166
 J S 44C/SDNY REV. 4/2012 CIVIL COVER SHEET The JS- 44 civil coversheet and the information contained hereinneither replace norOTPpleme nt tfieTilin? and servii pleadingsor ot her papers as requiredbylaw,exceptas provided bylocalrul esofcourt. This form, approvedt? JudicialConference oftheUnitedStatesinSeptember1974, is requir ed for us e oftheClerkofCourtforthe purposeof initi ati ng the civil docket sheet. 4 1 7 o PLAINTIFFS CROWN AWARDS, INC. DEFENDANTS TROPHY DEPOT, INC., JAMES O'BOYLE an d HOWARD BECKER ATT ORNEYS (FI RM NAME,ADDRESS, AND TELEPHONE NUMBER Richard Lehv, Esq., Emily Weiss, Esq. FROSS ZELNICKLEHRMAN & ZISSU, P.C. 86 6 U.N. Plaza, New York, NY 10017, Tel: (212) 813-5900 ATT ORNEYS (IF KNOWN) FEB 18 201* CAUSEOF ACTION (CITE THE U.S. CIVIL STAT UTE UNDER WHI CH YO U ARE FILING AND WRITE A BRIE F STATE MENT OFCAUSE) Claimsforcopyrightinfringemenfund er tie cbon 108 ofthe UnitedStatesCopyngntActof 1976 , as amended (the Copyright Act ), 17 U.S .C.§ 106;unfaircompetiti onunder Sec tio 43(a)ofthe United Sta tes Tra demarkActof1946 , as ame nded (th e  Lanham Act ), 15U.S.C.§ 1125(a);trad emark infringement unde r Section32(1)ofthe Lanh am Act, 15 U.S.C. § 1114(1); fals e adve rti singunder Sec tion43(a)( 1)(B)ofthe LanhamAct,15 U.S .C.§ 1125(a) (1 )(B); and relatedcla imsunder NewYork'sstat utory and commonlaw. Hasthisora similar cas e been previously filed in SDNY at anytime? No |x] Yes Judge Previously Assigned If yes,wasthiscase Vol. || Invol. | | Dismissed. No Q Yes Q If yes, give date & Case No . IS THI S AN INTERNAT IONA L ARBITRATION CASE? No (PLACEAN [x]IN ONEBOX ONLY) TORTS Yes D NATURE O F 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 ME D MALPRACTICE [ ]620 OTHER FOOD & 28 US C 15 8 REAPPORTIONMENT [ M3 0 MILLER ACT LIABILITY [ ]365 PERSONAL INJURY DRUG [ ]423 WITHDRAWAL [ ]410 ANTITRUST [ ]140 NEGOTIABLE [ ]320 ASSAULT, L IB EL & PRODUCT LIABILITY [ ]625 DRUG RELATED 28 US C 15 7 [ ]430 BANKS & BANKING INSTRUMENT SLANDER [ ]368 ASBESTOS PERSONAL SEIZURE OF [ ]450 COMMERCE [ ]150 RECOVERYOF [ ]330 FEDERAL INJURY PRODUCT PROPERTY [ ]460 DEPORTATION OVERPAYMENT & EMPLOYERS' LIABILITY 21 USC881 PROPERTY RIGHTS I I 470 RACKETEER INFLU ENFORCEMENT LIABILITY [ )630 LIQUORLAWS ENCED & CORRUPT OF JUDGMENT [ ]340 MARINE PERSONALPROPERTY [ I 64 0 RR & TRUCK P<]820 COPYRIGHTS ORGANIZATIONACT []151 MEDICARE AC T [ ]345 MARINE PRODUCT [ ]650 AIRLINE REGS [ ] 83 0 PATENT (RICO) [ ]152 RECOVERY OF LIABILITY I ]370 OTHER FRAUD [ ]660 OCCUPATIONAL [ J 84 0 TRADEMARK [ ]480 CONSUMER CREDIT DEFAULTED [ ]350 MOTOR VEHICLE t 1371 TRUTH IN LENDING SAFETY/HEALTH [ ]490 CABLE/SATELLITE TV STUDENT LOANS [ ]355 MOTOR VEHICLE [ J380 OTHERPERSONAL [ ]690 OTHER [ ]810 SELECTIVE SERVICE (EXCLVETERANS) PRODUCT LIABILITY PROPERTY DAMAGE SOCIALSECURITY [ ]850 SECURITIES/ [ ]153 RECOVERY OF [ ]360 OTHER PERSONAL [ J 38 5 PROPERTY DAMAGE COMMODITIES/ OVERPAYMENT INJURY PRODUCT LIABILITY LABOR [ ]861 H IA (1 39 5f f) EXCHANGE OF VETERAN'S [ ]862 B LAC K LUN G ( 92 3) [ ]875 CUSTOMER BENEFITS [ ]710 FAIR LABOR I ]863 DI WC /DI WW ( 40 5( g) ) CHALLENGE [ ]160 STOCKHOLDERS STANDARDS AC T [ ] 864 SSID TITLE XVI 12 US C 3410 SUITS t ]720 LABOR/MGMT [ J 86 5 RSI (405(g)) [ ]890 OTHER STATUTORY [ ]190 OTHER PRISONER PETITIONS RELATIONS ACTIONS CONTRACT [ J 73 0 LABOR/MGMT [ ]891 AGRICULTURAL ACTS 1 ]195 CONTRACT []510 MOTIONSTO REPORTING & FEDERAL TAX SUITS [ ]892 ECONOMIC PRODUCT ACTIONS UNDER STATUTES VACATE SENTENCE DISCLOSUREACT STABILIZATION AC T LIABILITY 20 US C 2255 [ ]740 RAILWAY LABOR AC T [ ] 87 0 TAXES (U.S. Plaintiffor [ ]893 ENVIRONMENTAL [ ]196 FRANCHISE CIVIL RIGHTS [ ]530 HABEAS CORPUS []790 OTHER LABOR Defendant) MATTERS ]535 DEATH PENALTY LITIGATION [ ] 871 IRS-THIRD PARTY [ ]894 ENERGY [ ]441 VOTING [ ]540 MANDAMUS & OTHER []791 EMPLRETINC 26 US C 7609 ALLOCATION ACT [ ]442 EMPLOYMENT SECURITY AC T [ ]895 FREEDOMOF REALPROPERTY [ ]443 HOUSING/ INFORMATION AC T ACCOMMODATIONS IMMIGRATION [ ]900 APPEAL OF FE E [ ]210 LAND [ ]444 WELFARE PRISONER CIVIL RIGHTS DETERMINATION CONDEMNATION ( ]445 AMERICANS WITH [ ]462 NATURALIZATION UNDEREQUAL [ ]220 FORECLOSURE DISABILITIES - [ ]550 CIVIL RIGHTS APPLICATION ACCESS TOJUSTICE [ ]230 RENTLEASE & EJECTMENT [ ]446 EMPLOYMENT AMERICANS WITH [ ]555 PRISON CONDITION [ ]463 HABEAS CORPUS- ALIEN DETAINEE [ ]950 CONSTITUTIONALITY OF STATESTATUTES [ ]240 TORTS TO LAND DISABILITIES -OTHER I OTHER IMMIGRATION [ ]245 TORT PRODUCT LIABILITY [ ]440 OTHER CIVIL RIGHTS (Non-Prisoner) ACTIONS [ ]290 AL L OTHER REAL PROPERTY Check if demanded in complaint: CHECK IF THIS IS A CLASS ACTION UNDERF.R.C.P. 2 3 DO YO U CLAIM THIS CASE IS RELATED TO A CIVI L CASE NO W PENDING IN S.DNY IF S O, STATE: DEMAND $ undeterm ined other Injunctive judge DOCKET NUMBER Check YESonlyifdemanded in complaint JURY DEMAND: YES S NO NOTE: Please submitat th e timeof filing an expl anation ofwhy cases are deemed re late d.

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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

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    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

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    coMDeposit Account: Iftheregistration fee is tobe charged to a Deposit Account established in theCopyright Office, give name and numberofAccount.Name

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    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

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    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

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    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]

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    Certificatewill bemailed InwindowenvelopstothlBaddress:

    NamefElyseWeisenfeldCrown Awards, Inc.Number/SftBsl/AptT9 Skyline DriveOtv/BlalaSDPY

    Hawthorne, NY 10532

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    17[ I A- hjiojtx(XUc^,Register ofCopyrights, United States of America

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    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

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    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

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    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

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  • Certificate of Registration

    *.,870.*

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    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

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    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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    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

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    Crown Awards, Inc.Elyse Weisenfeld9 Skyline DriveHawthorne, NY 10532 United States

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    S^ TTLuLA'rtkUfeRegister of Copyrights, UnitedStates ofAmerica

    Title

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    VA 1-811-025Effective date of

    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

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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

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