Pretty Star Store v. Chen - Complaint

Case 2:18-cv-05187 Document 1 Filed 06/12/18 Page 1 of 28 Page ID #:1
Tommy SF Wang (SBN: 272409)

1
Leontyne Fan (SBN: 285042)
2 WANG IP LAW GROUP, P.C.
18645 E. Gale Ave., Suite 205
3
City of Industry, CA 91748
4 Telephone: (888) 827-8880
Facsimile: (888) 827-8880
5 Email: twang@thewangiplaw.com, lfan@thewangiplaw.com
6
Attorneys for Plaintiff Pretty Star Store, LLC
7
UNITED STATES DISTRICT
8
CENTRAL DISTRICT OF CALIFORNIA
9
PRETTY STAR STORE, LLC, a Case No.:
10 California limited liability company
11 PLAINTIFF’S COMPLAINT FOR
Plaintiff, DAMAGES AND PERMANENT
12 INJUNCTION FOR:
vs. 1. DESIGN PATENT
13
INFRINGEMENT;
14 YUANMIN CHEN, an individual, and 2. FALSE ADVERTISING;
DOES 1 TO 10, 3. CALIFORNIA COMMON LAW
15
Defendant. UNFAIR COMPETITION;
16 4. UNFAIR COMPETITION (Cal.
Bus. & Prof. Code § 17200);
17
5. INTENTIONAL
18 INTERFERENCE WITH
PROSPECTIVE ECONOMIC
19 RELATIONS;
20 6. UNJUST ENRICHMENT; AND
7. DEMAND FOR ACCOUNTING
21
[Unlimited]
22
23 JURY TRIAL DEMANDED

24
25
COMPLAINT
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1 PLAINTIFF PRETTY STAR STORE, LLC d.b.a DecoBros (hereinafter

2 “Plaintiff” or “DecoBros”) hereby files this Complaint against the Defendant
3 YUANMIN CHEN, an individual (hereinafter “Defendant”), and DOES 1 to 10
4 (collectively, “Defendants”), and alleges as follows:
5 INTRODUCTION
6 1. This action concerns Defendant’s willful and blatant infringement of
7 Plaintiff’s protectable rights in and to the design patent of DecoBros Stackable
8 Under Sink Cabinet Sliding Basket Organizer Drawer (“DecoBros Stackable
9 Drawer”) and DecoBros Metal Mesh Rolling Cart, Silver (“DecoBros Rolling
10 Cart”). Plaintiff seeks damages, attorneys’ fees, costs, pre-judgment and post-
11 judgment interest, and preliminary and permanent injunctive relief.
12 JURISDICTION AND VENUE
13 2. This action arises under 35 U.S.C. §§ 271, 281, 283, 284 and 285.
14 This Court has jurisdiction over the subject matter of this action pursuant to 28
15 U.S.C. § 1331 and 1332, and 28 U.S.C. § 1338. This Court has supplemental
16 jurisdiction over California state law and common law claims pursuant to 28 U.S.C.
17 § 1367(a).
18 3. This Court has personal jurisdiction over Defendant, as Defendant has
19 engaged in acts of patent infringement in the United States and in the Central
20 District of California. Specifically, Defendant has purposely and intentionally
21 subjected itself to the privileges of doing business in the State of California by
22 placing its goods in the stream of commerce with the intent that they would be sold
23 in California. Defendant has offered for sale and sold products in the State of
24 California, which infringe upon certain design patents owned by DecoBros.
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COMPLAINT
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1 4. Supplemental jurisdiction exists over Defendant because on

2 information and belief, Defendant conducts business in California and in this
3 judicial district, has purposefully availed itself to California in this judicial district,
4 or has otherwise availed itself of the privileges and protections of the law of the
5 State of California such that this Court’s assertion of jurisdiction over Defendant
6 does not offend traditional notions of fair play and justice.
7 5. Venue is proper in this judicial district under 28 U.S.C. §§ 1391(b)
8 and 1400(b), as Defendant has committed acts of infringement in this judicial
9 district.
10 THE PARTIES
11 6. Plaintiff PRETTY STAR STORE, LLC, d.b.a. DecoBros, is, and at all
12 relevant times herein, was a limited liability company with its principal place of
13 business in 19745 Colima Road, #1-52, Rowland Heights, California, 91748.
14 7. Plaintiff is informed and believes, and based thereon alleges, that
15 Defendant CHEN is, and at all relevant time was, an individual who resides in
16 either Industry, California or the People’s Republic of China.
17 8. Upon information and belief, Defendant is marketing, advertising,
18 promoting, importing, offering for sale, and/or selling the organization products as
19 described in further detail below.
20 9. Plaintiff does not know the true names, identities and capacities of
21 Defendant sued herein as DOES 1 to 10, and therefore sues this Defendant by such
22 fictitious names. At such time as Plaintiff learns the true names, identities, and
23 capacities of Defendants DOES 1 to 10, Plaintiff will amend this Complaint to
24 reflect such names and capacities. Plaintiff is informed and believes, and thereon
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COMPLAINT
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1 alleges that Defendants DOES 1 to 10, are responsible in some manner for the
2 actions alleged herein and the damages caused to Plaintiff.
3 THE PATENT IN SUIT
4 10. On or about July 23, 2014, Tsung-Yu Tsai filed an application for a
5 design patent on “Stackable Cabinet Basket Drawer.” On or about February 3,
6 2015, the United States Patent and Trademark Office (“USPTO”) duly granted U.S.
7 Patent No. D721,904 S (“the ‘904 Patent”) to Mr. Tsai. A copy of the ‘904 Patent
8 is attached as Exhibit 1 to this Complaint.
9 11. On or about October 7, 2014 the ‘904 Patent was assigned to Plaintiff.
10 A copy of the Assignment of the ‘904 Patent is attached as Exhibit 2.
11 12. On or about July 28, 2014, Plaintiff filed an application for a design
12 patent on “Portion of a Rolling Cart.” On or about July 21, 2015, the United States
13 Patent and Trademark Office (“USPTO”) duly granted U.S. Patent No. D734,914 S
14 (“the ‘914 Patent”) to Plaintiff. A copy of the ‘914 Patent is attached as Exhibit 3
15 to this Complaint.
16 13. The ‘904 Patent and ‘914 Patent are referred to as “Asserted Patent”.
17 FACTUAL BACKGROUND
18 14. Plaintiff produces organizational products (houseware) for consumers
19 to simply and easily manage and organize their home and office.
20 15. Plaintiff is an owner of the Asserted Patent and has all rights
21 thereunder, including the right and standing to enforce the Asserted Patent.
22 16. Plaintiff is fiercely protective of the superior quality and practicability,
23 as well as the user-oriented design that its product has come to represent, closely
24 monitoring the manufacturing and marketing of its products.
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COMPLAINT
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1 PLAINTIFF’S “DECOBROS STACKABLE UNDER SINK CABINET

2 SLIDING BASKET ORGANIZER DRAWER”
3 17. Plaintiff sells its product based on the Asserted Patent as “DecoBros
4 Stackable Under Sink Cabinet Sliding Basket Organizer Drawer” on Amazon.com,
5 the online shopping platform.
6 18. DecoBros Stackable Drawer became an instant success and has more
7 than 2,700 customer reviews and has earned a four and a half stars rating from
8 customers. A printout showing the sale of DecoBros Stackable Drawer is attached
9 as Exhibit 4 to this Complaint.
10 19. Plaintiff’s DecoBros Stackable Drawer is designed distinctively with
11 the following features: 1) stackable sliding baskets provide easy access; 2) fits well
12 into cabinets to increase organizational capabilities; 3) features elegant Chrome or
13 Bronze finish; and 4) dimensions that are 10.2 inches high by 10.8 inches wide by
14 6.7 inches long.
15 20. The above-described characteristics and design together constitute
16 Plaintiff’s ‘904 Patent, in which Plaintiff owns protectable rights.
17 21. On or around September of 2017, Plaintiff discovered that Defendant
18 was manufacturing and selling a low quality version of the DecoBros Stackable
19 Drawer branded as “NEX Under Sink Cabinet Sliding Basket Organizer Kitchen
20 Storage Drawers Bathroom Holder, Plating” (“NEX 1-Tier Basket”) and “NEX 2-
21 Tier Sliding Basket Organizer Drawer Under Sink Cabinet Kitchen Storage
22 Drawers Bathroom Organizer, Plating” (“NEX 2-Tier Basket”) (collectively,
23 “Infringing Products”) on the internet that infringed upon Plaintiff’s ‘904 Patent.
24
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COMPLAINT
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1 The design of the Infringing Products is substantially the same as the design that is
2 the subject matter of the ‘904 Design Patent.
3 22. Defendant ’s infringing product, NEX 1-Tier Basket, contains the
4 following characteristics: 1) 16.77 x 10.90 x 10.23 inches in dimension; 2) easy
5 assembly; 3) no tools needed; 4) Good-quality material; 5) removable sliding
6 basket and sturdy rack; and 6) metallic silver finish.
7 23. Defendant ’s infringing product, NEX 2-Tier Basket, contains the
8 following characteristics: 1) 16.81 x 10.90 x 11.93 inches in dimension; 2) easy
9 assembly; 3) no tools needed; 4) Good-quality material; 5) two removable sliding
10 basket and sturdy rack; and 6) metallic silver finish.
11 24. Below is a comparison of the description of DecoBros Stackable
12 Drawer and the Infringing Products on Amazon.com showing substantially similar
13 characteristics:
14
15
16
17
18
19
20
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22 Plaintiff’s Listing
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COMPLAINT
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5 Defendant’s Listings NEX 1-Tier Basket

6
10
11
12
13

15 25. The simple comparison of the descriptions of each product shows that
16 Defendant only makes slight changes in narrative and wording. But the essence of
17 the concept is the same. In addition, Defendant’s chosen product titles, “NEX
18 Under Sink Cabinet Sliding Basket Organizer Kitchen Storage Drawers Bathroom
19 Holder, Plating” and “NEX 2-Tier Sliding Basket Organizer Drawer Under Sink
20 Cabinet Kitchen Storage Drawers Bathroom Organizer, Plating,” mirrors
21 Plaintiff’s product, entitled, “DecoBros Stackable Under Sink Cabinet Sliding
22 Basket Organizer Drawer” on Amazon.com. Defendant thus has a clear intention
23 to confuse customers by presenting the same title and same description as
24 Plaintiff’s product.
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COMPLAINT
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1 26. A further comparison of the graphics of Plaintiff’s ‘904 Patent and the
2 photograph of the Defendant’s Infringing Products on Amazon.com also indicates
3 approximately same characteristics:
4
10
11
12
13
14 U.S. Patent No. 721,904

15
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21
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23 Defendant’s Listings
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COMPLAINT
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1 27. The simple comparison of the two graphics shows that Defendant
2 does not make any significant changes in the design of the infringing product. Both
3 products feature a metal top with one or two baskets. Each product’s purpose is to
4 act as additional under drawer storage compartments.
5 28. Further, the Defendant’s manual accompanying the NEX 1-Tier
6 Basket exactly replicates Plaintiff’s manual for DecoBros Stackable Drawer
7 (“Manual”). See Exhibit 6. As demonstrated below, the only difference between
8 the two manuals is the company name and information:
9
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20 Plaintiff’s Manual
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COMPLAINT
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10
11 Defendant’s Manual
12 29. Upon information and belief, Plaintiff alleges that Defendant’s
13 product was, and still is, being manufactured, packaged and marketed using the
14 similar description and the same exact design and characteristic in product size and
15 color, as Plaintiff’s DecoBros Stackable Drawer. Defendant’s infringing product is
16 substantially identical to Plaintiff’s DecoBros Stackable Drawer. Additionally, the
17 listing of DecoBros Stackable Drawer and Defendant’s Infringing Products, on
18 Amazon.com are substantially the same:
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20
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22
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COMPLAINT
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1 Plaintiff’s Listing
2

11
12
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14
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18

20 30. Upon information and belief, Defendant is offering for sale, selling,
21 importing into the United States, or otherwise distributing the Infringing Products.
22 A printout of the Infringing Products the Defendant continues to sell on
23 Amazon.com is attached as Exhibit 5.
24 PLAINTIFF’S “DECOBROS METAL MESH ROLLING CART, SILVER”
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COMPLAINT
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1 31. Plaintiff sells its product based on the Asserted Patent as “DecoBros
2 Metal Mesh Rolling Cart, Silver” on Amazon.com, the online shopping platform.
3 32. DecoBros Rolling Cart became an instant success and has more than
4 650 customer reviews and earned a four and a half stars customer rating. A
5 printout showing the sale of DecoBros Rolling Cart is attached to this Complaint as
6 Exhibit 7.
7 33. Plaintiff’s DecoBros Rolling Cart is designed distinctively with the
8 following features: 1) Easy rolling using four sturdy casters; 2) Multiple Purposes
9 as File Cart or Laundry Cart; and 3) dimensions of 26.1 inches high by 9.8 inches
10 wide by 18.5 inches deep.
11 34. The above-described characteristics and design together constitute the
12 Plaintiff’s ‘914 Patent, in which Plaintiff owns protectable rights.
13 35. On or around October of 2017, Plaintiff discovered that Defendant
14 was manufacturing and selling low-quality versions of the DecoBros Rolling Cart
15 branded as “NEX 3 Tier Mesh Utility Cart, Storage Rolling Cart, Kitchen Basket
16 Shelving Trolley” (“NEX Rolling Cart” or “Infringing Products”) on the internet
17 that infringed upon Plaintiff’s ‘914 Patent. The design of the Infringing Products is
18 substantially the same as the design that is the subject matter of the ‘914 Design
19 Patent.
20 36. Defendant ’s Infringing Product, NEX Rolling Cart, contains the
21 following characteristics: 1) 16.53*9.72*25.47 inches in dimension; 2) easy
22 assembly; 3) no tools needed; 4) great for kitchen, laundry room, bathroom,
23 bedroom and pantry; 5) 3 baskets to keep materials orderly; and 6) 4 sturdy casters
24 for easy basket removal.
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COMPLAINT
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1 37. Below is a comparison of the Amazon.com description for DecoBros

2 Rolling Cart and the Infringing Products showing substantially similar
3 characteristics:
4
10
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Plaintiff’s Listing
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13
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15
16
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21 Defendant’s Listing
22 38. The simple comparison of the two descriptions for each product
23 shows that Defendant only makes slight changes in narrative and wording. But the
24 essence of the concept is the same. In addition, Defendant’s chosen product titles,
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COMPLAINT
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1 “NEX 3 Tier Mesh Utility Cart, Storage Rolling Cart, Kitchen Basket Shelving
2 Trolley” mirrors Plaintiff’s product, entitled, “DecoBros Metal Mesh Rolling Cart,
3 Silver” on Amazon.com. Defendant thus has a clear intent to confuse customers
4 by utilizing the same title and description as Plaintiff’s product.
5 39. A further comparison of the graphic of Plaintiff’s ‘914 Patent and the
6 photograph used by Defendant’s Infringing Products on Amazon.com also
7 indicates approximately same characteristics:
8
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U.S. Patent No. 734,914 Defendant’s Listing
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21
40. The simple comparison of the two graphics shows that Defendant
22
does not make any significant changes in the design of the Infringing Products.
23
Both products feature the rolling cart with 3 baskets and 4 sturdy casters.
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COMPLAINT
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1 41. Further, the Defendant’s manual accompanying the Infringing

2 Products is almost identical to Plaintiff’s manual for DecoBros Rolling Cart
3 (“Manual”). See Exhibit 9. As demonstrated below, the only difference between
4 the two manuals is the company information:
5
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Plaintiff’s Manual
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Defendant’s Manual
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42. Upon information and belief, Plaintiff alleges that Defendant’s
22
product was, and still is, being manufactured, packaged and marketed using similar
23
descriptions and the same exact design and characteristic in size and color as
24
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COMPLAINT
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1 Plaintiff’s DecoBros Rolling Cart. Defendant’s Infringing Products are

2 substantially identical to Plaintiff’s DecoBros Rolling Cart. Additionally, the
3 listing of DecoBros Rolling Cart and Defendant’s Infringing Products, on
4 Amazon.com are substantially the same:
5
10
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Plaintiff’s Listing
12
13
14
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19 Defendant’s Listing
20 43. Upon information and belief, Defendant is offering for sale, selling,
21 importing into the United States, or otherwise distributing the Infringing Products.
22 A printout of the Infringing Products that Defendant continues to sell on
23 Amazon.com is attached as Exhibit 8.
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COMPLAINT
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1 44. Plaintiff is informed and believes, and thereon alleges that as a result
2 of Defendant’s sale and distribution of the aforementioned Infringing Products,
3 customers are confused as to the source of the aforementioned Asserted Patent.
4 45. Defendant’s use of the Asserted Patent and the sale of the Infringing
5 Products have and continues to dilute Plaintiff’s goodwill in its products and
6 business that it has invested significant time and resources.
7 46. Plaintiff is informed and believes that Defendant continues to sell the
8 Infringing Products with the similar name and identical manual on Amazon.com
9 and as a result, Plaintiff has lost substantial amount of orders.
10 47. Plaintiff is informed and believes that Defendant was aware of
11 Plaintiff’s rights before it began its infringing activity, and that Defendant’s use
12 and infringement is therefore willful.
13 48. Plaintiff is informed and believes that Defendant intends to continue
14 their unlawful infringing activities, and Plaintiff continues to and will continue to
15 suffer irreparable harm; for which there is no adequate remedy at law-unless
16 Defendant is enjoined by this Court.
17 49. As a result of Defendant’s infringement of Plaintiff’s DecoBros
18 Stackable Drawer, Plaintiff has suffered damages in the amount of lost profits,
19 injury to its goodwill and business reputation, and expenses incurred in trying to
20 prevent customer confusion.
21 FIRST COUNT
22 Design Patent Infringement
23 (Pursuant to 35 U.S.C. §§ 271, 281, 283, 284, and 285)
24
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COMPLAINT
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1 50. Plaintiff re-alleges and incorporates by reference each and every

2 allegation set forth in paragraphs 1-49 above.
3 51. The conduct of Defendant as set forth hereinabove gives rise to a
4 cause of action for infringement of the Asserted Patent, pursuant to at least 35
5 U.S.C. §§ 271 and 281.
6 52. Defendant has directly infringed, and continues to directly infringe,
7 the Asserted Patent under 35 U.S.C. § 271(a) by making, using, selling, offering
8 for sale, and importing within the United States the Infringing Products.
9 53. Defendant has manufactured, used, sold, imported, and offered for
10 sale Infringing Products despite an objectively high likelihood that its actions
11 constitute infringement of the Asserted Patent.
12 54. Defendant has had, and continues to have, the specific intent to
13 induce its customers or users of its products to infringe the Asserted Patent.
14 55. Defendant has indirectly infringed and continues to indirectly infringe
15 the Asserted Patent under 35 U.S.C. §§ 271 (b) and (c) by actively inducing
16 infringement of, or contributorily infringing the Asserted Patent.
17 56. Upon information and belief, Defendant’s infringement has taken
18 place with full knowledge of the Asserted Patent and has been intentional,
19 deliberate, and willful.
20 57. By reason of the foregoing, Plaintiff is entitled to monetary relief
21 against Defendant, pursuant to 35 U.S.C. §§ 283-85, as more fully set forth herein
22 below.
23 58. As a direct and proximate result of Defendant’s infringement of the
24 Asserted Patent, Plaintiff has been and continues to be damaged in an amount yet
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COMPLAINT
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1 to be determined. Plaintiff seeks damages adequate to compensate for this

2 infringement in an amount no less than Defendant’s total profit, from sales of the
3 Infringing Product, together with interest and costs affixed by the Court.
4 59. By reason of the above acts, Defendant has caused, is causing, and
5 unless enjoined and restrained by this court, will continue to cause Plaintiff great
6 and irreparable injury to, among other things, the good will and business reputation
7 of Plaintiff, all of which cannot be adequately compensated or measured in money.
8 Plaintiff has no adequate remedy at law. Plaintiff is entitled to injunctive relief,
9 enjoining and restraining Defendant and its respective officers, agents, servants,
10 and employees, and all persons acting in concert with it, from further infringement
11 of the Asserted Patent.
12 SECOND COUNT
13 False Advertising
14 (Pursuant to Cal. Bus. & Prof. Code § 17500, et seq.)
17 61. The conduct of Defendant is unfair and unlawful and violate
18 California statutory law, including, without limitation, California Business and
19 Professions Code §§ 17500, et seq.
20 62. As a result of Defendant’s false and misleading advertising, potential
21 and actual consumers have been, and will continue to be, misled about the source
22 and legitimacy of the Infringing Products, which is being wrongfully marketed,
23 advertised, and sold in association with Plaintiff’s Asserted Patent. Defendant
24 knew or should have known that the advertising was untrue and/or misleading.
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COMPLAINT
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1 63. As a result of the above conduct, Defendant has been, and will
2 continue to be, unjustly enriched in profits, income, and ill-gotten gains at the
3 expense of Plaintiff and consumers.
4 64. As a further result of the above conduct, Plaintiff has been, and will
5 continue to be, unjustly deprived of the full value of the goodwill and public image
6 associated with its Asserted Patent.
7 65. The wrongful conduct of Defendant, unless restrained and enjoined by
8 order of this Court, will cause great and irreparable injury to the general public and
9 to Plaintiff, its business, reputation, and goodwill. Plaintiff has no adequate
10 remedy at law for the injuries that have been or will continue to be sustained in this
11 action.
12 THIRD COUNT
13 California Common Law Unfair Competition
16 67. The Court has jurisdiction over this claim pursuant to 28 U.S.C.
17 § 1367.
18 68. By Defendant’s acts alleged herein, the Defendant has engaged in
19 unfair competition under the common law of the State of California.
20 69. Defendant has manufactured and sold Infringing Products in
21 California, thereby creating a false designation of origin of Plaintiff’s brand of
22 goods and unfairly competing with Plaintiff’s business.
23 70. Upon information and belief, Defendant has knowingly and willfully
24 misappropriated Plaintiff’s Asserted Patent in an effort to create the impression
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COMPLAINT
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1 that the Defendant’s Infringing Products is sanctioned by the Plaintiff and to

2 misappropriate the goodwill associated with Plaintiff, entitling Plaintiff to an
3 award of exemplary damages and attorneys’ fees.
4 71. The aforesaid acts of the Defendant have caused damage to Plaintiff,
5 in an amount to be determined.
6 72. By reason of the acts of the Defendant alleged herein, Plaintiff has
7 suffered, is suffering and will continue to suffer irreparable damage, which damage
8 will continue unless enjoined by Order of this Court.
9 FOURTH COUNT
10 Unfair Competition
11 (Pursuant to Cal. Bus. & Prof. Code § 17200, et seq.)
14 74. The Court has jurisdiction over this Cause pursuant to 28 U.S.C.
15 § 1367.
16 75. As alleged above, Plaintiff’s DecoBros Stackable Drawer has
17 acquired secondary meaning indicative of origin, relationship, sponsorship and/or
18 association with Plaintiff. The ordinary purchaser is likely to attribute to Plaintiff
19 the misuse by Defendant of the Asserted Patent and thereby purchase Defendant’s
20 Infringing Products based upon that erroneous belief.
21 76. Plaintiff is informed and believes, and upon that basis alleges, that
22 Defendant copied Plaintiff’s DecoBros Stackable Drawer and reproduced it with
23 the intent of causing confusion, mistake and deception as to the source of the
24 Defendant’s Infringing Products and with the intent to palm off such goods as
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COMPLAINT
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1 those of Plaintiff. As such, Defendant has committed design patent infringement,

2 misleading advertising, and unfair competition, all in violation of the California
3 Unfair Business Practices Act, Cal. Bus. & Prof. Code § 17200 et seq.
4 77. Upon information and belief, Plaintiff alleges that unless enjoined by
5 the Court, the confusion and deception alleged herein and the likelihood thereof
6 will continue with irreparable harm and damage to Plaintiff.
7 78. Plaintiff has been proximately damaged by Defendant’s infringement
8 and is thus entitled to a permanent injunction to prevent further such conduct, and
9 monetary damages including, but not limited to, all of Defendant’s profits on the
10 products sold under or in connection with its infringing use of Plaintiff’s Asserted
11 Patent, Plaintiff’s lost profits, compensation for the injury to Plaintiff’s goodwill
12 and business reputation, expenses incurred in trying to prevent customer confusion,
13 plus Plaintiff’s attorney fees and costs.
14 FIFTH COUNT
15 Intentional Interference with Prospective Economic Relations
18 80. The Court has jurisdiction over this Cause pursuant to 28 U.S.C.
19 § 1367.
20 81. Plaintiff alleges that Plaintiff and consumers of its DecoBros
21 Stackable Drawer were in an economic relationship that probably would have
22 resulted in an economic benefit for Plaintiff in the form of continued DecoBros
23 Stackable Drawer purchases from the abovementioned consumers.
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COMPLAINT
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1 82. Plaintiff is informed and believes and therefore alleges that Defendant
2 was aware of the relationship between Plaintiff and the current and potential
3 consumers of Plaintiff’s DecoBros Stackable Drawer.
4 83. Plaintiff alleges that Defendant engaged in the wrongful conduct of
5 infringing Plaintiff’s Asserted Patent and in doing so, intended or at least knew that
6 Plaintiff’s relationship with its DecoBros Stackable Drawer consumers was certain
7 to be disrupted due to confusion as to which company’s products consumers were
8 purchasing.
9 84. Plaintiff alleges, upon information and belief, that its relationship with
10 its consumers has in fact been disrupted where consumers mistakenly purchased
11 Defendant’s Infringing Product over Plaintiff’s DecoBros Stackable Drawer, and
12 consumers have stopped placing orders with Plaintiff.
13 85. Upon information and belief, Plaintiff alleges that unless enjoined by
14 the Court, the confusion and deception alleged herein and the likelihood thereof
15 will continue with irreparable harm and damage to Plaintiff.
16 86. Plaintiff has been proximately damaged by Defendant’s infringement
17 and is thus entitled to a permanent injunction to prevent further such conduct, and
18 monetary damages including, but not limited to, all of Defendant’s profits on the
19 products sold under or in connection with its infringing use of Plaintiff’s Asserted
20 Patent, Plaintiff’s lost profits, compensation for the injury to Plaintiff’s goodwill
21 and business reputation, expenses incurred in trying to prevent customer confusion,
22 plus Plaintiff’s attorney fees and costs.
23 SIXTH COUNT
24 Unjust Enrichment
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COMPLAINT
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3 88. As a result of its conduct in selling the Infringing Products, Defendant
4 has been unjustly enriched and, at the same time, is causing a loss of revenue to
5 Plaintiff to its detriment.
6 89. Plaintiff is entitled to recover from the Defendant their unjust
7 enrichment including gains, profits, and advantages they have obtained as a result
8 of their wrongful conduct. Plaintiff is, at present, unable to ascertain the full extent
9 of the gains, profits, and advantages Defendant has obtained by reason of their
10 wrongful conduct.
11 SEVENTH COUNT
12 Demand For Accounting
15 91. Plaintiff has an interest in all monies generated from the exploitation
16 of its exclusive rights to its design patent in DecoBros Stackable Drawer.
17 92. Plaintiff is informed and believes that Defendant has generated an
18 undetermined, yet substantial amount of money, due to their unlawful commercial
19 exploitation of Asserted Patent.
20 93. The amount of money due from the Defendant is unknown to Plaintiff
21 and cannot be ascertained without an accounting of all of the Defendant’s financial
22 records related to the sales generated through their infringing and unlawful
23 activities.
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COMPLAINT
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1 94. As a result of Defendant’s actions, Plaintiff has been damaged in an

2 amount to be proven after an accounting has been conducted. Accordingly,
3 Plaintiff hereby requests that the Court order an accounting of all of Defendant’s
4 financial records related to the infringing activities in order to determine the sums
5 rightfully due to Plaintiff.
6 95. Furthermore, Plaintiff demands that those sums be paid to them
7 accordingly.
8 PRAYER FOR RELIEF
9 WHEREFORE, Plaintiff demands entry of a judgment against the Defendant
10 as follows:
11 1. For a judgment declaring that Defendant has infringed on Plaintiff’s
12 Asserted Patent;
13 2. For a judgment awarding Plaintiff compensatory damages as a result
14 of Defendant’s infringement of Plaintiffs Design Patent, together with interest and
15 costs, and in no event less than a reasonable royalty;
16 3. For a judgment declaring that Defendant’s infringement of Plaintiff’s
17 Asserted Patent was willful and deliberate;
18 4. The Defendant, its officers, agents, servants, employees, attorneys,
19 and all those in active concert or participation with them be enjoined and restrained:
20 a. From further using Plaintiff’s Asserted Patent or any other
21 confusingly similar design, in connection with the manufacture, sale,
22 advertisement or promotion of any product or any other similar infringement
23 of Plaintiff’s Asserted Patent, for products not originating from Plaintiff or
24 authorized by Plaintiff;
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COMPLAINT
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1 b. From diluting any of Plaintiff’s Asserted Patent, with any other

2 confusingly similar design patent; and
3 c. From engaging in unfair competition by making and selling its
4 products or otherwise using confusingly similar designs, in such a way as to
5 misrepresent the origin of any of the Defendant’s products.
6 5. For an order requiring Defendant to deliver and be impounded during
7 the pendency of this action all material in Defendant’s possession, custody or
8 control that include or incorporate products that infringe Plaintiff’s Asserted Patent
9 rights, including but not limited to, any products, containers, packages, labels and
10 advertisements in their possession or under their control bearing any of Plaintiff’s
11 Trademark or utilizing Plaintiff’s design patents, or any simulation, reproduction,
12 counterfeit, copy, or colorable imitation thereof;
13 6. Directing that the Defendant report to this Court within thirty (30)
14 days after a Permanent Injunction is entered to show its compliance with
15 paragraphs 4 and 5 above;
16 7. For compensatory damages in an amount to be proven at trial;
17 8. For all gains, profits and advantages derived by Defendant by its
18 infringement of Plaintiff’s Asserted Patent;
19 9. For punitive damages in an amount sufficient to punish Defendant for
20 its wrongful conduct and to deter others from engaging in similar conduct in the
21 future;
22 10. For statutory damages as provided by law;
23
24
25
COMPLAINT
26 26
27
28
1 11. For preliminary and permanent injunction against Defendant,

2 preventing Defendant from any future usage of any identical or similarly confusing
3 design related to Plaintiff’s Asserted Patent;
4 12. Directing such other relief as the Court may deem appropriate to
5 prevent the trade and public, or individual members thereof, from gaining the
6 erroneous impression that the Plaintiff authorized or approved any products
7 manufactured, sold, or otherwise circulated or promoted by the Defendant or that
8 such products are in any way related to the Plaintiff;
9 13. Awarding the Plaintiff damages by reason of the infringement by
10 Defendant as set forth in this Complaint, pursuant to 35 U.S.C. §§ 284 and 289,
11 and common law;
12 14. Ordering an independent accountant to conduct an accounting of all of
13 Defendant’s financial records relating to the infringing activities in order to
14 determine the sums of money owed to Plaintiff. Upon a determination of sums due
15 to Plaintiff, demand is made that those sums be paid to Plaintiff.
16 15. Awarding to the Plaintiff its reasonable attorneys’ fees and
17 investigative fees pursuant to 35 U.S.C. § 285;
18 16. Awarding to the Plaintiff its costs in bringing this action; and
19 17. Awarding other such relief to the Plaintiff as this Court deems just.
20 June 12, 2018 Respectfully submitted,
21
22
23
24 Attorney for Pretty Star Store, LLC

25
COMPLAINT
26 27
27
28
1 DEMAND FOR JURY TRIAL

2 Pretty Star Stores, LLC hereby demands a jury trial on all issues that can be
3 heard by a jury.
4
5
June 12, 2018 Respectfully submitted,
6
9
Attorney for Pretty Star Store, LLC
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
COMPLAINT
26 28
27
28
Case 2:18-cv-05187 Document 1-1 Filed 06/12/18 Page 1 of 36 Page ID #:29
Exhibit 1
Exhibit 2
Assignment abstract of title for Application 29497385
Invention title/Inventor Patent Publication Application PCT International registration

Stackable Cabinet Basket Drawer D721904 29497385
Tsung-Yu Tsai Feb 03, 2015 Jul 23, 2014
Assignments (1 of 1 total)
Assignment 1
Reel/frame Execution date Date recorded Properties Pages
034780/0586 Oct 07, 2014 Jan 22, 2015 1 2
Conveyance
ASSIGNMENT OF ASSIGNORS INTEREST (SEE DOCUMENT FOR DETAILS).
Assignors Correspondent
TSAI, TSUNG-YU KEVIN PRINCE
2580 ANTHEM VILLAGE DRIVE
HENDERSON, NV 89052
Assignee
PRETTY STAR STORE LLC
19745 COLIMA ROAD #1-152
ROWLAND HEIGHTS, CALIFORNIA 91748
Exhibit 3
U.S. Patent Jul. 21 , 2015 Sheet 4 of 6 US D734,914 S
FIG. 4
U.S. Patent Jul. 21, 2015 Sheet 5 of 6 US D734,914 S
FIG. 5
Exhibit 4
Home & Kitchen
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DecoBros Stackable Under Sink
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Cabinet Sliding Basket Organizer
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Color: Chrome
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Buy used: $22.16
USPTO Patent USD721904

Stackable Sliding Basket provides an easy way to access
Fit well into cabinet to increase the organize capabilities Add to List
Elegant Chrome Finish
Dimension: 16.7'' L x 10.8'' W x 10.2'' H
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Used & new (20) from $22.16 & FREE shipping on orders
over $25.00. Details $24.00 Add to Cart
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THERMOS Details
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Thermos Sipp 16 Ounce
Stainless Stee
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Your Sink
Total price: $63.71 As Well
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SinkShroom The Revolutionary Sink
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Drain Protector Hair Catcher/Strainer/...
972
$10.95
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This item: DecoBros Stackable Under Sink Cabinet Sliding Basket Organizer Drawer,Chrome $24.87
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SimpleHouseware Over the Cabinet Door Organizer Holder, Silver $13.97
Exhibit 5
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Home & Kitchen › Kitchen & Dining › Storage & Organization › Cabinet & Drawer Organization › Pull-Out Organizers
NEX Share
NEX Under Sink Cabinet Sliding
Qty: 1
Basket Organizer Kitchen Storage
Drawers Bathroom Holder, Plating
6 customer reviews
#1 New Release in Pull-Out Home Organizers
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Price: $27.99
Sale: $23.99
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choose One-Day Shipping at checkout. Details
Roll over image to zoom in Sold by Better-New Life and Fulfilled by Amazon. Gift-wrap
available. Add to Wedding Registry
Dimension--16.77*10.90*10.23 inches, easy assembly; no

tools needed.
Other Sellers on Amazon
Good-quality material--The whole set is finished with
fashionable silber-grey powder coating, so beautiful and
$22.99 Add to Cart
attractive.
& FREE Shipping on eligible orders.
Removable basket & sturdy rack--The basket is so large
Details
in size that it can store lots of things, and can be slided
Sold by: e-topus
along the rack for easy moving.
Great for anywhere--Deal for anywhere in the house. It New (3) from $22.99 & FREE shipping
can hold fruit and vegetable, bread and snack, on orders over $25.00. Details
condiment and caddy in the kitchen, store cosmetic and
toilettries in the bathroom, it can also hold books,
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stationery, tool, and receipt in the officer or studio.
Guarantee--We offer a no-hassle 30-day money back
guarantee to insure you have the best shopping
experience.
New (3) from $22.99 & FREE shipping on orders over

$25.00. Details
Keep your
drinks hot or
SIMPLEHOUSEWARE cold on the go
Reusable meal prep food Thermos Sipp 16 Ounce Stainless Steel
storage container Insulated Drink Bottle, Rose Gold
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10 PK 3 compartment food $29.99
grade meal pr Ad feedback
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Tools & Home Improvement › Storage & Home Organization › Garage Storage › Storage Racks
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NEX 2-Tier Sliding Basket Organizer
Qty: 1
Drawer Under Sink Cabinet Kitchen
Storage Drawers Bathroom
$27.99 + Free Shipping
Organizer, Plating In Stock. Sold by e-topus
9 customer reviews
Add to Cart
Price: $36.99
Sale: $27.99 & FREE Shipping
You Save: $9.00 (24%) Turn on 1-Click ordering for this browser
In Stock.
Get it as soon as Oct. 11 - 16 when you choose Expedited Ship to:
Shipping at checkout. Select a shipping address:
Ships from and sold by e-topus.
Add to List
Dimension--16.81*10.90*11.93 inches, Easy assembly; no
Roll over image to zoom in tools needed
Good-quality material--The whole set is finished with Add to Wedding Registry
fashionable silber-grey powder coating, beautiful and
attractive
Removable basket & sturdy rack--The two baskets are Have one to sell? Sell on Amazon
large in size that it can store lots of things, and can be
slided along the rack for easy moving
Great for anywhere--Deal for anywhere in the house. It
can hold fruit and vegetable, bread and snack,
condiment and caddy in the kitchen, store cosmetic and
toilettries in the bathroom, it can also hold books,
stationery, tool, and receipt in the officer or studio No unraveling
Guarantee--We offer a no-hassle 30-day money back patented
guarantee to insure you have the best shopping technology
experience Kamenstein Perfect Tear Wall Mount
Paper Towel Holder, Stainless Steel
New (1) from $27.99 & FREE shipping. 2,812

$14.99
SPOGA
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High Quality Organization
by Spoga
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Spoga Mop, Broom
Equipment Wall Mount
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+ Add both to List
One of these items ships sooner than the other. Show details
Exhibit 6
Exhibit 7
2017/10/12 Amazon.com
Case 2:18-cv-05187 : DecoBros
Document Metal Mesh
1-1 FiledRolling Cart, Silver :Page
06/12/18 Utility Carts
28: of
Office
36Products
Page ID #:56
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DecoBros Metal Mesh Rolling Cart, Silver

650 customer reviews | 43 answered questions Buy new: $26.77
Price: $26.77 & FREE Shipping. Details Qty: 1
In Stock.
Want it tomorrow, Oct. 13? Order within 1 hr 31 mins and choose
One-Day Shipping at checkout. Details
Sold by DecoBros Direct and Fulfilled by Amazon. Gift-wrap Add to Cart
available.
Dimension: 26.1"H x 9.8"W x 18.5"D

Turn on 1-Click ordering for this
Easily rolling around by four sturdy casters
browser
Multiple Use Purpose: File Cart, Laundry Cart
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Used & new (3) from $24.09 & FREE shipping on orders over lapuente, 91744
$25.00. Details
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Heavy-Duty 12-Drawer Add to List

Rolling Cart
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HoneyCanDo CRT01683 Other Sellers on Amazon
12 Drawer C...
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Total price: $35.64
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This item: DecoBros Metal Mesh Rolling Cart, Silver $26.77 For legs that
24 Pockets - SimpleHouseware Crystal Clear Over the Door Hanging Shoe Organizer, Gray (64'' x 19'') $8.87 look, and feel,
like pure silk
Pure Silk® Disposable Three Razor, 4
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38
$5.60
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3 Tier Utility Cart, Lifewit Mesh Rolling HollyHOME Premium Shelving Solutions
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Rolling Wheel, Metal Multifunction Utility Cart Cart with 4 Baskets and 5 Wire Mesh Storage Cart,
Mesh Wire Basket… with 4 Baskets and… Hooks, Kitchen and… 4 Tier
$28.87 43 11
$39.68 $34.99 $19.99
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2017/10/12 Amazon.com
Case 2:18-cv-05187 : DecoBros
Document Metal Mesh
1-1 FiledRolling Cart, Silver :Page
06/12/18 Utility Carts
29: of
Office
36Products
Page ID #:57
Customers who bought this item also bought Page 1 of 4
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Product description
DecoBros mesh rolling cart provides a better way to store almost everything for your kitchen, bathroom, bedroom or living room. The sturdy wheels also provides easy way
to move around. USPTO Patent USD734914 914
Product information
Technical Details Additional Information
Brand Name Deco Brothers ASIN B008AFVL0K
Item Weight 5.5 pounds Customer Reviews 650 customer

reviews
Product Dimensions 16.5 x 10.5 x 24.5 inches 4.5 out of 5 stars
Item model number CT0011 Best Sellers Rank #3,041 in Office Products (See top

100)
Color Silver #10 in Office Products > Office
Furniture & Accessories > Carts &
Material Type Steel
Stands > Utility Carts
Manufacturer Part Number KTCT001
Shipping Weight 5.5 pounds (View shipping rates and
policies)
Domestic Shipping Currently, item can be shipped only

within the U.S. and to APO/FPO
addresses. For APO/FPO shipments,
please check with the manufacturer
regarding warranty and support
issues.
International Shipping This item can be shipped to select

countries outside of the U.S. Learn
More
Date First Available June 11, 2012
Warranty & Support
Product Warranty: For warranty information about this product, please click here
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Exhibit 8
2017/10/11 Amazon.com : NEXDocument
Case 2:18-cv-05187 3 Tier Mesh Utility
1-1Cart, Storage
FiledRolling Cart, Kitchen
06/12/18 Basket31
Page Shelving
of 36TrolleyPage
: Office ID
Products
#:59
Office Products
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Rolling Cart, Kitchen Basket Shelving
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available. lapuente, 91744
Easy assembly; no tools needed
Dimension--16.53*9.72*25.47 inches Add to List
Great for kitchen, laundry room, bathroom, bedroom and pantry
The rolling cart with 3 baskets to keep your stuff orderly and 4
Roll over image to zoom in
sturdy casters is easily removing Other Sellers on Amazon
We offer a no-hassle 30-day money back guarantee that insure
you have the best shopping experience $30.99 Add to Cart
& FREE Shipping on eligible orders.
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Details
SCOUT CART
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season
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Scout Cart Your Personal
Shopping...
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Total price: $53.21 any easier
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1,011
$36.68
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Exhibit 9

Pretty Star Store v. Chen - Complaint

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Case 2:18-cv-05187 Document 1 Filed 06/12/18 Page 1 of 28 Page ID #:1

Tommy SF Wang (SBN: 272409)

23 JURY TRIAL DEMANDED

1 PLAINTIFF PRETTY STAR STORE, LLC d.b.a DecoBros (hereinafter

1 4. Supplemental jurisdiction exists over Defendant because on

1 PLAINTIFF’S “DECOBROS STACKABLE UNDER SINK CABINET

5 Defendant’s Listings NEX 1-Tier Basket

14 Defendant’s Listings NEX 2-Tier Basket

14 U.S. Patent No. 721,904

10 Defendant’s Listings NEX 1-Tier Basket

19 Defendant’s Listings NEX 1-Tier Basket

1 37. Below is a comparison of the Amazon.com description for DecoBros

1 41. Further, the Defendant’s manual accompanying the Infringing

1 Plaintiff’s DecoBros Rolling Cart. Defendant’s Infringing Products are

1 50. Plaintiff re-alleges and incorporates by reference each and every

1 to be determined. Plaintiff seeks damages adequate to compensate for this

1 that the Defendant’s Infringing Products is sanctioned by the Plaintiff and to

1 those of Plaintiff. As such, Defendant has committed design patent infringement,

1 87. Plaintiff re-alleges and incorporates by reference each and every

1 94. As a result of Defendant’s actions, Plaintiff has been damaged in an

1 b. From diluting any of Plaintiff’s Asserted Patent, with any other

1 11. For preliminary and permanent injunction against Defendant,

24 Attorney for Pretty Star Store, LLC

1 DEMAND FOR JURY TRIAL

Assignment abstract of title for Application 29497385

Invention title/Inventor Patent Publication Application PCT International registration

U.S. Patent Jul. 21 , 2015 Sheet 4 of 6 US D734,914 S

U.S. Patent Jul. 21, 2015 Sheet 5 of 6 US D734,914 S

‹ Back to Deco Brothers store

Deco Brothers Share 860+ Shares

In Stock. Turn on 1-Click ordering for this browser

Roll over image to zoom in $24.87 $24.87

USPTO Patent USD721904

Used & new (20) from $22.16 & FREE

Dimension--16.77*10.90*10.23 inches, easy assembly; no

New (3) from $22.99 & FREE shipping on orders over

Total price: $50.98

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Total price: $50.98

+ Add both to List

‹ Back to search results for "decobros Storage Rolling Cart, "

Deco Brothers Share 210+ Shares

DecoBros Metal Mesh Rolling Cart, Silver

Price: $26.77 & FREE Shipping. Details Qty: 1

Dimension: 26.1"H x 9.8"W x 18.5"D

Compare with similar items Ship to:

Heavy-Duty 12-Drawer Add to List

Have one to sell? Sell on Amazon

Add both to Cart

+ Add both to List

Technical Details Additional Information

Brand Name Deco Brothers ASIN B008AFVL0K

Item Weight 5.5 pounds Customer Reviews 650 customer

Item model number CT­001­1 Best Sellers Rank #3,041 in Office Products (See top

Domestic Shipping Currently, item can be shipped only

International Shipping This item can be shipped to select

Date First Available June 11, 2012

Warranty & Support

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Office Products Office Deals School Supplies Office Electronics Printers Ink & Toner Projectors Pens & Writing Calendars & Planners

Fall is Scout Cart Have one to sell? Sell on Amazon

+ Add both to List

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Dimension--16.7710.9010.23 inches, easy assembly; no

Item model number CT0011 Best Sellers Rank #3,041 in Office Products (See top