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COMPLAINT
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John E. Lord (Bar No. 216111) [email protected] Joanna Ardalan (Bar No. 285384) [email protected] ONE LLP 9301 Wilshire Boulevard Penthouse Suite Beverly Hills, CA 90210 Telephone: (310) 866-5157 Facsimile: (310) 943-2085
Attorneys for Plaintiff, AMERICAN SOCCER COMPANY, INC.
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
AMERICAN SOCCER COMPANY, INC., a California corporation,
Plaintiff,
v.
SQOR, INC., a Delaware corporation,
Defendant.
Case No. 2:15-cv-6600
COMPLAINT FOR:
(1)TRADEMARK INFRINGEMENT, 15 U.S.C. § 1114(1);
(2) FALSE DESIGNATION OF ORIGIN, UNFAIR COMPETITION, AND TRADEMARK INFRINGEMENT, 15 U.S.C. § 1125(a);
(3) CYBERSQUATTING, 15 U.S.C. § 1125(d);
(4) COMMON LAW TRADEMARK INFRINGEMENT; AND
(5) UNFAIR COMPETITION UNDER STATE LAW
DEMAND FOR JURY TRIAL
Case 2:15-cv-06600 Document 1 Filed 08/27/15 Page 1 of 34 Page ID #:1
1 COMPLAINT
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Plaintiff American Soccer Company, Inc., appearing through undersigned counsel,
hereby brings the present action against Defendant Sqor, Inc., and alleges as follows:
PARTIES
1. Plaintiff American Soccer Company, Inc. (“ASC” or “Plaintiff”) is a
California corporation and has a principal place of business at 726 E. Anaheim Street,
Wilmington, California 90744.
2. On information and belief, Defendant Sqor, Inc. (“Sqor” or “Defendant”) is a
Delaware corporation, with a principal place of business at 475 Sansome Street, San
Francisco, California 94111.
3. On information and belief, Defendant owns and operates www.sqor.com, and
has actively participated in the acts complained of herein.
JURISDICTION AND VENUE
4. This is an action for trademark infringement, false designation of origin,
cybersquatting, and unfair competition under the Trademark Act of 1946, as amended, 15
U.S.C. §§ 1051 et seq. (“Lanham Act”), and for related claims under the statutory and
common law of California.
5. This Court has jurisdiction over the subject matter of this action under 15
U.S.C. § 1121, 28 U.S.C. §§ 1331 and 1338 (a) and (b), and has supplemental jurisdiction
over Plaintiff’s state law claims pursuant to 28 U.S.C. § 1367(a) because those claims are
so related to its federal claims that they form part of the same case or controversy.
6. This Court has personal jurisdiction over Defendant because it has established
minimum contacts with the forum and the exercise of jurisdiction over the Defendant will
not offend traditional notions of fair play and substantial justice. On information and
belief, Defendant has voluntarily conducted business in, conducted advertising in, and
marketed itself in this District.
7. Venue is proper in this district pursuant to 28 U.S.C. § 1391.
Case 2:15-cv-06600 Document 1 Filed 08/27/15 Page 2 of 34 Page ID #:2
2 COMPLAINT
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PLAINTIFF AND ITS MARKS
8. ASC has been involved in the sports industry for over 35 years. ASC
manufactures and sells a wide range of sporting goods for team sports, including balls,
uniforms, apparel, and other accessories and equipment under the SCORE® brand.
9. ASC commenced use of the SCORE trademark in connection with its products
and services at least as early as 1986. Since that time, the SCORE trademark has been
continually used in commerce by ASC.
10. ASC uses its SCORE trademark in standard character and stylized forms, with
and without a distinctive design element. ASC’s marks and logos using “SCORE” are
collectively referred to herein as the SCORE Marks (or the “Marks”).
11. ASC has used the SCORE Marks in interstate commerce in connection with,
at least, uniforms, shorts, socks, warm-ups, coaches’ gear, balls, bags, clipboards, buckets
for balls, and field equipment.
12. The SCORE Marks are inherently distinctive. Each of the Marks serves to
identify and indicate the source of ASC’s goods and services to the consuming public, and
to distinguish its goods and services from those of others. Over the years, ASC has
prominently used and promoted the SCORE Marks in advertising, promotion, and various
other ways. ASC has invested considerable effort and resources in advertising and
promoting its SCORE products and services, and it distributes its SCORE products across
the United States of America. ASC advertises through its catalogs, website, trade shows,
social media accounts, and flyers.
13. As a result of ASC’s long history of usage and extensive promotion of the
SCORE Marks, the Marks are distinctive to designate ASC, and they distinguish ASC and
its goods and services from others. The SCORE Marks are well-known and widely
recognized to consumers. ASC has developed exclusive and valuable goodwill and strong
federal and common-law rights in the Marks as a result of the usage and promotion of the
SCORE Marks.
Case 2:15-cv-06600 Document 1 Filed 08/27/15 Page 3 of 34 Page ID #:3
3 COMPLAINT
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14. ASC owns the domain name “scoresports.com,” which was registered in or
around March 1997, and which has been used to identify ASC’s website since on or about
that date.
15. In accordance with the provisions of the Lanham Act, ASC has registered the
SCORE Marks on the Principal Register of the United States Patent and Trademark Office,
including the following registrations:
MARK REG. NO. ISSUE DATE
1,422,027 Dec. 23, 1986
SCORE 1,916,007 Sep. 5, 1995
3,618,127 May 12, 2009
SCORE SPORTS 3,930,807 Mar. 15, 2011
SCORE 4,253,691 Dec. 4, 2012
4,312,024 Apr. 2, 2013
16. Copies of these registrations are attached to the Complaint as Exhibits A, B, C,
D, E, and F are incorporated herein by reference. The registrations identified above are
valid and subsisting.
Case 2:15-cv-06600 Document 1 Filed 08/27/15 Page 4 of 34 Page ID #:4
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17. Pursuant to the Lanham Act, ASC’s registrations identified above constitute
prima facie evidence of: (a) the validity of the SCORE Marks and of the registration of
those marks; (b) ASC’s ownership of the Marks; and (c) ASC’s exclusive right to use the
Marks on or in connection with the goods and services stated in the registration. 15 U.S.C.
§§ 1057(b) and 1115(a). In addition, ASC’s registrations constitute constructive notice of
ASC’s claim of ownership of the SCORE Marks. See 15 U.S.C. § 1072. Indeed, the
registrations identified in Exhibits A and B have become incontestable pursuant to 15
U.S.C. § 1065. That these Marks have become incontestable is conclusive evidence of
their validity and their respective registrations, and of ASC’s exclusive right to use them in
commerce. See 15 U.S.C. § 1115(b).
DEFENDANT’S ACTIVITIES
18. On information and belief, long after ASC began using its SCORE Marks and
after ASC had registered the Marks, Defendant began using the marks “SQOR” and
“SQOR Sports” in connection with its sports-related app and website at www.sqor.com, as
well as on apparel products sold through this website. Copies of screenshots are attached to
the Complaint as Exhibit G. The “SQOR” and “SQOR Sports” marks are hereafter referred
to as the “Infringing Marks.” On information and belief, these activities have occurred in
the Central District of California, as well as other judicial districts.
19. On information and belief, Defendant’s platform revolves exclusively around
sports, creating economic opportunities for athletes by connecting them with fans and
marketers at massive scale, including the merchandising of athletic wearing apparel
products, sold through this website.
20. Defendant’s SQOR mark is pronounced as the English word “score.”
21. Defendant has marketed, promoted, and advertised its Infringing Marks on its
website at sqor.com, through social media, and on various mobile applications distribution
platforms including Google Play™ and iTunes™, and on various merchandising to the
public.
Case 2:15-cv-06600 Document 1 Filed 08/27/15 Page 5 of 34 Page ID #:5
5 COMPLAINT
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22. Defendant markets, promotes, and advertises the Infringing Marks to the
public in a stylized font and color which is substantially similar to ASC’s own presentation
of its SCORE marks.
23. The products offered by Defendant under the Infringing Marks, such as
athletic wearing apparel, are directly competitive, and/or closely related to the products
offered by ASC in connection with ASC’s SCORE marks.
24. ASC has objected to Defendant’s use of the Infringing Marks, but Defendant
has not ceased its unauthorized imitation of ASC’s SCORE Marks.
25. On information and belief, Defendant intends to continue its unauthorized
imitation of ASC’s SCORE Marks.
26. Defendant’s use of the Infringing Marks in commerce is without the
permission, license or authority of ASC. Such use is confusingly similar to ASC’s
federally-registered SCORE Marks.
27. Defendant’s continued infringement of the SCORE Marks is with full
knowledge, and in blatant disregard of ASC’s prior registration and use of the Marks.
28. Defendant is using the Infringing Marks in commerce in the United States, and
in this District, in an effort to trade on ASC’s valuable goodwill.
29. After ASC registered its distractive SCORE Marks, Defendant registered the
domain name “sqor.com” (the “Sqor domain name”). Defendant has used, and currently
uses the Sqor domain name for its website. ASC has not authorized nor consented to
Defendant’s use or registration of the Sqor domain name.
EFFECT OF DEFENDANT’S ACTIVITIES ON THE
CONSUMING PUBLIC AND ASC
30. Use of the Infringing Marks by Defendant in the manner described above is
likely to cause confusion, to cause mistake, and/or to deceive customers and potential
customers of the parties, at least as to some affiliation, connection or association of
Defendant with ASC, or as to the origin, sponsorship, or approval of the goods and/or
services of Defendant by ASC.
Case 2:15-cv-06600 Document 1 Filed 08/27/15 Page 6 of 34 Page ID #:6
6 COMPLAINT
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31. Use of the Infringing Marks by Defendant in the manner described above
falsely indicates to the purchasing public that the goods and/or services of Defendant
originate with ASC, or are affiliated, connected or associated with ASC, or are sponsored,
endorsed, or approved by ASC, or are in some manner related to ASC.
32. Use of the Infringing Marks by Defendant in the manner described above
falsely designates the origin of the goods and/or services of Defendant, and falsely and
misleadingly describes and represents material facts with respect to the goods, websites
and/or commercial activities of Defendant.
33. Use of the Infringing Marks by Defendant in the manner described above
enables Defendant to trade on and receive the benefit of goodwill in those marks, which
ASC has built up at great labor and expense over many years. Use of the Infringing Marks
by Defendant in the manner described above also enables Defendant to gain acceptance for
its goods and/or services, not solely on its own merits, but on the reputation and goodwill
of ASC and the SCORE Marks.
34. Use of the Infringing Marks by Defendant in the manner described above
prevents ASC from controlling the nature and quality of goods and services provided under
those marks and places the valuable reputation and goodwill of ASC in the hands of
Defendant, over whom ASC has no control.
35. The activities of Defendant has caused irreparable injury to ASC and to the
public and, unless restrained by this Court, will continue to cause irreparable injury to ASC
and to the public. There is no adequate remedy at law for this injury.
COUNT I: FEDERAL TRADEMARK INFRINGEMENT
36. Plaintiff realleges and incorporates by reference the above allegations.
37. The acts of Defendant complained of herein constitute infringement of
federally registered SCORE Marks in violation of 15 U.S.C. § 1114(1).
38. The acts of Defendant described herein have been willful and in bad faith,
making this an exceptional case within the meaning of 15 U.S.C. § 1117(a).
Case 2:15-cv-06600 Document 1 Filed 08/27/15 Page 7 of 34 Page ID #:7
7 COMPLAINT
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39. In light of the foregoing, Plaintiff is entitled to injunctive relief and to recover
from Defendant all damages, including attorneys’ fees, that Plaintiff has sustained and will
sustain as a result of such infringing acts, and all gains and profits obtained by Defendant
as a result thereof, in an amount not yet known.
COUNT II: FALSE DESIGNATION OF ORIGIN, UNFAIR COMPETITION,
AND TRADEMARK INFRINGEMENT
40. Plaintiff realleges and incorporates by reference the above allegations.
41. The acts of Defendant complained of herein constitute false designation of
origin, unfair competition, and trademark infringement of the SCORE Marks in violation of
Section 43(a) of the Lanham Act, 15 U.S.C. § 1125(a).
42. The acts of Defendant described herein have been willful and in bad faith,
making this an exceptional case within the meaning of 15 U.S.C. § 1117(a).
43. In light of the foregoing, Plaintiff is entitled to injunctive relief and to recover
from Defendant all damages, including attorneys’ fees, that Plaintiff has sustained and will
sustain as a result of such infringing acts, and all gains and profits obtained by Defendant
as a result thereof, in an amount not yet known.
COUNT III: CYBERSQUATTING UNDER 15 U.S.C. § 1125(d)
44. Plaintiff realleges and incorporates by reference the above allegations.
45. Defendant had and has a bad faith intent to profit from Plaintiff’s ASC Score
Marks, based upon, among other things, Defendant registering the Sqor domain name well
after the registering and use of ASC’s Marks, the Sqor domain name containing a name
confusingly similar to ASC’s legal or common name, and Defendant’s use of the Sqor
domain name not in connection with a bona fide noncommercial or fair use purpose,
46. Defendant registered, used, and uses the Sqor domain name, which at the time
of registration was, and still is, confusingly similar to ASC’s Marks, in violation of 15
U.S.C. § 1125(d).
47. The acts of Defendant described herein have been willful and in bad faith,
making this an exceptional case within the meaning of 15 U.S.C. § 1117(a).
Case 2:15-cv-06600 Document 1 Filed 08/27/15 Page 8 of 34 Page ID #:8
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48. In light of the foregoing, Plaintiff is entitled to injunctive relief and to recover
from Defendant all damages, including attorneys’ fees, that Plaintiff has sustained and will
sustain as a result of such infringing acts, and all gains and profits obtained by Defendant
as a result thereof, in an amount not yet known.
COUNT IV: COMMON LAW TRADEMARK INFRINGEMENT
49. Plaintiff realleges and incorporates by reference the above allegations.
50. The acts of Defendant complained of herein constitute trademark infringement
in violation of the common law of California.
51. The acts of Defendant have been conducted willfully to divert sales from
Plaintiff and inflict injury on Plaintiff.
52. In light of the foregoing, Plaintiff is entitled to injunctive relief and to recover
from Defendant all damages, including attorneys’ fees, that Plaintiff has sustained and will
sustain as a result of such infringing acts, and all gains and profits obtained by Defendant
as a result thereof, in an amount not yet known.
COUNT V: UNFAIR COMPETITION UNDER STATE LAW
53. Plaintiff realleges and incorporates by reference the above allegations.
54. Defendant’s conduct is unlawful, unfair, and/or fraudulent.
55. The acts of Defendant complained of herein have at all times been willful, and
constitute unfair competition in violation of California Business & Professions Code
§ 17200 et. seq.
56. As a result of this unfair competition, Plaintiff has suffered, and will in the
future suffer, irreparable injury to its business, reputation, and goodwill. Plaintiff will
suffer such irreparable injury unless and until Defendant’s misconduct is enjoined by the
Court.
57. Plaintiff has been damaged by the acts of Defendant in an amount currently
unknown.
Case 2:15-cv-06600 Document 1 Filed 08/27/15 Page 9 of 34 Page ID #:9
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PRAYER FOR RELIEF
WHEREFORE, American Soccer Company, Inc. prays for entry of judgment against
Defendant as follows:
1. Defendant, its officers, agents, servants, employees, attorneys, and all those
persons in active concert or participation with them be preliminarily and permanently
enjoined and restrained:
(a) From using “SQOR,” the Infringing Marks, or the SCORE Marks or any
variation thereof, whether alone or in combination with any other word(s) or element(s), or
any mark, name, domain name, or other designation which depicts, contains, or consists of
any name or mark confusingly similar to the SCORE Marks;
(b) From registering, attempting to register, or maintaining any trademark
registration, trademark, trade name, domain name, trade designation, or other indicia of
origin or source containing “SQOR,” the Infringing Marks, or the SCORE Marks or any
variation thereof, whether alone or in combination with any other word(s) or element(s), or
any mark, name, domain name, or other designation which depicts, contains, or consists of
any name or mark confusingly similar to the SCORE Marks; and
(c) From committing any acts or making any statements calculated, or the
reasonably foreseeable consequence of which would be, to infringe any of ASC’s
trademark rights in the SCORE Marks, or to confuse, mislead, or deceive consumers as to
sponsorship, approval or affiliation of ASC by, with, or of Defendant.
2. Consistent with paragraph (1)(a) above, Defendant be ordered to remove from
sale or display, and recall, any and all products, catalogs, advertisements, and any other
items or goods bearing “SQOR,” the Infringing Marks, or the SCORE Marks, or any word
or words confusingly similar thereto.
3. Defendant be required to deliver to the Court for destruction, or show proof of
destruction of, any and all products, labels, signs, prints, advertisements, signage, building
design(s), packages, wrappers, catalogs, internet web pages, and any other materials in its
possession or control bearing or depicting “SQOR” the Infringing Marks, or the SCORE
Case 2:15-cv-06600 Document 1 Filed 08/27/15 Page 10 of 34 Page ID #:10
10 COMPLAINT
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Marks, or any other mark, name, or designation that includes “SCORE” (or any variation
thereof, whether alone or in combination with any other word(s) or element(s)).
4. Defendant be ordered to file with this Court and to serve upon Plaintiff within
thirty (30) days after the entry and service on Defendant of an injunction, a report in
writing and under oath setting forth in detail the manner and form in which Defendant has
complied with the injunction.
5. Pursuant to 15 U.S.C. § 1117, Plaintiff be awarded treble damages and
attorneys’ fees for willful infringement.
6. An accounting be directed to determine the profits of Defendant resulting from
the activities complained of herein, and that such profits be paid over to Plaintiff, increased
as the Court finds to be just under the circumstances of this case.
7. For an award of profits, damages, and fees to the full extent available,
including statutory damages, and punitive damages to the full extent available in
connection with the claims under California law.
8. Plaintiff be awarded prejudgment and post-judgment interest.
9. Plaintiff be granted such other and further relief, at law or in equity, as the
Court may deem just and proper.
Dated: August 27, 2015 ONE LLP
By:/s/John E. Lord John E. Lord
Attorneys for Plaintiff, AMERICAN SOCCER COMPANY, INC.
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DEMAND FOR JURY TRIAL
Plaintiff hereby demands a trial by jury as to all claims and all issues properly triable
thereby.
Dated: August 27, 2015 ONE LLP
By:/s/John E. Lord John E. Lord
Attorneys for Plaintiff, AMERICAN SOCCER COMPANY, INC.
Case 2:15-cv-06600 Document 1 Filed 08/27/15 Page 12 of 34 Page ID #:12
EXHIBIT A
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EXHIBIT B
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EXHIBIT C
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EXHIBIT D
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EXHIBIT E
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EXHIBIT F
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EXHIBIT G
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Case 2:15-cv-06600 Document 1 Filed 08/27/15 Page 31 of 34 Page ID #:31
Buy (/collections/sqorsports/products/sqormenspulloverhoodie)SQOR men's pullover hoodie (/collections/sqor-sports/products/sqor-mens-pullover-hoodie)
$ 38.00
Buy (/collections/sqorsports/products/sqormensbaseballtshirt)SQOR men's baseball t-shirt (/collections/sqor-sports/products/sqor-mens-baseball-t-shirt)
$ 25.00
Buy (/collections/sqorsports/products/menspremiumtshirt)Sqor Sports T-Shirt Red Logo (/collections/sqor-sports/products/mens-premium-t-shirt)
$ 24.95
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(/collections/sqorsports/products/menspremiumtshirt)
Case 2:15-cv-06600 Document 1 Filed 08/27/15 Page 32 of 34 Page ID #:32
Buy (/collections/sqorsports/products/sqorsportsladiestank)Sqor Sports women's tank (/collections/sqor-sports/products/sqor-sports-ladies-tank)
$ 24.95
Buy (/collections/sqorsports/products/sqorsportscamouflagehat)Sqor Sports camouflage hat (/collections/sqor-sports/products/sqor-sports-camouflage-hat)
$ 24.95
Buy (/collections/sqorsports/products/blackperformancehat)Sqor Black performance hat (/collections/sqor-sports/products/black-performance-hat)
$ 24.95
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Case 2:15-cv-06600 Document 1 Filed 08/27/15 Page 33 of 34 Page ID #:33
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Case 2:15-cv-06600 Document 1 Filed 08/27/15 Page 34 of 34 Page ID #:34
