Case 3:22-cv-05744-AGT Document 1-2 Filed 10/05/22 Page 1 of 10
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`JOHN F. DOMINGUE(SBN 193570)
`ROSSI DOMINGUE LLP
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`GREGORYS. GERSON(SBN 318795)
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`1570 The Alameda, Suite 316
`San Jose, CA 95050
`Tel: (408) 495-3900
`Email: john@rdlaw.net
`Email: greg@rdlaw.net
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`E-FILED
`7/27/2022 9:38 AM
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`Simerorcaut ofCA
`peeit Clara
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`Reviewed By: P. Newton
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`Attorneys for Plaintiff
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`SUPERIOR COURT OF CALIFORNIA
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`COUNTY OF SANTA CLARA
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`UNLIMITED JURISDICTION
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`CASE NO:
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`22CV402129
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`COMPLAINT FOR:
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`1. VIOLATION OF CAL. BUS. &
`PROF. CODE,§§ 14200 et seq.
`2. TRADE NAME INFRINGEMENT
`3. VIOLATION OF CALIFORNIA'S
`ANTI-PHISHING ACT OF2005
`[CAL. BUS. & PROF. CODE,§§
`22948 et seq.|
`4. UNFAIR COMPETITION
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`ONLINE LEARNING LLC, dba
`ONE CLICK TRAFFIC SCHOOL,
`a California Limited Liability
`Company
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`Plaintiff,
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`vs.
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`MIZUNETWORK,LLC,a
`California limited liability company
`and dba TRAFFIC SCHOOL4
`BUSY PEOPLE, and DOES1
`through 25, inclusive,
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`Defendants.
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`Plaintiff, ONLINE LEARNING LLC, dba ONE CLICK TRAFFIC SCHOOL,a California
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`Limited Liability Company (“Plaintiff’ or “One Click”) is informed and believes and alleges as
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`follows:
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`I.
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`INTRODUCTION
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`OneClick is the owner of the business name and webpagefor oneclicktrafficschool.com.
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`One Click devoted substantial time and resources to build a namefor itself and create business
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`through its premier services and easy accessto those services through its website. Defendant has
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`Case 3:22-cv-05744-AGT Document 1-2 Filed 10/05/22 Page 2 of 10
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`pirated One Click’s onlinetraffic by using Google ad words andlikely other meansto
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`misappropriate One Click’s name, goodwill, and customers. For example, at various times the
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`following would come up in a Google search result when doing a search for One Click:
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`Ad- https:/Awww.trafficschool4busypeople.com/quickest_online/dmv_co...
`OneClick Traffic School - CA DMV & Court Approved
`Instant Certificate, No Timers, Open Book Test, Finish As Fast As You Read! Court Approved
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`:
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`(800) 287-9841
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`Asis readily apparent from this search result, Defendant openly manipulated its Google
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`account and ad words to cause One Click’s name to appear prominently next to Defendant’s own
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`website. The One Click nameis shownin bright, large font, and users could easily believe, when
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`clicking on Defendant’s website, that they were selecting One Click. Despite One Click’s demand
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`that Defendant stop, it refused and kept misappropriating One Click’s mark and customers.
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`IL.
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`THE PARTIES
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`A.
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`PLAINTIFF
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`1.
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`Plaintiff, One Click, is a California limited liability company with its main offices
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`in Santa Clara County is and wasatall times mentioned herein, a California limited liability
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`company havingits principal place of business in San Jose, California, County of Santa Clara.
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`OneClick is a company engagedin the business of providing online driver’s training in
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`California, including Santa Clara County. One Click is the owner andregistrant of the "One Click
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`TRAFFIC SCHOOL"service mark under both federal and California state law. One Click is also
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`the owner of the web page: https://www.oneclicktrafficschool.com/.
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`B.
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`DEFENDANT
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`2.
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`Defendant, MIZUNETWORK,LLC,a California limited liability company doing
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`business as TRAFFIC SCHOOL 4 BUSY PEOPLE(“Traffic School’) doing business in various
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`counties including Santa Clara County. On information and belief, Kevin J. Mizuharais the
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`managing memberand chief executive officer of Mizunetwork, LLC. Traffic School holds itself
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`out as an onlinetraffic violator school licensed by the California Department of Motor Vehicles.
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`Traffic School does business through the website www.trafficschool4busypeople.com andsolicits
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`and/or conducts traffic-school-related business online.
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`Case 3:22-cv-05744-AGT Document 1-2 Filed 10/05/22 Page 3 of 10
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`— C.
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`OTHER DEFENDANTS
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`Plaintiff is ignorant of the true names and capacities of defendants sued herein as
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`3||Does 1 through 25, inclusive, and therefore sues these defendants by suchfictitious names under
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`4||California Code of Civil Procedure section 474. Plaintiff will amend this Complaint to allege their
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`true namesand capacities when the sameare ascertained. Plaintiff is informed and believes and
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`thereon alleges that each ofthe fictitiously named Defendants are legally responsible in some
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`mannerfor the occurrences herein alleged and the injuries of Plaintiff as herein alleged have been
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`proximately caused by the aforementioned defendants, and each of them.
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`ROLE OF DEFENDANTS
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`4.
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`Atall times mentioned herein, and on information and belief, Plaintiff alleges that
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`11||Defendants, and each of them were the agents, servants, employees, or alter egos of their co-
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`12||Defendants, and cach of them, and were joint venturers with, or co-partners with, or sureties for
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`13||the co-Defendants, and each of them, and wereat all times mentionedherein acting within the
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`14||course and scope of said agency, employment, and/or other relationship.
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`IL. JURISDICTION
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`5.
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`Jurisdiction and venueare proper in Santa Clara County because Plaintiffs
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`17||business is located within Santa Clara County andit is believed, based uponthe online activity of
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`18||Traffic School, it also conducts business within Santa Clara County.
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`The amountin controversy exceeds the minimumjurisdiction of this Court.
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`IV.
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`GENERAL ALLEGATIONS
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`CAUSES OF ACTION
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`FIRST CAUSE OF ACTION
`Violation of California Bus. & Prof. Code, §14200 et seq.
`(Against Traffic School, and DOES 1-25)
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`7.
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`Plaintiff hereby incorporates by reference each of the paragraphsset forth above as
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`8.
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`Plaintiff adopted the standard character mark "One Click Traffic School"
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`28||(hereinafter "Mark") and has usedit in California in commerce for more than seven years in
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`Case 3:22-cv-05744-AGT Document 1-2 Filed 10/05/22 Page 4 of 10
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`relation to traffic school. Within the last six years, Plaintiff has successfully registered said Mark
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`in the State of California (and also with the United States Patent and Trademark Office) covering
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`the use of said Markontraffic school services. Said registrations are valid and current.
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`9.
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`Plaintiff has used the Markto identify its services and to distinguish them from
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`those sold by others, by, among other things, prominently displaying the Mark onthe internet,
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`advertising materials, social media, building signage, letterheads, and other advertising throughout
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`California. Plaintiff has devoted substantial resources each year in advertising the Mark.
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`10.
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`As explained above,at all times relevant hereto, Plaintiff has owned the webpage
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`located at oneclicktrafficschool.com. Accordingly, if a consumer using an internet web browser
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`types in the company's URL—for example, by typing www.oneclicktrafficschool.com in his or her
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`web browser address bar—the consumeris directed to Plaintiff's website where he or she can
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`view its offering of services.
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`11.
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`A significant and critical amount of Plaintiff's solicitations are conducted via the
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`internet. Plaintiff estimates that, each day, it receives many visits by customersor potential
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`customersto its internet website and said website currently generates hundreds of confirmed new
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`clients annually.
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`12.
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`Plaintiff has devoted substantial resources in developing, maintaining, enhancing,
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`and updating its website. Plaintiff's services, provided under the Mark, have acquired a fine
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`reputation, and are famous among prospective clients in the State of California, particularly in
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`Santa Clara County.
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`13. Within the last two years and continuing, Defendanthas infringed Plaintiff's Mark
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`by various acts, including, among other things, advertising traffic school services online using the
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`Mark.For instance, upon information and belief, Defendant has purchased, through a common
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`search engine or engines (such as "Google" "Yahoo!" and "Bing"), keywords which are
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`comprised, in whole orin part, of the Mark. In an attemptto illegally capitalize on the Mark,
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`Defendant, whois Plaintiff's competitor, purchased and intentionally used these advertising
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`keywords(i.e. the Mark) so that its website would belisted in a position above or next to
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`Plaintiff's website link when a consumertypes a search query identical or substantially similar to
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`Case 3:22-cv-05744-AGT Document 1-2 Filed 10/05/22 Page 5 of 10
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`Plaintiff's Mark.
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`14.
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`To furtherillustrate, at various times within the past two years a consumer could
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`run a search on Google's main search engine for "One Click Traffic School"—Plaintiff s
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`registered Mark—with the obviousintent of locating and visiting Plaintiff's website. Nonetheless,
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`one ofthe first links shown on the Google search results page would be one or more ofthe
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`Defendant’s URL. As a result thereof, Defendant will have obtained a customer, or potential
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`customer, solely as a result of the goodwill and reputation associated with Plaintiff and its
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`products and services.
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`15.
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`Defendant has also used the Markas a headingto link to, or within, Defendant
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`and/orits affiliate websites, which are in direct competition with Plaintiff by, inter alia, offering
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`traffic schoolor traffic school related services via those websites.
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`16.|Defendant’s conduct, including the use and purchase of the keywords, is deceptive
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`and misleads consumersinto believing falsely that the website links to which they are directed via
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`manipulated search "results" links actually belong to Plaintiff or are sponsored/authorized
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`originating by it, the trademark ownerfor which the user was searching.
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`17.
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`The manipulated search "results" engineered by the Defendantfail to inform the
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`consumers that the companieslisted therein may have norelationship with, and maydirectly
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`compete with Plaintiff, the trademark/webpage ownerfor which the user was searching.
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`18.
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`Said use of the Mark by Defendant is without permission or authority of Plaintiff
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`and said use by Defendantis likely to cause confusion, to cause mistake, and to deceive
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`consumers.
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`19.
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`On or about December17, 2021, Plaintiff placed Defendant on notice that Plaintiff
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`is the Mark owner and Defendantshould cease its conduct alleged herein. Defendant continued to
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`20.
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`Defendant has diluted the distinctive quality of Plaintiff's Mark by variousacts,
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`including the manipulation of search engine results, discussed above, whichare infact,
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`advertisements purchased by Defendant based on the utilization of Plaintiff's Mark, and also by,at
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`times, the displaying of Plaintiff's Mark on their web pages.
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`21.
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`Such use by Defendant of copies, variations, reproductions, simulations, or
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`colorable imitations of the Mark, without permission, in connection with the use and purchasing of
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`keyword advertising services, among other things, has and will continue to lessen the capacity of
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`the Mark to distinguish Plaintiff's services from those of others and hasdiluted the distinctive
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`quality of Plaintiff's Mark.
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`22.
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`By reason of Defendant's acts alleged herein, including unlawful use ofPlaintiff's
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`Mark, not only has Defendantreceived ill-gotten profits, but Plaintiff has and will suffer damage
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`in Santa Clara County to its business, reputation, and goodwill, and the loss of sales and profits
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`that Plaintiff would have made but for Defendant's acts.
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`23.|Defendant threatens to continue to do the acts complained of herein, and unless
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`restrained and enjoined, will continue to do so, all to Plaintiff's irreparable damage. It would be
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`difficult to ascertain the amount of compensation which could afford Plaintiff adequate relief for
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`such continuing acts, and a multiplicity ofjudicial proceedings would be required. Plaintiff's
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`remedy at law is not adequate to compensateit for injuries threatened.Plaintiff is entitled to seek
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`injunctive relief in addition to damages. See Bus & Prof. Code, §§14247,14250.
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`WHEREFOREPlaintiff prays for relief as set forth below.
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`SECOND CAUSE OF ACTION
`(Trade Name Infringement)
`(Against Traffic School, and DOES 1-25)
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`24.
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`Plaintiff hereby incorporates by reference each of the paragraphsset forth above as
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`though fully set forth hereinafter.
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`25.
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` Defendant' actions alleged herein constitute trade name infringement under
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`California common law.Plaintiff is the owner of the trade name "One Click Traffic School"(i.e.
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`the Mark) as a result of adopting the name prior to Defendant's use of the Mark.
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`26.
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`Plaintiffs trade name has acquired a secondary meaning becauseit has been used
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`exclusively to identify Plaintiffs goods or business so as to indicate its goods or business andits
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`alone.
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`2),
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`Defendanthas infringed Plaintiff's trade name by usingit after Plaintiff, and after
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`Plaintiff's trade name had acquired a secondary meaning. Defendant' use of said trade nameis
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`without permission or authority of Plaintiff and said use by Defendantis likely to cause confusion,
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`to cause mistake, and to deceive.
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`28.
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`Asadirect and proximate result of Defendant's use of Plaintiff's trade name,
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`Plaintiff has and will continue to suffer damagesto its business, goodwill, and reputation, and lost
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`profits, and in an amountto be proven.Plaintiff has no adequate remedy at law for the injuries
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`inflicted by Defendant’ actions. Accordingly, Plaintiff is entitled to temporary, preliminary, and
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`permanent injunctiverelief.
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`WHEREFOREPlaintiff prays for relief as set forth below.
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`THIRD CAUSE OF ACTION
`Violation of California’s Anti-Phishing Act of 2005;
`California Bus. & Prof. Code, § 22948 et seq.
`(Against Traffic School, and DOES 1-25)
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`29.
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`Plaintiff hereby incorporates by reference each of the paragraphsset forth above as
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`though fully set forth hereinafter.
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`30.
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`Aspart of Defendant's conduct described above, Plaintiff alleges on information
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`and belief that Defendantutilized the internet, including possibly email correspondence, in order
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`to solicit, request, or otherwise induce individuals to provide identifying information (such as their
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`name, address, telephone number, email address, and other information) by representing
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`themselvesto be Plaintiff's business without the consentof Plaintiff.
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`31.
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`Under California Business & Professions Code § 22948.3(a), Plaintiff is entitled to
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`statutory damages under § 22948.3(a)(1), injunctive relief, and $5,000 per violation under§
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`22948 .3(a)(2), and reasonable costs and attorneys’ fees under § 22948 .3(c)(2).
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`32.
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` Plaintiffis also entitled to an increase in its recoverable damages in an amount up
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`to three times the damages otherwise recoverable in light of Defendant's pattern and practice of
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`illegally utilizing Plaintiff's Mark in the mannerdescribed above notwithstanding Plaintiff's
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`request to cease and desist such illegal use of the Mark.
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`WHEREFOREPlaintiff prays for relief as set forth below.
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`FOURTH CAUSE OF ACTION
`Unfair Competition
`(Against Traffic School, and DOES 1-25)
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`33.
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`Plaintiff hereby incorporates by reference each of the paragraphsset forth above as
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`though fully set forth hereinafter.
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`34.
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`Plaintiff is informed and believes, and on that basis alleges, that Defendant’ conduct
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`was unlawful, unfair and/or fraudulent and has the potential to cause confusion in the marketplace.
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`35.
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`Defendant' conduct, including that as alleged above, which includes, but is not
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`limited to, engaging in unlawful, unfair or fraudulent business practices, business practices in
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`violation of statute and/or court made and regulatory law, misleading prospective traffic school
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`customers; deceiving consumersinto using Defendant' services under the impression that they
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`themselvesare, or are associated with, or sponsored by, Plaintiff without Plaintiff's consent,
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`constitutes false advertising and unfair competition under California law, including Cal. Bus. &
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`Profs. Code §§17200 et seg. and 17500 et seq.
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`36.
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`Defendant knew or should have knownthatthe acts described herein would be
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`misleading and deceptive.
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`37.
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`Uponinformation andbelief, Plaintiff alleges that Defendant's acts described above
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`were done with oppression, fraud, and malice, thereby entitling Plaintiff to an award for punitive
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`damages in an amountto be establishedattrial.
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`38.
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`Defendant is a "person" as defined under Business and Professions Code §17021.
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`Eachofthe directors, officers, and/or agents of Defendant, and each of them, are equally
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`responsible for the acts complaint of herein pursuant to Bus. & Prof. Code, § 17095.
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`39,
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`As a direct and proximate result of Defendant's wrongful and unfair conduct,
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`Plaintiff has and will continue to suffer damage and injury to its business, reputation, and
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`goodwill, and suffer loss of profits that would have been made but for Defendant’ conduct, in an
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`amount to be establishedat trial. Unless enjoined and restrained, Defendant's conduct will
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`continue to cause irreparable injury to Plaintiff's reputation and goodwill, for which Plaintiff has
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`no adequate remedyat law. Accordingly, Plaintiff is entitled to temporary, preliminary, and
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`permanent injunctive relief under Bus. & Prof Code, §17203 in additional to all other remedies
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`1||available at law.
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`WHEREFOREPlaintiff prays for relief as set forth below.
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`PRAYER FOR RELIEF
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`Plaintiff prays for judgmentas follows:
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`1.
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`That this Court grant a permanent injunction prohibiting Defendantandits officers,
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`partners, agents, subcontractors, servants, employees, subsidiaries, and related companies or
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`entities, and all others acting in concern or participating with them from:
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`A. Purchasing keywordsthat are identical or substantially similar to the Mark
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`which are likely to cause consumerconfusion, mistake, or deception with respect to the
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`Mark;
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`B. Making any use of the Mark and/or terms confusingly similar thereto whichis
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`likely to confuse consumersinto believing that the services provided by Defendantare
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`sponsoredby,affiliated with, or otherwise tacitly endorsed by Plaintiff and/or whichis
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`likely to dilute the distinctive and famous Mark;
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`C. Making any designations of origin, descriptions, representations, or suggestions
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`that Plaintiff is the source, sponsor or in any wayaffiliated with Defendant, its products or
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`its website; and
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`nyNOOUNlUDNUNOUUNUNlSUPSCUTUSUPSOlaeUrPSPCOrcaPGTlUlllrYNAaF&>&»YYfeOoODOFENANHBatkB&BYEF-&O&O
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`D. Engaging in any other act constituting unfair competition or deceptive practices
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`with Plaintiff and its affiliated entities or constituting an infringementofPlaintiff's rights
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`in and to the Mark.
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`2.
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`That Defendant be required to accountto Plaintiff for any and all profits derived by
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`its wrongful acts alleged herein and for all damagessustained by Plaintiff by reason ofsaid acts of
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`infringement complained of herein.
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`3.
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`That this Court order Defendantto disgorgeall of its profits from its unlawfulacts,
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`and all other sums constituting Defendant's unjust enrichment from its unlawful conduct, in
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`accordance with California Civil Code section 3426.3(a).
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`4.
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`Due to Defendant’s violations of California Business & Professions Code §
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`22948.2, and pursuant to California Business & Professions Code § 22948.3, statutory damagesin
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`an amountto be provenattrial, an increase in the recoverable damages to an amountup to three
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`times the damages otherwise recoverable, and an award of costs of suit and reasonable attorneys’
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`fees.
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`proof
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`5.
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`6.
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`For an award of compensatory damages as maybeprovided by law, according to
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`For an award of punitive damages and other penalties as maybe provided by law,
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`according to proof.
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`7.
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`8.
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`expense.
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`For an award of attorneys’ fees and costs as otherwise may be provided by law.
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`For such other and further relief as the Court may deem just and proper.
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`Forrestitution of all amounts Defendants were unjustly enriched at Plaintiff's
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`10.
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`Forinterest at the statutory rate.
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`11.|For exemplary damages; and,
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`12.
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`Such further and other relief as may be awardable.
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`Dated: July 27, 2022
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`ROSSI DOMINGUE LLP
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`
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`om N
`By:
`~ John F. Domingue
`orneysfoy Plaintiff ONLINE LEARNING
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`LLC,
`dba One Click Traffic School, a
`California Limited Liability Company
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`ROSSI
`4 DOMINGUE
`LLP
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`10
`COMPLAINT
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`