* * *
99. The conduct described in the Complaint amounts to copying of every aspect of
Plaintiffs business. Defendants have copied entire lines ofproducts, individual product and
component designs, the selection, coordination, and arrangement of products on the website, the
display ofpricing ofthe products, and the look and feel ofthe website pages that allow the
products to be designed (Trophy Builder) and customized (Engraving Engine). Indeed, a
(F1617946.9) 54
customer cannot order an award from Defendants without encountering an infringing aspect of
Defendants' business. As a result, the only way for these recidivist Defendants to stop their
infringing conduct is to redesign their entire business, including their website, from scratch, and
stop selling all their infringing products.
FIRST CLAIM FOR RELIEFCOPYRIGHT INFRINGEMENT IN VIOLATION OF 17 U.S.C. 106
100. Plaintiff repeats and incorporates herein by reference each ofthe foregoing
allegations.
101. Plaintiffs awards, product lines, catalog, website, and Trophy Builder and
Engraving Engine programs (collectively, the "Copyrighted Works") are original and creative
works of Plaintiff. Plaintiff is the owner of all right, title, and interest in and to the copyright in
the Copyrighted Works and own the copyrights registrations for the same.
102. Defendants, without Plaintiffs authorization or consent, have willfully
manufactured, displayed, advertised, reproduced, distributed, imported, offered for sale, and sold
products incorporating designs that were copied from and are substantially similar to Plaintiffs
awards.
103. Defendants, without Plaintiffs authorization or consent, have willfully
manufactured, displayed, advertised, reproduced, distributed, imported, offered for sale, and sold
product lines incorporating a selection, coordination, and arrangement of elements that was
copied from and is substantially similar to the selection, coordination, and arrangement reflected
in Plaintiffs product lines.
104. Defendants, without Plaintiffs authorization or consent, have displayed, advertised,
and reproduced the design and content of Plaintiffs website, including the Trophy Builder and
Engraving Engine. As such, Defendants' website has the same overall look and feel as
Plaintiffs website, and reflects the same selection, coordination and arrangement of elements as
Plaintiffs website, including the Trophy Builder and Engraving Engine.
(FI617946.9 155
t105. Defendants thereby have violated and, on information and belief, continue to
violate, Plaintiffs exclusive rights in the Copyrighted Works under Section 106 ofthe Copyright
Act, 17 U.S.C. 106, in violation of Section 501 ofthe Copyright Act, 17 U.S.C. 501.
106. On information and belief, Defendants' aforesaid conduct has been undertaken
knowingly, willfully, and in bad faith.
107. Defendants' infringement of Plaintiff s exclusive rights in the Copyrighted Works
has enabled Defendants to profit illegally therefrom.
108. Defendants' copyright infringement has caused, and unless enjoined by this Court,will continue to cause, Plaintiff to sustain irreparable damage, loss, and injury, for whichPlaintiff has no adequate remedy at law.
SECOND CLAIM FOR RELIEF:TRADE DRESS INFRINGEMENT
IN VIOLATION OF 15 U.S.C. 1125(a)109. Plaintiff repeats and incorporates herein by reference each ofthe foregoing
allegations.
110. Plaintiffs Website Trade Dress is used in commerce, is non-functional, and is
inherently distinctive or has acquired secondary meaning as the indicator of Plaintiff as the
exclusive source ofproducts containing or incorporating such design.
111. Defendants have adopted the Website Trade Dress and have, without Plaintiffs
authorization or consent, used the Website Trade Dress or designs that are confusingly similar
thereto on Defendants' own website.
112. Plaintiffs Packaging Trade Dress is used in commerce, is non-functional, and is
inherently distinctive or has acquired secondary meaning as the indicator of Plaintiff as the
exclusive source of products containing or incorporating such design.
113. Defendants have adopted the Packaging Trade Dress and have, without Plaintiffs
authorization or consent, used the Packaging Trade Dress or designs that are confusingly similar
thereto on Defendants' own packaging.
{F1617946.9) 56
114. Defendants' conduct is likely to cause confusion, cause mistake, or deceive as to the
affiliation, connection, or association between Defendants and Plaintiff, or as to Plaintiffs
sponsorship or approval ofDefendants' goods, services, or commercial activities.
115. As a result ofthe foregoing, Defendants have falsely designated the origin of their
website, all in violation of Section 43(a) ofthe Lanham Act, 15 U.S.C. 1125(a).
116. On information and belief, Defendants' aforesaid conduct has been undertaken
knowingly, willfully, and in bad faith.
117. Defendants' aforesaid conduct has caused, and unless enjoined by this Court, willcontinue to cause, Plaintiff to sustain irreparable damage, loss, and injury, for which Plaintiff hasno adequate remedy at law.
THIRD CLAIM FOR RELIEF:TRADEMARK INFRINGEMENT IN VIOLATION OF 15 U.S.C. 1114(1)118. Plaintiff repeats and incorporates herein by reference each ofthe foregoing
allegations.
119. Over many years of extensive use in connection with the sale of awards, Plaintiffs
federally registered CROWN AWARDS mark has become well-known in the industry
nationwide. Plaintiff has established a strong reputation and substantial goodwill by reason of its
success and reputation.
120. Defendants' actions described above, including its use of CROWN AWARDS as a
Google keyword, are likely to cause confusion and mistake and to deceive consumers into
believing that Defendants' goods and services are provided, authorized, endorsed, or sponsored
by Plaintiff, thereby damaging Plaintiffs reputation, goodwill, and sales.
121. Defendants' conduct described herein is willful and violates Section 32(1) ofthe
Lanham Act, 15 U.S.C. 1114(1).
122. Defendants' aforesaid conduct has caused, and unless enjoined by this Court, willcontinue to cause, Plaintiff to sustain irreparable damage, loss, and injury, for which Plaintiff hasno adequate remedy at law.
(F1617946.9) 57
FOURTH CLAIM FOR RELIEF:FALSE ADVERTISING IN VIOLATION OF 15 U.S.C. 1125(a)(1)(B)
123. Plaintiff repeats and incorporates herein by reference each ofthe foregoing
allegations.
124. Defendants advertise on their website that they offer "Same-day Shipping," but they
in fact do not offer same-day shipping at least four months out ofthe year.
125. Defendants' representation all year round that they offer "Same-day Shipping" is a
false and misleading description of fact and a false and misleading representation of facts in
commercial advertising or promotion that misrepresents the nature, characteristics, or qualities of
Defendants' products, services, and commercial activities.
126. On information and belief, Defendants made this false and misleading
representation of fact to lure consumers to Defendants' Website.
127. Defendants have placed both their false and deceptive advertising and the goods
sold as a result of such deceptive advertising in interstate commerce and into this district.
128. Defendants' conduct described herein is willful and violates Section 43(a)(1)(B) of
the Lanham Act, 15 U.S.C. 1125(a)(1)(B).
129. Defendants' aforesaid conduct has caused, and unless enjoined by this Court, willcontinue to cause, Plaintiff to sustain irreparable damage, loss, and injury, for which Plaintiff hasno adequate remedy at law.
130. Defendants' conduct as described herein is also harming the public.
FIFTH CLAIM FOR RELIEF:COMMON LAW TRADE DRESS INFRINGEMENT
131. Plaintiff repeats and incorporates herein by reference each ofthe foregoing
allegations.
132. Defendants' aforesaid conduct constitutes common law trade dress infringement
under the common law ofthe State of New York.
{F1617946.9J 58
133. Defendants' aforesaid conduct of common law trade dress infringement has caused,
and unless enjoined by this Court, will continue to cause, Plaintiff to sustain irreparable damage,loss, and injury, for which Plaintiff has no adequate remedy at law.
SIXTH CLAIM FOR RELIEF:COMMON LAW UNFAIR COMPETITION
134. Plaintiff repeats and incorporates herein by reference each ofthe foregoing
allegations.
135. Defendants' aforesaid conduct constitutes common law unfair competition with
Plaintiff under the common law ofthe State of New York.
136. Defendants' aforesaid conduct of common law unfair competition has caused, and
unless enjoined by this Court, will continue to cause, Plaintiff to sustain irreparable damage, loss,and injury, for which Plaintiff has no adequate remedy at law.
SEVENTH CLAIM FOR RELIEF:DECEPTIVE TRADE PRACTICES
IN VIOLATION OF NEW YORK GENERAL BUSINESS LAW 349137. Plaintiff repeats and incorporates herein by reference each ofthe foregoing
allegations.
138. By reason ofthe acts set forth above, Defendants have been and are engaged in
deceptive acts or practices in the conduct of a business, trade, or commerce, in violation of
Section 349 ofthe New York General Business Law.
139. On information and belief, through such deceptive acts, Defendants have engaged
in consumer-oriented conduct that has affected the public interest of New York and has resulted
in injury to consumers and harm to the public in the state ofNew York.140. On information and belief, Defendants' conduct is willful and in knowing disregard
of Plaintiffs rights.
(F1617946.9)59
141. Defendants' aforesaid conduct has caused, and unless enjoined by this Court, willcontinue to cause, Plaintiff to sustain irreparable damage, loss, and injury, for which Plaintiff hasno adequate remedy at law.
WHEREFORE, Plaintiff demands judgment as follows:1. That a permanent injunction be issued enjoining Defendants, any of their respective
officers, agents, privies, shareholders, principals, directors, licensees, attorneys, servants,
employees, affiliates, subsidiaries, successors, and assigns, and all those persons in concert or
participation with any of them who receive actual notice ofthe order by personal service or
otherwise, from:
(a) infringing any of Plaintiffs copyrights, including, without limitation, by
manufacturing, reproducing, importing, distributing, displaying, advertising, promoting, offering
for sale, selling, distributing, importing, or exporting any infringing works, or by operating any
website or customization program that is substantially similar in overall look and feel to the
website and customization programs of Plaintiff or that copy Plaintiffs selection, arrangement,
and coordination ofproducts, displays and other elements;
(b) imitating, copying, or making unauthorized use ofthe Website Trade Dress and
Packaging Trade Dress, including, without limitation, by reproducing, importing, displaying,
advertising, or promoting any website or packaging bearing the Website Trade Dress or
Packaging Trade Dress, respectively, or any other design that is confusingly similar to the
Website Trade Dress or Packaging Trade Dress;
(c) using any false designation of origin or false description or performing any actthat can or is likely to lead members ofthe trade or public to believe that Defendants are
associated with Plaintiff or that any product manufactured, distributed, advertised, displayed,
promoted, offered for sale, sold, imported, or exported by Defendants is in any manner
associated or connected with Plaintiff, or is authorized, licensed, sponsored, or otherwise
approved by Plaintiff;
(F1617946.9 )60
(d) infringing the CROWN AWARDS mark, including but not limited to use as a
keyword for advertising;
(e) using the CROWN AWARDS mark, or any derivation or colorable imitationthereof, or any name or mark that is confusingly similar to the CROWN AWARDS mark, on or
in connection with Defendants' goods or services;
(f) using any false or misleading representations of fact, or performing any act, whichcan, or is likely to, lead members ofthe trade or public to hold false beliefs concerning the
nature, qualities, or characteristics of Defendants' goods or services;
(g) engaging in any other activity constituting unfair competition with Plaintiff or
false advertising, or constituting an infringement of Plaintiffs copyrights or trade dresses; and
(h) assisting, aiding, or abetting any other person or business entity in engaging in or
performing any ofthe activities referred to in subparagraphs (a) through (g) above or taking any
action that contributes to any ofthe activities referred to in subparagraphs (a) through (g) above.2. Directing that Defendants turn over to Plaintiff for impoundment and eventual
destruction or other disposition, without compensation to Defendants, all materials in their
possession or control that violate the provisions of paragraphs l(a)-(h) above, along with all
articles by means of which such unauthorized copies may be reproduced.
3. Directing that Defendants, at their own expense, recall from any distributors, retailers,
vendors, or others to whom it has distributed materials that violate the provisions of paragraph
l(a)-(h) above, and that Defendants deliver up to Plaintiff for destruction or other disposition allmaterials returned to them.
4. Directing that Defendants, pursuant to 15 U.S.C. 1116(a), file with the Court andserve upon Plaintiff, within thirty (30) days ofthe entry of injunction prayed for herein, a writtenreport under oath or affirmed under penalty of perjury setting forth in detail the form and mannerin which it has complied with the permanent injunction.
IF1617946.9 )61
5. That Plaintiff be awarded monetary relief, including Defendants' profits, as provided
by 17 U.S.C. 504(b), or statuary damages as Plaintiff may elect as provided by 17 U.S.C. 504(c).
6. That Plaintiff be awarded monetary relief, including Defendants' profits, trebled or
increased as provided by 15 U.S.C. 1117(a); and punitive, exemplary or enhanced damages asprovided for under applicable law.
7. Granting Plaintiff its full costs, including, as part of such costs, reasonable attorneys'
fees pursuant to 15 U.S.C. 1117 and/or 17 U.S.C. 505;
8. That Plaintiff be awarded interest, including pre-judgment interest, on the foregoingsums.
9. That Plaintiff be awarded such other and further relief as the Court may deem just andproper.
FROSS ZELNICK LEHRMAN & ZISSU, P.C.Dated: February 18, 2015
{F1617946.9)
By_ AjttLA^iUL,JUL.Lichard Lehv
Emily Weiss866 United Nations PlazaNew York, New York 10017Tel: (212) 813-5900rlehv@frosszelnick. [email protected]
Attorneysfor Plaintiff
62
EXHIBIT A
CUT OUT STAR RIM MEDALHOLDS 2" INSERT
YEARLY BLANK MEDAL
YEARLY BLANK MEDAL
FOOTBALL INSERT MEDALHOLDS 2" INSERT
GYM INSERT MEDALHOLDS 2" INSERT
BASKETBALL INSERT MEDALHOLDS 2" INSERT
BASEBALL INSERT MEDALHOLDS 2" INSERT
CHEER INSERT MEDALHOLDS 2" INSERT
SOCCER INSERT MEDALHOLDS 2" INSERT
TRACK INSERT MEDALHOLDS 2" INSERT
WRESTLING INSERT MEDALHOLDS 2" INSERT
5K 2" 3D MEDALS
GOLD, SILVER, BRONZE 2" 3D MEDALS
HIP HOP 2" 3D MEDALS
MUD RUN 2" 3D MEDALS
PIANO 2" 3D MEDAL
RACING 2" 3D MEDALS
READING 2" 3D MEDAL
SPORTMANSHIP 2" 3D MEDALS
SPORTSMANSHIP*
SPORTSiViMSHIP
STAR PERFORMER 2" 3D MEDAL
jf+*%i
ERFORME
PAW PRINT 2" 3D MEDALS
SILVER GLITTER RIM INSERT MEDALHOLDS 2" INSERT
LARGE HIP HOP "TAGS"
?
ft
it
?
GYMNASTICS SATEEN NECK RIBBON
RIBBON CLOSE UP
DANCE SATEEN NECK RIBBON
RIBBON CLOSE UP
CHEER SATEEN NECK RIBBON
RIBBON CLOSE UP
SWIM SATEEN NECK RIBBON
RIBBON CLOSE UP
POP OUT STAR ACRYLIC
/ 1 LJBLJ
l t'.n'!11 n'.iid
'i fvj I !v-II :-':-II,:, i- ' *y-Y
STAR PERFORMER3D LASER CRYSTAL
GYM 3D LASER CRYSTAL
WRESTLING 3D LASER CRYSTAL
TORCH 3D LASER CRYSTAL
SOCCER DIAMOND PLAQUE
BASKETBALL DIAMOND PLAQUE
FOOTBALL DIAMOND PLAQUE
P&\ %l "W W% JH I Iill! 1 HIIS 1
W
BASKETBALL STAND UP PLAQUE
BASEBALL STAND UP PLAQUE
SOCCER STAND UP PLAQUE
FOOTBALL STAND UP PLAQUE
CLEAR TROPHIESHOLDS 2" INSERT
BASKETBALL COLUMN TROPHY
I
W,1!MtAi
ft.-/
SOCCER COLUMN TROPHY
FOOTBALL COLUMN TROPHY
BASEBALL COLUMN TROPHY
BASEBALL CUP SCULPTURE
SOCCER CUP SCULPTURE
BASKETBALL CUP SCULPTURE
EXHIBIT B
Certificate ofRegistraUonsS*.
/^Io^uLJk. f-^fajj-
Previous 0rAlfTit,:0fW0rk:'^ medals^vious or Alternative Title- 2013 ne
Completion/Publication '""** *"** ***"imm'ribbed insert-Vear ofCompletion: 2012
Author . N"" ''' pwicu: Un[,ed Ste,esAn Crom,Arards.lnc
An"rCre"e* PhMW
1
H^rfteB #: VAOOOl 850985Service *** 1-887253017
Crown Awards, Inc.Elyse Weisenfeld
FORM CA RECEIVED
FUNDS RECEIVED DATE
EXAMINED BY
CORRESPONDENCE
REFERENCE TO THIS REGISTRATION ADDED TOBASICREGISTRATION YES Q NO
DONOTWRITE ABOVE THIS LINE. IFYOU NEEDMORE SPACE, USE A SEPARATE CONTINUATION SHEET.
Continuation of: Q Part B or Q Part C
Correspondence: Give name and addressto whichcorrespondence aboutthisapplication shouldbesent
Phone QH^)MlLlM^^i2^L Fax, ) Em
FORM CA
FORCOPYRIGHT
OFFICEUSE
ONLY
%
coMDeposit Account: Iftheregistration fee is tobe charged to a Deposit Account established in theCopyright Office, give name and numberofAccount.Name
Account Number _
Certification* I, the undersigned, hereby certify that 1am the: (Checkonly one)author Downer ofexclusive right(s)other copyright claimant Qauly authorized agent of Cg^vNNi AajM/VF-P^, JNo .
Name ofauthoror othercopyright claimant, or owner ofexclusive right(s) of the work identified in this applicationand that the statements made by me in this applicationare conect to the best of my knowledge.
Typed or printed name g(z.\to AtopR-gyv^
Handwritten signature
Certificatewill bemailed inwindowenvelopeto thisaddress:
eu-v|4e \ajvs6*vjf&ue>Number/Street/Apt
City/SlaleCIP T
=fc
DateVjp\2.\ JEfrfe.
1. Application form2. Nomefundabts tiling fee in check or
money otdor payable lo Register ofCopyright*
Library ot CongressCopyright OMiceirji Independence Avcmjfi SirWashington DC 20559-6000
*17 L/SC506(e): Any parsonwhoknowingly makesatalse representational a material (aclinthe applicalion lorcopyrighl registralion provided forbysection409,or inanywritten statementtiledinconnectionwiththe application, shall be lined not more than $2,500
Form CA-Full Rev 07/2006 Print: 07/2006,000 Printed on recycled paper U S Government Printing Office; 2006 /,
Certificate ofRegistrationri>-l?* This Certificate issued under the seal ofthe Copyright
Office in accordance withtitle17, United States Code,attests that registration has been made for the workidentified below. The information on this certificatehasbeen made a partofthe Copyright Office records.
1870
Title
/TicuuL A- i^jtt****jLRegisterof Copyrights,United Statesof America
Registration Number
VA 1-815-363Effective date of
registration:
February 17,2012
Title ofWork: Insert MedalsPrevious or Alternative Title: Diamond Cut, Gold Shooting Star, Black Shooting Star, Galaxy Star, 2012
double action
Completion/Publication
Author
Year of Completion: 2011Dateof 1st Publication: January 28, 2012
Author: CrownAwards, Inc.
Author Created: sculpture
Work made for hire: YesDomiciled in: United States
Nation of 1st Publication: United States
Copyright claimantCopyright Claimant: Crown Awards, Inc.
9 Skyline Drive, Hawthorne, NY, 10532, United States
CertificationName: Elyse WeisenfeldDate: February 17,2012
Correspondence: Yes
Page 1 of 1
Registration #: VA0001815363Service Request #: 1-726768699
Crown Awards, Inc.Elyse Weisenfeld9 Skyline DriveHawthorne, NY 10532 United States
Certificate ofRegistrationi**.
1870
Title
This Certificate issued under the seal ofthe CopyrightOffice inaccordance with title 17, United States Code,attests that registrationhas been made for the workidentified below. The information on this certificatehasbeen made a partofthe Copyright Office records.
^(SfeoRegisters Copyrights, United States of America
Registration Number:
VA 1-639-384
Effective date ofregistration:
March 18.2008
Title of Work: Insert Medals
Previous or Alternative Title: 2-1/2" star insert knock out, 2-1/2" Venetian insert, 3" star insert knock out2008 insert '
Natu re ofWork: Medals
Completion/Publication
Author
Yearof Completion: 2007
Dateof1stPublication: January 28.2008
Author: CrownAwards, Inc.
Author Created: 3-Dimensional sculpture
Work made for hire: YesDomiciled in: United States
Nation of 1st Publication: United States
Copyright claimantCopyrightClaimant: Crown Awards, Inc.
9 Skyline Drive, Hawthorne, NY, 10532
Limitation of copyright claimPreviously registered: No
Certification
Name: Elyse WeisenfeldDate: March 14,2008
Correspondence: Yes
Page 1of I
IPN#:
Registration*: VA0001639384
Service Request*: 1-57995469
Crown Awards, Inc. jElyse Weisenfeld I9 Skyline Drive iHawthorne, NY10532 |
I
Certificate ofRegistrationt>-*. This Certificate issued under theseal oftheCopyright
Officein accordance with title 17, United States Code,attests that registration has been made for the workidentified below. The information on this certificate hasbeenmadea part ofthe Copyright Office records.
Title
TlLuL A *hkA*JGtRegister of Copyrights, UnitedStates ofAmerica
Title ofWork: 3" Double Action MedalsPrevious or Alternative Title: Swimming ,2013 Double action
Completion/Publication
Registration Number
VA 1-849-588Effective date of
registration:
February 4,2013
Year of Completion: 2012Date of 1st Publication: January 30, 2013 Nation of 1st Publication: United States
Author Author: Crown Awards, Inc.
Author Created: sculpture
Work made for hire: Yes
Domiciled in: United States
Copyright claimantCopyright Claimant: Crown Awards, Inc.
9 Skyline Drive, Hawthorne, NY, 10532, United States
CertificationName: Elyse Weisenfeld
Date: February 4, 2013
Page 1 of 1
Certificate of RegistrationO-STAT^ This Certificate issued under the seal ofthe Copyright
Office inaccordance with title 17, United States Code,atteststhat registration hasbeen madefor the workidentified below. The information on thiscertificate hasbeen made apart ofthe Copyright Office records.
f^.FormVA VA 1 329789
" rflNIIIHiHIIc- - iifcwk~r*t.if:M..i *.*.
^dSfeoRegisterofCopyrights, United States ofAmerica
KTrVEDAreOF REGISTRATION ***
NOTEUnder tha taw,the'author* at "wort madefor hire" Itgenerally thaemployer, notilia employee(H* Instructions) Foranypin ot urnwortthatwas _______"made lorhire" .. 77^enocn *VM*'in t ***** *Author the span I
DO NOT WRITE ABOVE THIS LINE. IF YOU NEED MORE SPACE, USE ASEPAHATE CONTJNUATON SHEET.PREVIOUS REGISTRATION Has registration for dm work, or lot an enlier version ofriiswrA already beeaoiadeuOYea QNo If your answeru"Yes," why uanother registration being sought? (Check apuiopimle box )a.O This isthe firtt published edition ofawork pevic^y register^ in unpublisr^ termb. O This u Ike first appucahoo aubmtned byuna author as copyn|>t dainuaLc O Tresis achanted version ofdie work, asshown byspate* ontins appbcaimaIf your answer is "Yes," give PreTlonl ItegWretktn Murnber T Year ofRegistration T
DERTVATnTE WORK ORCOMPOATION Complete both sr*M6*a*dttredenvahvev/ork,cnetaema, Preedstsag Material Irkatilyanypreejuiiiig work or works that this work ubased oner incorporates T
b.Maitrhd Added to TtlsWork Giveabn*f,pr,erelsrnlerrteftnemet^ T
DEPOSIT ACCOUNT Ifthe regislrabon fee isto be charged lo aDeposit Accountotabtahed in it* &HmeJOffii^Wtmt- Account Number
CORRESPONDENCE Oivenaineejul address to whchcorrespondeiMab^ NaiiitfAddresa/AptrTJiyia__'TElyseWeisenfeld9 SkylineDriveHawthorne,NY 10532
Area code ami daytt^sslephor* number (914)347-7700x121Email [email protected]
CERTIFICATION* I,Aeiiridersigiied,iuMetryoerrifythaIamthe
checkonly one
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8{rf _ . , 'Crown Awards, Inc.B euthonxed agentof m __-Mnol*Anforee*weopyrtgMcsrners.or thework identified thappbcaHonaruilJ^Typed or printed name and dateTIf this application gives adate of r^bUcahooinepaceidoiuMaignandsubimtttrje&rerlurtd^ElyseWeisenfeld 08730/05
Hand (X)T
Certificatewill bemailed InwindowenvelopstothlBaddress:
NamefElyseWeisenfeldCrown Awards, Inc.Number/SftBsl/AptT9 Skyline DriveOtv/BlalaSDPY
Hawthorne, NY 10532
Date
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Certificate ofRegistration
,**_^to This Certificate issued under the seal ofthe CopyrightOffice in accordance with title 17, United States Code,atteststhat registration hasbeen made for the workidentified below.The information on this certificate hasbeen made apart ofthe Copyright Office records.
OjlM &juL&Registers Copyrights, United States of America
G FormVAPore Work*/theVassalArte__.. UNITEOSTAriSCOrYRICrlTOfnCf
" VA 1-349-852
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DERIVATIVE VKMUCOR COMPILATION Complete both space 6a and 6b faede*redvewo*eomr^wordyiVeeoti*a.Prcexhting Matcrkfi (ibeatuV any raeexisb^
b. Material Added toTali Work ffive abrief, general slaterrentofuwsnaterial that r been added to this wcrk and in whichc^
DEPOSn ACCOVJOT Ulb* reglstrarie.. fee Ulobecharged toaDee^Nmme Account Number
CORRESPONDENCE Give name and address to which correrpondence about this applicalion should be sent. Naoe/Addnss/ADtX^/SolrVZIPElyseWeisenfeld9 Skyline DriveHawthorne, NY 10532
Aeodeerldaye>iieteler^ore)iiurnr)et (914)347-7700x121Email [email protected]
CERTIFICATION* I,tlvtiinaripied,hefetryce
Certificate ofRegistrationSTAT^
J870
Title
This Certificate issued under the seal ofthe CopyrightOffice in accordance withtitle 17, United States Code,attests that registration has been made for the workidentified below.The information on this certificate hasbeen made a partoftheCopyright Office records.
17[ I A- hjiojtx(XUc^,Register ofCopyrights, United States of America
Registration Number
VA 1-850-398Effective date of
registration:
February 4, 2013
Title of Work: 2" 3D PiepastMedalsPrevious or Alternative Title: Rugby, grand piano, gold, silver, bronze, mud racing
Completion/Publication _
Author
Year of Completion: 2012Date of 1st Publication: January 30, 2012
Author: Crown Awards, Inc.
Author Created: sculpture
Work made for hire: YesDomiciled in: United Slates
Nation of1st Publication: United States
Copyright claimantCopyright Claimant: Crown Awards, Inc.
9 Skyline Drive. Hawthorne, NY, 10532, United States
CertificationName: Elyse Weisenfeld
Date: February 4, 2013
Correspondence: Yes
Page 1 of 1
Registration #: VA0001850398Service Requests 1-887252365
Crown Awards, Inc.Elyse Weisenfeld9 Skyline DriveHawthorne, NY 10532 United States
Certificate ofRegistrationvJIlZ**.
1870
Title
This Certificate issued under the seal ofthe CopyrightOffice in accordance with title17, United States Code,attests that registration has been made for the workidentified below.The information on this certificate hasbeen made apartofthe Copyright Office records.
7homc^A- t^Mo^JxRegister ofCopyrights, UnitedStates ofAmerica
Registration Number
VA 1-892-651Effective date of
registration:
February 21, 2014
Title ofWork: 2" 3D Diecast MedalsPrevious or Alternative Title: Microphone, 4th Place, Skiing, Hip Hop, Road Bike, Bookworm, T-Ball and
Tennis 2" 3D Diecast Medals
Completion/PublicationYear of Completion: 2013
Dateof 1st Publication: February 10, 2014 Nation of 1st Publication: United StatesAuthor
Author: Crown Awards, Inc.
Author Created: photograph(s), sculpture
Work made for hire: Yes
Citizen of: United States
Copyright claimantCopyright Claimant: CrownAwards, Inc.
9 Skyline Drive, Hawthorne
CertificationName: Erin Andrews
Date: February 21, 2014
Domiciled in: United States
Page 1 of 1
Registration#: VAOOOl892651Service Request #: 1-1236737501
Elyse Weisenfeld9 Skyline DriveHawthorne, NY 10532
Certificate of Registration
*.,870.*
Title
ThisCertificate issued under the seal ofthe CopyrightOffice in accordance with title 17, United States Code,attests that registration has been made for the workidentified below. The information on this certificate hasbeen made a part ofthe CopyrightOffice records.
1%>mL a ^ LjfeRegister of Copyrights,United States of America
Registration Number
VA 1-815-364Effective date of
registration:
February 17,2012
Title ofWork: 2" 3D Diecast MedalsPrevious orAlternative Title: cheerpyramid, large mouth bass, starperformer, together we can,5k,You're
a star, 1 year and 5 year
Completion/Publication
Author
Year of Completion: 2011Date of 1st Publication: January 28, 2012
Author: Crown Awards, Inc.
Author Created: sculpture
Work made for hire: Yes
Domiciled in: United States
Copyright claimant
Nation of 1st Publication: United States
Copyright Claimant: Crown Awards, Inc.
9 Skyline Drive, Hawthorne, NY, 10532, United States
CertificationName: Elyse Weisenfeld
Date: February 17,2012
Correspondence: Yes
Page 1 of 1
Certificate of Registration
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STAT^y This Certificate issued under the seal ofthe CopyrightOffice in accordance with title17, United States Code,attests that registrationhas been made for the workidentified below.The information on this certificatehasbeen made a part of theCopyright Office records.
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Areaooc*errfday1rriatereriK>r*raaricr (914) 347-7700x121Email [email protected]
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Certificate ofRegistrationo ___&.
Registration #: VA0001902773Service Request #: 1-1228992221
Elyse Weisenfeld9 Skyline DriveHawthorne, NY 10532
Certificate of Registrationo___l*\ ThisCertificate issued under theseal ofthe Copyrighl
Office in accordance with title 17, United Slates Code,attests that registration has been made for the workidentified below. The information on this certificate hasbeen made a part ofthe Copyright Office records.
1870
Title
InActing Register of Copyrights,United Statesof America
Title ofWork: Icicle Series LucitesPrevious or Alternative Title: Shield, Large Star and Pink Star
Completion/Publication
Registration Number
VA 1-767-936Effective date of
registration:
February 3,2011
Year of Completion: 2010Date of 1st Publication: January 28, 2011 Nation of 1st Publication: United States
Author Author: Crown Awards, Inc.
Author Created: sculpture/3-D artwork
Work made for hire: Yes
Domiciled in: United States
Copyright claimantCopyright Claimant: Crown Awards, Inc.
9 Skyline Drive, Hawthorne, NY, 10532, United States
CertificationName: Crown Awards, Inc
Date: February 3, 2011
Correspondence: Yes
Page 1 of 1
Registration #: VAOOOl767936
Service Request #: 1-559062236
Crown Awards, Inc.Elyse Weisenfeld9 Skyline DriveHawthorne, NY 10532 United States
Certificate of Registration
.*-i___** This Certificate issued under theseal oftheCopyrightOfficein accordance with title 17, United States Code,attests that registration has been made for the workidentified below. The information on this certificate hasbeenmadea part ofthe Copyright Office records.
S^ TTLuLA'rtkUfeRegister of Copyrights, UnitedStates ofAmerica
Title
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registration:
February 17,2012
Title ofWork: trophy columnsPrevious orAlternativeTitle: patriot, 2012, silver swirl, black and goldbaseball, black andgoldbasketball,
black and gold football, black and gold soccer
Completion/Publication
Author
Year of Completion: 2011Date of 1st Publication: January 28, 2012
Author: Crown Awards, Inc.
Author Created: 2-D artwork, sculpture
Work made for hire: Yes
Domiciled in: United States
Copyright claimant
Nation of 1st Publication: United States
Copyright Claimant: Crown Awards, Inc.
9 Skyline Drive, Hawthorne, NY, 10532, United States
CertificationName: Elyse Weisenfeld
Date: February 17, 2012
Page 1 of 1
Registration #: VAOOO 1811025
Service Request #: 1-726598200
Crown Awards, Inc.Elyse Weisenfeld9 Skyline DriveHawthorne, NY 10532 United States
Certificate of Registration
*pj*L*
18 7 0
Title
This Certificate issuedunder the seal ofthe CopyrightOffice in accordance with title 17, UnitedStates Code,attests that registration has been made for the workidentified below. The information on this certificate hasbeen made a part ofthe Copyright Office records.
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Registration #: VAOOOl 849589
Service Request #: 1-887204753
Crown Awards, Inc.Elyse Weisenfeld9 Skyline DriveHawthorne, NY 10532 United States
Certificate of Registration
*!__?*. This Certificate issued under the seal ofthe CopyrightOffice in accordance withtitle 17, United States Code,atteststhat registration has been made for the workidentified below. The informationon this certificate hasbeen made apart ofthe Copyright Office records.
FormVA
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COPYRIGHT CLAIMANT(S) Nameandaddress mustbegivenevenif theclaimant 19 thesame sthe authorgivenin space2
Crown Awards Inc9 Skyline DriveHawthorne New York 10532
TRANSFER IIthedaimant(s)namedhere in space4ia(are) differentfromtheauthors) namedinspace i. give ebriefatarement ofhow the daimant(s) obtained ownership ofthe copynght
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DERIVATIVE WORK OR COMPILATIONPreexisting Material Identify anypreexisting workorworks thatthiswork isbased onorincorporates T
This work incorporates some illustrations photography andcompilations fromCrownAwards2004Catalog (Reg # TX 5 914 114) Crown Awards2003Catalog (Reg # TX 5 746 317) CrownAwards2002Catalog (Reg # TX 5 704-497) CrownAwards200) Catalog (Reg# TX 5 704 498) CrownAwards2000 Catalog (Reg TX5 907 758) end prior Crown Awards catalogs
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7N/ACORRESPONDENCE Give name and address towhich correspondence about thuapplication should besent Neme/Address/Apt/Oty/Sfate/ZIP T
Samuel Goldfarb EsqAronauer Goldfarb Re & Yudell LLP444 Madison Avenue 17th FloorNew York New York 10022
Area code and daytime telephone number e- (212)755 6000Email k-
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Fax number (212)755 6006
claimant
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Typed orpunted name and date Ifthisappbcabon gives edare ofpublication inspace 3 donotsign andsubmit itbefore that dateElyse Weisenfeld, President m D,te^ 1/21/05
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This Certificate issued under theseal oftheCopyrightOffice in accordance with title 17, United States Code,atteststhat registration hasbeen made forthe workidentified below. The information on this certificate hasbeenmadea part ofthe Copyright Office records.
l^&bteu>RegisterofCopyrights, United States of America
TitleTitle ofWork: CrownAwards 2009 Catalog
Completion/Publication ----------------
Registration Number:
VA 1-677-366Effective dale of
registration:February 9,2009
Year of Completion: 2008Date of 1stPublication: January 28,2009 Nation of 1st Publication: United States
Author Author: CrownAwards, Inc.
Author Created: 2-D artwork
Work made for hire: YesDomiciled in: United States
Copyright claimantCopyright Claimant: Crown Awards, Inc.
9 Skyline Drive, Hawthorne, NY, 10532, United States
CertificationName: Elyse WeisenfeldDate: February 9,2009
Correspondence: Yes
Page 1 of 1
Registration it: VAOOOl 677366
ServiceRequest*: 1-159012527
Crown Awards, Inc.Elyse Weisenfeld9 SkylineDriveHawthorne, NY 10532 United States
Certificate ofRegistration.*___*,.
J-r870-*
This Certificate issued under the seal ofthe CopyrightOffice in accordance with title 17, United States Code,attests that registration has been made for the workidentified below. The informationon this certificate hasbeen made a partofthe Copyright Office records.
QjCH) 6trSfel_RegisterofCopyrights, United States of America
Title Title ofWork: crown Awards 2010 Catalog
Completion/Publication
Registration Number
VA 1-701-983Effective date of
registration:February3,2010
Year of Completion: 2009Date of 1stPublication: February 1,2010 Nation of 1st Publication: United States
Author Author: Crown Awards, Inc.
Author Created: scuIpture'3-D artwork
Work made for hire: YesDomiciled in: United States
Copyright claimantCopyrightClaimant: Crown Awards, Inc.
9 Skyline Drive, Hawthorne, NY, 10532, United States
Certification
Name: Elyse WeisenfeldDate: February 3,2010
Correspondence: Yes
Page 1of 1
Registration*: VA0001701983
Service Request*: 1-327287272
Crown Awards, Inc.Elyse Weisenfeld9 Skyline DriveHawthorne,NY 10532 United States
Certificate ofRegistration
J870
Title
This Certificate issued under the seal ofthe CopyrightOffice in accordance with title 17, United States Code,attests thatregistration hasbeen made for the workidentified below. The information onthis certificate hasbeen made apart ofthe Copyright Office records.
n%Acting Register ofCopyrights, United States ofAmerica
Title ofWork: 2011 Crown Awards CatalogPrevious orAlternative Title: generic 1and generic 2
Completion/Publication
Registrarion Number
VA 1-759-294Effective date of
registration:
February 3, 2011
Year of Completion: 2010
Date of 1stPublication: January 28,201 ] Nation of 1st Publication: UnitedStatesAuthor
Author: CrownAwards, Inc.
Author Created: 2-D artwork
Work made for hire: Yes
Domiciled in: United States
Copyright claimantCopyright Claimant: Crown Awards, Inc.
9 Skyline Drive, Hawthorne, NY, 10532, United States
Certification - -Name: Elyse WeisenfeldDate: February 3,2011
Page 1 of 1
Registration #: VA0001759294ServiceRequest*: 1-559062372
Crown Awards, Inc.Elyse Weisenfeld9 Skyline DriveHawthorne, NY 10532 United States
Copyright Office fees are subject to change.For currenl fees, check the Copyright Officewebsite al www.copyright.gov.write the Copyright Office, or call (202) 707-3000.
fzOC*
e Form CAForSupplementary RegistrationUNITED STATES tOPVUIGHT OFFICE
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Title oWork
lOW Woc^ ^AW% CAlA-VC>6nRegistration Number of the Basic Registration
s/f\ \ --1*6=1 - 2.^Year of Basic Registralion
lo\oName(s) of AuthoHs)
Location and Nature of Incorrect Information in Basic Registration TLine Number Line Headingor Description.
Name(s) of Copyright Claimant(s) T
Incorrect Information as It Appears in Basic Registration T
Corrected Information T
Explanation of Correction T
Location and Nature of Information in Basic Registration to be Amplified TLine Number Z2 Line Heading or Description r\\J\ HOr* C-P-fe
Certificate ofRegistration
Title
This Certificate issued under the seal ofthe CopyrightOffice inaccordance with title 17, United States Code,attests that registration has been made for the workidentified below. The information on this certificate hasbeen made apartoftheCopyright Office records.
AIAomLA Tzfy.LXzRegister of Copyrights, UnitedStates ofAmerica
Titleof Work: 2012 Crown Awards CatalogPrevious orAlternative Title: Generic 1and generic 2
Completion/Publication
Registration Number
VA 1-811-016Effective date of
registration:
February 17,2012
Year of Completion: 2012Date of 1st Publication: January28, 2012 Nation of 1st Publication: United States
Author Author: Crown Awards, Inc.
Author Created: sculpture
Work made for hire: Yes
Domiciled in: United States
Copyright claimantCopyright Claimant: CrownAwards, Inc.
9 SkylineDrive, Hawthorne, NY, 10532,United States
CertificationName: Elyse Weisenfeld
Date: February 17,2012
Page 1 of 1
Registration #: VAOOOl 811016Service Request #: 1-726425978
Crown Awards, Inc.Elyse Weisenfeld9 Skyline DriveHawthorne, NY 10532 United States
Copyright Office fees are subject to change.For current fees, check the Copyright Officewebsite at www.copyhghi.gov. write the Copyright Office, or call (202) 707-3000.
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Incorrect Information as It Appears in Basic Registration T
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Title
TtIculL A- kRegisterof Copyrights,United Statesof America
Title ofWork: 2013 Crown Awards CatalogPrevious or Alternative Title: Generic 1 and Generic 2
Completion/Publication
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VA .1-849-715Effective date of
registration:
February 1,2013
Year of Completion: 2012Date of 1st Publication: January 30, 2013 Nation of 1st Publication: United States
Author Author: Crown Awards, Inc.
Author Created: sculpture
Work made for hire: Yes
Domiciled in: United States
Copyright claimantCopyright Claimant: Crown Awards, Inc.
9 Skyline Drive, Hawthorne, NY, 10532, United States
CertificationName: Elyse Weisenfeld
Date: February 1,2013
Page 1 of 1
Registration #: VA0001849715
Service Request #: 1-886058302
Crown Awards, Inc.Elyse Weisenfeld9 Skyline DriveHawthorne, NY 10532 United States