Samsonite IP Holdings v. Shenzhen Liangyiyou E-Commerce - Complaint

Case 1:19-cv-02564 Document 1 Filed 03/21/19 Page 1 of 23
MCCARTER & ENGLISH, LLP

Margarita Wallach
Irene M. Hurtado
Worldwide Plaza
825 Eighth Avenue, 31st Floor
New York, New York 10019
(212) 609-6800
mwallach@mccarter.com
ihurtado@mccarter.com
Attorneys For Plaintiffs
UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK
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SAMSONITE IP HOLDINGS S.àr.l. and :
SPECULATIVE PRODUCT DESIGN, LLC, :
: Civil Action No. 19-cv-2564
Plaintiffs, :
:
- against - : COMPLAINT
:
SHENZHEN LIANGYIYOU E-COMMERCE :
CO., LTD. a/k/a SHENZHEN LIANGYIYOU :
ELECTRONIC COMMERCE CO., LTD. a/k/a :
SHENZHEN CITY LIANGYIYOU E- :
COMMERCE LIMITED COMPANY a/k/a :
SHENZHEN CITY LIANGYIYOU :
ELECTRONIC COMMERCE LIMITED :
COMPANY d/b/a LIOEO, d/b/a LIOEO US, d/b/a :
:
LIO US, and JOHN AND JANE DOES A-Z
:
(UNIDENTIFIED); and XYZ COMPANIES 1-10 :
(UNIDENTIFIED), :
:
Defendants. :
:
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Plaintiffs Samsonite IP Holdings S.àr.l. (“Samsonite”) and Speculative Product Design,
LLC (“Speck”) (collectively, “Plaintiffs”), by and through their undersigned counsel, as and for
their complaint against Defendant Shenzhen Liangyiyou E-commerce Co., Ltd. a/k/a Shenzhen
Liangyiyou Electronic Commerce Co., Ltd. a/k/a Shenzhen City Liangyiyou E-Commerce
Limited Company a/k/a Shenzhen City Liangyiyou Electronic Commerce Limited Company
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d/b/a Lioeo, d/b/a Lioeo US, d/b/a LIO US (“SLEC”), John and Jane Does A-Z (unidentified),
and XYZ Companies 1-10 (unidentified) (collectively, “Defendants”), allege as follows:
NATURE OF THE ACTION
1. Plaintiffs bring this action to put an end to Defendants’ unlawful manufacture,
sale and distribution of infringing copies of Plaintiffs’ successful iGuy® brand protective
carrying cases for portable computers, portable media players, and tablet computers, depicted
below:
(the “iGuy® Case”).
2. Plaintiffs seek injunctive and monetary relief for acts of federal copyright
infringement under the United States Copyright Act, 17 U.S.C. § 101, et seq., including damages
pursuant to the Digital Millennium Copyright Act (the “DMCA”), 17 U.S.C. § 512(f), trademark
infringement, unfair competition, and deceptive trade practices under the Lanham Act, Title 15,
United States Code § 1051, et seq., and the statutes and common laws of the State of New York.
JURISDICTION AND VENUE
3. This is a civil action arising under the U.S. Copyright Act, 17 U.S.C. §101, et.
seq., and the Lanham Act of the United States, 15 U.S.C. §1051, et seq., and subject matter
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jurisdiction is conferred on this Court under 15 U.S.C. §1121, 28 U.S.C. §1332, 28 U.S.C.
§§1338 (a) and (b), and 28 U.S.C. § 1367.
4. This Court has personal jurisdiction over SLEC because SLEC transacts business
within the Southern District of New York and has sufficient minimum contacts with the State of
New York. In addition to transacting business within the District, SLEC submitted various
counter-notifications pursuant to the DMCA, as discussed below, to Amazon.com and, in doing
so, SLEC agreed, as required by the DMCA, to submit to the jurisdiction of the federal district
court in any judicial district in which Amazon.com can be found. On its website, Amazon.com
states that it has offices in New York, New York.
5. Venue is proper in this District pursuant to 28 U.S.C. §§1391(b) and (c).
Defendants market and offer their products for sale via Amazon.com and import and distribute
those products in interstate commerce and within the Southern District of New York, and based
upon the submission to jurisdiction included in each of the counter-notifications submitted by
SLEC to Amazon.com.
THE PARTIES
6. Plaintiff Samsonite is a société à responsabilité limitée (private limited liability
company) governed by the laws of the Grand-Duchy of Luxembourg, having its registered office
at 13-15 Avenue de la Liberté, L-1931 Luxembourg, registered with the Luxembourg Register of
Commerce and Companies (Registre de Commerce et des Sociétés, Luxembourg) under number
B 147.735.
7. Plaintiff Speck is a limited liability company organized and existing under the
laws of the State of California, having its principal place of business at 177 Bovet Road, Suite
200, San Mateo, California 94402.
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8. Upon information and belief, SLEC is a corporation duly organized and existing
under the laws of the People’s Republic of China, with an address of 18C Building/Block B,
No.1 Haishan Road, Haishan Street, Yantian District. Shenzhen City, Guangdong China 51808.
Upon further information and belief, SLEC also has an address of 1 Broadway Rd., Ste. 1. #
LIOE Ste. 1. #1211, Cranbury, New Jersey 08512.
9. Upon information and belief, Defendants identified as various JOHN DOES and
JANE DOES are various individuals and entities conducting business at various locations in the
State of New York and elsewhere who are acting in concert with SLEC and engaging in
infringing conduct, including but not limited to manufacturing, importing, distributing,
warehousing, or selling SLEC’s infringing tablet cases in this District and throughout the United
States, and are present in and/or doing business in the State of New York and subject to the
jurisdiction of this Court. The identities of the various JOHN DOES and JANE DOES
defendants are not presently known and the Complaint herein will be amended to include the
name or names of these individuals when such information becomes available (each a “Doe” and
collectively “Does”).
10. Upon information and belief, Defendants, the XYZ COMPANIES, through their
agents, servants, and employees, are conducting business at various locations in the State of New
York and elsewhere and are acting in concert with SLEC and engaging in infringing conduct,
including but not limited to manufacturing, importing, distributing, warehousing, or selling
SLEC’s infringing tablet cases in this District and throughout the United States, and are present
in and/or doing business in the State of New York and subject to the jurisdiction of this Court
(each a “Defendant Company” and collectively, “Defendant Companies”).
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PLAINTIFFS’ BUSINESS
11. Speck is one of the leading designers of protective cases for portable electronic
devices including smartphones, laptops and tablets, including the iGuy® Case.
12. Samsonite is the owner of, and Speck is the worldwide licensee of certain rights
of copyright and trade dress in and to the packaging and design of Plaintiffs’ iGuy® Cases.
13. Among Samsonite’s most important assets are the intellectual property rights it
owns, specifically its rights in and to the unique and inherently distinctive designs used on and in
connection with the iGuy® Cases and the packaging therefor. Such designs, which are subject to
copyright and/or trade dress protection, include the original and inherently distinctive design,
shape and overall appearance of the iGuy® Cases and the package insert for the iGuy® Cases.
THE COPYRIGHTED DESIGNS
14. Samsonite owns U.S. copyright registrations covering the unique and innovative
designs that it uses on and in connection with its iGuy® brand products.
15. Among the U.S. copyright registrations owned by Samsonite covering the original
and distinctive design of the iGuy® brand tablet case and the packaging therefor are the
following:
(a) U.S. Copyright Registration No. VA2-036-476, registered on June 15, 2016
for the design of the iGuy® Cases (the “iGuy® Design”). A copy of the
registration certificate for the design of the iGuy® Cases, along with
photographs of that design, is attached hereto as Exhibit A.
(b) U.S. Copyright Registration No. VA 2-036-473, registered on June 16, 2016,
for the packaging insert for iGuy® brand tablet case (the “iGuy® Insert”). A
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copy of the registration certificate for the iGuy® Insert, along with a
photograph of that design, is attached hereto as Exhibit B.
16. The foregoing copyrighted works shall hereinafter be referred to collectively as
the “Samsonite Copyrights.”
17. Samsonite owns all right, title and interest in and to the Samsonite Copyrights,
which constitute original and copyrightable subject matter under the U.S. Copyright Act.
18. Samsonite has duly complied with all relevant requirements of the U.S. Copyright
Act with respect to the Samsonite Copyrights.
THE iGUY® TRADE DRESS
19. Samsonite also own trade dress rights in and to the unique and inherently
distinctive configuration and design of the iGuy® Case (the “iGuy® Case Trade Dress”). The
iGuy® Case Trade Dress consists of the following combination of design elements: a
rectangular shaped cover, resembling a human, with a rectangular orifice for insertion of a tablet,
with two oblong protrusions at the base of the rectangular body of the case that resemble human
legs, and conical, elongated protrusions, extending from each side of the cover that resemble
arms.
20. In addition, the packaging for the iGuy® Cases includes a white cardboard insert
that fits within the rectangular orifice intended for insertion of a tablet and features a stylized
winking “smiley face” (the “iGuy® Packaging Trade Dress”). The iGuy® Case Trade Dress and
the iGuy® Packaging Trade Dress are referred to collectively herein as the “iGuy® Trade Dress”
and are depicted in Exhibit C hereto.
21. The iGuy® Trade Dress has been in use by Plaintiffs since at least as early as
2011. In addition to being, in and of itself, inherently distinctive, as a result of broad media
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exposure, and the uninterrupted and continuing promotion and sale of products bearing the
iGuy® Trade Dress, the iGuy® Trade Dress has also acquired distinctiveness, and has developed
a strong secondary meaning among consumers and the trade, such that consumers immediately
identify Samsonite as the exclusive source of products bearing the iGuy® Trade Dress,
signifying goodwill of incalculable value.
22. The iGuy® Cases generate considerable revenues for Plaintiffs. The iGuy®
Cases bearing the iGuy® Trade Dress have enjoyed substantial sales success.
23. During this same period, Plaintiffs have extensively advertised and marketed
products bearing the iGuy® Trade Dress primarily at trade shows, in print media, and through
Plaintiffs’ website and social media accounts.
24. As a result of the long and continuous sale and promotion throughout the United
States of products featuring the inherently distinctive iGuy® Trade Dress, consumers of
protective cases for electronic devices have come to associate the iGuy® Trade Dress as
signifying high-quality products originating from Samsonite. Indeed, in 2012, the iGuy® Cases
received the Tablet2Cases Golden Case Awards winner for Best Case for Kids.
25. The iGuy® Trade Dress is not functional. The various design elements, while
serving to create a unique and distinct appearance that is both visually appealing and source-
identifying, are not essential to the use or purpose of a tablet case, do not affect the cost or
quality of the tablet cases, and place no competitors at a significant non-reputation-related
disadvantage.
26. The Samsonite Copyrights and the iGuy® Trade Dress are hereinafter collectively
referred to as the “Samsonite’s Protected Designs.”
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DEFENDANTS’ UNLAWFUL ACTS
27. Upon information and belief, Defendants are in the business of designing,
manufacturing, importing, warehousing, distributing, offering for sale and/or selling various
products, including covers for tablets, via Amazon.com throughout the United States and via
SLEC’s website, www.lioeoglobal.com.
28. Upon information and belief, long after Samsonite obtained exclusive rights in
Samsonite’s Protected Designs, Defendants deliberately designed, manufactured, imported,
advertised, promoted, purchased, distributed, sold and/or offered for sale, without authorization
or license from Plaintiffs, infringing products bearing designs that are identical, substantially
similar and indistinguishable from, and confusingly similar to Samsonite’s Protected Designs
(the “Infringing Products”), as depicted below in the side-by-side comparison and in Exhibit D
hereto (the “Infringing Case Design”). Indeed, Defendants have so faithfully reproduced the
design of the distinctive iGuy® Case that the Infringing Products are indistinguishable from the
iGuy® Cases. The Infringing Case Design, like Plaintiffs’ protected design for the iGuy®
Cases, features a rectangular shaped cover, resembling a human, with a rectangular orifice for
insertion of a tablet, with two oblong protrusions at the base of the rectangular body of the case
that resemble human legs, and conical, elongated protrusions, extending from each side of the
cover that resemble arms (the “Infringing Case Trade Dress”):
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Plaintiffs’ iGuy® Case Trade Dress: The Infringing Case Trade Dress:
29. In addition, the packaging for its Infringing Products includes a white cardboard
insert that fits within the orifice intended for insertion of a tablet and features a stylized, winking
“smiley face” (the “Infringing Insert”), depicted in Exhibit E hereto, that is identical and
substantially similar to that featured in the iGuy® Insert:
Plaintiffs’ iGuy® Insert: The Infringing Insert:
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30. The Infringing Products are of lesser quality and are priced substantially lower than
Plaintiffs’ iGuy® Cases. Notably, Plaintiffs’ iGuy® cases retail for $39.99, while on
information and belief the Infringing Products retail for as low as $12.99.
31. As a result, in addition to unlawfully copying and misappropriating Samsonite’s
Protected Designs, the Infringing Products are likely to cause consumers, either at the point-of-
sale or post-sale, to mistakenly believe that the Infringing Products are authorized, sponsored,
approved, endorsed and/or licensed by Plaintiffs, or are in some other way affiliated, associated,
or connected with Plaintiffs.
32. Upon information and belief, Defendants were aware of the fact that Samsonite’s
Protected Designs are original creations of Samsonite at the time that Defendants first designed,
manufactured, imported, offered for sale, and/or sold the Infringing Products.
33. Upon information and belief, images that depict the Infringing Products and
infringe upon Samsonite’s copyright in the iGuy® Design are also displayed on SLEC’s website,
www.lioeo.com, as depicted in Exhibit D hereto.
34. In addition, Plaintiffs, upon discovering Defendants’ infringing conduct and sale of
the Infringing Products on Amazon.com, submitted multiple Notices of Infringement to
Amazon.com, pursuant to and in full compliance with the DMCA, identifying various listings
maintained by SLEC that offered the Infringing Products for sale (the “Infringing Listings”) and
requesting that Amazon.com disable access to the Infringing Listings. A chart identifying
Notices of Infringement submitted by Plaintiffs is attached hereto as Exhibit F.
35. In response, SLEC has submitted multiple false and fraudulent Counter-
Notifications to Amazon.com. In each of its false Counter-Notifications, SLEC knowingly made
material misrepresentations to Amazon.com, falsely stating that the Infringing Listings were
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removed or disabled as a result of mistake or mis-identification and that the products offered by
SLEC do not infringe Samsonite’s Protected Designs.
36. Specifically, SLEC made misrepresentations to the effect that the products reflected
in the Infringing Listings did not infringe Plaintiffs’ rights of copyright and that SLEC had the
lawful right to distribute and sell its Infringing Products, pursuant to a license to an unidentified
Chinese design patent and based upon SLEC’s ownership of a trademark registration in the
United States for the word mark LIOEO.
37. To the extent that SLEC does in fact hold a license pursuant to a Chinese design
patent embodying the case design at issue, such patent is, upon information and belief, invalid.
38. SLEC’s reliance upon its registration for the LIOEO word mark is irrelevant and
has no bearing upon the validity of Plaintiffs’ Notices of Infringement, which are premised
solely upon Plaintiffs’ rights of copyright in and to the iGuy® Case Design.
39. Upon receipt of such Counter-Notifications, Amazon.com has restored access to the
Infringing Listings. This process of repeated submission of Notices of Infringement by Plaintiffs
and corresponding submission of false Counter-Notifications by SLEC has occurred multiple
times, with Amazon.com restoring access to the Infringing Listings in reliance upon SLEC’s
false Counter-Notifications.
40. Plaintiffs submitted a Notice of Infringement on February 6, 2019. In response,
SLEC submitted a Counter-Notification on March 7, 2019, which is attached hereto as Exhibit
G. On March 1, 2019, Plaintiff submitted another Notice of Infringement concerning listings
depicting Infringing Products, but to date, SLEC has not yet submitted a Counter-Notification in
response to the March 1, 2019 Notice of Infringement.
41. Accordingly, upon information and belief, Defendants have been engaging in the
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above-described unlawful activities knowingly and intentionally, or with reckless disregard for
Samsonite’s rights in and to Samsonite’s Protected Designs.
42. Upon information and belief, Defendants are manufacturing, sourcing, purchasing,
supplying, importing, distributing, advertising, promoting, offering for sale and/or selling, and/or
are causing to be manufactured, imported, purchased, supplied, distributed, advertised,
promoted, offered for sale and/or sold, without authorization or license, the Infringing Products,
which are of inferior quality, at prices substantially below the retail prices at which Plaintiffs’
iGuy® Cases are sold, in an effort to induce consumers into thinking either that they are
purchasing Plaintiffs’ iGuy® Cases, or in the hope that the Infringing Products will appear to
consumers to be Plaintiffs’ genuine products.
43. Upon information and belief, the Infringing Products are also listed for sale on
Amazon’s platforms in India, Italy, Japan and Canada.
44. Upon information and belief, Defendants intend to continue to manufacture, import,
purchase, distribute, advertise, promote, offer for sale and/or sell the Infringing Products, unless
otherwise restrained by this Court.
45. Unless Defendants’ conduct is enjoined, such conduct will diminish the value of
Samsonite’s valuable intellectual property rights, and severely inhibit and/or destroy the ability
of Samsonite’s Protected Designs to identify Samsonite as the exclusive source of goods to
which they are affixed.
FIRST CLAIM FOR RELIEF

COPYRIGHT INFRINGEMENT (17 U.S.C. § 501)
(AGAINST ALL DEFENDANTS)
46. The allegations set forth in paragraphs 1 through 45 hereof are adopted and
incorporated by reference as if fully set forth herein.
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47. Samsonite is the owner of and Speck is the worldwide licensee of the copyright
registrations for the iGuy® Design and the iGuy® Insert.
48. Defendants, without authorization from Plaintiffs, have reproduced, designed,
manufactured, supplied, imported, purchased, advertised, promoted, distributed, sold and/or
offered for sale products and packaging that are slavishly copied from and are substantially
similar in overall appearance to the iGuy® Design and the iGuy® Insert, and are displaying
images of the Infringing Products on SLEC’s website, www.lioeoglobal.com.
49. Defendants thereby have willfully infringed and, upon information and belief,
continue to willfully infringe Samsonite’s copyright registrations for the iGuy® Design and the
iGuy® Insert.
50. Upon information and belief, by their acts, Defendants have made and will continue
to make substantial profits and gains to which they are not in law or in equity entitled.
51. Upon information and belief, Defendants intend to continue their willful conduct,
and will continue to willfully infringe Samsonite’s copyright registrations for the iGuy® Design
and the iGuy® Insert and to act in bad faith, unless restrained by this Court.
52. The acts of Defendants have damaged and will continue to irreparably damage
Plaintiffs, and Plaintiffs have no adequate remedy at law.
SECOND CLAIM FOR RELIEF

VIOLATION OF DMCA (17 U.S.C. § 512(f))
(AGAINST SLEC)
54. SLEC knowingly made material misrepresentations in each of the Counter-
Notifications submitted by SLEC to Amazon.com, including but not limited to the Counter-
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Notifications attached as Exhibit G hereto.
55. Specifically, SLEC made misrepresentations to the effect that the products reflected
in the Infringing Listings did not infringe Plaintiffs’ rights of copyright and that SLEC had the
lawful right to distribute and sell its Infringing Products, pursuant to a license to an unidentified
Chinese design patent and based upon SLEC’s ownership of a trademark registration in the
United States for the word mark LIOEO.
56. To the extent that SLEC does in fact hold a license pursuant to a Chinese design
patent embodying the case design at issue, such patent is, upon information and belief, invalid.
57. SLEC’s reliance upon its registration for the LIOEO word mark is irrelevant and
has no bearing upon the validity of Plaintiffs’ Notices of Infringement, which are premised
solely upon Samsonite’s rights of copyright in and to the iGuy® Design.
58. Plaintiffs have been damaged as a result of Amazon.com’s reliance upon SLEC’s
repeated material misrepresentations in each of the Counter-Notifications submitted by SLEC.
59. As a result, Plaintiffs are entitled to an award of damages, including all costs and
attorneys’ fees incurred by Plaintiffs, including the costs and fees associated with this action, as a
result of SLEC’s material misrepresentations in its Counter-Notifications.
THIRD CLAIM FOR RELIEF

TRADE DRESS INFRINGEMENT (15 U.S.C. § 1125(a))
61. The iGuy® Trade Dress is inherently distinctive, non-functional, and serves to
identify Plaintiffs and their leading brand of protective tablet cases.
62. In addition, the iGuy® Trade Dress has acquired secondary meaning and
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distinctiveness in light of Plaintiffs’ substantial marketing efforts, customer identification of
Plaintiffs’ iGuy® Cases with a particular, single source, and the length of use of the iGuy®
Trade Dress as identifying Samsonite as the source of this particular high quality line of
protective tablet cases.
63. By virtue of use of the distinctive and non-functional iGuy® Trade Dress, through
its worldwide licensee, Speck, Samsonite is the owner at common law of the iGuy® Trade Dress
in connection with protective tablet cases. Samsonite has established valuable good will in the
iGuy® Trade Dress.
64. The Infringing Case Trade Dress used in connection with the Infringing Products
and the design depicted on the Infringing Insert so closely resembles the iGuy® Trade Dress that
it is likely to cause confusion, mistake or deception. Such use is likely to cause persons to
believe, contrary to fact, that the business and products of Defendants originate with, are
sponsored by, or are associated with Plaintiffs, thereby infringing the iGuy® Trade Dress and
diminishing and impairing Samsonite’s good will in the iGuy®Trade Dress.
65. Defendants’ acts of infringement are willful and intentional.
66. Plaintiffs have suffered and will continue to suffer immediate and irreparable harm
as a result of the promotion, use and sale of the Infringing Products.
FOURTH CLAIM FOR RELIEF

FEDERAL UNFAIR COMPETITION (15 U.S.C. §1125(a))
68. Defendants’ use of a product design and a packaging that infringe the iGuy® Trade
Dress in connection with their goods is in violation of 15 U.S.C. §1125 in that such use is likely
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to cause confusion, to cause mistake, or to deceive persons as to the affiliation, connection, or
association of Defendants with Plaintiffs, or as to the origin, sponsorship, or approval of
Defendants’ Infringing Products or commercial activities by Plaintiffs.
69. Defendants’ unauthorized use of a product design and packaging that is identical
and confusingly similar to the iGuy® Trade Dress constitutes violations of 15 U.S.C. §1125.
Such acts constitute (a) a false designation of origin, (b) a false or misleading description of fact
and/or (c) a false and misleading representation of fact resulting in unfair competition with
Plaintiffs in that such conduct is likely to cause confusion, mistake or deception, contrary to fact,
that the business and products of Defendants are sponsored by, endorsed by or emanate from
Plaintiffs or otherwise are connected with Plaintiffs. Such use, therefore, causes irreparable
damage and harm to Samsonite’s goodwill in the iGuy® Trade Dress.
70. Defendants’ wrongful and infringing conduct is willful and intentional.
71. Defendants’ wrongful and infringing conduct has caused and will continue to cause
Plaintiffs to suffer damage and injury to their business, reputation and goodwill and to sustain
substantial loss of revenues and profits.
72. Unless enjoined by this Court, Defendants will continue to perform the acts
complained of herein and cause said damages and injury, all to the immediate and irreparable
harm of Plaintiffs. Plaintiffs have no adequate remedy at law for Defendants’ wrongful acts.
FIFTH CLAIM FOR RELIEF

DECEPTIVE ACTS AND PRACTICES UNDER NEW YORK GENERAL BUSINESS
LAW §§ 349 AND 350
74. Samsonite enjoys well-established common law rights in and to the iGuy® Trade
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Dress in the State of New York, which rights are superior to any rights that Defendants may
claim, and Samsonite has built significant goodwill in the iGuy® Trade Dress.
75. The iGuy® Trade Dress is inherently distinctive, non-functional, and serves to
identify Samsonite and its licensee, Speck’s leading brand of protective tablet cases.
76. In addition, the iGuy® Trade Dress has acquired secondary meaning and
distinctiveness in light of Plaintiffs’ substantial marketing efforts, customer identification of the
iGuy® Cases with a particular, single source, and the length of use of the iGuy® Trade Dress as
identifying Samsonite as the source of this particular high quality line of protective tablet cases.
77. Plaintiffs first adopted and used the iGuy® Trade Dress as a means of establishing
goodwill and reputation and to describe, identify or denominate particular goods offered by
Plaintiffs and to distinguish them from similar goods offered by others. As a result, the iGuy®
Trade Dress has acquired secondary meaning.
78. Defendants have used, in connection with the sale of their Infringing Products, a
product design and packaging that is identical or confusingly similar to the iGuy® Trade Dress
and which is likely to cause and/or has caused confusion or mistake as to the source, affiliation,
connection or association of Defendants’ products in that consumers thereof are likely to
associate or have associated such products as originating with Samsonite, all to the detriment of
Plaintiffs.
79. Through the advertisement, offer to sell and/or sale of the Infringing Products
bearing a design and packaging that infringe the iGuy® Trade Dress, Defendants have engaged
in consumer-oriented conduct that has directly and/or indirectly affected the public interest of
New York and has resulted in injury to consumers of New York.
80. Defendants’ acts as complained of herein are materially misleading to a substantial
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portion of the consuming public and have deceived and/or are likely to deceive a material
segment of the consuming public to whom Defendants have directed Defendants’ products and
such acts have cause injury to Plaintiffs.
81. Through the acts complained of herein, Defendants have willfully engaged in
deceptive acts or practices in the conduct of business and the furnishing of Defendants’ products
in violation of Section 349 and 350 of the New York General Business Law.
82. Plaintiffs have no adequate remedy at law.
83. Plaintiffs have suffered and continue to suffer economic loss directly and
proximately caused by Defendants’ actions alleged herein.
SIXTH CLAIM FOR RELIEF

TRADEMARK INFRINGEMENT AND UNFAIR COMPETITION UNDER NEW YORK
STATE COMMON LAW
85. Samsonite enjoys well-established common law rights in and to the iGuy® Trade
Dress in the State of New York, which are superior to any rights that Defendants may claim, and
Samsonite has built significant goodwill in the iGuy® Trade Dress.
86. Defendants used, in connection with the sale of their Infringing Products, a design
and a packaging that are identical to or confusingly similar to the iGuy® Trade Dress and which
are likely to cause and/or have caused confusion or mistake as to the source, affiliation,
connection or association of Defendants’ products in that consumers thereof are likely to
associate or have associated such products as originating with Plaintiffs, all to the detriment of
Plaintiffs.
87. Defendants’ acts complained of herein constitute trademark infringement and unfair
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competition under the laws of the state of New York.
88. Defendants have been unjustly enriched and have damaged Plaintiffs’ business,
reputation, and goodwill.
89. Upon information and belief, Defendants’ conduct is intentional, with knowledge,
and in bad faith, entitling Plaintiffs to increased damages and attorneys’ fees.
90. Defendants’ acts, as complained of herein, have caused irreparable injury and
damage to Plaintiffs and, unless restrained, will continue to do so.
91. Plaintiffs have no adequate remedy at law.
92. Plaintiffs have suffered and continue to suffer economic loss directly and
proximately caused by Defendants’ actions alleged herein.
PRAYER FOR RELIEF
WHEREFORE, Plaintiffs demand judgment against Defendants as follows:
1. That Defendants, and all persons acting in concert or participating with
Defendants, be permanently enjoined from:
(a) Reproducing, publishing, distributing, or selling any products, including
but not limited to the Infringing Products, and any product packaging, that copies, reproduces,
incorporates, or replicates the iGuy® Design, the iGuy® Insert, or any portion thereof, or
otherwise infringes the Samsonite Copyrights;
(b) Using in any manner the iGuy® Trade Dress, the Infringing Case Trade
Dress, the Infringing Insert, or any other trade dress that is confusingly similar to the iGuy®
Trade Dress, including, but not limited to, selling, offering for sale, displaying, promoting or
advertising products bearing the iGuy® Trade Dress, the Infringing Case Trade Dress, the
Infringing Insert, or any other confusingly similar trade dress;
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(c) Depicting the Infringing Products, the Infringing Case Trade Dress and the
Infringing Insert on SLEC’s website, www.lioeoglobal.com, or on any other website and/or
social media accounts owned, controlled or maintained by any of the Defendants;
(d) Passing off, inducing, or enabling others to sell or pass off any products
that do not emanate from Plaintiffs or that are not distributed under the control and supervision
of Plaintiffs and approved by Plaintiffs for sale bearing the iGuy® Trade Dress, the Infringing
Case Trade Dress, the Infringing Insert, or any other confusingly similar trade dress, as products
distributed by or with the approval of Plaintiffs;
(e) Committing any act calculated to cause purchasers to falsely believe that
Defendants’ products are those sold under the control and supervision of Plaintiffs, are
sponsored, approved or connected with, guaranteed, warranted, or produced under the control
and supervision of Plaintiffs;
(f) Shipping, importing, delivering, distributing, returning, or otherwise
disposing of in any manner products or inventory bearing the iGuy® Trade Dress, the Infringing
Case Trade Dress, the Infringing Insert, or any trade dress that is confusingly similar to the
iGuy® Trade Dress;
(g) Further infringing the iGuy® Trade Dress and damaging Samsonite’s
goodwill and Plaintiffs’ business reputation;
(h) Otherwise competing unfairly with Plaintiffs in any manner; and
(i) Continuing to perform in any manner whatsoever any act deemed contrary
to law by this Court.
20
ME1 29906234v.1
2. That Plaintiffs be awarded such damages as they have sustained as a result of
Defendants’ infringement of the Samsonite Copyrights, as well as Defendants’ profits
attributable to their unlawful acts in violation of the Samsonite Copyrights. 17 U.S.C. § 504(b).
3. That all listings on Amazon.com for the Infringing Products be permanently
disabled.
4. That Defendants immediately remove all images depicting the Infringing Products,
the Infringing Case Trade Dress and the Infringing Insert from all websites, including but not
limited to www.lioeoglobal.com, all social media accounts, and all other advertising or
promotional materials, whether in print or electronic form.
5. That Plaintiffs be awarded such damages, including costs and attorneys’ fees,
incurred by Plaintiffs as a result of SLEC’s knowing and material misrepresentations in each of
the Counter-Notifications submitted by SLEC to Amazon.com. 17 U.S.C. § 512(f).
6. That Defendants be ordered to provide an accounting of all revenue generated from
their use of the Infringing Case Trade Dress and the Infringing Insert, and to pay Plaintiffs all
profits realized by Defendants by reason of their unlawful acts as set forth in this Complaint. 15
U.S.C. § 1117(a).
7. That Defendants be ordered to pay Plaintiffs all damages suffered by Plaintiffs by
reason of Defendants’ trade dress infringement, unfair competition, and false designation of
origin, as set forth in this Complaint. 15 U.S.C. § 1117(a).
8. That the Court award Plaintiffs three times the damages suffered by reason of the
intentional, unlawful acts of Defendants as set forth in this Complaint. 15 U.S.C. § 1117(a).
9. That Defendants be required to file with the Court and serve on the undersigned
counsel for Plaintiffs, within thirty (30) days after the entry of judgment, a written report under
21
ME1 29906234v.1
oath setting forth in detail the manner in which Defendants have complied with the injunction
ordered by this Court. 15 U.S.C. § 1116.
10. That this case be declared exceptional, and that Defendants be ordered to pay
Plaintiffs, the prevailing party, the costs of this action, filing fees, and their reasonable attorneys’
fees. 15 U.S.C. § 1117(a).
11. That Plaintiffs shall have other such relief as this Court may deem just and proper.
Dated: March 21, 2019
McCARTER & ENGLISH, LLP
By: s/Margarita Wallach

Margarita Wallach
Irene M. Hurtado
Worldwide Plaza
Tel.: (212) 609-6800
Attorneys for Plaintiffs
22
ME1 29906234v.1
DEMAND FOR TRIAL BY JURY
Plaintiffs hereby demand trial by jury on all issues.
Dated: March 21, 2019
McCARTER & ENGLISH, LLP
By: s/Margarita Wallach

Margarita Wallach
Irene M. Hurtado
Worldwide Plaza
Tel.: (212) 609-6800
Attorneys for Plaintiffs
23
ME1 29906234v.1
Case 1:19-cv-02564 Document 1-1 Filed 03/21/19 Page 1 of 28
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Exhibit E
Plaintiffs’ iGuy® Insert:
The Infringing Insert:

Exhibit F
Notices of Infringement Submitted to Amazon against SLEC’s

Infringing Listings
Last updated March 21, 2019
ASIN Product Name Submission Dates for

Notices of Infringement
B01GJML0HE Lioeo iPad Air 2 Kids Case iPad Air Kids  05/21/2018
Case Cute 3D Cartoon Light Weight  10/12/2018
ShockProof Protection Cases EVA Foam  10/30/2018
Protective Children Cases and Covers for  11/14/2018 (SIPI)
Apple iPad 5 6 Generation New iPad  12/11/2018
2017(Yellow)  02/06/2019 (SIPI)
B01GJML1EQ Lioeo iPad Air 2 Kids Case iPad Air Kids  05/21/2018
Shock Proof Protection Cases EVA Foam  11/14/2018 (SIPI)
Protective Children Cases and Covers for  12/11/2018
Apple iPad 5 6 Generation New iPad 2017  02/06/2019 (SIPI)
(Red)
B01GJML0QA Lioeo iPad Air 2 Kids Case iPad Air Kids  05/21/2018
Case Cute 3D Cartoon LightWeight  10/12/2018
Apple iPad 5 6 Generation New iPad 2017  12/11/2018
(Purple)  02/06/2019 (SIPI)
B01GJML1XW Lioeo New iPad 9.7 2017 Case for Kids  05/21/2018
iPad Air Kids Cases Light Weight Shock  10/12/2018
Proof Protection Cases Protective Handle  10/30/2018
Cases Cover for New iPad 2017 Apple  11/14/2018 (SIPI)
iPad Air/iPad Air 2 /iPad Pro 9.7inch  12/11/2018
（Pink）  02/06/2019 (SIPI)
B01GJML2YU Lioeo iPad Pro 9.7 Case Kids iPad Air  05/22/2018
Case Kids iPad Air 2 Case Cartoon  05/30/2018
LightWeight Shockproof Durable  11/14/2018 (SIPI)
Protection Cases EVA Foam Protective  12/11/2018
Cases and Covers for Apple iPad 5 6 New  02/06/2019 (SIPI)
iPad 2017 (Hot Pink)
2

B01GJML0OW Lioeo iPad Air 2 Kids Case iPad Air Kids  05/21/2018
Shock Proof Protection Cases EVA Foam  11/14/2018 (SIPI)
(Blue)
B01GJML0N8 Lioeo iPad Pro 9.7 Case Kids iPad Air  05/21/2018
Case Kids iPad Air 2 Case Cartoon  10/12/2018
Lightweight Shockproof Durable  11/14/2018 (SIPI)
Protection Cases EVA Foam Protective  12/11/2018
Cases and Covers for Apple iPad 5 6 New  02/06/2019 (SIPI)
iPad 2017 (Black)
B01KHEKUVC Lioeo iPad Mini Case for Kids iPad Mini 4  05/21/2018
Case with Handle Stand Shock Proof  08/06/2018
Cover Lightweight EVA Foam Protective  08/24/2018
Cases and Covers for Apple iPad Mini 4 3  09/11/2018
2 1 7.9 inch (Hot Pink)  10/12/2018
 10/30/2018
 11/14/2018
 12/11/2018
 03/01/2019 (SIPI)
B01KHEKUAI Lioeo iPad Mini Case for Kids iPad Mini 4  05/21/2018
Case Shock Proof Freestanding with  08/06/2018
Handle Lightweight EVA Foam Protective  08/24/2018
2 1 7.9 inch (Yellow)  09/13/2018
 10/12/2018
 10/30/2018
 11/14/2018 (SIPI)
 12/11/2018
 02/06/2019 (SIPI)
B01KHEKVN4 Lioeo iPad Mini Case for Kids iPad Mini 4  05/21/2018
Case with Handle Stand Shock Proof  08/06/2018
Cover Lightweight EVA Foam Protective  08/24/2018
2 1 7.9 inch (Red)  10/30/2018
 11/14/2018 (SIPI)
 12/11/2018
 02/06/2019 (SIPI)
3

B01KHEKULW Lioeo iPad Mini Case for Kids iPad Mini 4  05/21/2018
2 1 7.9 inch (Purple)  10/30/2018
 11/14/2018 (SIPI)
 12/11/2018
 02/06/2019 (SIPI)
B01KHEKV6Q Lioeo iPad Mini Case for Kids  05/21/2018
Freestanding with Handle Lightweight  08/06/2018
EVA Foam Case for Apple iPad Mini 4 3 2  08/24/2018
1 7.9 inch (Pink)  09/11/2018
 10/30/2018
 11/14/2018 (SIPI)
 12/11/2018
 02/06/2019 (SIPI)
B01KHEKUTO Lioeo iPad Mini Case for Kids iPad Mini 4  05/21/2018
2 1 7.9 inch (Orange)  10/30/2018
 11/14/2018 (SIPI)
 12/11/2018
 02/06/2019 (SIPI)
B01KHEKVES Lioeo iPad Mini Case for Kids iPad Mini 4  08/06/2018
2 1 7.9 inch (Blue)  10/30/2018
 11/14/2018 (SIPI)
 12/01/2018 (SIPI)
 12/11/2018
 02/06/2019 (SIPI)
B01KHEKU5S Lioeo iPad Mini Case for Kids iPad Mini 4  08/06/2018
2 1 7.9 inch (Black)  11/14/2018 (SIPI)
 12/11/2018
 02/06/2019 (SIPI)
4

B01GJML2XG Lioeo iPad Air 2 Kids Case iPad Air Kids  08/06/2018
Case Cute 3D Cartoon LightWeight  05/21/2018
(Orange)  12/01/2018 (SIPI)
 12/10/2018
 02/06/2019 (SIPI)
B01GJML3FS Lioeo iPad Air 2 Kids Case iPad Air Kids  05/21/2018
Case Cute 3D Cartoon Lightweight  10/12/2018
Shockproof Protection Cases EVA Foam  10/30/2018
(Green)  12/10/2018
 02/06/2019 (SIPI)
B01DNRTQXS Lioeo Samsung Galaxy Tab 3/3 Lite 7.0  05/01/2018
Case for Kids Rubber Shock Proof  10/12/2018
Protective Case Cover with Carry Handle  10/30/2018
for Samsung Galaxy Tab 3/3 Lite Tablet 7  12/10/2018
inch Screen  02/07/2019 (SIPI)
B01DNRTQTC Lioeo Samsung Galaxy Tab 3/3 Lite 7.0  05/01/2018
for Samsung Galaxy Tab 3/3 Lite Tablet 7  02/07/2019 (SIPI)
inch Screen
B01DNRTRRS Lioeo Samsung Galaxy Tab 3/3 Lite 7.0  05/01/2018
inch Screen
B01DNRTQVA Lioeo Samsung Galaxy Tab 3/3 Lite 7.0  05/01/2018
for Samsung Galaxy Tab 3/3 Lite Tablet 7  12/10/2018
inch Screen  02/07/2019 (SIPI)
B01DNRTS0O Lioeo Samsung Galaxy Tab 3/3 Lite 7.0  05/01/2018
inch Screen
5

B01DNRTQUQ Lioeo Samsung Galaxy Tab 3/3 Lite 7.0  05/01/2018

inch Screen
B01DNRTQXI Lioeo Samsung Galaxy Tab 3/3 Lite 7.0  05/01/2018

inch Screen
B01DNRTQWY Lioeo Samsung Galaxy Tab 3/3 Lite 7.0  05/01/2018

inch Screen
B01DNRTQM4 Lioeo Samsung Galaxy Tab 3/3 Lite 7.0  05/01/2018

inch Screen
B01KHEKUJO Lioeo iPad Mini Case for Kids iPad Mini 4  05/21/2018
2 1 7.9 inch (Green)  10/30/2018
 12/10/2018
 02/07/2019 (SIPI)
B06XQ12L1T Lioeo iPad 2 Case Kids iPad 3 Case iPad 4  05/23/2018

Kid proof case Shockproof Light Weight  07/12/2018
EVA Foam Protective Cover For Kids
carrying Handle Friendly Case for Apple
iPad 2/3/4 9.7 Inch Screen(Rose Pink)
B06XPZMDYN Lioeo iPad 2 Case Kids iPad 3 Case iPad 4  05/23/2018

iPad 2/3/4 9.7 Inch Screen (Yellow)
6

B06XRV9L69 Lioeo iPad 2 Case Kids iPad 3 Case iPad 4  05/23/2018

iPad 2/3/4 9.7 Inch Screen (Red)
B06XPZQ2J4 Lioeo iPad 2 Case Kids iPad 3 Case iPad 4  05/23/2018

iPad 2/3/4 9.7 Inch Screen (Purple)
B06XPZ56Q9 Lioeo iPad 2 Case Kids iPad 3 Case iPad 4  05/23/2018

iPad 2/3/4 9.7 Inch Screen (Pink)
B06XQ29JGB Lioeo iPad 2 Case Kids iPad 3 Case iPad 4  05/23/2018

iPad 2/3/4 9.7 Inch Screen (Orange)
B06XPZCFFS Lioeo iPad 2 Case Kids iPad 3 Case iPad 4  05/23/2018

iPad 2/3/4 9.7 Inch Screen (Green)
B06XQ24HQL iPad 2 Case Kids iPad 3 Case iPad 4 Kid  05/23/2018

proof case by Lioeo Shockproof Light  07/12/2018
Weight EVA Foam Protective Cover For
Kids carrying Handle Friendly Case for
Apple iPad 2/3/4 9.7 Inch Screen (Blue)
B06XPWRF8J Lioeo iPad 2 Case Kids iPad 3 Case iPad 4  05/23/2018

iPad 2/3/4 9.7 Inch Screen (Black)
7

B07KTPB2TB Lioeo New iPad 2017 Case, iPad Air 2  01/21/2019 (SIPI)(UK)
Kids Case Cute 3D Cartoon Light Weight
Shock Proof Durable Protection Cases
EVA Foam Protective Children Cases and
Covers for Apple iPad 5 6 Generation
(Yellow)
B07KTQFWZ3 Lioeo iPad Air Kids Case iPad Air 2 Case  01/21/2019 (SIPI)(UK)
Cute 3D Cartoon Light Weight Shock
Proof Durable Protection Cases EVA
Foam Protective Children Cases and
(Orange)
B07KTPV5PY Lioeo iPad Air Kids Case iPad Air 2 Case  01/21/2019 (SIPI)(UK)
Cute 3D Cartoon Light Weight Shock
Proof Durable Protection Cases EVA
Foam Protective Children Cases and
(Purple)
B07KK8HZ7Z Lioeo iPad Mini Case for Kids Silicone  03/19/2019 (SIPI)(UK)
Heavy Duty Protective iPad Mini 4 Case
Lightweight Hard Carrying Case with
Handle Shockproof Child Proof Case for
iPad Mini 4 3 2 1 7.9 inch (Yellow)
B07KK8XGYT Lioeo iPad Mini Case for Kids Silicone  03/19/2019 (SIPI)(UK)
Heavy Duty Protective iPad Mini 4 Case
Lightweight Hard Carrying Case with
Handle Shockproof Child Proof Case for
iPad Mini 4 3 2 1 7.9 inch (Blue)
B07KSZJW5V Lioeo iPad Mini Case for Kids Silicone  03/19/2019 (SIPI)(UK)
Protective iPad Mini 4 Case Lightweight
Hard Carrying Case with Handle
Shockproof Child Proof Case for iPad
Mini 4 3 2 1 7.9 inch (Pink)
B07KT14XKY Lioeo iPad Mini 2 Case for Kids  03/19/2019 (SIPI)(UK)

Shockproof iPad Mini 4 Case Silicone
Lightweight Carrying Cover Child Proof
Case for iPad Mini 4 3 2 1 7.9 inch
(Purple)
8

B07KKBGP4P Lioeo iPad Mini Case for Kids  03/19/2019 (SIPI)(UK)

Shockproof iPad Mini 4 Case Silicone
Lightweight Carrying Cover Child Proof
Case for iPad Mini 4 3 2 1 7.9 inch (Rosa
Pink)
B07KTQ23WK Lioeo New iPad 2017 Case, iPad Air 2  03/19/2019 (SIPI)(UK)
Kids Case Cute 3D Cartoon Light Weight
Shock Proof Durable Protection Cases
EVA Foam Protective Children Cases and
(Yellow)
9
Exhibit G
From: counter-notice <counter-notice@amazon.com>

Sent: Friday, March 8, 2019 02:32
To: Speck <speckcops@sipi.in>
Cc: lioeo2016@163.com; counter-notice <counter-notice@amazon.com>
Subject: FW: Counter-Notice to Complaint ID: 5765273681
Raj,
We have received the attached counter notice to your report of posting, hosting and/or distributing
unlicensed copyright protected material on our network. We will allow this material to be accessible,
unless you provide us with notice that a lawsuit has been filed against the counter-noticing party within
10 business days. Please ensure a copy is sent to counter-notice@amazon.com to help ensure efficient
processing.
Regards,
Amazon.com DMCA Counter-Notice Team
From: LIO US <lioeo2016@163.com>

Sent: Thursday, March 7, 2019 6:00 AM
To: counter-notice <counter-notice@amazon.com>
Subject: Counter-Notice to Complaint ID: 5765273681
Hi Amazon Team,
Greetings! Thank you for your busy schedule to reply our email. The revised
written counter-notice statement as follow:
Statement
We have a good-faith belief that the content was removed or disabled as a result
of a mistake, or mis-identification of the content to be removed or disabled. We
believe our product does not infringe the rights owner's copyright after our
research on this case. Please review and restore our listing.
The content that was removed or disabled are as following:
ASIN(s): B01GJML0HE, B01GJML0QA, B01GJML0N8, B01GJML1EQ, B01GJML1XW,
B01GJML0OW, B01GJML2XG, B01GJML2YU, B01GJML3FS
B01KHEKU5S, B01KHEKUVC, B01KHEKVES, B01KHEKV6Q, B01KHEKULW,
B01KHEKUTO, B01KHEKUJO, B01KHEKUAI, B01KHEKVN4
B01DNRTQM4, B01DNRTQVA, B01DNRTS0O, B01DNRTQWY, B01DNRTRRS,

B01DNRTQUQ, B01DNRTQXS, B01DNRTQXI, B01DNRTQTC, B01GJML2XG,
B01GJML3FS, B01KHEKUJO
First of all, we declare under penalty of perjury that we have a good faith belief
that the material at issue was mistakenly removed. Because our products are
produced by qualified manufacturer in China who with many years trading
experience. They have patent, including appearance patent, on their products
they produced and authorized us to sell their products on our selling channels.
Please check our purchase contract and patent authorization from supplier as
attachment. If the evidence is not enough, please tell us what type of this
infringement is. We have a good-faith belief for our products.
Secondly, the involved listings are created by LIOEO US, we had applied for
Amazon Brand Registry. LIOEO US is also a US registered trademark, (trademark
NO.: 5114328 ) protected by US law. We learned Amazon policy before we sell,
and always keep it in mind, so we take brand building and Intellectual Property
very seriously as well as Amazon. And we only sell products with our brand.
Review the growth process of Lioeo. Its sales are on the rise. It promotes the
development of Amazon. It has about 360 feedback and positive feedback is
over 99%. Its health indicators are very good. We focus on managing it, we firmly
believe that we're not only providing the product but also the customer service,
Lioeo has established its brand influence and is deeply rooted in the hearts of
the customer. We are so mindful and familiar with the Amazon rules, how can we
know the policy and violate it?
You could also check our products on our official website:
http://www.lioeoglobal.com/
Finally, we consent to the jurisdiction of the Federal District Court for the judicial
district, and we will accept service of process from the person who provided
notification under subsection (c)(1)(C) or an agent of such person.
Best Regards!
Yang Chun
Shenzhen Liangyiyou E-commerce Co.,Ltd

Add: 18C, Block B, Haishandao No.1 Building, Haishan Road, Yantian District
Shenzhen Guangdong. China 518081 Tel: 86 13873676471
LIO US
lioeo2016@163.com
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Samsonite IP Holdings v. Shenzhen Liangyiyou E-Commerce - Complaint

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Samsonite IP Holdings v. Shenzhen Liangyiyou E-Commerce - Complaint

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Case 1:19-cv-02564 Document 1 Filed 03/21/19 Page 1 of 23

MCCARTER & ENGLISH, LLP

UNITED STATES DISTRICT COURT

Plaintiffs Samsonite IP Holdings S.àr.l. (“Samsonite”) and Speculative Product Design,

and XYZ Companies 1-10 (unidentified) (collectively, “Defendants”), allege as follows:

NATURE OF THE ACTION

1. Plaintiffs bring this action to put an end to Defendants’ unlawful manufacture,

(the “iGuy® Case”).

JURISDICTION AND VENUE

§§1338 (a) and (b), and 28 U.S.C. § 1367.

counter-notifications pursuant to the DMCA, as discussed below, to Amazon.com and, in doing

states that it has offices in New York, New York.

5. Venue is proper in this District pursuant to 28 U.S.C. §§1391(b) and (c).

upon the submission to jurisdiction included in each of the counter-notifications submitted by

6. Plaintiff Samsonite is a société à responsabilité limitée (private limited liability

200, San Mateo, California 94402.

LIOE Ste. 1. #1211, Cranbury, New Jersey 08512.

infringing conduct, including but not limited to manufacturing, importing, distributing,

including but not limited to manufacturing, importing, distributing, warehousing, or selling

(each a “Defendant Company” and collectively, “Defendant Companies”).

THE COPYRIGHTED DESIGNS

photographs of that design, is attached hereto as Exhibit A.

photograph of that design, is attached hereto as Exhibit B.

16. The foregoing copyrighted works shall hereinafter be referred to collectively as

the “Samsonite Copyrights.”

Act with respect to the Samsonite Copyrights.

THE iGUY® TRADE DRESS

and are depicted in Exhibit C hereto.

signifying goodwill of incalculable value.

Plaintiffs’ website and social media accounts.

quality of the tablet cases, and place no competitors at a significant non-reputation-related

referred to as the “Samsonite’s Protected Designs.”

DEFENDANTS’ UNLAWFUL ACTS

SLEC’s website, www.lioeoglobal.com.

Samsonite’s Protected Designs, Defendants deliberately designed, manufactured, imported,

cover that resemble arms (the “Infringing Case Trade Dress”):

substantially similar to that featured in the iGuy® Insert:

Plaintiffs’ iGuy® Insert: The Infringing Insert:

31. As a result, in addition to unlawfully copying and misappropriating Samsonite’s

or connected with Plaintiffs.

www.lioeo.com, as depicted in Exhibit D hereto.

the Infringing Products on Amazon.com, submitted multiple Notices of Infringement to

Notices of Infringement submitted by Plaintiffs is attached hereto as Exhibit F.

Notifications to Amazon.com. In each of its false Counter-Notifications, SLEC knowingly made

SLEC do not infringe Samsonite’s Protected Designs.

United States for the word mark LIOEO.

Infringing Listings. This process of repeated submission of Notices of Infringement by Plaintiffs

and corresponding submission of false Counter-Notifications by SLEC has occurred multiple

40. Plaintiffs submitted a Notice of Infringement on February 6, 2019. In response,

SLEC submitted a Counter-Notification on March 7, 2019, which is attached hereto as Exhibit

G. On March 1, 2019, Plaintiff submitted another Notice of Infringement concerning listings

response to the March 1, 2019 Notice of Infringement.

Samsonite’s rights in and to Samsonite’s Protected Designs.

are causing to be manufactured, imported, purchased, supplied, distributed, advertised,

consumers to be Plaintiffs’ genuine products.

Amazon’s platforms in India, Italy, Japan and Canada.

otherwise restrained by this Court.

of Samsonite’s Protected Designs to identify Samsonite as the exclusive source of goods to

which they are affixed.

FIRST CLAIM FOR RELIEF

incorporated by reference as if fully set forth herein.

registrations for the iGuy® Design and the iGuy® Insert.

48. Defendants, without authorization from Plaintiffs, have reproduced, designed,