BSH v. Caliber Range - Complaint

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BSH01-04:1322718_1:7-25-14 - 1 -
COMPLAINT
Wayne W. Call, Bar No. 56676
wcall@calljensen.com
Scott P. Shaw, Bar No. 223592
sshaw@calljensen.com
Cardon B. Smith, Bar No. 277532
csmith@calljensen.com
CALL & J ENSEN
A Professional Corporation
610 Newport Center Drive, Suite 700
Newport Beach, CA 92660
Tel: (949) 717-3000
Fax: (949) 717-3100

Attorneys for Plaintiff BSH Home Appliances Corporation

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

BSH HOME APPLIANCES
CORPORATION, a Delaware corporation,

Plaintiff,

vs.

CALIBER RANGE CORPORATION, a
California corporation; DOES 1 through 10,
inclusive,

Defendants.
Case No. 14-cv-5821

COMPLAINT FOR
1. FEDERAL TRADEMARK
INFRINGEMENT
INFRINGEMENT
INFRINGEMENT
4. FEDERAL FALSE
DESIGNATION OF ORIGIN
5. DESIGN PATENT
INFRINGEMENT
6. CALIFORNIA COMMON LAW
TRADEMARK INFRINGEMENT
7. UNFAIR COMPETITION AND
UNFAIR BUSINESS PRACTICES

DEMAND FOR JURY TRIAL

Case 2:14-cv-05821 Document 1 Filed 07/25/14 Page 1 of 15 Page ID #:1

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BSH01-04:1322718_1:7-25-14 - 2 -
COMPLAINT
Plaintiff BSH Home Appliances Corporation (BSH), by and through its
attorneys of record, complains against Caliber Range Corporation (Caliber or
Defendant), and alleges as follows:
NATURE OF THE ACTION
1. By this Complaint, BSH seeks injunctive relief, damages, and other
remedies provided by law to remedy injuries caused by Calibers conduct of infringing
Plaintiffs distinctive trademarks, misappropriating Plaintiffs patent rights, and for
Calibers unfair competition and unfair business practices in violation of California and
United States laws.
2. BSHs primary business has been the manufacture and sale of home
appliances, including but not limited to, domestic and home cooking appliances. BSH
is a fully-owned subsidiary of Bosch and Siemens Home Appliance Group, the third
largest appliance manufacturer in the world.
3. BSH acquired Thermador Corp. in the 1990s, which had been making
kitchen appliances for over 75 years, along with Thermador Corp.s well recognized
brands including, but not limited to, THERMADOR and THERMADOR
PROFESSIONAL. Today, BSH enjoys a nationwide reputation for excellence for its
domestic and home cooking and other appliance products, which have been marketed
under numerous trademarks in interstate commerce in the United States and in other
countries.
4. As detailed below, BSH has established distinctive trademark rights in
THERMADOR and THERMADOR PROFESSIONAL products, as well as a family of
trademark rights using the name STAR for BSHs products and services. BSH also has
distinctive trademark rights in a distinctive star symbol, which consist of a five-pointed
star with truncated tips.
5. In a deliberate attempt to trade on the acclaim of BSHs appliances and the
goodwill developed by BSH in its THERMADOR or THERMADOR
PROFESSIONAL marks, Caliber is using the marks THERMASHELL and

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BSH01-04:1322718_1:7-25-14 - 3 -
COMPLAINT
THERMASHELL PRO for Calibers products. Caliber is also using the marks
STELLAR and STELLAR PRO to trade off BSHs goodwill in its STAR
trademarks for similar products. To make matters worse, Caliber is also using a five-
pointed star design with truncated tips. Calibers Star Design has the same unique five-
point star design with truncated tips as BSHs signature trademark.
6. Calibers actions are intentional and willful, and Calibers products are
likely to cause consumer confusion over source, sponsorship, affiliation, endorsement,
and/or association with BSHs trademark and patent rights. Caliber has prior
knowledge of BSHs products and distinctive intellectual property rights. In fact,
Calibers president and vice-president both previously worked for Dynamic Cooking
Systems (DCS)a direct competitor of Thermador and Bosch and a former sub-
contractor of Thermador. Caliber is now attempting to trade off BSHs goodwill and
reputation by adopting words and designs that will cause consumers to falsely believe
that BSH is affiliated with, or is connected in some way with Caliber.
PARTIES
7. BSH is and was at all times mentioned in this Complaint a corporation of
the State of Delaware, with places of business at 1901 Main Street, Suite 600, Irvine,
California 92614, and 100 Bosch Boulevard, New Bern, North Carolina 28562.
8. On information and belief, Defendant Caliber is a corporation of the State
of California, which has a place of business at 17812 Metzler Lane, Huntington Beach,
California 92647.
9. Plaintiff is unaware of the true names and capacities of defendants sued as
Does 1-10, inclusive, and therefore sues these Defendants by such fictitious names.
Plaintiff is informed and believes, and on the basis of that information and belief
alleges, that at all times mentioned in this Complaint, Does 1-10 were the agents and
employees of their co-defendants or otherwise responsible for the conduct complained
of herein, and in doing the things alleged in this Complaint were acting within the
course and scope of that agency and employment or were otherwise responsible for the

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BSH01-04:1322718_1:7-25-14 - 4 -
COMPLAINT
damages complained of by Plaintiff. Plaintiff will amend this Complaint to allege their
names and capacities when ascertained.
JURISDICTION AND VENUE
10. This is an action for federal trademark infringement pursuant to 15 U.S.C.
1114, federal false designation of origin pursuant to 15 U.S.C. 1125, patent
infringement pursuant to 35 U.S.C. 271, California common law trademark
infringement under California Business & Professions Code 14200 et seq., and unfair
competition and unfair business practices under California Business & Professions
Code 17200 et seq.
11. The Court has jurisdiction under 15 U.S.C. 1121, 1125; and 28 U.S.C.
1331 and 1338 in that this case arises under the trademark laws of the United States,
15 U.S.C. 1051 et seq., and patent laws. The Court has jurisdiction over state unfair
competition claims herein pursuant to 28 U.S.C. 1338(b) because these claims are
joined with a substantial and related claim arising under the trademark laws of the
United States.
12. Venue is proper in this district under 28 U.S.C. 1391(b) and (c) in that
Caliber is subject to personal jurisdiction in this district, Caliber resides in this district, a
substantial part of the events giving rise to the claim occurred in this district, and
Caliber has targeted their harm and injury to Plaintiff who has a place of business in this
district.
13. Caliber is subject to personal jurisdiction in this district under Federal
Rules of Civil Procedure Rule 4(k)(1)(A) and California Code of Civil Procedure
410.10. Caliber is domiciled in this state and is doing continuous and systematic
business in this judicial district.
BSHS INTELLECTUAL PROPERTY RIGHTS
14. For many years, BSH has marketed its products and services all around
the world using its Star Design, STAR, THERMADOR, and THERMADOR
PROFESSIONAL trademarks. In addition to obtaining common law rights to exclusive

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BSH01-04:1322718_1:7-25-14 - 5 -
COMPLAINT
use of these marks, BSH owns several federal trademark registrations, including but not
limited to: U.S. Registration Nos. 2362875, 3829556, 3829558, 4212541, 4259358,
1144768, 1197124, 1853576, 3477069, 3002017, 4223077 and 4265875.
15. BSHs STAR trademark and Star Design trademark rights date back to the
1990s, and the THERMADOR trademark rights date back to the 1920s.
16. Since the adoption and first use of its Star Design, STAR, THERMADOR,
and THERMADOR PROFESSIONAL trademarks, BSH (including its predecessors)
has expended substantial amounts of money, time, and effort to promote and advertise
its products and services around the world using its distinctive Star Design, STAR,
THERMADOR, and THERMADOR PROFESSIONAL trademarks. As a result of such
efforts, BSH has established an outstanding reputation in the minds of customers as to
the excellence of the quality of home appliance products and services sold and offered
in connection with the Star Design, STAR, THERMADOR, and THERMADOR
PROFESSIONAL trademarks.
17. Also, by virtue of these activities, BSH owns the entire right, title and
interest in and to the Star Design, STAR, THERMADOR, and THERMADOR
PROFESSIONAL trademarks, as well as the goodwill of the business with which those
marks have been used. Through the distribution, advertising, and sale of its products
under or in connection with the Star Design, STAR, THERMADOR, and
THERMADOR PROFESSIONAL trademarks, BSH has created substantial goodwill in
those marks. Consequently, the general public has become aware that the Star Design,
STAR, THERMADOR, and THERMADOR PROFESSIONAL trademarks indicate
origin, sponsorship by, or other connection with a single source, BSH.
18. BSH uses the THERMADOR brand and trademark in commerce. This
word mark has been registered on the Principal Register and assigned United States
Registration Nos. 1,144,768 (issued December 30, 1980); 1,197,124 (issued J une 8,
1982); and 3,002,017 (issued September 27, 2005). Copies of these registrations are
attached hereto as Exhibit A, Exhibit B, and Exhibit C respectively. These

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BSH01-04:1322718_1:7-25-14 - 6 -
COMPLAINT
trademarks have become incontestable under Section 15 of the Lanham Act, 15 U.S.C.
1065.
19. BSH also uses in commerce the THERMADOR PROFESSIONAL
trademark. This word mark has been registered on the Principal Register as United
States Registration No. 1853576 (issued September 13, 1994). A copy of this
registration is attached hereto as Exhibit D. Trademark Registration No. 1853576 has
become incontestable under Section 15 of the Lanham Act, 15 U.S.C. 1065.
20. BSH also owns a registration for THERMADOR. AN AMERICAN ICON
trademark. This trademark has been registered on the Principal Register as United
States Registration No. 3,477,069 (issued J uly 29, 2008). A copy of this registration is
attached hereto and made a part of the Complaint as Exhibit E.
21. BSH also uses in commerce the THERMADOR & Star Design trademark.
This trademark has been registered on the Principal Register as United States
Registration Nos. 4,223,077 (issued October 9, 2012) and 4,265,875 (issued December
25, 2012). Copies of these registrations are attached hereto as Exhibit F and Exhibit
G, respectively.
22. BSH also uses in commerce the STAR trademark. This trademark has
been registered upon the Principal Register as United States Registration No. 2,362,875
(issued J une 27, 2000). A copy of this registration is attached hereto as Exhibit H.
Trademark Registration No. 2,362,875 has become incontestable under Section 15 of
the Lanham Act, 15 U.S.C. 1065.
23. BSH also uses in commerce the STAR PARTNER trademark. This mark
has been registered upon the Principal Register as United States Registration No.
3,829,556 (issued August 3, 2010). A copy of this registration is attached hereto as
Exhibit I.
24. BSH also uses in commerce the STAR PARTNER & design trademark.
This mark has been registered upon the Principal Register as United States Registration

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BSH01-04:1322718_1:7-25-14 - 7 -
COMPLAINT
No. 3,829,558 (issued August 3, 2010). A copy of this registration is attached hereto as
Exhibit J .
25. BSH also uses in commerce the STAR SPEED trademark. This trademark
has been registered upon the Principal Register as United States Registration No.
4,247,197 (issued November 20, 2012). A copy of this registration is attached hereto as
Exhibit K.
26. BSH also uses in commerce the Star Design trademark. This trademark
has been registered upon the Principal Register as United States Registration Nos.
4,212,541 (issued September 25, 2012) and 4,259,358 (issued December 11, 2012).
Copies of these registrations are attached hereto as Exhibit L and Exhibit M,
respectively.
27. BSH has exclusively used its Star Design, which is in the shape of a five-
pointed star with trunctated tips, as the shape for the burners on its burners for many
years. BSHs star-shaped burner is highly distinctive, and serves to identify all products
using such a star-shape as coming from BSH. When used as a gas burner, consumers
immediately recognize the Star Design as being associated only with BSH. This same
Star Design is further protected as a Design Patent. (Exhibit N).
CALIBERS WILLFUL INFRINGEMENT
28. Caliber is using designs and trademarks that are highly similar to BSHs
trademarks, and which are likely to cause confusion, or to cause mistake, or to deceive
as to the affiliation, connection, or association of Caliber with BSH, or as to the origin,
sponsorship, or approval of Calibers goods, services, or commercial activities by BSH.
These infringing trademarks include the word marks STELLAR and STELLAR PRO in
place of BSHs STAR, STAR PARTNER, and THERMADOR PROFESSIONAL
trademarks; the word marks THERMASHELL and THERMASHELL PRO in place of
BSHs THERMADOR and THERMADOR PROFESSIONAL trademarks; and a gas
burner shaped as a five-pointed star with truncated tips that is nearly identical to BSHs
Star Design. Caliber calls its star-shaped burner the Stellar top burner and Stellar

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BSH01-04:1322718_1:7-25-14 - 8 -
COMPLAINT
Pro Power Top Burner, whereas BSH calls its star-shaped burner the Star
Burner. These actions constitute willful infringement and an attempt to trade upon
BSHs goodwill.
29. Without BSHs consent, Caliber has been offering for sale and selling
products within this district and throughout the United States under trademarks which
are likely to cause confusion, or to cause mistake, or to deceive as to the affiliation,
connection, or association of Caliber with BSH, or as to the origin, sponsorship, or
approval of Calibers goods, services, or commercial activities by BSH.
30. Calibers products are marketed and sold in similar channels of trade to
consumers seeking cooking appliances or grills. In fact, the parties are apparently
scheduled to showcase their products in an upcoming trade show early next year.
31. Calibers products and BSHs products are related goods. There is no
business affiliation between the two companies. Because both parties products are
related, consumers may think that BSH licensed or authorized Caliber to use BSHs
intellectual property rights, which is not true. Calibers infringing uses on related
products came only after BSH had established its rights in commerce for its products
and developed the reputation that goes with these distinctive marks.
32. Subsequent to BSHs use and registration of its Star Design and STAR
trademarks, Caliber commenced use of a Star design on its STELLAR PRO burner
products that infringes BSHs exclusive rights to the Star Design under US Registration
Nos. 4212541 and 4259358. Caliber knowingly created a Star design that copies the
distinctive BSH Star Design with the five-point star design with truncated tips.
33. There is no reason for Caliber to adopt a five-point star design with
truncated tips other than to trade upon BSHs goodwill.
34. Caliber would have and could have easily designed a burner with fingers
dissimilar from BSHs distinctive five-pointed star with truncated tips. BSHs design is
protected by a Design Patent that provided BSH with exclusive rights.


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BSH01-04:1322718_1:7-25-14 - 9 -
COMPLAINT
35. Caliber also is using in commerce the STELLAR and STELLAR PRO
trademarks which infringe BSHs rights to its registered STAR marks, US Registration
Nos. 2,362,875, 3,829,556, 3,829,558 and 4,247,197.
36. Caliber also is using in commerce the THERMASHELL and
THERMASHELL PRO trademarks which infringe BSHs rights to its registered
THERMADOR and THERMADOR PROFESSIONAL trademarks, US Registration
Nos. 1144768, 1197124, 1853576, 3477069, 3002017, 4223077 and 4265875.
37. Calibers use of its Star design, STELLAR, STELLAR PRO,
THERMASHELL, and THERMASHELL PRO trademarks is aimed at trading on the
good will associated with BSHs famous Star Design, STAR trademarks,
THERMADOR, and THERMADOR PROFESSIONAL trademarks. Caliber began this
unlawful conduct after BSH had begun using its distinctive trademarks in commerce.
FIRST CAUSE OF ACTION
(FEDERAL TRADEMARK INFRINGEMENT [15 U.S.C. 1114])
(Infringement of STAR marks)
38. BSH re-alleges and incorporates herein the allegations of paragraphs 1-37.
39. Calibers use of the marks STELLAR and STELLAR PRO in connection
with its products is likely to cause consumer confusion with BSHs STAR trademark
rights.
40. Unless Calibers use is enjoined, BSH will continue to suffer injury and
damage. Calibers infringement is intentional and willful and BSH is entitled to an
injunction, actual damages, and profit disgorgement from Caliber based on its sales of
infringing products.
41. Calibers actions render this an exceptional case, further entitling BSH to
recovery of its attorneys fees and costs of suit as detailed in 15 U.S.C. 1117.

/ / /
/ / /

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BSH01-04:1322718_1:7-25-14 - 10 -
COMPLAINT
SECOND CAUSE OF ACTION
(Infringement of THERMADOR marks)
43. Calibers use of the marks THERMASHELL and THERMASHELL PRO
in connection with its products is likely to cause consumer confusion with BSHs
THERMADOR and THERMADOR PROFESSIONAL trademark rights.
THIRD CAUSE OF ACTION
(Infringement of Star Design Trademark)
47. Calibers use of the five-pointed star with truncated tips on its products is
likely to cause consumer confusion with BSHs Star Design trademark rights.

/ / /
/ / /

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BSH01-04:1322718_1:7-25-14 - 11 -
COMPLAINT
FOURTH CAUSE OF ACTION
(FEDERAL FALSE DESIGNATION OF ORIGIN [15 U.S.C. 1125(a)])
50. BSH realleges and incorporates herein the allegations of paragraphs 1-49,
inclusive.
51. Calibers use of its Star design, blue flame marketing materials,
STELLAR, STELLAR PRO, THERMASHELL, and/or THERMASHELL PRO
trademarks in connection with its products constitutes a false designation of origin
which is likely to cause consumer confusion over sponsorship, endorsement, affiliation,
connection, or association with BSH.
FIFTH CAUSE OF ACTION
(DESIGN PATENT INFRINGEMENT [35 U.S.C. 271])
inclusive.
55. BSH is the owner of all right, title, and interest in and to the Design Patent
for its Star Design.
56. Caliber has knowingly and intentionally manufactured, caused to be
produced, distributed, offered for sale, and sold a substantially similar product, as
described above, that infringes on BSHs Design Patent rights.
injunction, actual damages, profit disgorgement from Caliber based on its sales of
infringing products, attorneys fees, and possibly treble damages.

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BSH01-04:1322718_1:7-25-14 - 12 -
COMPLAINT
SIXTH CAUSE OF ACTION
(CALIFORNIA COMMON LAW TRADEMARK
INFRINGEMENT [Cal. Bus. & Prof. Code 14200 et seq.])
inclusive.
59. BSH has developed substantial California common law rights in and to its
Star Design, STAR, THERMADOR, and THERMADOR PROFESSIONAL
trademarked products as fully described herein.
60. Caliber has infringed BSHs trademarks by using similar marks in
commerce in the state of California in a way that is likely to cause confusion as to
BSHs association, affiliation, sponsorship or endorsement of Caliber and its products.
61. Calibers infringement is intentional and willful and BSH is entitled to an
injunction, actual damages, profit disgorgement, and punitive damages from Caliber
based on its sales of infringing products.
SEVENTH CAUSE OF ACTION
(CALIFORNIA UNFAIR COMPETITION AND UNFAIR BUSINESS
PRACTICES [Cal. Bus. & Prof. Code 17200 et seq.])
inclusive.
63. Calibers conduct alleged herein constitutes trademark infringement, false
designation of origin, and unfair competition under 15 U.S.C. 1051 et seq. and Cal.
Bus. & Prof. Code 14200 et seq. Calibers conduct thus constitutes willful and
deliberate unfair competition in wanton disregard of BSHs valuable intellectual
property rights.
64. Calibers conduct has directly and proximately caused and will continue to
cause BSH substantial and irreparable injury, including customer confusion, injury to its
reputation, and diminution in value of its intellectual property, and unless restrained,

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BSH01-04:1322718_1:7-25-14 - 13 -
COMPLAINT
will continue to seriously and irreparably impair further the value of the BSH brand and
marks, for which there is no adequate remedy at law.
65. The harm to BSH and to members of the general public outweighs the
utility of Calibers business practices.
66. The unlawful, unfair, and fraudulent business practices of Caliber, as
described in this Complaint, present a continuing threat to members of the public in that
they are likely to cause confusion as to the source of Calibers products in that the
general public is likely to believe that Calibers products originate from, or are affiliated
or associated with Plaintiff, or are otherwise sponsored or endorsed by Plaintiff.
67. As a direct and proximate result of Calibers wrongful acts as alleged in
this Complaint, Caliber obtained unlawful profits to the detriment of BSH.
68. Unless restrained, Caliber will continue the acts and conduct set forth in
this cause of action, to BSHs great and irreparable injury, for which damages will not
afford adequate relief. BSH is therefore entitled to an injunction prohibiting Calibers
wrongful acts.
69. Caliber committed the wrongful acts willfully, intending to gain business
and a share of the market at the expense of BSHs profits and market share while
creating customer confusion regarding the source of goods bearing the BSH marks.
Calibers conduct justifies an award of exemplary damages.
70. Upon proof, BSH is entitled to recover its costs, including attorneys fees,
under California Code of Civil Procedure Section 1021.5.
PRAYER FOR RELIEF
For these reasons, BSH Home Appliances Corporation respectfully requests that
this Court enter judgment in its favor and grant the following relief:
A. Actual damages according to proof;
B. Profit disgorgement from Calibers sales of infringing products;
C. Injunctive relief preventing Caliber from engaging in further sales of
infringing products;

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BSH01-04:1322718_1:7-25-14 - 14 -
COMPLAINT
D. Punitive or exemplary damages, including but not limited to treble
damages as a result of Defendants willful infringement;
E. Reasonable attorneys fees and costs of suit;
F. Pre-judgment interest on all amounts claimed as permitted by law; and
G. Such other and further relief as this Court may deem just and appropriate.

Dated: J uly 25, 2014 CALL & J ENSEN
Wayne Call
Scott P. Shaw
Cardon B. Smith

By:/s/ Scott P. Shaw
Scott P. Shaw

Attorneys for Plaintiff BSH Home Appliances
Corporation

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BSH01-04:1322718_1:7-25-14 - 15 -
COMPLAINT
DEMAND FOR JURY TRIAL
BSH Home Appliances Corporation demands a trial by jury on all issues so
triable pursuant to Federal Rule of Civil Procedure 38.

Dated: J uly 25, 2014 CALL & J ENSEN
Wayne Call
Scott P. Shaw
Cardon B. Smith

By:/s/ Scott P. Shaw
Scott P. Shaw

Attorneys for Plaintiff BSH Home Appliances
Corporation


EXHIBIT A

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Case 2:14-cv-05821 Document 1-1 Filed 07/25/14 Page 1 of 34 Page ID #:16
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EXHIBIT B

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EXHIBIT C
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EXHIBIT D

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EXHIBIT E

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EXHIBIT F
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EXHIBIT G

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EXHIBIT H

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EXHIBIT I

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EXHIBIT J

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EXHIBIT K

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EXHIBIT L

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EXHIBIT M

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EXHIBIT N

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BSH v. Caliber Range - Complaint

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