`
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF FLORIDA
`FORT LAUDERDALE DIVISION
`
`CASE NO.: 0:24-cv-60908
`
`
`
`
`
`VPR BRANDS, LP,
`
`
`Plaintiff,
`
`
`v.
`
`RUFPUF LLC and ZAYDAN
`INNOVATIONS INC.,
`
`
`Defendants.
`
`
`
`
`
`COMPLAINT FOR TRADEMARK INFRINGEMENT, UNFAIR COMPETITION
`AND PATENT INFRINGEMENT
`(INJUNCTIVE RELIEF DEMANDED)
`
`Plaintiff VPR BRANDS, LP by and through its undersigned counsel, brings this
`
`Complaint against Defendants RUFPUF LLC and ZAYDAN INNOVATIONS INC., for
`
`damages and injunctive relief, and in support thereof states as follows:
`
`NATURE OF THE LAWSUIT
`
`
`
`Plaintiff VPR BRANDS, LP (“VPR”) brings this action for trademark
`
`infringement and unfair competition arising under the Lanham Act, 15 U.S.C. § 1114 and
`
`1125(a), and Florida common law, to enjoin and obtain damages resulting from the Defendants’
`
`unauthorized marketing, advertising, promotion, sale, and importation of e-cigarette products
`
`that infringe Plaintiff’s United States Trademark Registration No. 5,392,011 for RIPPER for
`
`electronic cigarettes and smokeless cigarette vaporizer pipe (“RIPPER Mark”).
`
`
`
`Plaintiff seeks preliminary and permanent injunctive relief to prevent Defendants
`
`from continuing to infringe Plaintiff’s RIPPER Mark, and monetary damages resulting from
`
`Defendants’ past and ongoing infringement.
`
`SRIPLAW
`CALIFORNIA ♦ GEORGIA ♦ FLORIDA ♦ TENNESSEE ♦ NEW YORK
`
`
`
`Case 0:24-cv-60908-WPD Document 1 Entered on FLSD Docket 05/28/2024 Page 2 of 15
`
`JURISDICTION AND VENUE
`
`
`
`This is an action arising under the Lanham Act, 15 U.S.C. § 1114 and § 1125(a).
`
`
`
`
`
`This is also an action arising under the Patent Act.
`
`This Court has original and exclusive subject matter jurisdiction over this action
`
`pursuant to 35 U.S.C. § 271.
`
`
`
`This Court has subject matter jurisdiction over the claims herein pursuant to 28
`
`U.S.C. §§ 1331, 1338(a).
`
`
`
`Defendants are subject to personal jurisdiction in Florida pursuant to Fla. Stat. §
`
`48.193 because Defendants market, advertise, distribute, and sell trademark infringing products
`
`in this judicial district to consumers in this judicial district, and Defendants’ trademark
`
`infringement and unfair competition caused injury to Plaintiff in this judicial district.
`
`
`
`Venue for Plaintiff’s Lanham Act claims is proper in this district under 28 U.S.C.
`
`§ 1391(b) and (c) because the events giving rise to the claims occurred in this district,
`
`Defendants engaged in infringement in this district, and Defendants are subject to personal
`
`jurisdiction in this district.
`
`THE PLAINTIFF
`
`
`
`Plaintiff, VPR Brands, LP (“VPR”), is a Delaware limited partnership with its
`
`principal place of business in this judicial district, located at 3001 Griffin Road, Fort
`
`Lauderdale, FL 33312.
`
` VPR is a market leader and pioneer engaged in product development for the
`
`vaping market, including e-liquids, vaporizers, and electronic cigarettes (also known as e-
`
`cigarettes) which are devices that deliver nicotine and or cannabis through atomization or
`
`vaping, and without smoke and other chemical constituents typically found in traditional
`
`products.
`
`2
`SRIPLAW
`CALIFORNIA ♦ GEORGIA ♦ FLORIDA ♦ TENNESSEE ♦ NEW YORK♦ INDIANA
`
`
`
`Case 0:24-cv-60908-WPD Document 1 Entered on FLSD Docket 05/28/2024 Page 3 of 15
`
` VPR is in the business of creating, designing, and distributing innovative
`
`electronic cigarette technologies and other related technologies. VPR is also in the business of
`
`creating valuable e-cigarette brands.
`
` VPR has been successful in building valuable intellectual property due, at least in
`
`part, to the extensive experience of CEO Kevin Frija’s extensive experience in the e-cigarette
`
`industry. Frija began working in the e-cigarette business in 2008. In 2009, Frija became the
`
`President and Chief Executive Officer of Vapor Corp., one of the first U.S. importers and first
`
`publicly traded electronic cigarette companies. Frija helped grow Vapor Corp. into one of the
`
`largest and most recognized electronic cigarette companies at the time.
`
`THE PLAINTIFF’S RIPPER TRADEMARK
`
` As early as August 9, 2017, VPR first used the mark RIPPER in commerce in
`
`relation with electronic cigarettes.
`
` On January 30, 2018, VPR obtained the United States Trademark Registration
`
`No. 5,392,011 for RIPPER in International Class 34 for use in connection with “Electronic
`
`cigarettes; Smokeless cigarette vaporizer pipe.” (the “RIPPER Mark” or “’011 Registration”).
`
`Exhibit 1 annexed hereto is a true and correct copy of the RIPPER registration.
`
` VPR’s RIPPER Mark is entitled to a presumption of validity. 15 U.S.C. §
`
`1057(b); 15 U.S.C. § 1115(a); see also Welding Servs., Inc. v. Forman, 509 F.3d 1351, 1357 n.3
`
`(11th Cir. 2007) (“Registration establishes a rebuttable presumption that the marks are
`
`protectable or ‘distinctive.’”).
`
` RIPPER is an arbitrary mark that had no significance in the electronic cigarette
`
`business prior to VPR’s usage of the mark.
`
` Because the RIPPER Mark is an arbitrary mark it deserves greater trademark
`
`protection.
`
`3
`SRIPLAW
`CALIFORNIA ♦ GEORGIA ♦ FLORIDA ♦ TENNESSEE ♦ NEW YORK♦ INDIANA
`
`
`
`Case 0:24-cv-60908-WPD Document 1 Entered on FLSD Docket 05/28/2024 Page 4 of 15
`
` VPR currently markets its wax power vaporizer and essential oil vape under the
`
`RIPPER brand. The RIPPER Essential Oil & Wax Vaporizer is a reusable (non-disposable) e-
`
`cigarette that is designed to be disguised as a lighter. The product features a high capacity 1300
`
`mAh rechargeable battery, micro USB port, replaceable oil vape tank with ceramic heater, dual
`
`quartz wax vape tank, a flip open top for concealment and cleanliness, and a textured grip for
`
`durability. An example of VPR’s RIPPER-branded hand-held vaporizing device is shown
`
`below.
`
` VPR’s RIPPER Mark is highly distinctive, and the purchasing public equates the
`
`
`
`RIPPER Mark with Plaintiff’s high-quality goods and services.
`
` VPR markets and sells its RIPPER devices on its publicly available website
`
`https://www.vapehoneystick.com/.
`
` VPR also sells its RIPPER e-cigarette products and e-cigarette accessory products
`
`through retailers nationwide.
`
` VPR was the first to use the mark RIPPER in connection with RIPPER e-cigarette
`
`products and e-cigarette accessory products. Prior to VPR’s use of the RIPPER mark, no other
`
`e-cigarette brand used the RIPPER mark for e-cigarettes or accessories.
`
`4
`SRIPLAW
`CALIFORNIA ♦ GEORGIA ♦ FLORIDA ♦ TENNESSEE ♦ NEW YORK♦ INDIANA
`
`
`
`Case 0:24-cv-60908-WPD Document 1 Entered on FLSD Docket 05/28/2024 Page 5 of 15
`
` RIPPER is an arbitrary mark that had no significance in the electronic cigarette
`
`industry.
`
` VPR chose the arbitrary and unique RIPPER mark to signify to its consumers its
`
`RIPPER e-cigarette products and e-cigarette accessory products from other devices on the
`
`market.
`
` VPR continually and exclusively used the RIPPER mark for RIPPER e-cigarette
`
`products and e-cigarette accessory products to date. VPR has continuously used the RIPPER
`
`Mark in commerce to distinguish its e-cigarette products and e-cigarette accessory products
`
`since 2017.
`
` VPR has never licensed the use of the RIPPER Mark to anyone for use with e-
`
`cigarette products or e-cigarette accessory products.
`
` VPR’s RIPPER mark is distinctive, and the purchasing public equates Plaintiff’s
`
`Mark with Plaintiff’s high-quality goods and services.
`
` VPR expended significant resources to market RIPPER e-cigarette products and
`
`e-cigarette accessory products to consumers.
`
` VPR’s RIPPER mark is widely recognized by consumers of e-cigarette products
`
`and e-cigarette accessory products.
`
` VPR’s RIPPER mark is well known by national distributors of e-cigarette
`
`products and e-cigarette accessory products.
`
` VPR’s RIPPER mark signifies the highest industry standards for e-cigarette
`
`products and e-cigarette accessory products.
`
` VPR’s RIPPER mark serves as an indication of origin, source, and quality for
`
`consumers and distributors of e-cigarette products and e-cigarette accessory products.
`
`5
`SRIPLAW
`CALIFORNIA ♦ GEORGIA ♦ FLORIDA ♦ TENNESSEE ♦ NEW YORK♦ INDIANA
`
`
`
`Case 0:24-cv-60908-WPD Document 1 Entered on FLSD Docket 05/28/2024 Page 6 of 15
`
` VPR carefully monitors and controls the use of the RIPPER mark to ensure that
`
`only the highest quality e-cigarette products and e-cigarette accessory products carry the
`
`RIPPER brand.
`
` At all times relevant, VPR was the senior user of the RIPPER Mark in the United
`
`States.
`
`DEFENDANTS
`
` Defendant Rufpuf LLC (“Rufpuf”) is an Illinois limited liability company with its
`
`principal place of business at 4320 Winfield Road, Suite 200, Warrenville, IL 60555 and can be
`
`served by serving its registered agent, Nida Shahid at 1121 W. Ogden Ave Apt. 356, Naperville,
`
`IL 60563.
`
` Defendant Zaydan Innovations Inc. (“Zaydan”) is a Canadian corporation based
`
`in Alberta, Canada.
`
` Zaydan is the manufacturer and supplier of RIPPER electronic cigarettes.
`
`Examples of the RIPPER electronic cigarette products sold by defendants are shown below:
`
`
`
`6
`SRIPLAW
`CALIFORNIA ♦ GEORGIA ♦ FLORIDA ♦ TENNESSEE ♦ NEW YORK♦ INDIANA
`
`
`
`Case 0:24-cv-60908-WPD Document 1 Entered on FLSD Docket 05/28/2024 Page 7 of 15
`
`
`
`
`
`
`
` Defendants distributed, advertised and sold RIPPER electronic cigarette products
`
`throughout this district to consumers in this jurisdiction.
`
` Defendants used the registered RIPPER Mark in interstate commerce without the
`
`consent, authorization, license or permission of VPR.
`
` Defendants are the junior users of the RIPPER Mark for electronic cigarettes in
`
`this district.
`
` Defendants advertised, marketed, promoted, offered for sale, distributed, and sold
`
`hand-held electronic cigarette products under the RIPPER name in this judicial district.
`
` Defendants’ RIPPER name is confusingly similar to Plaintiff’s RIPPER Mark as
`
`applied to e-cigarette products, and is likely to cause confusion among consumers, retailers and
`
`distributors in the United States.
`
` The RIPPER name is confusingly similar to Plaintiff’s registered RIPPER mark
`
`as applied to e-cigarette products.
`
` The RIPPER name is causing actual confusion among consumers, retailers and
`
`distributors of e-cigarettes in this district.
`
`7
`SRIPLAW
`CALIFORNIA ♦ GEORGIA ♦ FLORIDA ♦ TENNESSEE ♦ NEW YORK♦ INDIANA
`
`
`
`Case 0:24-cv-60908-WPD Document 1 Entered on FLSD Docket 05/28/2024 Page 8 of 15
`
` The RIPPER name is causing confusion among consumers, retailers and
`
`distributors of e-cigarettes in the United States.
`
` VPR has been harmed.
`
` The harm to VPR is irreparable.
`
`THE PLAINTIFF’S PATENT
`
` VPR owns all right, title and interests in, and/or has standing to sue for
`
`infringement of United States Patent Number 8,205,622 (the “‘622 Patent”) entitled “Electronic
`
`Cigarette.” A copy of the ‘622 Patent is attached hereto as Exhibit 2.
`
`49.
`
`The ‘622 Patent discloses an electronic cigarette consisting of an electronic
`
`inhaler and an electronic atomizer.
`
`50.
`
`The electronic inhaler contains a rechargeable or non-rechargeable power source
`
`such as a battery, which supplies electric power to the electronic inhaler. In addition to the power
`
`source, the inhaler also includes an electric airflow sensor to detect air movement generated by a
`
`user's inhaling or puffing act. The sensor's role is to collect an airflow signal that triggers the
`
`electronic cigarette to supply electric power to the inhaler and atomizer connected through an
`
`electric connector.
`
`51.
`
`Inside the electronic atomizer are an electric connector, electric heating wire,
`
`liquid container, and atomizer cap with an air-puffing hole. The user inhales through the air
`
`puffing hole at an end of the electronic cigarette to create an air inflow, which triggers the
`
`atomization process that converts a solution to a gas emulating the smoking process.
`
`DEFENDANTS’ PATENT INFRINGEMENT
`
` Defendants make, use, import, offer for sale, distribute and sell one or more
`
`electronic cigarette products that practice all the steps of at least one claim of the ‘622 Patent.
`
`8
`SRIPLAW
`CALIFORNIA ♦ GEORGIA ♦ FLORIDA ♦ TENNESSEE ♦ NEW YORK♦ INDIANA
`
`
`
`Case 0:24-cv-60908-WPD Document 1 Entered on FLSD Docket 05/28/2024 Page 9 of 15
`
` The electronic cigarette products that infringe the ‘622 Patent are branded as
`
`RIPPER.
`
`54.
`
`RIPPER products are electronic cigarettes that contain a rechargeable battery that
`
`functions as a power source which supplies electric power to an electronic inhaler. In addition to
`
`the power source, the inhaler also includes an electric airflow sensor to detect air movement
`
`generated by a user's inhaling or puffing act.
`
`55.
`
`RIPPER products also contain an electronic atomizer with an electric connector,
`
`electric heating wire, liquid container, and atomizer cap with an air-puffing hole.
`
`56.
`
`The user inhales through the air puffing hole at an end of the RIPPER to create an
`
`air inflow, which triggers the atomization process that converts a solution to a gas emulating the
`
`smoking process.
`
`57.
`
`The electronic cigarette products that Defendants make, use, import, offer for
`
`sale, distribute and sell under the RIPPER brand name infringe one or more claims of the ‘622
`
`Patent.
`
`58.
`
`At all times during which Defendants imported, made, used, offered to sell and
`
`sold electronic cigarette products that infringe one or more claims of the ‘622 Patent, Defendants
`
`had knowledge of the ‘622 Patent.
`
`59.
`
`Plaintiff has been irreparably harmed by Defendants’ infringement of VPR’s
`
`valuable patent rights.
`
`60.
`
`Defendants’ unauthorized, infringing use of VPR’s patented electronic cigarette
`
`has threatened the value of VPR’s intellectual property because Defendants’ conduct results in
`
`VPR’s loss of its lawful patent rights to exclude others from importing, making, using, selling,
`
`offering to sell and/or importing the patented inventions.
`
`9
`SRIPLAW
`CALIFORNIA ♦ GEORGIA ♦ FLORIDA ♦ TENNESSEE ♦ NEW YORK♦ INDIANA
`
`
`
`Case 0:24-cv-60908-WPD Document 1 Entered on FLSD Docket 05/28/2024 Page 10 of 15
`
`61.
`
`Defendants’ disregard for VPR’s property rights similarly threatens VPR’s
`
`relationships with potential licensees of this intellectual property.
`
`62.
`
`Defendants will derive a competitive advantage from using VPR’s patented
`
`technology without paying compensation for such use.
`
`63.
`
`Unless and until Defendants’ continued acts of infringement are enjoined, VPR
`
`will suffer further irreparable harm for which there is no adequate remedy at law.
`
`COUNT I - TRADEMARK INFRINGEMENT UNDER SECTION 32(a) OF THE
`LANHAM ACT, 15 U.S.C. § 1114(a)
`
` Plaintiff repeats and realleges the allegations set forth in paragraphs 1 through 63
`
`as if set forth fully herein.
`
` VPR registered the RIPPER Mark, in International Class 34 for use in connection
`
`with electronic cigarettes, with the USPTO on January 30, 2018 and was assigned the
`
`registration number 5,392,011.
`
` At all relevant times VPR was the owner of the RIPPER Mark at issue in this
`
`case.
`
` Defendants’ use of the mark RIPPER in connection with electronic cigarettes is
`
`likely to cause confusion in the marketplace.
`
` Defendants’ infringement of Plaintiff’s RIPPER Mark is willful and done with
`
`knowledge that their use of RIPPER is likely to cause confusion in the marketplace.
`
` Defendants’ activities alleged in this Count have been without license,
`
`permission, or authorization from VPR.
`
` The activities of Defendants as set forth in this Count have been to the injury,
`
`detriment and irreparable harm to VPR.
`
`10
`SRIPLAW
`CALIFORNIA ♦ GEORGIA ♦ FLORIDA ♦ TENNESSEE ♦ NEW YORK♦ INDIANA
`
`
`
`Case 0:24-cv-60908-WPD Document 1 Entered on FLSD Docket 05/28/2024 Page 11 of 15
`
` Unless enjoined, Defendants’ infringement will continue to harm VPR’s valuable
`
`registered trademark rights.
`
`COUNT II - FALSE DESIGNATION OF ORIGIN, AND UNFAIR COMPETITION
`UNDER SECTION 43(a) OF THE LANHAM ACT, 15 U.S.C. § 1125(a)
`
` Plaintiff repeats and realleges the allegations set forth in paragraphs 1 through 63
`
`as if set forth fully herein.
`
` At all relevant times VPR was the owner of the RIPPER Mark at issue in this
`
`case.
`
` Defendants used plaintiff’s RIPPER mark to promote the sale of electronic
`
`cigarette products in interstate commerce under the name RIPPER.
`
` Defendants’ use of plaintiff’s RIPPER mark is a false designation of origin, false
`
`or misleading description of fact, or false or misleading representation of fact, because
`
`Defendants have never been licensed or otherwise authorized to use Plaintiff’s RIPPER Mark
`
`for any purpose.
`
` Defendants’ use of plaintiff’s RIPPER mark is a false designation of origin, false
`
`or misleading description of fact, or false or misleading representation of fact that is likely to
`
`cause confusion, mistake, or deceive consumers as to the affiliation, connection, or association
`
`of VPR with the Defendants.
`
` Defendants’ use of plaintiff’s RIPPER mark is a false designation of origin, false
`
`or misleading description of fact, or false or misleading representation of fact that is likely to
`
`cause confusion, mistake, or deceive as to the origin, sponsorship, or approval by VPR of
`
`Defendants’ goods.
`
` Defendants’ use of plaintiff’s RIPPER mark is a false designation of origin, false
`
`or misleading description of fact, or false or misleading representation of fact that Defendants’
`
`11
`SRIPLAW
`CALIFORNIA ♦ GEORGIA ♦ FLORIDA ♦ TENNESSEE ♦ NEW YORK♦ INDIANA
`
`
`
`Case 0:24-cv-60908-WPD Document 1 Entered on FLSD Docket 05/28/2024 Page 12 of 15
`
`use in commercial advertising or promotion misrepresents the nature, characteristics, or
`
`qualities of Defendants’ RIPPER products.
`
` The activities of Defendants as set forth in this Count have been to the injury,
`
`detriment and irreparable harm to VPR.
`
` Unless enjoined, Defendants’ unfair competition will continue to deceive the
`
`public and injure competition.
`
`COUNT III – COMMON LAW UNFAIR COMPETITION
`
` VPR incorporates the allegations of paragraphs 1 through 63 as if fully set forth
`
`herein.
`
`case.
`
` At all relevant times VPR was the owner of the RIPPER Mark at issue in this
`
` Defendants used plaintiff’s RIPPER mark to promote the sale of electronic
`
`cigarette products under the name RIPPER.
`
` Defendants’ use of the RIPPER mark is unfair and injures competition.
`
` Defendants’ activities alleged in this Count have been without license,
`
`permission, or authorization from VPR.
`
` Defendants’ activities alleged herein constitute unfair methods of competition in
`
`violation of the common law of the state of Florida.
`
` As a direct and proximate result of Defendants’ unfair competition, VPR has
`
`suffered and will continue to suffer loss of reputation among its purchasers and potential
`
`purchasers, and Defendants will continue to unfairly acquire income, profits, and goodwill.
`
` VPR has been damaged.
`
` The damage to VPR is irreparable.
`
`12
`SRIPLAW
`CALIFORNIA ♦ GEORGIA ♦ FLORIDA ♦ TENNESSEE ♦ NEW YORK♦ INDIANA
`
`
`
`Case 0:24-cv-60908-WPD Document 1 Entered on FLSD Docket 05/28/2024 Page 13 of 15
`
` Unless enjoined, Defendants’ unfair competition will continue to deceive the
`
`public and injure competition.
`
`COUNT IV- DIRECT INFRINGEMENT OF U.S. PATENT NO. 8,205,622
`
` VPR incorporates the allegations of paragraphs 1 through 63 as if fully set forth
`
`herein.
`
` Within the six years preceding the filing of the original Complaint, Defendants
`
`directly infringed at least one claim of U.S. Patent No. 8,205,622 by the activities referred to in
`
`herein in violation of 35 U.S.C. § 271(a).
`
` Without limiting the foregoing, Defendants infringed at least claim 13 of the ‘622
`
`Patent by making, using, distributing, importing, offering to sell and selling RIPPER branded
`
`electronic cigarettes.
`
`
`
`Defendants’ activities alleged in this Count have been without license,
`
`permission, or authorization from VPR.
`
`
`
`The activities of Defendants as set forth in this Count have been to the injury,
`
`detriment and irreparable harm to VPR.
`
`PRAYER FOR RELIEF
`
`WHEREFORE, the Plaintiff VPR Brands, LP prays for judgment against the Defendants
`
`Rufpuf LLC and Zaydan Innovations Inc. that:
`
`a.
`
`Defendants and their officers, agents, servants, employees, affiliated
`
`entities, and all of those in active concert with them, be preliminarily and permanently
`
`enjoined from committing the acts alleged herein in violation of 15 U.S.C. § 1114 and §
`
`1125;
`
`b.
`
`Defendants be required to pay Plaintiff its damages including lost sales
`
`and Defendants’ profits as provided in 15 U.S.C. § 1125;
`
`13
`SRIPLAW
`CALIFORNIA ♦ GEORGIA ♦ FLORIDA ♦ TENNESSEE ♦ NEW YORK♦ INDIANA
`
`
`
`Case 0:24-cv-60908-WPD Document 1 Entered on FLSD Docket 05/28/2024 Page 14 of 15
`
`c.
`
`Enter a finding of willful patent infringement against Defendants under the
`
`patent asserted in this Complaint;
`
`d.
`
`e.
`
`Permanently enjoin Defendants from committing patent infringement;
`
`Award in favor of Plaintiff and against Defendants such damages as
`
`Plaintiff may have suffered but in no event less than a reasonable royalty pursuant to 35
`
`U.S.C. § 284;
`
`f.
`
`Award in favor of Plaintiff and against Defendants an enhancement of
`
`damages;
`
`g.
`
`Award in favor of Plaintiff for treble damages pursuant to 15 U.S.C. §
`
`1117(a);
`
`h.
`
`Enter a preliminary injunction and permanently enjoining Defendants
`
`from using the RIPPER Mark in relation to selling and marketing electronic cigarettes;
`
`i.
`
`j.
`
`Find that this is an exceptional case;
`
`Award Plaintiff its attorneys’ fees against Defendants under 35 U.S.C. §
`
`285 15 U.S.C. § 1117(a);
`
`k.
`
`l.
`
`Award Plaintiff its costs against Defendants,
`
`Plaintiff be awarded pre- and post-judgment interest; and
`
`m.
`
`Plaintiff be awarded such other and further relief as the Court deems just
`
`and proper.
`
`
`
`JURY DEMAND
`
`Plaintiff hereby demands a trial by jury of all issues so triable.
`
`DATED: May 28, 2024
`
`
`
`Respectfully submitted,
`
`14
`SRIPLAW
`CALIFORNIA ♦ GEORGIA ♦ FLORIDA ♦ TENNESSEE ♦ NEW YORK♦ INDIANA
`
`
`
`Case 0:24-cv-60908-WPD Document 1 Entered on FLSD Docket 05/28/2024 Page 15 of 15
`
`
`
`/s/ Joel B. Rothman
`JOEL B. ROTHMAN
`Florida Bar Number: 98220
`joel.rothman@sriplaw.com
`LAYLA T. NGUYEN
`Florida Bar Number: 1024723
`layla.nguyen@sriplaw.com
`
`SRIPLAW, P.A.
`21301 Powerline Road
`Suite 100
`Boca Raton, FL 33433
`561.404.4350 – Telephone
`561.404.4353 – Facsimile
`
`Counsel for Plaintiff VPR Brands LP
`
`15
`SRIPLAW
`CALIFORNIA ♦ GEORGIA ♦ FLORIDA ♦ TENNESSEE ♦ NEW YORK♦ INDIANA
`
`