throbber
Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov
`ESTTA274761
`ESTTA Tracking number:
`03/27/2009
`
`Filing date:
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`92050480
`Plaintiff
`Farouk Systems, Inc.
`Defendant
`Shuo Cai Huang
`
`Proceeding.
`Applicant
`
`Other Party
`
`Motion for Suspension in View of Civil Proceeding With Consent
`
`The parties are engaged in a civil action which may have a bearing on this proceeding. Accordingly, Farouk
`Systems, Inc. hereby requests suspension of this proceeding pending a final determination of the civil action.
`Trademark Rule 2.117.
`Farouk Systems, Inc. has secured the express consent of all other parties to this proceeding for the
`suspension and resetting of dates requested herein.
`Farouk Systems, Inc. has provided an e-mail address herewith for itself and for the opposing party so that
`any order on this motion may be issued electronically by the Board.
`
`Certificate of Service
`
`The undersigned hereby certifies that a copy of this paper has been served upon all parties, at their address
`record by USPS Express Mail Post Office to Addressee on this date.
`Respectfully submitted,
`/Jason P. Sander/
`Jason P. Sander
`sanderj@gtlaw.com, mathenya@gtlaw.com, toborb@gtlaw.com, laipmail@gtlaw.com
`ehalstead@lawabel.com
`03/27/2009
`
`

`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD
`
`In re U.S. Registration No.:
`
`3,122,125
`
`For the Mark:
`
`GLOBAL BEAUTY
`
`Registrant:
`
`Registered:
`
`Shuo Cai Huang
`
`July 25, 2006
`
`Cancellation No.: 92050480
`
`)
`)
`)
`
`) )
`
`) )
`
`) )
`
`FAROUK SYSTEMS, INC.,
`
`Petitioner,
`
`V.
`
`SHUO CAI HUANG,
`
`)
`Registrant.
`____j________._.)
`
`CONSENTED RE UEST FOR SUSPENSION
`
`Dear Sir or Madam:
`
`Pursuant
`
`to 37 CFR § 2.117, Petitioner, Farouk Systems, Inc., hereby moves for
`
`suspension of the above indicated proceeding.
`
`In addition to this Cancellation proceeding, Petitioner and Registrant are also involved in
`
`litigation involving the mark GLOBAL BEAUTY in the United States District Court for the
`
`Southern District of Texas, Civil Action No. 4:09-CV-0900. A copy of the Complaint filed in
`
`this litigation is attached hereto as Exhibit A.
`
`

`
`The parties wish to suspend action in the present Cancellation proceeding pending
`
`resolution of the related litigation matters.
`
`In addition, Petitioner and Registrant are engaged in
`
`ongoing settlement discussions with regard to the above mentioned litigation actions.
`
`Counsel for Registrant has consented to this Petitioner’s Request for Suspension.
`
`WHEREFORE, Petitioner hereby requests that the above referenced Cancellation be
`
`suspended by consent and agreement of counsel for the parties.
`
`Respectfully submitted this 27th day of March, 2009.
`
`GREENBERG TRAURIG, LP
`
`/
`
`
`
`Ben D. Tobor
`
`Anthony F. Matheny
`Mark G. Chretien
`
`Jason Sander
`
`GREENBERG TRAURIG LLP
`
`1000 Louisiana Street, Suite 1700
`
`Houston, Texas 77002
`Tel: 713-374-3528
`
`Fax: 713-754-7528
`
`E-mail:
`
`toborb@gtlaW.com
`
`Attorneys for Petitioner,
`Farouk Systems, Inc.
`
`

`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on March 27, 2009, a true and correct copy of the foregoing
`Petitioner’s Consented Request for Suspension was served by USPS Express Mail Post Office to
`Addressee, and by e-mail on the following:
`
`Lawrence E. Abelman
`
`Erica R. Halstead
`
`Abelman Frayne & Schwab
`666 Third Avenue
`
`New York, New York 10017
`E-mail: eha1stead@1awabe1.com
`
`son Sander
`
`

`
`EXHIBIT
`
`C CA9 9
`
`

`
`Case 4:09-cv-00900 Document 1
`
`Filed in TXSD on 03/26/2009
`
`Page 1 of 10
`
`IN THE UNITED STATES DISTRICT
`
`FOR THE SOUTHERN DISTRICT OF TEXAS
`HOUSTON DIVISION
`
`Civil Action No. 4:09—cv-0900
`
`JURY DEMANDED
`
`§
`
`E
`S
`3
`
`§
`
`§ §
`
`§
`
`FAROUK SYSTEMS, INC.
`
`Plaintiff,
`
`vs.
`SHUO CAI HUANG, individually and
`
`doing business as
`EXCEON AMERICAN BEAUTY SUPPLY,
`
`Defendant.
`
`PLAINTIFF’S ORIGINAL COMPLAINT
`
`Farouk Systems, Inc. (“FSI” or “Plaintiff’) files this Original Complaint against Shuo Cai
`
`Huang, individually and doing business as Exceon American Beauty Supply (“Defendant”) and
`
`would respectfully show the Court as follows:
`
`PARTIES
`
`1.
`
`Plaintiff Farouk Systems, Inc. is a Texas corporation with its principal place of
`
`business in Houston, Texas.
`
`2.
`
`Upon information and belief, Defendant Shuo Cai Huang individually and doing
`
`business as Exceon American Beauty Supply is an individual residing at 5 Cypress Court,
`
`Plainsboro, New Jersey 08536. Defendant Shuo Cai Huang may be personally at 5 Cypress
`
`Court, Plainsboro, New Jersey 08536.
`
`JURISDICTION AND VENUE
`
`3.
`
`The United States District Court
`
`for
`
`the Southern District of Texas has
`
`jurisdiction over this action pursuant to the provisions of 28 U.S.C. § 1331 in that this matter is a
`
`

`
`Case 4:O9—cv—0O9OO Document 1
`
`Filed in TXSD on 03/26/2009
`
`Page 2 of 10
`
`civil action arising under the Constitution, laws, or treaties of the United States. This action
`
`involves a federal Lanham Act violation.
`
`4.
`
`This Court also has jurisdiction over this action pursuant to the provisions of 28
`
`U.S.C. § 1332 in that this matter is a civil action between citizens of different states wherein the
`
`amount in controversy is believed to exceed the sum of $75,000, exclusive of interest and costs.
`
`Plaintiff is a Texas corporation with its principal place of business in Houston, Texas. Defendant
`
`is a resident of the state of New Jersey and is doing business in Texas and, on information and
`
`belief, has systematic and continuous contacts with the state of Texas. Defendant, on
`
`information and belief, also does business in Harris County, Texas, and a substantial part
`
`Defendant’s acts and conduct giving rise to the claims herein occurred in Harris County, Texas.
`
`FACTUAL BACKGROUND
`
`5.
`
`FS1 is the owner of the trademark GLOBAL BEAUTY for electric hair curling
`
`irons, hair styling irons, hair straightening irons, and hair flat irons. FSI first began using the
`
`mark GLOBAL BEAUTY on its electric hair curling irons, hair styling irons, hair straightening
`
`irons, and hair flat irons at least as early as December 31, 2002.
`
`6.
`
`In addition to including the mark GLOBAL BEAUTY on its electric hair curling
`
`irons, hair styling irons, hair straightening irons, and hair flat irons, FSI includes the mark CHI
`
`shown in U.S. Trademark Registration No. 2,660,257, issued December 10, 2002, for the mark
`
`CHl® for electric hair curling irons. The trademark CHI is associated exclusively with FSI for
`
`use with electric hair curling irons and other hand-held electric styling irons. As a result of this
`
`exclusive use of the trademarks GLOBAL BEAUTY and CH1 and the long and widespread use
`
`that has been made by FSI of the trademarks GLOBAL BEAUTY and CH1, there is substantial
`
`

`
`Case 4:09-cv-00900 Document 1
`
`Filed in TXSD on 03/26/2009
`
`Page 3 of 10
`
`recognition and association of the trademarks GLOBAL BEAUTY and CHI with FSI by the
`
`consuming public for hair care products.
`
`7.
`
`Defendant is the President of Folica, Inc. which, in turn, owns the domain name
`
`www.folica.com. The website located at the domain name www.folica.com sells numerous
`
`types of hair care products, including hair curling irons, hair styling irons, hair straightening
`
`irons, and hair flat irons. Although neither Folica, Inc. or www.folica.com are authorized
`
`distributors of FSI’s products, Folica,
`
`Inc. and www.folica.com have been successful
`
`in
`
`obtaining FSI’s hair curling irons, hair styling irons, hair straightening irons, and hair flat irons
`
`through unauthorized channels and have offered for sale, and sold, FSI’s GLOBAL BEAUTY
`
`and CH1 branded air curling irons, hair styling irons, hair straightening irons, and hair flat irons
`
`and, therefore, Defendant is and has been fully aware of FSI’s rights to the mark GLOBAL
`
`BEAUTY, including its first adoption of the mark GLOBAL BEAUTY for FSI’s air curling
`
`irons, hair styling irons, hair straightening irons, and hair flat irons.
`
`8.
`FSI recently learned that Defendant was selling “Global Beauty” branded hair
`irons in violation of FSI’s trademark rights.
`In particular, Defendant imports, sells, offers for
`
`sale, advertises, and promotes electric hair irons having FSI’s GLOBAL BEAUTY mark. Upon
`
`information and belief, Defendant did not adopt or use the mark “Global Beauty” until 2005,
`
`well after FSI’s adoption and use of its GLOBAL BEAUTY mark.
`
`9.
`
`Despite being fully aware of FSI and its mark GLOBAL BEAUTY, Defendant
`
`sought and obtained a federal registration for FSI’s mark GLOBAL BEAUTY. On July 26,
`
`2006, Defendant obtained U.S. Trademark Registration No. 3,122,125 for GLOBAL BEAUTY
`
`for “electric hair straightener.” This registration states that Defendant first used FSI’s mark
`
`GLOBAL BEAUTY on electric hair straighteners on June 2, 2005.
`
`

`
`Case 4:09—cv—00900 Document 1
`
`Filed in TXSD on 03/26/2009
`
`Page 4 of 10
`
`10.
`
`Upon learning of Defendant’s infringement of FSI’s mark GLOBAL BEAUTY,
`
`FSI sent a letter to Defendant demanding that he cease using FSI’s GLOBAL BEAUTY mark
`
`and that he voluntarily abandon his federal registration.
`
`Instead of complying with F SI’s
`
`demands, Defendant responded to FSI’s letter stating that FSI is infringing upon Defendant’s
`
`trademark rights and demanded that FSI “cease all use of GLOBAL BEAUTY as a trademark on
`
`all products, in all advertising and promotional materials, and on the internet.”
`
`11.
`
`Defendant’s use of FSI’s mark GLOBAL BEAUTY on Defendant’s products and
`
`in advertisements and promotional materials for Defendant’s products creates a false association
`
`between Defendants and Defendants’ Products on one hand and FSI on the other hand. By using
`
`FSI’s common law trademark GLOBAL BEAUTY in such a way as to likely cause confusion
`
`among consumers, Defendants are infringing upon FSI’s trademark rights.
`
`12.
`
`Given the similarity of Defendant’s products to F SI’s products, and Defendant’s
`
`use of F SI’s mark GLOBAL BEAUTY on Defendant’s products, there is a substantial likelihood
`
`that consumers will be confused, misled or deceived. Moreover, Defendant’s improper use of
`
`F SI’s mark GLOBAL BEAUTY creates a false association of FSI’s mark GLOBAL BEAUTY
`
`with Defendant’s products.
`
`13.
`
`Furthermore, Defendant’s
`
`sales of his
`
`infringing products without FSI’s
`
`permission are diluting the value of FSl’s mark GLOBAL BEAUTY and damaging the goodwill
`
`and high quality reputation of FSI’s GLOBAL BEAUTY-branded products.
`
`14.
`
`By engaging in the industry of selling hair care products, and in particular,
`
`owning and/or operating the domain name www.folica.com and as President of Folica, Inc.,
`
`Defendant is well aware of FSI’s valuable trademark rights to the mark GLOBAL BEAUTY.
`
`In
`
`fact, Defendant is purposefully using FSI’s trademark GLOBAL BEAUTY to sell Defendant’s
`
`

`
`Case 4:09-cv—O09OO Document 1
`
`Filed in TXSD on 03/26/2009
`
`Page 5 of 10
`
`products while simultaneously selling FSI’s products that also include the mark GLOBAL
`
`BEAUTY.
`
`Therefore, Defendant
`
`is knowingly undertaken the above-described activities
`
`resulting in an infringement of FSI’s mark GLOBAL BEAUTY. Thus, on information and
`
`belief, the above—described activities by Defendants have been willful.
`
`15.
`
`On information and belief, Defendants will continue to undertake such activities
`
`which infringe FSI’s mark GLOBAL BEAUTY unless enjoined by the Court.
`
`16.
`
`As a consequence of these activities and the impairment to FSI’s goodwill,
`
`reputation, and customer base, FSI has been irreparably harmed to an extent not yet determined
`
`and will continue to be irreparably damaged by such acts in the future unless Defendants are
`
`immediately and, after trial, permanently enjoined by this Court from committing further such
`
`activity.
`
`COUNT I - VIOLATION OF 15 U.S.C. § 1125(a)
`
`17.
`
`FSI repeats and realleges the allegations set forth in paragraphs 1-16.
`
`18.
`
`Defendants’ improper use of, and sale of products under, a mark confusingly
`
`similar to FSI’s mark GLOBAL BEAUTY is confusing to consumers and violates Section 43(a)
`
`of the Lanham Trademark Act (“Lanham Act”) which prohibits the use of a trademark by
`
`Defendant in such a manner as is likely to cause confusion, mistake, or to deceive as to the
`
`affiliation, connection, or association of Defendant with FSI or as to the origin, sponsorship or
`
`approval of Defendant’s’ products by FSI. See 15 U.S.C. § 1125.
`
`19.
`
`Defendant
`
`is currently selling, offering for sale, and advertising Defendants’
`
`products under FSI’s common law trademark without the consent of FSI and will continue to do
`
`so unless enjoined from doing so by this Court.
`
`In addition, Defendant’s products have a nearly
`
`identical appearance and/or trade dress, with the location of the mark GLOBAL BEAUTY on
`
`Defendant’s hair irons being in the same place as where FSI places its mark GLOBAL
`
`

`
`Case 4:09—cv—0090O Document 1
`
`Filed in TXSD on 03/26/2009
`
`Page 6 of 10
`
`BEAUTY. The parties hair irons are both black with golden colored heating places. Although
`
`FSI’s products include the mark CHI in red on the hinge plate located at the rear of FSI’s hair
`
`irons and Defendant’s products include the initials “GB” on the hinge plate, Defendant’s “GB” is
`
`in the same color red as FSI’s mark CHI. Thus, Defendant’s adoption of a nearly identical trade
`
`dress or appearance having nearly identical
`
`features as FSI’s hair irons,
`
`including FSI’s
`
`GLOBAL BEAUTY mark shows that Defendant is “pa1ming off’ its hair irons as those of FSI.
`
`20.
`
`If FSI has no way of controlling the quality of Defendant’s products and
`
`Defendant
`
`is allowed to continue to sell Defendant’s products in connection with FSI’s
`
`trademark, FSI’s goodwill created by its mark GLOBAL BEAUTY is placed in jeopardy. The
`
`continuing acts of Defendant is jeopardizing the goodwill of FSI and its valuable trademark
`
`GLOBAL BEAUTY, and such acts have caused and are causing irreparable injury to FSI and to
`
`the consuming public. Unless the acts of the Defendant complained of herein are enjoined by
`
`this Court, they will continue to cause irreparable injury to FSI and to the public, for which there
`
`is no adequate remedy at law. Accordingly, FSI seeks injunctive relief prohibiting the infringing
`
`acts by Defendant complained of herein.
`
`21.
`
`In addition, the acts of Defendant complained of above have resulted in trademark
`
`violation of Section 43(a) of the Lanham Act. Therefore, pursuant to 15 U.S.C. § lll7(a), F S1 is
`
`entitled to recover 1) Defendant’s profits; 2) any damages sustained as a result of Defendant’s
`
`infringing acts; and 3) the costs associated with these causes of action.
`
`22.
`
`Moreover, FSI is entitled to an award of treble damages, as well as an award of
`
`punitive damages, pursuant to 15 U.S.C. § 1117(b) as a result of the extenuating circumstances
`
`of this case, Defendant’s intentional use of FSI’s trademark, and its gross, wanton, or willful
`
`conduct.
`
`

`
`Case 4:09—cv—009OO Document 1
`
`Filed in TXSD on 03/26/2009
`
`Page 7 of 10
`
`23.
`
`Furthermore, as a result of Defendant’s actions, FSI has been required to retain
`
`the services of counsel to represent it in this matter, and it has been forced to incur and is
`
`presently incurring attorneys’ fees in order to enforce its trademark rights. These fees and
`
`expenses are necessary and reasonable in order to prosecute this matter. Accordingly, FSI
`
`requests that it be granted an award of attorneys’ fees and costs as a result of Defendant’s actions
`
`as permitted under 15 U.S.C. § l1l7(a).
`
`COUNT H — TRADEMARK INFRINGEMENT AND
`UNFAIR COMPETITION UNDER TEXAS LAW
`
`24.
`
`FSI repeats and realleges the allegations set forth in paragraphs 1-23.
`
`25.
`
`In addition to federal trademark rights, FSI also owns trademark rights to the
`
`mark GLOBAL BEAUTY, among others, under the common law of the State of Texas. Thus,
`
`the acts of Defendant complained of above also constitute trademark infringement, “palming
`
`off,” and unfair competition under the common law of the State of Texas. As a result of the
`
`infringement and unfair competition by Defendant, FSI has suffered and will continue to suffer
`
`injury and damage in an amount yet to be determined. Upon information and belief, the acts of
`
`infringement by Defendant has resulted in, and is currently resulting in, substantial unjust profits
`
`to, and unjust enrichment of, Defendant in an amount yet to be determined. Such acts of
`
`trademark infringement and unfair competition are causing harm to F SI.
`
`26.
`
`The continuing acts of Defendant is jeopardizing the goodwill of F SI and its
`
`valuable trademark GLOBAL BEAUTY and such acts have caused and will continue to cause
`
`irreparable injury to FSI and to the consuming public. Unless the acts of the Defendant
`
`complained of herein are enjoined by this Court, they will continue to cause irreparable injury to
`
`FSI and to the public, for which there is no adequate remedy at law.
`
`

`
`Case 4:O9—cv—OO900 Document 1
`
`Filed in TXSD on 03/26/2009
`
`Page 8 of 10
`
`27.
`
`Additionally, or in the alternative, FSI seeks an accounting and its actual and
`
`consequential damages as a result of Defendant’s infringing acts which have resulted in
`
`confusion among the public. Moreover, FSI seeks punitive and enhanced damages for
`
`Defendant’s willful conduct.
`
`COUNT IH - TRADEMARK DILUTION UNDER TEXAS LAW
`
`28.
`
`FSI repeats and realleges the allegations set forth in paragraphs 1-27.
`
`29.
`
`The facts set out above demonstrate that Defendant is diluting the exclusivity and
`
`distinctiveness of FSI’s mark GLOBAL BEAUTY in violation of the Texas Anti—Di1ution Act.
`
`Defendant’s unauthorized use of FSI’s mark GLOBAL BEAUTY constitutes a dilution of FSI’s
`
`mark GLOBAL BEAUTY and injures FSI’s business reputation, in violation of TEX. BUS. &
`
`COM. CODE § 16.29.
`
`30.
`
`As a result of the dilution by Defendant, FSI has suffered, and is suffering, injury
`
`and damage in an amount yet to be determined. Upon information and belief, the acts of dilution
`
`by Defendant has resulted in, and is currently resulting in, substantial unjust profits to, and unjust
`
`enrichment of, Defendant in an amount yet to be determined. FSI seeks injunctive relief to
`
`prevent this type of injury from continuing. Additionally, or in the alternative, FSI seeks an
`
`accounting and damages.
`
`COUNT IV - CANCELLATION OF REGISTRATION NO. 3,122,125
`
`31.
`
`FSI repeats and realleges the allegations set forth in paragraphs 1-30.
`
`32.
`
`As set forth herein, Defendant’s use of the mark GLOBAL BEAUTY creates a
`
`false connection, association or affiliation with FSI will be presumed by consumers. As further
`
`set forth herein, Defendant’s use of the mark GLOBAL BEAUTY is confusingly similar to the
`
`FSI’s mark GLOBAL BEAUTY, in violation of 15 U.S.C. § 1125(a) and has caused and/or is
`
`likely to cause dilution of the FSI’s mark GLOBAL BEAUTY. Thus, the continued registration
`
`

`
`Case 4:09—cv-00900 Document 1
`
`Filed in TXSD on 03/26/2009
`
`Page 9 of 10
`
`of U.S. Trademark Registration No. 3,122,125 is inconsistent with FSI’s rights in the mark
`
`GLOBAL BEAUTY under common law and the Lanham Act, and is damaging to FSI.
`
`Accordingly, pursuant to 15 U.S.C. § 1119, FSI requests that U.S. Trademark Registration
`
`No. 3,122,125 be cancelled.
`
`DEMAND FOR JURY TRIAL
`
`33.
`
`FSI demands a trial byjury on all claims and issues.
`
`CONCLUSION AND PRAYER
`
`WHEREFORE, Farouk Systems, Inc. prays for entry ofjudgment:
`
`finding that Defendant has violated 15 U.S.C. § 1l25(a);
`
`finding that Defendant has infringed Farouk Systems,
`trademark rights in the mark GLOBAL BEAUTY;
`
`Inc.’s common law
`
`finding that Defendant has falsely and intentionally mislead consumers by directly
`or indirectly representing that infringing products are endorsed by, sponsored by,
`or affiliated with Farouk Systems, Inc.;
`
`finding that Defendant has engaged in unfair competition;
`
`enjoining Defendant, his officers, directors, agents, employees, representatives,
`successors, assigns, if any, and those in privity or concert with them from further
`acts that would amount to violation of Farouk Systems, Inc.’s rights under 15
`U.S.C. § 1l25(a) or amount
`to an infringement of Farouk Systems,
`Inc.’s
`common law rights in the trademark GLOBAL BEAUTY, or unfair competition;
`
`awarding Farouk Systems, Inc. all damages caused by the acts of Defendant and
`all profits of Defendant from acts complained of, and/or all costs to Farouk
`Systems, Inc. caused by Defendant’s activities complained of herein;
`
`trebling the damages and profits awarded to Farouk Systems, Inc. as authorized
`by 15 U.S.C.§1117;
`
`granting Farouk Systems, Inc. pre-judgment and post-judgment interest on the
`damages caused to Farouk Systems, Inc. by reasons of Defendant’s activities
`complained of herein at the highest rates allowed by law;
`
`finding that this is an exceptional case and awarding Farouk Systems, Inc.
`reasonable and necessary attorneys’ fees in accordance with 15 U.S.C. § 11 17;
`
`its
`
`

`
`Case 4:09-cv—0090O Document 1
`
`Filed in TXSD on 03/26/2009
`
`Page 10 of 10
`
`j.
`
`k.
`
`1.
`
`in.
`
`awarding costs to Farouk Systems, Inc.;
`
`awarding Farouk Systems,
`enforcing its state law rights;
`
`Inc.
`
`its attorneys’
`
`fees incurred as a result of it
`
`cancelling U.S. Trademark Registration No. 3,122,125; and
`
`awarding Farouk Systems, Inc. such other and further relief, at law or in equity, as
`the Court may deem just and proper under the circumstances.
`
`Dated: March 26, 2009
`
`Of Counsel:
`
`Mark Chretien
`
`Texas State Bar No. 24036364
`
`GREENBERG TRAURIG LLP
`
`1000 Louisiana, Suite 1700
`Houston, Texas 77002
`
`(713) 374-3500 (Telephone)
`(713) 374-3505 (Fax)
`
`Respectfully submitted,
`
`GREENBERG TRAURIG LLP
`
`By: /Anthony F. Matheny/
`Anthony Matheny
`Attomey-in-Charge
`S.D. Tex. Bar No. 303157
`Texas State Bar No. 24002543
`
`1000 Louisiana, Suite 1700
`Houston, Texas 77002
`
`(713) 374-3583 (Telephone)
`(713) 754-7583 (Fax)
`
`ATTORNEYS FOR PLAINTIFF
`
`FAROUK SYSTEMS, INC.
`
`10

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