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Case 3:15-cv-02099-JAF Document 1 Filed 08/12/15 Page 1 of 16

IN THE UNITED STATES DISTRICT COURT


FOR THE DISTRICT OF PUERTO RICO

PUERTO RICO COFFE ROASTERS,


LLC

CIVIL NO.

Plaintiff
TRADEMARK INFRINGMENT;
UNFAIR COMPETITION;
DECLARATORY JUDGMENT;
PAN AMERICAN GRAIN MFG. CO., PERMANENT INJUNCTION
INC.
JURY TRIAL DEMANDED
Defendant
v.

COMPLAINT
COMES NOW plaintiff PUERTO RICO COFFEE ROASTERS, LLC (PRCR),
through its undersigned counsel, and respectfully alleges and prays as follows:
I.
NATURE OF THE ACTION, JURISDICTION AND VENUE
1. This is an action for trademark infringement and unfair competition arising under the
Lanham Act of 1946, 15 U.S.C. 1051 et seq. (Lanham Act) and the Puerto Rico
Trademark Act, 10 P.R. Laws Ann. 223 et seq. This is also an action for trademark misuse
and abuse of monopoly power, sham litigation or malicious prosecution, abuse of
commercial speech, misuse of the regulatory process, and tort. Damages, permanent
injunctive relief and a declaratory judgment are sought.
2. There is original jurisdiction over the trademark claims asserted pursuant to the Lanham Act,
15 U.S.C. 1114 and 1125. There is supplemental jurisdiction over the state law claims
pursuant to 28 U.S.C. 1338 and 1367.

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3. Venue is proper in this District Court under 28 U.S.C. 1391(b)(1) and (2) insofar as
Defendant is a Puerto Rico resident and a substantial part of the events giving rise to the
claims occurred, or are continuing to occur, in Puerto Rico.
II.
THE PARTIES
4. Plaintiff PRCR is a limited liability company organized under the laws of the
Commonwealth of Puerto Rico with principal place of business in Puerto Rico. PRCR is in
the business of roasting, packaging and selling Puerto Rico coffee and related products for
distribution in Puerto Rico and the United States. PRCR has also invested in the planting and
growth of coffee in Puerto Rico.
5. Defendant Pan American Grain Mfg. Co., Inc. (PAG) is a corporation organized under the
laws of the Commonwealth of Puerto Rico with principal place of business in Puerto Rico.
PAG is in the business of importing, packaging and selling rice; roasting, packaging and
selling coffee, and other products. PAG is also the parent company or affiliate of: Pan
American Properties, Inc. (PAP), which imports alcohol and produces the Gasolina brand
of alcoholic beverages, Trofima Corporation (Trofima), which also packages and sells rice,
and Pan American Fertilizer (PAF), which imports, packages and sells fertilizer. PAG and its
affiliates and subsidiaries distribute their products in Puerto Rico and the United States.
6. PAG, PAP, PAF and Trofima are owned, directed and run by their President, Jose Gonzlez
Freyre, a convicted federal felon.1
III.
FACTS COMMON TO ALL CLAIMS

See U.S. v. Jos Gonzlez Freyre, Case 3:08-CR-036-013. Case documents are attached as Exhibit 1.

Case 3:15-cv-02099-JAF Document 1 Filed 08/12/15 Page 3 of 16

7. The Caf Rico mark is a famous coffee trademark of that has been in continuous use since
approximately 1936. Through the continuous use of the Caf Rico mark in interstate
commerce and in connection with coffee goods, the Caf Rico mark has acquired a high
degree of fame, distinctiveness, international exposure, and goodwill in the Caf Rico name,
mark, and related forms.
8. The Caf Rico mark has been registered in the United States Patent and Trademark Office
(USPTO) since October 19, 2010 (Cert. Reg. No. 3862361). This registration is valid,
subsisting, and unrevoked; and is prima facie evidence of PRCRs exclusive right to use the
Caf Rico mark in commerce in connection with the goods specified in the registration,
namely coffee. See Caf Rico Certificate of Registration attached hereto as Exhibit 2.
9. The Caf Rico mark has been registered in the Puerto Rico Trademark Office (PRTO)
since December 16, 1992 (Cert. Reg. No. 32,028). This registration is valid, subsisting, and
unrevoked; and is prima facie evidence of PRCRs exclusive right to use the Caf Rico mark
in commerce in connection with all the goods specified in the registration, namely coffee.
See Caf Rico Certificate of Existence attached hereto as Exhibit 3.
10. Caf Rico 50/50 (Cert. Reg. No. 66,709), Caf Rico Decaff (Cert. Reg. No. 66,708), and
Caf Rico Espresso (Cert. Reg. No. 66,707) are related Caf Rico trademarks which have
contributed to the fame and distinctiveness of the Caf Rico trade name. These marks have
been used in commerce since 1996 and registered in the Puerto Rico Trademark Office since
2005. These registrations are valid, subsisting, and unrevoked; and are prima facie evidence
of PRCRs exclusive right to use these Caf Rico marks in commerce in connection with all
the goods specified in the registrations, namely different types of coffee.

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11. The Caf Rico mark has also been filed for registration in the USPTO, Serial No. 86414336,
and in the PRTO, Pres. Nos. 206205-16-1 and 206206-16-1, for coffee filters. This product
has been used in commerce since 2004.
12. PRCR has further secured or requested other registrations for coffee related products under
the Rico trademark. See Rico Mara (Cert. Reg. No. 66,820) and Rico Mara Gold (Cert.
Reg. No. 66,821) cookies; Rico (Pres. No. 67,738) bottled water; Rico (Pres. Nos. 20670730-1 and 206208-30-1, and Serial No. 86414346) sugar and sugar substitutes.
13. Prior to June 3, 2008, Caf Rico, Inc. was the owner of the Caf Rico trademark together
with the goodwill of the coffee business symbolized in connection with the goods on which
this mark is used.
14. On June 3, 2008, PRCR entered into an Asset Purchase Agreement with Caf Rico, Inc.,
among others. PRCR acquired certain assets of Caf Rico, Inc., including all intellectual
property and trademarks owned by it.
15. As part of this transaction, on June 30, 2008, Caf Rico, Inc. executed an Assignment and
transferred all rights, titles and interests in the Caf Rico mark to PRCR.
16. Since then, PRCR has continuously used the Caf Rico mark in interstate commerce in
connection with coffee and coffee-related goods, and has continued to establish a high degree
of fame, distinctiveness, and goodwill in the Caf Rico name, mark, and related forms.
17. Caf Rico is currently sold in Puerto Rico, Florida, New York, New Jersey, and elsewhere
through the Internet.
18. The fact of PRCRs ownership over the Caf Rico trademark is notorious and known to
PAG; particularly given prior litigation between the parties relating to such trademark and in
light of current proceedings between the parties before the PRTO.

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19. Despite this knowledge, PAG has been packaging, marketing and pre-selling coffee under the
Rico trademark for distribution in Florida. PRCR learned about this in August 2015. See
Rico Coffee picture attached hereto as Exhibit 4.
20. PAG has been undertaking the introduction of packaged coffee using the brand Rico
Coffee in Orlando, Florida, using the same name and color scheme as PRCRs Caf Rico, to
sell it to the Puerto Rican community in Orlando, who know and have been consuming Caf
Rico for more than 70 years.
21. Consumer confusion as to the source and quality of the coffee is certain. Indeed, PAG is
purposely using PRCRs trademark and trade dress for Caf Rico with the intent of deceiving
consumers in Florida.
22. This is part of PAGs intent to illegally obtain what PAG has not been able to obtain legally.
PAG has been trying to acquire the Caf Rico trademark through fraudulent actions in the
PRTO and the USPTO ever since it attempted to buy -and failed- the Caf Rico mark in
2008 from the Giraud-Pieiro Group.
23. Indeed, after PAG failed in its efforts to acquire Caf Rico and other coffee marks from the
Giraud-Pieiro Group, and PRCR successfully bought the same, PAG then attempted to
obtain the Caf Rico and the other marks by filing two cases in this Court.
24. The two cases filed by PAG sought to annul and set aside PRCRs purchase of Caf Rico and
other coffee marks, including Yaucono and Rioja. PAG lost both of the cases, before two
different judges of this Court. In other words, PAG struck out in its three attempts to acquire
the Caf Rico mark through legal proceedings: it lost in its bid to purchase the mark and it

Case 3:15-cv-02099-JAF Document 1 Filed 08/12/15 Page 6 of 16

lost in the two cases in which it tried to attack PRCRs purchase of Caf Rico so as to attain
the mark for itself.2
25. PAG, as it has repeatedly done in the past in pursuing its commercial interests and in trying
to control multiple industries and products in Puerto Rico, then turned to misleading
statements, insults, threats, libel and slander, and, finally, trademark infringement and unfair
competition, including fraud upon the PRTO and the USPTO, in its attempt to illegally
obtain PRCRs Caf Rico mark.3 In particular, in such pursuit, PAG has committed fraud on
the PRTO and the USPTO by requesting the registration of the Rico trademark for coffee and
other products, misrepresenting it uses the mark for those products when at the time of filing
the applications it only used the Rico mark for rice, beans, and tomato sauce. Indeed, PAG
has attempted to parlay its use of the trademark Rico for the sale of imported rice -which it
illegally controlled- in order to control the use of said mark for coffee and other products.
26. PAG filed Serial No. 86515771 allegedly trying to register the Rico trademark for rice,
tomato sauce, and coffee with the USPTO, when it already has the trademark registered for
rice and tomato sauce. PAG is trying to employ those uses and particularly the dominant use
of its imported rice products, to register Rico for coffee, as if it had a right to the trademark
in commerce for that product.
27. PAG did the same in the PRTO with Filing No. 73545, which includes a list of products,
including coffee, in relation with which PAG affirmed, under penalty of perjury, that it used
the Rico trademark. The only products in that list that, at the time of filing the application,
PAG actually sold under the Rico trademark are, again, rice and tomato sauce. PAG only
2

See Pan American Grain, Inc. v. Alberto de la Cruz, et al., Civil No. 12-1154; Giraud et al. v. FDIC et al., Civil
No. 10-2041. Case documents are attached as Exhibit 5.
3
See Pan American Grain v. Puerto Rico Ports Authority, 295 F.3d 108, 116-118 (2002); Pan American Grain v.
Puerto Rico Ports Authority, 193 F.R.D. 26, 29-33 (2000); Pan American Grain Co. and Unin de Trabajadores de
Muelles Local 1740, 281 N.L.R.B. No. 19, pg. *98 (1986). Case documents are attached as Exhibit 6.

Case 3:15-cv-02099-JAF Document 1 Filed 08/12/15 Page 7 of 16

provides evidence of use as to rice, a product in which it developed and exploited market
control to exclude others from said market.
28. PAG has used the trademark Arroz Rico in developing its control of over 91% of said
market. As a result, PAG gained recognition of the trademark Rico in the rice market
through illegal means.4 In particular, PAG willfully acquired, enhanced, and maintained
control over Puerto Ricos rice market by engaging in clearly exclusionary and
anticompetitive conduct that includes but is not limited to: (1) denying competitors
reasonable access to essential facilities fully controlled by PAG to import, package, and
process bulk rice in Puerto Rico; (2) the illegal acquisition of its sole competitor in the
import, packaging, and processing of bulk rice market in Puerto Rico -Trofima Corporationwith the intent and result of controlling 100% of said market; (3) using its control of the
essential facilities to import, package, and process bulk rice in Puerto Rico to impose
exclusive dealing arrangements at the wholesale levels so as to control the supply and price
of all rice sold at the retail level in Puerto Rico; (4) extending or attempting to extend its
100% market share of the import, packaging, and processing of rice market to the wholesale
and retail rice markets; (5) willfully and illegally limiting without any business justification
the amounts of bulk rice exclusively imported, packaged, and processed in PAGs import,
packaging, and processing essential facilities by other competitors in the rice market; (5)
incurring in price squeezes by charging rates to clients in the retail level for rice finished
products that are so low compared to the price it charges for the raw materials PAG sells to
competitors that those competitors are unable to compete in the rice market; (6) the use of
sham litigation and/or baseless lawsuits or administrative actions against competitors such

See Puerto Rico Senate, Consumer and Federal Affairs Commission, Partial Report on R. del S. 3319 (Rice
Monopoly), October 7, 2008, attached as Exhibit 7.

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as Trofima Corporation to impede their ability to compete, and (7) reaching agreements with
potential competitors in the import, packaging, and processing of rice market to preclude
their entrance to the same.
29. PAG aims to dominate the coffee market, as it dominates the rice, grains, animal food,
fertilizers and prepared alcoholic beverages industries in Puerto Rico, through diverse
companies owned and operated by Jos Gonzlez Freyre, including PAG, PAP, and Trofima.
PAG is trying to use the power it illegally achieved in the rice market to gain an unfair
advantage in other markets, including the coffee market. PAG alleges Rico is its house-mark
and, therefore, that it has exclusive rights to the Rico trademark as to each and every market
product, even those as to which other real users have previous or senior rights. That is the
case of PRCRs Caf Rico.
30. The illegal actions to obtain PRCRs Rico mark also include a defamation campaign that
PAG, through its president, Jos Gonzlez Freyre, is circulating in the press, with media
tours of PAGs public relations team, paid by PAG, and through social media to affect the
reputation and goodwill of PRCRs coffee trademarks, including Caf Rico, Yaucono,
Crema, Alto Grande, and Rioja. This campaign includes false statements accusing PRCR of
exploiting children in other countries and as to the quality of the PRCR coffee brands. PAG
is looking to damage PRCRs coffee trademarks in order to promote its own coffee
trademarks, like Caf Mami, and to introduce its Rico Coffee mark in the market that PRCR
has developed with its Caf Rico and other coffee trademarks.
31. Although PAG has developed a public campaign alleging it is protecting locally produced
coffee and is promoting that consumers only purchase coffee made with 100% Puertorican
coffee, two of the three coffee brands affiliated to PAG, Del Patio produced by Trofima, a

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corporation owned by Gonzlez Freyre- and De Mi Tierra also produced by Gonzlez


Freyre-, use imported coffee. In other words, both brands are completely misleading or ipso
facto misleading advertising. This is typical of PAG's unfair competition tactics in all
industries in which it participates and controls or attempts to control. Indeed, at a March 30,
2015 meeting of the Asociacin de Agricultores, Gonzalez Freyre boasted that he
(presumably meaning his companies) were the leaders in all markets in which he
participated-except coffee.
32. One example of PAGs use of unfair competition tactics were the threats, insults and unfair
competition, including the violation of Law 75, that PAGs affiliate Pan American Properties
(PAP), which is also owned by Gonzalez Freyre, used in relation with the distribution of its
Gasolina alcoholic beverages, which is manufactured with imported alcohol.5
33. Moreover, PAGs public campaign is completely deceitful; designed by PAG to promote its
own agenda and economic interests in the areas PAG controls. The truth is that the coffee
growers have and are being distressed by the high costs of fertilizers-another industry
controlled by PAG, in which its subsidiary and/or affiliate PAF boasts market control of 95%
of fertilizer sales in Puerto Rico. In fact, using its 95% market control, PAG doubled the
price of fertilizers in 2005, thereby affecting several industries, including the coffee industry.
34. PAGs campaign against PRCR is deceitful, since it is based on the slogan Salvemos el
Caf 100% puertorriqueo and the demise of the Puerto Rico coffe industry has been caused

In a decision by the Superior Court of Bayamn, in CC1 Beer Distributors, Inc. v. Pan American Properties Corp.,
D PE 2011-0175, the Court not only concluded (as the NLRB had already concluded in another case) that Gonzlez
Freyre's testimony under oath before said court was not worthy of credibility but also that PAP used CC1s
distribution of Gasolina to create the market for it and then tried to take away the distribution from CC1 to distribute
the product on its own, benefiting from CC1s work and strategies; PAP engaged in the direct distribution of
Gasolina and hid it from CC1, that had exclusive distribution rights . It further concluded that Gonzlez Freyre had
threatened one of its distributors and developed a scheme to take away its distribution rights by deceiving the
distributor, and then insulting him and even firing and employee that testified against PAP.

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in large part by PAGs abusive use of its control of the fertilizer market against the same
coffee growers it now claims to defend.
IV.
CAUSES OF ACTION
COUNT I
FEDERAL TRADEMARK INFRINGEMENT, 15 U.S.C. 1114
35. PRCR incorporates by reference the allegations contained in Paragraphs 1 through 30 of this
Verified Complaint.
36. PRCR is the owner of the Caf Rico trademark, given its use of the mark, by itself and its
predecessors, since the 1930s.
37. PRCR owns registration of the Caf Rico trademark in the USPTO and the PRTO. See Caf
Rico Certificate of Registration attached hereto as Exhibit 2.
38. PRCR also owns the Rico and Caf Rico marks with regards to several other products related
to coffee.
39. PAG is infringing PRCRs exclusive right to use the trademark Caf Rico in connection with
coffee by offering for sale a coffee under the mark Rico Coffee.
40. This use is likely to cause confusion because PAG is using the same name of PRCRs coffee,
only changing the descriptive part of the name by translating it from Spanish to English and,
accordingly with English grammar, moving it from the top to the bottom of the mark. Not
only that, but PAG is also using the same color scheme as that used by Caf Rico.
41. PAGs Rico Coffee will be marketed to the same type of consumers and through the same
type of channels as PRCRs Caf Rico and other Rico products that are related to coffee.

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42. Any ordinary consumer may reasonably think Caf Rico is introducing a new look for its
product.
43. PAGs Rico Coffee trademark is designed to deceive, misleading consumers, including
Puerto Ricans living in Orlando, to believe they are buying the same PRCRs Caf Rico they
have known and enjoyed for the past decades, when in reality, they are buying another
product, PAGs confusingly similar package of coffee.
44. The likelihood of confusion is further increased by the fact that both PRCR and PAG are not
only selling the same goods, but also using the same channels of trade and publicity, and
aiming to attract the same customers.
45. PAGs actions thereby demonstrate an intentional, wrongful, and bad faith attempt to trade
on the goodwill associated with the Caf Rico mark.
46. Furthermore, PAGs trademark misuse scheme demonstrates its intention to use the Rico
trademark in relation to products which are in PRCRs natural zone of expansion and which
PRCR is already producing or intends to produce under its Caf Rico and Rico trademarks,
such as sugar, milk, water, and cookies.
47. PRCR is entitled to permanent injunctive relief, to prevent PAG from using the Rico
trademark in connection with coffee and related goods in PRCRs natural zone of expansion,
and to recover PRCRs statutory and/or actual damages, profits, costs, and reasonable
attorneys fees under 15 U.S.C. 1114 and 1117.
COUNT II
FEDERAL TRADEMARK INFRINGEMENT AND
UNFAIR COMPETITION, 15 U.S.C. 1125 (a)
48. PRCR incorporates by reference the allegations contained in Paragraphs 1 through 47 of this
Verified Complaint.

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Case 3:15-cv-02099-JAF Document 1 Filed 08/12/15 Page 12 of 16

49. PRCR is the owner of the Caf Rico mark.


50. PAG is using a misleading name and package which is likely to deceive as to the affiliation
or origin of its coffee, in violation of 15 U.S.C. 1125(a). By using a name and image
confusingly similar to PRCRs Caf Rico, PAG is creating the false and misleading
impression that its coffee originates with or is affiliated, connected, or associated with PRCR.
51. But PAGs illegitimate tactics dont end there, because, at the same time it takes advantage
of Caf Ricos goodwill to introduce its Rico Coffee in the market PRCR has created, PAG
develops a campaign to actively harm PRCRs position, reputation, and ability to compete on
fair terms. PAG intends to benefit from Caf Ricos goodwill and, later on, when it has
tarnished PRCRs reputation with its defamation campaign, promote its own Rico Coffee.
PAGs plans are to intrude on Caf Ricos market using Caf Ricos name and image;
damage PRCRs reputation, and unfairly occupy the market after benefiting from Caf
Ricos goodwill and then eliminating Caf Rico as a competitor.
52. PRCR is entitled to a permanent injunction, to prevent PAG from using the Rico trademark
in connection with coffee and to prevent its unfair competition scheme, and to recover
damages, actual and/or statutory, profits, costs, and reasonable attorneys fees pursuant to 15
U.S.C. 1117 and 1125(a).
COUNT III
TRADEMARK MISUSE
53. PRCR incorporates by reference the allegations contained in Paragraphs 1 through 52 of this
Verified Complaint.

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54. PAG is using its registration of the Arroz Rico trademark to unfairly attempt to control the
coffee market and to devalue trademark rights over trademarks that contain the word Rico in
relation to all kinds of goods.
55. PAGs violation of fair competition boundaries that legitimate trademarks impose on their
owners is even more serious, because the unfairly acquired fame that the Arroz Rico mark
has in the Puerto Rico rice market is the result of another unfair competition tactic by PAG,
as set forth above., through different illegal and unfair tactics and unfair competition
schemes.
56. PAGs abuse of its trademark registration merits the cancellation of all of its Rico
trademarks. Therefore, PRCR requests this Court to order the cancellation of PAGs Rico
trademarks for trademark misuse.
COUNT IV
PUERTO RICO TRADEMARK INFRINGMENT
57. PRCR incorporates by reference the allegations contained in Paragraphs 1 through 48 of this
Verified Complaint.
58. PRCR is the owner of the Caf Rico (Cert. Reg. No. 32,028), Caf Rico 50/50 (Cert. Reg.
No. 66,709), Caf Rico Decaff (Cert. Reg. No. 66,708), and Caf Rico Espresso (Cert. Reg.
No. 66,707) marks for coffee and coffee-related goods registered in the PRTO. See Exhibit
3. These registrations are valid, subsisting, and unrevoked; and are prima facie evidence of
PRCRs exclusive right to use the Caf Rico mark in commerce in connection with all the
goods and services specified in the registrations.
59. PAG has willfully and deliberately used PRCRs registered trademarks or confusingly
similar trademarks in violation of the law of Puerto Rico, 10 P.R. Laws Ann. 223w.

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60. PAG began and continues such use with knowledge of PRCRs prior adoption and use of the
Caf Rico mark, the registration for which covers coffee and coffee-related goods.
61. PRCR is entitled to permanent injunctive relief and to recover damages, actual and/or
statutory, profits, costs, and reasonable attorneys fees pursuant to 10 P.R. Laws Ann.
223w.
COUNT V
DAMAGES UNDER THE PUERTO RICO CIVIL CODE
62. PRCR incorporates by reference the allegations contained in Paragraphs 1 through 53 of this
Verified Complaint.
63. By packaging and marketing coffee using a name and image substantially and confusingly
similar to PRCRs Caf Rico, PAG has caused PRCR damages under Article 1802 of the
Puerto Rico Civil Code, 31 P.R. Laws Ann. 5141.
64. PAG has also caused damages to PRCRs reputation and to the goodwill of its trademarks,
including Caf Rico, Caf Yaucono, Yauco Selecto, Caf Crema, Rioja, and Alto Grande,
through the false and defamatory campaign it has published and continues to publish in the
traditional media and social media, in violation of 31 P.R. Laws Ann. 5141 and 32 P.R.
Laws Ann. 3141.
65. PRCR is entitled to recover damages, costs, and reasonable attorneys fees pursuant to 31
P.R. Laws Ann. 5141 and 32 P.R. Laws Ann. 3147.
COUNT VI
DECLARATORY JUDGMENT
66. PRCR incorporates by reference the allegations contained in Paragraphs 1 through 57 of this
Verified Complaint.

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67. PRCR requests that the Court declare that PRCR is the owner of the Caf Rico mark and the
Rico marks in connection with coffee and coffee-related goods and, therefore, while PRCR
uses its trademarks in commerce, PAG and no other person or entity may use the same or
confusingly similar trademarks for the sale, distribution, promotion or marketing of coffee
and coffee-related products.
V.
PRAYER FOR RELIEF
WHEREFORE, PRCR demands judgment in its favor and against Defendants and seeks
the following relief from this Court:
(a)

a permanent injunction restraining PAG from packaging, selling, distributing, or

otherwise disposing of coffee bearing the Rico mark and from taking any actions that infringe
the trademark, and ordering PAG to immediately produce to PRCR an accounting of all goods
produced and all profits derived from the use of the Rico mark in relation to coffee;
(b)

a declaratory judgment that PRCR is the owner of the Caf Rico and Rico

trademarks for coffee and related products in its natural zone of expansion;
(c)

an award of statutory damages in the maximum amount allowed pursuant to

Puerto Rico and federal trademark laws for bad faith infringement and/or loss profits and
damages in an amount to be determined at trial for PAGs bad faith infringement of PRCRs
trademark;
(d)

an award of damages for PRCRs loss of goodwill and harm to reputation, in an

amount to be determined at trial;


(e)

an award of costs and attorneys fees in favor of PRCR;

(f)

the cancellation of all of PAGs Rico trademarks for trademark misuse, and

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(g)

an Order awarding PRCR such other and further relief as the Court may deem just

and proper.
In San Juan, Puerto Rico, on August 12, 2015.
PIETRANTONI MNDEZ & ALVAREZ LLC
Popular Center-19th Floor
208 Ponce de Len Ave.
San Juan, P.R. 00918
Tel. 787-274-1212
Fax 787-274-1470

/S/ NSTOR MNDEZ GMEZ


Nstor M. Mndez-Gmez
E-mail: nmendez@pmalaw.com
USCA No. 118,409
/S/ MARA D. BERTLEZ
Mara D. Bertlez Elvira
E-mail: mbertolez@pmalaw.com
USCA No. 217,112
/S/ MARIANA MUIZ LARA
Mariana Muiz-Lara
E-mail: mmuniz@pmalaw.com
USCA No. 231,706

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