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`Case 1:22-cv-01722-CAP Document 1 Filed 05/01/22 Page 1 of 23
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`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF GEORGIA
`ATLANTA DIVISION
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`SAMA CAMP, LLC,
`Plaintiff,
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` CIVIL ACTION NO. ______________
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`v.
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`SAMA TEA, LLC; SAMA
`WORLDWIDE INC.; SAMA
`BEVERAGES, LLC; and 100.CO,
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`Defendants.
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`COMPLAINT
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`Plaintiff Sama Camp, LLC (“Sama Camp” or “Plaintiff”), for its Complaint
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`against Defendants Sama Tea, LLC; Sama Worldwide Inc.; Sama Beverages, LLC;
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`and 100.co, (collectively, “Defendants”) states as follows:
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`NATURE OF THE ACTION
`This is an action for trademark infringement, unfair competition and
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`1.
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`false designation of origin arising under the Trademark Act of 1946, as amended, 15
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`U.S.C. § 1051, et seq. (the “Lanham Act”), and under the common law of the State
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`of Georgia.
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`2.
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`In the highly competitive and extraordinarily challenging restaurant
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`and prepared food industries, Sama Camp has successfully developed a strong
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`reputation for the high quality of its various products, including its unique blends of
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`tea.
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`3.
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`For nearly five years, Sama Camp has offered a variety of products and
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`services under its distinctive SAMA® brand and developed a loyal and enthusiastic
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`consumer base.
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`4.
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`Among Sama Camp’s products are a variety of proprietary tea
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`blends, which are sold on premises at Sama Camp’s physical location, as well as
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`sold via direct-to-consumer orders through its website as shown below:
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`5.
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`In October 2017, Sama Camp obtained a federal registration for the
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`mark SAMA® with the United States Patent Office, covering its full suite of
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`goods and services.
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`6.
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`Sama Camp or its predecessor or successor in interest has made
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`longstanding, continuous and, until the Defendants’ conduct giving rise to this
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`action, exclusive use of the SAMA® mark, which consumers have come to associate
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`with Sama Camp, and which Sama Camp has dedicated significant resources to
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`protect.
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`7.
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`Despite Sama Camp’s prior rights in the SAMA® mark, Sama Camp
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`became aware that Defendants are producing, marketing, selling, and distributing to
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`consumers, under the identical “Sama” name, products that are identical to certain
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`products produced under Sama Camp’s SAMA® mark (the “infringing goods”).
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`8.
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`Defendants have made repeated, blatant, far-reaching, and expensive
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`efforts to market the infringing goods in the United States, in plain violation of Sama
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`Camp’s senior rights, including but not limited to using “Sama” as a stand-alone in
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`the same manner Sama Camp has used and continues to use its SAMA® mark.
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`9.
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`Defendants’ infringing goods are likely to cause, and in fact have
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`caused, confusion among the trade and consuming public as to the source or origin
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`of the infringing goods, thereby causing ongoing irreparable harm to Sama Camp.
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`THE PARTIES
`10. Sama Camp is a limited liability company organized and existing under
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`the laws of the State of Georgia, having its principal place of business at 872
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`Argonne Avenue, Atlanta, Georgia 30309.
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`11. On information and belief, Defendant Sama Tea, LLC is a limited
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`liability company organized and existing under the laws of the State of California,
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`having its principal place of business at 404 14th Street, San Diego, California 92101.
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`12. On information and belief, Defendant Sama Tea, LLC manufactures,
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`distributes, markets, and sells the infringing goods, or causes the infringing goods
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`to be manufactured, distributed, marketed, and sold.
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`13. On information and belief, Defendant Sama Worldwide Inc. is a
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`corporation organized and existing under the laws of the State of Delaware, having
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`its principal place of business at 382 NE 191st Street, Miami, Florida 33179.
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`14. On
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`information and belief, Defendant Sama Worldwide Inc.
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`manufactures, distributes, markets, and sells the infringing goods, or causes the
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`infringing goods to be manufactured, distributed, marketed, and sold.
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`15. On information and belief, Defendant Sama Beverages, LLC is a
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`limited liability company organized and existing under the laws of the State of
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`California, having its principal place of business at 4420 N Bay Road, Miami Beach,
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`Florida 33140.
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`16. On information and belief, Defendant Sama Beverages, LLC
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`manufactures, distributes, markets, and sells the infringing goods, or causes the
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`infringing goods to be manufactured, distributed, marketed, and sold.
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`17. On information and belief, Defendant 100.co is a Florida company
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`having its principal place of business at 382 NE 191st Street, Miami, Florida 33179.
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`18. On information and belief, Defendant 100.co exercises control over the
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`other Defendants’ commercial activities and/or causes the infringing goods to be
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`manufactured, distributed, marketed, and sold.
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`JURISDICTION AND VENUE
`19. This Court has subject matter jurisdiction over this Complaint by virtue
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`of 28 U.S.C. §§1331 and 1338, and under its supplemental jurisdiction of 28 U.S.C.
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`§1367, the Counts of which concern acts of trademark infringement, false
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`designation of origin, and unfair competition under the Lanham Act, 15 U.S.C.
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`§1125(a), and trademark infringement and unfair competition under the laws of the
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`State of Georgia.
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`20. The Court has supplemental jurisdiction over the claims arising under
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`the laws of the State of Georgia, pursuant to 28 U.S.C. § 1367(a), because the state
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`law claims are so related to the federal subject-matter claims that they form part of
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`the same case or controversy and derive from a common nucleus of operative fact.
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`21. This court has personal jurisdiction over Defendants because
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`Defendants have deliberately and intentionally marketed, sold, and shipped, or
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`caused to be marketed, sold, and shipped, the infringing goods to consumers within
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`the State of Georgia.
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`22. Venue is proper in this Court under 28 U.S.C. § 1391 in that Defendants
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`are subject to personal jurisdiction in this judicial district, and that a substantial part
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`of the events giving rise to this action occurred in this judicial district.
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`23. Defendants have deliberately and intentionally shipped or caused to be
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`shipped the infringing goods to this judicial district.
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`STATEMENT OF FACTS
`24. Since 2017, Sama Camp (or its predecessor or successor in interest) has
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`designed, produced, and provided for sale unique and distinctive goods and services
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`under its SAMA® brand.
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`25. Among these products is Sama Camp’s SAMA® branded teas and
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`health cleansing products, which Sama Camp has produced and marketed under the
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`SAMA® mark since at least as early as 2017.
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`26. True and accurate images of the SAMA® branded products are
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`attached hereto as Exhibit A.
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`27. Sama Camp or its predecessor or successor in interest, over a period of
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`nearly half a decade, has spent extraordinary time, effort, and money, and absorbed
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`commercial risk, in the course of developing its brand and line of products. As a
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`result of these efforts, Sama Camp enjoys a substantial and loyal customer
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`following, who associate the SAMA® brand with Sama Camp and its high-quality
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`products and services.
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`28. Same Camp has an active social media presence with which it interacts
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`with its customers across the United States.
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`29. True and accurate examples of Sama Camp’s social media presence
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`and performance among the relevant consuming public are attached hereto as
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`Exhibit B.
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`30. Consequently, the SAMA® mark is distinctive and enjoys a highly
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`favorable reputation among the members of the trade and the consuming public and
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`has become a valuable symbol of Sama Camp’s goodwill.
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`Sama Camp’s Federal Trademark Registrations
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`31. On July 20, 2016, Sama Camp filed U.S. Application Serial No.
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`87/110,918, on an intent-to-use basis, to register the SAMA® mark in standard
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`characters with the United States Patent and Trademark Office (“USPTO”).
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`32. On August 11, 2017, Sama Camp submitted its statement of use of the
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`SAMA® mark, which the USPTO accepted on September 27, 2017.
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`33. On October 31, 2017, the SAMA® mark was registered by the USPTO
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`on the Principal Register and accorded Registration No. 5,325,040 covering the use
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`of the SAMA® mark for the following goods and services:
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`Class 3: non-medicated skin care preparations, namely, organic and
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`herbal facial cleansers, skin cleansers, bath oils and bath salts, skin
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`peels, face and body moisturizers, body scrubs, skin calming lotions,
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`facial serums
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`Class 5: herbal supplements, nutritional supplements
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`Class 29: hummus chick pea paste
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`Class 30: salad dressings, tea
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`Class 32: fruit juices, vegetable-fruit juices
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`Class 43: food preparation services, restaurant services
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`Class 44: health spa services for health and wellness of the body and
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`spirit, wellness and health-related consulting services
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`A true and correct copy of the Certificate of Registration for the SAMA® mark is
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`attached hereto as Exhibit C.
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`34. The SAMA® mark is inherently distinctive and thus entitled to the
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`highest degree of protection under the law.
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`35. Sama Camp’s SAMA® Registration is prima facie evidence of its
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`validity of the SAMA® mark and conclusive evidence of Sama Camp’s exclusive
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`right to use the mark in commerce in connection with the goods and services covered
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`by the SAMA® Registration. The SAMA® Registration also constitutes
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`constructive notice to Defendants of Sama Camp’s ownership and exclusive rights
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`in the SAMA® mark. Further, Sama Camp’s SAMA® mark is valid, subsisting,
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`unrevoked, and uncancelled.
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`Defendants’ Infringing Acts
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`36. Sama Camp became aware that Defendants are producing, marketing,
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`offering for sale, and selling, under the materially identical name “Sama Tea” in
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`connection with a line of tea products and blends (the “infringing goods”).
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`37. Defendants market and sell the infringing goods through, among other
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`channels, social media channels the same as those used by Sama Camp.
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`38. On information and belief, Defendants have spent hundreds of
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`thousands of dollars marketing the infringing goods bearing the SAMA® mark in
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`the United States.
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`39. On information and belief, Defendants deliberately intend to push
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`Sama Camp out of the market by flooding the market with advertising.
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`40. The infringing goods manifestly copy the distinctive elements of Sama
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`Camp’s SAMA® branded goods, including by associating the word SAMA with tea
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`directly, and by using materially similar design elements.
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`41. True and correct copies of social media posts in which Defendants
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`market and sell the infringing goods are attached hereto as Exhibit D.
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`42. Defendants are not, and have never been, affiliated with, sponsored, or
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`licensed by Sama Camp to use the SAMA® mark in connection with products
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`identical to the genuine SAMA® branded products.
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`43. Defendants have never obtained permission to use or license the
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`SAMA® mark, or any other marks or designs confusingly similar thereto, for use
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`on or in connection with any goods or services, including on the infringing goods.
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`44. Sama Camp has corresponded with Defendants or their counsel on
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`several occasions to demand that Defendants immediately cease all marketing and
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`sales of the infringing goods.
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`45. Defendants are aware of Sama Camp’s notifications as to Defendant’s
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`use of the SAMA® mark and Sama Camp’s business, as Defendants’ counsel has
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`responded to Sama Camp’s communications. Nonetheless, Defendants have failed
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`and refused to cease their unlawful actions.
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`46. Notwithstanding Defendants’ awareness of Sama Camp’s rights in the
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`SAMA® mark and Sama Camp’s business, Defendant Sama Tea, LLC filed U.S.
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`Trademark Application Serial No. 90/016,315 to register the mark SAMA in
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`standard characters for “tea, beverages made of tea” in international class 30.
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`47. Defendants’ application to register SAMA was refused due to the
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`USPTO’s recognition of Sama Camp’s senior rights in the SAMA® mark.
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`48. Notwithstanding Defendants’ awareness of Sama Camp’s rights in the
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`SAMA® mark and Sama Camp’s business, as well as the USPTO’s determination
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`of a likelihood of confusion between Defendants’ proposed SAMA mark and the
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`SAMA® mark, Defendants filed a petition to cancel the SAMA® Registration
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`before the USPTO’s Trademark Trial & Appeal Board (“TTAB”) on the basis of
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`non-use.
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`49. That petition is the subject of TTAB Cancellation No. 92077032 (the
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`“Cancellation Proceeding”).
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`50. Prior to filing the Cancellation Proceeding, Defendant Sama Tea, LLC
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`and its counsel knew or should have known that the SAMA® mark underlying the
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`SAMA® Registration was in use.
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`51. Sama Camp has, concurrent with filing this action, moved to suspend
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`the Cancellation Proceeding.
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`52. By using the SAMA® mark in connection with their competing and
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`infringing goods, Defendants seek to confuse and deceive the trade and the
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`consuming public as to the source or origin of the infringing goods and the genuine
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`SAMA® branded Sama Camp products.
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`53. On information and belief, trademark searching performed by
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`Defendants or their agents disclosed the existence of Sama Camp prior to
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`Defendants’ adoption of the name “Sama Tea.”
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`54. Defendants intended to copy Sama Camp’s SAMA® mark when they
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`adopted the name “Sama Tea.”
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`55. Defendants culpably disregarded the risk of reverse confusion to the
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`public.
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`56. On information and belief, Defendants therefore knowingly, willfully,
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`intentionally, and maliciously adopted and used the confusingly similar “Sama Tea”
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`name for marketing and selling the infringing goods, knowing that such use would
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`mislead, deceive, and generate reverse confusion among the consuming public.
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`The Harm to Sama Camp as a Result of Defendants’ Unlawful Conduct
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`57. Both Sama Camp and Defendants provide identical products to
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`identical consumers, namely, tea products to consumers interested in health and
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`wellness considerations when purchasing consumable goods.
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`58. Upon information and belief, Defendants have intentionally and
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`willfully directed their advertising, promotional and sales efforts at the same classes
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`of consumers as those to whom Sama Camp caters in an effort to capitalize on Sama
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`Camp’s commercial goodwill and also to push Sama Camp out of the market.
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`Defendants have intentionally flooded the market with advertising they know Sama
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`Camp cannot reasonably counter to a degree sufficient to avoid confusion and
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`preserve its hard-won reputation for quality.
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`59. Further, upon information and belief, Defendants have engaged in such
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`conduct with the knowledge that the SAMA® mark is valid and subsisting, is in use
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`by Sama Camp, and possesses substantial commercial goodwill.
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`60. Defendants’ infringing goods are closely similar, if not virtually
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`identical, to the products Sama Camp offers under the SAMA® mark. Thus,
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`Defendants’ use of the mark SAMA and the “Sama Tea” name is likely to be
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`confusing to a substantial number of actual and potential customers, and is likely to
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`cause them to be deceived and to erroneously assume that the parties’ respective
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`goods are in some way connected with one another.
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`61. Given Defendants’ cavalier attitude toward intellectual property
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`infringement and Sama Camp’s manifestly superior rights in the SAMA® mark,
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`Defendants put at risk and damage Sama Camp’s reputation, goodwill, and ability
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`to market and promote its goods and services.
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`62. Defendants’ unauthorized use of the confusingly similar “Sama Tea”
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`name has injured Sama Camp’s interests and will continue to do so unless
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`immediately enjoined. Specifically, Defendants have (a) deliberately attempted to
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`push Sama Camp out of the market by flooding the market in a manner against which
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`Sama Camp cannot defend; (b) damaged and threaten to damage Sama Camp’s
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`rights and valuable goodwill in the SAMA® mark; and (c) injured and threaten to
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`injure Sama Camp’s right to use and license the SAMA® mark as the exclusive
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`indicia of origin of Sama Camp’s goods and services, including but not limited to
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`through filing a knowingly false petition to cancel before the TTAB.
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`63. All conditions precedent to the filing of this action have occurred or
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`have been waived or excused.
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`64. As a result of the wrongful conduct by Defendants alleged herein, Sama
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`Camp has been forced to engage its counsel of record to enforce its rights in
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`connection with the trademarks at issue. Its counsel is accordingly entitled to its
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`reasonable attorneys’ fees and costs in connection with these legal services.
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`COUNT I
`Federal Trademark Infringement – SAMA® Mark
`(Section 32(1) of the Lanham Act, 15 U.S.C. § 1114(1))
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`65. Sama Camp repeats and realleges the allegations in Paragraphs 1
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`through 64 above as if fully set forth herein.
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`66. The SAMA® Registration is valid and subsisting, and is prima facie
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`evidence of the validity of the SAMA® mark, of Sama Camp’s ownership of the
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`SAMA® mark, and of Sama Camp’s exclusive right to use the SAMA® mark for
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`the goods and services enumerated in the SAMA® Registration, including but not
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`limited to tea. By virtue of the SAMA® Registration, the SAMA® mark is entitled
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`to protection under the Lanham Act, 15 U.S.C. § 1051 et seq.
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`67. Defendant’s use of the confusingly similar “Sama Tea” name for
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`competing tea products is likely to cause confusion, mistake, or deception as to the
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`source or origin of Defendants’ goods.
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`68. Defendants’ adoption and use of the confusingly similar “Sama Tea”
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`name and attempt to register the identical mark SAMA for competing tea products
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`was intentional and was for the purpose of misleading the trade and the consuming
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`public. These willful actions violate Section 32(1) of the Lanham Act, 15 U.S.C. §
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`1114(1).
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`69. As a result of Defendants’ infringement, as described above, the trade
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`and the consuming public are likely to be confused and deceived as to the source,
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`sponsorship, affiliation or approval of the parties’ respective goods.
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`70. Sama Camp has been damaged by the aforementioned acts in an amount
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`to be determined at trial. Defendants’ adoption and use of the “Sama Tea” name and
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`attempt to register the identical mark SAMA for competing tea products is
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`confusingly similar to Sama Camp’s SAMA® mark and was undertaken by
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`Defendants intentionally, maliciously, and in bad faith. Therefore, Sama Camp is
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`entitled to recover from Defendants treble damages and attorneys’ fees.
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`71.
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`In addition, Defendants’ conduct, if it continues, will result in
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`irreparable harm to Sama Camp and, specifically, to the goodwill associated with
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`the SAMA® mark, unless such conduct is enjoined.
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`COUNT II
`False Designation of Origin
`(Section 43(a) of the Lanham Act, 15 U.S.C. § 1125(a))
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`72. Sama Camp repeats and realleges the allegations in Paragraphs 1
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`through 64 above as if fully set forth herein.
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`73. Through the long-standing, continuous, and exclusive use of the
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`SAMA® mark in commerce, the relevant trade and consuming public has come to
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`identify the SAMA® mark and the goods and services offered under it as originating
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`with Sama Camp.
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`74. Sama Camp has built a valuable business in its use of the SAMA®
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`mark, and the goodwill associated with Sama Camp, is of great value to Sama Camp.
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`75. Sama Camp or its predecessor or successor in interest has continuously
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`used the SAMA® mark in commerce to market, sell, and distribute its goods and
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`services since at least 2017.
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`76. Defendants’ conduct as described herein constitutes use of a false
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`designation of origin and/or a false or misleading description or representation of
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`fact on or in connection with his goods which is likely to cause confusion, mistake
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`or deception as to the affiliation, connection, or association of the parties, and/or as
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`to the origin, sponsorship or approval of their respective goods, in violation of
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`Section 43(a) of the Lanham Act, 15 U.S.C. § 1125(a). Defendants’ conduct as
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`described herein also constitutes an attempt to arrogate to itself the substantial
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`goodwill that Sama Camp has developed in the SAMA® mark, all to the damage of
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`Sama Camp.
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`77. Defendants’ use in commerce of designations which are confusingly
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`similar to the SAMA® mark, despite having actual and constructive notice of Sama
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`Camp’s prior rights in and to the SAMA® mark, constitutes intentional conduct by
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`Defendants to make false designations of origin and false descriptions about their
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`goods and commercial activities.
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`78. Defendants have caused and, unless restrained and enjoined by this
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`Court, will continue to cause irreparable harm, damage and injury to Sama Camp.
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`COUNT III
`Common Law Trademark Infringement Under Georgia Law
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`79. Sama Camp repeats and realleges the allegations in Paragraphs 1
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`through 64 as if fully set forth herein.
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`80. Through the long-standing, continuous, and exclusive use of the
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`SAMA® mark in commerce, the relevant trade and consuming public have come to
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`understand the SAMA® mark as identifying Sama Camp and indicating the source
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`of origin of the SAMA® products and services as coming from Sama Camp.
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`81. Sama Camp has built a valuable business in its use of the SAMA®
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`mark, and the goodwill associated with Sama Camp is of great value to Sama Camp.
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`The SAMA® mark has come to indicate to the trade and the consuming public that
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`the particular products and services bearing the SAMA® mark originate from Sama
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`Camp.
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`82. Sama Camp or its predecessor or successor in interest has exclusively
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`used the SAMA® mark in commerce to market, sell, and distribute its products since
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`at least 2017.
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`83. Defendants have used, and are continuing to use, designations that are
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`confusingly similar and/or virtually identical to Sama Camp’s SAMA® mark in
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`interstate commerce and within the State of Georgia in connection with products
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`identical to those offered under the SAMA® mark.
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`84. Defendants’ unauthorized use of the infringing goods is likely to cause
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`confusion in the marketplace between the parties’ respective products and services.
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`85. Defendants’ infringement of Sama Camp’s SAMA® mark is in willful
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`and wanton disregard of Sama Camp’s rights in and to the same, and without the
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`consent of Sama Camp.
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`COUNT IV
`Attorneys’ Fees Under Georgia Law
`(O.C.G.A. § 13-6-11)
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`86. Sama Camp repeats and realleges the allegations in Paragraphs 1
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`through 64 as if fully set forth herein.
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`87. Under Georgia law, a jury may allow an award of attorney’s fees if the
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`party seeking the award has specially pleaded such an award and the party from
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`whom attorney’s fees are sought has acted in bad faith, been stubbornly litigious, or
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`caused unnecessary trouble and expense. O.C.G.A. § 13-6-11.
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`88. Defendants knew or should have known that Sama Camp owns the
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`SAMA® mark and is using it in connection with tea products in interstate commerce.
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`89. Defendants knew or should have known that their use of the “Sama”
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`name in connection with their marketing and sale of tea products would be actually
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`confusing or likely to confuse the consuming public as to the origin of their products.
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`90. Accordingly, Defendants knew or should have known that their use of
`
`the “Sama” name in the manner described would constitute infringement of Sama
`
`Camp’s SAMA® mark in violation of the Lanham Act and Georgia law.
`
`91. Nevertheless, Defendants
`
`launched an unjustified cancellation
`
`
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`19
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`
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`Case 1:22-cv-01722-CAP Document 1 Filed 05/01/22 Page 20 of 23
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`proceeding before the USPTO’s Trademark Trial and Appeal Board and continue to
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`market and sell products identical or nearly identical to Sama Camp’s under the
`
`infringing “Sama” name.
`
`92. Sama Camp has been forced to hire legal counsel and incur substantial
`
`and unnecessary attorney’s fees and costs as a result of Defendants’ bad faith and
`
`stubbornly litigious conduct set forth above.
`
`93. Thus, Sama Camp is entitled to an award of attorneys’ fees under
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`O.C.G.A. § 13-6-11.
`
`PRAYER FOR RELIEF
`
`WHEREFORE, Plaintiff Sama Camp, LLC prays for relief against each
`
`Defendant as follows:
`
`A.
`
`That Defendants and their agents, servants, employees, attorneys,
`
`successors, and assigns, and any and all persons acting in concert or participating
`
`with them, or any of their successors or assigns or any of them, be preliminarily and
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`permanently enjoined and restrained from directly or indirectly:
`
`(1)
`
`using the “Sama Tea” name or SAMA mark, or any other
`
`reproduction, counterfeit, copy, confusingly similar variant, or colorable imitation
`
`of the SAMA® mark;
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`(2) making, distributing, advertising, marketing, offering for sale, or
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`20
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`Case 1:22-cv-01722-CAP Document 1 Filed 05/01/22 Page 21 of 23
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`selling the infringing goods;
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`(3)
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`using the SAMA® mark, or any reproduction, counterfeit, copy,
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`confusingly similar variant or colorable imitation of the same, in any manner likely
`
`to cause others to believe that Defendants’ goods or services are connected with
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`Sama Camp or are genuine Sama Camp-licensed products or services;
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`(4)
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`committing any other acts that may cause the purchasing public
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`to believe that Defendants’ goods and services are genuinely licensed by Sama
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`Camp or otherwise provided for the benefit of Sama Camp;
`
`(5)
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`shipping, delivering, holding for sale, importing, distributing,
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`returning, transferring, or otherwise moving or disposing of any materials falsely
`
`bearing the “Sama Tea” name or SAMA mark, the infringing goods, or any other
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`reproduction, counterfeit, copy, confusingly similar variant or colorable imitation of
`
`the SAMA® mark; and
`
`(6)
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`assisting, aiding, or abetting any other person or business entity
`
`in engaging in or performing any of the activities referred to in the above
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`subparagraphs (1) through (5).
`
`B.
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`That Defendants and any and all persons controlled by or acting in
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`concert with them be required to deliver to Sama Camp for destruction all goods,
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`packages, and any other written or printed materials, in tangible or intangible form,
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`
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`21
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`Case 1:22-cv-01722-CAP Document 1 Filed 05/01/22 Page 22 of 23
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`that bear or depict the “Sama Tea” name or SAMA mark, the infringing goods, or
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`any other reproduction, counterfeit, copy, confusingly similar variant or colorable
`
`imitation of the SAMA® mark.
`
`C.
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`That Defendants be required to account for and pay to Sama Tea
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`Defendants’ profits from sales of the infringing goods and any other product
`
`incorporating, copying, or imitating the Sama Camp products or services or sold
`
`under the “Sama Tea” name or SAMA mark, and such sum in addition thereto as the
`
`Court shall find just.
`
`D.
`
`That this case be found exceptional, and Sama Camp be awarded its
`
`attorneys’ fees pursuant to 15 U.S.C. § 1117(a) and/or other applicable law.
`
`E.
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`That Sama Camp recover the damages arising out of Defendants’
`
`wrongful acts in a sum equal to three times the actual damages suffered by Sama
`
`Camp, as provided in 15 U.S.C. § 1117(b) and/or other applicable law.
`
`F.
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`That Defendants be required to disgorge their profits and other ill-
`
`gotten gains pursuant to 15 U.S.C. § 1117(a) and other applicable law.
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`G.
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`That Sama Camp have and recover the taxable costs of this civil
`
`action, including reasonable attorneys’ fees, costs, and interest.
`
`H.
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`That Sama Camp be awarded punitive or exemplary damages in view
`
`of Defendants’ reckless, willful, wanton acts committed with conscious disregard
`
`
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`22
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`Case 1:22-cv-01722-CAP Document 1 Filed 05/01/22 Page 23 of 23
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`for the rights of Sama Camp.
`
`I.
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`That Sama Camp have such other general and further relief as this Court
`
`deems just and proper.
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`JURY DEMAND
`
`
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`Sama Camp hereby demands a trial by jury as to all issues so triable.
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`Respectfully submitted this 1st day of May 2022,
`
`SPERRY IP LAW d/b/a VIVID IP
`/Tayah L. Woodard/
`
`
`Marcy L. Sperry
`marcy@vividip.com
`Tayah L. Woodard
`tayah@vividip.com
`3017 Bolling Way, NE
`Atlanta, Georgia 30305
`(404) 474-1600
`
`
`
`BEKIARES ELIEZER, LLP
`Zachary Eyster
`2870 Peachtree Rd. #512
`Atlanta GA 30305
`zeyster@founderslegal.com
`Telephone: 404.537.3686
`
`Attorneys for Plaintiff Sama Camp, LLC
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`23
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