Case 1:20-cv-04029 Document 1 Filed 05/26/20 Page 1 of 16
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`
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`Plaintiff,
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`
`
`v.
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`
`Defendants.
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`
`
`
`
`
`
`Civ. Action No. 1:20-cv-4029
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`COMPLAINT
`
`
`JURY TRIAL DEMANDED
`
`UNITED STATES DISTRICT COURT FOR THE
`SOUTHERN DISTRICT OF NEW YORK
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`Plymouth Beef Co., Inc.
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`
`
`
`
`Wonder Food Distributors, David Hamedan, Jack
`Hamedan, Nations Best Meat Wholesalers, Inc.,
`James Hyland and Guy Robinson,
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`
`
`
`
`
`
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`Plaintiff Plymouth Beef Co., Inc. (“Plaintiff”), by and through its attorneys, Foley &
`
`Lardner LLP, as and for its Complaint against defendants Wonder Food Distributors, David
`
`Hamedan, Jack Hamedan, Nations Best Meat Wholesalers, Inc., James Hyland and Guy
`
`Robinson (“Defendants”), alleges as follows:
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`PRELIMINARY STATEMENT
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`1.
`
`This is an action for infringement of Plaintiff’s trademark PLYMOUTH and its
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`federally-registered trademark, PLYMOUTH and Design, and the distinctive package design (or
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`trade dress) of Plaintiff’s ground beef products, arising under Section 32(1) of the Lanham Act,
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`15 U.S.C. § 1114(1); for unfair competition and false designation of origin under Section 43(a)
`
`of the Lanham Act, 15 U.S.C. § 1125(a), for substantially related claims of trademark
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`infringement and unfair competition under the statutory and common law of the State of New
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`York, and for tortious interference with economic relations, all arising from the Defendants’ use
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`of the identical name PLYMOUTH and a package design copying Plaintiff’s package design and
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`4839-0181-1644.1
`
`
`
`
`
`Plaintiff,
`
`
`
`v.
`
`
`
`Defendants.
`
`
`
`
`
`
`
`Civ. Action No. 1:20-cv-4029
`
`COMPLAINT
`
`
`JURY TRIAL DEMANDED
`
`UNITED STATES DISTRICT COURT FOR THE
`SOUTHERN DISTRICT OF NEW YORK
`
`Plymouth Beef Co., Inc.
`
`
`
`
`
`Wonder Food Distributors, David Hamedan, Jack
`Hamedan, Nations Best Meat Wholesalers, Inc.,
`James Hyland and Guy Robinson,
`
`
`
`
`
`
`
`
`Plaintiff Plymouth Beef Co., Inc. (“Plaintiff”), by and through its attorneys, Foley &
`
`Lardner LLP, as and for its Complaint against defendants Wonder Food Distributors, David
`
`Hamedan, Jack Hamedan, Nations Best Meat Wholesalers, Inc., James Hyland and Guy
`
`Robinson (“Defendants”), alleges as follows:
`
`PRELIMINARY STATEMENT
`
`1.
`
`This is an action for infringement of Plaintiff’s trademark PLYMOUTH and its
`
`federally-registered trademark, PLYMOUTH and Design, and the distinctive package design (or
`
`trade dress) of Plaintiff’s ground beef products, arising under Section 32(1) of the Lanham Act,
`
`15 U.S.C. § 1114(1); for unfair competition and false designation of origin under Section 43(a)
`
`of the Lanham Act, 15 U.S.C. § 1125(a), for substantially related claims of trademark
`
`infringement and unfair competition under the statutory and common law of the State of New
`
`York, and for tortious interference with economic relations, all arising from the Defendants’ use
`
`of the identical name PLYMOUTH and a package design copying Plaintiff’s package design and
`
`4839-0181-1644.1
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`
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`Case 1:20-cv-04029 Document 1 Filed 05/26/20 Page 2 of 16
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`associated trade dress, in connection with the production, distribution, marketing, advertising,
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`promotion, offering for sale, and/or sale of Defendants’ ground beef products.
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`PARTIES
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`2.
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`Plaintiff Plymouth Beef Co., Inc. (“Plymouth”) is a New York corporation with a
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`principal place of business at 355 Food Center Drive, Bronx New York 10474.
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`3.
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`Upon information and belief, Defendant Wonder Food Distributors (“Wonder”) is
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`an unincorporated business operating from a principal place of business at 5710 Flushing Ave,
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`Maspeth, NY 11378.
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`4.
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`Upon information and belief, Defendant David Hamedan is a principal owner of
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`Wonder, with an address c/o Wonder, and together with Defendant Jack Hamedan, was
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`responsible for the conduct of Wonder complained of herein.
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`5.
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`Upon information and belief, Defendant Jack Hamedan is a principal owner of
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`Wonder, with an address c/o Wonder, and together with Defendant David Hamedan, was
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`responsible for the conduct of Wonder complained of herein.
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`6.
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`Upon information and belief, Defendant Nations Best Meat Wholesalers, Inc.
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`(“Nation’s Best”) is a New York corporation having a principal place of business at D-7 Hunts
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`Point Cooperative, The Bronx, NY 10474.
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`7.
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`Upon information and belief, Defendant James Hyland (“Hyland”) is a principal
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`owner of Nation’s Best, with an address c/o Nation’s Best, and together with Defendant Guy
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`Robinson, was responsible for the conduct of Nation’s Best complained of herein.
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`4839-0181-1644.1
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`2
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`Case 1:20-cv-04029 Document 1 Filed 05/26/20 Page 3 of 16
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`8.
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`Upon information and belief, Defendant Guy Robinson (“Robinson”) is a
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`principal owner of Nation’s Best, with an address c/o Nation’s Best, and together with Defendant
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`James Hyland, was responsible for the conduct of Nation’s Best complained of herein.
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`JURISTICTION AND VENUE
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`9.
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`This court has subject matter jurisdiction over this action pursuant to 15 U.S.C. §
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`1121, 28 U.S.C. §§ 1331, and 1338(a) and (b), and pursuant to the principles of supplemental
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`jurisdiction under 28 U.S.C. § 1367, because this case arises under the Federal Trademark Act,
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`as amended, 15 U.S.C. §§ 1051, et seq., and because the state law claims are so related to the
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`federal claims that they form part of the same case or controversy.
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`10.
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`This Court has personal jurisdiction over Defendants under New York Civil
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`Practice Law and Rules §§ 301 and/or 302(a) because Defendants’ place of incorporation and
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`principal place of business is New York and because Defendants have transacted business in
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`New York and have supplied or offered to supply goods in New York in connection with matters
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`giving rise to this suit.
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`11.
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`Venue is proper in this district under 28 U.S.C. § 1391(b)(2), in that a substantial
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`part of the events or omissions giving rise to the claim occurred in this district.
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`BACKGROUND OF PLAINTIFF AND THE TRADEMARKS AT ISSUE
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`12.
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`For over fifty years, Plymouth has been distributing, offering for sale, and selling
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`high quality, USDA-certified ground beef and burger patties in the United States under the name
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`PLYMOUTH or PLYMOUTH BEEF.
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`4839-0181-1644.1
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`3
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`Case 1:20-cv-04029 Document 1 Filed 05/26/20 Page 4 of 16
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`13.
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`Plymouth Beef is the owner of United States Registration Number 2,057,070 for
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`the mark PLYMOUTH BEEF CO. and Design as follows, for “meat,” claiming using since at
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`least as early as 1963, and said registration has become incontestable within the meaning of
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`Section 15 of the Lanham Act, 15 U.S.C. § 1065.
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`As a result of its widespread, continuous, and exclusive use of the name
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`14.
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`PLYMOUTH to identify its goods and Plymouth as their source, Plymouth owns valid and
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`subsisting rights to the PLYMOUTH trademark, alone and in combination with other elements,
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`since long prior to the acts of Defendants complained of herein.
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`15.
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`For at least twenty years, Plymouth has been selling high quality, USDA-certified
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`ground beef and burger patties in the United States in distinctive red, white and blue packaging
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`(the “PLYMOUTH Trade Dress”) as follows:
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`4839-0181-1644.1
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`4
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`Case 1:20-cv-04029 Document 1 Filed 05/26/20 Page 5 of 16
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`As marketed at retail, the product is usually stacked in refrigerator cases as
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`16.
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`follows, with the side label facing the consumer:
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`4839-0181-1644.1
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`5
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`Case 1:20-cv-04029 Document 1 Filed 05/26/20 Page 6 of 16
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`17.
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`As a result of its widespread, continuous, and exclusive use of the PLYMOUTH
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`Trade Dress to identify its goods, Plymouth owns valid and subsisting rights to the PLYMOUTH
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`Trade Dress since long prior to the acts of Defendants complained of herein.
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`18.
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`The distinctive design of the PLYMOUTH Trade Dress has no inherent meaning,
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`and the PLYMOUTH Trade Dress is therefore inherently distinctive in identifying Plymouth’s
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`products.
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`19.
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`Plaintiff’s ground beef products sold under the PLYMOUTH trademark and
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`PLYMOUTH Trade Dress have been enormously successful, generating sales annually of
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`approximately $15 million or more.
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`DEFENDANTS’ UNLAWFUL ACTIVITIES
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`20.
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`Upon information and belief, Defendant Wonder is owned and operated by
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`Defendants David and Jack Hamedan and other family members.
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`21.
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`Upon information and belief, Defendants are engaged in the distribution, offering
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`for sale, and selling of meat, including ground beef and burger patties.
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`22.
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`Upon information and belief, Defendants David and Jack Hamedan directed and
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`were responsible for the conduct of Wonder complained of herein.
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`23.
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`Upon information and belief, Defendant Nation’s Best is engaged in the
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`producing and offering for sale various meat and meat products, including ground beef and
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`burger patties.
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`4839-0181-1644.1
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`6
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`Case 1:20-cv-04029 Document 1 Filed 05/26/20 Page 7 of 16
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`24.
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`Upon information Defendants Hyland and Robinson are owners of Defendant
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`Nation’s Best and directed and were responsible for the conduct of Wonder complained of
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`herein.
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`25. Without Plymouth’s authorization, and beginning long after Plymouth acquired
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`protectable and exclusive rights in its PLYMOUTH Trademark and PLYMOUTH Trade Dress
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`Defendants commenced the production, distribution, advertising, promotion, offering for sale,
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`and sale of their ground beef and burger patties in a trade dress that closely approximates
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`Plaintiff’s package design, as follows, which it has specifically identified to customers using
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`Plaintiff’s name PLYMOUTH:
`
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`Increasing the likelihood of confusion caused by Defendants’ copying of the
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`26.
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`PLYMOUTH Trade Dress is the fact that the products are placed on sale with only the side
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`facing out to the consumer, as follows:
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`4839-0181-1644.1
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`7
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`Case 1:20-cv-04029 Document 1 Filed 05/26/20 Page 8 of 16
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`On information and belief, because Defendants have promoted their accused
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`27.
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`product to customers by identifying it under the name PLYMOUTH, those retail customers
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`identify Defendants’ accused product in retail displays under the name PLYMOUTH, which
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`name appears on the green stickers this retailer used to identify the accused products.
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`28.
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`Not only have retailers carrying the accused products displayed them under the
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`name PLYMOUTH, as shown above, but such retailers have also specifically invoiced the
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`infringing product to customers under the name PLYMOUTH.
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`29.
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`Such conduct of promoting Defendants’ accused product under the name
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`PLYMOUTH constitutes passing off.
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`4839-0181-1644.1
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`8
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`Case 1:20-cv-04029 Document 1 Filed 05/26/20 Page 9 of 16
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`30.
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`Defendants Wonder and Jack and David Hamedan commenced their unlawful
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`conduct after repeatedly requesting from Plymouth permission to distribute its PLYMOUTH
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`hamburger meat in its distinctive red, white and blue packaging, which requests Plymouth
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`consistently declined.
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`31.
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`Upon information and belief, Defendants had actual knowledge of the
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`PLYMOUTH Trademark PLYMOUTH Trade Dress and adopted the infringing package design
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`and use of the PLYMOUTH trademark with a specific intent to trade upon the reputation of and
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`goodwill in Plymouth’s name and mark and trade dress.
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`32.
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`Defendants’ conduct as aforesaid is likely to cause confusion among consumers
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`and to mislead as to the source and quality of their products, is likely to deceive the relevant
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`consuming public into believing, mistakenly, that Defendants’ goods originate from, are
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`associated or affiliated with, or otherwise authorized by Plymouth, and divert potential sales of
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`Plymouth’s goods to the Defendants.
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`33.
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`Defendants have used the accused products as a means to establish relationships
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`with Plaintiff’s customers and to continue to make sales derived from such initial infringing
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`conduct at the expense of Plaintiff.
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`34.
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`Defendants’ acts have caused, and unless restrained, will continue to cause
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`damage and immediate irreparable harm to Plymouth and to its valuable reputation and goodwill
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`with the consuming public for which Plymouth has no adequate remedy at law.
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`4839-0181-1644.1
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`9
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`Case 1:20-cv-04029 Document 1 Filed 05/26/20 Page 10 of 16
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`COUNT I
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`Federal Trademark Infringement Under 15 U.S.C. § 1114(1)
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`35.
`
`Plaintiff repeats, realleges, and incorporates by reference paragraphs 1 through 34
`
`hereof, as though fully set forth herein.
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`36.
`
`Defendants’ unauthorized use in commerce of the name PLYMOUTH as alleged
`
`herein has been and is likely to deceive consumers as to the origin, source, sponsorship, or
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`affiliation of Defendants’ goods, has caused and is likely to cause consumers to believe, contrary
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`to fact, that Defendants’ goods are sold, authorized, endorsed, or sponsored by Plymouth, or that
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`Defendants are in some way affiliated with or sponsored by Plymouth. Defendants’ conduct
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`therefore constitutes trademark infringement in violation of Section 32(1) of the Lanham Act, 15
`
`U.S.C. § 1114(1).
`
`37.
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`Upon information and belief, Defendants have committed the foregoing acts of
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`infringement with full knowledge of Plymouth’s prior rights in the PLYMOUTH trademark and
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`with the willful intent to cause confusion and trade on Plymouth’s goodwill.
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`38.
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`Defendants’ conduct is causing immediate and irreparable harm and injury to
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`Plaintiff and its distributors, and to Plainitff’s goodwill and reputation, and will continue to both
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`damage Plymouth and confuse the public unless enjoined by this court. Plymouth has no
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`adequate remedy at law.
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`39.
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`Plymouth is entitled to, among other relief, injunctive relief and an award of
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`actual damages, Defendants’ profits, enhanced damages and profits, reasonable attorneys’ fees,
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`and costs of the action under Sections 34 and 35 of the Lanham Act, 15 U.S.C. §§ 1116, 1117,
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`together with prejudgment and post-judgment interest.
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`4839-0181-1644.1
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`10
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`Case 1:20-cv-04029 Document 1 Filed 05/26/20 Page 11 of 16
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`COUNT II
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`Unfair Competition Under 15 U.S.C. § 1125(a)
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`40.
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`Plaintiff repeats, realleges, and incorporates by reference paragraphs 1 through 39
`
`hereof, as though fully set forth herein.
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`41.
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`Defendants’ unauthorized use in commerce of the name PLYMOUTH and the the
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`accused trade dress as alleged herein has been and is likely to deceive consumers as to the origin,
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`source, sponsorship, or affiliation of Defendants’ goods, and is likely to cause consumers to
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`believe, contrary to fact, that Defendants’ goods are sold, authorized, endorsed, or sponsored by
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`Plymouth, or that Defendants are in some way affiliated with or sponsored by Plymouth.
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`42.
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`Defendants’ unauthorized use in commerce of the name PLYMOUTH and the
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`accused trade dress as alleged herein constitutes use of a false designation of origin.
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`43.
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`Upon information and belief, Defendants’ conduct as alleged herein is willful and
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`is intended to and is likely to cause confusion, mistake, or deception as to the affiliation,
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`connection, or association of Defendants with Plymouth.
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`44.
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`Defendants’ conduct as alleged herein constitutes unfair competition in violation
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`of Section 43(a) of the Lanham Act, 15 U.S.C. § 1125(a).
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`45.
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`Defendants’ conduct as alleged herein is causing immediate and irreparable harm
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`and injury to Plymouth and its distributors, and to Plaintiff’s goodwill and reputation, and will
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`continue to both damage Plymouth and confuse the public unless enjoined by this court. Plaintiff
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`has no adequate remedy at law.
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`4839-0181-1644.1
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`11
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`Case 1:20-cv-04029 Document 1 Filed 05/26/20 Page 12 of 16
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`46.
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`Plymouth is entitled to, among other relief, injunctive relief and an award of
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`actual damages, Defendants’ profits, enhanced damages and profits, reasonable attorneys’ fees,
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`and costs of the action under Sections 34 and 35 of the Lanham Act, 15 U.S.C. §§ 1116, 1117,
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`together with prejudgment and post-judgment interest.
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`COUNT III
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`Deceptive Practices and Acts Under New York GBL § 349
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`47.
`
`Plaintiff repeats, realleges, and incorporates by reference paragraphs 1 through 46
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`hereof, as though fully set forth herein.
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`48.
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`The aforesaid acts of Defendants constitute deceptive acts or practices in the
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`conduct of business, trade, or commerce in New York State in violation of Section 349 of the
`
`New York General Business Law.
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`49.
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`Defendants’ aforesaid conduct has caused, and unless enjoined by this Court, will
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`continue to cause, Plaintiff to sustain irreparable damage, loss, and injury, for which Plaintiff has
`
`no adequate remedy at law.
`
`COUNT V
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`Common Law Trademark Infringement and Unfair Competition
`
`50.
`
`Plaintiff repeats, realleges, and incorporates by reference paragraphs 1 through 49
`
`hereof, as though fully set forth herein.
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`51.
`
`Defendants’ unauthorized use in commerce of the PLYMOUTH trademark and
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`the accused trade dress as alleged herein has been and is likely to confuse and deceive consumers
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`as to the origin, source, sponsorship, or affiliation of Defendants’ goods, and is likely to cause
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`4839-0181-1644.1
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`12
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`Case 1:20-cv-04029 Document 1 Filed 05/26/20 Page 13 of 16
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`consumers to believe, contrary to fact, that Defendants’ goods are sold, authorized, endorsed, or
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`sponsored by Plymouth, or that Defendants are in some way affiliated with or sponsored by
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`Plymouth.
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`52.
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`The aforesaid conduct of the Defendants constitutes the infringement of
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`Plymouth’s common law rights in the PLYMOUTH Trademark and PLYMOUTH Trade Dress
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`and unfair competition in violation of the common law of the State of New York.
`
`53.
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`Defendants’ aforesaid conduct has caused, and unless enjoined by this Court, will
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`continue to cause, Plaintiff to sustain irreparable damage, loss, and injury, for which Plaintiff has
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`no adequate remedy at law.
`
`COUNT VI
`
`Common Law Tortious Interference With Economic Relations
`
`54.
`
`Plaintiff repeats, realleges, and incorporates by reference paragraphs 1 through 53
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`hereof, as though fully set forth herein.
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`55.
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`Plaintiff has long enjoyed successful relationships with its customers throughout
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`the United States and in New York, and is able to enter into relationships with new customers
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`due in no small part to the goodwill that it has accumulated through the years.
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`56.
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`Defendants’ conduct has interfered with Plaintiff’s existing and prospective
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`relationships with customers and constitutes tortious interference with economic relations.
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`57.
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`Defendants knew of Plaintiff, the goodwill it has accumulated with customers,
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`and the existing and prospective relationships Plaintiff has with its customers.
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`4839-0181-1644.1
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`13
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`Case 1:20-cv-04029 Document 1 Filed 05/26/20 Page 14 of 16
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`58.
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`Upon information and belief, Defendants’ deliberate, unfair, and improper use of
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`the PLYMOUTH name and the accused products as a means to establish relationships with
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`Plaintiff’s customers and to take business from Plaintiff’s established customers has been and is
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`intended to interfere with Plaintiff’s existing and potential relationships with such customers.
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`59.
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`Defendants’ tortious interference with Plaintiff’s economic relationships has
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`caused, and unless enjoined by this Court, will continue to cause, Plaintiff to sustain irreparable
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`damage, loss, and injury, for which Plaintiff has no adequate remedy at law.
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`60.
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`As a direct and proximate result of Defendants’ tortious interference with
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`Plaintiff’s economic relationships, Plaintiff has suffered damages in an amount to be proven at
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`trial.
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`PRAYER FOR RELIEF
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`WHEREFORE, Plaintiff requests judgment against Defendants as follows:
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`1.
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`Preliminarily and permanently enjoining Defendants, their employees, agents,
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`officers, directors, attorneys, successors, affiliates, subsidiaries, and assigns, and all of those in
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`active concert and participation with any of the foregoing persons and entities who receive actual
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`notice of the Court’s order by personal service or otherwise from using the name or mark
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`PLYMOUTH or the infringing trade dress, or any other names or marks or trade dress that is
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`likely to cause confusion, to cause mistake or to deceive with respect to the PLYMOUTH
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`trademark or the PLYMOUTH Trade Dress, from otherwise infringing PLYMOUTH trademark
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`or the PLYMOUTH Trade Dress, or from competing unfairly with Plaintiff.
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`2.
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`Preliminarily and permanently enjoining Defendants, their employees, agents,
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`officers, directors, attorneys, successors, affiliates, subsidiaries, and assigns, and all of those in
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`4839-0181-1644.1
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`14
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`Case 1:20-cv-04029 Document 1 Filed 05/26/20 Page 15 of 16
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`active concert and participation with any of the foregoing persons and entities who receive actual
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`notice of the Court’s order by personal service or otherwise from further acts of tortious
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`interference with Plaintiff’s economic relations.
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`3.
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`Awarding Plaintiff all damages to and costs incurred by it because of Defendants’
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`infringing activities and other conduct complained of herein, jointly and severally, in an amount
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`to be determined at trial but believed to be in excess of $10 million, together with all profits of
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`Defendants.
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`4.
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`Awarding Plaintiff an amount up to three times the amount of its actual damages,
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`in accordance with Section 35(a) of the Lanham Act (15 U.S.C. § 1117(a)).
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`5.
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`Awarding Plaintiff punitive and exemplary damages as the court finds appropriate
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`to deter any future willful infringement.
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`6.
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`Declaring that this is an exceptional case pursuant to Section 35(a) of the Lanham
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`Act and awarding Plaintiff its costs and reasonable attorneys’ fees thereunder (15 U.S.C. §
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`1117(a)).
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`7.
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`Awarding Plaintiff interest, including prejudgment and post-judgment interest, on
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`the foregoing sums.
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`4839-0181-1644.1
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`15
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`Case 1:20-cv-04029 Document 1 Filed 05/26/20 Page 16 of 16
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`8.
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`Awarding such other and further relief as the Court deems just and proper.
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`DEMAND FOR JURY TRIAL
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`Under Fed. R. Civ. P. Rule 38, Plaintiff requests a trial by jury of any issues so triable by
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`
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`right.
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`Dated: May 26, 2020
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`Respectfully submitted,
`/s/ Jonathan Moskin
`
`Jonathan E. Moskin
`FOLEY & LARDNER LLP
`90 Park Avenue
`New York, New York 10016
`Telephone: 212-682-7474
`E-mail:jmoskin@foley.com
`
`Attorneys for Plaintiff
`Plymouth Beef, Inc.
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`4839-0181-1644.1
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`16
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