Case 1:14-cv-09182-WHP Document 1 Filed 11/18/14 Page 1 of 24

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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

OEISSELE AUTOMATICS, LLC, and

WHO PROPERTIES, LLC
Plaintiffs,

Civil Action No.

14 CV

9182

(JURY TRIAL DEMANDED)

v.
JOE BOB OUTFITTERS, LLC
Defendant.

COMPLAINT

Plaintiffs Oeissele Automatics, LLC and WHO Properties, LLC (collectively

"Plaintiffs"), by their attorneys, hereby complain of Defendant Joe Bob Outfitters, LLC
("Defendant" or "Joe Bob") as follows:
NATURE OF THE ACTION

1.

This is an action for trademark infringement and unfair competition under Section

43 of the Lanham Act, 15 U.S.C. 1125, and under the law of the State of New York.
THE PARTIES

2.

Plaintiff Oeissele Automatics, LLC ("Oeissele"), the exclusive licensee of the

intellectual property cited herein, is a Pennsylvania limited liability company with a principal
place of business at 800 North Wales Road, North Wales, PA 19454.
3.

Plaintiff WHO Properties, LLC ("WHO Properties"), the owner of the

intellectual property cited herein, is a Pennsylvania limited liability company with a principal
place of business at 800 North Wales Road, North Wales, PA 19454.

Case 1:14-cv-09182-WHP Document 1 Filed 11/18/14 Page 2 of 24

4.

Upon information and belief, Defendant Joe Bob Outfitters, LLC is a Kansas

limited liability company with its principal place of business at 1340 280th Avenue, Hays,
Kansas 67601..
JURISDICTION AND VENUE
5.

This Court has jurisdiction over the federal claims of this action pursuant to 28

U.S.C. 1331, 28 U.S.C. 1338, and 15 U.S.C. 1121, and has jurisdiction over the state claims
under 28 U.S.C. 1338(b) and further pursuant to its supplemental jurisdiction under 28 U.S.C.
1367. The state claims asserted herein are so related to the federal claims as to form part of the
same case or controversy.
6.

This Court has personal jurisdiction over Defendant because it has engaged in acts

constituting doing business in this State, including in this judicial district, and has intentionally
directed its tortious activities toward New York, including this judicial district.

Upon

information and belief, Defendant has engaged in tortious acts within this State, including this
judicial district. These acts include but are not limited to acts of trademark infringement and
unfair competition directed to consumers in this State, including in this judicial district.
7.

Venue in this district is proper pursuant to 28 U.S.C. 1391(b).

STATEMENT OF FACTS

8.
States.

Established in 2004, Geissele is a premier trigger manufacturer in the United

Throughout the years, it has invested enormous amounts of time and money in

researching and developing unique designs of firearm tools and accessories including, but not
limited to, triggers, gas blocks, rails, and other components, that have been supplied to both
civilian consumers and the U.S. military, including Special Operations Forces.

Case 1:14-cv-09182-WHP Document 1 Filed 11/18/14 Page 3 of 24

9.

Through its website and the excellence of its products, Geissele has not only sold

goods but has built the Geissele brand to be synonymous with excellence in quality and design
of unique firearm tools and accessories. Geissele sells its products in the United States and
abroad through itself and through authorized distributors.
10.

WHG Properties is the owner of U.S. Trademark Registration No. 3,581,972 to

the distinctive mark GEISSELE. Geissele is the exclusive licensee of this trademark registration.
A true and correct copy of the registration certificate is attached as Exhibit A.
11.

WHG Properties is the owner of U.S. Trademark Registration No. 4,160,204 to

the distinctive mark GEISSELE. Geissele is the exclusive licensee of this trademark registration.
A true and correct copy of the registration certificate is attached as Exhibit B.
12.

WHG Properties is the owner of U.S. Trademark Registration No. 4,216,273, a

distinctive design mark for G. Geissele is the exclusive licensee of this trademark registration.
A true and correct copy of the registration certificate is attached as Exhibit C.
13.

Joe Bob uses illicit and unlawful means to drive customers to the Joe Bob

website, diminish the goodwill of Geissele, among others, and lure customers away from
legitimate manufacturers such as Geissele.
14.

For example, a customer who searches for Geissele products on Joe Bobs

website is offered both Geissele products at a price well below the Minimum Advertised Price
(MAP) set by Geissele, in addition to third party products that do not originate with, and are
not sponsored or approved by, Geissele. (See Exhibits D and E.)
15.

These and Joe Bobs other unlawful acts evince an intent by Joe Bob to deceive

the public in an effort to lure consumers into purchasing, directly from Joe Bob, Geissele
products at a price below the MAP set by Geissele, in addition to non-Geissele products.

Case 1:14-cv-09182-WHP Document 1 Filed 11/18/14 Page 4 of 24

16.

Moreover, Joe Bobs website, including but not limited to its references to

Geissele, is likely to confuse consumers into believing that Joe Bob has an affiliation,
connection, and/or association with Geissele, and is further likely to confuse and deceive
consumers into believing that non-Geissele products originate with, are sponsored by, or
approved by Geissele.
17.

At one point in time, Joe Bob was one of Geisseles retailers. However, in or

about January 2014, the parties had a falling out, and in or about that time Geissele instituted a
Do Not Sell List policy to prevent Joe Bob from selling Geissele products. Joe Bob is
currently one of two companies on Geisseles Do Not Sell List.
18.

Notwithstanding Geisseles efforts, Joe Bob unlawfully continues to advertise,

offer to sell, and sell Geissele products on its website illicitly utilizing Geisseles trademarks
mentioned above even though Geissele neither sponsors nor approves such use. (See Exhibits D
and E.)

FIRST CAUSE OF ACTION

TRADEMARK INFRINGEMENTLANHAM ACT
19.

Plaintiffs repeat and re-allege the allegations contained in each of the preceding

paragraphs of this Complaint, as though fully set forth herein.

20.

This claim arises under the Lanham Act, 15 U.S.C. 1051 et seq.

21.

On the basis of the foregoing paragraphs, Joe Bob is intentionally using copies of

Plaintiffs registered trademarks in commerce in connection with the sale, offering for sale,
distribution, or advertising of goods on or in connection with which such use is likely to cause
confusion, or to cause mistake, or to deceive in violation of the Lanham Act, 15 U.S.C. 1114.
22.

Joe Bob has profited from its illegal and bad faith activities.

Case 1:14-cv-09182-WHP Document 1 Filed 11/18/14 Page 5 of 24

23.

Plaintiffs have suffered, and continue to suffer, substantial damages as a result of

Joe Bobs bad faith activities. Plaintiffs have no adequate remedy at law and are thus damaged
in an amount to be determined by the jury and this Court.

SECOND CAUSE OF ACTION

UNFAIR COMPETITONLANHAM ACT
24.

Plaintiffs repeat and re-allege the allegations contained in each of the preceding

paragraphs of this Complaint, as though fully set forth herein.

25.

Section 43(a) of the Lanham Act, 15 U.S.C. 1125(a), prohibits, inter alia, the use

by a person of a false or misleading designation of origin or representation in connection with the

offering for sale and sale of goods which is likely to cause confusion, mistake or deception as to
the affiliation, connection, or association of such person with another person, or which is likely
to cause confusion, mistake, or deception as to the origin, source, sponsorship or approval of
such goods.
26.

Joe Bobs activities, in advertising, offering for sale, and selling Geissele products

are likely to cause confusion, mistake, or deception as to the affiliation, connection, or

association of Joe Bob and Geissele, and/or to cause confusion, mistake or deception as to the
origin, source, sponsorship, or approval by Geissele of Joe Bobs activities in connection with
the aforesaid Geissele products, constituting unfair competition, false designation of origin, and
false description and representations, in violation of Section 43(a) of the Lanham Act, 15 U.S.C.
1125(a).
27.

Joe Bob has profited from its illegal and bad faith activities.

Case 1:14-cv-09182-WHP Document 1 Filed 11/18/14 Page 6 of 24

28.

Plaintiffs have suffered, and continue to suffer, substantial irreparable damages as

a result of Joe Bobs bad faith activities. Plaintiffs have no adequate remedy at law and are thus
damaged in an amount to be determined by the jury and this Court.
THIRD CAUSE OF ACTION
DECEPTIVE ACTS AND PRACTICES UNDER
SECTION 349 OF THE NEW YORK GENERAL BUSINESS LAW
29.

Plaintiffs repeat and re-allege the allegations contained in each of the preceding

paragraphs of this Complaint, as though fully set forth herein.

30.

By the acts described above, Joe Bob has willfully engaged in deceptive acts or

practices in the conduct of business and furnishing of goods in violation of Section 349 of the
New York General Business Law.
31.

Joe Bobs acts have caused, and will continue to cause, irreparable injury to

Plaintiffs. Plaintiffs have no adequate remedy at law and are thus damaged in an amount to be
determined by the jury and this Court.

FOURTH CAUSE OF ACTION

TRADEMARK INFRINGEMENTCOMMON LAW
32.

Plaintiffs repeat and re-allege the allegations contained in each of the preceding

paragraphs of this Complaint, as though fully set forth herein.

33.

By the acts described above, Joe Bob has engaged in trademark infringement in

violation of the common law of the State of New York.

34.

Joe Bobs acts have caused, and will continue to cause, irreparable injury to

Plaintiffs. Plaintiffs have no adequate remedy at law and are thus damaged in an amount to be
determined by the jury and this Court.

Case 1:14-cv-09182-WHP Document 1 Filed 11/18/14 Page 7 of 24

FIFTH CAUSE OF ACTION

UNFAIR COMPETITIONCOMMON LAW
35.

Plaintiffs repeat and re-allege the allegations contained in each of the preceding

paragraphs of this Complaint, as though fully set forth herein.

36.

By the acts described above, Joe Bob has engaged in unfair competition in

violation of the common law of the State of New York.

37.

Joe Bobs acts have caused, and will continue to cause, irreparable injury to

Plaintiffs. Plaintiffs have no adequate remedy at law and are thus damaged in an amount to be
determined by the jury and this Court.

JURY TRIAL DEMAND

38.

Pursuant to Rule 38, Fed R. Civ. P., Plaintiffs hereby demand a trial by jury on all

issues set forth herein that are properly triable to a jury.

PRAYER FOR RELIEF

WHEREFORE, Plaintiffs respectfully request that the Court, upon final hearing of this
matter, grant the following relief against Defendant:
A.

That Defendant be adjudged to have engaged in federal trademark infringement

and unfair competition under the Lanham Act, 15 U.S.C. 1114 and 1125,
trademark infringement and unfair competition under the common law of New
York, and deceptive acts and practices under Section 349 of the New York
General Business Law;

B.

That Defendant, its officers, agents, servants, employees, representatives,

distributors and all persons in concert or participation with Defendant be
7

Case 1:14-cv-09182-WHP Document 1 Filed 11/18/14 Page 8 of 24

preliminarily and permanently enjoined from engaging in any activities, including

but not limited to making, using, importing, advertising, offering for sale and
selling any products or packaging, which directly or contributorily infringe or
actively induce infringement of Plaintiffs rights in its products or advertising
materials, including Plaintiffs rights in its trademarks;
C.

That Defendant, its officers, agents, servants, employees, representatives,

distributors, and all persons in concert or participation with Defendant be
preliminarily and permanently enjoined from offering for sale, selling or
marketing merchandise that tends in any way to deceive, mislead or confuse the
public into believing that Defendants merchandise in any way originates with, is
sanctioned by, sponsored by, or is affiliated with Plaintiffs;

D.

That Defendant, its officers, agents, servants, employees, representatives,

distributors, and all persons in concert or participation with Defendant be
preliminarily and permanently enjoined from otherwise competing unfairly with
Plaintiffs;

E.

That Defendant, its officers, agents, servants, employees, representatives,

distributors, and all persons in concert or participation with Defendant be
preliminarily and permanently enjoined from engaging in further deceptive and
unfair business practices with respect to Plaintiffs;

F.

That Defendant, its officers, agents, servants, employees, representatives,

distributors, and all persons in concert or participation with Defendant be
preliminarily and permanently enjoined from engaging in further acts infringing
Plaintiffs rights under New York law;

Case 1:14-cv-09182-WHP Document 1 Filed 11/18/14 Page 9 of 24

G.

That Defendant be directed to file with this Court and serve on Plaintiffs within
thirty (30) days after service of the injunction, a report in writing, under oath,
setting forth in detail the manner and form in which the Defendant has complied
with the injunction;

H.

That Defendant be required to account for and pay over to Plaintiffs all damages
sustained by Plaintiffs, as well as any and all of Defendants gains, revenues,
profits and advantages attributable to or derived from the acts complained of in
this Complaint, including an assessment of interest on the damages so computed,
and that the damages be enhanced, pursuant to Section 35 of the Lanham Act,
and as otherwise permitted by law;

I.

That each such award of damages be enhanced to the maximum available for each
infringement in view of Defendants willful infringement of Plaintiffs rights;

J.

That Defendant be required to deliver up for impoundment during the pendency

of this action, and for destruction thereafter, all copies of the infringing materials
in its possession or under its control and all materials used for making same;

K.

That Plaintiffs be awarded punitive damages because of the egregious and

malicious nature of the conduct of Defendant complained of herein;

L.

That Plaintiffs recover the costs of this action including their expenses and
reasonable attorneys fees pursuant to all applicable law, because of the deliberate
and willful nature of the infringing activities of Defendant sought to be enjoined
hereby, which make this an exceptional case warranting such award;

Case 1:14-cv-09182-WHP Document 1 Filed 11/18/14 Page 10 of 24

M.

That Plaintiffs be awarded pre-judgment and post-judgment interest;

N.

That Plaintiffs obtain all further relief permitted under the laws of the United
States and the State ofNew York; and,

0.

That Plaintiffs obtain all such other and further relief as the Court may deem just
and equitable.

Dated: November 18, 2014

Respectfully submitted,

1)~1~
Lee A. Goldberg (LG-9423)
Dianna G. El Hioum (DG-4294)
Benjamin H. Graf(BG-1409)
MERCHANT & GOULD PC
767 Third Avenue, 23rd Floor
New York, New York 10017
(212) 223-6520 (phone)
(212) 223-6521 (fax)
[email protected]
[email protected]
[email protected]
Attorneys for Plaintiffs

10

Case 1:14-cv-09182-WHP Document 1 Filed 11/18/14 Page 11 of 24

EXHIBIT A

Case 1:14-cv-09182-WHP Document 1 Filed 11/18/14 Page 12 of 24

Case 1:14-cv-09182-WHP Document 1 Filed 11/18/14 Page 13 of 24

EXHIBIT B

Case 1:14-cv-09182-WHP Document 1 Filed 11/18/14 Page 14 of 24

Case 1:14-cv-09182-WHP Document 1 Filed 11/18/14 Page 15 of 24

EXHIBIT C

Case 1:14-cv-09182-WHP Document 1 Filed 11/18/14 Page 16 of 24

Case 1:14-cv-09182-WHP Document 1 Filed 11/18/14 Page 17 of 24

EXHIBIT D

11/18/2014

Geissele
Case 1:14-cv-09182-WHP Document
1 Triggers
Filed 11/18/14 Page 18 of 24
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EXHIBIT E

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Case 1:14-cv-09182-WHP Document
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