Oakley v. Frontier Fashion - Complaint

Case 3:17-cv-01693-WQH-BGS Document 1 Filed 08/22/17 PageID.
1 Page 1 of 118
1 Michael K. Friedland (SBN 157,217)

michael.friedland@knobbe.com
2 Ali S. Razai (SBN 246,922)
ali.razai@knobbe.com
3 Daniel C. Kiang (SBN 307,961)
daniel.kiang@knobbe.com
4 KNOBBE, MARTENS, OLSON & BEAR, LLP
2040 Main Street, Fourteenth Floor
5 Irvine, CA 92614
Telephone: (949) 760-0404
6 Facsimile: (949) 760-9502
7 Attorneys for Plaintiff
OAKLEY, INC.
8
9
10
IN THE UNITED STATES DISTRICT COURT
11
FOR THE SOUTHERN DISTRICT OF CALIFORNIA
12
13
OAKLEY, INC., a Washington ) Civil Action No. '17CV1693 WQHBGS
14 corporation, )
)
15 Plaintiff, ) COMPLAINT FOR PATENT
) INFRINGEMENT, TRADE DRESS
16 v. ) INFRINGEMENT, FALSE
) DESIGNATION OF ORIGIN, AND
17 FRONTIER FASHION, INC., ) UNFAIR COMPETITION
)
18 Defendant. )
) DEMAND FOR JURY TRIAL
19 )
20
21
22
23
24
25
26
27
28
COMPLAINT
Case 3:17-cv-01693-WQH-BGS Document 1 Filed 08/22/17 PageID.2 Page 2 of 118
1 Plaintiff Oakley, Inc. (Oakley) hereby complains of Frontier Fashion,

2 Inc. (Defendant) and alleges as follows:
3 I. JURISDICTION AND VENUE
4 1. This Court has original subject matter jurisdiction over the claims
5 in this action that relate to design patent infringement and trade dress
6 infringement pursuant to 35 U.S.C. 271 and 281, 15 U.S.C. 1116(a),
7 1125(a), and 28 U.S.C. 1331 and 1338 as these claims arise under the laws of
8 the United States. This Court has supplemental jurisdiction over the claims in
9 this Complaint which arise under state statutory and common law pursuant to 28
10 U.S.C. 1367(a) because the state law claims are so related to the federal claims
11 that they form part of the same case or controversy and derive from a common
12 nucleus of operative facts.
13 2. This Court has personal jurisdiction over Defendant because
14 Defendant has a continuous, systematic, and substantial presence within this
15 judicial district including by regularly doing and soliciting business and deriving
16 revenue from goods provided to individuals in this judicial district, including
17 but not limited to selling infringing eyewear directly to consumers and/or
18 retailers in this district and selling into the stream of commerce knowing such
19 eyewear products would be sold in California and this district, which acts form a
20 substantial part of the events or omissions giving rise to Oakleys claim.
21 3. Venue is proper in this judicial district under 28 U.S.C. 1391(b),
22 1390(d) and 1400(b).
23 II. THE PARTIES
24 4. Plaintiff Oakley is a corporation organized and existing under the
25 laws of the State of Washington, having its principal place of business at One
26 Icon, Foothill Ranch, California 92610.
27 5. Plaintiff is informed and believes, and thereon alleges, that
28 Defendant Frontier Fashion, Inc. is a corporation organized and existing under
-1- COMPLAINT
1 the laws of the State of California, having its principal place of business at 1293
2 S. Johnson Drive, City of Industry, CA 91745.
3 6. Oakley is informed and believes, and thereon alleges, that
4 Defendant regularly conducts business in, and has committed the acts alleged
5 herein, within this judicial district.
6 III. GENERAL ALLEGATIONS
7 7. Oakley is one of the worlds most iconic brands. The company and
8 its products, particularly in the realm of eyewear, are instantly and universally
9 recognized for their innovative technology and distinctive style. Since Oakleys
10 founding, Oakleys engineers and designers have worked continuously to bring
11 new technology and breakthrough designs to the market.
12 8. Oakley has been actively engaged in the manufacture and sale of
13 high quality eyewear since at least 1985. Oakley is the manufacturer and
14 retailer of several lines of eyewear that have enjoyed substantial success and are
15 protected by various intellectual property rights owned by Oakley.
16 9. On May 8, 2012, the United States Patent & Trademark Office
17 (U.S.P.T.O.) duly and lawfully issued United States Design Patent No.
18 D659,180 (the D180 Patent), titled EYEGLASS. Oakley is the owner by
19 assignment of all right, title, and interest in the D180 Patent. A true and correct
20 copy of the D180 Patent is attached hereto as Exhibit A.
21 10. On March 29, 2016, the U.S.P.T.O. duly and lawfully issued
22 United States Design Patent No. D752,678 (the D678 Patent), titled
23 EYEGLASS. Oakley is the owner by assignment of all right, title, and
24 interest in the D678 Patent. A true and correct copy of the D678 Patent is
25 attached hereto as Exhibit B.
26 11. On May 2, 2017, the U.S.P.T.O. duly and lawfully issued United
27 States Design Patent No. D785,700 (the D700 Patent), titled PORTIONS OF
28 AN EYEGLASS. Oakley is the owner by assignment of all right, title, and
-2- COMPLAINT
2 attached hereto as Exhibit C.
3 12. On August 7, 2007, the U.S.P.T.O. duly and lawfully issued United
4 States Design Patent No. D548,269 (the D269 Patent), titled
5 EYEGLASSES. Oakley is the owner by assignment of all right, title, and
7 attached hereto as Exhibit D.
8 13. On February 9, 2010, the U.S.P.T.O. duly and lawfully issued
10 EYEGLASS AND EYEGLASS COMPONENT. Oakley is the owner by
11 assignment of all right, title, and interest in the D737 Patent. A true and correct
12 copy of the D737 Patent is attached hereto as Exhibit E.
13 14. On April 6, 2010, the U.S.P.T.O. duly and lawfully issued United
14 States Design Patent No. D613,329 (the D329 Patent), titled EYEGLASS
15 FRONT. Oakley is the owner by assignment of all right, title, and interest in
16 the D329 Patent. A true and correct copy of the D329 Patent is attached hereto
17 as Exhibit F.
18 15. On July 31, 2007, the U.S.P.T.O. duly and lawfully issued United
22 attached hereto as Exhibit G.
23 16. On November 6, 2007, the U.S.P.T.O duly and lawfully issued
25 EYEGLASS FRAME. Oakley is the owner by assignment of all right, title,
26 and interest in the D689 Patent. A true and correct copy of the D689 Patent is
27 attached hereto as Exhibit H.
28 ///
-3- COMPLAINT
1 17. On December 4, 2007, the U.S.P.T.O. duly and lawfully issued

3 EYEGLASS COMPONENTS. Oakley is the owner by assignment of all
4 right, title, and interest in the D818 Patent. A true and correct copy of the D818
5 Patent is attached hereto as Exhibit I.
6 18. On July 31, 2007, the U.S.P.T.O. duly and lawfully issued United
10 attached hereto as Exhibit J.
11 19. On June 5, 2012, the U.S.P.T.O. duly and lawfully issued United
12 States Design Patent No. D661,339 (the D339 Patent), titled EYEGLASS.
13 Oakley is the owner by assignment of all right, title, and interest in the D339
14 Patent. A true and correct copy of the D339 Patent is attached hereto as Exhibit
15 K.
16 20. On August 3, 2010, the U.S.P.T.O. duly and lawfully issued United
17 States Design Patent No. D620,970 (the D970 Patent), titled EYEGLASS
18 COMPONENT. Oakley is the owner by assignment of all right, title, and
20 attached hereto as Exhibit L.
21 21. Defendant manufactures, uses, sells, offers for sale, and/or imports
22 into the United States eyewear that infringes Oakleys intellectual property
23 rights, including the D180 Patent, the D678 Patent, the D700 Patent, the D269
24 Patent, the D737 Patent, the D329 Patent, the D794 Patent, the D689 Patent, the
25 D818 Patent, the D793 Patent, the D339 Patent, and the D970 Patent
26 (collectively, the Asserted Patents).
27 22. Oakley manufactures and sells sunglasses under the mark
28 HOLBROOK bearing distinctive trade dress in the overall design of the
-4- COMPLAINT
1 sunglasses (HOLBROOK Trade Dress). An example of an Oakley product

2 bearing the distinctive HOLBROOK Trade Dress is depicted in the photograph
3 attached as Exhibit M.
4 23. As a result of Oakleys widespread use and display of the
5 HOLBROOK Trade Dress in association with its eyewear, (a) the public has
6 come to recognize and identify eyewear bearing the HOLBROOK Trade Dress
7 as emanating from Oakley, (b) the public recognizes that products bearing the
8 HOLBROOK Trade Dress constitute high quality products that conform to the
9 specifications created by Oakley, and (c) the HOLBROOK Trade Dress has
10 established strong secondary meaning and extensive goodwill.
11 24. The HOLBROOK Trade Dress is not functional. The design
12 features embodied by the HOLBROOK Trade Dress are not essential to the
13 function of the product, do not make the product cheaper or easier to
14 manufacture, and do not affect the quality of the product. The design of the
15 HOLBROOK Trade Dress is not a competitive necessity.
16 25. Subsequent to Oakleys use and adoption of the HOLBROOK
17 Trade Dress, Defendant has developed, manufactured, imported, advertised,
18 and/or sold products that use trade dress that is confusingly similar to the
19 HOLBROOK Trade Dress.
20 26. Oakley manufactures and sells sunglasses under the mark
21 STRAIGHT JACKET bearing distinctive trade dress in the overall design of the
22 earstems of the sunglasses (STRAIGHT JACKET Trade Dress). An example
23 of an Oakley product bearing the distinctive STRAIGHT JACKET Trade Dress
24 is depicted in the photograph attached as Exhibit N.
25 27. As a result of Oakleys widespread use and display of the
26 STRAIGHT JACKET Trade Dress in association with its eyewear, (a) the
27 public has come to recognize and identify eyewear bearing the STRAIGHT
28 JACKET Trade Dress as emanating from Oakley, (b) the public recognizes that
-5- COMPLAINT
1 products bearing the STRAIGHT JACKET Trade Dress constitute high quality
2 products that conform to the specifications created by Oakley, and (c) the
3 STRAIGHT JACKET Trade Dress has established strong secondary meaning
4 and extensive goodwill.
5 28. The STRAIGHT JACKET Trade Dress is not functional. The
6 design features embodied by the STRAIGHT JACKET Trade Dress are not
7 essential to the function of the product, do not make the product cheaper or
8 easier to manufacture, and do not affect the quality of the product. The design
9 of the STRAIGHT JACKET Trade Dress is not a competitive necessity.
10 29. Subsequent to Oakleys use and adoption of the STRAIGHT
11 JACKET Trade Dress, Defendant has developed, manufactured, imported,
12 advertised, and/or sold products that use trade dress that is confusingly similar
13 to the STRAIGHT JACKET Trade Dress.
14 30. Oakley manufactures and sells sunglasses under the mark FLAK
15 JACKET bearing distinctive trade dress in the overall design of the front face of
16 the sunglasses (FLAK JACKET Trade Dress). An example of an Oakley
17 product bearing the distinctive FLAK JACKET Trade Dress is depicted in the
18 photograph attached as Exhibit O.
19 31. As a result of Oakleys widespread use and display of the FLAK
20 JACKET Trade Dress in association with its eyewear, (a) the public has come to
21 recognize and identify eyewear bearing the FLAK JACKET Trade Dress as
22 emanating from Oakley, (b) the public recognizes that products bearing the
23 FLAK JACKET Trade Dress constitute high quality products that conform to
24 the specifications created by Oakley, and (c) the FLAK JACKET Trade Dress
25 has established strong secondary meaning and extensive goodwill.
26 32. The FLAK JACKET Trade Dress is not functional. The design
27 features embodied by the FLAK JACKET Trade Dress are not essential to the
28 function of the product, do not make the product cheaper or easier to
-6- COMPLAINT
1 manufacture, and do not affect the quality of the product. The design of the
2 FLAK JACKET Trade Dress is not a competitive necessity.
3 33. Subsequent to Oakleys use and adoption of the FLAK JACKET
5 and/or sold products that use trade dress that is confusingly similar to the FLAK
6 JACKET Trade Dress.
7 34. Defendants acts complained of herein have caused Oakley to
8 suffer irreparable injury to its business. Oakley will continue to suffer
9 substantial loss and irreparable injury unless and until Defendant is enjoined
10 from its wrongful actions complained of herein.
11 35. Oakley is informed and believes, and on that basis alleges, that
12 Defendants acts complained of herein are willful and deliberate.
13 36. Defendants acts complained of herein have caused Oakley to
14 suffer irreparable injury to its business. Oakley will suffer substantial loss of
15 goodwill and reputation unless and until Defendant is preliminarily and
16 permanently enjoined from its wrongful actions complained of herein.
17 IV. FIRST CLAIM FOR RELIEF
18 (Patent Infringement)
(35 U.S.C. 271)
19 37. Oakley repeats and re-alleges the allegations of paragraphs 1-36 of
20 this Complaint as if set forth fully herein.
21 38. This is a claim for patent infringement under 35 U.S.C. 271.
23 Defendant is the owner of U.S. Trademark Registration No. 3983166 for the
24
25
26 design mark for Sunglasses.
27 ///
28 ///
-7- COMPLAINT
2
3
4 Defendant sells sunglasses under its brand KHAN and its mark.
6 Defendant is the owner of U.S. Trademark Registration No. 2928637 for the
7 mark DXTREME in connection with, for example, eyewear.
9 Defendant sells sunglasses under its DXTREME mark.
10 43. Defendant, through its agents, employees, and/or servants has, and
11 continues to, knowingly, intentionally, and willfully directly infringe the D180
12 Patent by making, using, selling, offering for sale, and/or importing eyewear
13 having a design that would appear to an ordinary observer to be substantially
14 similar to the claim of the D180 Patent, including for example, Defendants
15 Khan Premium Polarized Mens Sport Cycling Fishing Baseball Running model
16 sunglasses as shown below.
17 Accused Product Oakleys Patent
18 Khan Premium Polarized Mens Sport D659,180
Cycling Fishing Baseball Running
19 Sunglasses
20
21
22
23
24
25
26 44. Defendants acts of infringement of the D180 Patent were
27 undertaken without permission or license from Oakley. Upon information and
28 belief, Defendant had actual knowledge of Oakleys rights in the design claimed
-8- COMPLAINT
1 in the D180 Patent. Oakley and its iconic designs are well-known throughout
2 the eyewear industry, and Defendants Khan Premium Polarized Mens Sport
3 Cycling Fishing Baseball Running model sunglasses are an identical copy of
4 Oakleys design. Accordingly, Defendants actions constitute willful and
5 intentional infringement of the D180 Patent. Defendant infringed the D180
6 Patent with reckless disregard of Oakleys patent rights. Defendant knew, or it
7 was so obvious that Defendant should have known, that its actions constituted
8 infringement of the D180 Patent. Defendants acts of infringement of the D180
9 Patent were not consistent with the standards of commerce for its industry.
14 similar to the claim of the D678 Patents including for example, Defendants
15 2J004-CM model sunglasses as shown below, which were sold and/or offered
16 for sale on Defendants website, www.frontierfashion.com.
18 2J004-CM D752,678
19
20
21
22
23
24
25
-9- COMPLAINT
2 the eyewear industry, and Defendants 2J004-CM model sunglasses are an
3 identical copy of Oakleys designs. Accordingly, Defendants actions constitute
4 willful and intentional infringement of the D678 Patent. Defendant infringed
5 the D678 Patent with reckless disregard of Oakleys patent rights. Defendant
6 knew, or it was so obvious that Defendant should have known, that its actions
7 constituted infringement of the D678 Patent. Defendants acts of infringement
8 of the D678 Patent were not consistent with the standards of commerce for its
9 industry.
15 2J004-CM model sunglasses as shown below, which were sold and/or offered
16 for sale, for example, on Defendants website, www.frontierfashion.com.
18 2J004-CM D785,700
19
20
21
22
23
24
- 10 - COMPLAINT
1 the eyewear industry, and Defendants 2J004-CM model sunglasses are a nearly
2 identical copy of Oakleys designs. Accordingly, Defendants actions constitute
8 industry.
14 P8644-KN and Khan Driving Skiing Biking model sunglasses as shown below,
15 which were sold and/or offered for sale, for example, on Defendants website,
16 www.frontierfashion.com.
18 P8644-KN D548,269
19
20
21
22
23 Khan Driving Skiing Biking Sunglasses
24
25
26
27
28
- 11 - COMPLAINT

5 the eyewear industry, and Defendants P8644-KN and Khan Driving Skiing
6 Biking model sunglasses are identical copies of Oakleys design. Accordingly,
7 Defendants actions constitute willful and intentional infringement of the D269
8 Patent. Defendant infringed the D269 Patent with reckless disregard of
9 Oakleys patent rights. Defendant knew, or it was so obvious that Defendant
10 should have known, that its actions constituted infringement of the D269 Patent.
11 Defendants acts of infringement of the D269 Patent were not consistent with
12 the standards of commerce for its industry.
18 POL-BP0039 model sunglasses as shown below, which were sold and/or
19 offered for sale, for example, on Defendants website,
22 POL-BP0039 D609,737
23
24
25
26
27
28
- 12 - COMPLAINT

5 the eyewear industry, and Defendants POL-BP0039 model sunglasses are an
6 identical copy of Oakleys design. Accordingly, Defendants actions constitute
12 industry.
18 POL-BP0039 model sunglasses as shown below, which were sold and/or
22 POL-BP0039 D613,329
23
24
25
26
27
28
- 13 - COMPLAINT

5 the eyewear industry, and Defendants POL-BP0039 model sunglasses are an
6 identical copy of Oakleys design. Accordingly, Defendants actions constitute
12 industry.
18 DXT-5019 model sunglasses as shown below, which were sold and/or offered
21 DXT-5019 D547,794
22
23
24
25
26
27
28
- 14 - COMPLAINT

5 the eyewear industry, and Defendants DXT-5019 model sunglasses copy
17 DXT-5019 model sunglasses as shown below, which were sold and/or offered
20 DXT-5019 D554,689
21
22
23
24
25
26
27
28
- 15 - COMPLAINT

5 the eyewear industry, and Defendants DXT-5019 model sunglasses copy
17 BP0072-CM and DXT-5019 model sunglasses as shown below, which were
18 sold and/or offered for sale, for example, on Defendants website,
21 BP0072-CM D556,818
22
23
24
25
26
27
28
- 16 - COMPLAINT
1 DXT-5019
2
3
4
5
6
7
8
13 the eyewear industry, and Defendants BP0072-CM and DXT-5019 model
14 sunglasses copy Oakleys design. Accordingly, Defendants actions constitute
20 industry.
26 Khan Slim Shield model sunglasses as shown below.
27 ///
28 ///
- 17 - COMPLAINT

2 Khan Slim Shield Sunglasses D547,793
3
4
5
6
7
8
9
10
15 the eyewear industry, and Defendants Khan Slim Shield model sunglasses are a
16 nearly identical copy of Oakleys design. Accordingly, Defendants actions
17 constitute willful and intentional infringement of the D793 Patent. Defendant
18 infringed the D793 Patent with reckless disregard of Oakleys patent rights.
19 Defendant knew, or it was so obvious that Defendant should have known, that
20 its actions constituted infringement of the D793 Patent. Defendants acts of
21 infringement of the D793 Patent were not consistent with the standards of
22 commerce for its industry.
28
- 18 - COMPLAINT
1 DXtreme Lightweight Sport Mens Baseball Cycling Shield model sunglasses

2 as shown below.
4 DXtreme Lightweight Sport Mens D661,339
Baseball Cycling Shield Sunglasses
5
6
7
8
9
10
15 the eyewear industry, and Defendants DXtreme Lightweight Sport Mens
16 Baseball Cycling Shield model sunglasses infringe Oakleys design.
17 Accordingly, Defendants actions constitute willful and intentional infringement
18 of the D339 Patent. Defendant infringed the D339 Patent with reckless
19 disregard of Oakleys patent rights. Defendant knew, or it was so obvious that
20 Defendant should have known, that its actions constituted infringement of the
21 D339 Patent. Defendants acts of infringement of the D339 Patent were not
22 consistent with the standards of commerce for its industry.
28 DXT-1325-CM model sunglasses as shown below, which were sold and/or
- 19 - COMPLAINT

4 DXT-1325-CM D620,970
5
6
7
8
9
10
11
16 the eyewear industry, and Defendants DXT-1325-CM model sunglasses
17 infringe Oakleys design. Accordingly, Defendants actions constitute willful
18 and intentional infringement of the D970 Patent. Defendant infringed the D970
23 67. As a direct and proximate result of Defendants acts of
24 infringement, Defendant has derived and received gains, profits, and advantages
25 in an amount that is not presently known to Oakley.
26 68. Pursuant to 35 U.S.C. 284, Oakley is entitled to damages for
27 Defendants infringing acts and treble damages together with interests and costs
28 as fixed by this Court.
- 20 - COMPLAINT
1 69. Pursuant to 35 U.S.C. 285, Oakley is entitled to reasonable

2 attorneys fees for the necessity of bringing this claim.
3 70. Pursuant to 35 U.S.C. 289, Oakley is entitled to Defendants total
4 profits from Defendants infringement of Oakleys design patents.
5 71. Due to the aforesaid infringing acts, Oakley has suffered great and
6 irreparable injury, for which Oakley has no adequate remedy at law.
7 72. Defendant will continue to directly and/or indirectly infringe
8 Oakleys patent rights to the great and irreparable injury of Oakley, unless
9 enjoined by this Court.
10 V. SECOND CLAIM FOR RELIEF
11 (Trade Dress Infringement)
(15 U.S.C. 1125(a))
12
13 73. Oakley repeats and re-alleges the allegations of paragraphs 1-36
14 and 39-73 of this Complaint as if set forth fully herein.
15 74. This is a claim for trade dress infringement under 15 U.S.C.
16 1125(a).
17 75. Subsequent to Oakleys use and adoption of the HOLBROOK
19 and/or sold products that use trade dress that is confusingly similar to the
20 HOLBROOK Trade Dress. As shown below, for example, Defendants
21 BP0088-CM and BP0089-SFT model sunglasses, which are sold and/or offered
22 for sale, for example, on Defendants website www.frontierfashion.com, use a
23 trade dress that is confusingly similar to Oakleys HOLBROOK Trade Dress.
24 ///
25 ///
26 ///
27 ///
28 ///
- 21 - COMPLAINT
1 Accused Product HOLBROOK TRADE DRESS

2 BP0088-CM HOLBROOK Trade Dress
3
4
5
6
7 BP0089-SFT
8
9
10
11
12
13
14 76. Defendants use of the HOLBROOK Trade Dress in connection
15 with its sunglasses is likely to cause confusion, or to cause mistake, or to
16 deceive as to the affiliation, connection, or association of Defendant with
17 Oakley.
18 77. Subsequent to Oakleys use and adoption of the STRAIGHT
19 JACKET and FLAK JACKET Trade Dress, Defendant has developed,
20 manufactured, imported, advertised, and/or sold products that use trade dress
21 that is confusingly similar to the STRAIGHT JACKET and FLAK JACKET
22 Trade Dress. As shown below, for example, Defendants BP0083 model
23 sunglasses use trade dress that is confusingly similar to Oakleys STRAIGHT
24 JACKET and FLAK JACKET Trade Dress.
25 ///
26 ///
27 ///
28 ///
- 22 - COMPLAINT
1 Accused Product HOLBROOK TRADE DRESS

2 BP0083 STRAIGHT JACKET Trade Dress
3
4
5
6
7
FLAK JACKET Trade Dress
8
9
10
11
12
13
14 78. Defendants use of the STRAIGHT JACKET and FLAK JACKET
15 Trade Dress in connection with its sunglasses is likely to cause confusion, or to
16 cause mistake, or to deceive as to the affiliation, connection, or association of
17 Defendant with Oakley.
19 Defendant infringed Oakleys trade dress rights with the intent to unfairly
20 compete with Oakley, to trade upon Oakleys reputation and goodwill by
21 causing confusion and mistake among customers and the public, and to deceive
22 the public into believing that Defendants products are associated with,
23 sponsored by, originated from, or are approved by Oakley, when they are not,
24 resulting in a loss of reputation in, and mischaracterization of, Oakleys
25 products and its brand, damaging its marketability and saleability.
26 80. Defendants activities constitute willful and intentional
27 infringement of the Oakleys trade dress rights in total disregard of Oakleys
28 proprietary rights, and were done despite Defendants knowledge that the use of
- 23 - COMPLAINT
1 each of the HOLBROOK Trade Dress, STRAIGHT JACKET Trade Dress, and
2 FLAK JACKET Trade Dress was and is in direct contravention of Oakleys
3 rights.
5 Defendant has derived and received, and will continue to derive and receive,
6 gains, profits, and advantages from Defendants trade dress infringement in an
7 amount that is not presently known to Oakley. By reason of Defendants
8 actions, constituting trade dress infringement, Oakley has been damaged and is
9 entitled to monetary relief in an amount to be determined at trial.
10 82. Due to Defendants actions, constituting trade dress infringement,
11 Oakley has suffered and continues to suffer great and irreparable injury, for
12 which Oakley has no adequate remedy at law.
14 Defendants infringing acts, up to three times actual damages as fixed by this
15 Court, and its reasonable attorneys fees for the necessity of bringing this claim.
16 VI. THIRD CLAIM FOR RELIEF
17 (Federal Unfair Competition & False Designation of Origin)
(15 U.S.C. 1125(a))
18
21 85. This is a claim for unfair competition and false designation of
22 origin arising under 15 U.S.C. 1125(a).
23 86. Defendants use of the HOLBROOK Trade Dress without Oakleys
24 consent constitutes a false designation of origin, false or misleading description
25 of fact, or false or misleading representation of fact, which is likely to cause
26 confusion, or to cause mistake, or to deceive as to the affiliation, connection, or
27 association of such person with another person, or as to the origin, sponsorship,
28
- 24 - COMPLAINT
1 or approval of his or her goods or commercial activities by another person in

2 violation of 15 U.S.C. 1125(a).
3 87. Defendants use of the HOLBROOK Trade Dress without Oakleys
4 consent constitutes a false designation of origin, false or misleading description
5 of fact, or false or misleading representation of fact, which in commercial
6 advertising or promotion, misrepresents the nature, characteristics, qualities, or
7 geographic origin of his or her or another persons goods or commercial
8 activities in violation of 15 U.S.C. 1125(a).
9 88. Such conduct by Defendant is likely to confuse, mislead, and
10 deceive Defendants customers, purchasers, and members of the public as to the
11 origin of the HOLBROOK Trade Dress or cause said persons to believe that
12 Defendant and/or its products have been sponsored, approved, authorized, or
13 licensed by Oakley or are in some way affiliated or connected with Oakley, all
14 in violation of 15 U.S.C. 1125(a) and constitutes unfair competition with
15 Oakley.
16 89. Defendants use of the STRAIGHT JACKET Trade Dress without
17 Oakleys consent constitutes a false designation of origin, false or misleading
18 description of fact, or false or misleading representation of fact, which is likely
19 to cause confusion, or to cause mistake, or to deceive as to the affiliation,
20 connection, or association of such person with another person, or as to the
21 origin, sponsorship, or approval of his or her goods or commercial activities by
22 another person in violation of 15 U.S.C. 1125(a).
23 90. Defendants use of the STRAIGHT JACKET Trade Dress without
25 description of fact, or false or misleading representation of fact, which in
26 commercial advertising or promotion, misrepresents the nature, characteristics,
27 qualities, or geographic origin of his or her or another persons goods or
28 commercial activities in violation of 15 U.S.C. 1125(a).
- 25 - COMPLAINT

3 origin of the STRAIGHT JACKET Trade Dress or cause said persons to believe
4 that Defendant and/or its products have been sponsored, approved, authorized,
5 or licensed by Oakley or are in some way affiliated or connected with Oakley,
6 all in violation of 15 U.S.C. 1125(a) and constitutes unfair competition with
7 Oakley.
8 92. Defendants use of the FLAK JACKET trade dress without
10 description of fact, or false or misleading representation of fact, which is likely
11 to cause confusion, or to cause mistake, or to deceive as to the affiliation,
12 connection, or association of such person with another person, or as to the
13 origin, sponsorship, or approval of his or her goods or commercial activities by
14 another person in violation of 15 U.S.C. 1125(a).
15 93. Defendants use of the FLAK JACKET Trade Dress without
17 description of fact, or false or misleading representation of fact, which in
18 commercial advertising or promotion, misrepresents the nature, characteristics,
19 qualities, or geographic origin of his or her or another persons goods or
20 commercial activities in violation of 15 U.S.C. 1125(a).
23 origin of the FLAK JACKET Trade Dress or cause said persons to believe that
24 Defendant and/or its products have been sponsored, approved, authorized, or
25 licensed by Oakley or are in some way affiliated or connected with Oakley, all
26 in violation of 15 U.S.C. 1125(a) and constitutes unfair competition with
27 Oakley.
28 ///
- 26 - COMPLAINT

2 Defendants actions were undertaken willfully with full knowledge of the falsity
3 of such designation of origin and false descriptions or representations.
6 gains, profits, and advantages from Defendants false designation of origin, false
7 or misleading statements, descriptions of fact, false or misleading
8 representations of fact, and/or unfair competition in an amount that is not
9 presently known to Oakley. By reason of Defendants actions, constituting false
10 designation of origin, false or misleading statements, false or misleading
11 descriptions of fact, false or misleading representations of fact, and/or unfair
12 competition, Oakley has been damaged and is entitled to monetary relief in an
13 amount to be determined at trial.
14 97. Due to Defendants actions, constituting false designation of origin,
15 false or misleading statements, false or misleading description of fact, false or
16 misleading representations of fact, and/or unfair competition, Oakley has
17 suffered and continues to suffer great and irreparable injury, for which Oakley
18 has no adequate remedy at law.
20 Defendants acts constituting false designation of origin, false or misleading
21 statements, false or misleading descriptions of fact, false or misleading
22 representations of fact, and/or unfair competition, up to three times actual
23 damages as fixed by this Court, and its reasonable attorneys fees for the
24 necessity of bringing this claim.
25 VII. FIFTH CLAIM FOR RELIEF
26 (California Unfair Competition)
- 27 - COMPLAINT
1 100. This is a claim for unfair competition, arising under California

2 Business & Professions Code 17200, et seq. and California common law.
3 101. Defendants acts of trade dress infringement, and false designation
4 of origin, complained of herein constitute unfair competition with Oakley under
5 the common law and statutory laws of the State of California, particularly
6 California Business & Professions Code 17200 et seq.
9 gains, profits, and advantages from Defendants unfair competition in an
10 amount that is not presently known to Oakley. By reason of Defendants
11 wrongful acts as alleged in this Complaint, Oakley has been damaged and is
12 entitled to monetary relief in an amount to be determined at trial.
13 103. By its actions, Defendant has injured and violated the rights of
14 Oakley and has irreparably injured Oakley, and such irreparable injury will
15 continue unless Defendant is enjoined by this Court.
16 WHEREFORE, Oakley prays for judgment in its favor against
17 Defendant for the following relief:
18 A. An Order adjudging Defendant to have willfully infringed the
19 Asserted Patents under 35 U.S.C. 271;
20 B. A preliminary and permanent injunction enjoining Defendant, its
21 respective officers, directors, agents, servants, employees, and attorneys, and
22 those persons in active concert or participation with Defendant, from making,
23 using, selling, offering to sell, and/or importing Defendants Khan Premium
24 Polarized Mens Sport Cycling Fishing Baseball Running Sunglasses, 2J004-
25 CM, P8644-KN, Khan Driving Skiing Biking Sunglasses, POL-BP0039, DXT-
26 5019, BP0072-CM, Khan Slim Shield, DXtreme Lightweight Sport Mens
27 Baseball Cycling Shield Sunglasses, DXT-1325-CM, and any products that are
28 not colorably different from these products;
- 28 - COMPLAINT
1 C. A preliminary and permanent injunction enjoining Defendant, its

2 respective officers, directors, agents, servants, employees, and attorneys, and
3 those persons in active concert or participation with Defendant, from infringing
4 any of the Asserted Patents in violation of 35 U.S.C. 271;
5 D. That Defendant accounts for all gains, profits, and advantages
6 derived by Defendants infringement of the Asserted Patents in violation of
7 35 U.S.C. 271, and that Defendant pays to Oakley all damages suffered by
8 Oakley and/or Defendants total profit from such infringement pursuant to 35
9 U.S.C. 284 and 289;
10 E. An Order for a trebling of damages and/or exemplary damages
11 because of Defendants willful conduct pursuant to 35 U.S.C. 284;
12 F. That the Court find for Oakley and against Defendant on Oakleys
13 claims of trade dress infringement, false designation of origin, and unfair
14 competition under 15 U.S.C. 1125(a);
15 G. That the Court find for Oakley and against Defendant on Oakleys
16 claims of unfair competition under California Business & Professions Code
17 17200, et seq. and California common law;
18 H. That the Court issue a preliminary and permanent injunction
19 against Defendant, its agents, servants, employees, representatives, successors,
20 and assigns, and all persons, firms, or corporations in active concert or
21 participation with Defendant, enjoining them from engaging in the following
22 activities and from assisting or inducing, directly or indirectly, others to engage
23 in the following activities:
24 1. Manufacturing, importing, marketing, displaying,
25 distributing, offering to sell, and/or selling Defendants
26 BP0088-CM, BP0089-SFT, and BP0083 products shown
27 above and any products that are not colorably different
28 therefrom;
- 29 - COMPLAINT
1 2. using Oakleys HOLBROOK Trade Dress, or any other trade

2 dress that is confusingly similar to Oakleys HOLBROOK
3 Trade Dress;
4 3. using Oakleys STRAIGHT JACKET Trade Dress, or any
5 other trade dress that is confusingly similar to Oakleys
6 STRAIGHT JACKET Trade Dress;
7 4. using Oakleys FLAK JACKET Trade Dress, or any other
8 trade dress that is confusingly similar to Oakleys FLAK
9 JACKET Trade Dress;
10 5. falsely designating the origin of Defendants goods;
11 6. unfairly competing with Oakley in any manner whatsoever;
12 7. causing a likelihood of confusion or injuries to Oakleys
13 business reputation; and,
14 8. manufacturing, importing, marketing, displaying,
15 distributing, offering to sell, and/or selling any goods that
16 infringe Oakleys HOLBROOK Trade Dress, STRAIGHT
17 JACKET Trade Dress or FLAK JACKET Trade Dress.
18 I. That an accounting be ordered to determine Defendants profits
19 resulting from its trade dress infringement, false designation of origin, and
20 unfair competition, and that Oakley be awarded monetary relief in an amount to
21 be fixed by the Court in its discretion as it finds just as an equitable remedy and
22 as a remedy under 15 U.S.C. 1117, including:
23 1. all profits received by Defendant from sales and revenues of
24 any kind made as a result of its infringing actions, said
25 amount to be trebled;
26 2. all damages sustained by Oakley as a result of Defendants
27 acts of trade dress infringement, unfair competition, and
28
- 30 - COMPLAINT
1 false designation of origin, and that such damages be trebled;

2 and
3 3. punitive damages stemming from Defendants willful,
4 intentional, and malicious acts;
5 J. That such damages and profits be trebled and awarded to Oakley
6 pursuant to 15 U.S.C. 1117;
7 K. An Order adjudging that this is an exceptional case;
8 L. That, because of the exceptional nature of this case resulting from
9 Defendants deliberate infringing actions, this Court award to Oakley all
10 reasonable attorneys fees, costs, and disbursements incurred as a result of this
11 action, pursuant to 15 U.S.C. 1117 and/or 35 U.S.C. 285;
12 M. That Oakley recover exemplary damages pursuant to California
13 Civil Code 3294;
14 N. An award of pre-judgment and post-judgment interest and costs of
15 this action against Defendant; and,
16 O. Such other and further relief as this Court may deem just and
17 proper.
18 Respectfully submitted,
20
21 Dated: August 22, 2017 By: /s/ Ali S. Razai
Michael K. Friedland
22 michael.friedland@knobbe.com
Ali S. Razai
23 ali.razai@knobbe.com
Daniel C. Kiang
24 daniel.kiang@knobbe.com
25 Attorneys for Plaintiff
OAKLEY, INC.
26
27
28
- 31 - COMPLAINT
1 DEMAND FOR JURY TRIAL

2 Plaintiff Oakley, Inc. hereby demands a trial by jury on all issues so
3 triable.
4 Respectfully submitted,
6
7 Dated: August 22, 2017 By: /s/ Ali S. Razai
Michael K. Friedland
8 michael.friedland@knobbe.com
Ali S. Razai
9 ali.razai@knobbe.com
Daniel C. Kiang
10 daniel.kiang@knobbe.com
Attorneys for Plaintiff
11 OAKLEY, INC.
12 26500201
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
- 32 - COMPLAINT
1 TABLE OF EXHIBITS
2 Page #
3 Exhibit A ............................................................................................................... 1
4 Exhibit B ............................................................................................................... 7
5 Exhibit C ............................................................................................................. 14
6 Exhibit D ............................................................................................................. 21
7 Exhibit E ............................................................................................................. 26
8 Exhibit F ............................................................................................................. 31
9 Exhibit G ............................................................................................................. 35
10 Exhibit H ............................................................................................................. 40
11 Exhibit I .............................................................................................................. 45
12 Exhibit J .............................................................................................................. 51
13 Exhibit K ............................................................................................................. 56
14 Exhibit L ............................................................................................................. 61
15 Exhibit M ............................................................................................................ 67
16 Exhibit N ............................................................................................................. 68
17 Exhibit O ............................................................................................................. 69
18
19
20
21
22
23
24
25
26
27
28
TABLE OF EXHIBITS
EXHIBIT A
EXHIBIT A
-1-
EXHIBIT A
-2-
EXHIBIT A
-3-
EXHIBIT A
-4-
EXHIBIT A
-5-
EXHIBIT A
-6-
EXHIBIT B
EXHIBIT B
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EXHIBIT B
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EXHIBIT B
-9-
EXHIBIT B
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EXHIBIT B
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EXHIBIT B
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EXHIBIT B
- 13 -
EXHIBIT C
EXHIBIT C
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EXHIBIT C
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EXHIBIT C
- 16 -
EXHIBIT C
- 17 -
EXHIBIT C
- 18 -
EXHIBIT C
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EXHIBIT C
- 20 -
EXHIBIT D
EXHIBIT D
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EXHIBIT D
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EXHIBIT D
- 23 -
EXHIBIT D
- 24 -
EXHIBIT D
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EXHIBIT E
EXHIBIT E
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EXHIBIT E
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EXHIBIT E
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EXHIBIT E
- 29 -
EXHIBIT E
- 30 -
EXHIBIT F
EXHIBIT F
- 31 -
EXHIBIT F
- 32 -
EXHIBIT F
- 33 -
EXHIBIT F
- 34 -
EXHIBIT G
EXHIBIT G
- 35 -
EXHIBIT G
- 36 -
EXHIBIT G
- 37 -
EXHIBIT G
- 38 -
EXHIBIT G
- 39 -
EXHIBIT H
EXHIBIT H
- 40 -
EXHIBIT H
- 41 -
EXHIBIT H
- 42 -
EXHIBIT H
- 43 -
EXHIBIT H
- 44 -
EXHIBIT I
EXHIBIT I
- 45 -
EXHIBIT I
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EXHIBIT I
- 47 -
EXHIBIT I
- 48 -
EXHIBIT I
- 49 -
EXHIBIT I
- 50 -
EXHIBIT J
EXHIBIT J
- 51 -
EXHIBIT J
- 52 -
EXHIBIT J
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EXHIBIT J
- 54 -
EXHIBIT J
- 55 -
EXHIBIT K
EXHIBIT K
- 56 -
EXHIBIT K
- 57 -
EXHIBIT K
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EXHIBIT K
- 59 -
EXHIBIT K
- 60 -
EXHIBIT L
EXHIBIT L
- 61 -
EXHIBIT L
- 62 -
EXHIBIT L
- 63 -
EXHIBIT L
- 64 -
EXHIBIT L
- 65 -
EXHIBIT L
- 66 -
EXHIBIT M
EXHIBIT M
- 67 -
EXHIBIT N
EXHIBIT N
- 68 -
EXHIBIT O
EXHIBIT O
- 69 -
Case 3:17-cv-01693-WQH-BGS Document 1-1 Filed 08/22/17 PageID.119 Page 1 of 1
JS 44 (Rev. 06/17) CIVIL COVER SHEET
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
I. (a) PLAINTIFFS DEFENDANTS

OAKLEY, INC., a Washington corporation FRONTIER FASHION, INC., a California corporation
(b) County of Residence of First Listed Plaintiff Orange County of Residence of First Listed Defendant
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.
(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)
Michael K. Friedland, Ali S. Razai, Daniel C. Kiang
Knobbe, Martens, Olson & Bear, LLP
2040 Main Street, 14th Floor, Irvine, CA 92614 (949) 760-0404
'17CV1693 WQHBGS
II. BASIS OF JURISDICTION (Place an X in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an X in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
u 1 U.S. Government u 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State u 1 u 1 Incorporated or Principal Place u 4 u 4
of Business In This State
u 2 U.S. Government u 4 Diversity Citizen of Another State u 2 u 2 Incorporated and Principal Place u 5 u 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State
Citizen or Subject of a u 3 u 3 Foreign Nation u 6 u 6

Foreign Country
IV. NATURE OF SUIT (Place an X in One Box Only) Click here for: Nature of Suit Code Descriptions.
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
u 110 Insurance PERSONAL INJURY PERSONAL INJURY u 625 Drug Related Seizure u 422 Appeal 28 USC 158 u 375 False Claims Act
u 120 Marine u 310 Airplane u 365 Personal Injury - of Property 21 USC 881 u 423 Withdrawal u 376 Qui Tam (31 USC
u 130 Miller Act u 315 Airplane Product Product Liability u 690 Other 28 USC 157 3729(a))
u 140 Negotiable Instrument Liability u 367 Health Care/ u 400 State Reapportionment
u 150 Recovery of Overpayment u 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS u 410 Antitrust
& Enforcement of Judgment Slander Personal Injury u 820 Copyrights u 430 Banks and Banking
u 151 Medicare Act u 330 Federal Employers Product Liability u 830 Patent u 450 Commerce
u 152 Recovery of Defaulted Liability u 368 Asbestos Personal u 835 Patent - Abbreviated u 460 Deportation
Student Loans u 340 Marine Injury Product New Drug Application u 470 Racketeer Influenced and
(Excludes Veterans) u 345 Marine Product Liability u 840 Trademark Corrupt Organizations
u 153 Recovery of Overpayment Liability PERSONAL PROPERTY LABOR SOCIAL SECURITY u 480 Consumer Credit
of Veterans Benefits u 350 Motor Vehicle u 370 Other Fraud u 710 Fair Labor Standards u 861 HIA (1395ff) u 490 Cable/Sat TV
u 160 Stockholders Suits u 355 Motor Vehicle u 371 Truth in Lending Act u 862 Black Lung (923) u 850 Securities/Commodities/
u 190 Other Contract Product Liability u 380 Other Personal u 720 Labor/Management u 863 DIWC/DIWW (405(g)) Exchange
u 195 Contract Product Liability u 360 Other Personal Property Damage Relations u 864 SSID Title XVI u 890 Other Statutory Actions
u 196 Franchise Injury u 385 Property Damage u 740 Railway Labor Act u 865 RSI (405(g)) u 891 Agricultural Acts
u 362 Personal Injury - Product Liability u 751 Family and Medical u 893 Environmental Matters
Medical Malpractice Leave Act u 895 Freedom of Information
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS u 790 Other Labor Litigation FEDERAL TAX SUITS Act
u 210 Land Condemnation u 440 Other Civil Rights Habeas Corpus: u 791 Employee Retirement u 870 Taxes (U.S. Plaintiff u 896 Arbitration
u 220 Foreclosure u 441 Voting u 463 Alien Detainee Income Security Act or Defendant) u 899 Administrative Procedure
u 230 Rent Lease & Ejectment u 442 Employment u 510 Motions to Vacate u 871 IRSThird Party Act/Review or Appeal of
u 240 Torts to Land u 443 Housing/ Sentence 26 USC 7609 Agency Decision
u 245 Tort Product Liability Accommodations u 530 General u 950 Constitutionality of
u 290 All Other Real Property u 445 Amer. w/Disabilities - u 535 Death Penalty IMMIGRATION State Statutes
Employment Other: u 462 Naturalization Application
u 446 Amer. w/Disabilities - u 540 Mandamus & Other u 465 Other Immigration
Other u 550 Civil Rights Actions
u 448 Education u 555 Prison Condition
u 560 Civil Detainee -
Conditions of
Confinement
V. ORIGIN (Place an X in One Box Only)
u 1 Original u 2 Removed from u 3 Remanded from u 4 Reinstated or u 5 Transferred from u 6 Multidistrict u 8 Multidistrict
Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation -
(specify) Transfer Direct File
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
35 U.S.C. 271; 15 U.S.C. 1125(a)
VI. CAUSE OF ACTION Brief description of cause:
Patent Infringement, Federal Trade Dress Infringement, Federal Unfair Competition & False Designation of Origin
VII. REQUESTED IN u CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RULE 23, F.R.Cv.P. to be determined JURY DEMAND: u Yes u No
VIII. RELATED CASE(S)
(See instructions):
IF ANY JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
08/22/2017 /s/ Ali S. Razai
FOR OFFICE USE ONLY
RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

Oakley v. Frontier Fashion - Complaint

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Oakley v. Frontier Fashion - Complaint

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Case 3:17-cv-01693-WQH-BGS Document 1 Filed 08/22/17 PageID.

1 Michael K. Friedland (SBN 157,217)

1 Plaintiff Oakley, Inc. (Oakley) hereby complains of Frontier Fashion,

1 17. On December 4, 2007, the U.S.P.T.O. duly and lawfully issued

1 sunglasses (HOLBROOK Trade Dress). An example of an Oakley product

1 50. Defendants acts of infringement of the D269 Patent were

1 52. Defendants acts of infringement of the D737 Patent were

1 54. Defendants acts of infringement of the D329 Patent were

1 56. Defendants acts of infringement of the D794 Patent were

1 58. Defendants acts of infringement of the D689 Patent were

1 Accused Product Oakleys Patent

1 DXtreme Lightweight Sport Mens Baseball Cycling Shield model sunglasses

1 offered for sale, for example, on Defendants website,

1 69. Pursuant to 35 U.S.C. 285, Oakley is entitled to reasonable

1 Accused Product HOLBROOK TRADE DRESS

1 Accused Product HOLBROOK TRADE DRESS

1 or approval of his or her goods or commercial activities by another person in

1 91. Such conduct by Defendant is likely to confuse, mislead, and

1 95. Oakley is informed and believes, and thereon alleges, that

1 100. This is a claim for unfair competition, arising under California

1 C. A preliminary and permanent injunction enjoining Defendant, its

1 2. using Oakleys HOLBROOK Trade Dress, or any other trade

1 false designation of origin, and that such damages be trebled;

1 DEMAND FOR JURY TRIAL

I. (a) PLAINTIFFS DEFENDANTS

Citizen or Subject of a u 3 u 3 Foreign Nation u 6 u 6

RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

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