Case 3:15-cv-01736-AJB-DHB Document 1 Filed 08/05/15 PageID.1 Page 1 of 17
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CHRISTOPHER L. PITET, SBN 196861 cpitet@grobatypitet.com JOHN M. ALPAY, SBN 198127 jalpay@grobatypitet.com GROBATY & PITET LLP 100 Bayview Circle, Suite 210 Newport Beach, California 92660 Telephone: (949) 502-7755 Facsimile: (949) 502-7762
6 7
Attorneys for Plaintiff LUXOTTICA GROUP S.P.A.
8 9 10
UNITED STATES DISTRICT COURT
11
SOUTHERN DISTRICT OF CALIFORNIA
12 13 14
LUXOTTICA GROUP S.P.A., an Italian corporation,
CASE NO. '15CV1736 MMA RBB ASSIGNED FOR ALL PURPOSES TO:
Plaintiff,
15 16
v.
COMPLAINT FOR:
17 18
SWISS WATCH INTERNATIONAL, INC., a Delaware corporation; and DOES 1 through 10, inclusive
19
Defendants.
1. 2. 3. 4.
20
5.
TRADEMARK INFRINGEMENT; FALSE DESIGNATION OF ORIGIN; TRADEMARK DILUTION; COMMON LAW TRADEMARK INFRINGEMENT; AND UNFAIR COMPETITION.
21 DEMAND FOR JURY TRIAL 22 23 24 25 26 27 28 Grobaty & Pitet LLP
________________________________________________________________________________ COMPLAINT
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Plaintiff LUXOTTICA GROUP S.P.A. (“Luxottica” or “Plaintiff”)
2
hereby complains of Defendant SWISS WATCH INTERNATIONAL, INC.
3
(“Defendant”) and DOES 1 through 10, inclusive, and alleges as
4
follows:
5
I.
6
THE PARTIES
7
1.
Plaintiff is a corporation organized and existing under the
8
laws of the Republic of Italy, having its principal place of business
9
at Piazzale Luigi Cadorna 3, Milan, 20123 Italy.
10
2.
Plaintiff is informed and believes, and thereon alleges,
11
that Defendant is a corporation organized and existing under the laws
12
of the state of Delaware and has a principal place of business at 101
13
S. State Road 7, Suite 201, Hollywood, Florida 33023.
14
3.
Plaintiff is informed and believes, and thereon alleges,
15
that Defendant regularly conducts business in, and has committed the
16
acts alleged herein, within this judicial district.
17
II.
18
JURISDICTION AND VENUE
19
4.
This is an action for (a) trademark infringement arising
20
under 15 U.S.C. § 1114, (b) false designation of origin arising under
21
15 U.S.C. § 1125(a), (c) trademark dilution arising under 15 U.S.C.
22
§ 1125(c), (d) trademark infringement arising under the common law of
23
the State of California, and (f) unfair competition arising under
24
California Business & Professions Code
25
§ 17200.
26
5.
This
Court
has
original
subject
matter
jurisdiction
27
pursuant to 15 U.S.C. §§ 1116(a) and 1121(a) and 28 U.S.C. §§ 1331
28
and 1338 over the claims arising under the laws of the United States.
Grobaty & Pitet LLP
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This Court has supplemental jurisdiction over the remaining claims in
2
this Complaint pursuant to 28 U.S.C. § 1367(a) because the state law
3
claims are so related to the federal claims that they form part of
4
the same case or controversy and derive from a common nucleus of
5
operative facts.
6
6.
This Court has personal jurisdiction over Defendant because
7
Defendant has a continuous, systematic, and substantial presence
8
within
9
soliciting business and deriving revenue from goods provided to
10
individuals in this judicial district, including but not limited to
11
selling infringing eyewear directly to consumers and/or retailers in
12
this district and selling into the stream of commerce knowing such
13
eyewear products would be sold in California and this district, which
14
acts form a substantial part of the events or omissions giving rise
15
to Luxottica’s claim.
16 17
7.
this
judicial
district
including
by
regularly
doing
and
Venue is proper in this judicial district under 28 U.S.C.
§ 1391 (b)-(d).
18
III.
19
GENERAL ALLEGATIONS
20
8.
Luxottica is a well-known and established manufacturer,
21
distributor and retailer of high quality eyewear. Many of these lines
22
of eyewear, such as Ray-Ban®, have enjoyed substantial success and
23
are
24
licensed by Luxottica.
25
protected
9.
by
various
intellectual
property
rights
owned
or
Luxottica has marketed and sold its high quality eyewear in
26
connection with the WAYFARER® mark (the “Luxottica Mark”).
27
Luxottica began using the Luxottica Mark, its use of the mark in
28
connection with eyewear has been continuous and exclusive.
Grobaty & Pitet LLP
Since
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10.
Over the years Luxottica has invested a considerable amount
2
of time and money in establishing the Luxottica Mark in the minds of
3
consumers as a source of high quality eyewear.
4
Luxottica’s substantial use and promotion of the Luxottica Mark in
5
connection with the eyewear and other products, the mark has acquired
6
great value as a specific identifier of Luxottica’s products and
7
serves to distinguish Luxottica’s products from that of others.
8
Customers in this Judicial District and elsewhere readily recognize
9
the
Luxottica
Mark
as
distinctive
As a result of
designations
of
origin
of
10
Luxottica’s products.
11
asset of great value as a symbol of Luxottica’s quality products and
12
goodwill.
13 14 15
11.
Luxottica
The Luxottica Mark is an intellectual property
is
the
owner
of
Trademark
Registration
595,513 for the Luxottica Mark. 12.
Trademark Registration No. 595,513 was registered with the
16
U.S.P.T.O. on September 21, 1954.
17
is associated with the following goods: sunglasses.
18
correct
19
Registration No. 595,513 is attached hereto as Exhibit A.
20
Nos.
13.
copy
of
the
Trademark Registration No. 595,513
certificate
of
registration
A true and of
Trademark
Without permission or consent from Luxottica, Defendant is
21
offering for sale, distributing, marketing, and/or selling eyewear
22
bearing the Luxottica Mark.
23
14.
Defendant
did
not
begin
using
its
infringing
mark
in
24
connection with eyewear until long after Luxottica began using the
25
Luxottica Mark.
26
15.
Luxottica is informed and believes, and on that basis
27
alleges, that Defendant’s unauthorized use of its infringing mark is
28
intended to trade upon the goodwill and substantial recognition
Grobaty & Pitet LLP
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associated with Luxottica and the Luxottica Mark. 16.
Luxottica is informed and believes, and on that basis
3
alleges, that Defendant is using its infringing mark in an attempt to
4
associate its eyewear products with Luxottica and the Luxottica Mark,
5
to cause mistake or deception as to the source of Defendant’s eyewear
6
products
7
reputation and customer goodwill in its mark.
8 9 10 11
17.
and/or
to
otherwise
trade
upon
Luxottica’s
valuable
Luxottica is informed and believes, and on that basis
alleges, that Defendant’s use of its infringing mark is designed to cause confusion, mistake, or deception. 18.
By virtue of the acts complained of herein, Defendant has
12
created a likelihood of injury to Luxottica’s business reputation,
13
caused
14
deception as to the source of or origin or relationship of Luxottica’s
15
and Defendant’s goods, has caused actual confusion, and has otherwise
16
competed unfairly with Luxottica by unlawfully trading on and using
17
the Luxottica Mark without Luxottica’s permission or consent.
18
a
19.
strong
likelihood
of
consumer
confusion,
mistake,
and
At no time has Luxottica ever given Defendant license,
19
permission or authority to use or display the Luxottica Mark in
20
connection with any of Defendant’s eyewear products.
21
20.
Luxottica is informed and believes, and on that basis
22
alleges, that Defendant’s acts complained of herein are willful and
23
deliberate.
24
21.
Defendant’s acts complained of herein have caused Luxottica
25
to suffer irreparable injury to its business.
26
substantial loss of goodwill and reputation unless and until Defendant
27
is preliminarily and permanently enjoined from its wrongful actions
28
complained of herein.
Grobaty & Pitet LLP
Luxottica will suffer
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1 2
IV.
3
FIRST CLAIM FOR RELIEF
4
(Federal Trademark Infringement)
5
(15 U.S.C. § 1114)
6 7 8 9 10
22.
Luxottica
repeats
and
re-alleges
the
allegations
of
paragraphs 1- 22 of this Complaint as if set forth fully herein. 23.
This is a claim for trademark infringement arising under 15
U.S.C. § 1114. 24.
Defendant
has
used
in
commerce,
without
Luxottica’s
11
permission, reproductions, copies or colorable imitations of the
12
Luxottica Mark in connection with distributing, selling, offering for
13
sale, advertising, and/or promoting Defendant’s eyewear.
14
25.
Without Luxottica’s permission, Defendant is reproducing,
15
copying, or colorably imitating the Luxottica Mark and applying such
16
reproductions, copies or colorable imitations to merchandise, labels,
17
signs, packages, receptacles or advertisements intended to be used in
18
commerce
19
offering for sale, advertising and/or promoting of goods or services
20
on or in connection with which such use is likely to cause confusion,
21
or to cause mistake, or to deceive.
22
26.
upon
or
in
connection
with
the
distributing,
selling,
Luxottica is informed and believes, and on that basis
23
alleges, that Defendant’s activities complained of herein constitute
24
willful and intentional infringements of the Luxottica Mark, and that
25
Defendant
26
Luxottica, to trade upon Luxottica’s reputation and goodwill by
27
causing confusion and mistake among customers and the public, and to
28
deceive the public into believing that Defendant’s eyewear products
Grobaty & Pitet LLP
did
so
with
the
intent
to
unfairly
compete
against
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are associated with, sponsored by, originated from, or are approved
2
by Luxottica, when in truth and fact they are not.
3
27.
Luxottica is informed and believes, and on that basis
4
alleges, that Defendant had actual knowledge of Luxottica’s ownership
5
and prior use of the Luxottica Mark and without the consent of
6
Luxottica has willfully infringed the Luxottica Mark in violation of
7
15 U.S.C. § 1114.
8
28.
Luxottica is informed and believes, and thereon alleges,
9
that Defendant has derived and received, and will continue to derive
10
and receive, gains, profits, and advantages from the use of the
11
Luxottica Mark in an amount that is not presently known to Luxottica.
12
By reason of Defendant’s actions, constituting unauthorized use of
13
the Luxottica Mark, Luxottica has been damaged and is entitled to
14
monetary relief in an amount to be determined at trial.
15
29.
Due to Defendant’s actions, constituting unauthorized use
16
of the Luxottica Mark, Luxottica has suffered and continues to suffer
17
great and irreparable injury, for which Luxottica has no adequate
18
remedy at law.
19
V.
20
SECOND CLAIM FOR RELIEF
21
(Federal Unfair Competition & False Designation of Origin)
22 23 24 25 26 27 28 Grobaty & Pitet LLP
15 U.S.C. § 1125(a)) 30.
Luxottica
repeats
and
realleges
the
allegations
of
paragraphs 1-22 of this complaint as if set forth fully herein. 31.
This is a claim for unfair competition and false designation
of origin arising under 15 U.S.C. § 1125(a). 32. create
a
Without Luxottica’s consent, Defendant has created and will false
designation
of
origin
by
using
in
commerce
the
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Luxottica Mark and/or other marks confusingly similar to the Luxottica
2
Mark in connection with the distribution, sale, offering for sale,
3
advertising, and/or promotion of Defendant’s eyewear, thereby causing
4
a likelihood of confusion, mistake or deception as to an affiliation,
5
connection or association with Luxottica or to suggest Luxottica as
6
the origin of the goods and/or services, or that Luxottica has
7
sponsored or approved Defendant’s commercial activities.
8
33.
Luxottica is informed and believes, and on that basis
9
alleges, that Defendant acted with the intent to unfairly compete
10
against Luxottica, to trade upon Luxottica’s reputation and goodwill
11
by causing confusion and mistake among customers and the public, and
12
to deceive the public into believing that Defendant’s eyewear products
13
are associated with, sponsored by or approved by Luxottica, when they
14
are not.
15
34.
Luxottica is informed and believes, and on that basis
16
alleges, that Defendant had knowledge of Luxottica’s ownership and
17
prior use of the Luxottica Mark, and without the consent of Luxottica,
18
has
19
designation of origin in violation of 15 U.S.C. § 1125(a).
20
willfully
35.
committed
acts
of
unfair
competition
and
false
Luxottica is informed and believes, and thereon alleges,
21
that Defendant has derived and received, and will continue to derive
22
and receive, gains, profits, and advantages from Defendant’s false
23
designation of origin, false or misleading statements, descriptions
24
of fact, or false or misleading representations of fact in an amount
25
that is not presently known to Luxottica.
26
actions,
27
misleading statements, false or misleading descriptions of fact, or
28
false or misleading representations of fact, Luxottica has been
Grobaty & Pitet LLP
constituting
false
designation
By reason of Defendant’s of
origin,
false
or
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1
damaged and is entitled to monetary relief in an amount to be
2
determined at trial.
3 4
36.
Due to Defendant’s actions, constituting false designation
5
of
6
description of fact, or false or misleading representations of fact,
7
Luxottica has suffered and continues to suffer great and irreparable
8
injury, for which Luxottica has no adequate remedy at law.
origin,
false
or
misleading
statements,
false
9
VI.
10
THIRD CLAIM FOR RELIEF
11
(Federal Trademark Dilution)
12
(15 U.S.C. § 1125(c))
13 14
37.
Luxottica
repeats
and
re-alleges
the
or
misleading
allegations
of
paragraphs 1-37 of this Complaint as if set forth fully herein.
15
38.
16
1125(c).
17
39.
This is a claim for trademark dilution under 15 U.S.C. §
The products sold by Luxottica under the Luxottica Mark
18
have
19
purchasing public throughout the United States and the world.
20
been
40.
widely
advertised,
promoted,
and
distributed
to
the
Luxottica’s products sold under the Luxottica Mark, by
21
reason of their style and design and quality of workmanship, have
22
come to be known to the purchasing public throughout the United States
23
as high quality products, which are sold under excellent merchandising
24
and customer service conditions.
25
and
26
Luxottica.
27 28 Grobaty & Pitet LLP
the
41. coupled
goodwill
associated
As a result, the Luxottica Mark,
therewith,
are
of
great
value
to
By virtue of the wide renown acquired by the Luxottica Mark, with
the
national
and
international
distribution
and
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1
extensive sale of various products distributed under the Luxottica
2
Mark, the Luxottica Mark is famous and became so prior to Defendant’s
3
acts complained of herein.
4 5
42.
Defendant’s unauthorized commercial use of the Luxottica
6
Mark in connection with the advertisement, offering for sale and sale
7
of Defendant’s eyewear products has caused and is likely to continue
8
to cause dilution of the distinctive quality of the famous Luxottica
9
Mark.
10
43.
Defendant’s acts are likely to tarnish, injure, or trade
11
upon Luxottica’s business, reputation or goodwill, and to deprive
12
Luxottica of the ability to control the use of its Luxottica Mark and
13
quality of products associated therewith.
14 15
44.
Luxottica is informed and believes, and on that basis
alleges, that Defendant’s dilution has been willful and deliberate.
16
45.
By reason of the aforesaid acts constituting trademark
17
dilution, Luxottica has been damaged and is entitled to monetary
18
relief in an amount to be determined at trial.
19
46.
Due
to
Defendant’s
actions,
constituting
trademark
20
dilution, Luxottica has suffered and continues to suffer great and
21
irreparable injury, for which Luxottica has no adequate remedy at
22
law.
23
VII.
24
FOURTH CLAIM FOR RELIEF
25
(California Common Law Trademark Infringement)
26 27 28 Grobaty & Pitet LLP
47.
Luxottica
repeats
and
re-alleges
the
allegations
of
paragraphs 1-47 of this Complaint as if set forth fully herein. 48.
This is a claim for trademark infringement, arising under 10
________________________________________________________________________________ COMPLAINT
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1
California common law.
2
49.
3
infringement
4
complained of herein are willful and deliberate and committed with
5
knowledge that Defendant’s unauthorized use of the Luxottica Mark
6
causes a likelihood of confusion.
7
50.
Defendant’s acts complained of herein constitute trademark under
California
common
law.
Defendant’s
acts
Luxottica is informed and believes, and thereon alleges,
8
that Defendant has derived and received and will continue to derive
9
and receive, gains, profits and advantages from Defendant’s trademark
10
infringement in an amount that is not presently known to Luxottica.
11
By reason of Defendant’s wrongful acts as alleged in this Complaint,
12
Luxottica has been damaged and is entitled to monetary relief in an
13
amount to be determined at trial.
14
51.
Due to Defendant’s trademark infringement, Luxottica has
15
suffered and continues to suffer great and irreparable injury for
16
which Luxottica has no adequate remedy at law.
17
52.
Defendant’s willful acts of trademark infringement under
18
California
19
Accordingly, Luxottica is entitled to exemplary damages.
common
law
constitute
fraud,
oppression,
20
VIII.
21
FIFTH CLAIM FOR RELIEF
22
(California Unfair Competition)
23 24 25
53.
Luxottica
repeats
and
re-alleges
the
and
malice.
allegations
of
paragraphs 1-53 of this Complaint as if set forth fully herein. 54.
This is a claim for unfair competition, arising under
26
California Business & Professions Code § 17200, et seq. and California
27
common law.
28 Grobaty & Pitet LLP
55.
Defendant’s
acts
of
trademark
infringement,
false
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1
designation of origin, and trademark dilution complained of herein
2
constitute unfair competition with Luxottica under the common law and
3
statutory laws of the State of California, particularly California
4
Business & Professions Code
5
§ 17200 et seq.
6 7
56.
Luxottica is informed and believes, and thereon alleges,
8
that Defendant has derived and received, and will continue to derive
9
and receive, gains, profits and advantages from Defendant’s unfair
10
competition in an amount that is not presently known to Luxottica.
11
By reason of Defendant’s wrongful acts as alleged in this Complaint,
12
Luxottica has been damaged and is entitled to monetary relief in an
13
amount to be determined at trial.
14
57.
By its actions, Defendant has injured and violated the
15
rights of Luxottica and has irreparably injured Luxottica, and such
16
irreparable injury will continue unless Defendant is enjoined by this
17
Court.
18 19 20 21 22 23
PRAYER FOR RELIEF WHEREFORE, Luxottica prays for judgment in its favor against Defendant for the following relief: 1.
That the Luxottica Mark be deemed valid and willfully
infringed by Defendant in violation of 15 U.S.C. § 1114, et seq.; 2.
A preliminary and permanent injunction against Defendant,
24
its officers, agents, servants, employees, representatives,
25
successors, and assigns, and all persons, firms, or corporations in
26
active concert or participation with Defendant, enjoining them from
27
engaging in the following activities and from assisting or
28 Grobaty & Pitet LLP
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1
inducing, directly or indirectly, others to engage in the following
2
activities:
3
A. using to market, advertise, promote, sell, offer for
4
sale,
5
Luxottica Mark or any mark that is confusingly similar
6
to
7
erroneous impression that Defendant’s goods or services
8
originate from Luxottica, are endorsed by Luxottica, or
9
are connected in any way with Luxottica;
the
and/or
identify
Luxottica
Defendant’s
Mark
or
is
goods
likely
to
with
the
create
the
10
B. manufacturing,
11
reproducing,
12
promoting,
13
sell any eyewear products bearing any of the Luxottica
14
Mark and/or any confusingly similar marks;
15
C. otherwise
16
distributing, displaying,
transferring,
infringing
or
shipping,
importing,
advertising,
marketing,
selling,
diluting
and/or
the
offering
Luxottica
Mark
and/or any of Luxottica’s other trademarks;
17
D. falsely designating the origin of Defendant’s goods;
18
E. unfairly competing with Luxottica in any manner; or
19
F. causing
20 21
to
a
likelihood
of
confusion
or
injuries
to
Luxottica’s business reputation; 3.
That Defendant be directed to file with this Court and
22
serve on Luxottica within thirty (30) days after the service of the
23
injunction, a report, in writing, under oath, setting forth in
24
detail the manner and form in which Defendant has complied with the
25
injunction pursuant to 15 U.S.C. § 1116;
26
4.
That, because of the exceptional nature of this case
27
resulting from Defendant’s deliberate infringing actions, this
28
Court award to Luxottica all reasonable attorneys’ fees, costs and
Grobaty & Pitet LLP
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1
disbursements incurred as a result of this action, pursuant to 15
2
U.S.C. § 1117;
3
5.
That Defendant be required to account for any and all
4
profits derived by its acts of trademark infringement, false
5
designation of origin, trademark dilution, and unfair competition
6
complained of in this Complaint;
7
6.
That Luxottica be awarded damages for Defendant’s
8
trademark infringement pursuant to 15 U.S.C. § 1117 in the form of
9
Defendant’s profits, damages sustained by Luxottica and the costs
10
of the action, together with prejudgment and post-judgment
11
interest;
12
7.
That Defendant’s acts of trademark infringement, false
13
designation of origin, trademark dilution, and unfair competition
14
complained of in this Complaint be deemed willful, and that
15
Luxottica be entitled to enhanced damages;
16
8.
That Defendant be adjudged to have acted with willful intent
17
to trade on Luxottica’s reputation and to dilute the famous Luxottica
18
Mark in violation of 15 U.S.C. § 1125(c), et seq.;
19
9.
That Defendant be adjudged to have willfully and
20
maliciously infringed the Luxottica Mark in violation of
21
Luxottica’s common law rights under California common law;
22
10.
That Defendant be adjudged to have violated California
23
Business & Professional Code § 14247 by seeking to injure
24
Luxottica’s business reputation and to dilute the distinctive
25
quality of the Luxottica Mark;
26 27 28 Grobaty & Pitet LLP
11.
That Defendant be adjudged to have competed unfairly with
Luxottica under the common law of the State of California; 12.
That Defendant be adjudged to have competed unfairly with 14
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1
Luxottica under California Business & Professional Code § 17200, and
2
that Defendant’s actions in so doing be adjudged willful and done
3
knowingly;
4
13.
That an accounting be ordered to determine Defendant’s
5
profits
6
dilution, and false designation of origin, and that Luxottica be
7
awarded monetary relief in an amount to be fixed by the Court in its
8
discretion as it finds just as an equitable remedy, including:
9
resulting
A.
all
from
profits
its
infringement,
received
by
unfair
Defendant
competition,
from
sales
and
10
revenues of any kind made as a result of its infringing
11
actions, said amount to be trebled;
12
B.
all damages sustained by Luxottica as a result of
13
Defendant’s acts of infringement, unfair competition,
14
false designation of origin, and dilution, and that
15
such damages be trebled; and
16
C.
17 18 19 20 21 22 23 24 25
punitive damages stemming from Defendant’s willful, intentional, and malicious acts;
14.
That such damages and profits be trebled and awarded to
Luxottica pursuant to 15 U.S.C. § 1117; 15.
That
Luxottica
recover
exemplary
damages
pursuant
to
California Civil Code § 3294; 16.
That Luxottica have and recover the costs of this civil
action, including reasonable attorneys’ fees; 17.
An award of pre-judgment and post-judgment interest and
costs of this action against Defendant; and
26 27 28 Grobaty & Pitet LLP
15 ________________________________________________________________________________ COMPLAINT
Case 3:15-cv-01736-AJB-DHB Document 1 Filed 08/05/15 PageID.16 Page 16 of 17
1 2 3 4
18.
Such other and further relief as this Court may deem just
and proper. Dated:
August 5, 2015
CHRISTOPHER L. PITET JOHN M. ALPAY GROBATY & PITET LLP
5 6 By:
/s/ Christopher L. Pitet Christopher L. Pitet
7 8
Attorneys for Plaintiff LUXOTTICA GROUP S.P.A.
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Grobaty & Pitet LLP
16 ________________________________________________________________________________ COMPLAINT
Case 3:15-cv-01736-AJB-DHB Document 1 Filed 08/05/15 PageID.17 Page 17 of 17
1
DEMAND FOR JURY TRIAL
2
Plaintiff Luxottica Group S.P.A. hereby demands a trial by
3
jury on all issues triable by a jury as provided by Rule 38(a) of
4
the Federal Rules of Civil Procedure.
5 6 7
Dated:
August 5, 2015
CHRISTOPHER L. PITET JOHN M. ALPAY GROBATY & PITET LLP
8 9 10 11
By:
/s/ Christopher L. Pitet Christopher L. Pitet
Attorneys for Plaintiff LUXOTTICA GROUP S.P.A.
12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Grobaty & Pitet LLP
17 ________________________________________________________________________________ COMPLAINT
Case 3:15-cv-01736-AJB-DHB Document 1-1 Filed 08/05/15 PageID.18 Page 1 of 1
-6 5HY
CIVIL COVER SHEET
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I. (a) PLAINTIFFS
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Swiss Watch International, Inc., a Delaware corporation; and DOES 1 through 10, inclusive &RXQW\ RI 5HVLGHQFH RI )LUVW /LVWHG 'HIHQGDQW
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Christopher L. Pitet; John M. Alpay, Grobaty & Pitet LLP, 100 Bayview Circle, Suite 210, Newport Beach, CA 92660 (949) 502-7755
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