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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF COLORADO
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`Civil Action No.
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`CARRICK-HARVEST, LLC d/b/a VERITAS FINE CANNABIS,
`a Colorado limited liability company,
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`v.
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`VERITAS FARMS, INC., a Nevada corporation;
`271 LAKE DAVIS HOLDINGS, LLC d/b/a VERITAS FARMS,
`a Delaware limited liability company,
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`Plaintiff,
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`Defendants.
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`COMPLAINT
`DEMAND FOR JURY TRIAL
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`Plaintiff Carrick-Harvest, LLC d/b/a Veritas Fine Cannabis (“Plaintiff”) for its Complaint
`against Defendants Veritas Farms, Inc. and 271 Lake Davis Holdings, LLC d/b/a/ Veritas Farms
`(collectively, “Defendants” or “Veritas Farms”) hereby states and alleges as follows:
`NATURE OF THE CASE
`
`This is an action for trademark infringement, false designation of origin, unfair
`1.
`competition, cybersquatting and declaratory relief arising out of a competitor’s bad faith use of
`nearly identical and confusingly similar trademarks, creating and causing actual confusion in the
`marketplace.
`Plaintiff’s senior use in commerce of its VERITAS trademark to provide
`2.
`informational services about cannabis since September 2016 predates and thus precludes under
`federal and state law Defendants’ knowing, intentional and willful use of VERITAS FARMS in
`connection with similar products, to the same or substantially similar trade channels and in the
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`same markets as Plaintiff.
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`PARTIES, JURISDICTION AND VENUE
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`Plaintiff is a limited liability company organized and existing under the laws of the
`3.
`State of Colorado, with its principal place of business located at 4705 Oakland Street, Unit A,
`Denver, Colorado.
`4.
`Upon information and belief, Defendant Veritas Farms, Inc. is, and at all times
`relevant hereto was, a corporation organized and existing under the laws of the State of Nevada,
`with its principal place of business located at 8648 Lake Davis Road, Pueblo, Colorado.
`5.
`Upon information and belief, Defendant 271 Lake Davis Holdings, LLC d/b/a/
`Veritas Farms (“271 Lake Davis”) is, and at all times relevant hereto was, a limited liability
`company organized and existing under the laws of the State of Delaware, with its principal place
`of business located at 8648 Lake Davis Road, Pueblo, Colorado. Upon information and belief,
`271 Lake Davis is a wholly-owned subsidiary of Defendant Veritas Farms, Inc.
`6.
`This Court has subject matter jurisdiction under the Lanham Act, 15 U.S.C. § 1125
`et seq., 28 U.S.C. § 1338(a) and the Anti-Cybersquatting Protection Act (“ACPA”), 15 U.S.C. §
`1125(d). This Complaint also alleges violations of state law. This Court has supplemental
`jurisdiction over state law claims pursuant to 28 U.S.C. § 1338(b) and § 1367(a).
`7.
`Venue is proper in this Judicial District pursuant to 28 U.S.C. 1391(b) because
`Defendants have their principal place of business in this district and a substantial part of the events
`giving rise to the claims occurred in this district.
`8.
`This Court has personal jurisdiction over Defendants because Defendants have their
`principal place of business in this district and they are entities registered to conduct business in the
`State of Colorado. Also, Defendants have availed themselves of the laws of, and directed activities
`at, the State of Colorado in connection with the wrongful activities alleged in this Complaint.
`ALLEGATIONS COMMON TO ALL CLAIMS
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`Plaintiff’s Trademark Rights
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`9.
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`Plaintiff is the exclusive owner of all rights in and to the VERITAS trademark,
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`which Plaintiff has been using continuously in commerce since at least September 2016 in
`connection with providing information about cannabis and cannabis products, including, without
`limitation, through its website at <veritascannabis.com>. These informational services are
`permitted under federal law. In addition, Plaintiff sells hats, t-shirts, sweatshirts, lighters, ash trays,
`stickers and other similar items incorporating its VERITAS trademark.
`10.
`Plaintiff also uses the following “V” as a design mark (“V Design Mark”) in
`connection with all of the aforementioned goods and services:
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`Also Plaintiff uses in commerce the V Design Mark in combination with its
`11.
`VERITAS mark (the V Design Mark and VERITAS mark are referred to collectively herein as the
`“Veritas Marks”) in connection with all of the aforementioned goods and services as follows:
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`Plaintiff currently has the following trademark applications pending with the
`12.
`United States Patent and Trademark Office (“USPTO”) for the Veritas Marks:
`a.
`VERITAS, Serial No. 88809088, filed on February 25, 2020, in Class 34
`for “lighters for smokers” and “ashtrays.”
`b.
`VERITAS, Serial No. 88805285, filed on February 21, 2020, in Class 44,
`as amended, for “providing agricultural information about cannabis and cannabis strains;
`providing a website featuring information relating to the therapeutic benefits of cannabis;
`providing a website containing agricultural news and information about cannabis and cannabis
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`infused products.”
`VERITAS, Serial No. 88805282, filed on February 21, 2020, in Class 41,
`c.
`as amended, for “providing a website containing current events news and information about
`cannabis, cannabis infused products and smoker's articles.”
`d.
`VERITAS, Serial No.88978252, has an effective filing date of February 21,
`2020, in class 35, as amended, for “providing a website containing consumer product news and
`information about cannabis, cannabis infused products, and smoker’s articles.”
`e.
`, Serial No. 88805931, filed on February 21, 2020, in Class 35,
`as amended, for “providing consumer information in the field of marijuana, cannabis and cannabis-
`infused products;”
`The V Design Mark, Serial No. 88806205, filed on February 21, 2020,
`f.
`containing three classes of goods and services, particularly, Class 35 for “providing a website
`containing consumer product news and information about cannabis, cannabis infused products and
`smoker’s articles,” Class 41 “providing a website containing current events news and information
`about cannabis, cannabis infused products and smoker’s articles” and Class 44 for “providing a
`website containing medical news and information about cannabis, cannabis infused products and
`smoker’s articles; providing a website containing agricultural news and information about
`cannabis and cannabis infused products.”
`13.
`Although Plaintiff has been providing informational services using its Veritas
`Marks in connection with its website at <veritascannabis.com> since September 2016, Plaintiff
`filed each of its USPTO applications pursuant to Section 1(b) of the Trademark Act (“Section
`1(b)”) in order to obtain a filing date quickly while it investigated the extent of confusion caused
`by Defendant and resulting damages to the Veritas Marks.
`14.
`In addition to the foregoing, on June 26, 2020, Plaintiff filed a trademark
`application with the USPTO for VERITAS, Serial No. 90022561, in Class 34 for “pre-rolled hemp
`flower for smoking; Hemp for smoking or vaporizing; Hemp cigarettes; Hemp cigars; Pre-
`packaged hemp flower for smoking or vaporizing.” This application was filed under Section 1(b),
`and Plaintiff currently is developing these products and anticipates a first sale date of no later than
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`January 1, 2021.
`15.
`Plaintiff has invested significant monies in promoting, marketing and advertising
`its goods and services under its Veritas Marks. Its extensive use of the Veritas Marks has created
`a strong, distinctive and identifiable brand that carries substantial goodwill in the marketplace.
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`Defendants’ Unlawful Activities
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`Upon information and belief, Defendants use the mark VERITAS FARMS in
`16.
`connection with cannabis-related goods and services, including to provide information about
`cannabis and cannabis products at their websites located at <theveritasfarms.com> and
`<theveritaswellness.com>.
`17.
`Upon information and belief, the <theveritasfarms.com> domain was created on
`March 16, 2018 and the <theveritaswellness.com> domain was created on October 10, 2018.
`18.
`Upon information and belief, Defendants own and/or control the domain
`<myveritasfarms.com>, which was created on October 29, 2019, although Defendants currently
`do not maintain any content on that website.
`19.
`The three domain names, <theveritasfarms.com>, <theveritaswellness.com> and
`<myveritasfarms.com> will be referred to collectively herein as the “Infringing Domains.”
`20.
`Upon information and belief, 271 Lake Davis has filed at least four trademark
`applications with the USPTO to register VERITAS FARMS as follows:
`a.
`VERITAS FARMS, Serial No. 88366575, filed on April 1, 2019 in Class 5, as
`amended, for “herbal extracts for medicinal purposes, namely, tinctures, salves, and lotions, all the
`foregoing containing hemp extract,” “non-medicated herbal body care products, namely, body oils,
`salves, and lip balms, all the foregoing containing hemp extract,” “nutraceuticals for use as a
`dietary supplement containing hemp extract,” “nutritional supplements in the form of capsules,
`and gummies, all the foregoing containing hemp extract,” and “dietary supplements for pets
`containing hemp extract” pursuant to Section 2(a) of the Trademark Act, claiming a first use date
`of July 19, 2018. Upon information and belief, on March 12, 2020, this application was refused
`registration by the USPTO for, among other reasons, because the products listed in it are illegal
`under the Federal Food, Drug, and Cosmetic Act (“FDCA”).
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`VERITAS FARMS, Serial No. 88400810, filed on April 24, 2019 in Class 5 for
`b.
`“dietary supplements for pets” pursuant to Section 1(b). Upon information and belief, on May 6,
`2020, this application was refused registration by the USPTO for, among other reasons, because
`the products listed in it are illegal under the FDCA and because the products are illegal under the
`Controlled Substances Act, 21 U.S.C. §§801-971 (“CSA”).
`c.
`VERITAS FARMS, Serial No. 87926100, which was given an effective date of
`December 20, 2018 by the USPTO in Class 31, as amended, for “raw unprocessed hemp with a
`delta-9 tetrahydrocannabinol concentration of not more than 0.3 percent on a dry weight basis”
`and Class 40 for “manufacturing services for others in the field of processing hemp with a delta-9
`tetrahydrocannabinol concentration of not more than 0.3 percent on a dry weight basis” pursuant
`to Section 1(b). Plaintiff requested an extension of time from the USPTO to oppose this trademark
`application.
`The following stylized V trademark (“Stylized V Mark,” together with VERITAS
`d.
`FARMS, the “Infringing Marks”), which was given an effective date of December 20, 2018 by the
`USPTO, and for which trademark application Plaintiff requested an extension of time to oppose:
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`Upon information and belief, Defendants adopted the Stylized V Mark on their
`21.
`product packaging in or about October 2018, but such use in commerce remains illegal for most
`of Defendants’ products in the United States. Upon information and belief, Defendants began use
`the Stylized V Mark for informational services in late 2018. Also upon information and belief,
`Defendants intentionally selected the Stylized V Mark in order to create consumer confusion with
`Plaintiff’s V Design Mark, particularly based on its use in combination with VERITAS FARMS.
`22.
`The combination of using VERITAS FARMS in conjunction with the stylized V
`mark has created, and continues to create, consumer confusion in the marketplace.
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`Upon information and belief, consumers on social media websites and other
`23.
`information service channels have mistakenly tagged Plaintiff as Defendants, that is, such
`consumers have included the hashtag “#veritasfarms” when referring to Plaintiff, thus
`demonstrating actual confusion in the marketplace with respect to the VERITAS Marks.
`24.
`Upon information and belief, Defendant Veritas Farms, Inc. changed its name from
`SanSal Wellness Holdings, Inc. to “Veritas Farms Inc.,” which it announced in a press release on
`or about February 5, 2019 in connection with a public offering, a true and correct copy of which
`is attached hereto as Exhibit A.
`25.
`Also upon information and belief, Defendants intentionally and willfully selected
`the Infringing Marks, and Defendant Veritas Farms, Inc. implemented the name change in order
`to wrongfully trade on and benefit from the substantial goodwill Plaintiff has obtained in its Veritas
`Marks.
`Defendants’ websites use the Infringing Marks to provide information to consumers
`26.
`about cannabis. Defendants’ use of these websites to provide information about cannabis causes
`actual confusion in the marketplace.
`27.
`Upon information and belief, any goods offered for sale by Defendants prior to
`December 20, 2018 were illegal under federal law, and further upon information and belief, the
`sale of such goods remains illegal today, as determined by the USPTO in the office actions
`referenced above.
`28.
`To the extent that Defendants currently provide any goods or services that are
`permitted under United States law, Defendants began doing so subsequent to Plaintiff’s provision
`of information regarding cannabis on Plaintiff’s website.
`29.
`Also to the extent that any of Defendants’ current offering of goods or services are
`legal, they fall within Plaintiff’s zone of natural expansion and thus are precluded under the
`Lanham Act. For example, Plaintiff has provided information about cannabis on its website for
`many years, and it is well within Plaintiff’s zone of natural expansion to expand to the sale of
`smokeable hemp, which is legal in the United States.
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`Because Plaintiff’s Veritas Marks are strong, fanciful and have secondary meaning,
`30.
`there is a customer perception, based on Plaintiff’s current offering of goods and services, that
`Plaintiff likely will expand into offering goods and services similar to the goods and services
`currently offered by Defendants.
`31.
`Defendants’ use of the Infringing Marks is likely to cause, and does in fact cause,
`consumer confusion with Plaintiff’s senior use of its Veritas Marks in connection with Plaintiff’s
`informational services and Plaintiff’s pending launch of smokeable hemp products under the
`Veritas Marks in the United States.
`32.
`Since discovering Defendants’ use of the Infringing Marks and Infringing
`Domains, Plaintiff has demanded that Defendants cease and desist from using the Infringing Marks
`and Infringing Domains.
`33.
`Despite Plaintiff’s repeated demands, Defendants continue to utilize the Infringing
`Domains and offer for sale and sell products and services utilizing the Infringing Marks.
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`FIRST CLAIM FOR RELIEF
`Trademark Infringement
`(15 U.S.C. § 1125(a))
`(Against All Defendants)
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`Plaintiff repeats and realleges each and every allegation contained in the above
`34.
`paragraphs of this Complaint as though fully set forth herein.
`35.
`Plaintiff owns common law trademark rights in the Veritas Marks and the marks
`are protectable under 15 U.S.C. § 1125(a) and under common law for providing information about
`cannabis.
`At all relevant times hereto, Defendants used and/or are using the Infringing Marks
`36.
`and the Infringing Domains in competition with Plaintiff in commerce, inter alia, by providing
`information about cannabis, and such use is likely to cause confusion, or to cause mistake, or to
`deceive.
`Defendants’ acts of trademark infringement were undertaken with knowledge of
`37.
`Plaintiff’s marks and have been willful, deliberate and in bad faith.
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`Defendants’ acts of trademark infringement have proximately caused damage to
`38.
`Plaintiff. Defendants’ conduct has caused Plaintiff to suffer damages in an amount consisting of
`Defendants’ unlawful profits from use of the Infringing Marks and the Infringing Domains.
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`SECOND CLAIM FOR RELIEF
`False Designation of Origin and Unfair Competition
`(15 U.S.C. § 1125(a))
`(Against All Defendants)
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`Plaintiff repeats and realleges each and every allegation contained in the above
`39.
`paragraphs of this Complaint as though fully set forth herein.
`40.
`Defendants have been using the Infringing Marks and the Infringing Domains in
`connection with their sale, offer for sale and advertising of cannabis-related goods and services.
`The Infringing Marks and the Infringing Domains are identical or confusingly similar to Plaintiff’s
`Veritas Marks, which are non-functional and inherently distinctive.
`41.
`Defendants’ use of the Infringing Marks and the Infringing Domains constitutes a
`false designation of origin that is likely to cause confusion, or to cause mistake, or to deceive as to
`the affiliation, connection, or association of Defendants’ business with another person, or as to the
`origin, sponsorship, or approval of their goods, services or commercial activities by another
`person, in violation of 15 U.S.C. § 1125(a).
`42.
`Defendants’ conduct their use of the Infringing Marks and the Infringing Domains
`in commerce without authorization or consent by Plaintiff. Defendants’ conduct is intended to
`divert, and likely will divert, potential customers away from Plaintiff.
`43.
`Plaintiff has no control over the nature and quality of the goods and/or services that
`may be provided by Defendants.
`44.
`Defendants’ infringement of Plaintiff’s marks, especially in connection with goods
`and services similar to those of Plaintiff, dilutes and devalues Plaintiff’s marks.
`45.
`Defendants’ use of the Infringing Marks and the Infringing Domains in connection
`with their sale, offer for sale and advertising of competing goods and services with knowledge of
`Plaintiff’s trademark rights renders Defendants’ trademark infringement willful.
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`Defendants’ acts of trademark infringement have proximately caused damage to
`46.
`Plaintiff. Defendants’ conduct has caused Plaintiff to suffer damages in an amount consisting of
`Defendants’ unlawful profits from use of the Infringing Marks and the Infringing Domains.
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`THIRD CLAIM FOR RELIEF
`Cybersquatting
`(15 U.S.C. § 1125(d))
`(Against All Defendants)
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`Plaintiff repeats and realleges each and every allegation contained in the above
`47.
`paragraphs of this Complaint as though fully set forth herein.
`48.
`Plaintiff is the owner of all right, title and interest in VERITAS.
`49.
`The Infringing Domains are identical or confusingly similar to Plaintiff’s
`VERITAS mark.
`50.
`Defendants’ use of the Infringing Domains at all times has been an intentional and
`willful attempt to profit in bad faith from Plaintiff’s mark. Defendants have no trademark rights
`in Plaintiff’s mark or the Infringing Domains, and Defendants deliberately selected the Infringing
`Domains in order to cause initial interest confusion for commercial gain in competition with
`Plaintiff’s offering of similar goods and services, particularly in combination with the Infringing
`Marks.
`Upon information and belief, Defendants are not entitled to the 15 U.S.C. §
`51.
`1125(d)(1)(B)(ii) safe harbor because they neither subjectively believed nor had objectively
`reasonable grounds to believe that their unlawful use of the Infringing Domains constituted fair
`use or was otherwise lawful.
`52.
`As a direct and proximate result of Defendants’ conduct, Plaintiff is entitled to the
`following relief: (a) transfer to Plaintiff or cancellation of the Infringing Domains; (b) damages
`consisting of Defendants’ wrongful profits in amounts to be proven at trial; and (c) maximum
`statutory damages of $100,000.00 per domain. Plaintiff also seeks an award of its reasonable
`attorneys’ fees and costs under the “exceptional” case provision of the Lanham Act, 28 U.S.C. §
`1117(a).
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`FOURTH CLAIM FOR RELIEF
`(Common Law Unfair Competition)
`(Against All Defendants)
`Plaintiff repeats and realleges each and every allegation contained in the above
`53.
`paragraphs of this Complaint as though fully set forth herein.
`54.
`Defendants’ actions constitute unfair competition under applicable state common
`law, in that the Infringing Marks and the Infringing Domains are deceptively similar to Plaintiff’s
`marks and Plaintiff’s domain name and Defendants’ use of the Infringing Marks and the Infringing
`Domains is creating or increasing confusion between goods and services provided by Plaintiff and
`Defendant, to the detriment of Plaintiff and the public.
`55.
`Defendants’ use of the Infringing Marks and the Infringing Domains is likely to
`mislead consumers—and has in fact misled consumers—as to the separate origin of related goods
`and services and to damage Plaintiff’s goodwill and business reputation.
`56.
`Defendants’ conduct, as herein alleged, as caused, and unless restrained and
`enjoyed, will continue to cause irreparable harm to Plaintiff that cannot adequately be compensated
`or measured by monetary damages alone. Plaintiff has no adequate remedy at law. Plaintiff
`therefore is entitled to permanent injunctive relief preventing Defendants from continuing to
`infringe and trade on Plaintiff’s marks.
`57.
`As a direct and proximate result of Defendants’ conduct, as hereinabove alleged,
`Plaintiff has suffered and will continue to suffer damages consisting of Defendants’ wrongful
`profits, in an amount to be proven at trial.
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`FIFTH CLAIM FOR RELIEF
`(Declaratory Judgment of Superior Trademark Rights)
`(Against All Defendants)
`Plaintiff repeats and realleges each and every allegation contained in the above
`58.
`paragraphs of this Complaint as though fully set forth herein.
`59.
`A dispute and actual controversy has arisen between Plaintiff and Defendants as to
`the respective rights of the parties regarding the questions of whether: (i) Plaintiff is the senior
`user of its Veritas Marks; (ii) Defendants’ Infringing Marks and Infringing Domains infringe on
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`Plaintiff’s valid, enforceable and senior trademark rights; and (iii) Defendant 271 Lake Davis’
`registration of the Infringing Marks in the USPTO is precluded under 15 U.S.C. § 1052(d) based
`on a likelihood of confusion between Plaintiff’s Veritas Marks and Defendants’ Infringing Marks.
`60.
`Defendants’ conduct is directly and proximately causing immediate and irreparable
`harm and injury to Plaintiff and to its goodwill and reputation, and Defendants’ conduct will
`continue to both damage and cause irreparable harm and injury to Plaintiff and to confuse the
`public unless an Order is issued by this Court declaring Plaintiff as having superior trademark
`rights in and to the Veritas Marks and its <veritascannabis.com> domain name.
`61.
`Accordingly, pursuant to the Declaratory Judgment Act, 28 U.S.C. §§ 2201 through
`2202, the Plaintiff seeks an Order from this Court declaring: (i) Plaintiff has superior trademark
`rights in and to the Veritas Marks and its <veritascannabis.com> domain name; (ii) Defendants’
`Infringing Marks and Infringing Domains infringe on Plaintiff’s valid, enforceable and senior
`trademark rights; and (iii) Defendant 271 Lake Davis’ registration of the Infringing Marks in the
`USPTO is precluded under 15 U.S.C. § 1052(d) based on a likelihood of confusion between
`Plaintiff’s Veritas Marks and Defendants’ Infringing Marks.
`62.
`A judicial determination is necessary and appropriate at this time and under the
`circumstances so that the parties may ascertain their rights and duties.
`63.
`Plaintiff further requests an award of its reasonable attorneys’ fees and costs
`pursuant to the “exceptional case” standard of 15 U.S.C. § 1117(a).
`
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` PRAYER FOR RELIEF
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`WHEREFORE, Plaintiff pray for judgment as follows:
`
`A.
`
`B.
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`An Order entering judgment in favor of Plaintiff affirming that Plaintiff is the
`lawful owner of the Veritas Marks;
`An Order declaring that (i) Plaintiff has superior trademark rights in and to the
`Veritas Marks and its <veritascannabis.com> domain name; (ii) Defendants’
`Infringing Marks and Infringing Domains infringe on Plaintiff’s valid, enforceable
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`and senior trademark rights; and (iii) Defendant 271 Lake Davis’ registration of the
`Infringing Marks in the USPTO is precluded under 15 U.S.C. § 1052(d) based on
`a likelihood of confusion between Plaintiff’s Veritas Marks and Defendants’
`Infringing Marks.
`An Order awarding Plaintiff its damages in an amount consisting of Defendants’
`unlawful profits from use of the Infringing Marks and Infringing Domains in an
`amount to be proven at trial;
`An Order directing transfer or cancellation of the Infringing Domains pursuant to
`15 U.S.C. § 1125(d)(1)(C);
`An Order awarding Plaintiff a preliminary and permanent injunction against
`Defendants, their agents, representatives, employees, assigns and suppliers, and all
`persons acting in concert or privity with them, from using the Infringing Marks, the
`Infringing Domain Names or any other name or mark or domain name that is likely
`to cause confusion, to cause mistake, or to deceive with respect to Plaintiff’s Veritas
`Marks;
`An Order awarding Plaintiff maximum statutory damages under 15 U.S.C. §
`1117(d) of $300,000.00 for the three Infringing Domains; An Order awarding
`Plaintiff its reasonable attorneys’ fees and costs pursuant to 15 U.S.C. § 1117(a);
`and
`Such other relief as the Court may deem just and proper.
`
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`JURY DEMAND
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`C.
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`D.
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`E.
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`F.
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`G.
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`Plaintiff respectfully demand a jury trial on all appropriate issues pursuant to Rule 38(b)
`of the Federal Rules of Civil Procedure.
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`DATED: July 10, 2020
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`RESPECTFULLY SUBMITTED,
`
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`/s/ Sharon A. Urias
`Sharon A. Urias
`GREENSPOON MARDER LLP
`8585 E. Hartford Drive, Ste. 700
`Scottsdale, AZ 85255
`Telephone: 480.306.5458
`Email: sharon.urias@gmlaw.com
`
`/s/ Stuart Knight
`Stuart Knight
`GREENSPOON MARDER LLP
`1144 15th Street, Suite 2700
`Denver, CO 80202
`Telephone: 303.665.0860
`Email: stuart.knight@gmlaw.com
`
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`Attorneys for Plaintiff Carrick-Harvest, LLC d/b/a
`Veritas Fine Cannabis
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`Case 1:20-cv-02017-MEH Document 1 Filed 07/10/20 USDC Colorado Page 15 of 15
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`CERTIFICATE OF SERVICE
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`I hereby certify that on July 10, 2020, I electronically transmitted the attached document to
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`the Clerk’s Office using the CM/ECF System for filing and transmittal of a Notice of Electronic
`Filing to the CM/ECF registrants on record.
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` /s/ Lauren Fuller
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`15
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