IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF NEW YORK

ROBERT G. LOPEZ, an individual, Plaintiff,

V.
J. CREW. INC., and
Civil Action Na.
J. CREW INTERNATIONAL, INC.
JURY TRIAL DEMANDED
Defendants.

COM
PLAI
NT
FOR
TRAD
EMA
RK
INFRI
NGE
MEN
T,
UNFA
IR
COM
PETIT
ION
AND
RELA
TED
CLAI
MS
Plaintiff, Robert Cl. Loper, alleges
his complaint against defendants, J. Crew
Inc. and J. Crew International, Inc. as
 follows:
NATURE
OF THE
ACTION
I. This action arises from
Defendants' infringement of Plaintiffs
"ownership" and "use" rights in the mark
LOWER EAST SIDETm, in conjunction
with clothing, namely t-shirts and sweaters.
Despite Plaintiff being the registered
owner of the trademark LOWER EAST
SIDE•Tm and offering various clothing
items under such brand name, the
defendants' have infringed Plaintiff's rights
in the LOWER EAST SIDETh mark by
selling and offering for sale I.- shirts and
sweaters under the Plaintiff's trademark.
Plaintiff has already experienced "actual
confusion" in connection with this matter
and is likely to continue to experience
confusion as to the affiliation or
connection between the Defendants' and
Plaintiff resulting in the unjust
enrichment of Defendants' by using
Plaintiffs registered trademark.

St -1

?FiC) iC