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8/10/2019 Round Star v. Creativity Soccer Stars - SUPER SOCCER STARS trademark non-compete complaint.pdf
1/31
James D. Weinberger ([email protected])
Jason
D. Jones ([email protected])
FROSS ZELNICK LEHRMAN ZISSU, P.C.
866
United Nations Plaza
New York, New York 10017
Tel: (212)813-5900
Fax: (212)813-5901
Attorneys
for
Round Star Inc
UNITED
STATES DISTRICT
COURT
EASTERN DISTRICT OF NEW
YORK
ROUND STAR, INC.
Plaintiff,
CREATIVITY SOCCERSTARSLLCand
YVENER GUERRIER,
Defendants.
M
CV14-6
Civil
Action
No.:
COMP
JURY
TRI L
C
OREN
Plaintiff
Round Star,
Inc. (hereinafter Plaintiff or Super Soccer S
plaint
against Defendants
Creativity
Soccer Stars LLC ( Creativity
So
Yvener Guerrier
( Guerrier ) (Creativity Soccer
Stars
and
Guerrier
are
refe
hereinafteras Defendants ),respectfullyalleges:
INTRODUCT ION
om
8/10/2019 Round Star v. Creativity Soccer Stars - SUPER SOCCER STARS trademark non-compete complaint.pdf
2/31
following
his
termination with
Super
Soccer
Stars, almost
immediately form
Stars and, through
this entity,
began operating a
competing children s
socce
mark CREATIVITY SOCCER STARS in New York City in an
attempt
to r
Stars coattails and
to unfairly benefit
from the renown ofthe SUPER SOC
and program.
Moreover, Guerrier s
operation of the CREATIVITY SOCC
(as
well
as
his
solicitation
of
other former Super Soccer
Stars
coaches to
jo
SOCCER STARS
program) is aviolation ofhis employment agreement wi
which
prohibits
him
from operating
a
competing soccer coaching business i
New
York
City area
for
aperiod
of time
following
his termination
from
Su
from
soliciting
former
Super Soccer
Stars
employees
to
join
a
competing b
2. Accordingly, Super Soccer Stars asserts
claims
for trademar
Section
32(1)
ofthe Lanham
Act,
15U.S.C.
1114(1); unfair competition
the
Lanham
Act, 15
U.S.C.
1125(a);
trademark infringement and unfair c
common law ofNew York; trademark dilution under Section 360-/
ofthe
N
Business
Law; and
breach of
contract.
Super Soccer
Stars seeks
injunctive
ofDefendants
profits
flowing from their use ofthe infringing
marks,
dama
andsuchotherreliefas the
Court deems
just and
proper.
P RT IES
3. Plaintiff, Round
Star,
Inc., is acorporation
organized
under
8/10/2019 Round Star v. Creativity Soccer Stars - SUPER SOCCER STARS trademark non-compete complaint.pdf
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New
York
11236.
5. Upon information and belief,
Defendant Yvener
Guerrier
is
a
resident of
New
York and resides at 9215 Avenue A, Brooklyn, New York
information
and
belief, Guerrier is
an
owner and/or principal ofCreativity
S
responsible
for and
controls
the
business
ofCreativity Soccer Stars.
TTTmsniCTION
AND
VENUE
6. This Court has jurisdiction over
the
subject
matter
of
this
act
Section 39 ofthe Lanham Act, 15 U.S.C. 1121, and under Sections 1331,
ofthe Judicial
Code, 28
U.S.C. 1331,
1338(a)
and
1338(b). The Court h
jurisdiction
over
the
state law claims under Section
1367(a)
ofthe
Judicial
1367(a).
7. Venue is proper in this district pursuant
to
Sections 1391 (b)
Code,
28
U.S.C. 1391(b) and (c), because each Defendant
resides
in this
to personal jurisdiction in this district due to their
transacting ofbusiness h
Defendant
has
substantial
contacts
with
this
district, and because
a
substan
events at
issue
have arisen and will arise
in
this judicial district and
Super
S
suffering harm in
this
judicial district.
8. This Court has personal
jurisdiction
over each Defendant un
and/or 302 ofthe New York Civil Practice Laws
and Rules
because (i) eac
8/10/2019 Round Star v. Creativity Soccer Stars - SUPER SOCCER STARS trademark non-compete complaint.pdf
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FArTS COMMON TO
ALL
ALLEGATIONS
A. Super Soccer Stars
Business
and Use ofthe SUPER SOCCER S
9. Since
at least as early as September of
2000,
Super Soccer S
soccer
classes,
camps and clinics for children
under
the mark SUPER SOCC
United States,
mainly in
the tri-state
New
York area.
10.
Super Soccer
Stars
goal
is
to
teach children soccer skills
in
competitive, educational environment as well
as
to provide the highest-qual
for children
of
all ages.
11.
To
further
its goal, Super Soccer
Stars
has developed and us
coaching program structure that has largely contributed
to
its
great
success.
Super
Soccer
Stars website explains, all SUPER SOCCER STARS classes
based on age-specific curricula created by acombination ofearly childhoo
behavioral specialists to
guarantee
that each child
is learning
and having a
the
whistle blows. A
true
and
correct
copy ofawebpage from
Super
Socc
www suversoccer
stars com website is
attached
hereto asExhibit
A.
12. As part of
aSuper Soccer
Stars
class,
clinic or camp, childr
and other gifts branded with the SUPER SOCCER
STARS
mark, and all c
SOCCER STARS-branded soccer balls, goals,
coaches
uniforms, and
trai
13. Through long and continuous use,
and
asignificant investm
8/10/2019 Round Star v. Creativity Soccer Stars - SUPER SOCCER STARS trademark non-compete complaint.pdf
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14.
In
addition
to
its common law rights
in the
SUPER SOCCER
Super
Soccer Stars is
the owner ofU.S. Trademark Registration
No.
2,674,4
SOCCER
STARS and Design for educational services, namely providing s
instruction services
to
others
in International Class 41, clothing, namely t-
International
Class 25, and sports
equipment,
namely
soccer
balls
in Inter
This
registration
is
valid,
subsisting,
and
in
full
force and
effect.
In
addition
incontestable as to
all goods and
services
listed
therein under Section 15 of
U.S.C.
1065,
meaning that the
registration
is
conclusive
evidence
of Supe
exclusive
right to use the SUPER
SOCCER STARS mark
in commerce
on
the
goods or
services listed in
the
registration,
as
provided by Section
33(b)
15 U.S.C. 1115(b). Aprintout from the United States Patent
and
Tradem
database
reflecting
the
registration identified above is attached hereto
as
Ex
B. Super
Soccer
Stars Employee Agreements
15.
Super Soccer Stars
proprietary coaching
program discussed
inter alia confidential facts, formulas,
methods ofoperation, curricula,
and
16. When an
employee is
hired by
Super Soccer Stars
to
coach
STARS
classes,
clinics
and/or camps, Super Soccer Stars is required
to
sha
Super
Soccer Stars proprietary
coaching program, including such
confiden
methods ofoperation, curricula, and printed materials.
8/10/2019 Round Star v. Creativity Soccer Stars - SUPER SOCCER STARS trademark non-compete complaint.pdf
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Stars
employee
during
the term
of their employment with Super Soccer Star
competing
soccer coaching business.
19. The Super Soccer Stars Employee Agreement also
prohibits
Soccer
Stars employee,
following their termination with Super Soccer
Stars
children s
soccer or children s movement and from forming any business
engages
in
the
business
of
children s
soccer or
children s
movement in
any
York City or
the
100 miles
surrounding
New
York
City within the
18 mont
her
termination from Super Soccer Stars unless he or she
obtains
written ap
Soccer Stars. Likewise, the Super Soccer Stars Employee Agreement
proh
Soccer
Stars employee within
18
months
of
his or her termination
from
hiri
hire
any current
or
former employee of
Super Soccer
Stars
to work at a
com
soccer business.
C. Defendants Infringing Use ofCREATIVITY
SOCCER
STARS
Breach
of
His
Super
Soccer
Stars
Employee Agreement
20. In July 2013, Guerrier contacted Super Soccer Stars
via
its w
coach position in the
SUPER SOCCER
STARS
program.
21.
In
response to Guerrier s on-line application, Super Soccer
Programs, Mr. Dean Simpson,
telephoned
Guerrier
in early September
201
telephone interview. During this telephone call, and before Guerrier
signe
Employee Agreement or was hired by Super Soccer Stars,
Mr.
Simpson ad
8/10/2019 Round Star v. Creativity Soccer Stars - SUPER SOCCER STARS trademark non-compete complaint.pdf
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STARS program since Guerrier explained
that
he saw the SUPER SOCCER
many places and had
coached
teams playing against SUPER SOCCER
STA
23.
On both
his on-line
application and
during
his
telephone
inte
Simpson, Guerrier assured Super
Soccer
Stars that,
if
he
was
hired, he woul
of availability to coach SUPER SOCCER
STARS
classes, including availab
school
hours
everydayofthe
week.
24.
Super Soccer Stars decided
to
hire
Guerrier as an assistant
co
September 13,
2013,
Guerrier
came
to Super Soccer Stars office and signe
Stars Employee Agreement which included the terms discussed
in
paragrap
25.
Between September
13, 2013
and
October
1,
2013,
Guerrier
SOCCER
STARS classes inNewYorkCity.
26. Almost
immediately after Super Soccer
Stars
hired Guerrier
contrary to Guerrier s representations during the interview process, Guerrie
Soccer Stars
with
only
limited availability
to coach
Super
Soccer Stars clas
example, after Super Soccer Stars
hired
Guerrier, he informed Super Socce
available
to
coach
at
times that he already told Mr. Simpson
he was
availab
some after-school
hours.
27. Upon information and belief,
Guerrier s
subsequently-revea
availability was
due
to the fact that Guerrier continued to
coach
for the Bro
8/10/2019 Round Star v. Creativity Soccer Stars - SUPER SOCCER STARS trademark non-compete complaint.pdf
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29. Upon information and belief, on October
25,2013 (little
more
after his employment
with
Super
Soccer
Stars ended), Guerrier
formed Defe
Soccer Stars
and,
though this entity, began operating
(and
currently still ope
soccer program under
the
mark
CREATIVITY
SOCCER
STARS,
which
bu
Brooklyn borough ofNew
York
City.
30. Upon information and belief, on October 30, 2013, (less than
employment
with
Super
Soccer
Stars
ended), Guerrier purchased
the
domai
www creativitvsoccerstars com
which
is
where
Defendants offer
and prom
CREATIVITY SOCCER STARS program.
31.
According to
their
website,
Defendants
CREATIVITY SO
program offers soccer classes and
clinics
that are open to
welcome
[sic] al
2year old
and
up and
is
a program with soccer activities that are fun, dev
appropriate for children to
stimulate
their
movement
and
spatial
awareness,
peers, learn
the
wonderful
game
of
soccer,
[and]
develop teamwork.
A
tru
a
webpage
from Defendants www creativtvsoccerstars com website is atta
Exhibit C.
In
other words, under their CREATIVITY SOCCER STARS
m
services identical to
(and
competitive with) Plaintiffs SUPER SOCCER S
32. Upon information
and
belief,
Defendants
currently (and stil
covered
by
Guerrier s
Super Soccer Stars Employee
Agreement)
employ
a
8/10/2019 Round Star v. Creativity Soccer Stars - SUPER SOCCER STARS trademark non-compete complaint.pdf
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America ( NSCAA )
course
that
was
held at
aSuper
Soccer Stars
facility in
October andearly
November
2013.
33. Super Soccer Stars has not authorized or consented to Defend
CREATIVITY SOCCER STARS
mark or
to
Guerrier s operation
of and
em
CREATIVITY SOCCER STARS program.
34.
In
using
the
mark
CREATIVITY SOCCER STARS - amar
similar
to
Plaintiffs
SUPER SOCCER STARS mark in connection with
classes
services that
are
identical to
and/or
highly related to
goods
and se
Super Soccer Stars under the SUPER SOCCER STARS mark
-
Defendan
willful
disregard
ofthe
laws
protecting
Plaintiffs
rights in
its SUPER SOC
and have undermined and
are
continuing
to
undermine
the
value
ofthe SUP
STARS mark as an
indicator of activities,
goods
and services
that
emanate
Stars.
35.
Defendants infringing
acts
are
likely
to
deceive, mislead
an
concerning
the source or sponsorship of Defendants CREATIVITY SOCC
leading
consumers
to
mistakenly believe that Defendants CREATIVITY S
services come from, or are
otherwise sponsored
by, affiliated with, or
appr
Stars.
36.
Defendants unauthorized use ofthe CREATIVITY SOCCE
8/10/2019 Round Star v. Creativity Soccer Stars - SUPER SOCCER STARS trademark non-compete complaint.pdf
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t-shirt that
Super Soccer Stars
coaches wear in
the same
colors
(even though
hundreds
of
available coaching shirt options to
choose
from)
and Defendant
classes the exact same
brand and model of
soccer goals used
by
Super Socc
classes. Such willful
infringement
is also evidenced
by the
fact
that
the
con
.
creativitvsoccerstars
com website copies extensively from Super Socc
WWW
WWW
supersoccerstars com
website.
By
way
of
example,
Defendants
rrpntivitvsoccerstars com
website
bears a large, rotating set of
color
im
playing soccer
that
is substantially similar in
size,
placement and content to
images
featured near
the top
ofSuper Soccer
Stars www super
soccerstars
37.
Based
on
Guerrier s
admitted prior knowledge
of
Plaintiffs
STARS
program and
his
employment with Super Soccer Stars,
Defendants
Super Soccer Stars
rights
to and interest
in
the SUPER SOCCER STARS
ofthe confusingly similar CREATIVITY
SOCCER
STARS mark.
As
am
Defendants were on constructive notice
of
Plaintiff
s
rights in
the
SUPER S
mark based on
Plaintiffs registration for
the same as provided by Section 2
15 U.S.C. 1072.
38. The
use
by
Defendants ofa
mark confusingly similar
to the
STARS
mark
unfairly and unlawfully wrests from Super Soccer
Stars cont
and
reputation. Super Soccer Stars
has
no
control
over the quality
of
Defe
8/10/2019 Round Star v. Creativity Soccer Stars - SUPER SOCCER STARS trademark non-compete complaint.pdf
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39.
Accordingly, the goodwill that Plaintiffhas
built up
in its SU
STARS mark through years ofsubstantial investment and effort
is
put
at
risk
Defendants use ofthe confusingly similar CREATIVITY SOCCER STARS
promote its owncompeting soccerprogram.
40. Defendants conduct has caused and, unless enjoined by
this
to
cause, irreparable
injury
to
Plaintiff.
Plaintiff
has
no
adequate remedy
at
C O U N T I
Federal
Trademark
Infringement
By
Both Defendants- 15
U.S
41. Super Soccer Stars repeats and incorporates
by reference
the
paragraphs 1through 40 above
as
if
set
forth fully herein.
42. Defendants unauthorized use ofthe
CREATIVITY
SOCCE
services identical
or
related to those provided by Super Soccer Stars is
likel
or to
cause mistake,
or to
deceive
Defendants customers, potential consum
as to the source or sponsorship
of
Defendants
services.
Consumers
are
lik
believing that
Defendants
services are provided by,
licensed
by, sponsored
otherwise associated with Super Soccer Stars.
43. Upon information and belief,
Defendants
were on
both
actua
notice
of
Super
Soccer Stars exclusive rights
in the
registered
SUPER SOC
prior
to
their own use ofthe CREATIVITY
SOCCER
STARS mark. Defe
infringing
CREATIVITY SOCCER STARS mark is willful,
in
bad
faith, a
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44. Defendants acts
are
intended
to
reap the benefit ofthe goodw
Soccer
Stars
has
created
in its
SUPER SOCCER
STARS
trademark and con
of
Plaintiff
s
federally-registered
trademark
in
violation ofSection
32(1) of
U.S.C. 1114(1).
45.
Defendants conduct has
caused
and is causing
immediate
an
to
Super Soccer Stars and, unless enjoined by this Court, will continue
to
bo
Soccer
Stars and
deceive
the public. Super Soccer Stars has no
adequate re
C OU N T II
Federal
Unfair
Competition
By Both Defendants - 15 U.S.C.
46. Super Soccer Stars repeats and realleges paragraphs
1
throug
set forth herein.
47. Defendants
use
ofthe CREATIVTY SOCCER STARS ma
designation
of origin
and afalse
representation
with respect to the
origin
of
Defendants use ofthe CREATIVITY SOCCER STARS mark
is likely
to
c
mistake, or deception as to the source of
Defendants
services and is
likely
impression
that
Defendants
are affiliated with Super Soccer Stars or that th
authorized, sponsored, endorsed,
licensed by, or affiliated
with Super Socc
48.
Defendants
actions
constitute unfair competition
in
violatio
the LanhamAct, 15U.S.C. 1125(a).
49.
Defendants
conduct has caused and
is
causing
immediate a
8/10/2019 Round Star v. Creativity Soccer Stars - SUPER SOCCER STARS trademark non-compete complaint.pdf
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COUNT
II I
Common Law Trademark
Infringement
and Unfair Competition
By
50.
Super Soccer Stars
repeats
and
realleges paragraphs
1
throug
se t forth herein.
51. Defendants
have
used the confusingly similar
CREATIVITY
mark with full knowledge of Super Soccer
Stars
prior rights in
the SUPER
mark
and
ofthe
success and renown
of
Super Soccer
Stars
services sold un
SUPER
SOCCER STARS
mark. Defendants use ofa
mark
confusingly si
Stars mark is for the willful and calculated purpose of
misappropriating
an
Soccer Stars goodwill and business reputation. Furthermore, Defendants h
confusingly similar
to Super Soccer Stars mark for
the
willful
and
calcula
confusion
and mistake among the
public
and
of
deceiving the
public as to t
ofDefendants services in violation ofSuper
Soccer
Stars rights
under the
state
of
New
York.
52. Upon information and belief, Defendants were on
notice
of
exclusive rights in the
SUPER
SOCCER STARS mark before adopting
the
CREATIVITY SOCCER STARS mark
by virtue
ofGuerrier s employmen
Stars
and
by virtue
of
Super Soccer
Stars
federal trademark
registration
fo
SOCCER
STARS mark.
As aresult, Defendants adoption ofaconfusing
SUPER
SOCCER
STARS mark is willful, in bad faith and
with
full know
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53. The aforesaid conduct ofDefendants constitutes
unfair comp
infringement
under the common law
ofthe
State
of
New York.
54. Defendants conduct has caused
and
is causing immediate an
to
Super Soccer Stars
and will continue to both damage Super Soccer
Stars
public unless enjoined by this
Court.
Super Soccer Stars
has
no adequate re
COUNT
IV
Dilution Under
New
York
Law
By
Both
DefendantsN.Y.
Gen. B
55.
Super
Soccer
Stars
repeats
and
realleges paragraphs
1
throug
set forth herein.
56. As
a
result
of
extensive use and promotion ofthe SUPER SO
and the
services
offered thereunder by Super Soccer Stars for more than
a
d
SOCCER
STARS
mark
is
highly distinctive of
Super Soccer Stars
service
recognized
among the
consuming public
as
a
designation
of
source
of
Supe
services.
The
SUPER SOCCER
STARS
mark
was
distinctive
and widely
Defendants commenced their
unauthorized
use ofthe substantially
similar
SOCCERSTARSmark as described herein.
57. Defendants unauthorized use the CREATIVITY SOCCER
diluting and
is
likely
to
continue
diluting
the SUPER SOCCER
STARS
m
distinctiveness thereof and is
likely
to injure Super Soccer
Stars
business
removed Super
Soccer
Stars
reputation
from its own control and that
defi
8/10/2019 Round Star v. Creativity Soccer Stars - SUPER SOCCER STARS trademark non-compete complaint.pdf
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public unless enjoined by this Court. Super Soccer Stars has no adequate re
COUNT
V
(Breach of Contract by Guerrier)
59.
Super Soccer Stars repeats and realleges paragraphs 1throug
set forth herein.
60. Guerrier
entered
into a Super
Soccer
Stars
Employee
Agreem
13,
2013 and isboundby the terms of thatcontract.
61. Less than one month
after
his employment with Super Socce
Guerrier
formed and began operating (and
still operates)
Creativity
Soccer
entity that
engages
in children s soccer
instruction
in Brooklyn, New
York.
direct
violation
ofthe terms of Guerrier's
Super
Soccer Stars Employee
Ag
62. Through his
CREATIVITY
SOCCER STARS business,
Gu
employs Mr. Sidorski,
a
former
Super Soccer
Stars coach who
Guerrier
kne
Super Soccer
Stars
employee,
by virtue of
working
with Mr. Sidorski
at Su
partneringwith
Mr.
Sidorski
at an NSCAA course taken bybothmen at aS
facility. Such conduct is in
direct
violation ofthe terms ofGuerrier s Supe
Employee Agreement.
63.
Theaforesaid conduct of Guerrier constitutes breachof
con
64.
As
a direct and proximate result of
Guerrier s breach
ofcon
Stars
has suffered
and
continues
to
suffer immediate
and
irreparable injury
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WHEREFORE, PlaintiffRound Star,
Inc.
respectfully demands jud
1)
That a
permanent
injunction
be issued enjoining Defendants
jo
and any oftheir officers, agents, privies, shareholders, principals, directors,
servants, employees,
affiliates,
subsidiaries, successors and assigns,
and
all
concert orparticipation with
any
of
them,
and any entity owned orcontrolle
by any ofthe Defendants,
from:
(a) imitating, copying ormaking unauthorized use ofthemark
STARS, orany
simulation,
reproduction, copy,
colorable i
confusingly similar
variation ofthe SUPER SOCCER STA
CREATIVITY SOCCER
STARS
(anysuchmark, a Proh
as part of
any
corporate name, trademark, service mark, do
name, business
name,
fictitious name, or
otherwise
present
includes inwhole orinparta Prohibited Mark onorin con
goods,
businesses
or
services offered
by
Defendants
or
the
promotion thereof;
(b)
using aProhibited Mark to refer to
or
describe any produc
offered byor
on
behalf ofDefendants orany individual, en
party affiliatedwith Defendants;
(c)
using a
Prohibited
Mark in
or as part
of
any
domain name,
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(d) applying to register or registering in theUnited States Pate
Office, or in anystatetrademark registry, anyProhibited
M
CREATIVITY SOCCER STARS
mark;
(e)
using
a Prohibited Mark in connection with thepromotion,
offering for saleor the provisionof any goods or services;
(f)
engaging in any other activity constituting unfair competiti
constituting an infringement ofthe
SUPER SOCCER STA
(g) instructing, assisting,
aiding or abetting any
other person
o
engaging
inorperforming anyofthe activities referred toi
through (f) above.
2)
Directing that Defendants deliver up
to Super
Soccer Stars a
destruction all goods, labels, tags,
signs,
stationery, prints, packages, promo
materials,
advertisements
and
other materials
currently in
their possession
o
incorporating, featuring
or
bearing
the CREATIVITY SOCCER
STARS
m
incorporate,
feature
or
bear any
simulation, reproduction, copy, colorable im
confusingly similar
variation
ofthe SUPER SOCCER STARS
mark.
3)
Directing
such
other relief as the
Court
may
deem
appropria
public from
deriving the erroneous
impression that any
service
offered
or p
Defendants within the UnitedStates is authorizedby Super SoccerStars or
8/10/2019 Round Star v. Creativity Soccer Stars - SUPER SOCCER STARS trademark non-compete complaint.pdf
18/31
5)
That
an
injunction
be
issued enjoining
Guerrier, and any ofhis
shareholders, principals, directors, licensees,
attorneys,
servants, employees
subsidiaries, successors andassigns, andall those persons in concert or part
and any
entity
owned or
controlled
inwhole orin
part
byhim,
from
instruc
or children's movement classes or from operating a business thatoffers the
of
New
York City or
within 100
miles of
any
Super Soccer Stars
location
o
City
until the
expiration ofGuerrier s
obligations under
his Super
Soccer
S
Agreement
on
April
1,
2015 and
from
otherwise engaging in any other con
breach
of
Guerrier's Super Soccer Stars Employee Agreement.
6)
Awarding
Super
Soccer
Stars such damages
it
has
sustained
reasonof Defendants' acts of trademark infringement andunfair competitio
breach o f
contract.
7)
Awarding Super Soccer Stars all gains, profits, property and
by
Defendants
from
their
unlawful
conduct
and,
pursuant
to
15
U.S.C.
11
Soccer Stars an amount
up
to three times the amount ofactual damages sus
Defendants violation ofthe
Lanham Act.
8)
Awarding
to
Super Soccer Stars exemplary and punitive
dam
further willful trademark infringement as theCourtfinds appropriate.
9) Awarding to
Super
Soccer
Stars
its costs and disbursements
8/10/2019 Round Star v. Creativity Soccer Stars - SUPER SOCCER STARS trademark non-compete complaint.pdf
19/31
11)
Awarding to Super
Soccer
Stars such
other
and further relief
deem
just
and proper.
JURY TR I L DEM ND
Plaintiff demands a jury trial in this action.
FROSS
ZELNICK LEHRMAN Z
Dated: November 13, 2014 By:
James/ty
Weinberger
(jweinb/rier@
Jason V Jones (jjones@fross^lnick.
866
United Na tions Plaza
New
York,
New
York
10017
Tel: (212)813-5900
Fax: (212)813-5901
Attorneys
for l intiffRound Star
In
8/10/2019 Round Star v. Creativity Soccer Stars - SUPER SOCCER STARS trademark non-compete complaint.pdf
20/31
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21/31
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