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`UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF CONNECTICUT
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`JUUL LABS, INC.,
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`Plaintiff,
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`v.
`DIN SIPRA LLC,
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`Defendant.
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`
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`Civil Action No.
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`PLAINTIFF'S COMPLAINT FOR TRADEMARK INFRINGEMENT, FALSE DESIGNATION
`OF ORIGIN, UNFAIR COMPETITION, AND STATUTORY UNFAIR TRADE PRACTICES
`
`
`Plaintiff JUUL LABS, INC. ("JLI"), by and through its undersigned attorneys, files this
`Complaint against defendant DIN SIPRA LLC, a Connecticut limited liability company
`("Defendant"), and hereby alleges as follows:
`PARTIES
`JLI is a corporation organized and existing under the laws of the State of
`
`1.
`Delaware.
`Defendant Din Sipra LLC is a limited liability company organized and existing
`2.
`under the laws of the State of Connecticut and having a principal place of business at 275
`Washington Street, Norwich, Connecticut 06360. Defendant Din Sipra LLC owns and
`operates the Gulf – Sam's Food Store retail business at that same location.
`NATURE OF THE ACTION
`JLI is the designer, manufacturer, and distributor of JUUL-branded electronic
`3.
`nicotine delivery systems ("ENDS") and other related products (collectively, "the JUUL
`Products").
`4.
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`The JUUL Products have become targets for individuals and entities who
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`Case 3:21-cv-01546-AVC Document 1 Filed 11/19/21 Page 2 of 13
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`wish to take a "free ride" on the commercial success of the JUUL brand that JLI has spent
`considerable effort and resources to build.
`Specifically, wrongdoers have counterfeited JUUL Products by illegally
`5.
`manufacturing, selling, and distributing fake, copied, and non-genuine versions of JUUL
`Products and related packaging bearing JUUL trademarks.
`Through this action, JLI combats the sale and distribution of these unlawful
`6.
`counterfeit products.
`
`JURISDICTION AND VENUE
`This Court has subject matter jurisdiction over this case pursuant to 15 U.S.C.
`7.
`§1121 and 28 U.S.C. §§1331, 1338(a), and 1338(b) because (i) claims herein arise out of
`federal trademark laws as codified in 15 U.S.C. §1114 and 15 U.S.C. §1125(a) (i.e.,
`trademark infringement, false designation of origin, and unfair competition); and (ii) the unfair
`business practices claim herein is brought with and is related to the substantial claims based
`on trademark laws. This Court also has supplemental jurisdiction over JLI's claims arising
`under common law or state law pursuant to 28 U.S.C. §1367(a) because the claims are so
`related to JLI's federal law claims that they form part of the same case or controversy and
`derive from a common nucleus of operative facts.
`This Court has general personal jurisdiction over Defendant due to its
`8.
`residence and business activities in this judicial district. This Court has specific personal
`jurisdiction over Defendant due to the nature and quality of its actions toward the state in
`which this Court is located. The claims asserted herein arise out of and relate to such actions
`and this Court's exercise of specific personal jurisdiction over Defendant comports with
`traditional notions of fair play and substantial justice.
`Venue in this judicial district is proper for these claims pursuant to 28 U.S.C.
`9.
`§1391(b). As described herein, Defendant resides in this judicial district, a substantial part
`of the events or omissions giving rise to these claims occurred in this judicial district, and
`Defendant has extensive contacts with this judicial district relating to JLI's claims. Defendant
`conducts regular and systematic business transactions in this judicial district, including direct
`sales to consumers in this judicial district, which violate the intellectual property rights of JLI.
`FACTUAL ALLEGATIONS COMMON TO ALL CLAIMS
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`JUUL®
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`®
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`JUULpods®
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`Case 3:21-cv-01546-AVC Document 1 Filed 11/19/21 Page 3 of 13
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`JUUL Trademarks and Products
`JLI is the exclusive owner of federally-registered, registration-pending, and
`10.
`common law trademarks. For example, JLI owns the following United States Trademark
`Registrations:
`
`Depiction of Trademark
`
`(1) First Use
`Registration No.
`(2) In Commerce
`and Date
`(1) 06-01-2015
`4,818,664
`(2) 06-01-2015
`(09-22-2015)
`(1) 06-01-2015
`4,898,257
`(2) 06-01-2015
`(02-09-2016)
`(1) 06-30-2015
`5,918,490
`(2) 06-30-2015
`(11-26-2019)
`True and correct copies of the Registration Certificates for the above-listed
`11.
`trademarks are attached hereto as Exhibit A. Hereinafter, JLI may sometimes utilize the
`phrase "the JUUL Marks" to refer to, collectively, JLI's federally-registered, registration-
`pending, and common law trademarks.
`JLI creates, manufactures, distributes, markets, and sells JUUL Products,
`12.
`including the JUUL system comprised of: (i) a device containing a rechargeable battery,
`control circuitry and a receptacle for a cartridge or pod, (ii) a disposable cartridge or pod
`("JUULpod") that can be inserted into the device, has a heating chamber and is prefilled with
`a proprietary nicotine e-liquid formulation, and (iii) a charger for charging the device, and
`related accessories.
`The JUUL Marks appear clearly on JUUL Products and/or the packaging as
`13.
`shown in attached Exhibit B, and in marketing materials related to such products.
`The JUUL Marks, as well as the goodwill arising from such trademarks, have
`14.
`never been abandoned.
`JLI continues to preserve and maintain its rights with respect to the JUUL
`15.
`Marks, including those registered with the United States Patent and Trademark Office.
`Due in large part to the substantial commercial success of the JUUL
`16.
`Products, the JUUL brand is well-known to consumers and has garnered extensive coverage
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`Case 3:21-cv-01546-AVC Document 1 Filed 11/19/21 Page 4 of 13
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`by the media.
`Through the extensive use of the JUUL Marks, JLI has spent substantial time,
`17.
`money, and effort in developing consumer recognition and awareness of its brand. JLI
`markets JUUL Products nationwide to current adult smokers, including through its website,
`and sells its products nationwide, including in Connecticut, to current adult smokers through
`its website and through its authorized network. JLI also markets and sells its products
`internationally. JLI has built up and developed significant customer goodwill in its entire
`product line and JUUL Products are immediately identified by the JUUL Marks.
`Sales of Counterfeit Goods
`Beginning on a date that is currently unknown to JLI, Defendant, without the
`18.
`consent of JLI, has offered to sell and sold, and/or facilitated the offer and sale of, goods that
`were neither made by JLI nor by a manufacturer authorized by JLI, all by using reproductions,
`counterfeits, copies and/or colorable imitations of JUUL Products and the JUUL Marks
`("Counterfeit Goods").
`JLI has not authorized any third party, including Defendant, to make or sell
`19.
`ENDS or other types of products in connection with the JUUL Marks. The Counterfeit Goods
`sold by Defendant are therefore not manufactured in accordance with JLI's own stringent
`quality controls but are instead manufactured outside of JLI's knowledge and control, using
`unknown substances and materials, in unknown locations and with unknown manufacturing
`requirements/controls.
`The Counterfeit Goods sold by Defendant bear counterfeit and confusingly
`20.
`similar imitations of the JUUL Marks in a manner likely to be confused with genuine JUUL
`Products.
`For example, on December 23, 2020, a representative of JLI made an in-
`21.
`person purchase of a Counterfeit Good for sale at the Gulf – Sam's Food Store retail business
`owned and operated by Defendant located at 275 Washington Street, Norwich, Connecticut
`06360 (the "Gulf – Sam's Food Store Business"). A true and correct image of the counterfeit
`product purchased on December 23, 2020 is attached hereto as Exhibit C. JLI subsequently
`inspected the product purchased on December 23, 2020 and confirmed that the purchased
`product is in fact a counterfeit product.
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`Case 3:21-cv-01546-AVC Document 1 Filed 11/19/21 Page 5 of 13
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`Cease-and-Desist Correspondence to Defendant
`On December 29, 2020, JLI's counsel mailed a cease-and-desist
`22.
`correspondence to Defendant. A true and correct copy of this correspondence is attached
`hereto as Exhibit D. The cease-and-desist correspondence provided specific notice of the
`following, among other items: (i) JLI's confirmation that goods sold by Defendant are in fact
`counterfeit goods; (ii) JLI's demand that Defendant cease the sale, manufacture, marketing,
`and importation of Counterfeit Goods and all other unauthorized use of JLI's intellectual
`property; (iii) JLI's ownership of the JUUL Marks; (iv) the statutory prohibition of the sale of
`Counterfeit Goods and all other unauthorized use of JLI's intellectual property, and JLI's right
`to seek monetary judgments against infringers; and (v) Defendant's willful infringement under
`federal law would be established by any further sales of Counterfeit Goods or any other
`unauthorized use of JLI's intellectual property.
`The December 29, 2020 cease-and-desist correspondence requested that
`23.
`Defendant contact JLI's counsel to discuss pre-litigation resolution of the legal issues arising
`from the sale of the Counterfeit Goods and all other unauthorized use of JLI's intellectual
`property. Defendant contacted JLI's counsel, but such communication did not result in
`resolution of JLI's claims.
`Continued Sales of Counterfeit Goods
`On March 3, 2021, a representative of JLI made an in-person purchase of a
`24.
`Counterfeit Good for sale at the Gulf – Sam's Food Store Business. A true and correct image
`of the counterfeit product purchased on March 3, 2021 is attached hereto as Exhibit E. JLI
`subsequently inspected the product purchased on March 3, 2021 and confirmed that the
`purchased product is in fact a counterfeit product.
`Defendant is not authorized, and never has been authorized by JLI, to
`25.
`produce, manufacture, distribute, market, offer for sale, and/or sell merchandise bearing the
`JUUL Marks, or any variations thereof. JLI has no control over the nature, quality, or pricing
`of Defendant's products or marketing, or any other aspect of the business conduct of
`Defendant.
`Defendant uses words, symbols, images, designs, and names confusingly
`26.
`similar or identical to the JUUL Marks to confuse consumers and aid in the promotion and
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`Case 3:21-cv-01546-AVC Document 1 Filed 11/19/21 Page 6 of 13
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`sales of the Counterfeit Goods.
`Defendant's counterfeit sales outlined above are likely to deceive, confuse,
`27.
`and mislead purchasers and prospective purchasers into believing that the products are
`authorized by JLI. Purchasers and prospective purchasers using or simply viewing
`Defendant's Counterfeit Goods and who perceive a defect, lack of quality, or any other
`irregularity are likely to mistakenly attribute the issue to JLI, to the detriment of JLI's business,
`goodwill, and the JUUL brand.
`The likelihood of confusion, mistake, and deception brought about by
`28.
`Defendant's misappropriation of the JUUL Marks is causing irreparable harm to the goodwill
`symbolized by the JUUL Marks, and the reputation for quality that said marks embody.
`Defendant's unauthorized use of the JUUL Marks began after JLI legally
`29.
`established the existence and significant value of such trademarks, including after JLI's
`adoption and use of the JUUL Marks and after JLI obtained the trademark registrations
`described above.
`Defendant's infusion of the Counterfeit Goods into the marketplace reflects
`30.
`adversely on JLI, results in economic loss to JLI including loss of sales of genuine JUUL
`Products, damages the goodwill of the JUUL brand, and thwarts JLI's honest efforts and
`considerable expenditures to promote its genuine JUUL Products using the JUUL Marks.
`COUNT 1
`Trademark Infringement – Counterfeit Goods (15 U.S.C. §1114)
`JLI re-alleges and incorporates by this reference each and every allegation
`31.
`in paragraphs 1 through 30 as though set forth fully herein.
`Defendant's actions to sell and distribute the Counterfeit Goods which utilize
`32.
`spurious designations that are identical to, or substantially indistinguishable from, the JUUL
`Marks are intended to cause, have caused, and are likely to continue to cause public
`confusion or mistake, or to deceive consumers, the public, and the trade into believing that
`the Counterfeit Goods are genuine or authorized JUUL Products.
`Defendant's actions to sell and distribute the Counterfeit Goods therefore
`33.
`constitute trademark infringement in violation of 15 U.S.C. §1114.
`JLI has been damaged as a result of Defendant's infringement of the JUUL
`34.
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`Marks. On information and belief, Defendant's sale and distribution of the Counterfeit Goods
`have resulted in lost sales to JLI, have reduced the business and profits of JLI, and have
`injured the general reputation and goodwill of JLI, all to JLI's damage in an amount not yet
`ascertainable, but will be determined during this Civil Action or considered in relation to a
`request for statutory damages.
`On information and belief, that Defendant has derived, received, and will
`35.
`continue to derive and receive from the aforesaid acts of infringement, gains, profits, and
`advantages in an amount to be determined during this Civil Action or to be considered in
`relation to a request for statutory damages.
`On information and belief, Defendant acted intentionally and/or willfully in
`36.
`infringing upon the JUUL Marks through sale and distribution of the Counterfeit Goods,
`knowing that the JUUL Marks belonged to JLI, that the Counterfeit Goods were in fact
`infringing, and that Defendant was not authorized to infringe upon the JUUL Marks through
`sale and distribution of the Counterfeit Goods.
`Defendant's spurious designation of its products also constitutes the use by
`37.
`Defendant of at least one "counterfeit mark" as defined in 15 U.S.C. §1116(d)(1)(B).
`Therefore, JLI is entitled to recovery of treble damages and to an award of reasonable
`attorneys' fees pursuant to 15 U.S.C. §§1117(a) and 1117(b).
`Because Defendant's actions constitute the use by Defendant of at least one
`38.
`"counterfeit mark" as defined in 15 U.S.C. §1116(d)(1)(B), JLI reserves the right to elect, at
`any time before final judgment is entered in this case, an award of statutory damages
`pursuant to 15 U.S.C. §1117(c)(1) or (2). On information and belief, Defendant has knowingly
`and willfully engaged in the acts complained of with oppression, fraud, malice, and in
`conscious disregard of the rights of JLI. JLI is, therefore, entitled to the maximum statutory
`damages allowable.
`The acts of trademark infringement committed by Defendant, directly and/or
`39.
`in contributory or vicarious manner, have caused, and will continue to cause, JLI irreparable
`harm unless they are enjoined by this Court. On information and belief, Defendant's actions
`were committed in bad faith and with the intent to cause confusion and mistake, and to
`deceive the consuming public as to the source, sponsorship, and/or affiliation of Defendant
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`and/or the Counterfeit Goods.
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`COUNT 2
`False Designation of Origin – Counterfeit Goods (15 U.S.C. §1125(a))
`JLI re-alleges and incorporates by this reference each and every allegation
`40.
`in paragraphs 1 through 39 as though set forth fully herein.
`Defendant's unauthorized use of the JUUL Marks, brand names, and the
`41.
`other distinctive words, symbols, slogans, color schemes, images, and designs through
`which Defendant presents its Counterfeit Goods to the market constitutes a wrongful and
`false representation to the consuming public that the Counterfeit Goods sold by Defendant
`originated from JLI or somehow are authorized by or affiliated with JLI.
`Defendant's actions as described herein constitute violation of 15 U.S.C.
`42.
`§1125(a)(1)(A), as such actions are likely to cause confusion, or to cause mistake, or to
`deceive as to the affiliation, connection, or association of Defendant with JLI and/or as to the
`origin, sponsorship, and/or approval of the Counterfeit Goods by JLI. These acts amount to
`false designations of origin.
`JLI has been damaged as a result of Defendant's actions described herein.
`43.
`On information and belief, Defendant's sale of the Counterfeit Goods has resulted in lost
`sales to JLI, has reduced the business and profits of JLI, and has greatly injured the general
`reputation and goodwill of JLI, all to JLI's damage in an amount not yet ascertainable, but
`that will be determined during this Civil Action or to be considered in relation to a request for
`statutory damages.
`On information and belief, Defendant has derived, received, and will continue
`44.
`to derive and receive from the aforesaid acts of infringement, gains, profits, and advantages
`in an amount to be determined during this Civil Action or to be considered in relation to a
`request for statutory damages.
`On information and belief, Defendant acted intentionally and/or willfully in
`45.
`using the JUUL Marks on the Counterfeit Goods, knowing that the JUUL Marks belonged to
`JLI, that the Counterfeit Goods were in fact counterfeit, and that Defendant was not
`authorized to use the JUUL Marks on the Counterfeit Goods.
`Defendant's acts of violating 15 U.S.C. §1125(a), directly and/or in
`46.
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`Case 3:21-cv-01546-AVC Document 1 Filed 11/19/21 Page 9 of 13
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`contributory or vicarious manner, have caused, and will continue to cause, JLI irreparable
`harm unless they are enjoined by this Court. On information and belief, Defendant's actions
`were committed in bad faith and with the intent to cause confusion and mistake, and to
`deceive the consuming public as to the source, sponsorship, and/or affiliation of Defendant
`and/or the Counterfeit Goods.
`
`COUNT 3
`Unfair Competition – Counterfeit Goods (15 U.S.C. §1125(a))
`JLI re-alleges and incorporates by this reference each and every allegation
`47.
`in paragraphs 1 through 46 as though set forth fully herein.
`An express purpose of the Lanham Act is to protect commercial parties
`48.
`against unfair competition.
`Defendant's unauthorized use of the JUUL Marks, brand names, and the
`49.
`other distinctive words, symbols, color schemes, and designs through which JLI presents its
`products to the market constitutes wrongful and unfair business practices and marketplace
`bad faith, resulting in false designations and inaccurate representations to the consuming
`public that the Counterfeit Goods sold by Defendant originated from or somehow are
`authorized by or affiliated with JLI. Defendant so acted for Defendant's own financial benefit
`in disregard to the harm being caused to JLI.
`Defendant's actions as described herein constitute violation of 15 U.S.C.
`50.
`§1125(a)(1)(A), as such actions are likely to cause confusion, or to cause mistake, or to
`deceive as to the affiliation, connection, or association of Defendant with JLI and/or as to the
`origin, sponsorship, and/or approval of the Counterfeit Goods by JLI. These acts amount to
`false designations to compete unfairly with JLI.
`JLI has been damaged as a result of Defendant's actions described herein.
`51.
`On information and belief, Defendant's sale of the Counterfeit Goods has resulted in lost
`sales to JLI, has reduced the business and profits of JLI, and has greatly injured the general
`reputation and goodwill of JLI, all to JLI's damage in an amount to be determined during this
`Civil Action or to be considered in relation to a request for statutory damages.
`On information and belief, Defendant has derived, received, and will continue
`52.
`to derive and receive from the aforesaid acts of infringement, gains, profits, and advantages
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`in an amount to be determined during this Civil Action or to be considered in relation to a
`request for statutory damages.
`On information and belief, Defendant acted intentionally and/or willfully in
`53.
`using the JUUL Marks on the Counterfeit Goods, knowing that the JUUL Marks belonged to
`JLI, that the Counterfeit Goods were in fact counterfeit, and that Defendant was not
`authorized to use the JUUL Marks on the Counterfeit Goods.
`Defendant's acts of violating 15 U.S.C. §1125(a), directly and/or in
`54.
`contributory or vicarious manner, have caused, and will continue to cause, JLI irreparable
`harm unless they are enjoined by this Court. On information and belief, Defendant's actions
`were committed in bad faith and with the intent to cause confusion and mistake, and to
`deceive the consuming public as to the source, sponsorship, and/or affiliation of Defendant
`and/or the Counterfeit Goods.
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`COUNT 4
`Statutory Unfair Trade Practices – Conn. Gen. Stat. §42-110a, et seq.
`JLI re-alleges and incorporates by this reference each and every allegation
`55.
`in paragraphs 1 through 54 as though set forth fully herein
`Defendant's actions of trademark infringement, false designations of origin,
`56.
`misrepresentation, and deception described herein constitute unfair competition and/or unfair
`trade practices in violation of Connecticut's Unfair Trade Practices Act, Conn. Gen. Stat. §§
`42-110a, et seq. Defendant's actions described herein also offend public policy.
`JLI has been damaged by Defendant's acts of unfair competition or unfair
`57.
`trade practices. On information and belief, Defendant's sale and distribution of the
`Counterfeit Goods have resulted in economic loss to JLI and have injured JLI's general
`reputation and goodwill in the industry, all in an amount to be determined during this Civil
`Action.
`Defendant's actions described herein have caused, and will continue to
`58.
`cause, JLI to suffer irreparable harm unless enjoined by this Court.
`COUNT 5
`Common Law Unfair Competition
`JLI re-alleges and incorporates by this reference each allegation in
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`59.
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`Case 3:21-cv-01546-AVC Document 1 Filed 11/19/21 Page 11 of 13
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`paragraphs 1 through 58 as though set forth fully herein.
`JLI and Defendant are competitors in the marketing and sale of ENDS and
`60.
`related products.
`Defendant's actions of trademark infringement, false designation of origin,
`61.
`misrepresentation, and deception in the sale of ENDS described herein constitute unfair
`competition in the marketing and sale of ENDS and related products under the common law.
`JLI has been damaged by Defendant's acts of unfair competition. JLI alleges,
`62.
`on information and belief, that Defendant's sale and distribution of the Counterfeit Goods
`have resulted in economic loss to JLI, have injured the general reputation and goodwill of
`JLI, and caused JLI to suffer damage in an amount to be determined during this Civil Action.
`Defendant's actions described herein have caused, and will continue to
`63.
`cause, JLI to suffer irreparable harm unless enjoined by this Court.
`REQUEST FOR RELIEF
`WHEREFORE, JLI hereby respectfully requests the following relief against
`Defendant DIN SIPRA LLC, a Connecticut limited liability company, as follows:
`An award of Defendant's profits and JLI's damages for trademark infringement
`1.
`of the JUUL Marks under 15 U.S.C. §§ 1114 and 1117, trebled, in an amount
`to be proven at trial;
`An award of Defendant's profits and JLI's damages for false designations of
`origin in the sale of Counterfeit Goods under 15 U.S.C. §1125(a), trebled, in
`an amount to be proven at trial;
`An award of Defendant's profits and JLI's damages for unfair competition in
`the sale of Counterfeit Goods under 15 U.S.C. §1125(a), trebled, in an
`amount to be proven at trial;
`In the alternative to Defendant's profits and JLI's damages for trademark
`infringement of JUUL Marks, an award of statutory damages pursuant to 15
`U.S.C. §1117(c) of $2,000,000.00 for each of the counterfeited trademarks
`willfully utilized by Defendant per type of goods sold, offered for sale or
`distributed;
`An injunction by this Court prohibiting Defendant, and Defendant's respective
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`4.
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`agents, servants, employees, and representatives and all persons in active
`concert and participation with them, during the pendency of this action and
`permanently thereafter, from: engaging or continuing to engage in the
`infringing, unlawful, unfair, or fraudulent business acts or practices described
`herein, including the marketing, sale, distribution, and/or other dealing in any
`non-genuine JUUL Products, including fake counterfeit products or
`unauthorized grey-market products; using without permission any mark or
`other intellectual property right of JLI; acting to infringe the JUUL Marks;
`falsely designating the origin of any non-genuine JUUL Product; engaging in
`unfair competition with JLI; or acting in any other manner to derogate JLI's
`intellectual property rights;
`An Order requiring that Defendant provide complete accountings and for
`equitable relief;
`An Order that an asset freeze or constructive trust be imposed over all ill-
`gotten monies and profits in Defendant's possession;
`Pursuant to 15 U.S.C. §1116, including upon ex parte application, an Order
`for the seizure of goods and counterfeit marks and the means of making such
`marks, and records documenting the manufacture, sale, or receipt of things
`involved in trademark violations;
`Pursuant to 15 U.S.C. §1118, an Order requiring that Defendant and all others
`acting under Defendant's authority, at their cost, be required to deliver up to
`JLI for destruction all products, accessories, labels, signs, prints, packages,
`wrappers, marketing materials, and other material in their possession,
`custody, or control bearing any of the JUUL Marks;
`To the extent not duplicated by the awards sought above, an award of actual
`damages for the unfair acts and practices of Defendant, and in the Court's
`discretion punitive damages, pursuant Conn. Gen. Stat. §42-110g(a);
`To the extent not duplicated by the awards above, an award of costs and JLI's
`reasonable attorney's fees pursuant to Conn. Gen. Stat. §42-110g(d);
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`6.
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`7.
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`8.
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`9.
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`10.
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`11.
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`Prejudgment interest and post-judgment interest in the maximum amount
`allowed under the law; and
`Such other and further relief as the Court may deem just and equitable.
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`12.
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`13.
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`November 19, 2021
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`Respectfully submitted,
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`JUUL LABS, INC.
`Plaintiff
`
`s/ JOHN C. LINDERMAN
`JOHN C. LINDERMAN
`ct04291
`lind@ip-lawyers.com
`GERALD L. DEPARDO
`ct15134
`depardo@ip-lawyers.com
`MCCORMICK, PAULDING &
`HUBER PLLC
`CityPlace II, 18th Flr
`185 Asylum Street
`Hartford, CT 06103-3410
`Ph. 860-549-5290
`Fax 860-527-0464
`Counsel for Plaintiff JUUL LABS, INC.
`
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