Case 1:20-cv-12338-RMB-JS Document 1 Filed 09/04/20 Page 1 of 14 PageID: 1
`
`ARCHER & GREINER
`A Professional Corporation
`One Centennial Square
`Haddonfield, NJ 08033-0968
`(856) 795-2121
`Attorneys for Plaintiff,
`LaMonica Fine Foods, LLC.
`BY: TREVOR J. COONEY, ESQUIRE
`KATE A. SHERLOCK, ESQUIRE
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF NEW JERSEY
`CAMDEN VICINAGE
`
`LAMONICA FINE FOODS, LLC,
`
`
`
`Plaintiff,
`
`v.
`
`ATLANTIC CAPES FISHERIES, INC. and
`CAPE MAY SALT OYSTER COMPANY,
`LLC,
`
`Defendants.
`
`Civil Action No. __________________
`
`Electronically Filed
`
`COMPLAINT
`
`LaMonica Fine Foods, LLC (“Plaintiff” or “LaMonica”), by way of Complaint against
`
`Defendant Atlantic Capes Fisheries, Inc. (“Atlantic”), and Cape May Salt Oyster Company, LLC
`
`(“CMSOC”) (each “a Defendant” and together, the “Defendants”) alleges as follows:
`
`THE PARTIES
`
`1.
`
`LaMonica is a limited liability company organized and existing under the laws of
`
`the State of New Jersey, with its principal place of business at 48 Gorton Road, Millville, New
`
`Jersey 08332.
`
`
`
`ARCHER & GREINER
`A Professional Corporation
`One Centennial Square
`Haddonfield, NJ 08033-0968
`(856) 795-2121
`Attorneys for Plaintiff,
`LaMonica Fine Foods, LLC.
`BY: TREVOR J. COONEY, ESQUIRE
`KATE A. SHERLOCK, ESQUIRE
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF NEW JERSEY
`CAMDEN VICINAGE
`
`LAMONICA FINE FOODS, LLC,
`
`
`
`Plaintiff,
`
`v.
`
`ATLANTIC CAPES FISHERIES, INC. and
`CAPE MAY SALT OYSTER COMPANY,
`LLC,
`
`Defendants.
`
`Civil Action No. __________________
`
`Electronically Filed
`
`COMPLAINT
`
`LaMonica Fine Foods, LLC (“Plaintiff” or “LaMonica”), by way of Complaint against
`
`Defendant Atlantic Capes Fisheries, Inc. (“Atlantic”), and Cape May Salt Oyster Company, LLC
`
`(“CMSOC”) (each “a Defendant” and together, the “Defendants”) alleges as follows:
`
`THE PARTIES
`
`1.
`
`LaMonica is a limited liability company organized and existing under the laws of
`
`the State of New Jersey, with its principal place of business at 48 Gorton Road, Millville, New
`
`Jersey 08332.
`
`
`
`Case 1:20-cv-12338-RMB-JS Document 1 Filed 09/04/20 Page 2 of 14 PageID: 2
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`2.
`
`Atlantic Capes Fisheries, Inc. is a corporation organized and existing under the
`
`laws of the State of New Jersey, with its principal place of business at 985 Ocean Drive, Cape
`
`May, New Jersey 08204.
`
`3.
`
`Cape May Salt Oyster Company, LLC is a limited liability company organized
`
`and existing under the laws of the State of New Jersey, with its principal place of business at 985
`
`Ocean Drive, Cape May, New Jersey 08204.
`
`JURISDICTION AND VENUE
`
`4.
`
`This Court has jurisdiction over this matter pursuant to 28 U.S.C. § 1331 because
`
`claims asserted herein arise under the Lanham Act, 15 U.S.C. §§ 1114, 1125, and this Court
`
`exercises original jurisdiction pursuant to 15 U.S.C. §§ 1117, 1125(a), and 28 U.S.C. § 1338(a).
`
`This Court also exercises supplemental jurisdiction over Plaintiff’s pendant state law claims
`
`pursuant to 28 U.S.C. § 1367.
`
`5.
`
`This Court has personal jurisdiction over Defendants because Defendants transact
`
`business within New Jersey, derive substantial revenue from intrastate and interstate commerce,
`
`and have engaged in conduct that has significantly and adversely affected the interests of
`
`LaMonica, a corporation with its principal place of business in New Jersey. Defendants
`
`knowingly and in bad faith engaged in the acts and conduct set forth herein, including breaching
`
`a settlement agreement with LaMonica and advertising and selling products under the infringing
`
`mark at issue in this action, with the reasonable expectation that such products would be
`
`advertised and sold in the State of New Jersey. Defendants have also consented to personal
`
`jurisdiction in this Court.
`
`2
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`Case 1:20-cv-12338-RMB-JS Document 1 Filed 09/04/20 Page 3 of 14 PageID: 3
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`6.
`
`Venue is proper before this Court pursuant to 28 U.S.C. § 1391(a) and (c) because
`
`Defendants are subject to personal jurisdiction in this District. Venue is also proper in this
`
`District pursuant to 28 U.S.C. § 1391(b) because both Plaintiff’s and Defendants’ principal
`
`places of business are located in this District and a substantial part of the events giving rise to
`
`these claims occurred in this District.
`
`FACTUAL ALLEGATIONS
`
`Introduction
`
`This is not the Parties’ first litigation regarding Plaintiff’s CAPE MAY trademark and
`
`Plaintiff’s corresponding incontestable federal trademark registration for the mark CAPE MAY.
`
`In 2018, Plaintiff was forced to file a federal lawsuit against Defendant CMSOC, a subsidiary or
`
`affiliate of Atlantic, to protect its trademark rights in the mark CAPE MAY. After two years of
`
`litigation, the Parties entered into a settlement agreement that Defendants have completely
`
`disregarded, forcing Plaintiff to once again expend substantial amounts of time and money to
`
`protect its valuable rights and substantial goodwill in the CAPE MAY trademark.
`
`LaMonica’s CAPE MAY Trademark
`
`1.
`
`LaMonica is a family-owned seafood business located in Millville, New Jersey,
`
`operated by brothers Daniel LaVecchia and Michael LaVecchia.
`
`2.
`
`LaMonica owns and operates the largest hand-shucking plant in New Jersey with
`
`more than 200 employees and a state-of-the-art seafood packing facility.
`
`3.
`
`4.
`
`The LaVecchias also own a company called Cape May Foods, Inc.
`
`In 1992, Cape May Foods, Inc. began using the trademark CAPE MAY (the
`
`“CAPE MAY Mark”) in commerce to identify its goods.
`
`3
`
`
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`Case 1:20-cv-12338-RMB-JS Document 1 Filed 09/04/20 Page 4 of 14 PageID: 4
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`5.
`
`On September 27, 2000, Cape May Foods, Inc. applied to register the CAPE
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`MAY Mark with the United States Patent and Trademark Office (the “PTO”). On May 13, 2003,
`
`the PTO approved the application and issued a Certificate of Registration under Registration
`
`Number 2714953. A copy of the registration certificate is attached as Exhibit 1.
`
`6.
`
`On December 31, 2009, Cape May Foods, Inc. assigned its entire interest and
`
`goodwill in the CAPE MAY Mark to LaMonica.
`
`7.
`
`Since that time, LaMonica has continued to sell fresh, frozen, and canned clam
`
`and seafood products using the CAPE MAY Mark.
`
`8.
`
`On October 26, 2017, LaMonica filed a Declaration of Incontestability with the
`
`PTO pursuant to 15 U.S.C. § 1065 for its registration for the CAPE MAY Mark.
`
`9.
`
`On November 24, 2017, the PTO acknowledged LaMonica’s Section 15
`
`declaration, making LaMonica’s CAPE MAY registration incontestable.
`
`Defendants’ Unauthorized Activities
`
`10.
`
`Defendants sell farm-raised oysters from the Delaware Bay that Defendants call
`
`“Cape May Salts.”
`
`11.
`
`In or around 2014, the president of Atlantic, Daniel Cohen, contacted LaMonica
`
`seeking a license to use LaMonica’s CAPE MAY Mark.
`
`12. Mr. LaVecchia and Mr. Cohen were unable to agree on licensing terms and did
`
`not enter into a licensing agreement.
`
`13.
`
`Despite the lack of a license to do so, Mr. Cohen formed a new limited liability
`
`company and incorporated the CAPE MAY Mark into his new company name, Cape May Salt
`
`Oyster Company, LLC.
`
`4
`
`
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`Case 1:20-cv-12338-RMB-JS Document 1 Filed 09/04/20 Page 5 of 14 PageID: 5
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`14. Mr. Cohen also incorporated the CAPE MAY Mark into the CMSOC website at
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`the domain www.capemaysalts.com.
`
`15.
`
`At www.capemaysalts.com, CMSOC sold oysters and merchandise, including but
`
`not limited to, “Cape May Salt” oysters, “Elder Point” oysters, and apparel displaying the words
`
`“Cape May Salt Oyster Company.”
`
`16.
`
`In or around September 2017, LaMonica became aware of CMSOC’s existence
`
`and its use of the CAPE MAY Mark in its company name and domain.
`
`17.
`
`In or around October 2017, Daniel LaVecchia contacted Mr. Cohen and instructed
`
`him to cease using LaMonica’s CAPE MAY Mark.
`
`18.
`
`19.
`
`Defendant refused to comply with Mr. LaVecchia’s request.
`
`On January 23, 2018, LaMonica’s counsel sent a cease and desist letter to counsel
`
`for CMSOC regarding Defendant’s unauthorized use of LaMonica’s CAPE MAY Mark.
`
`20.
`
`21.
`
`CMSOC never responded to the January 23, 2018 cease and desist letter.
`
`On February 22, 2018, LaMonica filed a complaint in the U.S. District Court for
`
`the District of New Jersey against CMSOC, Civil Action No. 18-cv-02515, alleging claims of
`
`trademark infringement (15 U.S.C. §1114(1)), false designation of origin and false description
`
`(15 U.S.C. §1125(a)(1)(A)), cybersquatting, common law unfair competition, and New Jersey
`
`statutory unfair competition at N.J.S.A. 56:4-1 (the “2018 Litigation”).
`
`22.
`
`On May 23, 2019, LaMonica and CMSOC participated in a settlement conference
`
`with the Honorable Joel Schneider, U.S.M.J, during which a settlement was reached in principle.
`
`5
`
`
`
`Case 1:20-cv-12338-RMB-JS Document 1 Filed 09/04/20 Page 6 of 14 PageID: 6
`
`23.
`
`The Parties later memorialized their settlement in an agreement dated October 14,
`
`2019 (the “Settlement”). A true and accurate copy of the Settlement is attached hereto as Exhibit
`
`2.1
`
`24.
`
`25.
`
`26.
`
`27.
`
`28.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Cape May Salts are just one type of oyster sold by CMSOC.
`
`
`
`
`
`29.
`
`On November 6, 2019, the 2018 Litigation was dismissed with prejudice.
`
`1 The Settlement is subject to confidentiality provisions that prevent Plaintiff from attaching an unredacted copy to
`this Complaint. Plaintiff is contemporaneously filing a motion to file an unredacted copy of this Complaint and the
`Settlement under seal.
`
`6
`
`
`
`Case 1:20-cv-12338-RMB-JS Document 1 Filed 09/04/20 Page 7 of 14 PageID: 7
`
`30.
`
`Despite the promises it made to LaMonica as part of the Settlement, CMSOC and
`
`Atlantic continued to use the CAPE MAY Mark by adopting the new business name “Cape May
`
`Salt Oyster Farms.”
`
`31.
`
`Defendants have also continued to use the CAPE MAY Mark in their domain
`
`name, by operating a website at https://capemaysaltoysterfarms.com.
`
`32.
`
`On information and belief, Defendants have not formally dissolved, terminated, or
`
`canceled the legal entity Cape May Salt Oyster Company, LLC.
`
`33.
`
`On or around May 5, 2020, LaMonica notified Defendants of their breach of the
`
`Settlement and demanded that Defendants remove all infringing references to CAPE MAY
`
`within ten business days from the date of the letter and cease and desist from infringing
`
`LaMonica’s CAPE MAY Mark.
`
`34.
`
`As of September 4, 2020, Defendants are still breaching the Settlement and
`
`infringing LaMonica’s CAPE MAY Mark.
`
`FIRST CAUSE OF ACTION
`Breach of Contract
`
`35.
`
` LaMonica repeats and realleges the allegations contained in prior paragraphs as if
`
`fully set forth herein.
`
`36.
`
`LaMonica and Defendants entered into a Settlement that prohibited Defendants
`
`from using LaMonica’s CAPE MAY Mark as a trademark or source indicator for its seafood and
`
`shellfish products, except as expressly permitted under the Settlement.
`
`37.
`
`LaMonica and Defendants exchanged consideration in exchange for the promises
`
`set forth in the Settlement.
`
`38.
`
`LaMonica relied on CMSOC’s promises within the Settlement when it filed a
`
`stipulation to dismiss the 2018 Litigation.
`
`7
`
`
`
`Case 1:20-cv-12338-RMB-JS Document 1 Filed 09/04/20 Page 8 of 14 PageID: 8
`
`39.
`
`Defendants have materially breached and continue to materially breach the
`
`Settlement by operating as Cape May Salt Oyster Farms, LLC and utilizing the domain
`
`www.capemaysaltoysterfarms.com.
`
`40.
`
`LaMonica has suffered irreparable injury and continues to suffer irreparable
`
`injury as a result of Defendants’ breach.
`
`41.
`
`
`
`
`
`
`
`
`
`
`
`SECOND CAUSE OF ACTION
`Breach of the Implied Covenant of Good Faith and Fair Dealing
`
`42.
`
`LaMonica repeats and realleges the allegations contained in prior paragraphs as if
`
`fully set forth herein.
`
`43.
`
`LaMonica and Defendants entered into a Settlement that prohibited Defendants
`
`from using LaMonica’s CAPE MAY Mark as a trademark or source indicator for its seafood and
`
`shellfish products, except as expressly permitted under the Settlement.
`
`44.
`
`LaMonica and Defendants exchanged consideration in exchange for the promises
`
`set forth in the Settlement.
`
`45.
`
`LaMonica relied on CMSOC’s promises within the Settlement when it filed a
`
`stipulation to dismiss the 2018 Litigation.
`
`46.
`
`47.
`
`Defendants never complied with their obligations in the Settlement.
`
`Defendants acted in bad faith when they entered into the Settlement without ever
`
`intending to comply with their obligations.
`
`8
`
`
`
`Case 1:20-cv-12338-RMB-JS Document 1 Filed 09/04/20 Page 9 of 14 PageID: 9
`
`48.
`
`LaMonica is suffering damage as a result of the acts of Defendants as aforesaid in
`
`an amount thus far not determined.
`
`THIRD CAUSE OF ACTION
`Trademark Infringement
`15 U.S.C. §1114(1)
`
`49.
`
`LaMonica repeats and realleges the allegations contained in prior paragraphs as if
`
`fully set forth herein.
`
`50.
`
`LaMonica’s registration for the CAPE MAY Mark is in full force and effect, and
`
`the trademark thereof and the goodwill of LaMonica’s business in connection with which its
`
`trademark is used has never been abandoned.
`
`51.
`
`52.
`
`LaMonica’s registration for the CAPE MAY Mark is incontestable.
`
`LaMonica intends to continue to preserve and maintain its rights with respect to
`
`its trademark registration for the CAPE MAY Mark.
`
`53.
`
`LaMonica’s CAPE MAY Mark and the goodwill associated therewith are of
`
`inestimable value to LaMonica.
`
`54.
`
`Upon information and belief, Defendants commenced and continued their
`
`unauthorized use of the CAPE MAY Mark with full knowledge of and by reason of the fact that
`
`the CAPE MAY Mark is highly valuable.
`
`55.
`
`Defendants’ use of the CAPE MAY Mark has been without the consent of the
`
`LaMonica.
`
`56.
`
`The activities of Defendants complained of herein constitute willful and
`
`intentional infringement of the CAPE MAY Mark as protected by the respective registration set
`
`forth above. Defendants have acted in complete disregard of LaMonica’s rights and in spite of
`
`Defendants’ knowledge that their unauthorized use of the CAPE MAY Mark or any mark likely
`
`to be confused therewith infringes LaMonica’s rights.
`9
`
`
`
`Case 1:20-cv-12338-RMB-JS Document 1 Filed 09/04/20 Page 10 of 14 PageID: 10
`
`57.
`
`Defendants’ infringement of the CAPE MAY Mark is likely to cause confusion
`
`and mistake in the minds of the purchasing public.
`
`58.
`
`Defendants’ infringement of the CAPE MAY Mark tends to and does falsely
`
`create the impression that the products sold by Defendants are authorized, sponsored, or
`
`approved by LaMonica.
`
`59.
`
`Alternatively, or in addition to the foregoing, Defendants’ infringement of the
`
`CAPE MAY Mark is likely to cause reverse confusion, tending to and falsely creating the
`
`impression that the products sold by LaMonica are either authorized, sponsored, or approved by
`
`Defendants or the false impression that LaMonica is infringing on the rights of Defendants.
`
`60.
`
`LaMonica is suffering damage as a result of the acts of Defendants as aforesaid in
`
`an amount thus far not determined.
`
`FOURTH CAUSE OF ACTION
`False Designation of Origin and False Description
`15 U.S.C. §1125(a)(1)(A)
`
`61.
`
`LaMonica repeats and realleges the allegations contained in prior paragraphs as if
`
`fully set forth herein.
`
`62.
`
`Upon information and belief, Defendants have used in connection with the sale of
`
`its products, false designations of origin and false descriptions and representations that tend
`
`falsely to describe or represent their products.
`
`63.
`
`Upon information and belief, Defendants have caused the aforementioned
`
`products to enter into commerce with full knowledge of the falsity of such designations of origin
`
`and such descriptions and representations, all to the detriment of LaMonica.
`
`10
`
`
`
`Case 1:20-cv-12338-RMB-JS Document 1 Filed 09/04/20 Page 11 of 14 PageID: 11
`
`64.
`
`Defendants’ use of the CAPE MAY Mark constitutes the use of false designations
`
`of origin and false descriptions and representations tending falsely to describe or represent goods
`
`sold by Defendants.
`
`65.
`
`Upon information and belief, Defendants have distributed, offered for sale or sold
`
`its products by using the CAPE MAY Mark with the express intent to cause confusion and
`
`mistake, to deceive and mislead the purchasing public, to trade upon the reputation of LaMonica,
`
`and improperly to appropriate the valuable trademark rights of LaMonica.
`
`66.
`
`Alternatively, or in addition to the foregoing, Defendants’ conduct causes reverse
`
`confusion, tending to and falsely creating the impression that the products sold by LaMonica are
`
`either authorized, sponsored, or approved by Defendants or the false impression that LaMonica
`
`is infringing on the rights of Defendants.
`
`67.
`
`LaMonica is suffering damage as a result of the acts of Defendants as aforesaid in
`
`an amount thus far not determined.
`
`FIFTH CAUSE OF ACTION
`Common Law Unfair Competition
`
`68.
`
`LaMonica repeats and realleges the allegations contained in prior paragraphs as if
`
`fully set forth herein.
`
`69.
`
`Upon information and belief, Defendants have intentionally and with bad faith
`
`appropriated the CAPE MAY Mark with the intent of causing confusion, mistake, and deception
`
`as to the source of its goods or to otherwise wrongfully benefit from the infringement of
`
`LaMonica’s rights without due compensation.
`
`70.
`
`Upon information belief, Defendants have acted with the intent to palm off its
`
`goods as those of LaMonica, or to otherwise deceive the public. Such acts amount to trademark
`
`infringement, unfair competition, and wrongful misappropriation under the common law.
`11
`
`
`
`Case 1:20-cv-12338-RMB-JS Document 1 Filed 09/04/20 Page 12 of 14 PageID: 12
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`71.
`
`LaMonica is suffering damage as a result of the acts of Defendants as aforesaid in
`
`an amount thus far not determined.
`
`SIXTH CAUSE OF ACTION
`New Jersey Statutory Unfair Competition at N.J.S.A. 56:4-1
`
`72.
`
`LaMonica repeats and realleges the allegations contained in prior paragraphs as if
`
`fully set forth herein.
`
`73.
`
`Upon information and belief, Defendants have intentionally and with bad faith
`
`appropriated the CAPE MAY Mark with the intent of causing confusion, mistake, and deception
`
`as to the source of its goods or to otherwise wrongfully benefit from the infringement of
`
`LaMonica’s rights without due compensation.
`
`74.
`
`Upon information belief, Defendants have acted with the intent to palm off their
`
`goods as those of LaMonica, or to otherwise deceive the public. Such acts amount to trademark
`
`infringement and unfair competition in violation of N.J.S.A. 56:4-1.
`
`75.
`
`LaMonica is suffering damage as a result of the acts of Defendants as aforesaid in
`
`an amount thus far not determined.
`
`WHEREFORE, LaMonica demands judgment against Defendants as follows:
`
`1)
`
`2)
`
`3)
`
`4)
`
`For an Order requiring Defendants to comply with the terms of the Settlement
`Agreement;
`
`For actual damages suffered by LaMonica and for disgorgement of Defendants’
`profits as a result of Defendants’ actions described herein;
`
`For attorney’s fees, interest, and costs of suit;
`
`For an order barring Defendants and Defendants’ affiliates, subsidiaries, partners,
`joint venturers, parent companies, successors and assigns, and Defendants’
`officers, agents, servants, employees and attorneys, and all others in active
`concert or participation with Defendants who receive actual notice of the order by
`personal service or otherwise, from:
`
`12
`
`
`
`Case 1:20-cv-12338-RMB-JS Document 1 Filed 09/04/20 Page 13 of 14 PageID: 13
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`a)
`
`b)
`
`c)
`
`Using the CAPE MAY Mark, or any confusingly similar variation thereof,
`as a trademark or service mark, or in Defendants’ business name or trade
`name;
`
`Using the CAPE MAY Mark, or any confusingly similar variation thereof
`in Defendants’ website domain(s); and
`
`Using the CAPE MAY Mark, or any confusingly similar variation thereof
`in Defendants’ advertising that would cause a likelihood of confusion as to
`sponsorship, affiliation, or association between LaMonica and Defendants.
`
`5)
`
`For an order requiring Defendants, Defendants’ affiliates, subsidiaries, partners,
`joint venturers, parent companies, successors and assigns, and Defendants’
`officers, agents, servants, employees and attorneys, to deliver to LaMonica for
`destruction all labels, stickers, signs, prints, packages, wrappers, receptacles,
`advertisements, apparel, merchandise and other written or printed material in their
`possession, custody or control that bear the CAPE MAY Mark, alone or in
`combination with any other words, marks or other elements.
`
`6)
`
`Such other and further relief as the Court may deem just and equitable.
`
`13
`
`
`
`Case 1:20-cv-12338-RMB-JS Document 1 Filed 09/04/20 Page 14 of 14 PageID: 14
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`JURY DEMAND
`
`LaMonica demands trial by jury on all issues amenable thereto.
`
`ARCHER & GREINER
`A Professional Corporation
`One Centennial Square
`P.O. Box 3000
`(856) 795-2121
`Attorneys for Plaintiff,
`LaMonica Fine Foods, LLC
`
`By: /s/ Kate A. Sherlock
` Kate A. Sherlock, Esq.
` Trevor J. Cooney, Esq.
`
`Dated: September 4, 2020.
`
`218973327v3
`
`14
`
`
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