Squatty Potty v. Step and Go - Complaint

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ROBERT A. GURR (#13722)

GURR & BRANDE, PLLC 1031 S. Bluff St. Ste.105

St. George, Utah 84770

Phone: (435) 634-8854

Fax: (866)-232-8818

Email: [email protected]

Attorney for Plaintiff

IN THE UNITED STATES DISTRICT COURT

DISTRICT OF UTAH

SQUATTY POTTY, LLC,

Plaintiff,

v.

STEP AND GO HEALTH, LLC

Defendants.

COMPLAINT

Case No. 2:14-cv-00491-DBP Judge: Dustin B. Pead

JURY DEMANDED

Plaintiff, Squatty Potty, LLC, by and through its counsel, Gurr and Brande, PLLC,

hereby brings this Complaint against the Defendant, Step and Go Health, LLC, and alleges as

follows:

THE PARTIES

1. Plaintiff, Squatty Potty, LLC, is an active Utah Limited Liability Company with its

principal place of business at 1135 W 1130 N Ste. 1, Saint George, Utah 84770.

Case 2:14-cv-00491-DBP Document 2 Filed 07/02/14 Page 1 of 9

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2. Upon information and belief, Defendant Step and Go Health, LLC, is a California

Limited Liability Company with its principal place of business at 520 E Santa Anita Ave,

Burbank, California 91501.

JURISDICTION AND VENUE

3. Squatty Potty, LLC (“Plaintiff”), files this action against Defendant, Step and Go Health,

LLC (“Defendant”), for design patent infringement under the patent laws of the United

States; for trade dress infringement under the Lanham Act (15 U.S.C. § 1051 et seq.) and

under the common law of the state of Utah; and for related claims of unfair competition

under the common law of the state of Utah. This Court has subject matter jurisdiction

over the patent claim under 28 U.S.C. § 1338(a) and over the trade dress claim under 28

U.S.C. §§ 1331 and 1338(b), and over the remaining claims under §§ 1338(b) and

1367(a).

4. This Court has personal jurisdiction over the Defendant because Defendant, upon

information and belief, has committed acts of infringement in Utah and/or has regularly

solicited business or derived substantial revenue from goods promoted, advertised, sold,

used, and/or consumed in the state of Utah, specifically having sold the Step and Go stool

in Utah that infringes Plaintiff‟s intellectual property in the state of Utah and has

purposefully availed itself of the privilege of doing business in the state of Utah.

5. Venue is proper in this Court pursuant to 28 U.S.C. § 1391.

6. Trial by jury is demanded.


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GENERAL ALLEGATIONS

7. Plaintiff is the owner, by virtue of assignment, of the entire right, title and interest in and

to U.S. Design Patent D677,478, entitled “Toilet Stool” and which was filed on August

23, 2012 and granted on March 12, 2013 (referred to herein as the „478 patent). (See

Exhibit A).

8. Plaintiff operates a growing business in Saint George, Utah and sells product worldwide.

9. Plaintiff has invested substantial time and resources into developing its product line of

toilet stools and associated goods.

10. Plaintiff‟s ECCO toilet stool (the subject of the „478 patent) has a distinctive design that

features a U-shaped back portion, arched sidewalls, as well as other design features. In

combination, these features create a distinctive and unique appearance which customers

and retailers recognize as the trade dress of the ECCO toilet stool and associate it

exclusively with Plaintiff.

First Cause of Action

(Direct Infringement of the ‘478 Patent by Step and Go Health, LLC)

11. Plaintiff re-alleges and incorporates by reference the allegations contained in paragraphs

1 through 10 above, as though fully set forth herein.

12. Plaintiff is the owner of the „478 Patent, which is valid and enforceable.


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13. Upon information and belief, Defendant, has infringed and continues to infringe the „478

Patent by making, designing, selling, and/or offering for sale its toilet stool that applies

the design of the „478 Patent or a colorable imitation thereof, in violation of 35 U.S.C.

§271(a).

14. An ordinary observer, given such attention as a purchaser usually gives, would be

deceived by the substantial similarity between the design of the toilet stool made,

designed, sold, and/or offered for sale by Defendant and the patented design in the „478

Patent.

15. An ordinary observer would be induced to purchase the infringing toilet stool, either

through Defendant‟s websites, online retailers, or in person (if such a retail outlets exists),

due to Defendant‟s stool being substantially the same as the designs embodied and

protected under the „478 Patent.

16. Plaintiff sent a cease and desist letter, dated June 11, 2013 to Defendant, informing it of

the „478 patent.

17. Defendant has refused to cease its infringing activities.

18. Defendant‟s deliberate and willful actions in infringing the design of Plaintiff‟s „478

Patent, have caused and will continue to cause irreparable harm to Plaintiff unless

permanently enjoined pursuant to 35 U.S.C. §283.

19. Defendant has also profited from, and continues to profit from, its infringing stool.


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20. Plaintiff has suffered pecuniary damages in amounts to be determined at trial as a result

of Defendant‟s willful infringement of the „478 patent, pursuant to 35 U.S.C. §§284 and

289.

Second Cause of Action

(Trade Dress Infringement – the Lanham Act § 43(a))



22. Plaintiff is entitled to legal protection of its ECCO toilet stool‟s trade dress under § 43(a)

of the Lanham Act, which trade dress includes without limitation a distinctive design that

features a U-shaped back portion, arched sidewalls, has an angled footrest, textured

outlines of shoes/feet on the surface, a logo on the front center, and is white in color.

23. Plaintiff is further entitled to legal protection of its Bamboo toilet stool‟s trade dress

under § 43(a) of the Lanham Act.

24. Plaintiff‟s ECCO and Bamboo toilet stools‟ trade dress have acquired secondary meaning

as consumers have come to recognize the toilet stools as identifying Plaintiff as the

source of the high quality toilet stools.

25. Defendant‟s toilet stools have so closely imitated and/or copied Plaintiff‟s ECCO and

Bamboo toilet stools that the consuming public have been confused and will continue to

be confused as to the source or origin of Defendant‟s toilet stools and will erroneously

believe that the Defendant‟s stools came from Plaintiff.


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26. In the eye of an ordinary observer, giving such attention as a purchaser usually gives,

Plaintiff‟s ECCO and Bamboo toilet stools and Defendant‟s toilet stools are substantially

the same and the resemblance is such so as to deceive an ordinary observer, including an

ordinary observer to purchase Defendant‟s toilet stools supposing them to be Plaintiff‟s

toilet stools.

27. On information and belief, Defendant‟s copying of Plaintiff‟s toilet stools‟ trade dress

was intentional.

28. Defendant intended to create a toilet stool confusingly similar in appearance to Plaintiff‟s

toilet stool, and accompanies the sale with a confusingly similar tri-fold brochure.

29. Further, Defendant mimics Plaintiff‟s advertising material, including photographs, angles

of photography, artwork, etc.

30. Defendant‟s toilet stools and Plaintiff‟s toilet stools are strikingly similar, substantially

duplicated, virtually identical, substantially identical, remarkably similar, essentially

duplicated, and/or closely imitated.

31. Defendant‟s acts of trade dress infringement have caused and continue to cause damages

and injury to Plaintiff.

32. Plaintiff may recover for its damages an award to compensate Plaintiff for injuries and

damages it has sustained as a result of Defendant‟s conduct which violates § 43(a) of the

Lanham Act.

33. Because Defendant‟s acts were intentional, willful, and/or deliberate, Plaintiff is entitled

to an award of treble damages under § 43(a) of the Lanham Act.


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34. Plaintiff is entitled to an award of pre-judgment interest for the damages sustained as a

result of Defendant‟s wrongful conduct.

35. Defendant‟s wrongful, malicious, fraudulent, deliberate, willful, and/or intentional

conduct makes this an exceptional case entitling Plaintiff to an award of attorney‟s fees

and costs under the Lanham Act.

36. Plaintiff has no adequate remedy at law; Plaintiff has suffered and continues to suffer

irreparable harm as a result of Defendant‟s acts, and is therefore entitled to permanent

injunctive relief to enjoin Defendant‟s wrongful conduct.

Third Cause of Action

(Federal Unfair Competition, False Designation of Origin, Passing Off, and False

Advertising - the Lanham Act § 43(a))



38. The unauthorized use by Defendant of Plaintiff‟s ECCO toilet stool trade dress through

the sale of its unauthorized toilet stool, is likely to cause the public to mistakenly believe

that Defendant‟s products originate from, are endorsed by, or are in some way affiliated

with Plaintiff and thus constitute unfair competition, false designation of origin, and

passing off.

39. In addition, Plaintiff‟s ECCO toilet stool trade dress is likely to lose its significance as an

indicator of origin if Defendant is allowed to continue its infringment.

40. Defendant has used Plaintiff‟s ECCO toilet stool‟s trade dress, as well as other trade

dresses held by Plaintiff (such as the Bamboo), in connection with false and misleading


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descriptions or representations of fact in promoting Defendant‟s toilet stools, thereby

misrepresenting the nature, characteristics, source, and qualities of its goods, services or

commercial activities. Defendant‟s actions are thus in violation of § 43(a) of the Lanham

Act.

41. As set forth above, on information and belief, Defendant‟s misconduct is part of a

deliberate plan to trade off the valuable goodwill established by Plaintiff and has been

carried out in willful disregard of Plaintiff‟s rights and thereby constitutes a violation of §

43(a) of the Lanham Act.

Fourth Cause of Action

(Common Law Unfair Competition, Misappropriation, and Trade Dress

Infringement - Unfair Practices Act, Utah Code Ann. § 13-5-1 et seq.)



43. By its aforesaid conduct, calculated to increase business and profits by deceiving and

confusing members of the public, Defendant continues to misappropriate the valuable

goodwill of Plaintiff‟s toilet stools‟ trade dress, to infringe Plaintiff‟s rights therein and

unfairly compete with Plaintiff under the common laws of Utah.

44. Defendant‟s use of Plaintiff‟s toilet stools‟ trade dress to promote, mark, or sell products

constitutes an unfair practice under Utah Code Ann. § 13-5-1 et seq.

45. Defendant‟s use of Plaintiff‟s toilet stools‟ trade dress is an unfair or deceptive method of

competition occurring in trade or commerce that impacts the public interest and has

caused, and is causing, injury to Plaintiff‟s retailers and consumers.


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Request for Relief

Based on the foregoing, Plaintiff respectfully requests that the Court:

A. Enter judgment in favor of Plaintiff and against Defendant on all claims;

B. Enter judgment and permanently enjoin and restrain Defendant, its officers, directors,

principals, agents, servants, employees, successors and assigns, and all others aiding,

abetting, or acting in concert or active participation therewith, from making, using,

importing, selling or offering for sale, or otherwise distributing any product that

infringes the „478 Patent.

C. Enter a judgment against Defendant for direct infringement of Plaintiff‟s toilet stool‟s

trade dress;

D. Order an accounting for Plaintiff‟s damages and/or for Defendant‟s profits derived

and/or related to Defendant‟s infringement of the „478 Patent;

E. Order an assessment of interest and costs against Defendant;

F. Find this to be an exceptional case and to award reasonable attorneys‟ fees to

Plaintiff; and

G. Award Plaintiff such other relief as the Court deems just and proper.

DATED this 2nd

day of July, 2014

_/s/ Robert A. Gurr________________

Robert A. Gurr

Attorney for Plaintiff


JS 44 (Rev. 12/12) CIVIL COVER SHEETThe JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except asprovided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for thepurpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)

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’ 1 U.S. Government ’ 3 Federal Question PTF DEF PTF DEFPlaintiff (U.S. Government Not a Party) Citizen of This State ’ 1 ’ 1 Incorporated or Principal Place ’ 4 ’ 4

of Business In This State

’ 2 U.S. Government ’ 4 Diversity Citizen of Another State ’ 2 ’ 2 Incorporated and Principal Place ’ 5 ’ 5Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State

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’ 362 Personal Injury - Product Liability Leave Act Act Medical Malpractice ’ 790 Other Labor Litigation ’ 896 Arbitration

REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS ’ 791 Employee Retirement FEDERAL TAX SUITS ’ 899 Administrative Procedure’ 210 Land Condemnation ’ 440 Other Civil Rights Habeas Corpus: Income Security Act ’ 870 Taxes (U.S. Plaintiff Act/Review or Appeal of ’ 220 Foreclosure ’ 441 Voting ’ 463 Alien Detainee or Defendant) Agency Decision’ 230 Rent Lease & Ejectment ’ 442 Employment ’ 510 Motions to Vacate ’ 871 IRS—Third Party ’ 950 Constitutionality of’ 240 Torts to Land ’ 443 Housing/ Sentence 26 USC 7609 State Statutes’ 245 Tort Product Liability Accommodations ’ 530 General’ 290 All Other Real Property ’ 445 Amer. w/Disabilities - ’ 535 Death Penalty IMMIGRATION

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’ 1 OriginalProceeding

’ 2 Removed fromState Court

’ 3 Remanded fromAppellate Court

’ 4 Reinstated orReopened

’ 5 Transferred fromAnother District(specify)

’ 6 MultidistrictLitigation

VI. CAUSE OF ACTION

Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity): Brief description of cause:

VII. REQUESTED IN COMPLAINT:

’ CHECK IF THIS IS A CLASS ACTIONUNDER RULE 23, F.R.Cv.P.

DEMAND $ CHECK YES only if demanded in complaint:JURY DEMAND: ’ Yes ’ No

VIII. RELATED CASE(S) IF ANY (See instructions):

JUDGE DOCKET NUMBERDATE SIGNATURE OF ATTORNEY OF RECORD

FOR OFFICE USE ONLY

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

Case 2:14-cv-00491-DBP Document 2-1 Filed 07/02/14 Page 1 of 2

JS 44 Reverse (Rev. 12/12)

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(12) United States Design Patent (10) Patent N0.: Edwards et al.

USO0D677478S

US D677,478 S (45) Date of Patent: M Mar. 12, 2013

(54) TOILET STOOL

(76) Inventors: Judy Edwards, Saint George, UT (U S); Bill Edwards, Saint George, UT (US); Bobby Edwards, Ivins, UT (US)

(**) Term: 14 Years

(21) Appl.No.: 29/430,327

(22) Filed: Aug. 23, 2012 (51) LOC (9) Cl. ................................................ .. 06-01

(52) US. Cl. .................................... .. .. D6/349

(58) Field of Classi?cation Search ................. .. D6/335,

D6/340, 349*355, 495, 500502; 297/16.1, 297/175, 187, 195.1, 423.1, 423.11, 423.14,

297/423.16, 461, 462 See application ?le for complete search history.

(56) References Cited

U.S. PATENT DOCUMENTS

2,023,901 A * 12/1935 Rhodes ........................... .. 4/254

D192,218 S * 2/1962 Forsman etal D6/349 D268,796 S * 5/1983 Kola .......... .. D6/349

D297,789 S * 9/1988 Stepien D6/349 D398,678 S * 9/1998 Terry et a1. . D23/309 D435,993 S * 1/2001 Johnson . . . . . . . . . . . . .. D6/601

D508,556 S * 8/2005 PalaZZolo . . D23/309 D524,562 S * 7/2006 Franciosa D6/349 D538,557 S * 3/2007 Martyn ...... .. D6/484 D553,370 S * 10/2007 Meyers et a1. ............... .. D6/350

D582,168 S * 12/2008 Sandel ......................... .. D6/349

D606,768 S * 12/2009 Tu ..... .. D6/350

D629,222 S * 12/2010 Kay D6/349 D629,627 S * 12/2010 Mylet ....... .. D6/349

D632,101 S * 2/2011 Sandelet al. D6/349 D652,222 S * 1/2012 Edwards ...................... .. D6/349

* cited by examiner

Primary Examiner * Robert M Spear

Assistant Examiner * Vy Koenig

(74) Attorney, Agent, orFirm * QuickPatents; Kevin Prince

(57) CLAIM We claim the ornamental design for a toliet stool, as shown and described.

DESCRIPTION

FIG. 1 is a perspective view of a toliet stool, showing my new design; FIG. 2 is a right side elevation view thereof, the left-side elevational view being a mirror image thereof; FIG. 3 is a front elevation view thereof; FIG. 4 is a rear elevational view thereof; FIG. 5 is a top plan view thereof; and, FIG. 6 is a bottom plan view thereof. The broken lines showing structural ribbing in FIG. 6 depict environmental matter and form no part of the claimed design.

1 Claim, 3 Drawing Sheets


US. Patent Mar. 12, 2013 Sheet 1 of3 US D677,478 S

FIG. 2



FIG. 4



FIG. 6


Documents

Squatty Potty v. Step and Go - Complaint