Professional Documents
Culture Documents
1 Deckers Essential Outsole design, to which Deckers owns design patent rights, by
2 certain of Defendants slipper products (Accused Products), an example of which is
3 shown below.
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13 Defendants Accused Product
14 14. Deckers is informed and believes and herein alleges that Defendant is a
15 competitor and has copied Deckers outsole design in an effort to exploit Deckers
16 reputation in the market.
17 15. Upon information and belief, Defendant may have sold additional
18 products that infringe upon intellectual property owned by Deckers. Deckers may seek
19 leave to amend as additional information becomes available through discovery.
20 16. Deckers has not granted a license or any other form of permission to
21 Defendant with respect to its trademarks, design patents, trade dresses, or other
22 intellectual property.
23 17. Deckers is informed and believes and herein alleges that Defendant has
24 acted in bad faith and that Defendants acts have misled and confused and were
25 intended to cause confusion, or to cause mistake, or to deceive as to the affiliation,
26 connection, or association of Defendants Accused Products with Deckers, or as to the
27 origin, sponsorship, or approval of Defendants Accused Products by Deckers.
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30 COMPLAINT FOR DAMAGES AND EQUITABLE RELIEF
Case 2:17-cv-02904 Document 1 Filed 04/17/17 Page 5 of 15 Page ID #:5
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30 COMPLAINT FOR DAMAGES AND EQUITABLE RELIEF
Case 2:17-cv-02904 Document 1 Filed 04/17/17 Page 6 of 15 Page ID #:6
EXHIBIT A
Case 2:17-cv-02904 Document 1 Filed 04/17/17 Page 10 of 15 Page ID #:10
Case 2:17-cv-02904 Document 1 Filed 04/17/17 Page 11 of 15 Page ID #:11
Case 2:17-cv-02904 Document 1 Filed 04/17/17 Page 12 of 15 Page ID #:12
Case 2:17-cv-02904 Document 1 Filed 04/17/17 Page 13 of 15 Page ID #:13
Case 2:17-cv-02904 Document 1 Filed 04/17/17 Page 14 of 15 Page ID #:14
Case 2:17-cv-02904 Document 1 Filed 04/17/17 Page 15 of 15 Page ID #:15