Case 1:20-cv-11632-FDS Document 1 Filed 10/11/19 Page 1 of 23
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`UNITED STATES DISTRICT COURT
`DISTRICT OF CONNECTICUT
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`Civil Action No. ____________
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`JURY TRIAL DEMANDED
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`OCTOBER 11, 2019
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`LEGO A/S, LEGO SYSTEMS, INC.,
`and LEGO JURIS A/S
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`Plaintiffs,
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`v.
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`OYO TOYS, INC. and MARS 2000, INC.
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`Defendants.
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`COMPLAINT
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`Plaintiffs LEGO A/S (“LAS”), LEGO Systems, Inc. (“LSI”), and LEGO Juris A/S
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`(“LJAS”) (collectively, “the LEGO Group”) file this Complaint against Defendants OYO Toys,
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`Inc. (“OYO”) and Mars 2000, Inc. (“Mars”) (collectively, “Defendants”) and allege as follows:
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`THE PARTIES
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`1.
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`Plaintiff LAS is a private company with a place of business located at Aastvej 1,
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`Dk-7190, Billund, Denmark.
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`2.
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`Plaintiff LSI is a Delaware corporation having its principal place of business at
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`555 Taylor Road, Enfield, CT 06082.
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`3.
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`Plaintiff LJAS private company with a place of business located at Koldingvej 2,
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`Dk-7190, Billund, Denmark.
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`4.
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`Upon information and belief, Defendant OYO Toys, Inc. is a Delaware
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`corporation with a principal place of business located at 108 Forest Avenue, Hudson,
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`103825708
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`UNITED STATES DISTRICT COURT
`DISTRICT OF CONNECTICUT
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`Civil Action No. ____________
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`JURY TRIAL DEMANDED
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`OCTOBER 11, 2019
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`:::::::::::
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`:
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`LEGO A/S, LEGO SYSTEMS, INC.,
`and LEGO JURIS A/S
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`Plaintiffs,
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`v.
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`OYO TOYS, INC. and MARS 2000, INC.
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`
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`Defendants.
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`COMPLAINT
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`Plaintiffs LEGO A/S (“LAS”), LEGO Systems, Inc. (“LSI”), and LEGO Juris A/S
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`(“LJAS”) (collectively, “the LEGO Group”) file this Complaint against Defendants OYO Toys,
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`Inc. (“OYO”) and Mars 2000, Inc. (“Mars”) (collectively, “Defendants”) and allege as follows:
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`THE PARTIES
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`1.
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`Plaintiff LAS is a private company with a place of business located at Aastvej 1,
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`Dk-7190, Billund, Denmark.
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`2.
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`Plaintiff LSI is a Delaware corporation having its principal place of business at
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`555 Taylor Road, Enfield, CT 06082.
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`3.
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`Plaintiff LJAS private company with a place of business located at Koldingvej 2,
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`Dk-7190, Billund, Denmark.
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`4.
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`Upon information and belief, Defendant OYO Toys, Inc. is a Delaware
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`corporation with a principal place of business located at 108 Forest Avenue, Hudson,
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`Case 1:20-cv-11632-FDS Document 1 Filed 10/11/19 Page 2 of 23
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`Massachusetts and/or 1330 Beacon Street Ste. 243, Brookline, Massachusetts. Upon information
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`and belief, OYO does business in the State of Connecticut.
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`5.
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`Upon information and belief, Defendant Mars 2000, Inc. is a Rhode Island
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`corporation with a principal place of business located at 40 Agnes Street, Providence, Rhode
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`Island. Upon information and belief, Mars does business in the State of Connecticut.
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`JURISDICTION AND VENUE
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`6.
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` This Court has jurisdiction over the subject matter of this Complaint pursuant to
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`28 U.S.C. §§ 1331, 1338(a) and (b), and 1367.
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`7.
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`This Court has personal jurisdiction over Defendants by virtue of their
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`transacting, doing, and soliciting business in this District, and committing acts of copyright and
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`trademark infringement and causing injury in this District.
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`8.
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`Venue is proper in this District, because the Court has personal jurisdiction over
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`Defendants.
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`FACTS
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`9.
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`The LEGO Group is a well-established industry innovator and leader in designing
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`and manufacturing toys and play materials for children of all ages worldwide. The LEGO
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`Group’s toy building elements, figurines and toy sets established the construction toy category,
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`are well-recognized around the world and have enjoyed tremendous commercial success and
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`consistent popular acclaim. Constructive LEGO® play fosters positive, lifelong skills, such as
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`creativity, imagination and creative problem solving, which are valuable to any child.
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`10.
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`The LEGO Group is known for delivering the very best construction toy products
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`and associated play experiences. In fact, the name “LEGO” is an abbreviation of the Danish
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`words “leg godt” meaning “play well.” The LEGO Group was founded in 1932 by Ole Kirk
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`Kristiansen, who started the company making wooden toys and selling them from his workshop
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`in Billund, Denmark. The company has passed from parent to child with Thomas Kirk
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`Kristiansen, great grandchild of the founder, representing the fourth generation of ownership and
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`currently serving as Deputy Chairman of the Board of Directors. Ole Kristiansen’s motto– “det
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`bedste er ikke for godt” meaning “only the best is good enough”– helps explain why, according
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`to a 2014 survey by the Reputation Institute, the LEGO Group is the number two most-admired
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`brand in the United States and number nine globally. The phrase also explains why the LEGO
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`Group’s products have been named “Toy of the Century” by both Fortune magazine and the
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`British Association of Toy Retailers. Over the years, the LEGO Group has amassed significant
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`goodwill and a strong reputation for quality.
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`11.
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` The LEGO Group’s innovative and commercially successful products are the
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`result of its long-time investment in research and development and commitment to cutting-edge
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`toy designs. The LEGO Group’s innovations and products have become so popular and well-
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`recognized that they attract competitors who attempt to capitalize on the LEGO Group’s success
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`by copying its innovations and products and preying on the vulnerability of youthful consuming
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`population, instead of developing their own product lines. Over the years, the LEGO Group has
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`made substantial investments in design, research and development, licensing, and manufacturing
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`in a wide variety of product lines, including those containing the Minifigure figurine construction
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`toy products.
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`Case 1:20-cv-11632-FDS Document 1 Filed 10/11/19 Page 4 of 23
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`Representative LEGO® product lines
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`12.
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`As described in further detail below, Defendants are infringing the LEGO
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`Group’s intellectual property rights with all products featuring figurines that are confusingly,
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`strikingly and substantially similar to the overall look and feel of the LEGO® Minifigure
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`figurine.
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`THE LEGO GROUP’S INTELLECTUAL PROPERTY RIGHTS IN THE MINIFIGURE
`FIGURINE
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`13.
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`In 1978, the LEGO® brand introduced its Minifigure figurine. For more than 40
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`years, the Minifigure figurine has been sold worldwide in numerous varieties of LEGO® brand
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`toy sets, as well as individually, becoming one of the most iconic toys for the LEGO Group.
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`Over 120 million Minifigure figurines have been sold in the United States since 1978.
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`A Representative LEGO® Minifigure figurine
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`14.
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`LAS owns numerous copyrights registered with the United States Copyright
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`Office, including Registration Number VA0000655104 and Registration Number
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`VA0000655230 (the “Minifigure Copyrights”), protecting the 3D sculpture and derivative works
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`of the Minifigure figurine. The registrations and copies of the deposit material are attached as
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`Exhibits A and B.
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`Registration Number
`VA0000655104
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`Registration Number
`VA0000655230
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`15.
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`Since 1978, the LEGO Group has continuously displayed the © symbol in
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`connection to the Minifigure figurine on various product packaging.
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`16.
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`Since at least as early as 1993, the LEGO Group has continuously displayed the ©
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`symbol in the plastic of the Minifigure figurine in various locations.
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`17.
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`Since at least as early as 1998, the LEGO Group has continuously displayed “©
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`LEGO” in the plastic of the Minifigure figurine in various locations. For example, in the images
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`below, “© LEGO” is in the plastic of each element comprising the Minifigure figurine:
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`© LEGO located inside head element of Minifigure figurine
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`© LEGO located on the top
`of leg element of Minifigure
`figurine
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`© LEGO located on the
`bottom of leg element of
`Minifigure figurine
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`© LEGO located on the torso
`element of Minifigure
`figurine
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`18.
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`LJAS owns numerous trademarks registered with the United States Patent &
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`Trademark Office including Registration Number 4,903,968 for the Minifigure figurine (“the
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`Registered Minifigure Trademark”). A copy of the Registration Certificate for the Registered
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`Minifigure Trademark is attached as Exhibit C.
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`U.S. Trademark Registration Number 4,903,968
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`19.
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`The LEGO Group also has common law trademark rights in the Minifigure
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`figurine set forth in Exhibit C, by virtue of its continuous use of the mark in commerce
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`throughout the United States since 1978 (together with the Registered Minifigure Trademark, the
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`“Minifigure Trademarks”).
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`20.
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`The LEGO Group has established valuable (indeed, invaluable) trademark rights
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`and goodwill in the Minifigure Trademarks by virtue of its long use and registration of the
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`trademark, the substantial promotional and marketing efforts under the trademark, the
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`expenditure of vast sums in advertising and promotional activities under that trademark, and
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`third-party licensing agreements.
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`21.
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`The products and services offered, sold, and advertised in connection with the
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`Minifigure Trademarks have generated substantial revenue. Such revenue has exceeded over
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`one billion dollars (USD) internationally.
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`22.
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`As a result of the long and extensive use of the Minifigure Trademarks, and the
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`significant sales, promotion, advertising, third-party licensing, and commercial success under
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`those marks, the Minifigure figurine has achieved such widespread public exposure and
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`recognition that it is distinctive and is well-known and famous among the general consuming
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`public of the United States and abroad.
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`OYO’S INFRINGING FIGURINES
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`23.
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`OYO sells figurines (the “Infringing Figurines”), shown below, that are
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`confusingly, strikingly and substantially similar to the overall look and feel of the LEGO®
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`Minifigure figurine.
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`Representative Infringing Figurine
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`24.
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`The images below show different views of the copyrighted and trademarked
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`LEGO® Minifigure figurine and an Infringing Figurine:
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`Alternating LEGO® Minifigure figurines and an Infringing Figurines
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`25.
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`The Infringing Figurines are advertised and offered for sale on OYO’s website,
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`http://store.oyosports.com/. The website is interactive, as customers can place orders for existing
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`products or design a customized Infringing Figurine using “OYOme creator,” available at
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`http://store.oyosports.com/oyome.
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`Screenshots of OYOme creator for customizing Infringing Figurines
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`26.
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`The Infringing Figurines are also sold at Barnes & Noble in its retail locations
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`throughout the United States, including Connecticut locations.
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`27.
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`The Infringing Figurines are unauthorized reproductions of the LEGO Group’s
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`copyrights and trademarks including the Minifigure Copyrights and Minifigure Trademarks.
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`28.
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`Upon information and belief, OYO has had actual notice of the LEGO Group’s
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`copyrights and trademarks including the Minifigure Copyrights and Minifigure Trademarks in
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`and to the Minifigure figurine since at least as early as July 29, 2019. Counsel for the LEGO
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`Group sent letters regarding OYO’s infringement, but OYO did not respond in any manner.
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`29.
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`The construction toy market is highly competitive. Selling products that infringe
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`the LEGO Group’s copyrights and trademarks will allow OYO to increase its market share and
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`sales, and enable OYO to establish relationships with customers, and licensors potentially, for
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`whom the LEGO Group competes. That potential injury to the LEGO Group is unquantifiable.
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`30.
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`The LEGO Group has no agreement of any kind with OYO that would authorize
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`the manufacture or sale of the Infringing Figurines. The Infringing Figurines are sold through
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`many of the same trade channels as the LEGO® Minifigure figurine.
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`MARS’ INFRINGEMENT
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`31.
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`Upon information and belief, Mars manufactures or has manufactured the
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`Infringing Figurines for OYO that are confusingly, strikingly and substantially similar to the
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`overall look and feel of the LEGO® Minifigure figurine.
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`32.
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`Upon information and belief, Mars does so with knowledge that the Infringing
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`Figurines infringe the Minifigure Copyrights and Minifigure Trademarks and that the Infringing
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`Figurines are offered for sale throughout the United States, including in the State of Connecticut.
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`33. Mars also stated on its website, http://marsplastics.com/, that it produced injection
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`molded plastics, including figurines shown below. These figurines are virtually identical to the
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`LEGO® Minifigure figurine and thus infringe the Minifigure Copyrights and Minifigure
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`Trademarks.
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`Case 1:20-cv-11632-FDS Document 1 Filed 10/11/19 Page 13 of 23
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`Figurines offered on Mars’ website
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`34.
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`The LEGO Group has no agreement of any kind with Mars that would authorize
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`the manufacture or sale of the Infringing Figurines and other figurines. The Infringing Figurines
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`are sold through many of the same trade channels as the LEGO® Minifigure figurine.
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`THE LEGO GROUP’S “STUD” TRADEMARKS
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`35.
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`In 1958, the LEGO® brand of construction toys bearing distinctive cylindrical
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`studs for interconnectivity was launched. The familiar repeating cylindrical stud design has been
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`used by the LEGO Group in connection with a wide assortment of goods and services since that
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`time.
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`36.
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`LJAS owns numerous trademarks registered with the United States Patent and
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`Trademark Office, including Registration Numbers 2,273,314 and 2,273,321 for cylindrical
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`surface features, covering, “toy figures and construction toys,” amongst other goods, in Class 28
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`(“the Registered Cylinder Trademarks”). Copies of the Registration Certificates for the
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`Registered Cylinder Trademarks are attached as Exhibits D and E.
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`USPTO Registration No. 2,273,314
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`USPTO Registration No. 2,273,321
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`37.
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`LJAS also owns U.S. Trademark Registration Number 2,922,658 for an eight stud
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`brick in a two-by-four arrangement, covering, “construction toys” in Class 28 (“the Registered
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`Brick Trademark”) (together with the Registered Cylinder Trademarks, the “Stud Trademarks”).
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`A copy of the Registration Certificate for the Registered Brick Trademark is attached as Exhibit
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`F.
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`USPTO Registration No. 2,922,658
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`38.
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`The LEGO Group has common law trademark rights in the Registered Cylinder
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`Trademarks set forth in Exhibits D and E, by virtue of its continuous use of the marks in
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`commerce throughout the United States since 1961.
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`39.
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`The LEGO Group has common law trademark rights in the Registered Brick
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`Trademark set forth in Exhibit F, by virtue of its continuous use of the marks in commerce
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`throughout the United States since 1987.
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`40.
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`The LEGO Group has established valuable trademark rights and goodwill in the
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`Stud Trademarks by virtue of its long use and registration of the trademarks, the substantial
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`promotional and marketing efforts under the trademarks, the expenditure of vast sums in
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`advertising and promotional activities under those trademarks, and third-party licensing
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`agreements.
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`41.
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`The products and services offered, sold, and advertised in connection with the
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`Stud Trademarks have generated substantial revenue. Such revenue has exceeded over one
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`billion dollars (USD) internationally.
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`42.
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`As a result of the long and extensive use of the Stud Trademarks, and the
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`significant sales, promotion, advertising, third-party licensing, and commercial success under
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`those marks, the Stud Trademarks have achieved such widespread public exposure and
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`recognition that it is distinctive and is well-known and famous among the general consuming
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`public of the United States and abroad.
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`OYO’S INFRINGEMENT OF THE LEGO GROUP’S STUD TRADEMARKS
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`43.
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`OYO uses construction bricks as source identifiers (the “Infringing Stud
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`Trademarks”) that are confusingly similar to the LEGO Group’s Stud Trademarks.
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`44.
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`OYO uses a four stud construction brick in its packaging, shown below:
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`Four stud brick shown on OYO packaging
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`45.
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` OYO uses the four stud brick in connection with the sale of a line of construction
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`brick toys and figurines.
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`46.
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`OYO’s use of cylindrical protrusions and a four stud brick as source identifiers
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`for toy figurines and construction toy products is confusingly similar to the Stud Trademarks.
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`47.
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`The LEGO Group has no agreement of any kind with OYO that would authorize
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`the use of the Stud Trademarks.
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`COUNT I
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`(Copyright Infringement of Minifigure Figurine)
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`48.
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`The LEGO Group hereby repeats and realleges paragraphs 1 through 47 of this
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`Complaint as if fully set forth herein.
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`49.
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`The copyrighted Minifigure figurine comprises, in whole or in part, wholly
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`original works of authorship that are copyrightable subject matter under the copyright laws of the
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`United States, 17 U.S.C. §§ 101, et seq. The LEGO Group has complied in all respects with the
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`laws governing copyright and has secured the rights and privileges in, to, and under the
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`Minifigure Copyrights in the Minifigure figurine.
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`50.
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`In violation of the LEGO Group’s exclusive rights in the Minifigure figurine and
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`the Minifigure Copyrights, OYO has sold, and continues to sell, the Infringing Figurines that are
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`strikingly and substantially similar to the overall look and feel of the Minifigure figurine.
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`51.
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`In violation of the LEGO Group’s exclusive rights in the Minifigure figurine and
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`the Minifigure Copyrights, Mars has sold the Infringing Figurines and other figurines that are
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`strikingly and substantially similar to the overall look and feel of the Minifigure figurine.
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`52.
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`Defendants’ unlawful conduct constitutes direct and indirect infringement of the
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`LEGO Group’s exclusive rights in the Minifigure Copyrights, including without limitation the
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`LEGO Group’s rights under 17 U.S.C. § 106.
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`53.
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`Upon information and belief, as a direct and proximate result of Defendants’
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`wrongful conduct, Defendants have realized and continue to realize profits and other benefits
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`rightfully belonging to the LEGO Group.
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`54.
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`As a result of Defendants’ unlawful conduct, the LEGO Group has suffered and
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`will continue to suffer damages.
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`55.
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`The LEGO Group has suffered and will continue to suffer irreparable harm from
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`Defendants’ infringing acts, unless Defendants’ infringement is enjoined.
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`COUNT II
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`(Trademark Infringement under Section 32(a) of the Lanham Act, 15 U.S.C. § 1114(a))
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`56.
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`The LEGO Group hereby repeats and realleges paragraphs 1 through 55 of this
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`Complaint as if fully set forth herein.
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`57. Without the LEGO Group’s consent, OYO used and continues to use in
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`commerce the Infringing Figurines, and the Infringing Stud Trademarks, as described above, in
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`connection with the offering, sale, and advertising of toy figurines and construction toy products,
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`which are likely to cause confusion, or to cause mistake, or to deceive, in violation of Section 32
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`of the Lanham Act, 15 U.S.C. § 1114.
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`58. Without the LEGO Group’s consent, Mars used in commerce the Infringing
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`Figurines, as described above, in connection with the offering, sale, and advertising of toy
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`figurines, which are likely to cause confusion, or to cause mistake, or to deceive, in violation of
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`Section 32 of the Lanham Act, 15 U.S.C. § 1114.
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`59.
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`Upon information and belief, the actions of Defendants described above have at
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`all times relevant to this action been willful.
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`60.
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`As a direct and proximate result of the actions of Defendants alleged above, the
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`LEGO Group has been damaged and will continue to be damaged.
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`61.
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`The LEGO Group has suffered and will continue to suffer irreparable harm from
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`Defendants’ infringing acts, unless Defendants’ infringement is enjoined.
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`Case 1:20-cv-11632-FDS Document 1 Filed 10/11/19 Page 19 of 23
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`COUNT III
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`(Trademark Infringement, False Designation of Origin, and Unfair Competition under
`Section 43(a)(1)(A) of the Lanham Act, 15 U.S.C. § 1125(a)(1)(A))
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` The LEGO Group hereby repeats and realleges paragraphs 1 through 61 of this
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`62.
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`Complaint as if fully set forth herein.
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`63.
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`The actions of OYO relating to the Infringing Figurines and Infringing Stud
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`Trademarks are likely to cause confusion, mistake, or deception as to the origin, sponsorship, or
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`approval of the products and services and commercial activities of OYO, and thus constitute
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`trademark infringement, false designation of origin, and unfair competition with respect to the
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`Minifigure Trademarks and Stud Trademarks, in violation of Section 43(a)(1)(A) of the Lanham
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`Act, 15 U.S.C. § 1125(a)(1)(A).
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`64.
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`The actions of Mars relating to the Infringing Figurines and other figurines are
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`likely to cause confusion, mistake, or deception as to the origin, sponsorship, or approval of the
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`products and services and commercial activities of Mars, and thus constitute trademark
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`infringement, false designation of origin, and unfair competition with respect to the Minifigure
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`Trademarks, in violation of Section 43(a)(1)(A) of the Lanham Act, 15 U.S.C. § 1125(a)(1)(A).
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`65.
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`Upon information and belief, the actions of Defendants described above have at
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`all times relevant to this action been willful.
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`66.
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`As a direct and proximate result of the actions of Defendants alleged above, the
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`LEGO Group has been damaged and will continue to be damaged.
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`67.
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`The LEGO Group has suffered and will continue to suffer irreparable harm from
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`Defendants’ infringing acts, unless Defendants’ infringement is enjoined.
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`Case 1:20-cv-11632-FDS Document 1 Filed 10/11/19 Page 20 of 23
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`COUNT IV
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`(Common Law Trademark Infringement, Unfair Competition, and Misappropriation)
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`The LEGO Group hereby repeats and realleges paragraphs 1 through 67 of this
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`68.
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`Complaint as if fully set forth herein.
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`69.
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`OYO’s actions described above, including its manufacture, sale, offer for sale,
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`display and distribution of the Infringing Figurines constitute common law trademark
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`infringement, unfair competition, and misappropriation of the LEGO Group’s goodwill under the
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`common law of Connecticut and other states.
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`70. Mars’ actions described above, including its manufacture, sale, offer for sale,
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`display and distribution of the Infringing Figurines and other figurines constitute common law
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`trademark infringement, unfair competition, and misappropriation of the LEGO Group’s
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`goodwill under the common law of Connecticut and other states.
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`71.
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`Upon information and belief, the actions of Defendants described above have at
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`all times relevant to this action been willful.
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`72.
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`As a direct and proximate result of the actions of Defendants alleged above, the
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`LEGO Group has been damaged and will continue to be damaged.
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`73.
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`The LEGO Group has suffered and will continue to suffer irreparable harm from
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`Defendants’ infringing acts, unless Defendants’ infringement is enjoined.
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`COUNT V
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`(Violation of the Connecticut Unfair Trade Practices Act)
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`74.
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`The LEGO Group hereby repeats and realleges paragraphs 1 through 73 of this
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`Complaint as if fully set forth herein.
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`Case 1:20-cv-11632-FDS Document 1 Filed 10/11/19 Page 21 of 23
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`75.
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`By engaging in the acts alleged above, Defendants have willfully and maliciously
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`engaged in conduct offensive to public policy, governing statutes, common law principles, and
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`established concepts of fairness.
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`76.
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`Defendants’ willful and malicious conduct was and is immoral, unethical,
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`oppressive, and unscrupulous.
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`77.
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`Defendants’ conduct has caused and will continue to cause substantial injury to
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`the LEGO Group and to the public interest.
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`78.
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`Defendants committed such acts, and continue to commit such acts, in the conduct
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`of trade or commerce.
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`79.
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`The LEGO Group has suffered, and if Defendants are not enjoined will continue
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`to suffer, an ascertainable loss of money or property as a result of Defendants’ actions.
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`80.
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`By virtue of the conduct above, Defendants have engaged in unfair competition
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`and unfair or deceptive acts or practices in the conduct of trade or commerce in violation of the
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`Connecticut Unfair Trade Practices Act, Conn. Gen. Stat. § 42-110a, et seq.
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`Case 1:20-cv-11632-FDS Document 1 Filed 10/11/19 Page 22 of 23
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`PRAYER FOR RELIEF
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`WHEREFORE, the LEGO Group requests judgment in its favor and against OYO and
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`A judgment that OYO and Mars have infringed the Minifigure Copyrights;
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`A judgment that OYO and Mars have infringed the Minifigure Trademarks;
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`Mars as follows:
`1.
`2.
`3.
`4.
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`A judgment that OYO has infringed the Stud Trademarks;
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`For a temporary restraining order, preliminary and permanent injunction
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`restraining OYO, Mars, their employees, and all persons in active concert or participation with
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`OYO or Mars or with any of the foregoing from:
`a. manufacturing, selling, offering for sale, displaying or authorizing the sale of
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`products, including the Infringing Figurines, containing unauthorized
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`reproductions of the copyrighted and trademarked Minifigure figurine,
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`including any figurine or image that is substantially similar to the
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`Minifigure Copyrights or likely to be confused with the Minifigure
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`Trademarks;
`b. manufacturing, selling, offering for sale, displaying or authorizing the sale of
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`products that make use of the Infringing Stud Trademarks including use of
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`any trademarks that are confusingly similar to the Stud Trademarks;
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`5.
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`An order that OYO and Mars be directed to file with this Court and serve on the
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`LEGO Group within thirty days after the service of an injunction, a report, in writing and under
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`oath, confirming all copies of the Infringing Figurines, and products and product packaging
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`using the Infringing Stud Trademarks and means for copying the same, have been destroyed;
`6.
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` Awarding the LEGO Group its actual damages and Defendants’ profits in an
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`amount to be determined at trial or statutory damages pursuant to 17 U.S.C. § 504 and15 U.S.C.
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`§ 1117 and other applicable laws;
`7.
`8.
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`Awarding the LEGO Group its reasonable attorney’s fees and costs; and
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`Such other and further relief as the Court deems appropriate.
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`Case 1:20-cv-11632-FDS Document 1 Filed 10/11/19 Page 23 of 23
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`DEMAND FOR JURY TRIAL
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`Pursuant to Rule 38 of the Federal Rules of Civil Procedure, the LEGO Group demands
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`trial by jury in this action of all issues triable by jury in this matter.
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`Dated: October 11, 2019
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`Respectfully submitted,
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`/s/ Elizabeth A. Alquist______
`Elizabeth A. Alquist (ct15643)
`Woo Sin Sean Park (ct30074)
`Day Pitney LLP
`242 Trumbull Street
`Hartford, CT 06103-1212
`Phone (860) 275-0100
`Fax (860) 275-0343
`eaalquist@daypitney.com
`wpark@daypitney.com
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`Attorneys for Plaintiffs
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`LEGO A/S, LEGO SYSTEMS, INC., and
`LEGO JURIS A/S
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