Professional Documents
Culture Documents
1 PROSPECTIVE ECONOMIC
RELATIONS; AND
2 11. RESTITUTION TO AVOID
UNJUST ENRICHMENT
3
DEMAND FOR JURY TRIAL
4
5
6 Plaintiff A&A Global Imports, Inc. complains of defendants and alleges as
7 follows:
8 ALLEGATIONS COMMON TO ALL CAUSES OF ACTION
9 JURISDICTION AND VENUE
10 1. This is an action for injunctive relief and damages based on the unfair
11 competition and other tortious conduct committed by the defendants named herein,
LLP
1888 CENTURY PARK EAST, SUITE 1900
LOS ANGELES, CALIFORNIA 90067
FREEMAN, FREEMAN & SMILEY,
12 specifically arising under 35 U.S.C. 271, the United States Trademark Act of
13 1946, 15 U.S.C. 1051, et seq., as amended, (e.g., the Lanham Act, 15 U.S.C.
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14 1114, 1125, et seq.), California statutory law (California Business & Professions
15 Code 17200, et seq., and 17500, et seq.), and under the common law.
16 2. This Court has subject matter jurisdiction under 15 U.S.C. 1121(a),
17 28 U.S.C. 1331, and 28 U.S.C. 1338(a), as well as supplemental jurisdiction
18 under 28 U.S.C. 1338(b) and 1367(a).
19 3. Venue is proper in this district under 28 U.S.C. 1391(b) and (c).
20 4. The Court has personal jurisdiction over each defendant because, as set
21 forth below, each defendant either conducts business in California, including within
22 this judicial district, or has engaged in conduct directed at the State of California, or
23 both.
24 THE PARTIES
25 5. Plaintiff (hereinafter, Plaintiff or A&A Global) is and at all times
26 mentioned herein was a California corporation, doing business in California,
27 including within this judicial district. Plaintiffs principal place of business is located
28 in Commerce, California.
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PLAINTIFF A&A GLOBAL IMPORTS, INC.S COMPLAINT
Case 2:17-cv-03442 Document 1 Filed 05/05/17 Page 3 of 31 Page ID #:3
12 said fictitious names. Plaintiff will amend this Complaint to allege their true names
13 and capacities when ascertained.
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14 9. Plaintiff is informed and believes and thereupon alleges that at all times
15 relevant herein, each of the DOE defendants, and each of the named defendants, were
16 the agents and/or employees of one or more of the other defendants, were acting
17 within the course and scope of said agency and/or employment, and that each
18 defendant has aided and assisted one or more of the other defendants in committing
19 the wrongful acts alleged herein.
20 10. Plaintiff is informed and believes and thereupon alleges that defendants,
21 and each of them, conspired and agreed among themselves to do the acts complained
22 of herein and were, in doing the acts complained of herein, acting pursuant to said
23 conspiracy, and that each defendant sued herein is jointly and severally responsible
24 and liable to Plaintiff for the damages alleged herein.
25 GENERAL ALLEGATIONS
26 11. Plaintiff is a plastic packaging manufacturer. It manufactures, sells, and
27 distributes packaging materials, such as prescription bottles, vials, and exit bags, all
28 over the United States. Plaintiffs customer base includes pharmacies and cannabis
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PLAINTIFF A&A GLOBAL IMPORTS, INC.S COMPLAINT
Case 2:17-cv-03442 Document 1 Filed 05/05/17 Page 4 of 31 Page ID #:4
1 dispensaries, to which Plaintiff (and its assignees or licensees) distributes high quality
2 prescription vials and child-proof exit bags which are manufactured to comport with
3 the laws of the jurisdiction in which Plaintiffs customers (the pharmacies and
4 cannabis dispensaries) do business. Plaintiff does not now nor has it ever
5 manufactured, sold, or distributed actual cannabis or marijuana product listed as a
6 Schedule 1 drug under the Drug Enforcement Administrations (DEA) Drug
7 Schedules.
8 12. Plaintiff owns patent rights, and other intellectual property rights in and
9 to Patent No. US D766,076 S (the 076 Patent), issued by the United States Patent
10 and Trademark Office. The 076 Patent provides Plaintiff exclusive rights to
11 manufacture, sell, and distribute a plastic bag package bearing the design set forth in
LLP
1888 CENTURY PARK EAST, SUITE 1900
LOS ANGELES, CALIFORNIA 90067
FREEMAN, FREEMAN & SMILEY,
12 the 076 Patent. A true and correct copy of the 076 Patent is attached hereto as
13 Exhibit A and incorporated by reference herein.
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14 13. In addition to patent rights, Plaintiff alleges that its plastic bag package
15 bearing the design set forth in the 076 Patent is distinctive, such that it constitutes
16 Plaintiffs trade dress.
17 14. Plaintiff further asserts that it has common law trademark and statutory
18 trademark rights in U.S. Registration No. 4,894,410 (the 410 Registration) for the
19 word mark PINCHNSLIDE, which mark Plaintiff uses in connection with its
20 plastic bag package bearing the design set forth in the 076 Patent.
21 15. Moreover, with growing national acceptance of medical cannabis
22 products (and in some states, recreational cannabis products), many states have
23 passed laws regulating the sale of cannabis. Of importance, some states have
24 already passed laws requiring that cannabis products be packaged in certified child-
25 resistant packaging in accordance with federal consumer product safety guidelines,
26 codified at 16 C.F.R. 1700.1, et seq., and in accordance with ASTM standards.
27 Certainly, as time progresses and more regulatory laws regarding the sale of
28 cannabis are passed and codified, more states will likely enact the same or identical
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PLAINTIFF A&A GLOBAL IMPORTS, INC.S COMPLAINT
Case 2:17-cv-03442 Document 1 Filed 05/05/17 Page 5 of 31 Page ID #:5
12 website and the MMC Depot name, MMC solicits sales to cannabis dispensaries
13 of its various products, including its Child Secure Exit Bag. MMC specifically
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14 advertises on its website that its packaging products are child safe and are CPSC
15 approved and CFR compliant child resistant marijuana supplies and cannabis
16 packaging products approved for poison prevention. The website goes on to claim
17 that MMC Depot carries many packaging products that are ASTM Certified for
18 child safety and tamper resistance. As to its bags in particular, MMC touts Single-
19 use, re-closable and airtight tamper-resistant marijuana bags that are CPSC and CFR
20 approved for poison prevention 100% success rate for child safety! Indeed, the
21 phrase This package is child resistant appears directly on the front of MMCs
22 Child Secure Exit Bags.
23 19. MMC further advertises and represents on its website that All of the
24 marijuana containers that MMC Depot carries have been designed by established
25 manufacturers and tested by ASTM International to be significantly difficult for
26 children under age 5 to open or obtain a harmful amount of the contents in a
27 reasonable time.
28 / / /
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PLAINTIFF A&A GLOBAL IMPORTS, INC.S COMPLAINT
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1 20. Plaintiff is informed and believes and thereupon alleges that Tread
2 Global manufactures, sources, markets and sells the Child Secure Exit Bags to
3 MMC and other wholesalers and retailers throughout the United States. In fact,
4 Plaintiff is informed and believes that MMC purchases its Child Secure Exit Bags
5 through Tread Global.
6 21. Plaintiff is informed and believes and thereupon alleges that Tread
7 Global owns and operates the website domain www.treadglobal.com. Through its
8 website, Tread Global solicits sales of its various products, including the Child
9 Secure Exit Bag, to cannabis supply wholesalers, including MMC.
10 22. Tread Global specifically advertises on its website that its packaging
11 products are child resistant, that they specialize in child related safety testing
LLP
1888 CENTURY PARK EAST, SUITE 1900
LOS ANGELES, CALIFORNIA 90067
FREEMAN, FREEMAN & SMILEY,
12 and that its packaging products comply with ISO, FCC, CPSC, EPA, and ASTM
13 standards.
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14 23. Plaintiff is informed and believes and thereupon alleges that none of the
15 packaging bags that the Defendants advertise and offer for sale, including the Child
16 Secure Exit Bags, meet the child-resistant compliance regulations or ASTM
17 standards involving child-resistant packaging. Hereinafter, these products will be
18 referred as the Non-Compliant Products.
19 24. Plaintiff is informed and believes and thereupon alleges that at all times
20 relevant herein, the Defendants and each of them concealed material facts, including
21 that the Non-Compliant Products are not approved for lawful use in states that
22 require child-resistant packaging, that they do not meet federal consumer product
23 safety guidelines, codified at 16 C.F.R. 1700.1, et seq., and that they are not certified
24 under any ASTM standard involving child-resistant packaging.
25 25. Plaintiff is informed and believes and thereupon alleges that at all times
26 relevant herein, the Defendants have advertised or made representations to actual
27 and prospective customers that the Non-Compliant Products are in fact certified, do
28 in fact meet state compliance regulations, and are child proof, all of which are false.
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PLAINTIFF A&A GLOBAL IMPORTS, INC.S COMPLAINT
Case 2:17-cv-03442 Document 1 Filed 05/05/17 Page 7 of 31 Page ID #:7
14 28. In many instances, Plaintiff has either lost customers to the Defendants
15 or has been forced to price-match its fully compliant, child-resistant packaging
16 products to its customers who received solicitations from the Defendants to sell the
17 Non-Compliant Products at a much lower cost. As a consequence, Plaintiff has
18 suffered a significant amount of damages and continues to suffer damages unless
19 and until the Defendants improper conduct is enjoined.
20 29. Not only do they infringe on Plaintiffs intellectual property rights, but
21 the Non-Compliant Products sold and offered for sale by the Defendants in
22 jurisdictions that require child-resistant packaging are unlawful, unsafe, and pose an
23 immediate threat not only to Plaintiff (and other similarly situated businesses) but
24 also to the publics health and safety.
25 / / /
26 / / /
27 / / /
28 / / /
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PLAINTIFF A&A GLOBAL IMPORTS, INC.S COMPLAINT
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18 32. A simple review of the 076 Patent confirms that the Non-Compliant
19 Products infringe on that patent. A comparison of the Non-Compliant Products and
20 the 076 Patent reveal, for example, striking similarities that could only be the result
21 of conscious efforts to copy Plaintiffs design.
22 33. Although Plaintiff has provided Defendants with actual notice of their
23 infringing conduct, Plaintiff is informed and believes and thereupon alleges that
24 Defendants continue to engage in activities that infringe Plaintiffs patent rights.
25 34. As a direct and proximate result of Defendants infringing conduct,
26 Plaintiff has been injured and will continue to suffer injury to its business and
27 reputation unless Defendants are restrained by this Court from infringing Plaintiffs
28 076 Patent.
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PLAINTIFF A&A GLOBAL IMPORTS, INC.S COMPLAINT
Case 2:17-cv-03442 Document 1 Filed 05/05/17 Page 9 of 31 Page ID #:9
1 35. Defendants acts have damaged and will continue to damage Plaintiff,
2 and Plaintiff has no adequate remedy at law.
3 36. Plaintiff is informed and believes that Defendants had pre-suit
4 knowledge of Plaintiffs rights to the 076 Patent and have intentionally copied said
5 design for their own products in an effort to pass them off as if they originated, are
6 associated with, are affiliated with, are authorized by, and/or are approved by
7 Plaintiff.
8 37. In light of the foregoing, Plaintiff is entitled to injunctive relief
9 prohibiting Defendants from infringing the 076 Patent and to recover damages
10 adequate to compensate for the infringement, including Defendants profits pursuant
11 to 35 U.S.C. 289. Plaintiff is also entitled to recover any other damages as
LLP
1888 CENTURY PARK EAST, SUITE 1900
LOS ANGELES, CALIFORNIA 90067
FREEMAN, FREEMAN & SMILEY,
14 to a complete accounting of all revenue and profits derived by Defendants from the
15 unlawful conduct alleged herein. Additionally, the conduct alleged herein qualifies
16 this action as an exceptional case supporting an award of reasonable attorneys fees
17 pursuant to 35 U.S.C. 285.
18 SECOND CAUSE OF ACTION
19 FALSE DESIGNATION OF ORIGIN
20 (AGAINST MMC AND DOES 1 THROUGH 10, INCLUSIVE)
21 38. Plaintiff incorporates by this reference the allegations in paragraphs 1
22 through 37, above.
23 39. Defendant MMCs use of a Pinch N Twist mark which closely
24 resembles Plaintiffs PINCHNSLIDE mark constitutes false designation of origin
25 in violation of the Lanham Act, 15 U.S.C. 1125. Such unauthorized use causes,
26 and is likely to cause, confusion, mistake, or deception of others, as to the
27 affiliation, connection, or association of MMC with Plaintiff, and also causes, and is
28 likely to cause, confusion, mistake, or deception as to the origin, sponsorship, or
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PLAINTIFF A&A GLOBAL IMPORTS, INC.S COMPLAINT
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12 MMCs false description, false representation, and false designation of origin were
13 knowing, willful, and deliberate, making this an exceptional case within the
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1 55. Plaintiff is informed and believes that MMC had pre-suit knowledge of
2 Plaintiffs trademark rights and has intentionally copied said trademark for its own
3 products in an effort to pass them off as if they originated, are associated with, are
4 affiliated with, are authorized by, and/or are approved by Plaintiff.
5 56. In light of the foregoing, Plaintiff is entitled to injunctive relief
6 prohibiting MMC from infringing its trademark rights and to recover damages
7 adequate to compensate for the infringement.
8 FOURTH CAUSE OF ACTION
9 TRADE DRESS INFRINGEMENT
10 (AGAINST ALL DEFENDANTS)
11 57. Plaintiff incorporates by this reference the allegations in paragraphs 1
LLP
1888 CENTURY PARK EAST, SUITE 1900
LOS ANGELES, CALIFORNIA 90067
FREEMAN, FREEMAN & SMILEY,
14 Patent constitutes Plaintiffs protectable trade dress. The protectable trade dress of
15 Plaintiffs plastic bag package bearing the design set forth in the 076 Patent are
16 nonfunctional features that identify the product and its source to customers.
17 59. Defendants have willfully infringed on Plaintiffs trade dress rights in
18 connection with their distribution of their Non-Compliant Products. Defendants
19 have used, caused to be produced, distributed, advertised, marketed, offered for sale,
20 sold within the United States, and/or have imported into the United States the Non-
21 Compliant Products that incorporate distinctive features of Plaintiffs plastic bag
22 package, which actions constitute the use in commerce of false designations of
23 origin, false or misleading descriptions or representations that are likely to cause
24 confusion and mistake and to deceive consumers as to the source of origin of
25 Defendants products or affiliation, connection, or association of Defendants with
26 Plaintiff or the sponsorship or approval of Defendants products by Plaintiff,
27 constituting trade dress infringement in violation of the Lanham Act, 15 U.S.C.
28 1125.
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PLAINTIFF A&A GLOBAL IMPORTS, INC.S COMPLAINT
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1 60. Although Plaintiff has provided Defendants with actual notice of their
2 infringing conduct, Plaintiff is informed and believes and thereupon alleges that
3 Defendants continue to engage in activities that infringe Plaintiffs trade dress rights.
4 61. As a direct and proximate result of Defendants infringing conduct,
5 Plaintiff has been injured and will continue to suffer injury to its business and
6 reputation unless Defendants are restrained by this Court from infringing Plaintiffs
7 trade dress rights.
8 62. Defendants acts have damaged and will continue to damage Plaintiff,
9 and Plaintiff has no adequate remedy at law.
10 63. Plaintiff is informed and believes that Defendants had pre-suit
11 knowledge of Plaintiffs trade dress rights and have intentionally copied said trade
LLP
1888 CENTURY PARK EAST, SUITE 1900
LOS ANGELES, CALIFORNIA 90067
FREEMAN, FREEMAN & SMILEY,
12 dress for their own products in an effort to pass them off as if they originated, are
13 associated with, are affiliated with, are authorized by, and/or are approved by
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14 Plaintiff.
15 64. In light of the foregoing, Plaintiff is entitled to injunctive relief
16 prohibiting Defendants from infringing its trade dress rights and to recover damages
17 adequate to compensate for the infringement.
18 FIFTH CAUSE OF ACTION
19 UNFAIR COMPETITION IN VIOLATION OF THE LANHAM ACT
20 (AGAINST ALL DEFENDANTS)
21 65. Plaintiff incorporates by this reference the allegations in paragraphs 1
22 through 64, above.
23 66. Section 43(a) of the Lanham Act, 15 U.S.C. 1125(a), proscribes any
24 act amounting to unfair competition, including the use of any false or misleading
25 description of fact or false or misleading representation of fact, which:
26 (A) is likely to cause confusion, or to cause mistake, or to deceive as
to the affiliation, connection, or association of such person with
27
another person, or as to the origin, sponsorship, or approval of his or
28 her goods, services, or commercial activities by another person, or
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PLAINTIFF A&A GLOBAL IMPORTS, INC.S COMPLAINT
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12 the Defendants.
13 69. While Plaintiff has suffered damages and continues to suffer damages
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14 as a result of the Defendants conduct, monetary damages alone will not afford
15 Plaintiff adequate relief. As such, Plaintiff has no adequate remedy at law that will
16 compensate for the continued and irreparable harm it has suffered and will continue
17 to suffer if the Defendants conduct is allowed to continue.
18 70. Plaintiff is informed and believes and thereupon alleges that unless
19 enjoined by this Court, the Defendants, and any person or entity complicit or
20 participating with them, or each of them, will continue to engage in unfair
21 competition and unlawful conduct. Therefore, Plaintiff seeks injunctive relief as
22 further described herein.
23 71. Plaintiff is also informed and believes and thereupon alleges that the
24 Defendants have profited by reason of their acts of unfair competition and unlawful
25 acts as alleged herein. Therefore, Plaintiff also seeks an order requiring the
26 Defendants to disgorge all of their ill-gotten gains. Plaintiff also seeks an award of
27 treble damages and attorneys fees and costs under 15 U.S.C. 1117(a).
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PLAINTIFF A&A GLOBAL IMPORTS, INC.S COMPLAINT
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12 distributing, and making false and misleading assertions of fact regarding the Non-
13 Compliant Products, the Defendants acts described above constitute unfair
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14 dispose of personal property, or to induce the public to enter into any obligation
15 relating thereto to make any untrue or misleading statement concerning any
16 circumstance or matter of fact connected with the proposed performance or
17 disposition thereof.
18 81. In advertising, marketing, promoting, offering for sale, selling,
19 distributing, and making false and misleading assertions of fact regarding the Non-
20 Compliant Products, the Defendants acts described above constitute false
21 advertising in violation of the False Advertising Law.
22 82. As a direct and proximate result of the Defendants conduct as
23 described above, Plaintiff has suffered irreparable harm insofar as the Defendants
24 conduct has damaged the business, reputation, goodwill, and integrity of Plaintiff
25 and its products, and insofar as Plaintiff has lost actual and prospective customers to
26 the Defendants.
27 83. While Plaintiff has suffered damages and continues to suffer damages
28 as a result of the Defendants conduct, monetary damages alone will not afford
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PLAINTIFF A&A GLOBAL IMPORTS, INC.S COMPLAINT
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1 Plaintiff adequate relief. As such, Plaintiff has no adequate remedy at law that will
2 compensate for the continued and irreparable harm it has suffered and will continue
3 to suffer if the Defendants conduct is allowed to continue.
4 84. Plaintiff is informed and believes and thereupon alleges that unless
5 enjoined by this Court, the Defendants, and any person or entity complicit or
6 participating with them, or each of them, will continue to engage in unfair
7 competition, false advertising, and unlawful conduct. Therefore, Plaintiff seeks
8 injunctive relief as further described herein.
9 85. Plaintiff is also informed and believes and thereupon alleges that the
10 Defendants have profited by reason of their acts of unfair competition, false
11 advertising, and unlawful acts as alleged herein. Therefore, Plaintiff also seeks an
LLP
1888 CENTURY PARK EAST, SUITE 1900
LOS ANGELES, CALIFORNIA 90067
FREEMAN, FREEMAN & SMILEY,
1 informed and believes and thereupon alleges that the Defendants wrongful conduct
2 either has disrupted and will continue to disrupt those relationships.
3 90. As a direct and proximate result of the foregoing conduct by the
4 Defendants, Plaintiff has been damaged in an amount that cannot presently be
5 ascertained. Plaintiff is informed and believes and thereupon alleges that it will
6 incur additional damages in the future as long as the Defendants continue to engage
7 in the wrongful conduct alleged in this Complaint.
8 91. The conduct of the Defendants alleged herein was either malicious, in
9 that it was carried on with the intent to cause injury to Plaintiff, or despicable, in that
10 it was carried on with a conscious disregard for the rights of Plaintiff. In either case,
11 Plaintiff is entitled to an award of exemplary damages against the Defendants, and
LLP
1888 CENTURY PARK EAST, SUITE 1900
LOS ANGELES, CALIFORNIA 90067
FREEMAN, FREEMAN & SMILEY,
1 Plaintiffs contractual relationships with its existing and potential clients. Plaintiff is
2 informed and believes and thereupon alleges that the Defendants wrongful conduct
3 either has disrupted and will continue to disrupt those relationships.
4 96. As a direct and proximate result of the foregoing conduct by the
5 Defendants, Plaintiff has been damaged in an amount that cannot presently be
6 ascertained. Plaintiff is informed and believes and thereupon alleges that it will
7 incur additional damages in the future as long as the Defendants continue to engage
8 in the wrongful conduct alleged in this Complaint.
9 97. The conduct of the Defendants alleged herein was either malicious, in
10 that it was carried on with the intent to cause injury to Plaintiff, or despicable, in that
11 it was carried on with a conscious disregard for the rights of Plaintiff. In either case,
LLP
1888 CENTURY PARK EAST, SUITE 1900
LOS ANGELES, CALIFORNIA 90067
FREEMAN, FREEMAN & SMILEY,
1 101. Plaintiff is informed and believes and thereupon alleges that the
2 Defendants engaged in the conduct alleged hereinabove negligently and in conscious
3 disregard of Plaintiffs contractual relationships with its existing and potential clients.
4 Plaintiff is informed and believes and thereupon alleges that the Defendants
5 wrongful conduct either has disrupted and will continue to disrupt those relationships.
6 102. As a direct and proximate result of the foregoing conduct by the
7 Defendants, Plaintiff has been damaged in an amount that cannot presently be
8 ascertained. Plaintiff is informed and believes and thereupon alleges that it will
9 incur additional damages in the future as long as the Defendants continue to engage
10 in the wrongful conduct alleged in this Complaint.
11 103. The conduct of the Defendants alleged herein was either malicious, in
LLP
1888 CENTURY PARK EAST, SUITE 1900
LOS ANGELES, CALIFORNIA 90067
FREEMAN, FREEMAN & SMILEY,
12 that it was carried on with the intent to cause injury to Plaintiff, or despicable, in that
13 it was carried on with a conscious disregard for the rights of Plaintiff. In either case,
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EXHIBIT A
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