TBL Licensing v. Kotoni - Complaint

Case 2:18-cv-03950-R-RAO Document 1 Filed 05/11/18 Page 1 of 12 Page ID #:1
1 Marsha E. Diedrich (State Bar No. 93709)

E-mail: marsha.diedrich@alston.com
2 H. James Abe (State Bar No. 265534)
E-mail: james.abe@alston.com
3 ALSTON & BIRD LLP
333 South Hope Street, 16th Floor
4 Los Angeles, CA 90071-1410
Telephone: 213-576-1000
5 Facsimile: 213-576-1100
6
Attorneys for Plaintiff
7 TBL Licensing LLC
8
UNITED STATES DISTRICT COURT
9 CENTRAL DISTRICT OF CALIFORNIA
10
11 TBL LICENSING LLC, a Delaware Case No.: 2:18-CV-03950
Limited Liability Company,
12
Plaintiff,
13 COMPLAINT FOR PATENT
v. INFRINGEMENT
14
15 KOTONI TRADING, INC., a California DEMAND FOR JURY TRIAL
Company,
16
Defendant.
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COMPLAINT FOR PATENT INFRINGEMENT

1 TBL Licensing LLC (“Timberland” or “Plaintiff”), by and through its

2 attorneys, Alston & Bird LLP, files this Complaint for Patent Infringement against
3 Defendant Kotoni Trading, Inc. (“Kotoni” or “Defendant”), and, in support thereof,
4 alleges as follows:
5 JURISDICTION AND VENUE
6 1. This Court has jurisdiction over the subject matter of this action pursuant
7 to 28 U.S.C. §§ 1331 and 1338 because this case arises under the patent laws of the
8 United States, Title 35 of the United States Code.
9 2. This Court has personal jurisdiction over Defendant Kotoni because the
10 Defendant is incorporated in the State of California. Moreover, Defendant has
11 committed and continues to commit acts of infringement in violation of 35 U.S.C. § 271
12 in this judicial district.
13 3. Venue is proper in this judicial district pursuant to 28 U.S.C. §§ 1391 (b)
14 and (c) and § 1400(b) at least because Defendant (1) is a resident in this judicial district,
15 (2) has committed acts of infringement in this judicial district, and (2) has a regular and
16 established place of business in this judicial district.
17 NATURE OF THE SUIT
18 4. This is an action arising under the patent laws of the United States, Title
19 35 of the United States Code, to seek injunctive relief and obtain monetary remedies
20 resulting from Defendant’s unauthorized manufacture, use, importation, offer for sale,
21 and/or selling products that infringe the claims of Timberland’s U.S. Design Patent Nos.
22 D744,733 (“the ’D733 Patent”) and D785,305 (“the ’D305 Patent”) (collectively,
23 “Patents-in-suit”).
24 5. This action involves Defendant’s unauthorized manufacture, use,
25 importation, offer for sale, and/or selling the infringing footwear products, including,
26 without limitation, the “NOLTE”, “COOPER”, “CRUISE,” “DANNI”, “GERE”,
27 “DESOTO” and “DEGAMO” style shoes (“the Accused Products”).
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1
1 PARTIES
2 6. Plaintiff Timberland is a limited liability company organized and existing
3 under the laws of Delaware, with its principal place of business at 200 Domain Drive,
4 Stratham, NH 03885.
5 7. Upon information and belief, Defendant Kotoni is a company organized
6 and existing under the laws of California, with its principal place of business at 1760
7 Evergreen St., Duarte, California 91010.
8 GENERAL ALLEGATIONS
9 8. Timberland operates as an indirectly wholly-owned subsidiary of VF
10 Corporation, a Pennsylvania corporation with its principal place of business in
11 Greensboro.
12 9. Timberland is the owner of certain intellectual property rights associated
13 with the TIMBERLAND® brand footwear and apparel products.
14 10. U.S. Patent No. D744,733 (“the ’D733 Patent”), entitled “Footwear
15 Tread,” was duly and legally issued by the United States Patent & Trademark Office
16 (“USPTO”) on December 8, 2015. A true and correct copy of the ’D733 Patent is
17 attached hereto as Exhibit A. The ’D733 Patent is based on U.S. Patent Application No.
18 29/462,480 (“the ’480 Application”), filed on August 5, 2013, naming Christopher
19 Adam, Peter Dillon, and Michael P. Kirk as inventors.
20 11. U.S. Patent No. D785,305 (“the ’D305 Patent”), entitled “Footwear
21 Tread,” was duly and legally issued by the USPTO on May 2, 2017. A true and correct
22 copy of the ’D305 Patent is attached hereto as Exhibit B. The ’D305 Patent is based on
23 U.S. Patent Application No. 29/530,629 (“the ’629 Application”), filed on June 18,
24 2015, which is a division of the ’480 Application, naming Christopher Adam, Peter
25 Dillon, and Michael P. Kirk as inventors.
26 12. Both the ’D733 Patent and the ’D305 Patent discloses the ornamental
27 design for footwear thread.
28
2
1 13. The marking requirements of 35 U.S.C. § 287 have been satisfied with
2 respect to the ’D733 Patent and the ’D305.
3 14. Each claim of the Patents-in-suit is valid and enforceable.
4 15. Timberland is the current assignee to the ’D733 Patent and ’D305 Patent,
5 with the right to sue and recover for past infringement of the Patents-in-suit and any and
6 all causes of action and remedies, either legal and/or equitable, related thereto.
7 16. Defendant has manufactured, used, sold, offered for sale, and/or imported
8 into the United States footwear products that infringe Timberland’s patent rights,
9 including the Patents-in-suit.
10 17. On August 11, 2017, Counsel for Plaintiff Timberland provided written
11 notice to Defendant of its infringement of the Patents-in-suit. The notice was sent to
12 Defendant via UPS overnight shipping.
13 COUNT I
14 Infringement of the ’D733 Patent
15 18. Plaintiff incorporates herein by reference each and every allegation
16 contained in paragraphs 1–Error! Reference source not found., above.
17 19. Upon information and belief, Defendant has infringed, directly or
18 indirectly, the ’D733 Patent in violation of 35 U.S.C. § 271(a), either literally or under
19 the doctrine of equivalents, by making, using, selling, offering to sell, manufacturing,
20 and/or importing into the United States footwear products having a design that would
21 appear to an ordinary observer to be substantially similar to the claim of the ’D733
22 Patent, including but not limited to at least the Accused Products identified in Paragraph
23 5 above.
24 20. For the purpose of example only and without limitation, as shown below,
25 Defendant’s NOLTE footwear product infringes the claim of the ’D733 Patent.
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1 ’D733 Patent Defendant’s NOLTE Footwear

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21. Defendant actively induced others to infringe, literally and/or under the
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doctrine of equivalents, the ’D733 Patent in violation of 35 U.S.C. § 271(b) by
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importing and selling the Accused Products to various U.S. retailers, and by instructing
25
the retailers through its marketing, advertising and customer assistance relating to the
26
Accused Products, in a manner that infringes the ’D733 Patent.
27
22. Defendant’s infringement is willful, deliberate, intentional, and with
28
knowledge of the existence of the ’D733 Patent. Upon information and belief,
4
1 Defendant had knowledge of Timberland’s rights in the design claimed in the ’D733
2 Patent. Timberland and its footwear designs are well-known throughout the footwear
3 industry, and the footwear tread design of the Accused Products is an identical copy of
4 Timberland’s patented design. Furthermore, Defendant has had knowledge of the
5 ’D733 Patent since at least as early as August 2017, when Defendant received notice of
6 its infringement of the Patents-in-suit. Defendant infringed the ’D733 Patent with
7 reckless disregard of Timberland’s patent rights. Defendant knew, or it was so obvious
8 that Defendant should have known, that its actions constitute infringement of the ’D733
9 Patent. Defendant’s acts of infringement of the ’D733 Patent were not consistent with
10 the standards of commerce for its industry.
11 23. Timberland has been damaged by Defendant’s infringement of the ’D733
12 Patent in an amount to be determined at trial.
13 24. Timberland has been and continues to be irreparably injured by
14 Defendant’s infringement of the ’D733 Patent, and Defendant’s infringing activities
15 will continue unless enjoined by this Court pursuant to 35 U.S.C. § 283.
16 25. As a direct and proximate result of Defendant’s acts of infringement,
17 Defendant has derived and received gains, profits, and advantages in an amount to be
18 determined at trial or hearing.
19 26. Pursuant to 35 U.S.C. § 284, Timberland is entitled to damages for
20 Defendant’s infringing acts and treble damages together with interests and costs as fixed
21 by this Court.
22 27. Pursuant to 35 U.S.C. § 285, Timberland is entitled to reasonable
23 attorneys’ fees for the necessity of bringing this claim.
24 28. Pursuant to 35 U.S.C. § 289, Timberland is entitled to Defendant’s total
25 profits from Defendant’s infringement of the ’D733 Patent.
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1 COUNT II
2 Infringement of the ’D305 Patent
3 29. Plaintiff incorporates herein by reference each and every allegation
4 contained in paragraphs 1–28, above.
5 30. Upon information and belief, Defendant has infringed, directly or
6 indirectly, the ’D305 Patent in violation of 35 U.S.C. § 271(a), either literally or under
7 the doctrine of equivalents, by making, using, selling, offering to sell, manufacturing,
8 and/or importing into the United States footwear products having a design that would
9 appear to an ordinary observer to be substantially similar to the claim of the ’D305
10 Patent, including but not limited to at least the Accused Products identified in Paragraph
11 5 above.
12 31. For the purpose of example only and without limitation, as shown below,
13 Defendant’s NOLTE footwear product infringes the claim of the ’D305 Patent.
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1 ’D305 Patent Defendant’s NOLTE Footwear

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32. Defendant actively induced others to infringe, literally and/or under the
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doctrine of equivalents, the ’D305 Patent in violation of 35 U.S.C. § 271(b) by
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importing and selling the Accused Products to various U.S. retailers, and by instructing
24
the retailers through its marketing, advertising and customer assistance relating to the
25
Accused Products, in a manner that infringes the ’D305 Patent.
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33. Defendant’s infringement is willful, deliberate, intentional, and with
27
knowledge of the existence of the ’D305 Patent. Upon information and belief,
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1 Defendant had knowledge of Timberland’s rights in the design claimed in the ’D305
2 Patent. Timberland and its footwear designs are well-known throughout the footwear
3 industry, and the footwear tread design of the Accused Products is an identical copy of
4 Timberland’s patented design. Furthermore, Defendant has had knowledge of the
5 ’D305 Patent since at least as early as August 2017, when Defendant received notice of
6 its infringement of the Patents-in-suit. Defendant infringed the ’D305 Patent with
7 reckless disregard of Timberland’s patent rights. Defendant knew, or it was so obvious
8 that Defendant should have known, that its actions constitute infringement of the ’D305
9 Patent. Defendant’s acts of infringement of the ’D305 Patent were not consistent with
10 the standards of commerce for its industry.
11 34. Timberland has been damaged by Defendant’s infringement of the ’D305
12 Patent in an amount to be determined at trial.
13 35. Timberland has been and continues to be irreparably injured by
14 Defendant’s infringement of the ’D305 Patent, and Defendant’s infringing activities
15 will continue unless enjoined by this Court pursuant to 35 U.S.C. § 283.
16 36. As a direct and proximate result of Defendant’s acts of infringement,
17 Defendant has derived and received gains, profits, and advantages in an amount to be
18 determined at trial or hearing.
19 37. Pursuant to 35 U.S.C. § 284, Timberland is entitled to damages for
20 Defendant’s infringing acts and treble damages together with interests and costs as fixed
21 by this Court.
22 38. Pursuant to 35 U.S.C. § 285, Timberland is entitled to reasonable
23 attorneys’ fees for the necessity of bringing this claim.
24 39. Pursuant to 35 U.S.C. § 289, Timberland is entitled to Defendant’s total
25 profits from Defendant’s infringement of the ’D305 Patent.
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1 PRAYER FOR RELIEF

2 WHEREFORE, Timberland respectfully requests judgment against Defendant
3 as follows:
4 a) For a judgment in favor of Timberland that Defendant has infringed the
5 Patents-in-suit, whether literally or under the doctrine of equivalents, as
6 described herein;
7 b) For an award of such damages in an amount sufficient to compensate
8 Timberland for losses it has sustained as a consequence of Defendant’s
9 unlawful acts, as well as Timberland’s lost profits attributable to
10 Defendant’s unlawful acts; and
11 c) For an accounting for all gains and profits derived by Defendant from its
12 unlawful acts;
13 d) For an order under 35 U.S.C. § 283 permanently enjoining Defendant from
14 continuing to make, use, sell, or offer to sell the Accused Products in the
15 United States and from importing the Accused Products into the United
16 States, as well as any products that are not colorably different therefrom;
17 e) For an order under 35 U.S.C. § 283 permanently enjoining Defendant from
18 directly or indirectly infringing either of the Patents-in-suit in violation of 35
19 U.S.C. § 271;
20 f) For an order declaring that Defendant’s infringement was willful and an
21 award of treble damages to Timberland under 35 U.S.C. § 284; and
22 g) For an order declaring this to be an exceptional case pursuant to 35 U.S.C.
23 § 285;
24 h) For an award to Timberland of its reasonable attorney fees and full costs;
25 i) For such further relief as the Court may deem just and appropriate.
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1 Respectfully submitted,
2 DATED: May 11, 2018 ALSTON & BIRD LLP
3
/s/ H. James Abe
4
Marsha E. Diedrich (Cal. Bar No. 93709)
5 marsha.diedrich@alston.com
6 H. James Abe (Cal. Bar No. 265534)
james.abe@alston.com
7 ALSTON & BIRD LLP
8 333 South Hope Street, 16th Floor
Los Angeles, CA 90071
9 Telephone: (213) 576-1000
10 Facsimile: (213) 576-1100
11 Attorneys for Plaintiff TBL Licensing LLC
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1 DEMAND FOR JURY TRIAL

2 Plaintiff TBL Licensing LLC requests a jury trial of all issues triable by a jury.
3
4 Respectfully submitted,
5 DATED: May 11, 2018 ALSTON & BIRD LLP
6
/s/ H. James Abe
7
Marsha E. Diedrich (Cal. Bar No. 93709)
8 marsha.diedrich@alston.com
9 H. James Abe (Cal. Bar No. 265534)
james.abe@alston.com
10 ALSTON & BIRD LLP
11 333 South Hope Street, 16th Floor
Los Angeles, CA 90071
12 Telephone: (213) 576-1000
13 Facsimile: (213) 576-1100
14 Attorneys for Plaintiff TBL Licensing LLC
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Case 2:18-cv-03950-R-RAO Document 1-1 Filed 05/11/18 Page 1 of 8 Page ID #:13
EXHIBIT A
USOOD744733S
(12) United States Design Patent (10) Patent No.: US D744,733 S

Adam et al. (45) Date of Patent: . Dec. 8, 2015
54) FOOTWEAR TREAD Primaryy Examiner — T. Chase Nelson
- (74) Attorney, Agent, or Firm — Lerner, David, Littenberg,
(71) Applicant: TBL Licensing LLC, Wilmington (DE) Krumholz & Mentlik, LLP
(72) Inventors: Christopher Adam, Newburyport, MA (57) CLAM
(US); Peter Dillon, Topsfield, MA (US); The ornamental design for footwear tread, as shown and
Michael P. Kirk, Beverly, MA (US) described.
(73) Assignee: TBL Licensing LLC, Wilmington, DE
(US) DESCRIPTION
(**) Term: 14 Years FIG. 1 is a plan view of a footwear tread applied to an

unclaimed shoe sole in accordance with a first embodiment of
(21) Appl. No. 29/462,480 the ornamental design;
FIG. 2 is a perspective view of the footwear tread of the first
(22) Filed: Aug. 5, 2013 embodiment;
(51) LOC (10) Cl. ................................................ 02-04 FIG. 3 is a top plan view of the footwear tread of the first
(52) U.S. Cl embodiment;
USPG D2/957: D2/951 FIG. 4 is a front side elevational view of the footwear tread of
58) Field fo - - - - - ificati- - - - - -s - - - - - - - h- - - - - - - - s the first embodiment, the rear side being identical thereto;
(58) is." SS eart 908,916 918, 925 FIG. 5 is a right side elevational view of the footwear tread of
D2/946,962 977.36/3B 22 R 24 5 25 R. the first embodiment, the left side being identical thereto;
36/3s 32 R. 34 R 59 c 67 A 103 FIG. 6 is a plan view of the footwear tread of the first embodi
See appl1cauon
lication file
Ille fIor complete
s 1 st searcn
s h hist
n1Story. s ment applied in a different scale to an alternative unclaimed
shoe Sole;
FIG. 7 is a plan view of a footwear tread applied to an
(56) References Cited unclaimed shoe sole in accordance with a second embodi
U.S. PATENT DOCUMENTS ment of the ornamental design;
FIG. 8 is a perspective view of the footwear tread of the
3,018,571 A * 1/1962 Doherty ........................ 36,59 C second embodiment;
5-65. s : 286 Note CIO ...... 5.5. FIG. 9 is a top plan view of the footwear tread of the second
D414,023 S * 9/1999 Cretinonetal 556, embodiment;
D456,982 S * 5/2002 Rogers ............. D2,957 FIG. 10 is a front side elevational view of the footwear tread
D460,608 S * 7/2002 Laberge et al. ...... D2,957 of the second embodiment, the rear side being identical
D501,708 S * 2/2005 Andrews-Kramer .......... D2/960 thereto; and,
E. s : 39 alys-Kramer . . . . . . . . . R38s. FIG. 11 is a right side elevational view of the footwear tread
D550.436 S * 9, 2007 Matis et al... . . . . . . . D2/953 of the second embodiment, the left side being identical
D552,335 S * 10/2007 Matis et al. ...... D2,957 thereto.
7,322,131 B2 * 1/2008 Yamashita et al. ............ 36,59 R Broken lines are environmental only and form no part of the
(Continued) claimed design. Broken lines adjacent shaded areas of the
design represent the bounds of the claimed design and are not
FOREIGN PATENT DOCUMENTS themselves a part of the claimed design.
JP D1245895 7/2005 1 Claim, 5 Drawing Sheets
12
US D744,733 S
Page 2
(56) References Cited D639,539 S * 6, 2011 Lubart ........................... D2/951

D677,453 S * 3, 2013 Sakai ....... D2/959
U.S. PATENT DOCUMENTS D680,727 S * 4, 2013 Smith et al. .. D2,960
2010/0281711 A1* 11/2010 Vestuti et al. ..................... 36,28
D569,595 S * 5, 2008 Le ..... . . . . . . . . . . . . . . . . . . . . . . . . . . . . D2/960
2012/0110876 A1* 5, 2012 Lubart .......................... 36,59 C
D592,848 S. * 5/2009 Morgan D2,957
D619,346 S * 7, 2010 Moon . . . . . . . . . . . . . . . . . . . . . . . . . . . D2,957
* cited by examiner
13
14
U.S. Patent Dec. 8, 2015 Sheet 2 of 5 US D744,733 S
15
…*··:* *….
*
·
FG, 8
16
*
--.*
...
17
FG. Fict, 1
18
EXHIBIT B
USOOD785305S
(12) United States Design Patent (10) Patent No.: US D785,305 S

Adam et al. (45) Date of Patent: . May 2, 2017
13/34: A43B 13/36

(71) Applicant: TBL Licensing LLC, Wilmington, DE See application file for complete search history.
(US) (56) References Cited
(72) Inventors: Christopher Adam, Newburyport, MA U.S. PATENT DOCUMENTS
(US); Peter Dillon, Topsfield, MA 3,018,571 A 1/1962 Doherty
4,445,286 A 5/1984 Norton
(US); Michael P. Kirk, Beverly, MA D410,966 S 6/1999 Cretinon
(US) D414,023 S 9, 1999 Cretinon et al.
D456,982 S 5/2002 Rogers
D460,608 S 7/2002 Laberge et al.
(73) Assignee: TBL Licensing LLC, Stratham, NH D501,708 S 2/2005 Andrews-Kramer
(US) D504,205 S 4/2005 Andrews-Kramer
(Continued)
ck
(**) Term: 15 Years FOREIGN PATENT DOCUMENTS
(21) Appl. No.: 29/530,629 JP D1245895 7/2005
Primary Examiner — T. Chase Nelson
(22) Filed: Jun. 18, 2015 (74) Attorney, Agent, or Firm — Lerner, David,
Littenberg, Krumholz & Mentlik, LLP
Related U.S. Application Data
(57) CLAM
62) Division of application No. 29/462.480, filed on Aug.
(62) Division of application No 48U, Illed on Aug The ornamental design for a footwear tread, as shown and
5, 2013, now Pat. No. Des. 744,733. described.
(51) LOC (10) Cl. ............................................... 02-04 DESCRIPTION
(52) U.S. Cl.
USPC ................. D2/957. D2/951; D2/954; D2/960 FIG. 1 is a plan View of a footwear tread applied to an
s s s unclaimed shoe sole in accordance with the ornamental
(58) Field of Classification Search design;
USPC ................. D2/902,906, 908, 916,918, 925, FIG. 2 is an enlarged perspective view of the footwear tread
D2/946 962, 977: 36/3 B, 22 R, 24.5, of the design seen within the dot-dash circle of FIG. 1, but
36/25R 28, 32 R. 34 R 59 C, 67 A 103 with all of the unclaimed environment removed for clarity of
depiction;
CPC ....... A43B 13/00; A43B 13/02: A43B 13/023; FIG. 3 is a top elevational view thereof;
A43B 13/026; A43B 13/04; A43B 13/08: FIG. 4 is a front side elevational view thereof, the rear side
A43B 13/10; A43B 13/12: A43B 13/14; being identical thereto; and,
A43B 13/141; A43B 13/143; A43B FIG. 5 is a right side elevational view thereof, the left side
being identical thereto.
13/16: A43B 13/18: A43B 13/181; A43B The broken lines depict environmental structure that forms
13/187; A43B 13/189; A43B 13/20: A43B no part of the claimed design. The dot-dash circle seen in the
13/22: A43B 13/223; A43B 13/24: A43B (Continued)
19
US D785,305 S
Page 2
FIG. 1 view depicts the area of enlargement seen in the

views of FIGS. 2 through 5, and also forms no part of the
claimed design.
1 Claim, 3 Drawing Sheets
(56) References Cited

U.S. PATENT DOCUMENTS
D509,346 S 9, 2005 Recchi
D550,436 S 9, 2007 Matis et al.
D552,335 S 10/2007 Matis et al.
7,322,131 B2 * 1/2008 Yamashita ........... A43B 13,223
36.30 R
D569,595 S 5, 2008 Le
D592,848 S 5/2009 Morgan
D619,346 S 7, 2010 Moon
D639,539 S 6, 2011 Lubart
D677,453 S 3/2013 Sakai
D680,727 S 4/2013 Smith et al.
D743,678 S * 1 1/2015 Dombrow ...................... D2/951
D759,359 S * 6/2016 Dombrow ...................... D2/951
D764,780 S * 8/2016 Strother ......................... D2/951
2010/0281711 A1 11/2010 Vestuti et al.
2012/0110876 A1 5, 2012 Lubart
* cited by examiner
20
U.S. Patent May 2, 2017 Sheet 1 of 3 US D785,305 S
Fig. 1
21
22
23

TBL Licensing v. Kotoni - Complaint

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Case 2:18-cv-03950-R-RAO Document 1 Filed 05/11/18 Page 1 of 12 Page ID #:1

1 Marsha E. Diedrich (State Bar No. 93709)

COMPLAINT FOR PATENT INFRINGEMENT

1 TBL Licensing LLC (“Timberland” or “Plaintiff”), by and through its

1 ’D733 Patent Defendant’s NOLTE Footwear

1 ’D305 Patent Defendant’s NOLTE Footwear

1 PRAYER FOR RELIEF

1 DEMAND FOR JURY TRIAL

(12) United States Design Patent (10) Patent No.: US D744,733 S

(**) Term: 14 Years FIG. 1 is a plan view of a footwear tread applied to an

(56) References Cited D639,539 S * 6, 2011 Lubart ........................... D2/951

U.S. Patent Dec. 8, 2015 Sheet 2 of 5 US D744,733 S

U.S. Patent Dec. 8, 2015 Sheet 3 of 5 US D744,733 S

U.S. Patent Dec. 8, 2015 Sheet 4 of 5 US D744,733 S

U.S. Patent Dec. 8, 2015 Sheet 5 of 5 US D744,733 S

(12) United States Design Patent (10) Patent No.: US D785,305 S

13/34: A43B 13/36

FIG. 1 view depicts the area of enlargement seen in the

(56) References Cited

U.S. Patent May 2, 2017 Sheet 1 of 3 US D785,305 S

U.S. Patent May 2, 2017 Sheet 2 of 3 US D785,305 S

U.S. Patent May 2, 2017 Sheet 3 of 3 US D785,305 S

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