Case 2:22-cv-01144 Document 1 Filed 02/18/22 Page 1 of 15 Page ID #:1
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`Elizabeth Yang (SBN: 249713)
`Email: elizabeth@yanglawoffices.com
`Matthew Trejo (SBN: 320464)
`Email: matt@yanglawoffices.com
`YANG LAW OFFICES
`199 W. Garvey Ave., Suite 201
`Monterey Park, CA 91754
`Telephone: (877) 492-6452
`Facsimile: (626) 988-8827
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`Attorney for Plaintiffs,
`
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`OCM Globe Inc., a California
`corporation
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` PLAINTIFFS,
` vs.
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`Apollo Food International, Inc., a New
`York Corporation; A&C Best Food
`Trading, Inc., a New York corporation
`and DOES 1-100, inclusive
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` DEFENDANTS.
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`UNITED STATES DISTRICT COURT
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`CENTRAL DISTRICT OF CALIFORNIA
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`Case No.:
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`Complaint for:
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`1. Trademark Infringement under
`15 U.S.C. § 1114
`2. Unfair Competition and False
`Designation of Origin under 15
`U.S.C. § 1125(a)
`3. Common Law Trademark
`Infringement
`4. Unfair Competition Under
`California Business & Professions
`Code § 17200 et seq.
`5. Common Law Unfair
`Competition
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`DEMAND for JURY TRIAL
`
`COMPLAINT
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`COMPLAINT
`Come now, OCM Globe, Inc., (“OCM” or “Plaintiff”) allege, based upon personal
`knowledge or upon information and belief as to matter not within their own
`personal knowledge, as follows:
`JURISDICTION AND VENUE
`1. This subject matter jurisdiction of this Court is based upon 15 U.S.C. § 1121
`and 28 U.S.C. §§1331, 1338.
`2. The Court has supplemental jurisdiction over the sate law claims, pursuant
`to 28 U.S.C. § 1367.
`3. Venue is proper in this Court pursuant to 28 U.S.C. 1391(b) and (c) because
`a substantial part of the events giving rise to the claims for relief occurred in
`this district; the Defendant is subject to personal jurisdiction in this judicial
`District at the relevant time.
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`PARTIES
`4. Plaintiff OCM Globe, Inc., a California corporation (“OCM”), is a
`corporation incorporated in the State of California with its principal place of
`business in Los Angeles County, City of Industry, California.
`5. On information and belief Defendant, Apollo Food International, Inc., a
`New York corporation, is a corporation organized under the laws of the State
`of New York with its principal place of business in Long Island City, New
`York.
`6. On information and belief Defendant, A&C Best Food Trading, Inc., a New
`York corporation, is a corporation organized under the laws of the State of
`New York with its principal place of business in Long Island City, New
`York.
`7. Plaintiffs are unaware of the true names and capacities of the defendants
`sued as Does 1 through 100, inclusive, and therefore sues those defendants
`COMPLAINT
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`by such fictitious names. Plaintiff will amend this Complaint to allege their
`true names and capacities when that information is ascertained. Plaintiffs’
`allege such fictitiously named defendants is responsible in some manner for
`the occurrences herein alleged, and that plaintiffs’ injuries as herein alleged
`were proximately caused by said defendants.
`8. On information and belief, Defendants’ actions alleged herein were
`undertaken by each defendant(s) individually.
`GENERAL ALLEGATIONS
`9. OCM is generally in the merchandising business related to grocery products.
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`10.OCM makes purchases from suppliers and sells to retailers, grocery stores
`or supermarkets in the United States. OCM is, at relevant times, the exclusive
` licensee and distributor of certain brands of grocery products, the brands
` include: GENKI FOREST,
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` (the “Brands”).
` ,
` and
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`Attached hereto and incorporated herein by reference as Exhibit A is the
`Authorization Letter. Said authorization letter gives plaintiff standing to
`bring this action.
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`11. OCM is, at relevant times, the exclusive US licensee of the Brands, which
`includes the following registered marks with the United States Patent and
`Trademark Office (“USPTO”), having registration number(s):
`a. Registration No. 6070585;
`b. Registration No. 6070586;
`(collectively the “Registered Marks”). A true and correct copy of the
`Trademark Registration for Registration No. 6070585 is attached hereto
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`COMPLAINT
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`as Exhibit B and incorporated herein by reference. A true and correct
`copy of the Trademark Registration for Registration No. 6070586 is
`attached hereto as Exhibit C and incorporated herein by reference.
`12. OCM is, at all relevant times, the exclusive US licensee of the Brands,
`which includes the following unregistered marks:
`a. Serial No. 88368878;
`b. Serial No. 88368875;
`c. Serial No. 88368874; and
`d. Serial No. 88368871.
`(collectively the “Unregistered Marks”).
`13. Plaintiff’s Brands consist of the Registered Marks and Unregistered Marks.
`14. Plaintiff has continuously used and acquired common law trademark rights
`in all the foregoing marks.
`15. It came to OCM’s attention that A&C Best Food Trading Inc. and Apollo
`Food International, Inc., make, use, import, sell and/or offer to sell certain
`products, as shown in Exhibit D and incorporated herein by reference, that
`are protected by the Lanham Act and/or the common law.
`16. Such unauthorized use of the Brands and the Registrations is in violation of
`the law and infringed upon OCM’s rights, as an exclusive licensee.
`17. On July 9, 2021, OCM sent a cease-and-desist letter to A&C Best Food
`Trading Inc., demanding that A&C Best Food Trading Inc. immediately
`cease the infringing activities. Attached hereto and incorporated herein by
`reference as Exhibit E is a true and correct copy of the cease-and-desist
`letter.
`18. On February 2, 2021, OCM sent a cease-and-desist letter to Apollo Food
`International, Inc., demanding that Apollo Food International, Inc.
`immediately cease the infringing activities. Attached hereto and incorporated
`COMPLAINT
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`herein by reference as Exhibit F is a true and correct copy of the cease-and-
`desist letter.
`19. Defendants, A&C Best Food Trading Inc. and Apollo Food International,
`Inc., having been put on notice, did not respond, nor did it attempt to avoid
`further infringing acts.
`20. Defendants’ infringement is blatant and intentional and has been causing
`harms to OCM, including loss of good will and loss of revenue.
`21. On information and belief, certain Defendants’ beverage products offered
`for sales in U.S. do not comply with the certification requirements set by
`United States Department of Agriculture (“USDA”), particularly regarding
`product sourcing and ingredients.
`22. On information and belief, Defendants either failed to comply with the
`necessary certification requirements or presented false certification for
`certain of the beverage products.
`23. Defendants’ business activities are unlawful and constitute unfair
`competition that caused and continues to cause harm to Plaintiff.
`24. On information and belief, from the observable market activities, Plaintiff
`estimated that it lost over $500,000 and the loss is ongoing.
`FIRST CLAIM FOR RELIEF
`TRADEMARK INFRINGEMENT
`UNDER 15 U.S.C. § 1114
`25. Plaintiff hereby re-alleges and incorporates by reference each and every
`allegation and statement contained in the prior paragraphs above, as if fully
`set forth herein.
`26. The Registered Marks are valid, protectable trademarks.
`27. OCM is the exclusive US licensee of the Registered Marks.
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`COMPLAINT
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`28. Defendants used the products shown in Exhibit D bearing marks similar to
`Plaintiff’s Registered Marks without the consent of the plaintiff in a manner
`that is likely to cause confusion among ordinary consumers as to the source,
`sponsorship, affiliation, or approval of the goods.
`29. Defendants’ activities as described herein are likely to cause confusion, to
`cause mistake, or to deceive as to source, affiliation, or sponsorship, in
`violation of the Lanham Act, 15 U.S.C. § 1114.
`30. Defendants infringed the Registered Marks with knowledge of plaintiffs'
`exclusive rights in those marks, and despite actual notice of infringement.
`Defendants’ infringement is intentional after being put on notice since
`February 2021 and July 2021. On information and belief, defendants’
`conduct is willful, deliberate, intentional, and in bad faith, making this an
`exceptional case.
`31. Defendants’ infringing acts caused plaintiff to suffer monetary loss and
`reduction of business goodwill in the Brands, the Registrations, as well as
`the marks in the Applications.
`32. As a direct and proximate result of defendants' trademark infringement,
`plaintiffs suffered damage in an amount to be proved at trial, but not less
`than $500,000 ($500,000). Plaintiffs are entitled to an accounting and
`disgorgement of profits in connection with the products in Exhibit D.
`33. As a direct and proximate result of defendants’ trademark infringement,
`defendants have caused, and will continue to cause, irreparable harm to
`plaintiffs and the goodwill associated with the Registered Marks, for which
`plaintiffs have no adequate remedy at law. Plaintiffs are entitled to
`injunctive relief against continuing infringements under 15 U.S.C. § 1116,
`destruction of infringing items under 15 U.S.C. § 1117, and a sworn report
`of defendants' compliance under 15 U.S.C. § 1116(a).
`COMPLAINT
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`34. Under the circumstances described herein, defendants will be unjustly
`enriched if they are allowed to profit by their wrongful conduct. Therefore,
`plaintiffs are entitled to a constructive trust on, and disgorgement of, all
`funds, assets, accounts, and business opportunities unjustly acquired by
`defendants.
`35. Plaintiff will continue to suffer additional harms and damages if such
`infringing acts continue.
`SECOND CLAIM FOR RELIEF
`UNFAIR COMPETITION AND FALSE DESIGNATION OF ORIGIN
`UNDER 15 U.S.C. § 1125(a)
`36. Plaintiff hereby re-alleges and incorporates by reference each and every
`allegation and statement contained in the prior paragraphs above, as if fully
`set forth herein.
`37. OCM, as the exclusive licensee of the Registered Marks and Unregistered
`Marks has acquired common law and federal trademark rights in the
`Unregistered Marks and Registered Marks.
`38. Defendants used the products shown in Exhibit D bearing marks similar to
`Plaintiff’s Registered Marks without the consent of the plaintiff in a manner
`that is likely to cause confusion among ordinary consumers as to the source,
`sponsorship, affiliation, or approval of the goods.
`39. Defendants infringed the Registered Marks and Unregistered Marks and are
`unfairly competing with plaintiff with knowledge of plaintiff’s exclusive
`rights in those marks, and despite actual notice of infringement. Defendants’
`infringement is intentional after being put on notice since February 2021 and
`July 2021. On information and belief, defendants’ conduct is willful,
`deliberate, intentional, and in bad faith, making this an exceptional case.
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`COMPLAINT
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`40. Defendants’ infringing acts caused plaintiff to suffer monetary loss and
`reduction of business goodwill in the Brands, the Registrations, as well as
`the marks in the Applications.
`41. As a direct and proximate result of defendants' trademark infringement,
`plaintiffs suffered damage in an amount to be proved at trial, but not less
`than $500,000 ($500,000). Plaintiffs are entitled to an accounting and
`disgorgement of profits in connection with the products in Exhibit D.
`42. As a direct and proximate result of defendants’ trademark infringement,
`defendants have caused, and will continue to cause, irreparable harm to
`plaintiffs and the goodwill associated with the Registered Marks and
`Unregistered Marks, for which plaintiffs have no adequate remedy at law.
`Plaintiffs are entitled to injunctive relief against continuing infringements
`under 15 U.S.C. § 1116, destruction of infringing items under 15 U.S.C. §
`1117, and a sworn report of defendants' compliance under 15 U.S.C. §
`1116(a).
`43. Under the circumstances described herein, defendants will be unjustly
`enriched if they are allowed to profit by their wrongful conduct. Therefore,
`plaintiffs are entitled to a constructive trust on, and disgorgement of, all
`funds, assets, accounts, and business opportunities unjustly acquired by
`defendants.
`44. Plaintiff will continue to suffer additional harms and damages if such
`infringing acts continue.
`THIRD CLAIM FOR RELIEF
`COMMON LAW TRADEMARK INFRINGEMENT
`45. Plaintiff hereby re-alleges and incorporates by reference each and every
`allegation and statement contained in the prior paragraphs above, as if fully
`set forth herein.
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`COMPLAINT
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`46. OCM, as the exclusive licensee of the Registered Marks and Unregistered
`Marks has acquired common law and federal trademark rights in the
`Unregistered Marks and Registered Marks.
`47. Defendants used the products shown in Exhibit D bearing marks similar to
`Plaintiff’s Registered Marks without the consent of the plaintiff in a manner
`that is likely to cause confusion among ordinary consumers as to the source,
`sponsorship, affiliation, or approval of the goods.
`48. Defendants infringed the Registered Marks and Unregistered Marks and are
`unfairly competing with plaintiff with knowledge of plaintiff’s exclusive
`rights in those marks, and despite actual notice of infringement. Defendants’
`infringement is intentional after being put on notice since February 2021 and
`July 2021. On information and belief, defendants’ conduct is willful,
`deliberate, intentional, and in bad faith, making this an exceptional case.
`49. Defendants’ infringing acts caused plaintiff to suffer monetary loss and
`reduction of business goodwill in the Brands, the Registrations, as well as
`the marks in the Applications.
`50. As a direct and proximate result of defendants' trademark infringement,
`plaintiffs suffered damage in an amount to be proved at trial, but not less
`than $500,000 ($500,000). Plaintiffs are entitled to an accounting and
`disgorgement of profits in connection with the products in Exhibit D.
`51. As a direct and proximate result of defendants’ trademark infringement,
`defendants have caused, and will continue to cause, irreparable harm to
`plaintiffs and the goodwill associated with the Registered Marks and
`Unregistered Marks, for which plaintiffs have no adequate remedy at law.
`Plaintiffs are entitled to injunctive relief against continuing infringements
`and destruction of continuing infringements.
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`COMPLAINT
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`52. Defendants’ conduct was malicious, fraudulent, oppressive, and despicable
`within the meaning of California law. Plaintiff is therefore entitled to an
`award of exemplary damages and punitive damages against defendants in a
`sum appropriate to punish and to make an example of them.
`53. Under the circumstances described herein, defendants will be unjustly
`enriched if they are allowed to profit by their wrongful conduct. Therefore,
`plaintiffs are entitled to a constructive trust on, and disgorgement of, all
`funds, assets, accounts, and business opportunities unjustly acquired by
`defendants.
`54. Plaintiff will continue to suffer additional harms and damages if such
`infringing acts continue.
`FOURTH CLAIM FOR RELIEF
`UNFAIR COMPETITION UNDER CALIFORNIA
`BUSINESS & PROFESSIONS CODE § 17200 et seq.
`55. Plaintiff hereby re-alleges and incorporates by reference each and every
`allegation and statement contained in the prior paragraphs above, as if fully
`set forth herein.
`56. Defendants’ acts of unfair competition constitute unlawful business practices
`in Violation of California Business and Professions Code Section 17200 et
`seq.
`57. Plaintiff suffered injury and lost money or property as a result of
`Defendants’ unfair competition.
`58. As a result, Plaintiffs are entitled to injunctive relief pursuant to California
`Business & Professions Code § 17203, and an award restoring to Plaintiffs
`any and all monies acquired by defendants by means of such unlawful,
`unfair, or fraudulent business acts or practices.
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`COMPLAINT
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`59. Under the circumstances described herein, Defendants will be unjustly
`enriched if they are allowed to profit by their wrongful conduct. Therefore,
`Plaintiffs are entitled to a constructive trust on, and disgorgement of, all
`funds, assets, accounts, and business opportunities unjustly acquired by
`defendants.
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`FIFTH CLAIM FOR RELIEF
`COMMON LAW UNFAIR COMPETITION
`60. Plaintiff hereby re-alleges and incorporates by reference each and every
`allegation and statement contained in the prior paragraphs above, as if fully
`set forth herein.
`61. OCM, as the exclusive licensee of the Registered Marks and Unregistered
`Marks has acquired common law and federal trademark rights in the
`Unregistered Marks and Registered Marks.
`62. Defendants used the products shown in Exhibit D bearing marks similar to
`Plaintiff’s Registered Marks without the consent of the plaintiff in a manner
`that is likely to cause confusion among ordinary consumers as to the source,
`sponsorship, affiliation, or approval of the goods.
`63. Defendants infringed the Registered Marks and Unregistered Marks and are
`unfairly competing with plaintiff with knowledge of plaintiff’s exclusive
`rights in those marks, and despite actual notice of infringement. Defendants’
`infringement is intentional after being put on notice since February 2021 and
`July 2021. On information and belief, defendants’ conduct is willful,
`deliberate, intentional, and in bad faith, making this an exceptional case.
`64. Defendants’ infringing acts caused plaintiff to suffer monetary loss and
`reduction of business goodwill in the Brands, the Registrations, as well as
`the marks in the Applications.
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`COMPLAINT
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`65. As a direct and proximate result of defendants' unfair competition, plaintiffs
`suffered damage in an amount to be proved at trial, but not less than
`$500,000 ($500,000). Plaintiffs are entitled to an accounting and
`disgorgement of profits in connection with the products in Exhibit D.
`66. As a direct and proximate result of defendants’ trademark infringement,
`defendants have caused, and will continue to cause, irreparable harm to
`plaintiffs and the goodwill associated with the Registered Marks and
`Unregistered Marks, for which plaintiffs have no adequate remedy at law.
`Plaintiffs are entitled to injunctive relief against continuing infringements
`and destruction of continuing infringements.
`67. Defendants’ conduct was malicious, fraudulent, oppressive, and despicable
`within the meaning of California law. Plaintiff is therefore entitled to an
`award of exemplary damages and punitive damages against defendants in a
`sum appropriate to punish and to make an example of them.
`68. Under the circumstances described herein, defendants will be unjustly
`enriched if they are allowed to profit by their wrongful conduct. Therefore,
`plaintiffs are entitled to a constructive trust on, and disgorgement of, all
`funds, assets, accounts, and business opportunities unjustly acquired by
`defendants.
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`PRAYER FOR RELIEF
`WHEREFORE, plaintiffs pray for judgment in their favor and
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`against defendants as follows:
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`1. On all claims for relief, for damages in an amount to be proved at
`trial, but not less than $500,000.
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`2. On all claims for relief, for an accounting of all profits realized by
`defendants, and all others acting in concert or participating with them, in
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`COMPLAINT
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`connection with the Fully Surprise Egg, and disgorgement of all monetary gains,
`profits, and advantages derived therefrom.
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`3. On all claims for relief, for injunctive relief, preliminarily and
`permanently enjoining defendants and their assignees, transferees, employees,
`agents, and representatives, and all others acting in concert or participating with
`them from engaging in the unlawful acts alleged herein, including the following:
`(a) Manufacturing, selling, offering to sell, marketing, advertising,
`promoting, importing, shipping, distributing, and otherwise exploiting the
`products in Exhibit D.
`(b) Using, reproducing, copying, duplicating, displaying, distributing,
`advertising, and otherwise exploiting the Registered Marks and Unregistered
`Marks.
`(c) Using, displaying, marketing, advertising, promoting, importing,
`shipping, distributing, registering, transferring, assigning, and otherwise
`exploiting any mark or trade dress that is confusingly similar to the
`Registered Marks and Unregistered Marks.
`4. On all claims for relief, for destruction of infringing items.
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`5. On the First and Second Claims for Relief, for an order requiring
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`defendants, pursuant to 15 U.S.C. § 1116(a), to file with this Court and to serve
`upon plaintiffs within thirty (30) days after entry of an injunction, a report in
`writing and under oath, setting forth in detail the manner in which defendants
`complied with such judgment.
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`6. On the Third and Fifth of Action, for an award of exemplary and
`punitive damages against defendants in an amount not less than $5,000,000.
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`7. On the Fourth Claim for Relief, for restitutionary relief in an
`amount to be proved at trial.
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`COMPLAINT
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`8. On all claims for relief, for constructive trust and disgorgement of
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`all unjust enrichment.
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`9. For costs of suit, attorney's fees in an amount not less than
`$150,000, and prejudgment interest.
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`Dated: February 15, 2022,
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`YANG LAW OFFICES
`/s/ Elizabeth Yang
`Elizabeth Yang
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`COMPLAINT
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`Case 2:22-cv-01144 Document 1 Filed 02/18/22 Page 15 of 15 Page ID #:15
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`DEMAND FOR JURY TRIAL
`Plaintiff hereby demands a trial by jury.
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`Dated: February 15, 2022,
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`YANG LAW OFFICES
`/s/ Elizabeth Yang
`Elizabeth Yang
`Attorneys for Plaintiff,
`OCM Globe Inc., a California
`corporation
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`COMPLAINT
`15
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