Figs v. My Open Heart - Complaint

Case 2:22-cv-06129 Document 1 Filed 08/29/22 Page 1 of 30 Page ID #:1
1 David H. Boren, Esq. SBN 186316

dboren@rlfllp.com
2
RITHOLZ LEVY FIELDS LLP
3 10940 Wilshire Boulevard, Suite 1600
Los Angeles, CA 90024
4
Bus: (310) 443-4176; Fax: (310) 443-4220
5
Joseph C. Gioconda, Esq.
6
joseph.gioconda@giocondalaw.com
7 Gioconda Law Group PLLC
100 Park Avenue, 16th Floor
8 New York, NY 10017
9 Bus: (212) 235-1220; Fax: (888) 697-9665
Application for Admission Pro Hac Vice to be Filed
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11 Attorneys for Plaintiff FIGS, INC.
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UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA
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15
FIGS, INC., a Delaware corporation;
) Case No.: 22-CV-06129
16 )
17
Plaintiff, ) COMPLAINT for
)
18 vs. ) 1. Design Patent Infringement
19 ) (US D946,867S)
MY OPEN HEART LLC, a California ) 2. Design Patent Infringement
20 limited liability company; ) (US D951,594S)
21 ) 3. Design Patent Infringement
Defendant. ) (US D948,170S)
22
) 4. Design Patent Infringement
23
_________________________________ ) (US D950,196S)
24 5. Design Patent Infringement
(US D950,890S)
26 (US D949,517S)
7. Design Patent Infringement
27
(US D949,518S)
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COMPLAINT FOR DESIGN PATENT INFRINGEMENT, FALSE ASSOCIATION, FALSE

ADVERTISING AND UNFAIR COMPETITION

2 (US D949,516S)
9. Design Patent Infringement
3 (US D957,092S)
4 10.False Advertising In Violation
of 15 U.S.C. § 1125(a)(1)(A)
5
11.False Advertising In Violation
6 of 15 U.S.C. § 1125(a)(1)(B)
7 12.Unfair Competition In
Violation of Cal. Bus. & Prof.
8
Code § 17200
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10 JURY TRIAL DEMANDED
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1
COMPLAINT
2
Plaintiff FIGS, INC. (“Plaintiff” or “FIGS”) alleges the following for its
3
Complaint against Defendant MY OPEN HEART LLC (“Defendant” or “My Open
4
Heart”):
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6
JURISDICTION
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1. This Court has subject matter jurisdiction over FIGS’ Lanham Act
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claims (15 U.S.C. § 1125) and design patent claims (35 U.S.C. §§ 281, 289) under 28
9
U.S.C. § 1338 (acts of Congress related to intellectual property) and 28 U.S.C. § 1331
10
(federal question). This Court has subject matter jurisdiction over FIGS’ related
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California state law claims under 28 U.S.C. § 1367 (supplemental jurisdiction).
12
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VENUE
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2. Venue is proper in this district pursuant to 28 U.S.C. § 1400(b) as
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Defendant resides and is subject to personal jurisdiction in this district. In addition,
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Defendant has committed acts of infringement in this district and Defendant has a
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regular and established place of business in this district.
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19
PARTIES
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3. Plaintiff is a Delaware corporation with a principal place of business at
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2834 Colorado Avenue, Suite 100, Santa Monica, CA 90404.
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4. Defendant is a California limited liability company in good standing,
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formed on or about October 28, 2020, with a principal place of business at 8851
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Garden Grove Boulevard, Suite 103, Garden Grove CA 92844. Ms. Catherine Bui
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and the California Secretary of State are designated agents for Defendant.
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1
1
PATENTS-IN-SUIT
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I. U.S. Patent No. D946,867S (“RAFAELA”)
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5. On March 29, 2022, the United States Patent and Trademark Office
4
(“USPTO”) duly and legally issued U.S. Patent No. D946,867S entitled “SCRUB
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TOP” (Exhibit 1) (“the ’867 Patent”).
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6. The ’867 Patent is valid and enforceable.
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7. FIGS is the sole assignee and owner of all right, title and interest to the
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’867 Patent.
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II. U.S. Patent No. D951,594S (“YOLA”)
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8. On May 17, 2022, the USPTO duly and legally issued U.S. Patent No.
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D951,594S entitled “SCRUB PANTS” (Exhibit 2) (“the ’594 Patent”).
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13
14
’594 Patent.
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III. U.S. Patent No. D948,170S (“CASMA”)
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11. On April 12, 2022, the USPTO duly and legally issued U.S. Patent No.
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D948,170S entitled “SCRUB TOP” (Exhibit 3) (“the ’170 Patent”).
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19
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’170 Patent.
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IV. U.S. Patent No. USD950,196S (“LEON”)
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USD950,196S entitled “SCRUB TOP” (Exhibit 4) (“the ’196 Patent”).
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’196 Patent.
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V. U.S. Patent No. D950,890S (“KADE”)
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2
1
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’890 Patent.
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VI. U.S. Patent No. D949,517S (“CHISEC”)
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D949,517S entitled “SCRUB TOP” (Exhibit 6) (“the ’517 Patent”).
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9
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’517 Patent.
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VII. U.S. Patent No. D949,518S (“TANSEN”)
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13
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15
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’518 Patent.
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VIII. U.S. Patent No. D949,516S (“LIVINGSTON”)
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19
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21
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’516 Patent.
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IX. U.S. Patent No. D957,092S (“AXIM”)
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29. On July 12, 2022, the USPTO duly and legally issued U.S. Patent No.
25
26
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’092 Patent.
3
1
FIGS’ ADDITIONAL INTELLECTUAL PROPERTY
2
32. FIGS owns numerous registered or common law trade names,
3
trademarks or service marks, including “FIGS”, the “Cross & Shield” logo, “Threads
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for Threads”, “FIONtechnology”, “FIONx”, “Technical Comfort” and “Awesome
5
Humans”.
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33. In addition to the Patents-in-Suit identified above, many of FIGS’
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products have acquired distinctiveness in the marketplace, such as its well-known and
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commercially successful ZAMORA scrub pants design. See Exhibit 10.
9
10
COMMON FACTUAL ALLEGATIONS
11
FIGS
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34. FIGS was founded in 2013 and is a founder-led, direct-to-consumer
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healthcare apparel and lifestyle brand company. It designs and sells scrubwear, and
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other non-scrub offerings, such as lab coats, underscrubs, outerwear, activewear,
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loungewear, compression socks, footwear and masks.
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35. The journey of FIGS began almost a decade ago after FIGS’ co-founder,
17
Heather Hasson, grew disillusioned with the substandard apparel options available to
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healthcare professionals, including uncomfortable and unflattering scrubs that made
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working lengthy shifts under difficult circumstances even more challenging and
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strenuous.
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36. Although multi-billion dollar companies utilized innovative fabric
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blends, smart technology, and/or modernized design for other industries such as
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athletics and athleisure, Ms. Hasson recognized a market need specifically for
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healthcare professionals. Ms. Hasson thought to herself: What about the people
25
saving lives? Who is focused on them? To FIGS, focusing on the needs of those
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helping to care for patients, cure diseases, and save lives was imperative.
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37. With an understanding of design, fashion, and fabric technology, FIGS
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modernized and revolutionized medical apparel by offering fashion-forward
4
1
alternatives that featured purposeful designs. The outcome was a major disruption to
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the existing industry, and a fashion and innovation leap from conventional healthcare
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apparel that was notoriously ill fitting, uncomfortable, baggy, boxy, and lacking in
4
design. The advancements in design, comfort, and style that FIGS blended and
5
infused into the medical apparel industry are unprecedented.
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38. FIGS’ innovative approach did not stop with its products. It also
7
disrupted the industry’s historical distribution model, which required healthcare
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professionals to physically travel to brick-and-mortar stores to purchase their
9
uniforms. FIGS has built the largest online direct-to-consumer platform in healthcare
10
apparel, leading the industry in the shift to digital.
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39. As a result of its many innovations and disruption of a centuries-old
12
industry, FIGS has enjoyed remarkable success in the healthcare apparel space. Every
13
year between its founding in 2013 and 2020, FIGS grew its net revenues by triple
14
digit percentages, and it reached net revenues of approximately $420 million in 2021.
15
By June 30, 2022, FIGS’ active customer base had grown to be in excess of 2.0
16
million. In May 2021, FIGS went public through an initial public offering with a
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multi-billion dollar valuation.
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40. FIGS’ immense growth is attributable to its success in disrupting the
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medical apparel industry in three primary ways: (1) it branded a previously
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unbranded industry; (2) it de-commoditized a previously commoditized product—
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redefining what scrubs are by creating technically advanced apparel and products that
22
feature an unmatched combination of comfort, durability and style, all at an
23
affordable price; and (3) through direct to customer relationships, it built a
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community and lifestyle around a profession, revolutionizing the large and
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fragmented healthcare apparel market and becoming the industry’s category-defining
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healthcare apparel and lifestyle brand.
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28

5
1
MY OPEN HEART
2
41. My Open Heart is a California limited liability company in good
3
standing, formed on or about October 28, 2020, with its principal place of business at
4
8851 Garden Grove Boulevard, Suite 103, Garden Grove, CA 92844.
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42. My Open Heart sells its products online direct to consumers.
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43. My Open Heart maintains a social media presence on Facebook,
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Instagram, Twitter and others.
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44. My Open Heart’s website(s) and social media presence are national, if
9
not international, and actively market and solicit sales to customers nationwide.
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45. My Open Heart advertises and sells it products to consumers located
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throughout the United States, including in California and this Judicial District.
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DEFENDANT’S WRONGFUL CONDUCT
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46. On information and belief, Defendant sought to leverage FIGS’ success
14
and recognition in the marketpace by intentionally designing as many as ten (10)
15
different styles of scrubs and other products to closely resemble FIGS’ patented
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and/or distinctive product designs, and to benefit from consumer confusion before,
17
during and after the point of sale.
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47. Upon information and belief, Defendant also intentionally placed its
19
logo in the same or a similar location as the logo that appears on FIGS’ products.
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48. Defendant’s logo even uses a similar cross with slanted edges inside a
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heart to conceptually simulate the cross in FIGS’ logo:
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FIGS’ CROSS MY OPEN HEART’S CROSS
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14 49. Defendant’s products are of a lower quality and price point compared to
15 FIGS’ products and prices.
16 50. On or about July 1, 2021, Defendant was given actual notice of certain
17 of FIGS’ intellectual property rights by written correspondence. See Exhibit 11.
18 51. On or about July 12, 2021, Ms. Caroline David, on behalf of Defendant,
19 responded by stating that the photographs of the accused products were on an “old
20 website,” and were “stock photos” from “MediChic” and “Med Couture.”
21 52. Defendant also contended that she “closed Open Heart Scrubs” as of
22 December 31, 2020.
23 53. However, as of today’s filing, My Open Heart is still an active limited
24 liability company in good standing with the State of California.
25 54. My Open Heart’s U.S. websites, which include https://mohscrubs.com/
26 and https://myopenheart.us/ , are still active and state:
27
28

7
1 WE WILL BE BACK
2
Thank you for being a part of our story, we appreciate our customers who believe in us
3 and our products. We got so many valuable feedbacks that makes us feel confident that the
4 next go around will be even better.
5 We will be back with improved products and service, please look out for us!
6
55. Furthermore, Defendant’s websites continue to state that many of its
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infringing products are only “temporarily sold out,” and other products appear
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currently available for sale.
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56. Finally, upon information and belief, Defendant owns and maintains an
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active Vietnamese website located at: https://mohscrubs.com.vn
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57. On this website, Defendant continues to actively advertise, solicit and
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market infringing products including scrubs.
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58. As a summary, below is a chart containing the Patents-in-Suit, FIGS’
14
claims, FIGS product names, and the Defendant’s accused product names:
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1 Claim FIGS’ Product Name U.S Patent Accused MOH

2 Number Number Product Name
3 RAFAELA D946,867S Mandarin Collar
I. Scrub Top
4
5 YOLA D951,594S 10 Pocket Scrub Pant
II.
6 CASMA D948,170S 3 Pocket Scrub Top
III.
7
LEON D950,196S 2 Pocket Scrub Top
8 IV.
KADE D950,890S 4 Pocket Cargo Scrub
9 V. Pant
10
CHISEC D949,517S 3 Pocket Scrub Top
11 VI.
12 TANSEN D949,518S 5 Pocket Jogger Scrub
VII. Pants
13
14
LIVINGSTON D949,516S 2 Pocket Scrub Pant
VIII.
15 AXIM D957,092S 5 Pocket Jogger Scrub
IX. Pants
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17 I to IX plus N/A MOH Products I to IX
X. ZAMORA
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I to IX plus N/A MOH Products I to IX
19 XI. ZAMORA
20 I to IX plus N/A MOH Products I to IX
XII. ZAMORA
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25
26
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1
FIRST CLAIM FOR RELIEF
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(Infringement of U.S. Patent No. D946,867S)
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35 U.S.C. § 271
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(“RAFAELA”)
5
59. All previous paragraphs are incorporated by reference as if fully set forth
6
herein.
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60. As shown by the side-by-side comparison below, the Defendant has
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misappropriated and infringed U.S. Patent No. D946,867S (the ’867 Patent), attached
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as Exhibit 1, in the accused product design.
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61. Below is a diagram showing a comparison of one of the frontal figures
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of FIGS’ “RAFAELA” Product and the ’867 Patent to at least one of Defendant’s
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products:
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62. The Defendant’s product design is deceptively similar to and
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substantially the same as the patented design of the ’867 Patent when viewed through
3
the eyes of the ordinary observer and considering the infringing product as a whole.
4
63. Defendant’s unauthorized making, use, importation into the United
5
States, offer for sale, and/or sale of at least the ’867 design identified in this
6
Complaint during the term of the patent infringes the ’867 Patent.
7
8
States, offer for sale, and/or sale of at least one of the products identified in this
9
Complaint, which incorporates the patented design of the ’867 Patent, has caused, and
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will continue to cause, FIGS financial and reputational harm.
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65. The Defendant’s infringement of the ’867 Patent has been and continues
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to be willful and deliberate.
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66. Unless the Defendant’s acts are enjoined, FIGS will suffer irreparable
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injury for which there is no adequate remedy at law.
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SECOND CLAIM FOR RELIEF
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35 U.S.C. § 271
19
(“YOLA”)
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herein.
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25
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of FIGS’ “YOLA” Product and the ’594 Patent to at least one of Defendant’s
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products:
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States, offer for sale, and/or sale of at least the design identified in this Complaint
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during the term of the patent infringes the ’594 Patent.
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States, offer for sale, and/or sale of at least one product design identified in this
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THIRD CLAIM FOR RELIEF
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35 U.S.C. § 271
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(“CASMA”)
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herein.
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of FIGS’ “CASMA” Product and the ’170 Patent to at least one of Defendant’s
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products:
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FOURTH CLAIM FOR RELIEF
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35 U.S.C. § 271
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(“LEON”)
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herein.
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of FIGS’ “LEON” Product and the ’196 Patent to at least one of Defendant’s
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products:
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FIFTH CLAIM FOR RELIEF
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3
35 U.S.C. § 271
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(“KADE”)
5
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herein.
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10
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of FIGS’ “KADE” Product and the ’890 Patent to at least one of Defendant’s
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products:
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26 94. The Defendant’s product design is deceptively similar to and
27 substantially the same as the patented design of the ’890 Patent when viewed through
28 the eyes of the ordinary observer and considering the infringing product as a whole.

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13
SIXTH CLAIM FOR RELIEF
14
15
35 U.S.C. § 271
16
(“CHISEC”)
17
18
herein.
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20
21
22
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of FIGS’ “CHISEC” Product and the ’517 Patent to at least one of Defendant’s
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products:
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SEVENTH CLAIM FOR RELIEF
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35 U.S.C. § 271
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(“TANSEN”)
5
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herein.
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10
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of FIGS’ “TANSEN” Product and the ’518 Patent to at least one of Defendant’s
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products:
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111. Defendant’s unauthorized use, importation into the United States, offer
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for sale, and sale of at least the design identified in this Complaint during the term of
6
the patent infringes the ’518 Patent.
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EIGHTH CLAIM FOR RELIEF
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18
35 U.S.C. § 271
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(“LIVINGSTON”)
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herein.
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of FIGS’ “LIVINGSTON” Product and the ’516 Patent to at least one of
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Defendant’s products:
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NINTH CLAIM FOR RELIEF
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3
35 U.S.C. § 271
4
(“AXIM”)
5
6
herein.
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10
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of FIGS’ “AXIM” Product and the ’092 Patent to at least one of Defendant’s
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products:
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25 126. The Defendant’s product design is deceptively similar to and
26 substantially the same as the patented design of the ’092 Patent when viewed through
27 the eyes of the ordinary observer and considering the infringing product as a whole.
28

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1
2
3
during the term of the patent infringes the ‘092 Patent.
4
5
6
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TENTH CLAIM FOR RELIEF
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(False Association)
15
15 U.S.C. § 1125(a)(1)(A)
16
17
herein.
18
132. The Defendant’s acts of designing and/or labeling and marketing its
19
products in a manner intended to sow confusion amongst consumers constitutes the
20
use of a word, term, name, symbol, or device, false designation of origin, false or
21
misleading description of fact, and false or misleading description of fact, which is
22
likely to cause confusion, or to cause mistake, or to deceive as to the affiliation,
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connection, or association of FIGS with Defendant, and as to the origin, sponsorship,
24
or approval of Defendant’s goods and FIGS’ commercial activities.
25
133. These acts have injured FIGS in its commercial reputation and sales,
26
including by misleading consumers to believe that Defendant’s products are the same
27
as FIGS’ products, but at a lower price, and/or that FIGS has entered a lower tier
28
price and product market.
23
1
2
3
4
ELEVENTH CLAIM FOR RELIEF
5
(False Advertising)
6
15 U.S.C. § 1125(a)(1)(B)
7
8
herein.
9
136. The Defendant’s acts of designing and/or labeling and marketing its
10
products in a manner intended to sow confusion amongst consumers constitutes the
11
use of a word, term, name, symbol, or device, false designation of origin, false or
12
misleading description of fact, and false or misleading description of fact, which in
13
commercial advertising or promotion misrepresents the nature, characteristics, and
14
qualities of Defendant’s goods and commercial activities.
15
137. In particular, the Defendant’s advertisements and designs as alleged
16
herein mislead consumers into believing its products are connected to FIGS.
17
138. On information and belief, such advertisements and designs have
18
actually deceived and have the tendency to deceive a substantial segment of
19
consumers in the healthcare apparel market.
20
139. The Defendant’s deception is material in that it is likely to influence
21
consumer purchasing decisions.
22
140. The Defendant has caused its false advertisements and designs to enter
23
interstate commerce.
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141. These acts have injured FIGS in its commercial reputation and sales,
25
including by misleading consumers to believe that Defendant’s products are the same
26
as FIGS’ products, but at a lower price, and/or that FIGS has entered a lower tier
27
price and product market.
28

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2
3
4
TWELFTH CLAIM FOR RELIEF
5
(Unfair Competition)
6
California Business & Professions Code § 17200
7
8
herein.
9
144. Defendant’s actions, as alleged above, constitute fraudulent, unfair and,
10
unlawful conduct in violation of 15 U.S.C. §1125(a) and California Business and
11
Professions Code § 17200. Accordingly, the Defendant’s actions are in violation of
12
§17200 of the Business and Professions Code.
13
145. Unless restrained by this Court, the Defendant will continue to engage in
14
such conduct. FIGS has no adequate remedy at law.
15
16
PRAYER FOR RELIEF
17
WHEREFORE, FIGS prays for judgment as follows:
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A. An accounting and award of all gains, profits, savings and advantages realized
19
by the Defendant for the wrongful conduct alleged herein.
20
B. An enhancement of FIGS’ monetary award by three times pursuant to 15
21
U.S.C. § 1117(a) and/or 35 U.S.C. Section 284.
22
C. Damages for Defendant’s design patent infringement pursuant to 35 U.S.C. §
23
289, including an award of the profits realized thereby, and/or a reasonable
24
royalty to be paid therefor.
25
D. A preliminary and permanent injunction restraining the Defendant, its affiliates
26
and subsidiaries, and any of their officers, directors, agents, employees,
27
servants, attorneys, successors, assigns and others controlling, controlled by or
28
affiliated with them and all those in privity or in active concert or participation
25
1
with any of the foregoing, and all those who receive actual notice by personal
2
service or otherwise from making, using, importing, exporting, distributing,
3
supplying, selling or offering to sell, or causing to be sold any product falling
4
within the scope of the Patents-in-Suit, or otherwise contributing or inducing
5
the infringement of any thereof.
6
E. A preliminary and permanent injunction restraining the Defendant, its affiliates
7
and subsidiaries, and any of their officers, directors, agents, employees,
8
servants, attorneys, successors, assigns and others controlling, controlled by or
9
affiliated with them and all those in privity or in active concert or participation
10
with any of the foregoing, and all those who receive actual notice by personal
11
service or otherwise from engaging in any acts that deceive or are likely to
12
deceive consumers as to the source of their goods.
13
F. Pre-judgment and post-judgment interest on FIGS’ monetary award.
14
G. The costs of this action.
15
H. An award of FIGS’ attorneys’ fees pursuant to 15 U.S.C. § 1117(a) and/or 35
16
U.S.C. § 285.
17
I. Any other further relief as this Court may deem just and proper.
18
19
20 Dated: August 29, 2022 RITHOLZ LEVY FIELDS LLP
21
22
23 By: /s/ David H. Boren
David H. Boren, Esq.
24
Attorneys for Plaintiff
25 FIGS, INC.
26
27
28

26
1
2 Dated: August 29, 2022 GIOCONDA LAW GROUP PLLC
3
4 By: /s/ Joseph C. Gioconda
5 Joseph C. Gioconda, Esq. (Pro hac vice to be
filed)
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7 FIGS, INC.
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1
JURY TRIAL DEMAND
2
Pursuant to Rule 38(b) of the Federal Rules of Civil Procedure, Plaintiff FIGS,
3
INC. demands a trial by jury of all issues so triable which have been set forth above
4
or which may be raised in this action.
5
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Dated: August 29, 2022 RITHOLZ LEVY FIELDS LLP
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9 By: /s/ David H. Boren
10 David H. Boren, Esq.
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FIGS, INC.
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Dated: August 29, 2022 GIOCONDA LAW GROUP PLLC
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16 By: /s/ Joseph C. Gioconda
Joseph C. Gioconda, Esq. (Pro hac vice to be
17
filed)
18 Attorneys for Plaintiff
19
FIGS, INC.
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Figs v. My Open Heart - Complaint

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Case 2:22-cv-06129 Document 1 Filed 08/29/22 Page 1 of 30 Page ID #:1

1 David H. Boren, Esq. SBN 186316

COMPLAINT FOR DESIGN PATENT INFRINGEMENT, FALSE ASSOCIATION, FALSE

1 8. Design Patent Infringement

COMPLAINT FOR DESIGN PATENT INFRINGEMENT, FALSE ASSOCIATION, FALSE

COMPLAINT FOR DESIGN PATENT INFRINGEMENT, FALSE ASSOCIATION, FALSE

COMPLAINT FOR DESIGN PATENT INFRINGEMENT, FALSE ASSOCIATION, FALSE

COMPLAINT FOR DESIGN PATENT INFRINGEMENT, FALSE ASSOCIATION, FALSE

COMPLAINT FOR DESIGN PATENT INFRINGEMENT, FALSE ASSOCIATION, FALSE

COMPLAINT FOR DESIGN PATENT INFRINGEMENT, FALSE ASSOCIATION, FALSE

1 Claim FIGS’ Product Name U.S Patent Accused MOH

COMPLAINT FOR DESIGN PATENT INFRINGEMENT, FALSE ASSOCIATION, FALSE

COMPLAINT FOR DESIGN PATENT INFRINGEMENT, FALSE ASSOCIATION, FALSE

COMPLAINT FOR DESIGN PATENT INFRINGEMENT, FALSE ASSOCIATION, FALSE

COMPLAINT FOR DESIGN PATENT INFRINGEMENT, FALSE ASSOCIATION, FALSE

COMPLAINT FOR DESIGN PATENT INFRINGEMENT, FALSE ASSOCIATION, FALSE

COMPLAINT FOR DESIGN PATENT INFRINGEMENT, FALSE ASSOCIATION, FALSE

COMPLAINT FOR DESIGN PATENT INFRINGEMENT, FALSE ASSOCIATION, FALSE

COMPLAINT FOR DESIGN PATENT INFRINGEMENT, FALSE ASSOCIATION, FALSE

COMPLAINT FOR DESIGN PATENT INFRINGEMENT, FALSE ASSOCIATION, FALSE

COMPLAINT FOR DESIGN PATENT INFRINGEMENT, FALSE ASSOCIATION, FALSE

COMPLAINT FOR DESIGN PATENT INFRINGEMENT, FALSE ASSOCIATION, FALSE

COMPLAINT FOR DESIGN PATENT INFRINGEMENT, FALSE ASSOCIATION, FALSE

COMPLAINT FOR DESIGN PATENT INFRINGEMENT, FALSE ASSOCIATION, FALSE

COMPLAINT FOR DESIGN PATENT INFRINGEMENT, FALSE ASSOCIATION, FALSE

COMPLAINT FOR DESIGN PATENT INFRINGEMENT, FALSE ASSOCIATION, FALSE

COMPLAINT FOR DESIGN PATENT INFRINGEMENT, FALSE ASSOCIATION, FALSE

COMPLAINT FOR DESIGN PATENT INFRINGEMENT, FALSE ASSOCIATION, FALSE

COMPLAINT FOR DESIGN PATENT INFRINGEMENT, FALSE ASSOCIATION, FALSE

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