Case 4:22-cv-07789 Document 1 Filed 12/08/22 Page 1 of 14
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`J. Noah Hagey, Esq. (SBN: 262331)
` hagey@braunhagey.com
`BRAUNHAGEY & BORDEN LLP
`351 California Street, 10th Floor
`San Francisco, CA 94104
`Telephone: (415) 599-0210
`Facsimile: (415) 276-1808
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`Mitchell C. Stein (pro hac vice pending)
` stein@braunhagey.com
`Kirsten Jackson (pro hac vice pending)
` dooley@braunhagey.com
`BRAUNHAGEY & BORDEN LLP
`118 W. 22nd Street, 12th Floor
`New York, NY 10011
`Telephone: (646) 829-9403
`Facsimile: (646) 829-9403
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`ATTORNEYS FOR PLAINTIFF
`TARI LABS, LLC
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`UNITED STATES DISTRICT COURT
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`NORTHERN DISTRICT OF CALIFORNIA
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`TARI LABS, LLC,
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`LIGHTNING LABS, INC.,
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`Plaintiff,
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`v.
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`Defendant.
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`Case No. 4:22-cv-07789
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`COMPLAINT FOR TRADEMARK
`INFRINGEMENT AND UNFAIR
`COMPETITION
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`JURY TRIAL DEMANDED
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`COMPLAINT
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`Case No. 4:22-cv-07789
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`Case 4:22-cv-07789 Document 1 Filed 12/08/22 Page 2 of 14
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`Plaintiff Tari Labs, LLC (“Tari Labs”) brings this action for trademark infringement and
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`related causes of action against Defendant Lightning Labs, Inc. (“Defendant”) and alleges as
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`follows:
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`INTRODUCTION
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`1.
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`Plaintiff Tari Labs is a technology company headquartered in Oakland, California,
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`that is developing an innovative blockchain platform for the issuance of a wide range of digital
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`assets. Tari Labs owns the federally registered trademark TARI® and brings this action against its
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`competitor, defendant Lightning Labs (“Defendant”), to remedy and enjoin Defendant’s recent
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`adoption of the confusingly similar name “TARO” for one of its blockchain technologies. The
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`parties compete in the same digital blockchain ecosystem, provide similar, and in some instances
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`identical, goods and services, market to similar developers and users, and appear on the same
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`blockchain platforms. Tari Labs notified Defendant of its infringing use of the TARI® trademark,
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`but Defendant elected to continue using, advertising and implementing the TARO trade name for
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`its competing blockchain technology.
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`2.
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`Through this action, Tari Labs seeks to halt Defendant’s willful and infringing use
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`of TARO, which is likely to confuse users and developers who wish to join the TARI® developer
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`community, and cause injury to its brand, reputation and goodwill.
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`JURISDICTION AND VENUE
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`3.
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`The Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1337
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`and 15 U.S.C. § 15. The Court has supplemental jurisdiction pursuant to 28 U.S.C. § 1367.
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`4.
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`Venue is proper in this district under 28 U.S.C. § 1391 and 15 U.S.C. § 22, because
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`a “substantial part of the events or omissions” on which the claim is based occurred in this district.
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`COMPLAINT
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`Case No. 4:22-cv-07789
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`Case 4:22-cv-07789 Document 1 Filed 12/08/22 Page 3 of 14
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`THE PARTIES
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`Plaintiff
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`Plaintiff Tari Labs, LLC is a limited liability corporation headquartered in Oakland,
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`California and organized under the laws of the State of Delaware.
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`Defendant
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`Upon information and belief, Defendant Lightning Labs is a corporation organized
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`and existing under the laws of the State of Delaware, with its principal place of business at 720
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`University Avenue, #200, Palo Alto, California 94301.
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`FACTS
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`I.
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`TARI LABS ANNOUNCES AND LAUNCHES THE TARI BLOCKCHAIN
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`PROTOCOL
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`Tari Labs was founded in March, 2018. Two months later, on May 19, 2018, in a
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`blog post entitled “Hello World,” Tari Labs announced TARI®, a new open source blockchain
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`protocol focused on digital assets.1
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`8.
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`Although the protocol contained some features associated with cryptocurrency, such
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`as the ability for users to mine TARI tokens, Tari Labs’s plan for the protocol was more ambitious.
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`It included a plan to develop the protocol to become a leading platform for the minting, sale and
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`distribution of digital assets of various types, including non-fungible tokens, or NFTs.
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`9.
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`As explained in its announcement blog, Tari Labs announced that they chose to
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`focus the protocol on digital assets in general, and not just cryptocurrency, “because we see a huge
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`opportunity to revolutionize the way these assets are owned, managed and transferred.” See
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`Exhibit A. Tari Labs further announced that the purpose of the protocol was “to fundamentally
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`change the experience of owning, managing and transferring digital assets.” Id.
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`Tari Labs announced its goal that the protocol would become a new digital assets
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`ecosystem that works better for both issuers and consumers of digital assets:
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`With Tari, creators of digital assets will be able to issue them as
`programmable non-fungible tokens on the Tari blockchain and trust
`that their rules will be enforced. Consumers will be able to use
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`1 Prior to June 25, 2018, Tari Labs operated under the name Tari, LLC. Tari Labs, LLC offers goods and services both
`directly and through its parent and affiliated companies, AccessCoin, LLC, a Delaware limited liability company, and
`EMOJI ID, LLC d/b/a Yat Labs, a Delaware corporation (“Yat”), respectively.
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`COMPLAINT
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`Case No. 4:22-cv-07789
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`applications built on top of the Tari blockchain to more easily
`transfer their digital assets while respecting the rules set by issuers.
`Ultimately, our intended result is a more frictionless, lower cost
`digital asset ecosystem that benefits all constituents.
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`Id.
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`Tari Labs has continued to own and operate the protocol since the protocol’s launch
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`in April, 2020. During that time, Tari Labs has been the subject of press coverage in the
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`cryptocurrency space, having been featured in online publications by CoinDesk, Nasdaq.com, the
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`Merkle News, Fortune, Mashable, and Bitcoin Magazine, among others.
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`Tari Labs is the owner of record of the US trademark registration for TARI ®, U.S.
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`Reg. No. 6701730 for “Cryptocurrency trading and exchange services, namely, providing a digital
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`currency or digital token for use by members of an on-line community via a global computer
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`network; cryptocurrency trading and exchange services, namely, providing a digital currency or
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`digital token, incorporating cryptographic protocols, used to operate and build applications and
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`blockchains on a decentralized computer platform and as a method of payment for goods and
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`services and as a method of transfer of digital assets” in International Class 36, applied for
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`February 26, 2018 and registered April 12, 2022. (the “TARI® Mark”). See Exhibit B.
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`Tari Labs has used the TARI® Mark continuously in US interstate commerce since
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`its date of first use.
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`Since its launch on April 29, 2020, Tari Labs has continued to target the protocol,
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`platform and related goods and services to be used by consumers of digital assets both inside and
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`outside the realm of cryptocurrency.
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`15.
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`Tari Labs’s marketing materials and web site have focused on the protocol’s high
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`performance, the ease with which the platform can integrate with other software, the fact that the
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`code is open-source, scalable, secure, private and stable. See Exhibit C.
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`16.
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`Tari Labs markets the protocol and its TARI blockchain products and services to
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`retail consumers of digital assets. Tari Labs defines the mission for its product is to become “the
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`most useful decentralized platform that empowers anyone to create digitally scarce things people
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`love.” See Exhibit D (emphasis added). Likewise, “Tari is not just for developers or corporations,
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`as it targets consumers as well.” See Exhibit E.
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`COMPLAINT
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`Case No. 4:22-cv-07789
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`17.
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`In support of its mission, Tari Labs has established Tari Labs University, an open
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`source, curated set of online materials developed by the Tari community to help facilitate
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`knowledge transfer and education. Tari Labs’s goal for Tari Labs University is to “create the best
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`free, open source educational resource for the many technologies that comprise blockchain
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`systems.” See Exhibit F. Tari Labs actively solicits feedback and cooperation from the community
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`of blockchain software developers in order to improve the protocol and platform. See id.
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`18.
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`Tari Labs, through Yat, offers a range of services relating to the minting, sale and
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`distribution of NFTs via platforms other than the TARI protocol, and is planning to make such
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`services available for use on the TARI protocol and the TARI platform. Tari Labs, through Yat,
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`offers a product called EMOJI ID™ for use in connection with blockchain wallets holding digital
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`assets, including NFTs. This product creates a blockchain wallet address made of emojis. Utilizing
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`emojis makes the wallet address easier to identify and recall than one with only numbers, which
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`reduces the risk of the owner losing access to the wallet, and, therefore, the asset.
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`19.
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`Tari Labs also offers, through Yat, a feature it calls PODS, which is a social layer
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`that allows for NFT collectors to discuss NFTs.
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`20.
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`Tari Labs is planning to make NFT-related technology available for use on or in
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`connection platforms other than the TARI protocol and the TARI platform. One of the platforms
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`targeted by Tari Labs for its suite of NFT-related services is the Lightning Network. The Lightning
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`Network is a “second layer” network on the Bitcoin blockchain that allows for faster processing
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`times of transactions involving digital assets, and more transactions per second than currently
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`available on Bitcoin’s “layer 1” network.
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`II.
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`DEFENDANT LAUNCHES COPYCAT PROTOCOL WITH CONFUSING NAME
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`Upon information and belief, Defendant was incorporated and founded in 2016.
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`Defendant is a technology company working to develop applications for use in
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`connection with the Bitcoin blockchain.
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`23.
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`Since its founding, Defendant has launched products and services for use in
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`connection with:
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`Cryptocurrency transactions, such products include a mobile wallet.
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`COMPLAINT
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`Case No. 4:22-cv-07789
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`Case 4:22-cv-07789 Document 1 Filed 12/08/22 Page 6 of 14
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`b.
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`Software that connects users who need access to bitcoin liquidity to those
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`who have capital to deploy on Defendant’s network.
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`Software designed to making sale of goods and services and payment of
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`goods on the blockchain easier to complete.
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`Nodes for use on Defendant’s network.
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`Specifications that allows non-custodial Lightning wallets to verify
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`transactions and to provide full synchronization to the Bitcoin blockchain.
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`See Exhibit G.
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`On April 5, 2020 – more than two years after Tari Labs announced the protocol and
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`its TARI® platform – Defendant issued an announcement under the name “Hello Taro” which
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`announced that it would be launching its infringing TARO protocol.
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`Defendant’s TARO protocol is designed so that users can use digital assets, such as
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`digitized currency, stablecoins2 and NFTs, as part of transactions on the Bitcoin cryptocurrency
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`blockchain.
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`Defendant also offers users of its infringing TARO protocol the ability to mint, sell
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`and distribute NFTs and other unique assets.
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`Defendant publicly launched its test “alpha daemon” version of its infringing TARO
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`protocol on or around September 28, 2022. Defendant announced that the test version of TARO
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`would be available on Bitcoin’s layer 1 network, but that plans were underway to develop a version
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`of TARO that would work on the Lightning Network.
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`Defendant promotes its TARO protocol and platform by emphasizing the protocols’
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`high performance, the ease with which the platform can integrate with other software, and the fact
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`that the code is open-source, scalable, secure, private and stable. See Exhibit H.
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`2 “Stablecoins” are cyrptocurrencies whose value is tied to that of another currency, commodity or financial interest.
`Stablecoins are often used as an alternative to Bitcoin and other currencies, the value of which experiences greater
`volatility and renders such alternative unsuitable for common transactions.
`https://www.investopedia.com/terms/s/stablecoin.asp
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`COMPLAINT
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`Case No. 4:22-cv-07789
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`29.
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`Defendant, like Tari Labs, targets the same general consumer group for its TARO
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`protocol and platform as Tari Labs does for its TARI® platform: consumers without sophisticated
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`knowledge of how blockchain and digital assets works.
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`Defendant claims that its ideal Taro user is “somebody who doesn’t want to
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`understand the protocol or bitcoin. It’s just somebody who wants to transact cheaply and
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`globally without holding bitcoin themselves.” See Exhibit I (emphasis added).
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`Defendant, like Tari Labs, solicits feedback and cooperation from the community of
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`blockchain software developers in order to improve its infringing TARO protocol and platform. Its
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`website features a link to a Slack account for outside developers interested in working with
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`Defendant. See Exhibit J.
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`32.
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`The infringing TARO protocol and platform are designed to facilitate transactions
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`involving a wide range of digital assets, including stablecoins and the minting (creation), sale and
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`transfer of NFTs, including digital asset transactions on the Lightning Network. As explained in its
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`“Hello Taro” blog post:
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`A developer mints a new Taro asset by making an on-chain
`transaction that commits to special metadata in a Tap[r]oot output.
`When minting a new asset, the Taro daemon will generate the
`relevant witness data, assign the asset to a private key held by the
`minter, and broadcast the newly created bitcoin UTXO to the bitcoin
`network. This new outpoint becomes the genesis point of the newly
`minted asset, acting as its unique identifier. Taro minting has a few
`key design attributes: verifiability, ability to issue fungible assets like
`currencies, and scalability.
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`See Exhibit H.
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`III. DEFENDANT’S INFRINGING TARO GOODS AND SERVICES ARE LIKELY TO
`MISLEAD CONSUMERS
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`33.
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`Defendant’s use of TARO (the “TARO”) on and in connection with the
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`cryptocurrency services it offers is highly likely to confuse and mislead consumers. The relevant
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`likelihood of confusion factors enunciated by the Ninth Circuit in AMF Inc. v. Sleekcraft Boats,
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`599 F.2d 341, 348-49 (9th Cir. 1979) (“Sleekcraft”), including strength of the mark, proximity of
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`the goods, similarity of the marks, evidence of actual confusion, similarity of marketing channels
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`used, type of goods and degree of care likely to be exercised by purchasers, defendant’s intent in
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`COMPLAINT
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`Case No. 4:22-cv-07789
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`selecting the mark, and the likelihood of expansion of the product lines. Applying relevant factors
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`to Defendant’s use of the TARO to market and sell cryptocurrency services demonstrates
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`convincingly a likelihood of consumer confusion, and therefore infringement of the TARI® Mark
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`34.
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`Strength of the Mark. TARI is an inherently distinctive and therefore strong mark,
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`which is afforded the widest ambit of protection from infringing uses. Id. at 349; see, e.g.,
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`National Lead Co. v. Wolfe, 223 F.2d 195, 199 (9th Circuit), cert. denied, 350 U.S. 883 (1955)
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`(DUTCH BOY mark found inherently distinctive). The TARI® Mark has been used in interstate
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`commerce for over four (4) years, and has developed significant goodwill and reputation during
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`that period.
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`35.
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`Proximity of the Goods. Each of the TARI® and TARO marks purport to involve,
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`among other things, cryptocurrency trading and exchange services for both digital currency and
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`digital tokens. The services offered by Defendant – namely, creating a blockchain protocol
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`whereby consumers can exchange cryptocurrency and other digital assets – falls directly within the
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`range of services protected by the trademark registration for TARI. Additionally, as discussed
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`above, the TARI protocol and TARO protocol both offer services related to the minting, sale and
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`distribution of NFTs.
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`36. Where, as here, both the TARI protocol and the TARO protocol both provide
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`services in the field of cryptocurrency and digital assets, the goods and services are considered
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`similar for infringement purposes. See, e.g., Lexington Mgmt. Corp. v. Lexington Cap. Partners,
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`10 F. Supp. 2d 271, (S.D.N.Y. 1998) (likelihood of confusion “great” where the parties did not
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`offer identical services or products, but “both operate in the same discrete ‘investment securities’
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`field”); Morningside Grp. Ltd. v. Morningside Cap. Grp., L.L.C., 182 F.3d 133, 140 (2d Cir. 1999)
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`(“the nature of the financial investment market renders the proximity of the two compan[ies’]
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`services particularly troubling in likelihood-of-confusion terms”).
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`Similarity of the Marks: The TARI® mark and infringing TARO mark are highly
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`similar in sight and sound. Both are four-letter, two-syllable words, sharing the same first three
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`letters in identical order. The only difference is that Plaintiff’s TARI® mark ends in “I”, whereas
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`Defendant’s infringing TARO mark ends in an “O.” Where, as here, the majority of the marks are
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`COMPLAINT
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`identical except for a slight change at the end of the mark, the marks are considered infringingly
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`similar. See, e.g., In re Detroit Athletic Co., 903 F.3d 1279, 1303 (Fed. Cir. 2018) (affirming
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`holding that DETROIT ATHLETIC CO. and DETROIT ATHLETIC CLUB are “nearly identical,”
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`where each consisted of identical phrase “DETROIT ATHLETIC” followed by “one-syllable ‘C’
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`words”); In re Nat’l Data Corp., 753 F.2d 1056, 1060 (Fed. Cir. 1985) (CASH MANAGEMENT
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`ACCOUNT and THE CASH MANAGEMENT EXCHANGE found similar); Synoptek, LLC v.
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`Synaptek Corp., 309 F. Supp. 3d 825, 836 (C.D. Cal. 2018) (finding that SYNOPTEK and
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`SYNAPTEK are “virtually identical in appearance and only differ by one single letter, ‘O’ versus
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`‘A.’). As the owner of a federally registered trademark, Tari Labs is entitled to exclusive use of its
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`mark in connection with the services for which it is registered.
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`38.
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`Similarity of Marketing Channels Used. Tari Labs and Defendant market their
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`competing TARI® vs. TARO services and technologies to many overlapping, similar and/or
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`identical audiences, including developers and retail consumers. The protocols and/or platforms are
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`featured and discussed on the same publications, for instance, Bitcoin Magazine. Where, as here,
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`similar goods and services are sold under nearly identical names to the same target market,
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`consumer confusion is likely. FAZE Apparel, LLC v. Faze Clan, Inc., No. 218CV02052RGKJEM,
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`2018 WL 3830027, at *5 (C.D. Cal. May 22, 2018) (holding that FAZE APPAREL and FAZE
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`CLAN were likely to confuse the public given both brands target young male consumers and
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`“make heavy use of a similar marketing channel: the Internet.”).
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`39.
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`Degree of Care Likely to be Exercised by Consumers. The TARI® Mark and
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`TARO are discussed by, marketed to, and used by, a wide variety of users, many of which are
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`unsophisticated and will exercise little degree of care in seeking to type or identify a particular
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`protocol. This is particularly true where the TARI and TARO names are communicated orally, or
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`inputted while using mobile applications or text – given the extreme one-character similarity. See
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`infra at ¶¶16 and 32.
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`40.
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`Defendant’s Intent in Selecting the Mark. Defendant chose its infringing TARO
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`name for its blockchain platform and protocol two years after Tari launched its TARI® platform
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`and applied to register the mark with the PTO. Defendant nonetheless adopted TARO with full
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`COMPLAINT
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`Case No. 4:22-cv-07789
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`

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`Case 4:22-cv-07789 Document 1 Filed 12/08/22 Page 10 of 14
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`knowledge and understanding of Tari and the TARI® mark, and that in so doing it would cause
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`confusion while allowing Defendant to capitalize on and trade upon the goodwill associated with
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`the TARI® Mark.
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`41.
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`Likelihood of Expansion of the Product Lines. Tari Labs’ and Defendant’s services
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`are both currently in a field of rapidly developing technologies. Cryptocurrency trading and
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`exchange services involve both traditional cryptocurrencies such as Bitcoin, and other digital
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`assets, including NFTs, tokens, and stablecoins. The parties are involved in developing novel and
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`new solutions and platforms and will, based on information and belief, continue to expand and
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`diversify the services they offer. This will also create areas for future potential confusion and
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`interaction between the parties’ services and relevant users, developers and consumers.
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`CAUSES OF ACTION
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`FIRST CAUSE OF ACTION
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`(Federal Trademark Infringement – 15 U.S.C. § 1114)
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`42.
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`Plaintiff incorporates by reference the facts and allegations set forth in each of the
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`preceding paragraphs as if fully set forth herein.
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`43.
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`Plaintiff owns all right, title, and interest in the TARI® Mark, which it has
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`continuously used in US interstate commerce since 2020.
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`44.
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`Through the conduct alleged above, Defendant’s unauthorized use in commerce of
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`the TARO for cryptocurrency services infringes the TARI® Mark and violates 15 U.S.C. § 114
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`because the TARO is confusingly similar to the TARI® Mark. Defendant’s use of the TARO
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`creates the erroneous impression in consumers’ minds that Defendant’s protocol and other products
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`and services have developed, approved, sponsored, or endorsed by, or is in some way affiliated
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`with, Plaintiff and the TARI® Mark.
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`45.
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`On information and belief, Defendant chose to use the TARO with the intent to
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`capitalize on the reputation of and goodwill associated with Plaintiff and the TARI® Mark.
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`46.
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`Defendant’s infringement is causing irreparable harm to Plaintiff by confusing
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`consumers and enabling Defendant unlawfully to profit by trading off of Plaintiff’s TARI® Mark.
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`COMPLAINT
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`Case No. 4:22-cv-07789
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`

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`Case 4:22-cv-07789 Document 1 Filed 12/08/22 Page 11 of 14
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`47.
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`Plaintiff has no adequate remedy at law for Defendant’s misconduct. Unless
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`Defendant is enjoined from continuing its infringement, consumers will continue to be confused
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`and Plaintiff’s injuries will continue to occur.
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`48.
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`Defendant has profited from their infringement, and Plaintiff has suffered damages
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`in an amount to be proven at trial.
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`49.
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`Plaintiff is also entitled to recover from Defendant any gains, profits, and
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`advantages as a result of Defendant’s infringement, in an amount to be proven at trial.
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`50.
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`Defendant’s intentional and willful misconduct renders this an “exceptional case,”
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`entitling Plaintiff to treble damages and attorneys’ fees pursuant to 15 U.S.C. § 1117.
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`SECOND CAUSE OF ACTION
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`(Trademark Infringement – California Common Law)
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`51.
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`Plaintiff incorporates by reference the facts and allegations set forth in each of the
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`preceding paragraphs as if fully set forth herein.
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`52.
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`Since 2020, Plaintiff has continuously used the TARI® Mark to identify its products
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`and services in California. The TARI® Mark is inherently distinctive and serves to identify the
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`origin of the products and services sold by Plaintiff. Thus, Plaintiff has enforceable rights in and to
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`the TARI® Mark under California law.
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`53.
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`Through the conduct alleged above, Defendant’s unauthorized use in commerce of
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`the TARO infringes Plaintiff’s rights in its TARI® Mark because it renders Defendant’s products
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`and services confusingly similar to the products and services sold under the TARI® Mark.
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`54.
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`Defendant’s unauthorized use of the TARO creates the erroneous impression that
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`Defendant’s Infringing Fund has been developed, approved, sponsored, endorsed, or is in some
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`way affiliated with, Plaintiff and the goods and services offered under the TARI® Mark.
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`55.
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`Defendant’s unlawful activities in the state of California and/or directed at
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`California consumers have caused Plaintiff’s irreparable injury. Unless the Court enjoins such
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`conduct, Defendant will continue its intentional infringement to the continued, irreparable injury of
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`Plaintiff. This injury includes a reduction in the distinctiveness of the TARI® Mark, as well as
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`COMPLAINT
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`Case No. 4:22-cv-07789
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`

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`Case 4:22-cv-07789 Document 1 Filed 12/08/22 Page 12 of 14
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`injury to Plaintiff’s reputation that cannot be remedied through damages. Plaintiff has no adequate
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`remedy at law.
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`56.
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`In view of the foregoing, Plaintiff is entitled to a preliminary and permanent
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`injunction restraining and enjoining Defendant from further marketing and selling goods and
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`services under the TARO in the state of California.
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`57.
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`Plaintiff is also entitled to recover Defendant’s profits, Plaintiff’s ascertainable
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`economic damages, and Plaintiff’s costs of suit. Defendant’s willful infringement of Plaintiff’s
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`common-law rights in California, without excuse or justification, entitles Plaintiff to its reasonable
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`attorneys’ fees.
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`58.
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`In addition to all equitable relief that may be available, Plaintiff seeks an award of
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`Defendant’s unlawful gains, profits and money obtained through its unlawful conduct, and an
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`award of punitive damages, and attorneys’ fees and costs.
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`THIRD CAUSE OF ACTION
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`(Unfair Competition – Cal. Bus. & Prof. Code, § 17200 et seq.)
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`59.
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`Plaintiff incorporates by reference the facts and allegations set forth in each of the
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`preceding paragraphs as if fully set forth herein.
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`60.
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`Defendant’s unauthorized use of the TARO in a manner that is likely to confuse and
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`deceive consumers is unlawful, unfair, and/or fraudulent and constitutes unfair competition within
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`the meaning of California Business & Professions Code § 17200 et seq.
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`61.
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`Defendant has unlawfully profited from its unfair competition, and Plaintiff has
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`suffered damages in an amount to be proven at trial.
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`62.
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`Defendant’s infringement is causing irreparable harm by confusing consumers and
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`enabling Defendant unlawfully to profit by trading off of Plaintiff’s TARI® Mark. Plaintiff will
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`continue to suffer such harm unless Defendant’s infringing conduct is enjoined by this Court.
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`63.
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`In addition to all equitable relief that may be available, Plaintiff seeks an award of
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`Defendant’s unlawful gains, profits and money obtained through its unlawful conduct, and an
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`award of punitive damages, and attorneys’ fees and costs.
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`COMPLAINT
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`Case No. 4:22-cv-07789
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`

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`Case 4:22-cv-07789 Document 1 Filed 12/08/22 Page 13 of 14
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`PRAYER FOR RELIEF
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`WHEREFORE, Plaintiff respectfully demands judgment against Defendant as follows:
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`A.
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`Preliminarily and permanently enjoin Defendant from using any version of the
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`TARO in connection with the sale, offering to sell, advertising, or marketing of cryptocurrency
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`funds in the United States.
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`B.
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`Award Plaintiff its amount of damages and/or the amount of Defendant’s profits
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`arising from Defendant’s use of the TARO in the United States, pursuant to 15 U.S.C § 1117.
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`C.
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`Award Plaintiff three times their actual damages, as well as the costs of this action,
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`in accordance with 15 U.S.C § 1117.
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`D.
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`Find this action to be an “exceptional case” such that Plaintiff be awarded their
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`reasonable attorney’s fees in accordance with 15 U.S.C § 1117.
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`E.
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`F.
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`Award Plaintiff punitive damages as allowable.
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`Award Plaintiff such other and further relief as this Court deems just and proper.
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`Dated: December 8, 2022
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`Respectfully Submitted,
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`BRAUNHAGEY & BORDEN LLP
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`By:
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`/s/ J. Noah Hagey
`J. Noah Hagey
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`Attorneys for Plaintiff
`Tari Labs, LLC
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`12
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`COMPLAINT
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`Case No. 4:22-cv-07789
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`

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`Case 4:22-cv-07789 Document 1 Filed 12/08/22 Page 14 of 14
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`DEMAND FOR JURY TRIAL
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`Plaintiff hereby demand a jury trial of all claims and causes of action triable before a jury.
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`Dated: December 8, 2022
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`Respectfully submitted,
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`BRAUNHAGEY & BORDEN LLP
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`By:
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`/s/ J. Noah Hagey
`J. Noah Hagey
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`Attorneys for Plaintiff
`Tari Labs, LLC
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`COMPLAINT
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`Case No. 4:22-cv-07789
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