Violent Crown Trademark Suit

Case 1:21-cv-01142-RP Document 1 Filed 12/16/21 Page 1 of 14
UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF TEXAS
AUSTIN DIVISION
VIOLET CROWN CINEMAS, LLC, §

§
Plaintiff, §
§
v. § CASE NO. 1:21-cv-1142
§
INTERNATIONAL DEVELOPMENT §
MANAGEMENT, LLC, §
§
Defendant. §
PLAINTIFF’S ORIGINAL COMPLAINT
Plaintiff Violet Crown Cinemas, LLC (“Violet Crown”) files its Original Complaint
against International Development Management, LLC (“IDM”), and states:
I. INTRODUCTION
1. More than a decade ago, Violet Crown opened the Violet Crown theater in Austin
Texas (“Violet Crown Austin”). Since that time, Violet Crown Austin has become one of
Austin’s premiere entertainment venues.
COMPLAINT – Page 1
2. While Violet Crown Austin primarily exhibits motion pictures, it also
occasionally hosts live entertainment. It also provides comprehensive restaurant and bar services
as well. Since opening its first location in Austin, Violet Crown has expanded its locations to
Santa Fe, New Mexico and Charlottesville, North Carolina with a venue due to open in Dallas,
Texas in 2022.
3. Violet Crown is the owner of several U.S. registered trademarks including U.S.
Registration No. 5691295, 4979206 and 4795304 for VIOLET CROWN in connection with
movie theaters, production and distribution of motion pictures and bar and restaurant services,
respectively, and U.S. Registration No. 4367376 for VIOLET CROWN CINEMAS in
connection with movie theaters (collectively, the “VIOLET CROWN Marks”).1
4. IDM has announced plans to open a 20,000 seat amphitheater in the Austin area
near Bee Cave. IDM is calling its new development the “VIOLET CROWN AMPHITEATER.”
Precise details of the proposed amphitheater project are unknown other than it will host live
music. It will presumably also offer bar and restaurant services. IDM is currently using the
following logo to promote its development:
1
True and correct copies of the registration certificates for the VIOLET CROWN MARKS are attached hereto as
Exhibits A-D.
5. IDM has also generated a substantial amount of press coverage related to its
proposed project, not all of which has been positive. For instance, the Austin Business Journal
reported, on November 30, 2021, that development of the VIOLET CROWN AMPHITHEATER
raises serious environmental concerns. Local musicians have also expressed opposition due to
the proposed venues size as it will not promote local musical artists, promoting large concerts
instead. Finally, the Austin Business Journal has also reported that the founder of IDM, the
developer of the VIOLET CROWN AMPHITHEATER, pleaded guilty to a charge of indecent
exposure.
6. Because of the obvious similarity between VIOLET CROWN AMPHITHEATER
and VIOLET CROWN, Violet Crown has received a number of inquiries about the proposed
amphitheater project from individuals who reasonably but incorrectly conclude that Violet
Crown is the developer of the VIOLET CROWN AMPHITHEATER. Because of this actual
confusion and its existing rights in the VIOLET CROWN marks, Violet Crown sent IDM a
cease-and-desist letter on November 16, 2021. Although Violet Crown did receive a response to
its cease-and-desist letter, the response was not substantive and merely acknowledged receipt of
the letter. Violet Crown has received no substantive response to its demand that IDM cease any
further use of the VIOLET CROWN marks in connection with its proposed amphitheater project.
Accordingly, Violet Crown has been forced to file this lawsuit to protect its rights.
II. PARTIES
7. Plaintiff Violet Crown Cinemas, LLC is a Texas limited liability company with its
principal place of business located at 1614 W. 5th Street, Austin, TX 78703.
8. International Development Management, LLC is a Delaware limited liability
company doing business in Texas. IDM may be served with the summons and Complaint by
serving its registered agent for service of process, Oralia Everett, 1912 Melissa Oaks Lane,
Austin, TX 78744.
III. JURISDICTION AND VENUE
9. This Court has subject matter jurisdiction under section 39 of the Lanham Act, 15
U.S.C. § 1121, and under 28 U.S.C. §§ 1331 and 1338. Subject matter jurisdiction over Violet
Crown’s related state and common law claims is proper pursuant to 28 U.S.C. §§ 1338 and 1367.
10. This Court has personal jurisdiction over IDM because, on information and belief,
IDM has (1) contracted by mail or otherwise with a Texas resident and either party is to perform
the contract in whole or in part in Texas; (2) committed a tort in whole or in part in Texas and/or
(3) recruited Texas residents, directly or through an intermediary located in this Texas, for
employment inside or outside Texas and is therefore doing business in Texas.
11. The Western District of Texas is a proper venue pursuant to 28 U.S.C. §
1391(b)(2) because a substantial part of the acts or omissions giving rise to Violet Crown’s
claims occurred in this District.
IV. FACTS COMMON TO ALL CLAIMS FOR RELIEF
A. The VIOLET CROWN Mark.

12. More than a decade ago, Violet Crown opened its first theater in the heart of
Downtown Austin. Since that time, Violet Crown Austin has become one of Austin’s premiere
entertainment venues. Violet Crown Austin is not just a theater, it’s a part of the Austin
community. Violet Crown seeks to provide spaces for public entertainment but also to support its
neighbors in myriad ways. Violet Crown partners with local vendors whenever possible, and
always looks to connect with community members.
13. Violet Crown follows this same community focused business model in its other
theater locations. As a result, Violet Crown’s exposure to the community runs much deeper than
might be expected from other theater venues.
14. In addition to film exhibition, Violet Crown’s theaters also offer live musical
entertainment. Its theater facilities are also available for event rentals which are not limited to
film exhibition. Similarly, Violet Crown offers restaurant, in-house catering and full bar
services. This package of services makes Violet Crown a favorite entertainment destination.
15. Violet Crown is the owner of U.S. trademark registration nos. 5691295, 4979206
and 4795304 for VIOLET CROWN in connection with movie theaters, production and
distribution of motion pictures and bar and restaurant services, respectively, and U.S.
Registration No. 4367376 for VIOLET CROWN CINEMAS in connection with movie theaters.
16. The VIOLET CROWN Marks are well known in the markets where its theaters
are located and consumers associate the Mark with the Plaintiff. Violet Crown has used the
VIOLET CROWN marks for more than a decade in connection with its theater, bar and
restaurant services. Violet Crown also uses the VIOLET CROWN Marks in its sponsorship of
various community events.
17. Violet Crown has spent millions of dollars developing and promoting its theaters
under the VIOLET CROWN Marks. As a result of its continuous and exclusive use of the
VIOLET CROWN Marks in connection with its theater, bar and restaurant services, the mark
enjoys wide public acceptance and association with Violet Crown, and has come to be
recognized widely and favorably by the public as an indicator of the origin of Violet Crown’s
services.
18. As a result of Violet Crown’s extensive use and promotion of the VIOLET
CROWN Marks, Violet Crown has built up and now owns extremely valuable goodwill that is
symbolized by the mark. The purchasing public has come to associate the VIOLET CROWN
Marks with Violet Crown.
B. IDM’s Unlawful Activity.

19. Beginning in October 2021, Violet Crown’s management started receiving
inquiries about a newly proposed VIOLET CROWN AMPHITHEATER from individuals who
believed Violet Crown was the intended developer. As a result of those inquiries, Violet Crown
learned that IDM is developing a 20,000 seat amphitheater in the greater Austin area which it is
calling the VIOLET CROWN AMPHITHEATER. IDM is using the following logo on its
website:
20. IDM’s website, http://violetcrownaustin.com, promotes this new development as
including:2
THE ULTIMATE OUTDOOR VENUE

The Violet Crown Amphitheater will have a capacity of 20,000 making it the
largest music-specific room in the region. This ensures it will attract the largest
popular touring acts.
The bandshell will be one of the largest in the United States. The stage is
permanent and the largest in the region. The stage has been designed for efficient
loading, show production, recording, and broadcast, with ample support areas for
2
A copy of excerpts of the website is attached hereto as Exhibit E.
artists and crews alike. The orchestra and mezzanine sections are seated with
alternating bands of Lueders limestone and natural grass. The upper lawn and
mosh areas are flat and natural grass.
Concessions, merchandise, and sponsor areas have been located at the top of the
bowl. VIP lounges and boxes are located on the second level above the concourse
and in the bowl between the orchestra and mezzanine sections.
THE HIGH LIFE

The world’s most beautiful and most advanced live music amphitheater is only
the start. The Violet Crown also includes a 96-bay driving range with a top floor
pool club, a distillery with tasting room, a danceclub beneath the amphitheater, a
rooftop nightclub on the north tower, a rooftop pool club on the south tower, a
traditional dancehall and full-service restaurant in the podium level of the towers;
all set in the context of the natural beauty of the Texas Hill Country.
21. IDM has also started generating negative press. It faces backlash from
environmental groups.3 “Powerful environmental groups are taking aim at the 71-acre Violet
Crown project proposed near Bee Cave, saying it is ‘about the worst possible location to build a
new Austin entertainment district’ because of its proximity to environmentally sensitive areas.”
“Representatives from a number of groups — including the Nature Conservancy, Greater
Edwards Aquifer Alliance, Sierra Club Austin, Save Our Springs and Save Barton Creek
Association — have released statements opposing the project, with some saying they were
‘alarmed’ after reading about it in news reports. The biggest concerns are the project's proximity
to both Barton Creek and the 4,000-acre Barton Creek Habitat Preserve, which is owned by the
nonprofit Nature Conservancy, one of the world's largest environmental groups.”
22. In addition to the foregoing, it has been reported that IDM’s founder, Chris
Milam, pled guilty to charges of indecent exposure.
3
See Environmental groups raise concerns about Violet Crown amphitheater project proposed west of Austin,
Austin Business Journal, November 5, 2021, attached hereto as Exhibit F.
23. On information and belief, IDM knowingly, willfully, intentionally, and
maliciously adopted the VIOLET CROWN AMPHITHEATER mark which is confusingly
similar to the VIOLET CROWN Marks.
FIRST CLAIM FOR RELIEF

(Federal Trademark Infringement)
24. Violet Crown repeats and incorporates by reference the allegations in the
preceding paragraphs.
25. IDM’s use of the confusingly similar VIOLET CROWN AMPHITHEATER is
likely to cause confusion, deception, and mistake by creating the false and misleading impression
that IDM’s goods and services are manufactured, distributed or provided by Violet Crown, or are
associated or connected with Violet Crown, or have the sponsorship, endorsement, or approval of
Violet Crown.
26. IDM’s infringing VIOLET CROWN AMPHITHEATER mark is confusingly
similar to Violet Crown’s federally registered marks in violation of 15 U.S.C. § 1114. IDM’s
activities are causing and, unless enjoined by this Court, will continue to cause a likelihood of
confusion and deception of members of the trade and public, and, additionally, injury to Violet
Crown’s goodwill and reputation as symbolized by the VIOLET CROWN Marks, for which
Violet Crown has no adequate remedy at law.
27. IDM’s actions demonstrate an intentional, willful, and malicious intent to trade on
the goodwill associated with Violet Crown’s VIOLET CROWN Marks to Violet Crown’s great
and irreparable harm.
28. IDM caused and is likely to continue causing substantial injury to the public and
to Violet Crown, and Violet Crown is entitled to injunctive relief and to recover IDM’s profits,
actual damages, enhanced profits and damages, costs, and reasonable attorneys’ fees under 15
U.S.C. §§ 1114, 1116, and 1117.
SECOND CLAIM FOR RELIEF

(Federal Unfair Competition)
30. IDM’s use of a confusingly similar imitation of the VIOLET CROWN Marks has
caused and is likely to cause confusion, deception, and mistake by creating the false and
misleading impression that IDM’s goods are manufactured or distributed by Violet Crown, or are
affiliated, connected, or associated with Violet Crown, or have the sponsorship, endorsement, or
approval of Violet Crown.
31. IDM has made false representations, false descriptions, and false designations of,
on, or in connection with its goods or services in violation of 15 U.S.C. § 1125(a). IDM’s
activities have caused and, unless enjoined by this Court, will continue to cause a likelihood of
confusion and deception of members of the trade and public, and, additionally, injury to Violet
Crown’s goodwill and reputation as symbolized by Violet Crown’s VIOLET CROWN Marks,
for which Violet Crown has no adequate remedy at law.
the goodwill associated with Violet Crown’s VIOLET CROWN Marks to the great and
irreparable injury of Violet Crown.
33. IDM’s conduct has caused, and is likely to continue causing, substantial injury to
the public and to Violet Crown. Violet Crown is entitled to injunctive relief and to recover
IDM’s profits, actual damages, enhanced profits and damages, costs, and reasonable attorneys’
fees under 15 U.S.C. §§ 1125(a), 1116, and 1117.
THIRD CLAIM FOR RELIEF

(Federal Trademark Dilution of the VIOLET CROWN Mark)
35. For more than a decade, Violet Crown has exclusively and continuously promoted
and used the VIOLET CROWN Marks. The VIOLET CROWN Marks became a famous and
well-known symbol of Violet Crown and Violet Crown’s services well before IDM began using
the infringing VIOLET CROWN AMPHITHEATER mark.
36. IDM is preparing to make use in commerce of the infringing VIOLET CROWN
AMPHITHEATER mark, which is likely to dilute the distinctiveness of Violet Crown’s
VIOLET CROWN Marks by eroding the public’s exclusive identification of this famous mark
with Violet Crown, tarnishing and degrading the positive associations and prestigious
connotations of the mark, and otherwise lessening the capacity of the mark to identify and
distinguish Violet Crown’s services.
the goodwill associated with Violet Crown’s VIOLET CROWN Marks or to cause dilution of the
mark to the great and irreparable injury of Violet Crown. IDM has caused and will continue to
cause irreparable injury to Violet Crown’s goodwill and business reputations, and dilution of the
distinctiveness and value of Violet Crown’s famous and distinctive VIOLET CROWN Marks in
violation of 15 U.S.C. § 1125(c). Violet Crown therefore is entitled to injunctive relief and to
IDM’s profits, actual damages, enhanced profits and damages, and reasonable attorneys’ fees
under 15 U.S.C. §§ 1125(c), 1116, and 1117.
FOURTH CLAIM FOR RELIEF

(Common Law Trademark Infringement and Unfair Competition)
39. IDM’s acts constitute common law trademark infringement and unfair
competition, and have created and will continue to create, unless restrained by this Court, a
likelihood of confusion to the irreparable injury of Violet Crown. Violet Crown has no adequate
remedy at law for this injury.
40. On information and belief, IDM acted with full knowledge of Violet Crown’s use
of, and statutory and common law rights to, Violet Crown’s VIOLET CROWN Marks and
without regard to the likelihood of confusion of the public created by IDM’s activities.
the goodwill associated with Violet Crown’s VIOLET CROWN Marks to the great and
irreparable injury of Violet Crown.
42. As a result of IDM’s acts, Violet Crown has been damaged in an amount not yet
determined or ascertainable. At a minimum, however, Violet Crown is entitled to injunctive
relief, damages, and costs. Further, in light of the deliberate and malicious use of a confusingly
similar imitation of Violet Crown’s VIOLET CROWN Marks, and the need to deter IDM from
engaging in similar conduct in the future, Violet Crown additionally is entitled to punitive
damages.
FIFTH CLAIM FOR RELIEF

(State Trademark Dilution and Injury to Business Reputation)
44. Violet Crown has extensively and continuously promoted and used the VIOLET
CROWN mark, and the VIOLET CROWN Marks became a distinctive, famous, and well-known
symbol of Violet Crown’s goods well before IDM began using the infringing VIOLET CROWN
AMPHITHEATER mark.
45. IDM’s conduct dilutes and is likely to dilute the distinctiveness of Violet Crown’s
VIOLET CROWN Marks by eroding the public’s exclusive identification of this mark with
Violet Crown, and tarnishing and degrading the positive associations and prestigious
connotations of the mark, and otherwise lessening the capacity of the mark to identify and
distinguish Violet Crown’s goods.
46. Violet Crown, therefore, is entitled to injunctive relief, damages, and costs, as
well as, punitive damages, and reasonable attorneys’ fees.
PRAYER FOR RELIEF
WHEREFORE, Violet Crown prays that:

1. IDM and all of its agents, officers, employees, representatives, successors,
assigns, attorneys, and all other persons acting for, with, by, through or under authority from
IDM, or in concert or participation with IDM, and each of them, be enjoined from:
a. using the infringing VIOLET CROWN AMPHITHEATER mark on or in
connection with any of IDM’s goods or services;
b. using the VIOLET CROWN Marks or any other copy, reproduction, colorable
imitation, or simulation of Violet Crown’s VIOLET CROWN Marks on or in connection
with IDM’s goods or services;
c. using any trademark, name, logo, design, or source designation of any kind on or
in connection with IDM’s goods or services that is a copy, reproduction, colorable
imitation, or simulation of, or confusingly similar to any of Violet Crown’s trademarks,
trade dresses, names, or logos;
d. using any trademark, name, logo, design, or source designation of any kind on or
in connection with IDM’s goods that is likely to cause confusion, mistake, deception, or
public misunderstanding that such goods or services are produced or provided by Violet
Crown, or are sponsored or authorized by Violet Crown, or are in any way connected or
related to Violet Crown;
e. using any trademark, name, logo, design, or source designation of any kind on or
in connection with IDM’s goods or services that dilutes or is likely to dilute the
distinctiveness of Violet Crown’s trademarks, trade dresses, names, or logos; and
f. passing off, palming off, or assisting in passing off or palming off IDM’s goods or
services as those of Violet Crown, or otherwise continuing any and all acts of unfair
competition as alleged in this Complaint.
2. IDM be required to pay to Violet Crown the costs and reasonable attorneys’ fees
incurred by Violet Crown in this action pursuant to 15 U.S.C. § 1117(a).
3. Based on IDM’s willful and deliberate infringement and/or dilution of the Violet
Crown’s VIOLET CROWN Marks, and to deter such conduct in the future, Violet Crown be
awarded punitive damages;
4. Violet Crown be awarded prejudgment and post-judgment interest on all
monetary awards; and
5. Violet Crown be granted such other and further relief as the Court may deem just.
JURY TRIAL DEMAND
47. Violet Crown respectfully demands a trial by jury on all claims and issues so
triable.
Respectfully Submitted,
By: /s/ Baxter W. Banowsky

Baxter W. Banowsky
State Bar No. 00783593
bwb@banowsky.com
BANOWSKY & LEVINE, P.C.
12801 N. Central Expressway
Suite 1700
Dallas, Texas 75243
Telephone: (214) 871-1300
Facsimile: (214) 871-0038
ATTORNEY FOR PLAINTIFF
Case 1:21-cv-01142-RP Document 1-1 Filed 12/16/21 Page 1 of 2
Reg. No. 5,691,295 Violet Crown Cinemas, LLC (TEXAS LIMITED LIABILITY COMPANY)
1614 W. 5th Street
Registered Mar. 05, 2019 Austin, TEXAS 78703
CLASS 41: Movie theaters

Int. Cl.: 41
FIRST USE 4-29-2011; IN COMMERCE 4-29-2011
Service Mark
THE MARK CONSISTS OF STANDARD CHARACTERS WITHOUT CLAIM TO ANY
Principal Register PARTICULAR FONT STYLE, SIZE OR COLOR
OWNER OF U.S. REG. NO. 4979206, 5008882, 4795305
SER. NO. 88-050,187, FILED 07-24-2018

REQUIREMENTS TO MAINTAIN YOUR FEDERAL TRADEMARK REGISTRATION

WARNING: YOUR REGISTRATION WILL BE CANCELLED IF YOU DO NOT FILE THE
DOCUMENTS BELOW DURING THE SPECIFIED TIME PERIODS.
Requirements in the First Ten Years*

What and When to File:
First Filing Deadline: You must file a Declaration of Use (or Excusable Nonuse) between the 5th and 6th
years after the registration date. See 15 U.S.C. §§1058, 1141k. If the declaration is accepted, the
registration will continue in force for the remainder of the ten-year period, calculated from the registration
date, unless cancelled by an order of the Commissioner for Trademarks or a federal court.
Second Filing Deadline: You must file a Declaration of Use (or Excusable Nonuse) and an Application
for Renewal between the 9th and 10th years after the registration date.* See 15 U.S.C. §1059.
Requirements in Successive Ten-Year Periods*

What and When to File:
You must file a Declaration of Use (or Excusable Nonuse) and an Application for Renewal
between every 9th and 10th-year period, calculated from the registration date.*
Grace Period Filings*
The above documents will be accepted as timely if filed within six months after the deadlines listed above with
the payment of an additional fee.
*ATTENTION MADRID PROTOCOL REGISTRANTS: The holder of an international registration with an

extension of protection to the United States under the Madrid Protocol must timely file the Declarations of Use
(or Excusable Nonuse) referenced above directly with the United States Patent and Trademark Office (USPTO).
The time periods for filing are based on the U.S. registration date (not the international registration date). The
deadlines and grace periods for the Declarations of Use (or Excusable Nonuse) are identical to those for
nationally issued registrations. See 15 U.S.C. §§1058, 1141k. However, owners of international registrations
do not file renewal applications at the USPTO. Instead, the holder must file a renewal of the underlying
international registration at the International Bureau of the World Intellectual Property Organization, under
Article 7 of the Madrid Protocol, before the expiration of each ten-year term of protection, calculated from the
date of the international registration. See 15 U.S.C. §1141j. For more information and renewal forms for the
international registration, see http://www.wipo.int/madrid/en/.
NOTE: Fees and requirements for maintaining registrations are subject to change. Please check the
USPTO website for further information. With the exception of renewal applications for registered
extensions of protection, you can file the registration maintenance documents referenced above online at h
ttp://www.uspto.gov.
NOTE: A courtesy e-mail reminder of USPTO maintenance filing deadlines will be sent to trademark
owners/holders who authorize e-mail communication and maintain a current e-mail address with the
USPTO. To ensure that e-mail is authorized and your address is current, please use the Trademark
Electronic Application System (TEAS) Correspondence Address and Change of Owner Address Forms
available at http://www.uspto.gov.
Page: 2 of 2 / RN # 5691295
VIOLET CROWN AMPHITHEATER

violetcrownaustin.com
AUSTIN, TEXAS
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AMPHITHEATER
INCREDIBLE MEMORIES
Experience music under a blanket of stars, surrounded by pristine preserve land, in the city but a world apart. Designed to support the arts, protect the environment
and enhance social bonds.
RESIDENTIAL
LUXURY LIVING
Luxury apartments with pools and significant resident amenities, internal structured parking, restaurants, shops, a night club, pool club, and dancehall, all in two towers
that support a groundbreaking vertical forest.
ENTERTAINMENT
UNPARALLELED ENTERTAINMENT
Additional entertainment venues include a 96-bay driving range with restaurants and top floor pool club, a distillery and tasting room, a large nightclub beneath the
amphitheater, a rooftop nightclub on the north tower, a rooftop pool club on the south tower, and a traditional dancehall in the lobby of the towers.
ENVIRONMENT
DESIGNED TO HONOR
AND PROTECT THE LAND
We have made a concerted effort to maximize the use of natural and local building materials and stormwater quality controls, while minimizing impervious cover, the
use of plastics, the consumption of potable water, and carbon emissions. This has been accomplished while serving the community philanthropically at scale in a way
which is aesthetically pleasing.
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COMMUNITY
SUPPORTING THE ARTS
AND OUR COMMUNITY
We place a high priority on social responsibility. In the spirit of social-enterprise which is so much a part of Austin’s ethos, we are creating an endowment with
beneficiaries selected from private-sector non-profits with well-defined missions focused on natural resource preservation, the performing arts and artists, and the
mental, physical and spiritual health, welfare, safety and education of our community at large.
EXPERIENCE
A CONNECTON TO THE
MUSIC OF THE SPHERES
An important underlying objective of the VCA endeavor is for all of our visitors to sit upon the good Earth and listen to music in and of the cosmos, to feel deeply their
connection to the natural world, and upon departing to carry with them into their daily lives an understanding of, and respect for the fragility of our existence in this
unlikely paradise.
CONTACT
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AMPHITHEATER - Violet Crown Amphitheater

violetcrownaustin.com/amphitheater
AMPHITHEATER
THE ULTIMATE
OUTDOOR VENUE
The Violet Crown Amphitheater will have a capacity of 20,000 making it the largest music-specific room in
the region. This ensures it will attract the largest popular touring acts.
The bandshell will be one of the largest in the United States. The stage is permanent and the largest in the
region. The stage has been designed for efficient loading, show production, recording, and broadcast, with
ample support areas for artists and crews alike. The orchestra and mezzanine sections are seated with
alternating bands of Lueders limestone and natural grass. The upper lawn and mosh areas are flat and
natural grass.
Concessions, merchandise, and sponsor areas have been located at the top of the bowl. VIP lounges and
boxes are located on the second level above the concourse and in the bowl between the orchestra and
mezzanine sections.
PERFECT VIEWS
The Violet Crown Amphitheater sits at the highest elevation in Travis county. From the top of the bowl, there
are 360° views of the entire region. The site naturally lends itself to the placement of the amphitheater on the
west side of the hill facing the deepest point of the surrounding preserve land. This provides a dark, still, and
quiet background for concertgoers which will be the same a century from now as it is today.
CONVENIENT ACCESS
The Violet Crown Development is well within the city yet surrounded by many thousands of acres of preserve
land. It therefore neither disturbs nor is disturbed by anyone. Regional access is via two large thoroughfares
from the south, SH71 and Southwest Parkway; and two from the north, SH620 and Bee Cave Road. The site
benefits directly from significant road improvements underway at the new half billion dollar grade-separated
intersection at 71/290 in Oak Hill to the south, and significant improvements to SH620 at SH71 in Bee Cave
to the north. There will be three access points to the site directly from SH71, with the central one being fully
signalized. Internally, the masterplan simplifies internal traffic flow, access to parking garages, facilitates the
use of ride-sharing, and encourages the use of electric vehicles.
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MINUTES FROM
THE HEART OF AUSTIN
AIRPORT: 25 minutes
CITY CENTER: 20 minutes
WEST AUSTIN: 15 minutes
SOUTH AUSTIN: 10 minutes
LAKEWAY: 10 minutes
GALLERIA: 5 minutes
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GIVING BACK
We place a high priority on social responsibility. In addition to our environmental commitments, and in the
spirit of social enterprise, we are creating an endowment with beneficiaries selected from private-sector non-
profits with well-defined missions focused on natural resource preservation, the performing arts and artists,
and the mental, physical and spiritual health, welfare, safety and education of our community at large.
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SPECTACULAR
violetcrownaustin.com/residential
RESIDENTIAL
JOIN THE VCA INSIDERS CLUB

be the first to hear about leasing and insider offers
It goes without saying that the views from the towers are spectacular. It is important to us as well that the
views of the towers be equally spectacular. Consequently, the architecture of the buildings has been
predicated on a desire to achieve maximum integration with nature. To achieve this we have adopted new
building and agronomy technologies which allow for the creation of vertical forests on the exterior walls of tall
buildings. Our approach mirrors that of successful buildings in Europe and the Far East.
These vertical forests reduce heat, scrub the air, absorb significant carbon dioxide and emit large amounts of
oxygen. Irrigation and drainage have been designed into the external walls, and will be implemented as an
integral part of the structure from the outset. This substantially reduces water use through subsurface
irrigation while maximizing plant survival rates in the Texas heat and cold.
Photos from consulting architect Stefan Boeri: https://www.stefanoboeriarchitetti.net/en/
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APARTMENTS & AMENITIES
The residential towers will together contain approximately 500 living units of varying sizes and plans. Most
units will have large and deep balconies. This is a place where people will want to be outside and we have
planned for that. All units will have spectacular short and long views of the Texas Hill Country.
Each tower has large public and private lobbies, large amenity decks, and stunning 12th floor pools. The
common lobby level will be home to a traditional Texas dancehall. The roof of the north tower will be home to
a 30th floor nightclub and the roof of the south tower will be home to a 23rd floor pool club.
The bottom and top floors of each tower will have heroic 30’ clear heights. The living unit floors will have 11’
clear heights rather than the typical 9′. All units have enclosed structured parking within the building. Each
tower will have two floors of class A office space available for lease to corporate clients to meet the needs of
the new age of distributed and remote workforces.
SHORT TERM RENTAL

There will exist at the feet of these towers one of the country’s largest and most incredible live music venues,
an entertainment-driven driving range, and numerous other venues. What the development does not include
is a conventional hotel. Therefore, primary tenants will be allowed and encouraged to place their units on
Airbnb, Home Away/VRBO, and other systems for short-term rental. For guests, this will provide lodging. For
residents, this will provide income to offset their monthly rent. All revenues from short-term rentals will be
retained by the primary tenant.
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THE HIGH LIFE

violetcrownaustin.com/driving-range
ENTERTAINMENT
The world’s most beautiful and most advanced live music amphitheater is only the start. The Violet Crown
also includes a 96-bay driving range with a top floor pool club, a distillery with tasting room, a danceclub
beneath the amphitheater, a rooftop nightclub on the north tower, a rooftop pool club on the south tower, a
traditional dancehall and full-service restaurant in the podium level of the towers; all set in the context of the
natural beauty of the Texas Hill Country.
THE RANGE
AT VIOLET CROWN
AN ENTERTAINMENT FUELED DRIVING RANGE WITH ITS OWN PRIVATE POOL CLUB
VIOLET CROWN DISTILLERY AND CRAIG’S TASTING ROOM
CRAFTED ON SITE AND AGED UNDER THE STAGE
LUCIFER DANCECLUB
BENEATH THE VIOLET CROWN
A SUBTERRANEAN WORLD UNDER THE AMPHITHEATER
RAINBOW ROOM NIGHTCLUB

ABOVE THE VIOLET CROWN
ON TOP OF THE WORLD ON THE NORTH TOWER
OASIS POOL CLUB

WITHIN VIOLET CROWN
A PRIVATE OASIS ON THE SOUTH TOWER
MILAM DANCEHALL
IN THE TRADITION OF THE TEXAS HILL COUNTRY
BLOOM RESTAURANT
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LOCAL, PURE, HEALTHY, AND HAPPY
2/2
ENVIRONMENT - Violet Crown Amphitheater

violetcrownaustin.com/environment
ENVIRONMENT
We have made a concerted effort to maximize the use of natural and local building materials and stormwater
quality controls, while minimizing impervious cover, the use of plastics, the consumption of potable water,
and carbon emissions. This has been accomplished while serving the community philanthropically at scale in
a way which is aesthetically pleasing.
Full code compliance

The project is located in Travis County, within the City of Austin’s ETJ, and the Barton Springs Zone. The
project meets or exceeds all SOS requirements and is not seeking any variances.
LIMITATION OF IMPERVIOUS COVERAGE

Impervious coverage is limited to 20% irrespective of grandfathering. The bowl is an open green space, and
the exterior walls of the residential towers will be planted as a vertical forest aesthetically integrating them
into the surrounding preserves.
LIMITATION OF THE SALE OF SINGLE-USE PLASTICS

In keeping with the City of Austin’s zero waste goals for 2040, single-use plastics will be minimized in
concession sales in the venue. Preference will be given to vendors providing paper products which are
demonstrated to be sustainably sourced and recycled, and which do not contain chemical additives.
MAJORITY GREEN BOWL

In keeping with the natural environment the amphitheater seating is comprised of Lueders limestone blocks
separated by grass bands. There will be no use of plastic seating in the bowl. This combined with the grass
upper lawn and orchestra pit results in a majority green and natural seating.
REDUCED CARBON FOOTPRINT

The site plan has been developed with the use of ride-sharing in mind, with the goal of reducing the carbon
footprint of the amphitheater relative to prior generations. Ride-sharing and other forms of public transport
increase vehicle utilization rates, taking cars off the road and reducing emissions and congestion. The 80%
previous site, green bowl, and planting on the residential walls will all absorb CO2 and emit O2.
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COMMUNITY - Violet Crown Amphitheater

violetcrownaustin.com/community
COMMUNITY
In the spirit of social enterprise, we are creating the Violet Crown Amphitheater endowment, the beneficiaries
of which have been selected from among local private sector non-profits with well-defined missions focused
on natural resource preservation, the performing arts, and the mental, physical and spiritual health, welfare,
safety and education of our artists and the community at large. Once selected based on relevancy,
apportionment among the beneficiaries was predicated on the depth of other funding sources available to
those organizations; not their current level of outreach. Those organizations with less opportunity to secure
funding elsewhere were given a higher relative percentage participation in future proceeds.
Initial beneficiaries include but will not be limited to The Nature Conservancy (Texas), Hill Country
Conservancy, Natural Resources Defense Council, HAAM, SIMS, SAFE, CASA, 100 Club of Central Texas,
National Fallen Firefighters Association, KLRU Public Television, KUT Public Radio, The Texas Tribune,
Austin Symphony Orchestra, Austin Opera, Ballet Austin, Zachary Scott Theater, TED, and the Planetary
Society. VCA intends to implement the most modern ticketing technology such that at the moment a ticket is
purchased, the endowment assessment will be fractionalized and delivered to the beneficiaries accounts
directly, purchase-by-purchase, in real time, eliminating delays and overhead costs of administration to zero,
thereby maximizing proceeds to the beneficiaries.
ENVIRONMENT
The Nature Conservancy and the Hill Country Conservancy have worked effectively throughout the years to
secure specific tracts of land for preservation. The near perfect natural conditions (still, quiet, dark and
beautiful) for the Violet Crown Amphitheater exist today because of the Balconies Canyonland Preserve to
the east and the Nature Conservancy Preserve lands and Shield Ranch Conservation Easement to the west.
The National Resources Defense Council for its part acts on a national basis as an environmental plaintiff
helping form the basis for conservation policy at the federal level.
HEALTH
The Health Alliance for Austin Musicians (HAAM) provides assistance to musicians and other performing
artists with respect to healthcare which is otherwise unavailable primarily due to a lack of revenue to pay for
expensive private individual health insurance policies. Concurrently, SIMS fulfills a similar role for mental
health in recognition of the challenges which artists and performers face disproportionately.
WELFARE
The SAFE Alliance (the merger of Safe Place and the Austin Children’s Shelter) provides a wide range of
assistance to at-risk women and children in our community. Concurrently, Court Appointed Special
Advocates (CASA) provides legal assistance to at-risk children who would not otherwise have representation
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in the system. The SAFE and CASA roles are analogous to the HCC/TNC efforts in respect to the NRDC
efforts relative to the environment. In a complex world both are necessary components to achieve the best
outcomes in their respective areas of concern.
SAFETY
The Violet Crown Amphitheater has been designed to a 21st century specification with respect to all life
safety considerations. Nonetheless, the burden in an individual or collective emergency ultimately rests with
our EMTs, law enforcement, and fire departments. In respect to our first responder community, VCA supports
the 100 Club of Central Texas, and the National Fallen Firefighters Association. In addition to the
Endowment, VCA is also providing ground handling facilities for Starflight, and permanent emergency
response command centers in the stage building at the bottom of the bowl and in the concourse building at
the top of the bowl.
MEDIA
KLRU and KUT have long played a vital role in our community by providing reporting which is well
researched and free of the editorial content. Even more so, both outlets have deep roots in the Austin music
scene, having participated materially in its founding and continued growth and promotion over many
decades. For its part, the Texas Tribune is a rare professional media organization operated as a non-profit
which has demonstrated its commitment to high quality and apolitical reporting on issues of specific
importance to Texans.
ARTS
VCA’s support of the big four fine arts organizations goes without the need for explanation. It is our hope that
these organizations will grow to a point where they can expand their repertories to include summer programs
under the stars as is the case at the Hollywood Bowl (LA Philharmonic), Red Rocks (Colorado Symphony),
Ravinia (Chicago Symphony Orchestra), Tanglewood (Boston Pops) and Wolf Trap (National Opera), to
name only a few.
EDUCATION
VCA intends to host its own TEDx or similar lecture series which will be focused on music, the performing
arts generally, as well as a broad arts and sciences program of learning. The venue will be open to the public
on non-show nights at no cost for star parties similar to those held at the McDonald Observatory in Ft. Davis
and elsewhere.
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Photo: top, Earl J. McGehee
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It resonateswithin us
violetcrownaustin.com/experience
EXPERIENCE
Video Player
0:00
With a capacity of 20,000 persons, the Violet Crown Amphitheater is the largest music-specific venue in the region with the largest permanent stage. While well within
the Austin metropolitan area, it is enveloped in the dark, still, and quiet of the surrounding preserves. Listening to music outdoors under a blanket of stars is as old as
humanity itself. That tradition will continue here undisturbed for generations to come.
COMPARABLE VENUES
The Violet Crown Amphitheater has been designed for 21st century Austin which is to say unique, current and relevant from experiential, architectural, environmental
and social perspectives. It nonetheless has its roots in the great venues of the past having been modeled most closely on Red Rocks in Denver, and the Hollywood
Bowl in Los Angeles. These venues were recently rated in Rolling Stone as the No. 1 and No. 2 respectively in the country. The following are links to these and other
venues which are indicative of what we hope to achieve.
RED ROCKS
HOLLYWOOD BOWL
RAVINIA
WOLF TRAP
SANTE FE OPERA
TANGLEWOOD
Video Player
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0:00
ETYMOLOGY OF THE VIOLET CROWN

In one of the surviving fragments, the lyric poet Pindar writes of Athens “City of Light, with thy violet crown, beloved of the poets, thou art the bulwark of Greece.” The
climate of Athens is characterized by low humidity and a high percentage of dust in the air, making sunsets display hues of violet and purple and the surrounding
mountains often appear immersed in a purple haze.
During the 19th century, residents began to call Austin the “Athens of the South” due to the aspirations of the University of Texas. With this connection established in
the minds of local residents and similar purple sunsets as in Pindar’s description, Austin became the modern era’s City of the Violet Crown with that phrase first
appearing in the Austin Daily Statesman (now the Austin American Statesman) on May 5th, 1890. While humidity levels are higher in Austin than in Athens, global
wind patterns bring dust into the region high in the atmosphere giving local sunsets this same violet and purple hue.
Technically speaking, this atmospheric phenomenon is one of an anti-twilight arch visible shortly aver sunset (and before sunrise) near the anti-solar point when a
purple glow appears above the horizon. Sunlight is refracted by the fine particles high in the atmosphere with the color due to the backscatter of reddening light from
the rising or setting Sun. As twilight progresses, the arch of color, or violet crown, is separated from the horizon by the dark band of Earth’s shadow.
Mythologically, the common name for this dark band is the Necklace of Aphrodite (Greek) or Band of Venus (Roman); both goddesses of love. Inside the necklace was
kept the power over the heart. The greatest elongation between the planet Venus and the Sun is only 46 degrees, so Venus, even when visible, is never located
opposite the Sun relative to the Earth, and hence never actually in the Band of Venus. The inference is not astronomical, rather symbolic or allegorical in equating the
eternal beauty of the Earth’s twilight and the ancient gods who once inhabited those heavens, albeit in all their intense humanity.
The Violet Crown Amphitheater sits on the western slope of one of the highest elevations in the region surrounded at night by the dark stillness of nature. With most
shows beginning to seat around twilight, the colorful Central Texas sunsets will be on display with the Violet Crown and Necklace playing out in the mind’s eye as they
have done and will do for eternities past and future.
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Christine Haas
violetcrownaustin.com/contact
CONTACT
MEDIA Spokesperson
512-751-1592
christinehaasmedia@gmail.com
1/1
Environmental groups raise concerns about Violet Crown

amphitheater project proposed west of Austin
bizjournals.com/austin/news/2021/11/05/violet-crown-nature-conservancy-sierra-club.html
Enlarge
This site in the city of Austin's extraterritorial jurisdiction is being eyed for a major mixed-use development,
but environmental concerns are being raised.
Arnold Wells/ABJ
By Justin Sayers – Staff Writer, Austin Business Journal

Nov 5, 2021, 3:53pm EDT
Powerful environmental groups are taking aim at the 71-acre Violet Crown project proposed near Bee Cave,
saying it is "about the worst possible location to build a new Austin entertainment district" because of its
proximity to environmentally sensitive areas.
1/6
Austin Business Journal reported last month that International Development Management Co. wants to build
an entertainment and residential project that includes a 20,000-seat amphitheater, two luxury apartment
towers, a distillery and tasting room, a Top Golf-style driving range and parking garage. The site is northwest
of State Highway 71 and Southwest Parkway.
Representatives from a number of groups — including the Nature Conservancy, Greater Edwards Aquifer
Alliance, Sierra Club Austin, Save Our Springs and Save Barton Creek Association — have released
statements opposing the project, with some saying they were "alarmed" after reading about it in news
reports.
The biggest concerns are the project's proximity to both Barton Creek and the 4,000-acre Barton Creek
Habitat Preserve, which is owned by the nonprofit Nature Conservancy, one of the world's largest
environmental groups.
"Potential impacts from the mixed-use, proposed development and 20,000-seat music venue in southwest
Austin are very concerning — especially considering the investment that the citizens of Austin and Travis
County, The Nature Conservancy, and our government partners have made to protect our aquifer and Hill
Country habitat," Claire Everett, communications manager for the Nature Conservancy, wrote in a Nov. 2
post on the group's website. "The proposed project sits immediately adjacent to Barton Creek Habitat
Preserve; some of the best golden-cheeked warbler habitat in Travis County would be severely
compromised with the traffic, light and noise that a development of this scale would create."
Barton Creek has already been experiencing issues with toxic algae about a half-mile downstream from the
site, and environmentalists are concerned the construction and operation of such a facility could add
pollutants to the creek. The preserve is home to a number of endangered species, which could be impacted
by light, noise, traffic and water pollution from the development.
"If they want to do something like this further out in a more urban area, we certainly wouldn't have a problem
with it," said Mike Clifford, technical director for The Greater Edwards Aquifer Alliance. "Right now it's in a
place that's just so environmentally sensitive."
2/6
Enlarge
A map of the Violet Crown development's location based on the environmental areas that surrounds it.
Groups are concerned that the project will negatively affect the adjacent Barton Creek and Nature Preserve.
Sierra Club
IDM President Craig Bryan previously said the project, which is located in unincorporated Travis County, in
the city of Austin's extraterritorial jurisdiction, would still adhere to Austin's noise ordinances. He said the site
is going to be built with natural limestone, have a low-carbon footprint with the banning of single-use plastics
and place trees on the apartment towers to be more environmentally conscious. He said the music venue
would reserve portions of ticket sales for an endowment fund that benefits the media, arts education, at-risk
populations and environmental causes. The development team has worked with consultants to direct sound
from concerts away from neighbors.
In a response to the environmental groups' concerns, Bryan said in a statement that they "will continue to
utilize the very best experts and researchers to help us take every step necessary to preserve the
environment and protect the community that surrounds it."
Bryan previously said the project would add a crown jewel to the Austin area's already bustling live music
scene. He listed inspirations for Violet Crown ranging from the Hollywood Bowl in Los Angeles to Red Rocks
Park and Amphitheater just west of Denver, where he attended concerts growing up in Colorado.
"Austin has been given the moniker of the [Live] Music Capital of the World. By God, I'm going to solidify that
with this project," Bryan had said, adding that the development should cost between $600 million and $750
million.
3/6
Enlarge
The Violet Crown site, northwest of State Highway 71 and Southwest Parkway.
Arnold Wells/ABJ
The residential portion of the proposed development is supposed to feature 475 units spread across two
towers standing 29 and 20 stories tall, with amenities including pools, restaurants, shops, a night club, pool
club and dancehall. The other amenities in the site plan include the 96-bay driving range, which can be
converted into a downward sloping stage with room for 3,000 people. Meanwhile, the distillery and tasting
room could double as a small acoustic venue for up to 400 people. There would be parking on-site for one-
third of all visitors, not including those living or staying on site.
Bryan said the development team aims to start vertical construction early next year. Elements of the project
could open in 2023.
Bleyl Engineering, a civil engineering firm with an Austin office, submitted construction permits for the project
to Travis County in August, public records show. As of Nov. 4 they were still listed as pending.
4/6
Enlarge
Craig Bryan
Arnold Wells/ABJ
Clifford said all the things the developers like about the site are what concern environmental groups. He said
"just the construction gives us nightmares," because of what nutrient pollution could add to Barton Creek,
which is already experiencing worsening issues with toxic algae in Austin's creeks and rivers.
"Barton Creek already has so much stuff going into it. Barton Creek is what feeds Barton Springs. And
Barton Springs is the crown jewel of Austin," he said.
Clifford, who is a musician, also questioned whether the project was needed, due to the presence of other
large venues in Austin, including an outdoor one at the Circuit of The Americas race track that has a capacity
of about 14,000, not to mention the Backyard being redeveloped nearby, which should have a venue able to
hold about 3,700.
Everett wrote amid "unprecedented land development pressures" that the "conservation value is paramount"
for the Barton Creek Habitat Preserve, which the Nature Conservancy acquired in 1994.
"Not only does this property safeguard the quality and quantity of water in the Barton Springs recharge and
contributing zones, but it also provides habitat for endangered golden-cheeked warblers and numerous
wildlife endemic to Central Texas," she wrote.
Clifford said they've been organizing environmental groups and plan to fight the development. The project is
currently in an administrative process with the city of Austin for the project to obtain municipal water
approvals and site plan approvals, a requirement necessitated by the fact that it's in the city's extraterritorial
jurisdiction. Records show city staff issued comments on the site plan in September, with a list of
recommendations, requirements and updates.
5/6
Clifford said they haven't reached out to Bryan and his team because they feel the only way the project will
work from an environmental standpoint is without the amphitheater.
"We don't really feel we can have that discussion," he said. "We just feel it will go nowhere, unfortunately."
6/6
JS 44 (Rev. 10/20) Case 1:21-cv-01142-RP Document
CIVIL COVER1-7 Filed 12/16/21 Page 1 of 1
SHEET
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
I. (a) PLAINTIFFS DEFENDANTS
Violet Crown Cinemas, LLC International Development Management, LLC
(b) County of Residence of First Listed Plaintiff Travis County of Residence of First Listed Defendant Travis
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.
(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)
Baxter W. Banowsky, Banowsky & Levine, P.C., 12801
N. Central Expy, Ste 1700, Dallas, TX 75243 (214)
871-1300
II. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
1 U.S. Government 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State 1 1 Incorporated or Principal Place 4 4 x
of Business In This State
2 U.S. Government 4 Diversity Citizen of Another State 2 2 Incorporated and Principal Place 5 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State
Citizen or Subject of a 3 3 Foreign Nation 6 6

Foreign Country
IV. NATURE OF SUIT (Place an “X” in One Box Only) Click here for: Nature of Suit Code Descriptions.
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
110 Insurance PERSONAL INJURY PERSONAL INJURY 625 Drug Related Seizure 422 Appeal 28 USC 158 375 False Claims Act
120 Marine 310 Airplane 365 Personal Injury - of Property 21 USC 881 423 Withdrawal 376 Qui Tam (31 USC
130 Miller Act 315 Airplane Product Product Liability 690 Other 28 USC 157 3729(a))
140 Negotiable Instrument Liability 367 Health Care/ 400 State Reapportionment
150 Recovery of Overpayment 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS 410 Antitrust
& Enforcement of Judgment Slander Personal Injury 820 Copyrights 430 Banks and Banking
151 Medicare Act 330 Federal Employers’ Product Liability 830 Patent 450 Commerce
152 Recovery of Defaulted Liability 368 Asbestos Personal 835 Patent - Abbreviated 460 Deportation
Student Loans 340 Marine Injury Product New Drug Application 470 Racketeer Influenced and
(Excludes Veterans) 345 Marine Product Liability 840 Trademark Corrupt Organizations
153 Recovery of Overpayment Liability PERSONAL PROPERTY LABOR 880 Defend Trade Secrets 480 Consumer Credit
of Veteran’s Benefits 350 Motor Vehicle 370 Other Fraud 710 Fair Labor Standards Act of 2016 (15 USC 1681 or 1692)
160 Stockholders’ Suits 355 Motor Vehicle 371 Truth in Lending Act 485 Telephone Consumer
190 Other Contract Product Liability 380 Other Personal 720 Labor/Management SOCIAL SECURITY Protection Act
195 Contract Product Liability 360 Other Personal Property Damage Relations 861 HIA (1395ff) 490 Cable/Sat TV
196 Franchise Injury 385 Property Damage 740 Railway Labor Act 862 Black Lung (923) 850 Securities/Commodities/
362 Personal Injury - Product Liability 751 Family and Medical 863 DIWC/DIWW (405(g)) Exchange
Medical Malpractice Leave Act 864 SSID Title XVI 890 Other Statutory Actions
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS 790 Other Labor Litigation 865 RSI (405(g)) 891 Agricultural Acts
210 Land Condemnation 440 Other Civil Rights Habeas Corpus: 791 Employee Retirement 893 Environmental Matters
220 Foreclosure 441 Voting 463 Alien Detainee Income Security Act FEDERAL TAX SUITS 895 Freedom of Information
230 Rent Lease & Ejectment 442 Employment 510 Motions to Vacate 870 Taxes (U.S. Plaintiff Act
240 Torts to Land 443 Housing/ Sentence or Defendant) 896 Arbitration
245 Tort Product Liability Accommodations 530 General 871 IRS—Third Party 899 Administrative Procedure
290 All Other Real Property 445 Amer. w/Disabilities - 535 Death Penalty IMMIGRATION 26 USC 7609 Act/Review or Appeal of
Employment Other: 462 Naturalization Application Agency Decision
446 Amer. w/Disabilities - 540 Mandamus & Other 465 Other Immigration 950 Constitutionality of
Other 550 Civil Rights Actions State Statutes
448 Education 555 Prison Condition
560 Civil Detainee -
Conditions of
Confinement
V. ORIGIN (Place an “X” in One Box Only)
1 Original 2 Removed from 3 Remanded from 4 Reinstated or 5 Transferred from 6 Multidistrict 8 Multidistrict
Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation -
(specify) Transfer Direct File
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity) :
15 U.S.C. § 1121
VI. CAUSE OF ACTION Brief description of cause:
Infringement of VIOLET CROWN Trademark
VII. REQUESTED IN CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RULE 23, F.R.Cv.P. JURY DEMAND: Yes No
VIII. RELATED CASE(S)
(See instructions):
IF ANY JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
12/16/2021
FOR OFFICE USE ONLY
RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

Violent Crown Trademark Suit

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Case 1:21-cv-01142-RP Document 1 Filed 12/16/21 Page 1 of 14

UNITED STATES DISTRICT COURT

VIOLET CROWN CINEMAS, LLC, §

PLAINTIFF’S ORIGINAL COMPLAINT

against International Development Management, LLC (“IDM”), and states:

Austin’s premiere entertainment venues.

2. While Violet Crown Austin primarily exhibits motion pictures, it also

connection with movie theaters (collectively, the “VIOLET CROWN Marks”).1

following logo to promote its development:

developer of the VIOLET CROWN AMPHITHEATER, pleaded guilty to a charge of indecent

6. Because of the obvious similarity between VIOLET CROWN AMPHITHEATER

principal place of business located at 1614 W. 5th Street, Austin, TX 78703.

8. International Development Management, LLC is a Delaware limited liability

III. JURISDICTION AND VENUE

employment inside or outside Texas and is therefore doing business in Texas.

11. The Western District of Texas is a proper venue pursuant to 28 U.S.C. §

claims occurred in this District.

IV. FACTS COMMON TO ALL CLAIMS FOR RELIEF

A. The VIOLET CROWN Mark.

always looks to connect with community members.

might be expected from other theater venues.

various community events.

Marks with Violet Crown.

B. IDM’s Unlawful Activity.

20. IDM’s website, http://violetcrownaustin.com, promotes this new development as

THE ULTIMATE OUTDOOR VENUE

THE HIGH LIFE

“Representatives from a number of groups — including the Nature Conservancy, Greater

nonprofit Nature Conservancy, one of the world's largest environmental groups.”

Milam, pled guilty to charges of indecent exposure.

23. On information and belief, IDM knowingly, willfully, intentionally, and

maliciously adopted the VIOLET CROWN AMPHITHEATER mark which is confusingly

similar to the VIOLET CROWN Marks.

FIRST CLAIM FOR RELIEF

25. IDM’s use of the confusingly similar VIOLET CROWN AMPHITHEATER is

26. IDM’s infringing VIOLET CROWN AMPHITHEATER mark is confusingly

Violet Crown has no adequate remedy at law.

and irreparable harm.

U.S.C. §§ 1114, 1116, and 1117.

SECOND CLAIM FOR RELIEF

approval of Violet Crown.

for which Violet Crown has no adequate remedy at law.

irreparable injury of Violet Crown.

fees under 15 U.S.C. §§ 1125(a), 1116, and 1117.

THIRD CLAIM FOR RELIEF

the infringing VIOLET CROWN AMPHITHEATER mark.

AMPHITHEATER mark, which is likely to dilute the distinctiveness of Violet Crown’s

distinguish Violet Crown’s services.

under 15 U.S.C. §§ 1125(c), 1116, and 1117.

FOURTH CLAIM FOR RELIEF

remedy at law for this injury.

irreparable injury of Violet Crown.

determined or ascertainable. At a minimum, however, Violet Crown is entitled to injunctive

FIFTH CLAIM FOR RELIEF

distinguish Violet Crown’s goods.

well as, punitive damages, and reasonable attorneys’ fees.

PRAYER FOR RELIEF

WHEREFORE, Violet Crown prays that:

a. using the infringing VIOLET CROWN AMPHITHEATER mark on or in

connection with any of IDM’s goods or services;

imitation, or simulation of Violet Crown’s VIOLET CROWN Marks on or in connection

with IDM’s goods or services;

in connection with IDM’s goods or services that is a copy, reproduction, colorable