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COMPLAINT

954201
ADRIAN M. PRUETZ - State Bar No. 118215
apruetz@glaserweil.com
ERICA J. VAN LOON - State Bar No. 227712
evanloon@glaserweil.com
KOLLIN J. ZIMMERMANN - State Bar No. 273092
kzimmermann@glaserweil.com
GLASER WEIL FINK
HOWARD AVCHEN & SHAPIRO LLP
10250 Constellation Boulevard, 19th Floor
Los Angeles, California 90067
Telephone: (310) 282-6250
Facsimile: (310) 785-3550

Attorneys for Plaintiffs
British Broadcasting Corporation,
BBC Worldwide, Ltd., and
DWTS Productions, LLC fka
BBC Worldwide Productions, LLC

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

WESTERN DIVISION

BRITISH BROADCASTING
CORPORATION, a foreign corporation,
BBC WORLDWIDE, LTD., a foreign
limited company, and DWTS
PRODUCTIONS, LLC fka BBC
Worldwide Productions, LLC, a
California limited liability company,

Plaintiffs,

v.

SCOTT STANDER & ASSOCIATES,
INC., a California corporation, and
SCOTT STANDER, an individual,

Defendants.







Case No.: 2:14-cv-08047
COMPLAINT FOR:
1. FEDERAL TRADEMARK
INFRINGEMENT
2. FEDERAL UNFAIR
COMPETITION
3. FEDERAL TRADEMARK
DILUTION
4. CALIFORNIA TRADEMARK
DILUTION
5. CALIFORNIA COMMON LAW
UNFAIR COMPETITION
6. INDUCING BREACH OF
CONTRACT
7. INTENTIONAL
INTERFERENCE WITH
CONTRACTUAL RELATIONS
8. INTENTIONAL
INTERFERENCE WITH
PROSPECTIVE ECONOMIC
ADVANTAGE;

JURY TRIAL DEMANDED
Case 2:14-cv-08047 Document 1 Filed 10/17/14 Page 1 of 16 Page ID #:1
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1
COMPLAINT
954201
Plaintiffs British Broadcasting Corporation (BBC), BBC Worldwide, Ltd.
(BBC Worldwide), and DWTS Productions, LLC fka BBC Worldwide Productions,
LLC (DWTS Productions) (collectively, the BBC Entities) submit the following
complaint against Defendants Scott Stander & Associates, Inc. and Scott Stander
(collectively, SS&A) as follows:
PARTIES
1. BBC is a foreign corporation, headquartered at the Broadcasting House,
Portland Place, London W1A 1AA, United Kingdom.
2. BBC Worldwide is a foreign limited company, with its principal place of
business at Media Centre, 201 Wood Lane, London W12 7TQ, United Kingdom. It is
also a wholly owned subsidiary of BBC.
3. DWTS Productions is a California limited liability company with its
principal place of business at 10351 Santa Monica, Blvd., Ste. 250, Los Angeles,
California, 90025.
4. SS&A is a suspended California corporation with its principal place of
business at 13701 Riverside Dr., Ste. 201, Sherman Oaks, California, 92423 and/or
4533 Van Nuys Blvd., Ste. 401, Sherman Oaks, California, 91403.
5. Scott Stander is a resident of the State of California, located at 13701
Riverside Dr., Ste. 201, Sherman Oaks, California, 92423 and/or 4533 Van Nuys
Blvd., Ste. 401, Sherman Oaks, California, 91403. Scott Stander owns, supervises,
and/or controls the activities and operations of Scott Stander & Associates, Inc., and
was knowingly involved in and responsible for the actions alleged herein.
JURISDICTION AND VENUE
6. This complaint arises under the trademark laws of the United States, 15
U.S.C. 1114 et seq, as well as the laws of the State of California. This Court has
original jurisdiction over this action under 15 U.S.C. 1121 and 28 U.S.C. 1331
and 1338. This Court has supplemental jurisdiction over the California claims alleged
herein under 28 U.S.C. 1367 because they are so closely related to the claims over
Case 2:14-cv-08047 Document 1 Filed 10/17/14 Page 2 of 16 Page ID #:2
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COMPLAINT
954201
which the Court has original jurisdiction that they form part of the same case and
controversy and derive from a common nucleus of operative facts.
7. Scott Stander & Associates, Inc. and Scott Stander reside in this judicial
district and are subject to personal jurisdiction in this district. A substantial portion of
the events giving rise to this action occurred in this district. Personal jurisdiction and
venue are therefore proper in this district pursuant to 28 U.S.C. 1391.
FACTUAL ALLEGATIONS
Dancing With The Stars, And The Rights and Obligations Related Thereto
8. The BBC Entities own and produce the extremely popular television
program Dancing with the Stars, (DWTS), which has been continuously aired in
the United States since 2005.
9. The DWTS show features celebrity contestants paired with professional
dancers that compete in a weekly dance contest. Each couple performs predetermined
dances and competes against the others for judges points and audience votes. The
couple receiving the lowest combined total of judges points and audience votes is
eliminated each week until only the champion dance pair remains.
10. BBC owns common law and federally registered trademark rights to the
trademark DANCING WITH THE STARS for entertainment services, including
shows, stage events, theatrical performances, concerts, and live performances
(USPTO Reg. No. 3,749,844) (the DWTS Mark). The DWTS Mark is widely
recognized by the consuming public and famous.
11. DWTS has contracts with professional dancers that are relevant to this
complaint. Dancers under contract to DWTS include, but are not limited to, Valentin
Chmerkovskiy, Emma Slater, Sharna Burgess, Peta Murgatroyd, and Jenna Johnson
(the DWTS Dancers).
12. Prior to performing on DWTS, each of the DWTS Dancers entered into a
Dancer Agreement with DWTS Productions, the pertinent terms of which are
summarized as follows:
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COMPLAINT
954201
The DWTS Dancer shall not render services or appear in any other dance
related program in any medium, or authorize the use of the DWTS Dancers
name, voice, or likeness in connection with an endorsement for any such
program.
(a) The DWTS Dancer may appear or perform on the live stage or at private
events, subject to DWTS Productions prior written approval, or (b) the
DWTS Dancer shall not render services in connection with a dance
performance in any medium, including without limitation television and live
stage.
The DWTS Dancer irrevocably grants DWTS Productions the right to
videotape, film, portray, photograph, and otherwise record the DWTS
Dancer. All such material shall be a work made for hire and shall be DWTS
Productions sole and exclusive property. The DWTS Dancer grants and
assigns to DWTS Productions all rights of any nature in and to such
material.
The DWTS Dancer shall not enter into any agreement or incur any liability
that may interfere with DWTS Productions full enjoyment of its rights
under this agreement.
Except as authorized by DWTS Productions, the DWTS Dancer will not,
and will not authorize others to, publicize, advertise, or promote the DWTS
Dancers appearance on the DWTS show.
The DWTS Dancer shall not use any of DWTS Productions or any related
companies names, logos, trade names, or trademarks, (including but not
limited to the title of the show, Dancing with the Stars), in connection
with any media appearance or any other type of appearance, or any kind of
advertising, promotion, publicity, merchandise, or other product or service.
13. These Dancer Agreements are or were in full force and effect during the
relevant times alleged in this complaint.
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COMPLAINT
954201
Ballroom With A Twist, and SS&As Infringing Conduct
14. SS&A is the producer of a live performance stage show called Ballroom
with a Twist (BWAT), which features DWTS dancers performing live dances,
including the Samba, Waltz, Foxtrot, Quickstep, and Jive. SS&As show is
performed at theaters across the nation, and tickets are promoted and sold on
numerous theater websites, as well as on TicketMaster.com.
15. SS&A has infringed, and is still infringing, the DWTS Mark by
advertising, marketing, and promoting its BWAT show using the DWTS Mark
without the consent of the BBC Entities, in a manner that is likely to cause confusion
among ordinary consumers as to the source, sponsorship, affiliation, or approval of
the BWAT show, and to dilute the value of the DWTS Mark.
16. SS&A markets and distributes promotional posters, images, and other
materials online for its BWAT show, in which the phrase Ballroom with a Twist is
written in the same color, font, and design, as the mark Dancing with the Stars.
SS&As promotional materials also display the names and likenesses of well-known
DWTS Dancers. Examples of such promotional materials include, but are not limited
to the following, which were taken from SS&As website,
http://www.scottstander.com/, and a performance theatres website,
http://www.themahaffey.com/page/Contact/31:

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5
COMPLAINT
954201
17. In addition, SS&As website refers to BWAT as the national-tour
spinoff of Dancing With the Stars. Advertisements on websites of other theaters
acting in concert with SS&A, such as the Valley Performing Arts Theatre, also
describe the BWAT show as a non-competitive spinoff of Dancing with the Stars,
feature[ing] sizzling performances by jaw-dropping DWTS celebrity pros.
(http://www.valleyperformingartscenter.org/calendar/ballroom-with-a-twist/).
18. SS&As use of the same color, font, and design as the DWTS Mark to
depict its BWAT title, its use of the DWTS Mark and the names and likenesses of
well-known DWTS Dancers, and its description of the show as a spinoff of DWTS,
are all done to suggest sponsorship, authorization, or affiliation with the DWTS show.
19. SS&A is not licensed or authorized in any way to use the DWTS Mark.
SS&As use of the DWTS Mark is likely to deceive, confuse, and mislead the
consuming public into thinking that the BWAT show is somehow sponsored,
authorized, or affiliated with the DWTS show. The likelihood of confusion, mistake,
and deception engendered by SS&As infringement is causing irreparable harm to the
goodwill symbolized by the DWTS Mark and the reputation for high quality that it
embodies.
20. SS&A has realized and continues to realize an unjustified benefit in the
form of sales and profits from its falsely implied association or affiliation with
DWTS.
21. The BBC Entities have notified SS&A of its infringing conduct, but
despite this notice, SS&As violations of the BBC Entities rights have been
continuously expanding.
22. SS&As infringement of the DWTS Mark was done willfully,
knowingly, and with the intent of causing confusion and mistake and deceiving the
public.


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6
COMPLAINT
954201
SS&As Additional Unlawful Conduct
23. The performances on BWAT were choreographed by Louis Van Amstel,
who was a DWTS dancer and choreographer on DWTS for several years, ending in
Fall 2012.
24. As a prior DWTS dancer, Mr. Van Amstel executed DWTS Productions
standard Dancer Agreement, containing the same pertinent provisions that each of the
DWTS Dancers agreed to, as described above.
25. Louis Van Amstel has worked with SS&A, whether as an employee, or
in a partnership, agency, or other business capacity, to create and produce the BWAT
show.
26. Despite knowing that each of the DWTS Dancers were under contract
with DWTS Productions, and despite knowing that the contract prohibits the DWTS
Dancers from, among other things, rendering services or appearing in any other dance
related program in any medium, or authorizing the use of the DWTS Dancers name,
voice, or likeness in connection with an endorsement for any such program, SS&A
nevertheless approached the DWTS Dancers and induced them to perform in and
promote the BWAT show, thus breaching their agreements with DWTS Productions.
27. As a result of SS&As wrongful actions, DWTS Productions has been
denied the full benefit of its contracts with each of the DWTS Dancers, including, for
example, one or more of the DWTS Dancers being unavailable to fulfill their
contractual obligation to perform in live stage performances produced by DWTS
Productions.
28. SS&As use of the names and likenesses of the DWTS Dancers in
connection with the promotion of the BWAT show is also a violation of the Dancer
Agreements, and has caused additional harm to the BBC Entities and the value of the
DWTS show.
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7
COMPLAINT
954201
29. SS&As wrongful actions were done knowingly and intentionally, with
oppression, fraud, or malice, thus warranting an award of punitive and exemplary
damages.
FIRST CLAIM FOR RELIEF
(Trademark Infringement in Violation of 15 U.S.C. 1114 et seq.)
30. BBC realleges and incorporates by reference each and every allegation
contained in the above paragraphs as if fully set forth herein.
31. BBC owns the registered trademark DANCING WITH THE STARS, for
entertainment services, including shows, stage events, theatrical performances,
concerts, and live performances (USPTO Reg. No. 3,749,844) (the "DWTS Mark").
32. SS&A has infringed, and is still infringing, the DWTS Mark by
advertising, marketing, and promoting its BWAT show using the DWTS Mark
without the consent of the BBC Entities, in a manner that is likely to cause confusion
among ordinary consumers as to the source, sponsorship, affiliation, or approval of
the BWAT show.
33. SS&As actions have caused and, unless enjoined by this Court, will
continue to cause a likelihood of confusion and deception of members of the public,
and additional injury to the goodwill and reputation symbolized by the DWTS Mark,
for which there is no adequate remedy at law.
34. SS&As actions demonstrate an intentional, willful, and malicious intent
to trade on the goodwill associated with the DWTS Mark.
35. SS&As actions have caused and are likely to continue causing
substantial injury to the public and to BBC, and BBC is entitled to injunctive relief
and to recover SS&As profits, actual damages, enhanced profits and damages, costs
and reasonable attorneys' fees under 15 U.S.C. 1114, 1116, and 1117.
SECOND CLAIM FOR RELIEF
(Federal Unfair Competition and False Designation of Origin in
Violation of 15 U.S.C. 1125)
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COMPLAINT
954201
36. BBC realleges and incorporates by reference each and every allegation
contained in the above paragraphs as if fully set forth herein.
37. BBC owns the common law trademark rights to the DWTS mark, as used
to identify, market, advertise, and promote its highly popular television program,
which has aired in the United States continuously since 2005.
38. SS&A has infringed, and is still infringing, the DWTS Mark by
advertising, marketing, and promoting its BWAT show using the DWTS Mark
without the consent of the BBC Entities, in a manner that is likely to cause confusion
among ordinary consumers as to the source, sponsorship, affiliation, or approval of
the BWAT show.
39. SS&As actions have caused and, unless enjoined by this Court, will
continue to cause a likelihood of confusion and deception of members of the public,
and additional injury to the goodwill and reputation symbolized by the DWTS Mark,
for which there is no adequate remedy at law.
40. SS&As actions demonstrate an intentional, willful, and malicious intent
to trade on the goodwill associated with the DWTS Mark.
41. SS&As actions have caused and are likely to continue causing
substantial injury to the public and to BBC, and BBC is entitled to injunctive relief
and to recover SS&As profits, actual damages, enhanced profits and damages, costs
and reasonable attorneys' fees under 15 U.S.C. 1125(a), 1116, and 1117.
THIRD CLAIM FOR RELIEF
(Federal Trademark Dilution in Violation of 15 U.S.C. 1125(c))
42. BBC realleges and incorporates by reference each and every allegation
contained in the above paragraphs as if fully set forth herein.
43. The DWTS Mark is famous within the meaning of the Lanham Act.
44. SS&A's wrongful actions, as alleged above, have diluted and will likely
continue to dilute the unique and distinctive nature of the DWTS Mark, and have
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954201
harmed the reputation and goodwill of the DWTS Mark. Such actions began after the
DWTS Mark had already become famous.
45. SS&A acted knowingly, deliberately, and willfully with the intent to
trade on the recognition, harm the reputation, and dilute the value of the DWTS Mark.
46. BBC has no adequate remedy at law to compensate for the damages that
SS&A has caused and will continue to be caused, unless enjoined by this Court.
47. SS&As actions have caused and are likely to continue causing
substantial injury to the public and to BBC, and BBC is entitled to injunctive relief
and to recover SS&As profits, actual damages, enhanced profits and damages, costs
and reasonable attorneys' fees under 15 U.S.C. 1125(c), 1116, and 1117.
FOURTH CLAIM FOR RELIEF
(Trademark Dilution in Violation of California Law)
48. BBC realleges and incorporates by reference each and every allegation
contained in the above paragraphs as if fully set forth herein.
49. The DWTS Mark is distinctive, strong, and widely known throughout the
State of California and nationwide by virtue of the BBC Entities extensive use of the
DWTS Mark in advertising and widespread publicity of the DWTS show.
50. SS&A's wrongful actions, as alleged above, have diluted and will likely
continue to dilute the unique and distinctive nature of the DWTS Mark, and have
harmed the reputation and goodwill of the DWTS Mark. Such actions began after the
DWTS Mark had already become famous.
51. SS&A acted knowingly, deliberately, and willfully with the intent to
trade on the recognition, harm the reputation, and dilute the value of the DWTS Mark.
SS&As actions were done with oppression, fraud, or malice, thus warranting an
award of punitive damages sufficient to punish and make an example of SS&A.
52. BBC has no adequate remedy at law to compensate for the damages that
SS&A has caused and will continue to be caused, unless enjoined by this Court.
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954201
53. BBC is entitled to injunctive relief, and recovery of up to three times
S&As profits from, and up to three times all damages suffered by reason of, SS&As
wrongful use of the DWTS Mark.
FIFTH CLAIM FOR RELIEF
(California Common Law Unfair Competition)
54. The BBC Entities reallege and incorporate by reference each and every
allegation contained in the above paragraphs as if fully set forth herein.
55. SS&A intentionally incorporated distinctive and protected elements from
the DWTS Mark into its advertising and promotions of the BWAT show, utilized the
name and likenesses of well-known DWTS Dancers, and described the BWAT show
as a "spinoff" of DWTS, to purposefully trade off the goodwill and reputation of
DWTS and to confuse and deceive consumers by creating the false and misleading
impression that SS&A's show is endorsed, sponsored, approved, licensed, or affiliated
with the DWTS show.
56. SS&As conduct infringes the DWTS Mark and constitutes common law
unfair competition, which has damaged and will continue to irreparably damage the
goodwill and reputation associated with the DWTS Mark, unless enjoined by this
Court.
57. The BBC Entities have suffered and continue to suffer direct and actual
damages as a result of SS&As wrongful and infringing conduct, including but not
limited to lost sales and business opportunities, and damage to the reputation and
goodwill of the DWTS Mark. The BBC Entities are entitled to recover their actual
damages, as well as disgorgement of SS&As profits generated from the promotion,
distribution, and sale of tickets to its BWAT shows.
58. Because SS&As conduct alleged herein was intentional, oppressive,
malicious, fraudulent, and in willful disregard of the BBC Entities rights, the BBC
Entities are also entitled to recover punitive and exemplary damages.

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954201
SIXTH CLAIM FOR RELIEF
(Inducing Breach of Contract)
59. The BBC Entities reallege and incorporate by reference each and every
allegation contained in the above paragraphs as if fully set forth herein.
60. DWTS Productions and each of the DWTS Dancers entered into a
Dancer Agreement, pertinent terms of which are summarized in paragraph 12 above.
61. These Dancer Agreements are or were in full force and effect during the
relevant times alleged in this complaint.
62. SS&A knew of these Dancer Agreements, but nevertheless intended to
cause, and did cause, the DWTS Dancers to breach their agreements by, among other
things, performing in the BWAT show, and allowing the use of their name and
likeness in connection with the promotion of the BWAT show.
63. As a direct and proximate result of SS&A's wrongful actions, DWTS
Productions has been denied the full benefit of its contract with each of the DWTS
Dancers, and the exclusive nature and value of the DWTS show has been diminished,
thus causing harm to the BBC Entities in an amount to be proven at trial.
64. SS&A was also unjustly enriched by the profits received from the
promotion and performances of the DWTS Dancers in the BWAT show, which would
not have occurred but for SS&As wrongful actions.
65. Because SS&A's conduct alleged herein was intentional, oppressive,
malicious, and fraudulent, the BBC Entities are also entitled to recover punitive and
exemplary damages.
SEVENTH CLAIM FOR RELIEF
(Intentional Interference with Contractual Relations)
66. The BBC Entities reallege and incorporate by reference each and every
allegation contained in the above paragraphs as if fully set forth herein.
67. DWTS Productions and each of the DWTS Dancers entered into a
Dancer Agreement, pertinent terms of which are summarized in paragraph 12 above.
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954201
68. These Dancer Agreements are or were in full force and effect during the
relevant times alleged in this complaint.
69. SS&A knew of these Dancer Agreements, but nevertheless intended to
disrupt the DWTS Dancers performance of their contractual obligations, and
disrupted or made such performance more difficult by, among other things, paying
them to perform in the BWAT show and allow the use of their name and likeness in
connection with the promotion of the BWAT show.
70. As a direct and proximate result of SS&A's wrongful actions, DWTS
Productions has been denied the full benefit of its contractual terms with each of the
DWTS Dancers, and the exclusive nature of the DWTS show has been reduced, thus
causing harm to the BBC Entities in an amount to be proven at trial.
71. SS&A was also unjustly enriched by the profits received from the
promotion and performances of the DWTS Dancers in the BWAT show, which would
not have occurred but for SS&A's wrongful actions.
72. Because SS&A's conduct alleged herein was intentional, oppressive,
malicious, and fraudulent, the BBC Entities are also entitled to recover punitive and
exemplary damages.
EIGHTH CLAIM FOR RELIEF
(Intentional Interference with Prospective Economic Relations)
73. The BBC Entities reallege and incorporate by reference each and every
allegation contained in the above paragraphs as if fully set forth herein.
74. The BBC Entities and each of the DWTS Dancers were in an economic
relationship that probably would have resulted in an economic benefit, such as by
performing in additional shows, including live performance shows, that were to be
produced by the BBC Entities.
75. SS&A knew of, and intended to disrupt, the BBC Entities economic
relationship with the DWTS Dancers by, among other things, infringing the DWTS
Mark and unfairly competing with the BBC Entities by promoting the BWAT show in
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954201
a manner that confused consumers and implied it was sponsored, authorized, or
otherwise affiliated with the DWTS show.
76. As a direct and proximate result of SS&As wrongful conduct, the BBC
Entities relationship with the DWTS Dancers was disrupted, and the BBC Entities
suffered damages in amount to be proved at trial.
77. SS&A was also unjustly enriched by the profits received from the
promotion and performances of the DWTS Dancers in the BWAT show, which would
not have occurred but for SS&A's wrongful actions.
78. Because SS&A's conduct alleged herein was intentional, oppressive,
malicious, and fraudulent, the BBC Entities are also entitled to recover punitive and
exemplary damages.
PRAYER FOR RELIEF
WHEREFORE, the BBC Entities respectfully request:
1. That the Court enjoin SS&A, its successors, assigns, subsidiaries,
transferees, officers, directors, agents, employees, and all those acting in concert with
it, as follows:
a. From marketing, promoting, or advertising the BWAT show in
any manner that implies it is authorized, sponsored, licensed, or affiliated with
the DWTS show, including, without limitation, using the DWTS Mark or
depicting the title of the BWAT show in the same or similar color, font, or
design as the DWTS Mark, or describing the BWAT show as a spinoff of the
DWTS show;
b. From inducing the breach of, or otherwise interfering with, the
contractual relationships or prospective economic relationships between the
BBC Entities and any of the DWTS dancers that appear on the DWTS show;
2. That the BBC Entities be awarded compensatory damages under
California law in an amount adequate to compensate the BBC Entities for the harm
caused by SS&A, and to prevent the unjust enrichment of SS&A;
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COMPLAINT
954201
3. That the BBC Entities be awarded punitive damages under California
law in such amount that is deemed proper to punish and deter SS&A and others from
similar conduct;
4. That the Court find SS&As acts of trademark infringement, unfair
competition and dilution under the Lanham Act to be knowing and willful, and an
exceptional case within the meaning of 15 U.S.C. 1117;
5. That the BBC Entities be awarded SS&As profits and any damages
suffered by the BBC Entities as a result of SS&As unlawful and infringing and
diluting conduct, enhanced up to three times the actual amount, under Federal law;
and
6. That the BBC Entities be awarded their reasonable costs and attorneys
fees, and such other and further relief as the Court deems just and proper.

DATED: October 17, 2014
GLASER WEIL FINK
HOWARD AVCHEN & SHAPIRO LLP


By: /s/ Adrian M. Pruetz
ADRIAN M. PRUETZ
ERICA J. VAN LOON
KOLLIN J. ZIMMERMANN
Attorneys for Plaintiffs
British Broadcasting Corporation,
BBC Worldwide, Ltd., and
DWTS Productions, LLC fka
BBC Worldwide Productions, LLC



Case 2:14-cv-08047 Document 1 Filed 10/17/14 Page 15 of 16 Page ID #:15
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COMPLAINT
954201


DEMAND FOR JURY TRIAL
The BBC Entities respectfully request a jury trial on all issues triable by a jury.

DATED: October 17, 2014
GLASER WEIL FINK
HOWARD AVCHEN & SHAPIRO LLP


By: /s/ Adrian M. Pruetz
ADRIAN M. PRUETZ
ERICA J. VAN LOON
KOLLIN J. ZIMMERMANN
Attorneys for Plaintiffs
British Broadcasting Corporation,
BBC Worldwide, Ltd., and
DWTS Productions, LLC fka
BBC Worldwide Productions, LLC









Case 2:14-cv-08047 Document 1 Filed 10/17/14 Page 16 of 16 Page ID #:16