Global Allies v. JL Furnishings - Complaint
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8/21/2019 Global Allies v. JL Furnishings - Complaint
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ORIGINAL COMPLAINT AND JURY DEMAND Case No. __________________
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SPENCER HOSIE (CA Bar No. 101777)
[email protected] S. RICE (CA Bar No. 118303)[email protected] K. LEE (CA Bar No. 156018)[email protected]
DARRELL R. ATKINSON (CA Bar No. 280564)[email protected]
HOSIE RICE LLP600 Montgomery Street, 34
th Floor
San Francisco, CA 94111
(415) 247-6000 Tel.(415) 247-6001 Fax
Attorneys for Plaintiff
GLOBAL ALLIES, LLC
UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
GLOBAL ALLIES, LLC,
Plaintiff,
v.
JL FURNISHINGS LLC; JL FURNISHINGSEAST LLC; and LONE MEADOW, LLC
Defendants.
Case No. ___________________
ORIGINAL COMPLAINT AND
DEMAND FOR JURY TRIAL
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ORIGINAL COMPLAINT AND JURY DEMAND 1 Case No. __________________
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Plaintiff Global Allies, LLC (“Global Allies” or “Plaintiff”) hereby files its complaint
against defendant JL Furnishings LLC (“JLF”), JL Furnishings East LLC (“JLF East”), and
Lone Meadow, LLC (“Lone Meadow”) (collectively “Defendants”) for patent infringement.
For its complaint, Plaintiff alleges on personal knowledge as to its own acts and on
information and belief as to all other matters, as follows:
PARTIES
1. Global Allies is a limited liability company organized under the laws of the
State of California, with its principal place of business in Lockeford, California.
2. JLF is a limited liability company organized under the laws of the State of
California, with its principal place of business in Los Angeles County, California.
3. JLF East is a limited liability company organized under the laws of the State
of California, with its principal place of business in Los Angeles County, California. JLF
East is registered to do business in North Carolina and has a place of business there.
4. Lone Meadow is a limited liability company organized under the laws of the
State of California, with its principal place of business in Los Angeles County, California.
JURISDICTION AND VENUE
5. This complaint asserts a cause of action for patent infringement under the
Patent Act, 35 U.S.C. § 271. This Court has subject matter jurisdiction over this matter by
virtue of 28 U.S.C. § 1331 and 28 U.S.C. § 1338(a).
6. This Court has personal jurisdiction over JLF, because JLF is incorporated in
California, has a place of business in California, has an agent for service of process in
California, and provides products and services in California.
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ORIGINAL COMPLAINT AND JURY DEMAND 2 Case No. __________________
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7. This Court has personal jurisdiction over JLF East, because JLF East is
incorporated in California, has a place of business in California, has an agent for service of
process in California, and provides products and services in California.
8.
This Court has personal jurisdiction over Lone Meadow, because Lone
Meadow is incorporated in California, has a place of business in California, has an agent for
service of process in California, and provides products and services in California.
9. Venue is proper in this Court by virtue of 28 U.S.C. § 1391(c) and (d) and 35
U.S.C. §289, in that: Defendants do substantial and regular business in this district such that
Defendants reside here; Defendants may be found in this district and have committed acts of
infringement in this district; Defendants have introduced infringing products into the stream
of commerce with the expectation that they will be purchased and used in this district; and
this Court has jurisdiction over all the parties.
10. The website www.jlfurnishings.com offered/exposed for sale the infringing
product. See § I, B below. The website makes use of multiple business names. For
example, the website makes reference to “JLF/lone meadow (aka JL Furnishings),” “JLF
Lone Meadow LLC,” “JL Furnishings,” “Lone Meadow LLC,” and “JLF Collections.” All
three defendants use, operate and/or own the website www.jlfurnishings.com. The website
lists both addresses in California and North Carolina.
INTRADISTRICT ASSIGNMENT
11. Pursuant to Civil LR 3-2(c), this case should be subject to district-wide
assignment because it is an Intellectual Property Action.
I. STATEMENT OF FACTS.
A. The Plaintiff Global Allies and Its Patented Task Chairs.
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ORIGINAL COMPLAINT AND JURY DEMAND 3 Case No. __________________
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12. Plaintiff Global Allies is an innovative company that specializes in supplying
high-end, strikingly designed furniture to the hospitality (hotel) market, as described below.
13.
Over the past decade, Global Allies has invested significantly in product
research, design, and development to yield novel, market-defining designs. It owns a number
of important design patents, including the patent asserted here.
14. There are several important hospitality design shows held annually in the
domestic United States. These shows bring vendors and customers together, and give buyers
the opportunity to consider and review competing product lines. The three principal
hospitality design shows held annually are the Hospitality Design Show in Las Vegas, the
BDNY show in New York, and the BD West show in Southern California.
15. A corporate hotel owner may have various brands. These brands are
frequently referred to as “flags.” For example, Hilton Hotels has a brand/flag in Hilton, and
a separate brand/flag in Doubletree. The major domestic hotel corporations typically have
what is referred to as a “brand standard” for their various brands. For example, a particular
vendor’s furniture product selected and endorsed by the hotel corporation for use in
properties bearing a particular flag. The selection of a particular vendor and product as being
included in a hotel chain’s brand standard matters: it is a striking endorsement of quality and
novelty, and reflects the hotel buyer’s conviction that that vendor’s furnishings will support
and enhance the hotel brand.
16. Even absent selecting and publishing brand standards, hotel corporations
frequently recommend particular vendor’s products for flagged hotels.
17. Given its innovative and patented designs, and the underlying quality of its
products, Global Allies has met with considerable success in becoming part of the brand
standard for major domestic and international hotel chains. Global Allies’ “task chairs,” the
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ORIGINAL COMPLAINT AND JURY DEMAND 4 Case No. __________________
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product at issue here, are part of the brand standard for several major domestic hotel chains.
For example, Hilton Hotels has numerous brands which identify Global Allies and its
products as constituting part of the brand standard, including the Hilton, Doubletree, and
Embassy Suites’ flagged hotels. To illustrate further, Starwood Hotels is and has been a
significant Global Allies’ customer, and Starwood identifies Global Allies’ task chairs as part
of the Starwood Brand Standards program, including for such top tier hotels as the Sheraton,
and Four Points by Sheraton, Aloft, and further recommended for their St Regis, Le
Meridian, Westin and W Hotels to name a few. In addition, Global Allies’ patented task
chairs are also recommended for use by other hotel corporations for their flagged properties.
18. Global Allies’ success in the hospitality market reflects, in significant part,
their products’ innovative design, a design that distinguishes and separates the Global Allies’
task chairs from competitive chairs in the hospitality industry.
19. One such innovative design is reflected in U.S. Design Patent No. D622,987,
filed April 8, 2010 and issued September 7, 2010 (the ‘987 Patent”). This patent is attached
hereto as Exhibit A. Global Allies refers to this design and task chair as the “Coronado Task
Chair” (herein “Coronado”).
20. Reproduced below is an exemplary figure describing the claimed Coronado
design:
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ORIGINAL COMPLAINT AND JURY DEMAND 5 Case No. __________________
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‘987 Patent, Fig. 1.
21. In 2013 Global Allies filed suit in this district for infringement of the ‘987
Patent against Charter Furniture Corp. and Lodging by Liberty, Inc., dba Charter Furniture.
The prior suit on the ‘987 Patent was styled Global Allies, LLC. v. Charter Furniture Corp.
and Lodging by Liberty, Inc., Case No. 5:13-cv-00651-EJD (N.D. Cal.). This prior suit was
settled with Charter Furnitur e Corp. and Lodging by Liberty, Inc., taking a license to the ‘987
Patent. Global Allies has also secured other cease and desist agreements from other
infringing parties.
B. Defendants Knock Off the Coronado Task Chair.
22.
Defendants have either offered to sale or actually sold task chairs that infringe
Global Allies’ ‘987 Patent. Defendants infringing activities span the country and include
offering infringing products through their website, as illustrated, by example, below.
23. Defendants were awarded a project to produce chairs for the yet to open
Westin Denver International Airport Hotel. In obtaining this project, Defendants submitted a
visually identical copy of the Coronado Task Chair. Defendants intend to complete this
project through the production, delivery, and installation of chairs that knockoff Global
Allies’ Coronado task chair.
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ORIGINAL COMPLAINT AND JURY DEMAND 6 Case No. __________________
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24. In 2014, Defendants presented this knockoff chair at the BD West show and in
fact stated to the Hilton Brand manager that Defendants could supply them this chair and at a
lower price. At this trade show, the president of Global Allies saw the infringing chair, and
approached the C.E.O. of the Defendants’ various companies. Through its president, Global
Allies informed the Defendants’ C.E.O. that their chair infringed the Coronado patent, and
was a direct knockoff. Global Allies demanded that the Defendants cease and desist making,
selling, and offering to sell the chair. In this conversation, the Global Allies president told
the Defendants’ C.E.O. that the Coronado chair was a patented design. The Defendants’
C.E.O. responded that the Defendants used different manufacturing mechanisms to make
their infringing chair, to which Global Allies responded that the means of construction were
immaterial, given that the Defendants’ was a replica of the patented Global Allies’ chair, and
so infringed the design patent. The chair design Defendants submitted is visually identical to
Global Allies’ patented design.
25. In 2015, Plaintiff learned that Defendants had produced, shipped and installed
chairs that apply Global Allies’ Coronado patented design at the Onyx Hotel Boston (a
Kimpton Hotel). Reproduced below are three images showing the knockoff chair installed at
the Onyx Hotel Boston. The last of the images shows a label affixed to the underside of the
chair that clearly identifies Defendants as the manufacturer.
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ORIGINAL COMPLAINT AND JURY DEMAND 7 Case No. __________________
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26. Plaintiff also learned, in 2015, that Defendants were offering a knockoff that
applied Global Allies’ Coronado patented design on their website. An image of the website
page offering the knockoff chair is attached hereto as Exhibit B and incorporated herein by
reference.
27. In every instance Defendants’ knockoff chairs are essentially indistinguishable
from the patented Coronado chair, such that an ordinary observer would confuse the two
visually.
C. Defendants Refuse to Cease and Desist From Knocking Off the
Coronado Task Chair.
28. Plaintiff tried to resolve the issue of Defendants’ infringing activity short of
litigation.
29. On March 13, 2015 Global Allies’ counsel sent Defendants’ founder and
President, Jeffery Lazar, a cease and desist letter. The March 13, 2015 letter enclosed both
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ORIGINAL COMPLAINT AND JURY DEMAND 8 Case No. __________________
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am image of Defendants’ website with the infringing offering and a copy of the ‘987 Patent,
and both it and a follow-up April 2, 2015 letter requested that Defendants confirm their
cessation of all infringing activity.
30.
Mr. Lazar responded in writing on May 26, 2015. While Mr. Lazar claimed
that “JLF Collections does not copy Global Allies chairs, nor does [his] company have an
inter est or intent to do so,” and that “[a]s a courtesy to [the Global Allies’ managing partners]
as friends” he had the website image removed until he could investigate further, he
conspicuously failed to confirm that Defendants would cease and desist their infringing
activities.
31. On May 26, 2015 Global Allies’ counsel sent Defendants a letter pointing out
Mr. Lazar’s omission and again asking that they confirm that they would cease and desist
from infringing activity.
32. The next day, May 27, 2015, Mr. Lazar responded in writing with a reiteration
that “JLF Collections does not copy Global Allies chairs,” but without any commitment that
Defendants’ would cease and desist from infringing activity.
33. The fact is that Defendants have offered for sale, sold, produced and
manufactured chairs that apply the design protected by Global Allies’ 987 Patent and intend
to continue to do so. Faced with Defendants infringing activities and the inability to secure a
cease and desist assurance from Defendants, Global Allies brought this suit.
COUNT I
PATENT INFRINGEMENT
(The ’987 Patent)
34. Global Allies incorporates and realleges, as though fully set forth herein, the
allegations contained in paragraphs 1-33 above.
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ORIGINAL COMPLAINT AND JURY DEMAND 9 Case No. __________________
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35. On September 7, 2010, United States Patent No. D622,987 S (the “‘987
Patent”) entitled “Task Chair” was duly and legally issued. A true and correct copy of the
ʼ987 Patent is attached as Exhibit A (and incorporated herein by reference).
36.
Isaac Kubr yk is the inventor of the ʼ987 Patent. The ʼ987 Patent has been
assigned to Plaintiff. Plaintiff Global Allies is the sole legal and rightful owner of the ʼ987
Patent.
37. Defendants make, use, import, expose for sale, offer to sell, and/or sell
products that infringe the ʼ987 Patent through applying the patented design and/or colorable
imitations thereof to articles of manufacture, as alleged above in paragraphs 22 through 27.
This conduct constitutes infringement under 35 U.S.C. § 271(a).
38. Defendants’ infringement of the ‘987 Patent is willful. Defendants were on
notice that their activities infringed Global Allies’ patented design since at least the 2014 BD
West show. Global Allies’ president informed Defendants’ C.E.O. that Defendants’ chair
was an infringing knockoff at the 2014 BD West show. Further, Defendants were provided
with a copy of the ‘987 Patent in March 2015 by Plaintiff’s counsel. Yet, Defendants
continue to make, use, expose for sale, offer for sale and/or sell chairs that infringe the ‘987
Patent.
39. As a result of the infringement by Defendants, Plaintiff has been damaged,
and will continue to be damaged, until Defendants are enjoined from further acts of
infringement.
40. Defendants will continue to infringe unless enjoined by this Court. Plaintiff
faces real, substantial and irreparable damage and injury of a continuing nature from
infringement for which Plaintiff has no adequate remedy at law.
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ORIGINAL COMPLAINT AND JURY DEMAND 10 Case No. __________________
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PRAYER FOR RELIEF
WHEREFORE, Plaintiff prays for entry of judgment:
A. that the patent-in-suit is valid and enforceable;
B. that Defendants have infringed the claim of the patent-in-suit;
C. that Defendants’ infringement of the claim of the patent-in-suit was willful;
D. that Defendants account for and pay to Plaintiff all damages caused by the
infringement of the patent-in-suit, which by statute can be Defendants’ total profits, but
which, also by statute, can be no less than reasonable royalties;
E. that the damage to Plaintiff be increased by three times the amount found or
assessed pursuant to 35 U.S.C. § 284 and that Defendants account for and pay to Plaintiff the
increased amount;
F. that this Court issue a preliminary and final injunction enjoining Defendants,
their officers, agents, servants, employees and attorneys, and any other person in active
concert or participation with them, from continuing the acts herein complained of, and more
particularly, that Defendants and such other persons be permanently enjoined and restrained
from further infringing the ‘987 Patent;
G. that Plaintiff be granted pre-judgment and post-judgment interest on the
damages caused to it by reason of Defendants’ infringement of the patent-in-suit;
H. that this Court require Defendants to file with this Court, within thirty (30)
days after entry of final judgment, a written statement under oath setting forth in detail the
manner in which Defendants have complied with the injunction;
I. that this be adjudged an exceptional case and the Plaintiff be awarded its
attorney’s fees in this action pursuant to 35 U.S.C. § 285;
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ORIGINAL COMPLAINT AND JURY DEMAND 11 Case No. __________________
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J. that this Court award Plaintiff its costs and disbursements in this civil action,
including reasonable attorney’s fees; and
K. that Plaintiff be granted such other and further relief as the Court may deem
just and proper under the current circumstances.
Dated: June 18, 2015 Respectfully submitted,
/s/ Spencer Hosie ___________________________
SPENCER HOSIE (CA Bar No. 101777)[email protected] S. RICE (CA Bar No. 118303)
[email protected] K. LEE (CA Bar No. 156018)[email protected] R. ATKINSON (CA Bar No. 280564)[email protected]
HOSIE RICE LLP
Transamerica Pyramid
600 Montgomery Street, 34th
FloorSan Francisco, CA 94111
(415) 247-6000 Tel.
(415) 247-6001 Fax
Attorneys for Plaintiff
GLOBAL ALLIES, LLC
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ORIGINAL COMPLAINT AND JURY DEMAND 12 Case No. __________________
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DEMAND FOR JURY TRIAL
Plaintiff, by its undersigned attorneys, demands a trial by jury on all issues so triable.
Dated: June 18, 2015 Respectfully submitted,
/s/ Spencer Hosie ___________________________ SPENCER HOSIE (CA Bar No. 101777)
[email protected] S. RICE (CA Bar No. 118303)[email protected] K. LEE (CA Bar No. 156018)[email protected] R. ATKINSON (CA Bar No. 280564)[email protected]
HOSIE RICE LLP
Transamerica Pyramid600 Montgomery Street, 34th Floor
San Francisco, CA 94111
(415) 247-6000 Tel.(415) 247-6001 Fax
Attorneys for Plaintiff
GLOBAL ALLIES, LLC
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EXHIBIT A
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I ll
USOOD622987S
c12 United States Design Patent
Kubryk
(10)
Patent No.:
(45)
Date of Patent:
US D622 987 S
** Sep. 7 2010
(54)
TASK CH IR
D493,642 S * 8/2004 Maran .................... ..... D6/500
(76) Inventor: Isaac Kubryk 18251 Hwy. 88,
Lockeford,
CA
(US) 95237
*
cited
by
examiner
Primary
Examiner Mimosa
De
(**)
Term:
14 Years
(74)
Attorney, Agent,
or
Firm Audrey
A. Millemann;
Weintraub Genshlea Chedial
(21) Appl. No.: 29/349 498
(57)
CL IM
(22) Filed: Apr. 8 2010
The ornamental design for a task chair, as shown and
described.
(51)
LOC
(9)
Cl.
..................................................
06-01
(52)
U.S. Cl.
.......................................................
D6/500
DESCRIPTION
(58)
Field of Classification Search
.......... D6/334-336,
FIG.
1
is a perspective view of a task chair, looking toward the
right front corner, showing
my
new design;
(56)
D6/364, 365, 366, 367, 374, 375, 376, 379,
D6/380, 500-502, 601; 297/411.2, 411.28,
297/452.19, 452.26, 452.29, 452.32, 452.35,
FIG. 2 is a front view thereof;
FIG. 3 is a back view thereof;
297/452.48
See application file for complete search history. FIG.
4
is a right side view thereof;
References Cited
FIG.
5
is a top view thereof; and,
U.S. PATENT DOCUMENTS
FIG. 6 is a bottom view thereof.
D328,395 S * 8/1992 Neuser .......... .............. D6/366
D351,069 S * 10/1994 Orlandini et al. ........ ..... D6/366
D370,805 S * 6/1996 McDiarmid .................. D6/502
.
. ..
.....
The broken lines shown
in
the drawing are for illustrative
purposes only
and
form no part of the claimed design.
1 Claim 5 Drawing Sheets
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Case3:15-cv-02751-HRL Document1-1 Filed06/18/15 Page5 of 7
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U.S. Patent
Sep.7,2010
Sheet 4 of 5
US D622,987 S
FIG 4
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U.S. Patent
Sep.7,2010
Sheet 5 of 5
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Case3:15-cv-02751-HRL Document1-1 Filed06/18/15 Page7 of 7
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Exhibit B
Case3:15-cv-02751-HRL Document1-2 Filed06/18/15 Page1 of 2
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12-40279SP -
JL
Furniture
AmPficon Made
world
RenoNned
RETURN TO THUMBNAILS
http://www.jlfurnishings.com/furniture/1620
12-40279SP : Desk Chairs
Dimensions US
W 19.75" x D 23.25" x H 24-28"
SH: 17-21"
SD: 19"
Dimensions Metric
W 501.65mm x D 590.55mm x H 609.6-711.2mm
SH: 431.8-533.4mm
SD: 482.6mm
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(SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
(Firm Name, Address, and Telephone Number) (If Known)
(Place an “X” in One Box Only) (Place an “X” in One Box for(For Diversity Cases Only) and One Box for Defendant
(U.S. Government Not a Party) or
and
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(Place an “X” in One Box Only)
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(specify)
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Damages,injunction,etc.
Global Allies, LLC
San Joaquin, CA
Spencer Hosie, Anthony K. Lee, Darrell R. Atkinson, Diane S. RiceHosie Rice LLP600 Montgomery St., 34th Fl., San Francisco, CA 94111, 415.247.6000
JL Furnishings LLC; JL Furnishings East LLC; Lone Meadow, LL
35 U.S.C. § 271
Design patent infringement case
Edward J. Davila 5:13-cv-00651-EJD
06/18/2015 /s/ Spencer Hosie Spencer Hosie Attorneys for Plaintiff
Case3:15-cv-02751-HRL Document1-3 Filed06/18/15 Page1 of 1