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`Case 3:21-cv-09409-CRB Document 1 Filed 12/06/21 Page 1 of 18
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`G. ROXANNE ELINGS (pro hac vice pending)
` roxanneelings@dwt.com
`DAVIS WRIGHT TREMAINE LLP
`1251 Avenue of the Americas
`New York, New York 10020
`Telephone: (212) 489-8230
`Facsimile: (212) 489-8340
`
`ADAM S. SIEFF (CA Bar No. 302030)
` adamsieff@dwt.com
`DAVIS WRIGHT TREMAINE LLP
`865 South Figueroa Street, 24th Floor
`Los Angeles, California 90017
`Telephone: (213) 633-6800
`Facsimile: (213) 633-6899
`
`Attorneys for Plaintiffs
`GARAN, INC. and GARAN SERVICES CORP.
`
`
`
`UNITED STATES DISTRICT COURT
`
`NORTHERN DISTRICT OF CALIFORNIA
`
`
`
`
`vs.
`
`GARAN, INC. and GARAN SERVICES
`CORPORATION,
`
`
`
`
`
`GRIZZLY PEAK FARMS, LLC,
`
`
`
`
`
`
`
`
`Plaintiffs,
`
`Defendant.
`
`
`
`
`Case No.
`
`
`COMPLAINT FOR:
`
`
`(1) Trademark Dilution in Violation of
`15 U.S.C. § 1125(c);
`
`(2) Trademark Dilution in Violation of
`Cal. Bus. & Prof. Code § 14247;
`
`(3) Unfair Competition in Violation of
`Cal. Bus. & Prof. Code §§ 17200, et
`seq.
`
`
`
`JURY TRIAL DEMANDED
`
`
`
`
`
`
`COMPLAINT FOR
`TRADEMARK DILUTION
`
`
`1
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`DAVIS WRIGHT TREMAINE LLP
`865 S. FIGUEROA ST, SUITE 2400
`LOS ANGELES, CALIFORNIA 90017-2566
`Tel: (213) 633-6800
`
`Fax: (213) 633-6899
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`Case 3:21-cv-09409-CRB Document 1 Filed 12/06/21 Page 2 of 18
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`Plaintiffs Garan, Inc. and Garan Services Corp. (collectively, “Garan” or “Plaintiffs”), for
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`their complaint against defendant Grizzly Peak Farms, LLC (“Defendant”), allege as follows:
`
`PRELIMINARY STATEMENT
`
`1.
`
`The GARANIMALS brand has been a fixture in American culture since the early
`
`1970s, when Garan first coined the fanciful and arbitrary GARANIMALS trademark.
`
`GARANIMALS was founded on a simple but unique concept: to help parents affordably dress their
`
`young children in comfortable clothing that is easy to mix and match. The GARANIMALS brand
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`is sold through more than 4,700 Walmart stores across the United States, where 90 percent of the
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`population resides within 10 miles of a Walmart store.
`
`2.
`
`Defendant is using the fanciful and arbitrary GARANIMALS trademark to
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`advertise, promote, distribute, import/export, offer for sale and/or sell cannabis-derived goods under
`
`a “Garanimals” name (see images below). These products are illegal for most uses in most states.
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`Defendant’s use thus tarnishes Garan’s goodwill and reputation—as well as the innocent and
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`wholesome nature associated with the GARANIMALS brand (which is child and family friendly)—
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`and also blurs and weakens the public’s association of the GARANIMALS brand and
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`GARANIMALS Marks with GARANIMALS products. In both respects, Defendant’s use actually
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`impairs the distinctive character and reputation of the GARANIMALS Marks in violation of, inter
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`alia, Section 43(c) of the Lanham Act, 15 U.S.C. §1125(c), and various state and common laws.
`
`
`3.
`
`Garan has suffered actual damages as a result of Defendant’s unpermitted use, and
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`unless Defendant is enjoined, will continue to suffer the same. Garan accordingly files this action
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`pursuant to Section 43(c)(1) and 15 U.S.C. § 1125 (c)(1) to enjoin and recover damages and
`
`COMPLAINT FOR
`TRADEMARK DILUTION
`
`
`2
`
`DAVIS WRIGHT TREMAINE LLP
`865 S. FIGUEROA ST, SUITE 2400
`LOS ANGELES, CALIFORNIA 90017-2566
`Tel: (213) 633-6800
`
`Fax: (213) 633-6899
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`Case 3:21-cv-09409-CRB Document 1 Filed 12/06/21 Page 3 of 18
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`restitution from Defendant’s adoption and unpermitted use of the GARANIMAL trademark in
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`connection with the sale of cannabis and cannabis-related products.
`
`PARTIES
`
`4.
`
`Plaintiff Garan, Incorporated is a corporation organized and existing under the laws
`
`of the State of Delaware, with its principal place of business located at 200 Madison Avenue, New
`
`York, New York 10016.
`
`5.
`
`Plaintiff Garan Services Corporation is a wholly owned subsidiary of Garan,
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`Incorporated and is organized and existing under the laws of the State of Delaware, with its principal
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`place of business located at 200 Madison Avenue, New York, New York 10016.
`
`6.
`
`Defendant Grizzly Peak Farms, LLC is a limited liability company organized and
`
`existing under the laws of the State of California, with its principal place of business located at 200
`
`Hegenberger Road, Oakland, California 94621.
`
`JURISDICTION AND VENUE
`
`7.
`
`The Court has subject matter jurisdiction over this action pursuant to 28 U.S.C. §
`
`1331, 28 U.S.C. § 1338(a), 28 U.S.C. § 1338(b), 15 U.S.C. § 1121(a), and 28 U.S.C. § 1367.
`
`8.
`
`This Court has personal jurisdiction over Defendant because Defendant conducts
`
`business in this district and jurisdiction. Personal jurisdiction is also proper over Defendant because
`
`Defendant distribute, manufacture, advertise, promote, market, offer for sale and sell cannabis
`
`goods under the infringing GARANIMAL Mark and otherwise conduct business in California,
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`including in this judicial district, resulting in injury to Garan in California, including in this district.
`
`9.
`
`Venue in this district is proper pursuant to 28 U.S.C. § 1391(b) because, among other
`
`reasons, a substantial part of the events giving rise to the claims alleged occurred in this district and
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`further, on information and belief, Defendant transacts business within this district and distribute,
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`manufacture, advertise, promote, market, offer for sale and sell goods in this district in a manner
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`that dilutes and tarnishes Garan’s trademark rights. Venue is also proper pursuant to 28 U.S.C.
`
`§ 1391(d), as Defendant’s contacts with this district would be sufficient to establish personal
`
`jurisdiction within this district were it its own state.
`
`COMPLAINT FOR
`TRADEMARK DILUTION
`
`
`3
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`DAVIS WRIGHT TREMAINE LLP
`865 S. FIGUEROA ST, SUITE 2400
`LOS ANGELES, CALIFORNIA 90017-2566
`Tel: (213) 633-6800
`
`Fax: (213) 633-6899
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`Case 3:21-cv-09409-CRB Document 1 Filed 12/06/21 Page 4 of 18
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`FACTS COMMON TO ALL CLAIMS
`
`The Garanimals Brand
`
`The GARANIMALS brand has been a fixture in American culture since the early
`
`A.
`
`10.
`
`1970s, when Garan first coined the fanciful and arbitrary trademark. Since then, Garan has
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`continuously used GARANIMALS alone or in combination with other words and/or designs, many
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`of which are federally registered (collectively, the “GARANIMALS Marks”) to distribute, market,
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`advertise, promote, offer for sale and/or sell children’s apparel, including hosiery, undergarments,
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`outerwear and sleepwear; footwear; headwear, including hats and caps; books; bedding; games and
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`toys (including “plush”, bath, and learning toys) (“GARANIMALS Products”) to parents and
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`grandparents for use by their children and grandchildren.
`
`11.
`
`The GARANIMALS brand quickly gained recognition for its innovative system of
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`using animal hang-tags to help with the selection of clothes at the point-of-sale and sewn-in animal
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`labels to assist children with mixing and matching tops and bottoms.
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`12.
`
`The brand loyalty that GARANIMALS first cemented in the 1970s and 1980s has
`
`persisted over several generations as children and grandchildren who grew up wearing
`
`GARANIMALS Products now buy GARANIMALS Products for their own children and
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`grandchildren.
`
`13.
`
`Now, close to fifty years since its inception, GARANIMALS is one of the most
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`famous trademarks in the United States. This is in large part due to Garan’s significant investment
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`in the national distribution, promotion and advertisement of the GARANIMALS brand and the
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`uniqueness of the GARANIMALS tagging system which led to its ubiquitous place in the American
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`vocabulary.
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`14.
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`Since 2007, Garan has invested tens of millions of dollars to market and advertise
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`the GARANIMALS brand. Garan has consistently marketed the GARANIMALS brand on multiple
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`platforms such as mail, print (Parents, American Baby and People en Español), television (network
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`and cable channels including ABC Family, Animal Planet, Discovery, MTV, Bravo, Fuse, WE,
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`VH1, CMTV, E!, Lifetime, POP and 23 Spanish-language networks such as Univision, Telemundo,
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`and ESPNDeportes), and social media (Facebook, Instagram and YouTube).
`
`COMPLAINT FOR
`TRADEMARK DILUTION
`
`
`4
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`DAVIS WRIGHT TREMAINE LLP
`865 S. FIGUEROA ST, SUITE 2400
`LOS ANGELES, CALIFORNIA 90017-2566
`Tel: (213) 633-6800
`
`Fax: (213) 633-6899
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`Case 3:21-cv-09409-CRB Document 1 Filed 12/06/21 Page 5 of 18
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`15.
`
`The GARANIMALS Products are frequently featured on Walmart’s social media
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`accounts as well as its own. In 2019, Garan’s Facebook advertising around the GARANIMALS
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`brand reached more than 10 million people and resulted in more than 35 million impressions (i.e.,
`
`the number of people reached through additional engagement).
`
`16.
`
`Today, GARANIMALS is sold through Walmart, the largest retailer in the United
`
`States, with over 4,700 stores nationwide and through its website (walmart.com). GARANIMALS
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`is also marketed through the GARANIMALS website at www.garanimals.com (where the
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`consumer is redirected to the Walmart website).
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`17.
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`GARANIMALS popularity has translated into significant retail sales of more than
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`$4,000,000,000 during the last five years alone, representing a significant market share.
`
`18.
`
`Based on the longevity in popularity and success of GARANIMALS, it is no surprise
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`that the brand is an integral part of American culture and enjoys a high degree of recognition
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`nationally.
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`19.
`
`As an example, the NPD Group, a market research company, recently found that the
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`GARANIMALS brand ranks second in brand awareness among the general adult population in
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`connection with children’s clothing brands, ahead of vertically integrated competitors with their
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`own brick and mortar stores such as Old Navy, Children’s Place and Baby Gap.
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`20.
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`GARANIMALS popularity and fame is reflected by the high degree of unsolicited
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`media attention it has received, including at The Academy Awards Show, The Tonight Show with
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`Jimmy Fallon, Saturday Night Live, Glee, Shameless, and in connection with news stories covering
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`everything from fashion to pop culture to politics, as reported in The Wall Street Journal,
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`Newsweek, Entertainment Weekly, The Washington Post, GQ and The New York Times.
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`GARANIMALS has been connected to and/or mentioned by prominent American cultural figures,
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`including President Joe Biden, and celebrities Ryan Seacrest, Ryan Gosling, Zach Galifianakis, and
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`Bryan Cranston; become synonymous with a system of mixing and matching separates; been
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`credited as the inspiration for many fashion start-ups and trends; mentioned in several books and
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`featured in at least one book on popular culture, From ABBA to Zoom: A Pop Culture Encyclopedia
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`of the Late 20th Century, by David Mansaur; featured in the award-winning and iconic Dilbert
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`COMPLAINT FOR
`TRADEMARK DILUTION
`
`
`5
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`DAVIS WRIGHT TREMAINE LLP
`865 S. FIGUEROA ST, SUITE 2400
`LOS ANGELES, CALIFORNIA 90017-2566
`Tel: (213) 633-6800
`
`Fax: (213) 633-6899
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`Case 3:21-cv-09409-CRB Document 1 Filed 12/06/21 Page 6 of 18
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`comic strip; featured in the NY Times crossword puzzle; and, on a plethora of other occasions, has
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`been the subject of various political and other popular and well-known internet memes.
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`21.
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`Because of its longevity of continuous use, extensive advertising, nationwide
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`distribution, and high volume of sales of GARANIMALS Products, GARANIMALS Marks are
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`famous and widely recognized by consumers throughout the United States. Accordingly, the
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`GARANIMALS Marks enjoys substantial recognition and goodwill.
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`B.
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`22.
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`23.
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`The Garanimals Marks
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`In addition to being famous, the GARANIMALS Marks are distinctive.
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`The GARANIMALS Marks are coined, fanciful and arbitrary, and many of the
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`GARANIMALS Marks are registered under Section 2(f), indicating that the GARANIMALS Marks
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`have achieved acquired distinctiveness.
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`24.
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`Garan holds trademark applications and registrations for the GARANIMALS Marks
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`throughout the world, more than 30 in the United States alone, including GARANIMALS,
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`GARANIMAL, GARANIMALS EVERYDAY, GARANIMALS READING ZOO, 365 KIDS
`
`FROM GARANIMALS. See Exhibit A. Garan’s earliest trademark registrations date from the
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`1970s and 1980s, and include additional applications from as recently as 2020.
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`25. Many of Garan’s federal registrations of its GARANIMALS Marks are
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`incontestable within the meaning of Section 15 of the Lanham Act, 15 U.S.C. § 1065, and constitute
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`conclusive evidence that the marks are valid and that Garan is entitled to exclusive use of the
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`GARANIMALS Marks in commerce throughout the United States in connection with the goods
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`related thereto.
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`C.
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`26.
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`Defendant’s Use of the Garanimals Mark
`
`Decades after the GARANIMALS marks acquired their distinction and fame,
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`Defendant began to use (and still continue to use) the GARANIMALS Marks in connection with
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`the commercial distribution and sale of cannabis and cannabis-related products in markets within
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`the State of California, including counties located within this judicial district.
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`27.
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`Defendant’s use of the GARANIMALS Marks in connection with cannabis products
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`tarnishes and blurs, and thus dilutes, the GARANIMALS brand. The GARANIMALS brand is a
`
`COMPLAINT FOR
`TRADEMARK DILUTION
`
`
`6
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`DAVIS WRIGHT TREMAINE LLP
`865 S. FIGUEROA ST, SUITE 2400
`LOS ANGELES, CALIFORNIA 90017-2566
`Tel: (213) 633-6800
`
`Fax: (213) 633-6899
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`Case 3:21-cv-09409-CRB Document 1 Filed 12/06/21 Page 7 of 18
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`wholesome, family-oriented children’s brand. Consumers associate GARANIMALS-branded
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`products—which can be mixed, matched, and collected—with the playful, whimsical innocence of
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`childhood. The value of a GARANIMALS product, as distinguished from other children’s clothes
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`and toys, derives from these associated feelings and impressions, as well as the memories
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`GARANIMALS have made with American consumers across their lives during the past 50 years.
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`GARANIMALS relies upon these connections to market and sell products, and to develop new
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`products that will appeal to these same sentiments and establish future generations of loyal
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`customers.
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`28.
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`By impermissibly using the GARANIMALS Marks to sell cannabis-derived
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`products that are controversial and in some cases illegal, Defendant tarnishes and damages the
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`reputation of the GARANIMALS brand by affiliating it with products and conduct that are
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`inconsistent with the wholesome, playful, innocent, and family-friendly sentiments that underlie the
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`GARANIMALS brand, and that provide GARANIMALS products with a significant portion of
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`their market value.
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`29.
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`Defendant’s impermissible use of the GARANIMALS Marks also harms Garan by
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`multiplying the meanings associated with the GARANIMALS Marks, and, as a result, weakening
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`the GARANIMALS Marks’ ability to evoke their original associations. Consumers who become
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`familiar with “Garanimals” as a cannabis-related product will less readily associate the
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`GARANIMALS Marks with the GARANIMALS brand of children’s apparel and toys, and the
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`sentiments that Garan relies upon to market and sell its products.
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`30.
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`In both of these respects, Defendant’s use impairs the distinctiveness of the
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`GARANIMALS Marks, diminishing the value of Garan’s interests in the GARANIMALS Marks,
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`and causing Garan to suffer lost revenues and other damages.
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`FIRST CLAIM FOR RELIEF
`(Trademark Dilution)
`15 U.S.C. § 1125(c)
`
`31.
`
`Garan realleges and incorporates by reference the allegations in paragraphs 1
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`through 30, as if set forth fully herein.
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`COMPLAINT FOR
`TRADEMARK DILUTION
`
`
`7
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`DAVIS WRIGHT TREMAINE LLP
`865 S. FIGUEROA ST, SUITE 2400
`LOS ANGELES, CALIFORNIA 90017-2566
`Tel: (213) 633-6800
`
`Fax: (213) 633-6899
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`Case 3:21-cv-09409-CRB Document 1 Filed 12/06/21 Page 8 of 18
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`32.
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`Because of the high degree of distinctiveness of the GARANIMALS Marks, the
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`nearly fifty years of continuous use of the GARANIMALS Marks by Garan, the vast publicity the
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`GARANIMALS Marks has received, the extent to which the GARANIMALS Marks is used
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`nationally and the high degree of consumer recognition of the GARANIMALS Marks, the
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`GARANIMALS Marks is and has become famous pursuant to 15 U.S.C. § 1125(c).
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`33.
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`Garan’s use of GARANIMALS began at least as early as 1972, when Garan
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`registered the first of the GARANIMALS Marks.
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`34.
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`Defendant’s unpermitted use of the GARANIMALS Marks tarnishes Garan’s
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`goodwill and reputation associated with the GARANIMALS brand as child and family friendly.
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`Defendant’s unpermitted use of the GARANIMALS Marks, in connection with cannabis products,
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`also weakens the GARANIMALS Marks’ ability to evoke their original associations, and thus blurs
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`their meaning.
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`35.
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`Garan accordingly has been and will continue to be damaged by Defendant’s use of
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`the GARANIMALS Marks.
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`36.
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`Garan is entitled to recover damages as provided by Section 35(a) of the Lanham
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`Act, 15 U.S.C. § 1117(a) and is further entitled to injunctive relief under 15 U.S.C. § 1116(a) to
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`prevent Defendant’s use of the GARANIMALS Marks in connection with cannabis and cannabis-
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`related goods.
`
`SECOND CLAIM FOR RELIEF
`(Trademark Dilution under California Law)
`California Business & Professions Code § 14247
`
`37.
`
`Garan realleges and incorporates by reference the allegations in paragraphs 1
`
`through 36, as if set forth fully herein.
`
`38.
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`The GARANIMALS Marks are widely recognized by the general consuming public
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`of this state, or by a geographic area of this state, as a designation of source of the goods or services
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`of the mark’s owner.
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`39.
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`Defendant’s use GARANIMALS Marks as an ornament, decoration, garnishment,
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`or embellishment on or in connection with cannabis or cannabis-related products, for the purpose
`
`COMPLAINT FOR
`TRADEMARK DILUTION
`
`
`8
`
`DAVIS WRIGHT TREMAINE LLP
`865 S. FIGUEROA ST, SUITE 2400
`LOS ANGELES, CALIFORNIA 90017-2566
`Tel: (213) 633-6800
`
`Fax: (213) 633-6899
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`15
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`16
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`17
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`18
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`19
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`20
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`21
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`22
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`23
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`24
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`25
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`26
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`27
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`28
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`

`
`
`Case 3:21-cv-09409-CRB Document 1 Filed 12/06/21 Page 9 of 18
`
`of enhancing the commercial value of, or selling or soliciting purchases of, cannabis and/or
`
`cannabis-related products, without prior consent of the owner of the mark.
`
`40.
`
`Garan is entitled to an injunction against Defendant’s commercial use of the
`
`GARANIMALS Marks pursuant to California Business and Professions Code § 14247(b).
`
`THIRD CLAIM FOR RELIEF
`(California Unfair Competition)
`California Business & Professions Code § 17200
`
`41.
`
`Garan realleges and incorporates by reference the allegations in paragraphs 1
`
`through 40, as if set forth fully herein.
`
`42.
`
`Defendant’s unpermitted use of the GARANIMALS Marks to market, sell, and/or
`
`distribute cannabis-related products constitutes a business practice pursuant to California Business
`
`and Professions Code § 17200.
`
`43.
`
`Defendant’s unpermitted use of the GARANIMALS Marks to market, sell, and/or
`
`distribute cannabis-related products violates federal and state trademark laws, as alleged above.
`
`44.
`
`Defendant’s unpermitted use of the GARANIMALS Marks to market, sell, and/or
`
`distribute cannabis-related products has diminished the value of Garan’s interests in the
`
`GARANIMALS Marks, and caused Garan to suffer lost revenues.
`
`45.
`
`Garan is accordingly entitled to restitution, injunctive relief, and attorneys’ fees.
`
`PRAYER FOR RELIEF
`
`WHEREFORE, Garan prays for entry of judgment ordering that:
`
`1.
`
`Defendant has diluted by
`
`tarnishment and blurring Plaintiffs’
`
`famous
`
`GARANIMALS Marks under § 43(c)(1) of the Federal Trademark Act, 15 U.S.C. § 1125(c)(1), as
`
`well as California Business and Professions Code § 14247.
`
`2.
`
`Defendant’s conduct is an unlawful business practice prohibited by California
`
`Business and Professions Code § 17200.
`
`3.
`
`Defendant and each of its agents, employees, servants, attorneys, successors and
`
`assigns, and all others in privity or acting in concert therewith, shall be preliminarily and
`
`permanently enjoined from using any trademark, service mark, corporate name, domain name or
`
`other commercial indication of origin that consists of or incorporates the GARANIMALS Marks or
`
`COMPLAINT FOR
`TRADEMARK DILUTION
`
`
`9
`
`DAVIS WRIGHT TREMAINE LLP
`865 S. FIGUEROA ST, SUITE 2400
`LOS ANGELES, CALIFORNIA 90017-2566
`Tel: (213) 633-6800
`
`Fax: (213) 633-6899
`
`
`
`
`
`1
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`2
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`3
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`4
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`5
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`6
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`7
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`8
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`9
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`10
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`11
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`12
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`13
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`14
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`15
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`16
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`17
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`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`26
`
`27
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`28
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`
`
`
`
`
`
`

`

`
`
`Case 3:21-cv-09409-CRB Document 1 Filed 12/06/21 Page 10 of 18
`
`any other trademark, service mark, corporate name, or other commercial indication of origin that
`
`tarnishes, blurs, or diminishes the distinctive quality of the famous GARANIMALS Marks, or is
`
`otherwise contrary to law.
`
`4.
`
`Defendants shall be required to account for and pay monetary damages, including
`
`restitution, in amounts to be proven at trial.
`
`5.
`
`Plaintiffs shall be awarded their costs and attorneys’ fees incurred in this action,
`
`along with any other relief that the Court deems just and proper.
`
`DEMAND FOR JURY TRIAL
`
`Pursuant to Federal Rule of Civil Procedure 38(b), Garan demands a trial by jury of all the
`
`issues so triable.
`
`
`DATED: December 6, 2021
`
`DAVIS WRIGHT TREMAINE LLP
`
`By: /s/ Adam S. Sieff
` Adam S. Sieff
`
`
`Attorneys for Plaintiffs
`GARAN, INC. and
`GARAN SERVICES CORP.
`
`
`
`COMPLAINT FOR
`TRADEMARK DILUTION
`
`
`10
`
`DAVIS WRIGHT TREMAINE LLP
`865 S. FIGUEROA ST, SUITE 2400
`LOS ANGELES, CALIFORNIA 90017-2566
`Tel: (213) 633-6800
`
`Fax: (213) 633-6899
`
`
`
`
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`26
`
`27
`
`28
`
`
`
`
`
`
`
`

`

`Case 3:21-cv-09409-CRB Document 1 Filed 12/06/21 Page 11 of 18
`Case 3:21-cv-09409-CRB Document1 Filed 12/06/21 Page 11 of 18
`
`EXHIBIT A
`EXHIBIT A
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`

`

`Case 3:21-cv-09409-CRB Document 1 Filed 12/06/21 Page 12 of 18
`
`
`
`MARK
`
`EASY-PEASY BY
`GARANIMALS
`
`EASY-PEASY BY
`GARANIMALS
`
`EASY-PEASY BY
`GARANIMALS
`
`GARANIMALS
`
`GARANIMALS READING
`ZOO
`
`APP. NO.
`APP. DATE
`App 97022900
`App September
`15, 2021
`App 97022387
`App September
`15, 2021
`App 97022381
`App September
`15, 2021
`App 90432856
`App December
`30, 2020
`App 90298646
`App November
`4, 2020
`
`365 KIDS
`FROM GARANIMALS
`
`App 90298366
`App November
`4, 2020
`
`App 88833017
`App 13-MAR-
`2020
`App 88816999
`App 02-MAR-
`2020
`App 88817010
`App 02-MAR-
`2020
`
`App 88817070
`App 02-MAR-
`2020
`App 88817094
`App 02-MAR-
`2020
`
`GARANIMALS WE GO
`TOGETHER
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`REG. NO.
`REG. DATE
`
`GOODS AND SERVICES
`
`IC 24 BATH LINEN; BED BLANKETS; BED LINEN; CRIB
`BUMPERS; HOUSEHOLD LINEN; SWADDLING BLANKETS.
`
`IC 18 BACKPACKS; KNAPSACKS; UMBRELLAS; WALLETS;
`ALL-PURPOSE CARRYING BAGS; CHANGE PURSES; DUFFLE
`BAGS; FANNY PACKS; TOTE BAGS.
`IC 25 FOOTWEAR; HEADWEAR; HOSIERY; SLEEPWEAR;
`BOTTOMS AS CLOTHING; TOPS AS CLOTHING.
`
`IC 35 ON-LINE RETAIL STORE SERVICES FEATURING
`APPAREL, FOOTWEAR, CARRYING BAGS, HOUSEHOLD
`LINEN, TOYS, GAMES AND PUZZLES
`IC 41 PROVIDING ONLINE INFORMATION IN THE FIELD OF
`EDUCATIONAL PUBLICATIONS ABOUT ANIMALS;
`PROVIDING ON-LINE NON-DOWNLOADABLE
`PUBLICATIONS, NAMELY, BOOKS, NEWSLETTERS AND
`MAGAZINES IN THE FIELD OF ANIMALS
`IC 9 SUNGLASSES
`IC 14 RINGS, BRACELETS, NECKLACES, JEWELRY BOXES
`IC 18 BAGS, NAMELY, SPORTS BAGS, BACKPACKS, PURSES,
`ALL-PURPOSE CARRYING BAGS, AND UMBRELLAS
`IC 25 HEADBANDS
`IC 26 BARRETTES AND HAIR CLIPS
`INT. CL. 25 CLOTHING, NAMELY, TOPS AND BOTTOMS;
`CLOTHING, NAMELY, ONE PIECE GARMENTS FOR
`CHILDREN
`INT. CL. 25 CLOTHING, NAMELY, TOPS AND BOTTOMS;
`CLOTHING, NAMELY, ONE PIECE GARMENTS FOR
`CHILDREN
`INT. CL. 25 CLOTHING, NAMELY, TOPS AND BOTTOMS;
`CLOTHING, NAMELY, ONE PIECE GARMENTS FOR
`CHILDREN
`
`INT. CL. 25 CLOTHING, NAMELY, TOPS AND BOTTOMS;
`CLOTHING, NAMELY, ONE PIECE GARMENTS FOR
`CHILDREN
`INT. CL. 25 CLOTHING, NAMELY, TOPS AND BOTTOMS;
`CLOTHING, NAMELY, ONE PIECE GARMENTS FOR
`CHILDREN
`
`

`

`Case 3:21-cv-09409-CRB Document 1 Filed 12/06/21 Page 13 of 18
`
`
`
`MARK
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`GARANIMAL CRIBSIES
`
`CRIBSIES BY
`GARANIMALS
`
`BABY BASICS FROM
`GARANIMALS
`
`
`
`
`
`
`
`365 KIDS FROM
`GARANIMALS
`
`EVERYDAY
`GARANIMALS
`
`GARANIMALS
`EVERYDAY
`
`
`
`APP. NO.
`APP. DATE
`App 88817121
`App 02-MAR-
`2020
`
`App 88817137
`App 02-MAR-
`2020
`App 88695065
`App 16-NOV-
`2019
`
`
`
`
`
`
`
`App 87898875
`App 28-APR-
`2018
`
`Reg 5938926
`Reg 17-DEC-
`2019
`
`App 86559641
`App 10-MAR-
`2015
`App 86559662
`App 10-MAR-
`2015
`App 85847336
`App 12-FEB-
`2013
`App 85822956
`App 14-JAN-
`2013
`
`Reg 5023392
`Reg 16-AUG-
`2016
`Reg 5023393
`Reg 16-AUG-
`2016
`Reg 5041381
`Reg 13-SEP-
`2016
`Reg 4573171
`Reg 22-JUL-
`2014
`
`App 85822988
`App 14-JAN-
`2013
`
`Reg 4889844
`Reg 19-JAN-
`2016
`
`App 85980144
`App 28-NOV-
`2012
`
`App 85736972
`App 24-SEP-
`2012
`App 85736979
`App 24-SEP-
`2012
`
`Reg 4430103
`Reg 05-NOV-
`2013
`
`Reg 4472043
`Reg 21-JAN-
`2014
`Reg 4467507
`Reg 14-JAN-
`2014
`
`REG. NO.
`REG. DATE
`
`GOODS AND SERVICES
`
`INT. CL. 25 CLOTHING, NAMELY, TOPS AND BOTTOMS;
`CLOTHING, NAMELY, ONE PIECE GARMENTS FOR
`CHILDREN
`
`INT. CL. 25 CLOTHING, NAMELY, TOPS AND BOTTOMS;
`CLOTHING, NAMELY, ONE PIECE GARMENTS FOR
`CHILDREN
`INT. CL. 16 A SERIES OF CHILDREN'S BOOKS
`INT. CL. 18 ACCESSORIES, NAMELY, TOTE BAGS,
`BACKPACKS, FANNY PACKS, MESSENGER BAGS,
`HANDBAGS, WALLETS, KNAPSACKS, CHANGE PURSES,
`DUFFLE BAGS, BEACH BAGS, AND UMBRELLAS
`
`INT. CL. 25 CLOTHING, NAMELY, ONE PIECE GARMENTS
`FOR CHILDREN; CLOTHING, NAMELY, TOPS AND BOTTOMS
`
`INT. CL. 25 INFANT BODYSUITS; INFANT ROMPER SUITS
`
`INT. CL. 25 INFANT BODYSUITS; INFANT ROMPER SUITS
`
`INT. CL. 25 CLOTHING, NAMELY, TOPS AND BOTTOMS
`
`INT. CL. 25 CLOTHING, NAMELY, TOPS, BOTTOMS
`
`INT. CL. 25 CLOTHING, NAMELY, TOPS, BOTTOMS
`
`INT. CL. 25 CLOTHING, NAMELY, TOPS, BOTTOMS,
`SWEATSHIRTS AND HOODIES; SLEEPWEAR
`
`INT. CL. 25 CLOTHING, NAMELY, TOPS AND BOTTOMS
`
`INT. CL. 25 CLOTHING, NAMELY, TOPS AND BOTTOMS
`
`

`

`Case 3:21-cv-09409-CRB Document 1 Filed 12/06/21 Page 14 of 18
`
`
`
`MARK
`
`
`
`
`
`
`
`
`
`
`APP. NO.
`APP. DATE
`App 85392470
`App 08-AUG-
`2011
`
`App 85392495
`App 08-AUG-
`2011
`App 85183797
`App 23-NOV-
`2010
`
`REG. NO.
`REG. DATE
`Reg 4238802
`Reg 06-NOV-
`2012
`
`Reg 4238803
`Reg 06-NOV-
`2012
`Reg 4191352
`Reg 14-AUG-
`2012
`
`GARANIMALS BABY
`BASICS
`
`App 77956700
`App 11-MAR-
`2010
`
`Reg 4050024
`Reg 01-NOV-
`2011
`
`GARANIMALS
`
`App 77979530
`App 18-SEP-
`2008
`
`Reg 3823199
`Reg 20-JUL-
`2010
`
`
`
`
`
`
`
`App 77570759
`App 16-SEP-
`2008
`
`App 77981916
`App 19-SEP-
`2007
`
`Reg 3803956
`Reg 15-JUN-
`2010
`
`Reg 3994760
`Reg 12-JUL-
`2011
`
`
`
`GOODS AND SERVICES
`
`INT. CL. 25 CLOTHING, NAMELY, TOPS, BOTTOMS AND
`FOOTWEAR
`
`INT. CL. 25 CLOTHING, NAMELY, TOPS, BOTTOMS AND
`FOOTWEAR
`
`INT. CL. 16 CHILDREN'S BOOKS, CHILDREN'S ACTIVITY
`BOOKS, BOOKS THAT CAN BE USED IN THE BATH
`INT. CL. 24 BEDDING, NAMELY, BED SHEETS,
`COMFORTERS, BLANKETS, RECEIVING BLANKETS, PLUSH
`BLANKETS, FLANNEL BLANKETS, SWADDLE BLANKETS;
`THROWS, CRIB BUMPERS, BASSINET SHEETS, SHEET
`SAVERS, MATTRESS PADS, FABRIC VALANCES, FABRIC
`DIAPER STACKERS
`INT. CL. 25 FOOTWEAR; SHOES, ATHLETIC SHOES,
`SANDALS, SLIPPERS, HOSIERY, SOCKS, TIGHTS, LEG
`WARMERS, LEGGINGS; CHILDREN'S AND INFANTS' CLOTH
`BIBS
`INT. CL. 24 CLOTHS, NAMELY, FACE CLOTHS, WASH
`CLOTHS; CHILDREN'S BLANKETS, RECEIVING BLANKETS
`AND HOODED TOWELS
`INT. CL. 25 CLOTHING, NAMELY, TOPS, BOTTOMS, BABY
`BODYSUITS, GOWNS, SOCKS, HATS, MITTENS, BIBS NOT OF
`PAPER
`INT. CL. 28 TOYS, GAMES AND PLAYTHINGS, NAMELY,
`STUFFED TOYS, PLUSH TOYS, BEAN BAG PLUSH, PUPPETS,
`TOY PLASTIC FIGURES, PLASTIC PLAYSETS FOR USE IN THE
`BATH OR AT THE BEACH, PLASTIC PLAYSETS, NAMELY,
`PLASTIC SHAPE SORTERS, PLASTIC STACKING BLOCKS,
`LEARNING TOYS, PULL TOYS, MUSICAL TOYS, BOARD
`GAMES, CARD GAMES, MATCHING GAMES, PUZZLES, TOY
`BUILDING BLOCKS, TOY SOFT BLOCKS
`INT. CL. 25 FOOTWEAR
`
`INT. CL. 25 SWEATERS, JEANS, BATHING SUITS,
`SWIMWEAR, SLEEPWEAR, LEOTARDS, TIGHTS, ROMPERS,
`UNDERWEAR, HOSIERY
`
`

`

`Case 3:21-cv-09409-CRB Document 1 Filed 12/06/21 Page 15 of 18
`
`APP. NO.
`APP. DATE
`App 77978022
`App 19-SEP-
`2007
`
`REG. NO.
`REG. DATE
`Reg 3706928
`Reg 03-NOV-
`2009
`
`App 73561825
`App 07-OCT-
`1985
`
`Reg 1393357
`Reg 13-MAY-
`1986
`
`App 73561869
`App 07-OCT-
`1985
`
`Reg 1393358
`Reg 13-MAY-
`1986
`
`App 73250046
`App 13-FEB-
`1980
`
`App 72422254
`App 24-APR-
`1972
`
`Reg 1162044
`Reg 21-JUL-
`1981
`
`Reg 0954125
`Reg 27-FEB-
`1973
`
`GOODS AND SERVICES
`
`INT. CL. 25 CLOTHING, NAMELY, TOPS AND BOTTOMS,
`SWEATSHIRTS, PANTS, JEANS, SWEATPANTS, SHORTS,
`LEGGINGS, CAPRIS, DRESSES, HOODS, CREEPERS; AND
`FOOTWEAR, NAMELY, SHOES, BOOTS, SANDALS,
`SNEAKERS
`INT. CL. 25 CLOTHING, NAMELY, SHIRTS, PANTS, TOPS,
`SHORTS, SKIRTS, DRESSES, SUNDRESSES
`
`INT. CL. 25 CLOTHING, NAMELY, SHIRTS, PANTS, TOPS,
`SHORTS, SLEEPWEAR AND HOSIERY
`
`INT. CL. 25 CLOTHING, NAMELY, PANTS, TOPS,
`COVERALLS, OVERALLS, SUN SUITS, JUMPERS, SMOCKS,
`SHIRTS, BLOUSES, SHORTS, SKIRTS AND JEANS
`
`U.S. CL. 39 CHILDREN'S SHIRTS AND PANTS
`
`
`
`MARK
`
`
`
`
`
`
`
`GARANIMALS
`
`
`
`GARANIMAL
`
`
`
`
`
`

`

`Case 3:21-cv-09409-CRB Document 1 Filed 12/06/21 Page 16 of 18
`
`
`
`MARK
`
`
`
`
`
`
`GARANIMAL CRIBSIES
`
`CRIBSIES BY
`GARANIMALS
`
`BABY BASICS FROM
`GARANIMALS
`
`
`
`
`
`
`
`365 KIDS FROM
`GARANIMALS
`
`EVERYDAY
`GARANIMALS
`
`GARANIMALS
`EVERYDAY
`
`
`
`
`
`
`
`
`
`
`
`
`APP. NO.
`APP. DATE
`App 87898875
`App 28-APR-
`2018
`
`REG. NO.
`REG. DATE
`Reg 5938926
`Reg 17-DEC-
`2019
`
`App 86559641
`App 10-MAR-
`2015
`App 86559662
`App 10-MAR-
`2015
`App 85847336
`App 12-FEB-
`2013
`App 85822956
`App 14-JAN-
`2013
`
`Reg 5023392
`Reg 16-AUG-
`2016
`Reg 5023393
`Reg 16-AUG-
`2016
`Reg 5041381
`Reg 13-SEP-
`2016
`Reg 4573171
`Reg 22-JUL-
`2014
`
`App 85822988
`App 14-JAN-
`2013
`
`Reg 4889844
`Reg 19-JAN-
`2016
`
`App 85980144
`App 28-NOV-
`2012
`
`App 85736972
`App 24-SEP-
`2012
`App 85736979
`App 24-SEP-
`2012
`App 85392470
`App 08-AUG-
`2011
`
`App 85392495
`App 08-AUG-
`2011
`App 85183797
`App 23-NOV-
`2010
`
`Reg 4430103
`Reg 05-NOV-
`2013
`
`Reg 4472043
`Reg 21-JAN-
`2014
`Reg 4467507
`Reg 14-JAN-
`2014
`Reg 4238802
`Reg 06-NOV-
`2012
`
`Reg 4238803
`Reg 06-NOV-
`2012
`Reg 4191352
`Reg 14-AUG-
`2012
`
`GOODS AND SERVICES
`
`INT. CL. 25 CLOTHING, NAMELY, ONE PIECE GARMENTS
`FOR CHILDREN; CLOTHING, NAMELY, TOPS AND BOTTOMS
`
`INT. CL. 25 INFANT BODYSUITS; INFANT ROMPER SUITS
`
`INT. CL. 25 INFANT BODYSUITS; INFANT ROMPER SUITS
`
`INT. CL. 25 CLOTHING, NAMELY, TOPS AND BOTTOMS
`
`INT. CL. 25 CLOTHING, NAMELY, TOPS, BOTTOMS
`
`INT. CL. 25 CLOTHING, NAMELY, TOPS, BOTTOMS
`
`INT. CL. 25 CLOTHING, NAMELY, TOPS, BOTTOMS,
`SWEATSHIRTS AND HOODIES; SLEEPWEAR
`
`INT. CL. 25 CLOTHING, NAMELY, TOPS AND BOTTOMS
`
`INT. CL. 25 CLOTHING, NAMELY, TOPS AND BOTTOMS
`
`INT. CL. 25 CLOTHING, NAMELY, TOPS, BOTTOMS AND
`FOOTWEAR
`
`INT. CL. 25 CLOTHING, NAMELY, TOPS, BOTTOMS AND
`FOOTWEAR
`
`INT. CL. 16 CHILDREN'S BOOKS, CHILDREN'S ACTIVITY
`BOOKS, BOOKS THAT CAN BE USED IN THE BATH
`INT. CL. 24 BEDDING, NAMELY, BED SHEETS,
`COMFORTERS, BLANKETS, RECEIVING BLANKETS, PLUSH
`BLANKETS, FLANNEL BLANKETS, SWADDLE BLANKETS;
`THROWS, CRIB BUMPERS, BASSINET SHEETS, SHEET
`
`

`

`Case 3:21-cv-09409-CRB Document 1 Filed 12/06/21 Page 17 of 18
`
`
`
`MARK
`
`APP. NO.
`APP. DATE
`
`REG. NO.
`REG. DATE
`
`GOODS AND SERVICES
`
`GARANIMALS BABY
`BASICS
`
`App 77956700
`App 11-MAR-
`2010
`
`Reg 4050024
`Reg 01-NOV-
`2011
`
`GARANIMALS
`
`