Case 2:19-cv-06986 Document 1 Filed 08/12/19 Page 1 of 12 Page ID #:1

1 Kyri S. Tsircou (SBN 209905)

Konrad L. Trope (SBN 133214)
2 Tsircou Intellectual Property Law PC
515 S. Flower St. Floor 36
3 Los Angeles, California 90071
Telephone: (323) 660-9916
4 Facsimile: (323) 660-9917
Email: kyri@tsircoulaw.com
5 Email: ktrope@tsircoulaw.com
6 Counsel for Plaintiff Gold Crest, LLC,
a California Limited Liability Company
7
8 UNITED STATES DISTRICT COURT
9 CENTRAL DISTRICT OF CALIFORNIA
10 WESTERN DIVISION
11
12 GOLD CREST, LLC, a California ) CASE NO. 2:19-cv-6986
Limited Liability Company, )
13 ) COMPLAINT FOR DAMAGES,
Plaintiff, ) INJUNCTIVE RELIEF, ATTORNEYS’
14 vs. ) FEES AND COSTS FOR:
)
15 GLOBE ELECTRIC COMPANY ) 1. Design Patent Infringement Under 35
(U.S.A.), a Canadian Corporation; and ) U.S.C. § 271 for Design Patent No. US
16 DOES 1-10, inclusive; ) D769,512; and
) 2. Design Patent Infringement Under 35
17 Defendants. ) U.S.C. § 271 for Design Patent No. US
) D787,735
18 ) 3. Unfair Competition Under 15 U.S.C.
) §1125
19 )
) [JURY TRIAL DEMANDED]
20 )
21 Plaintiff Gold Crest, LLC (“Plaintiff”, or “Gold Crest”) for its claims against
22 Defendant GLOBE ELECTRIC COMPANY (U.S.A.), a Canadian Corporation
23 (“Defendant” or “Globe”) respectfully alleges as follows:
24 JURISDICTION AND VENUE
25 1. This is an action for patent infringement arising under the patent laws of
26 the United States, 35 U.S.C. § 271 et seq.
27 2. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331
28 and 1338.

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COMPLAINT FOR DAMAGES AGAINST GLOBE ELECTRIC
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1 3. This Court has personal jurisdiction over Defendant because Defendant

2 conducts business within the state of California. Defendant conducts business at 990
3 East 233rd Street, Carson, California, 90745.
4 4. This action arises out of wrongful acts, including advertising, offering for
5 sale, selling and distributing products by Defendant within this judicial district. Venue
6 is proper in this district pursuant to 28 U.S.C. §1391 because the claims asserted arise
7 in this district.
8 THE PARTIES
9 5. Plaintiff Gold Crest, LLC is a limited liability company organized and
10 existing under the laws of the State of California with its principal place of business at
11 650 Ward Drive, Santa Barbara, CA 93111. Gold Crest, LLC is the owner of Design
12 Patent No. US D769,512 (“’512 Design Patent”), and Design Patent No. US D787,735
13 (“’735 Design Patent”). A copy of the U.S. Patent and Trademark Office’s Design
14 Patent D769,512, is Exhibit “1”. A copy of the U.S. Patent and Trademark Office’s
15 Design Patent D787,735, is attached hereto as Exhibit “2”.
16 6. Plaintiff is informed and believes and based thereon alleges, that
17 Defendant GLOBE ELECTRIC COMPANY (U.S.A.), a Canadian Corporation with a
18 California place of business at 990 East 233rd Street, Carson, California, 90745.
19 Defendant is a seller of lamps, and lighting products, including the infringing products
20 complained of herein.
21 7. Plaintiff is unaware of the names and true capacities of Defendants,
22 whether individual, corporate and/or partnership entities, named herein as DOES 1
23 through 10, inclusive, and therefore sues them by their fictitious names. Plaintiff will
24 seek leave to amend this complaint when their true names and capacities are
25 ascertained. Plaintiff is informed and believes and based thereon alleges that said
26 Defendant and DOES 1 through 10, inclusive, are in some manner responsible for the
27 wrongs alleged herein, and that at all times referenced each was the agent and servant
28 of the other Defendants and was acting within the course and scope of said agency and

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1 employment.
2 8. Plaintiff is informed and believes and based thereon alleges, that at all
3 relevant times herein, Defendant and DOES 1 through 10, inclusive, knew or
4 reasonably should have known of the acts and behavior alleged herein and the damages
5 caused thereby, and by their inaction ratified and encouraged such acts and behavior.
6 Plaintiff further alleges that Defendant and DOES 1 through 10, inclusive, have a non-
7 delegable duty to prevent or cause such acts and the behavior described herein, which
8 duty Defendant and DOES 1 through 10, inclusive, failed and/or refused to perform.
9 ALLEGATIONS COMMON TO ALL CAUSES OF ACTION
10 A. Background
11 9. Gold Crest is a well-known and respected company in the lighting and
12 home goods field. Gold Crest is well known for its high quality products, and is
13 sought out as the supplier for a number of high-end hospitality chains and
14 corporations.
15 10. Gold Crest filed the D769,512 design patent on September 8, 2015, and
16 was legally registered by the USPTO on October 16, 2016. Additionally, Gold Crest
17 filed the D787,735 design patent on October 14, 2016, and was legally registered by
18 the USPTO on May 23, 2017. The patent has been in force since that time and
19 continues to be in force.
20 11. As a result of Gold Crest’s substantial advertising and promotional
21 efforts, as well as the high quality of the products associated with the ‘512 Design
22 Patent ’735 Design Patent, this distinctive design has earned valuable and residual
23 goodwill and reputation for Gold Crest being the sole source of said goods in the
24 United States.
25 B. Defendant’s Infringing Conduct
26 12. Defendant has infringed and continues to infringe on the ‘512 Design
27 Patent, and the ’735 Design Patent, or a colorable imitation thereof by using, selling
28 and/or offering to sell in the United States, and/or importing into the United States,

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1 infringing products as identified in this Complaint.

2 13. Plaintiff is informed and believes and based thereon alleges, that Plaintiff
3 was made aware that Defendant has been selling lamps under the name “Lumesty
4 Phoenix Black LED Integrated Desk Lamp” (“Infringing Product”).
5 14. Plaintiff is informed and believes that Defendant has been providing the
6 infringing product to a number of third party retailers, including but not limited to,
7 Home Depot, Walmart, Overstock and Wayfair.
8 15. Below is a comparison between the infringing product being offered by
9 Defendant, and Plaintiff’s ‘512 Design Patent
10
11 Design Pat. No. D769,512 Infringing Product
12
13
14
15
16
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27
28

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1 16. Below is a comparison between the infringing product being offered by

2 Defendant, and Plaintiff’s ‘735 Design Patent:
3
4 Design Pat. No. D787,735 Infringing Product
5
6
7
8
9
10
11
12
13
14
15
16
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26 17. Defendant was made aware of their infringing activity in April 2019 with
27 through a cease and desist letter sent to Defendant. The receipt of this letter was
28 confirmed by defendant on April 23, 2019.

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1 18. An ordinary observer familiar with the prior art would be deceived into
2 thinking that the design of the infringing products was the same as the ‘512 Design
3 Patent, and the ‘735 Design Patent.
4 19. Defendant’s actions have been without license or authority of Gold Crest.
5 20. Defendant’s actions have been taken knowingly and willingly.
6 21. Defendant has been made aware of their infringing conduct since April
7 22, 2019, and after having initially responded, have continued their infringing conduct
8 all the way up and until the present. As such this conduct was knowing and willful.
9 FIRST CLAIM FOR RELIEF
10 [Infringement of ‘512 Design Patent Under 35 U.S.C. § 271
11 Against All Defendants]
12 22. Plaintiff realleges, adopts and incorporates by reference, each and every
13 allegation contained in Paragraphs 1 through 21, inclusive, of this Complaint as though
14 fully set forth herein
15 23. Plaintiff is informed and believes and thereon alleges that Defendant has
16 infringed and continues to infringe the ‘512 Design Patent by manufacturing,
17 distributing, promoting, using, selling and/or offering to sell in the United States,
18 and/or importing into the United States infringing products as identified in this
19 Complaint, which embody the design covered by the ‘512 Design Patent. Defendant’s
20 actions constitute infringement of the ‘512 Design Patent under 35 U.S.C. § 271 and
21 35 U.S.C. § 289.
22 24. Plaintiff is informed and believes and thereon alleges that Defendant’s
23 acts of infringement were and are willful and deliberate.
24 25. Plaintiff is informed and believes and thereon alleges that Defendants,
25 through their agents, employees and servants, have, knowingly, intentionally and
26 willfully directly infringed, engaged in acts of contributory infringement, and/or
27 induced the infringement of the ‘512 Design Patent by directly and/or indirectly
28 making, using, selling, offering for sale and/or importing products into the United

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1 States that were covered by the claims of the ‘512 Design Patent.
2 26. Defendants’ acts of infringement of the ‘512 Design Patent were
3 undertaken without permission or license from Plaintiff Gold Crest. Defendants had
4 actual and/or constructive knowledge of the ‘512 Design Patent, and their actions
5 constitute willful and intentional infringement of the ‘512 Design Patent.
6 27. As a direct and proximate result of Defendants’ infringement of the ‘512
7 Design Patent, Defendants have derived and received gains, profits, and advantages in
8 an amount not presently known to Plaintiff Gold Crest.
9 28. Accordingly, pursuant to 35 U.S.C. § 289, Plaintiff Gold Crest is entitled
10 to Defendants’ total profits from Defendants’ infringement of the ‘512 Design Patent.
11 29. In addition, pursuant to 35 U.S.C. § 284, Plaintiff Gold Crest is entitled to
12 damages for Defendant’s infringing acts and treble damages together with interest and
13 costs as fixed by this Court.
14 30. Pursuant to 35 U.S.C. § 285, Plaintiff Gold Crest is entitled to reasonable
15 attorneys’ fees and costs for the necessity of bring this action.
16 31. Defendants, and each of them, in performing the conduct complained of
17 herein, acted willfully and with intent to cause injury to Plaintiff Gold Crest.
18 Defendants, and each of them, are therefore guilty of malice and oppression in
19 conscious disregard of Plaintiff Gold Crest’s rights thereby warranting an assessment
20 of punitive damages or exemplary damages or enhanced damages to the extent allowed
21 by law in an amount appropriate to punish Defendants and deter others from engaging
22 in such conduct.
23 32. Defendants have engaged in, continue to engage in, and unless restrained,
24 will continue to engage in the wrongful acts described herein. As a result, Plaintiff
25 will suffer great and irreparable injury, for which damages would not afford adequate
26 relief, in that said damages would not adequately compensate for the injury to Gold
27 Crest’s business operations, reputation, good will, and customer base. Consequently,
28 Defendants’ conduct, if allowed to continue, would inevitably result in the destruction

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1 of Plaintiff Gold Crest. Accordingly, Plaintiff Gold Crest is entitled to preliminary and
2 permanent injunctive relief against all Defendants for their misconduct.
3 SECOND CLAIM FOR RELIEF
4 [Infringement of ‘735 Design Patent Under 35 U.S.C. § 271
5 Against All Defendants]
6 33. Plaintiff realleges, adopts and incorporates by reference, each and every
7 allegation contained in Paragraphs 1 through 32, inclusive, of this Complaint as though
8 fully set forth herein
9 34. Plaintiff is informed and believes and thereon alleges that Defendant has
10 infringed and continues to infringe the ‘735 Design Patent by manufacturing,
11 distributing, promoting, using, selling and/or offering to sell in the United States,
12 and/or importing into the United States infringing products as identified in this
13 Complaint, which embody the design covered by the ‘735 Design Patent. Defendant’s
14 actions constitute infringement of the ‘735 Design Patent under 35 U.S.C. § 271 and
15 35 U.S.C. § 289.
16 35. Plaintiff is informed and believes and thereon alleges that Defendants,
17 through their agents, employees and servants, have, knowingly, intentionally and
18 willfully directly infringed, engaged in acts of contributory infringement, and/or
19 induced the infringement of the ‘512 Design Patent by directly and/or indirectly
20 making, using, selling, offering for sale and/or importing products into the United
21 States that were covered by the claims of the ‘512 Design Patent.
22 36. Defendants’ acts of infringement of the ‘512 Design Patent were
23 undertaken without permission or license from Plaintiff Gold Crest. Defendants had
24 actual and/or constructive knowledge of the ‘512 Design Patent, and their actions
25 constitute willful and intentional infringement of the ‘512 Design Patent.
26 37. As a direct and proximate result of Defendants’ infringement of the ‘512
27 Design Patent, Defendants have derived and received gains, profits, and advantages in
28 an amount not presently known to Plaintiff Gold Crest.

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1 38. Accordingly, pursuant to 35 U.S.C. § 289, Plaintiff Gold Crest is entitled

2 to Defendants’ total profits from Defendants’ infringement of the ‘512 Design Patent.
3 39. In addition, pursuant to 35 U.S.C. § 284, Plaintiff Gold Crest is entitled to
4 damages for Defendant’s infringing acts and treble damages together with interest and
5 costs as fixed by this Court.
6 40. Pursuant to 35 U.S.C. § 285, Plaintiff Gold Crest is entitled to reasonable
7 attorneys’ fees and costs for the necessity of bring this action.
8 41. Defendants, and each of them, in performing the conduct complained of
9 herein, acted willfully and with intent to cause injury to Plaintiff Gold Crest.
10 Defendants, and each of them, are therefore guilty of malice and oppression in
11 conscious disregard of Plaintiff Gold Crest’s rights thereby warranting an assessment
12 of punitive damages or exemplary damages or enhanced damages to the extent allowed
13 by law in an amount appropriate to punish Defendants and deter others from engaging
14 in such conduct.
15 42. Defendants have engaged in, continue to engage in, and unless restrained,
16 will continue to engage in the wrongful acts described herein. As a result, Plaintiff
17 will suffer great and irreparable injury, for which damages would not afford adequate
18 relief, in that said damages would not adequately compensate for the injury to Gold
19 Crest’s business operations, reputation, good will, and customer base. Consequently,
20 Defendants’ conduct, if allowed to continue, would inevitably result in the destruction
21 of Plaintiff Gold Crest. Accordingly, Plaintiff Gold Crest is entitled to preliminary and
22 permanent injunctive relief against all Defendants for their misconduct.
23 THIRD CLAIM FOR RELIEF
24 [Unfair Competition Under 15 U.S.C. §1125
25 Against All Defendants]
26 43. Plaintiff realleges, adopts and incorporates by reference, each and every
27 allegation contained in Paragraphs 1 through 42, inclusive, of this Complaint as though
28 fully set forth herein.

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1 44. Defendants’ conduct as described above constitutes illegal passing off,

2 and misappropriation of the trademarks, trade names and/or trade dress of Plaintiff in
3 violation of 15 U.S.C. §1125(a).
4 45. By reason of the foregoing, Plaintiff Gold Crest has been irreparably
5 harmed and will continued to be irreparably harmed. Plaintiff is entitled to the
6 remedies provided for in 15 U.S.C. §1116 et seq., including but not limited to,
7 damages, treble damages, injunctive relief, and attorneys’ fees.
8 46. Defendants, and each of them, in performing the conduct complained of
9 herein, acted willfully and with intent to cause injury to Plaintiff Gold Crest.
10 Defendants, and each of them, are therefore guilty of malice and oppression in
11 conscious disregard of Plaintiff Gold Crest’s rights thereby warranting an assessment
12 of punitive damages or exemplary damages or enhanced damages to the extent allowed
13 by law in an amount appropriate to punish Defendants and deter others from engaging
14 in such conduct.
15 47. Defendants have engaged in, continue to engage in, and unless restrained,
16 will continue to engage in the wrongful acts described herein. As a result, Plaintiff
17 will suffer great and irreparable injury, for which damages would not afford adequate
18 relief, in that said damages would not adequately compensate for the injury to Gold
19 Crest’s business operations, reputation, good will, and customer base. Consequently,
20 Defendants’ conduct, if allowed to continue, would inevitably result in the destruction
21 of Plaintiff Gold Crest. Accordingly, Plaintiff Gold Crest is entitled to preliminary and
22 permanent injunctive relief against all Defendants for their misconduct.
23 PRAYER FOR RELIEF
24 WHEREFORE, Plaintiff respectfully request that the Court, upon final hearing
25 of this matter, grant the following relief against Defendant:
26 On the First Claim for Relief:
27 1. A judgment that Defendant has infringed the asserted ‘512 Design Patent;
28 2. An order a judgment permanently enjoining Defendant and its officers,

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1 directors, agents, servants, employees, affiliates, attorneys, and all others acting in
2 privity or in concert with them, and their parents, subsidiaries, divisions, predecessors,
3 successors and assigns, from further acts of infringement of the asserted design patent;
4 3. A judgment awarding Plaintiff all damages adequate to compensate for
5 Defendant's infringement of the asserted patents, and particularly Defendant's total
6 profits pursuant to 35 U.S.C. § 289;
7 4. A judgment awarding Plaintiff all damages, costs, and interest, including
8 treble damages, based on any infringement found to be willful, pursuant to 35 U.S.C. §
9 284, together with prejudgment interest;
10 5. An accounting of Defendant's profits;
11 6. A judgment declaring this case to be exceptional and awarding Plaintiff
12 their reasonable attorneys’ fees pursuant to 35 U.S.C. § 285; and
13 7. For injunctive relief until trial is completed.
14 On the Second Claim for Relief:
15 1. For general and special damages to be proven at the time of trial to the
16 extent allowed by law;
17 2. For attorneys’ fees and costs to the extent allowed by law;
18 3. For punitive damages or exemplary damages or enhanced damages or
19 treble damages to the extent allowed by law; and
20 4. For injunctive relief until trial is completed.
21 Awarding Plaintiff such other and further relief as this Court deems just and
22 proper.
23 On the Third Claim for Relief:
24 1. For general and special damages to be proven at the time of trial to the
25 extent allowed by law;
26 2. For attorneys’ fees and costs to the extent allowed by law;
27 3. For punitive damages or exemplary damages or enhanced damages or
28 treble damages to the extent allowed by law; and

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1 4. For injunctive relief until trial is completed.

2 Awarding Plaintiff such other and further relief as this Court deems just and
3 proper.
4 DEMAND FOR JURY TRIAL
5 Pursuant to Rule 38(b) of the Federal Rules of Civil Procedure, Plaintiff hereby
6 demand a trial by jury as to all claims in this litigation.
7
8 Dated: August 12, 2019 Tsircou Intellectual Property Law

9
10 _______________________________________
Kyriacos S. Tsircou
11 Konrad L. Trope
12 Counsel for Plaintiff Gold Crest, LLC

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EXHIBIT "1"
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EXHIBIT "2"
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USOOD787735S

(12) United States Design Patent (10) Patent No.: US D787,735 S

Edgar et al. (45) Date of Patent: . May 23, 2017
(54) LIGHT ASSEMBLY (56) References Cited

(71) Applicant: Gold Crest LLC, Santa Barbara, CA U.S. PATENT DOCUMENTS
(US) D328,361 S * 7/1992 Paproski ...................... D26, 106
D556,363 S * 11/2007 Komar ... ... D26, 106
(72) Inventors: Roger Edgar, Santa Barbara, CA (US); D618,378 S * 6/2010 Huang ... ... D26/93
Leonardus Josephus van Oord, D639,490 S * 6/2011 Huang ........ D26/93
Voorschoten (NL) D673.321 S * 12/2012 Karkkainen D26/93
D681,865 S * 5/2013 Lee ................. ... D26/93
(73) Assignee: Gold Crest LLC, Santa Barbara, CA D759,290 S * 6/2016 Hsu ... D26/107
D769,512 S * 10/2016 Edgar .......................... D26/107
(US)
* cited by examiner
(**) Term: 15 Years
Primary Examiner — Brian N Vinson
(21) Appl. No.: 29/581,046 (74) Attorney, Agent, or Firm — Tsircou Law, P.C.
(57) CLAM
(22) Filed: Oct. 14, 2016
We claim the ornamental design for a light assembly, as
shown and described.
Related U.S. Application Data DESCRIPTION
(62) Division of application No. 29/538,822, filed on Sep. FIG. 1 a front, left perspective view of of a light assembly
8, 2015, now Pat. No. Des. 769,512.
of the new design.
(51) LOC (10) Cl. ............................................... 26-03 FIG. 2 is a back left perspective of the light assembly of FIG.
(52) U.S. C. 1.
USPC ......................................................... D26/107 FIG. 3 is a left elevational view of the light assembly of FIG.
(58) Field of Classification Search 1; and,
USPC ...... D26/1, 24, 93, 104, 106, 107, 109, 110, FIG. 4 is right elevational view of the light assembly of FIG.
D26/62 1.
CPC ..... F21S 6/00; F21S 6/043; F21S 8/08; F21V The dashed lines depict environmental aspects and form no
21/00; F21V 21/02; F21W 2121/00; part of the claimed design.
F21W 213 1/30
See application file for complete search history. 1 Claim, 3 Drawing Sheets
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U.S. Patent May 23, 2017 Sheet 1 of 3 US D787,735 S

FIG. 1
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U.S. Patent May 23, 2017 Sheet 2 of 3 US D787.735S

F.G. 3
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May 23, 2017 Sheet 3 of 3 US D787,735 s

FIG. 4