The Gillette Company v. SHNOOP - COM Corp. - Complaint

Case 1:17-cv-02236 Document 1 Filed 04/13/17 Page 1 of 17 PageID #: 1
UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF NEW YORK
THE GILLETTE COMPANY LLC )

One Gillette Park )
Boston, MA 02127, )
)
Plaintiff, )
v. )
)
)
SHNOOP.COM CORP. ) CIVIL ACTION NO. 17-CV-2236
1408 60th Street )
Brooklyn, NY 11219 )
)
and )
)
MENACHEM GROSSMAN )
1408 60th Street )
Brooklyn, NY 11219, )
)
Defendants. )
COMPLAINT AND JURY DEMAND
PRELIMINARY STATEMENT
This is an action by plaintiff The Gillette Company LLC (hereinafter Gillette), by and
through counsel, for claims against defendant SHNOOP.COM Corp. (hereinafter SHNOOP)
and defendant Menachem Grossman (hereinafter Mr. Grossman) (collectively, the
Defendants) seeking injunctive relief and damages from Defendants for their willful
infringement of Gillettes trademark and design patent rights, for conversion, and for unjust
enrichment.
PARTIES
1. The Gillette Company LLC is a limited liability company licensed in the state of
Delaware, with its principal place of business located at One Gillette Park, Boston,
Massachusetts 02127 and is a wholly-owned subsidiary of The Procter & Gamble Company
(hereinafter P&G), a corporation licensed in the state of Ohio. Gillettes Corporate Disclosure
Statement is filed concurrently with this Complaint, as required by Fed. R. Civ. P. 7.1.
2. SHNOOP.COM Corp. is a corporation licensed in the state of New York, with its
principal place of business located at 1408 60th Street, Brooklyn, New York 11219.
3. Upon information and belief, SHNOOP.COM was initially incorporated in the
state of New York on or around October 26, 2007.
4. Upon information and belief, Menachem Grossman is a resident of the state of
New York, with a last known address at 1408 60th Street, Brooklyn, New York 11219.
5. Upon information and belief, Menachem Grossman is the Chief Executive Officer
and Principal Executive Officer of SHNOOP.
JURISDICTION AND VENUE
6. This Court has original jurisdiction over the trademark and patent claims in this
matter pursuant to 28 U.S.C. 1331 and 28 U.S.C. 1338(a), as the claims arise under the patent
and trademark laws of the United States including, but not limited to, Patent Act, 35 U.S.C.
271 and Lanham Act, 15 U.S.C. 1114 and 15 U.S.C. 1125.
7. This Court has supplemental jurisdiction over the state law claims for conversion
and unjust enrichment pursuant to 28 U.S.C. 1367(a), as these claims are so related to the
federal claims within the Courts original jurisdiction that such state law claims form part of the
same case or controversy, under Article III of the United States Constitution.
8. This Court further has original jurisdiction over all of the claims asserted in this
matter pursuant to 28 U.S.C. 1332, as there is complete diversity of citizenship of the parties
and the amount in question exceeds $75,000.00.
2
9. This Court has personal jurisdiction over Defendants under Fed. R. Civ. P. 4 and
under NY C.P.L.R. 301-302 because Defendants are domiciled or reside in the state of New
York, and because, upon information and belief, Defendants transact business in the state of New
York, have committed the acts alleged in this Complaint in New York and/or have regularly
solicited business or derived substantial revenue from the stolen and/or infringing goods
promoted, advertised, sold, used, and/or consumed in the state of New York and specifically
have sold such razor blades/cartridges and dispensers/containers for razor cartridges that are
stolen and/or infringe Gillettes intellectual property in the state of New York and have thus
purposefully availed themselves of the privilege of doing business in the state of New York.
10. Venue is proper pursuant to 28 U.S.C. 1391.
FACTUAL BACKGROUND
A. Overview of Plaintiff Gillette
11. Gillette is in the business of, among other things, developing, designing,
advertising, and marketing personal care/grooming products for men and women. These
personal care/grooming products include a variety of shaving products for men. Gillette, as part
of the Procter & Gamble family, is the global market leader in razors, shaving, and razor blade
and shaving products.
12. For men, among other things, Gillette offers proprietary razors, razor blade
cartridges, shaving blade units, razor blade dispensers, and refill razor blades under the Fusion
brand (including Fusion and Fusion ProGlideTM brands).
13. Gillette has expended a great deal of time and money seeking federal protection
of its intellectual property including, but not limited to, its trademarks and its unique,
nonfunctional, and distinctive product designs.
3
14. Gillette is the owner of several federal registrations relating to its distinctive and
famous family of Gillette trademarks for a variety of goods.
15. Gillette is the owner, by assignment, of the entire right, title, and interest in and to
U.S. Registration No. 0,767,865 for GILLETTE, registered April 7, 1964, for safety razors and
safety razor blades in International Class 8, US Class 23 (hereinafter the GILLETTE
MARK). A true copy of the registration is attached hereto as Exhibit A. This registration is
valid, subsisting, and incontestable.
U.S. Registration No. 3,099,224 for FUSION, registered May 30, 2006, for razors and razor
blades; dispensers; cassettes; holders and cartridges; all containing blades; and structural parts
thereof in Class 8 (hereinafter the FUSION MARK). A true copy of the registration is
attached hereto as Exhibit B. This registration is valid, subsisting, and incontestable.
17. Gillette has engaged in open, notorious, and extensive widespread promotion and
advertising of its GILLETTE MARK and FUSION MARK for a variety of goods including
razors, razor blades, razor cartridges, and razor dispensers.
18. Gillette has expended substantial amounts of time, money, and effort in
advertising and promoting its GILLETTE MARK and FUSION MARK over many years, and in
establishing and preserving the goodwill associated therewith, and the goodwill associated with
each of the GILLETTE MARK and FUSION MARK is a valuable asset to Gillette.
U.S. Design Patent D531,518 S (518 Patent), issued on November 7, 2006, claiming the
ornamental design for a dispenser for razor cartridges. A true copy of the 518 Patent is
attached hereto as Exhibit C.
4
20. Gillette is the owner, by virtue of assignment, of the entire right, title, and interest
in and to U.S. Design Patent D604,904 S (904 Patent), issued on November 24, 2009,
claiming the ornamental design for a razor cartridge. A true copy of the 904 Patent is
attached hereto as Exhibit D.
21. The Fusion line of dispensers for razor cartridges are sold housed in a dispenser
that features a unique, distinctive, non-functional design that embodies the design of the 518
Patent.
22. The Fusion line of razor cartridges feature a unique, distinctive, non-functional
design that embodies the design of the 904 Patent.
23. Gillette has established tremendous goodwill and proprietary design rights in the
design of the Fusion line of razor cartridges and dispensers for razor cartridges.
24. Gillette has established exclusive manufacturing and distribution networks for
important and legitimate business reasons: protecting the validity of its intellectual property,
including its trademarks and design patent rights, maintaining assurance of quality control, and
avoiding product liability claims.
25. Gillette marks its razor blades/cartridges with lot numbers that can be used to
identify the manufacturing site and date at which the product was manufactured.
26. Gillette ships its razor blades, housed in dispensers, but not yet packaged or
labeled for retail sale, from warehouses to another facility for packaging and labeling.
27. The unpackaged products are shipped on pallets in green plastic trays.
28. Each green plastic tray contains 90 dispensers, each with four razor cartridges;
each pallet contains 88 trays, for a total of 7,920 dispensers per pallet.
29. These green plastic trays are only used to ship unpackaged product for shipment
5
to Gillette packaging facilities and not to retailers; the trays never contain product labeled and
are not packaged for retail sale.
30. On or around November 30, 2016, seven such pallets of Gillette Fusion ProGlide
razor blades were sealed and loaded onto a trailer originating at Gillettes Boston, Massachusetts
manufacturing plant, for shipment to Gillettes Milenio plant in Irapuato, Guanajuato, Mexico.
31. The shipment was intended to cross the border into Mexico at Laredo, Texas.
32. These pallets contained Gillette Fusion ProGlide razor blades with date codes
indicating a November 20, 2016 production date.
33. On or around Friday, December 2, 2016, the trailer loaded with the pallets
containing Gillette Fusion ProGlide razor blades with date codes indicating a November 20,
2017 production date was picked up in Boston by the contracted shipping company.
34. On or around December 5, 2016, the trailer arrived in Laredo, Texas and was
opened for inspection there.
35. Upon inspection in Laredo, Texas, three pallets of Gillette Fusion ProGlide Razor
blades, in green plastic trays, were missing from the trailer and presumed stolen.
B. Overview of Defendant SHNOOP.COM Corp.s Sale of Gillette Fusion ProGlide

Razor Blades on Websites Shnoop.com and Pennywise.biz.
36. Upon information and belief, SHNOOP owns and operates the websites
shnoop.com, schnoop.com (which redirects to shnoop.com), and pennywise.biz.
37. Upon information and belief, SHNOOP offered for sale, and sold, Gillette Fusion
ProGlide razor blades through its shnoop.com website. Attached as Exhibit E is a screen shot of a
listing of Gillette Fusion ProGlide razor blades offered for sale on shnoop.com.
38. Upon information and belief, SHNOOP offered the Gillette Fusion ProGlide razor
blades for sale on its shnoop.com website at a substantial discount from the typical retail price
6
for the same product.
39. The shnoop.com website listing for the Gillette Fusion ProGlide razor blades
includes photos of the product, without packaging or labeling for retail sale, stacked in green
plastic trays.
40. In January of 2017, Gillette arranged for a test purchase of the Gillette Fusion
ProGlide razor blades from shnoop.com.
41. The test purchase arrived without packaging or labeling for retail sale.
42. The return address on the package of the test purchase was listed as 1408 60th
Street, Brooklyn, New York 11219.
43. Upon inspection of the purchased product, Gillette determined that the date codes
on the razor blades indicated a November 20, 2016 production date.
44. Upon information and belief, SHNOOP offered for sale, and sold, Gillette Fusion
ProGlide razor blades through its pennywise.biz website. Attached as Exhibit F is a screen shot
of a listing of Gillette Fusion ProGlide razor blades offered for sale on pennywise.biz.
45. Upon information and belief, SHNOOP offered the Gillette Fusion ProGlide razor
blades for sale on its pennywise.biz website at a substantial discount from the typical retail price
for the same product.
46. The pennywise.biz website listing for the Gillette Fusion ProGlide razor blades
includes photos of the product, without packaging or labeling for retail sale, stacked in green
plastic trays.
ProGlide razor blades from pennywise.biz.
7
51. Upon information and belief, the Gillette Fusion ProGlide razor blades sold by
SHNOOP through the shnoop.com website and pennywise.biz website are the razor blades that
went missing from Gillettes shipment and were presumed stolen.
C. Overview of Defendant SHNOOP.COM Corp. and/or Defendant Menachem

Grossmans Sale of Gillette Fusion ProGlide Razor Blades on ebay.com.
52. Upon information and belief, an entity using the username shnoopcom, and
featuring a photo using the same logo as SHNOOP uses on its shnoop.com website, offers for
sale and sells a variety of products on the website ebay.com.
53. Upon information and belief, this entity has been using the username
shnoopcom to make such sales and offers for sale on ebay.com since September 8, 2006.
Attached as Exhibit G is a screen shot from ebay.com indicating such.
54. Upon information and belief, SHNOOP.COM Corporation was not registered as a
corporate entity until over eleven months later, on or around October 26, 2007.
55. Upon information and belief, Defendant Menachem Grossman created the
username schnoopcom in his individual capacity for use on ebay.com prior to the
incorporation of SHNOOP.COM Corp.
56. Upon information and belief, Mr. Grossman and/or SHNOOP offered for sale,
and sold, Gillette Fusion ProGlide razor blades through the ebay.com website under the
username shnoopcom. Attached as Exhibit H is a screen shot of a listing of Gillette Fusion
ProGlide razor blades offered for sale on ebay.com under the username shnoopcom.
8
57. Upon information and belief, Mr. Grossman and/or SHNOOP offered the Gillette
Fusion ProGlide razor blades for sale through the ebay.com website under the username
shnoopcom at a substantial discount from the typical retail price for the same product.
58. The username shnoopcoms ebay.com website listing for the Gillette Fusion
ProGlide razor blades includes photos of the product, without packaging or labeling for retail
sale, stacked in green plastic trays.
ProGlide razor blades from ebay.com.
63. Upon information and belief, the Gillette Fusion ProGlide razor blades sold by
Mr. Grossman and/or SHNOOP through the shnoopcom username on ebay.com are the razor
blades that went missing from Gillettes shipment and were presumed stolen.
D. GILLETTES COMMUNICATION WITH DEFENDANTS
64. On January 20, 2017, Gillette, through counsel, sent a letter via Federal Express
and electronic mail to Mr. Menachem Grossman at SHNOOP, at the 1408 60th Street, Brooklyn,
New York 11219 address notifying him that the Gillette Fusion ProGlide razor cartridges sold
and distributed by Defendants through ebay.com, shnoop.com, and pennywise.boz were stolen
goods and demanding, inter alia, that such Defendants cease the sale of such stolen goods. A
copy of the letter is attached hereto as Exhibit I.
9
65. Upon information and belief, Defendants knowingly obtained these stolen goods
through third parties with the intent to resell such products without the consent of, and without
paying value to, Gillette.
COUNT I
(Trademark Infringement of Registered Trademark GILLETTE)
66. Gillette restates and realleges paragraphs 1-65.
67. Gillette is the owner of U.S. Registration No. 767,865, for the GILLETTE
MARK, which is valid, enforceable, and uncontestable.
68. The Defendants have used the GILLETTE MARK in connection with the
unauthorized sale, offering for sale, distribution or advertising of unauthorized goods in interstate
commerce in such a way that is likely to cause confusion, mistake, or to deceive consumers in
violation of 15 U.S.C. 1114, including, but not limited to, the unauthorized sale of such
unauthorized goods on shnoop.com, pennywise.biz, and ebay.com.
69. The unauthorized goods sold by the Defendants bearing the GILLETTE MARK
are materially different from genuine and authorized Gillette goods in that these products were
not contained in retail packaging and did not contain Gillettes information on warranties,
manner of use and other information relevant to these goods.
70. Because Defendants sold and offered for sale unauthorized goods bearing the
GILLETTE MARK that are materially different from genuine and authorized Gillette goods,
Defendants actions have impaired Gillettes ability to control the quality and goodwill
associated with genuine and authorized Gillette goods bearing the GILLETTE MARK.
71. Each such use of the GILLETTE MARK by Defendants was without
authorization, approval, or license by Gillette.
72. As a direct and proximate result of Defendants actions, Gillette is entitled to
10
recover Defendants illicit profits from the infringement, Gillettes actual damages, Gillettes
costs and its reasonable attorneys fees, pursuant to 15 U.S.C. 1117(a).
73. Gillette has no adequate remedy at law and is therefore entitled to injunctive relief
pursuant to 15 U.S.C. 1116, against further infringement by Defendants.
74. Gillette has suffered damages in an amount to be proven at trial from the
Defendants illegal and unauthorized acts.
COUNT II
(Trademark Infringement of Registered Trademark FUSION)
76. Gillette is the owner of U.S. Registration No. 3,099,224, for the FUSION MARK,
which is valid, enforceable, and uncontestable.
77. The Defendants have used the FUSION MARK in connection with the
unauthorized sale, offering for sale, distribution, or advertising of unauthorized goods in
interstate commerce in such a way that is likely to cause confusion, mistake, or to deceive
consumers in violation of 15 U.S.C. 1114, including, but not limited to, the unauthorized sale
of such unauthorized goods on shnoop.com, pennywise.biz, and ebay.com.
78. The unauthorized goods sold by the Defendants bearing the FUSION MARK are
materially different from genuine and authorized Gillette goods in that these products were not
contained in retail packaging and did not contain Gillettes information on warranties, manner of
use and other information relevant to these goods.
79. Because Defendants sold and offered for sale unauthorized goods bearing the
FUSION MARK that are materially different from genuine and authorized Gillette goods,
Defendants actions have impaired Gillettes ability to control the quality and goodwill
associated with genuine and authorized Gillette goods bearing the FUSION MARK.
11
80. Each such use of the FUSION MARK by the Defendants was without
authorization, approval, or license by Gillette.
81. As a direct and proximate result of Defendants actions, Gillette is entitled to
recover Defendants illicit profits from the infringement, Gillettes actual damages, Gillettes
costs and its reasonable attorneys fees, pursuant to 15 U.S.C. 1117(a).
82. Gillette has no adequate remedy at law and is therefore entitled to injunctive relief
pursuant to 15 U.S.C. 1116, against further infringement by Defendants.
83. Gillette has suffered damages from the Defendants illegal and unauthorized acts,
the actual amount to be proven at trial, plus pre and post judgment interest and costs.
COUNT III
(Patent Infringement of 518 Patent)
85. Gillette is the owner of the 518 Patent, which is valid and enforceable.
86. Gillette has not authorized any Defendants to sell or offer for sale dispensers for
razor cartridges that apply the design of the 518 Patent or colorable imitation thereof.
87. Upon information and belief, all Defendants have infringed, and continue to
infringe, the 518 Patent by selling, and/or offering for sale unauthorized dispensers for razor
cartridges that apply the design of the 518 Patent or colorable imitation thereof, in violation of
35 U.S.C. 271(a), including, but not limited to, the Defendants unauthorized sale of such
unauthorized goods on shnoop.com, pennywise.biz, and ebay.com.
88. Defendants deliberate and willful actions in infringing the design of Gillettes
518 Patent, has caused and will continue to cause irreparable harm to Gillette unless
preliminarily and permanently enjoined pursuant to 35 U.S.C. 283.
89. Defendants have also profited, and Gillette has suffered pecuniary damage, in
12
amounts to be determined at trial as a result of Defendants willful infringement of Gillettes
518 Patent pursuant to 35 U.S.C. 284 and 289.
COUNT IV
(Patent Infringement of 904 Patent)
92. Gillette is the owner of the 904 Patent, which is valid and enforceable.
93. Gillette has not authorized Defendants to sell or offer for sale razor blade
cartridges that apply the design of the 904 Patent or colorable imitation thereof.
94. Upon information and belief, Defendants have infringed, and continue to infringe,
the 904 Patent by selling and/or offering for sale unauthorized razor blade cartridges that apply
the design of the 904 Patent or colorable imitation thereof, in violation of 35 U.S.C. 271(a),
including, but not limited to, the unauthorized sale of such unauthorized goods by the Defendants
the on shnoop.com, pennywise.biz, and ebay.com.
95. Defendants deliberate and willful actions in infringing the design of Gillettes
904 Patent, has caused and will continue to cause irreparable harm to Gillette unless
preliminarily and permanently enjoined pursuant to 35 U.S.C. 283.
96. Defendants have also profited, and Gillette has suffered pecuniary damage, in
amounts to be determined at trial, as a result of Defendants willful infringement of Gillettes
904 Patent pursuant to 35 U.S.C. 284 and 289.
13
COUNT V
(Conversion)
99. Upon information and belief, Defendants wrongfully converted, for their own
uses, at least 63,360 individual Gillette Fusion ProGlide razor cartridges (contained in 15,840
four-packs on 2 pallets) the amount and value of which is to be proven at trial.
100. Upon information and belief, Defendants have sold some of the stolen Gillette
Fusion ProGlide razor cartridges and remain in possession of the balance of the remaining stolen
inventory.
101. Upon information and belief, these Gillette Fusion ProGlide razor cartridges were
stolen from Gillette by unknown John Doe(s) and/or Jane Doe(s).
102. Prior to such theft, these Gillette Fusion ProGlide razor cartridges were the
property of Gillette, and Gillette was entitled to possession of such razor cartridges.
103. Defendants obtained possession of such Gillette Fusion ProGlide razor cartridges
without the knowledge, authorization, or consent of Gillette.
104. Defendants sold such Gillette Fusion ProGlide razor cartridges through various
means, including, but not limited to, sale on the websites shnoop.com, pennywise.biz, and
ebay.com.
105. Defendants made such sales without Gillettes knowledge or consent.
106. Defendants knew or should have known such products were stolen, based on
numerous factors, including that the products were sold in a large volume at a low cost, were not
obtained directly from Gillette or an authorized source, and were sold in pallets without retail
packaging.
107. Gillette has not received any benefit, monetary or otherwise, from the sale of
14
these stolen goods.
108. As a direct and proximate result of Defendants wrongful conversion, Gillette has
suffered damages from the Defendants illegal and unauthorized acts the actual amount to be
proven at trial, plus pre and post judgment interest and costs.
COUNT VI
(Unjust Enrichment)
110. Defendants wrongfully received a benefit by way of their unauthorized receipt,
and subsequent sale, of stolen Gillette Fusion ProGlide razor cartridges.
111. Gillette has not received any compensation for the wrongful benefit received by
Defendants from Defendants receipt and sale of such stolen goods.
112. If Defendants are not now required to pay Gillette in full for the value of such
stolen goods, Defendants will be unjustly enriched from their illegal and unauthorized acts, the
actual amount to be proven at trial, plus pre and post judgment interest and costs.
WHEREFORE, Gillette prays for judgment against Defendants as follows:
(a) In favor of Gillette and against the Defendants on all claims;
(b) Preliminarily and permanently enjoin and restrain each such Defendant against
continued infringement of the GILLETTE MARK and the FUSION MARK (15 U.S.C. 1116);
(c) Preliminarily and permanently enjoin and restrain each such Defendant against
continued infringement of the 518 Patent and/or the 904 Patent (35 U.S.C. 283);
(d) Order an accounting for Gillettes damages and/or for Defendants profits derived
from and/or related to Defendants infringement of the GILLETTE MARK and the FUSION
MARK (15 U.S.C. 1117) and Defendants infringement of the 518 Patent and/or the 904
15
Patent (35 U.S.C. 284 and 289);
(e) Order an accounting for Gillettes damages related to the value of the converted
property at the time of the conversion;
(f) Order an accounting for Gillettes damages as a measure of Defendants profits
derived from Defendants unjust enrichment;
(g) Order an assessment of interest and costs against Defendants (35 U.S.C. 283; 15
U.S.C. 1117);
(h) Find this to be an exceptional case and to award reasonable attorneys fees to
Gillette (35 U.S.C. 285; 15 U.S.C. 1117);
(i) Find that Defendants infringement was intentional and thus treble damages and
attorneys fees are appropriate (15 U.S.C. 1117(b)); and
(j) Award Gillette such other relief as the Court may deem just and proper.
16
JURY DEMAND
Pursuant to Fed. R. Civ. P. 38(b), Gillette demands a trial by jury for all claims so triable.
Respectfully submitted,
THE GILLETTE COMPANY,
Dated: April 13, 2017 By its attorneys,
Govinda M. Davis, EDNY Bar Code GD0398

govinda.davis@dinsmore.com
Of counsel:
Karen Kreider Gaunt, Bar #0068418
Pro hac vice forthcoming
karen.gaunt@dinsmore.com
Tammy L. Imhoff, Bar #0076720
Pro hac vice forthcoming
tammy.imhoff@dinsmore.com
DINSMORE & SHOHL LLP
255 East Fifth Street
Cincinnati, OH 45202
Tel.: (513) 977-8503
Fax: (513) 977-8141
Counsel for Plaintiff The Gillette Company LLC
17
Case 1:17-cv-02236 Document 1-1 Filed 04/13/17 Page 1 of 32 PageID #: 18
EXHIBIT A
EXHIBIT B
EXHIBIT C
EXHIBIT D
III III 0 II0 IN 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 IN
(12) United States Design Patent (10) Patent No.: US D604,904 S
Watson (45) Date of Patent: ** Nov. 24, 2009
(54) RAZOR CARTRIDGE 2003/0217470 Al * 11/2003 Follo et al ...................... 30/81

2004/0231161 Al* 11/2004 Coffin et al . ................... 30/50
(75) Inventor: Brian Patrick Watson, Albion, RI (US)
* cited by examiner
(73) Assignee: The Gillette Company, Boston, MA
Primary Examiner Jennifer Rivard
(US)
(74) Attorney, Agent, or Firm Kevin C. Johnson; Steven W.
(**) Term: 14 Years Miller
(21) Appl. No.: 29/325,197 (57) CLAIM
(22) Filed: Sep. 26, 2008 The ornamental design for a razor cartridge, as shown and
described.
(51) LOC (9) Cl . 28-03
..................................................
(52) U.S. Cl . D28/47

.......................................................
DESCRIPTION
(58) Field of Classification Search ..................... 30/32, FIG. 1 is a perspective view as seen from the bottom, rear and
30/34.05, 34.1, 34.2, 41-41.8, 44-45, 47-51, right side of a razor cartridge showing my new design;
30/53-58, 526-533, 537, 77-83, 538; D28/44.1 -48 FIG. 2 is a bottom plan view thereof;
See application file for complete search history.
FIG. 3 is a perspective view thereof as seen from the top, rear
(56) References Cited and right side;
U.S. PATENT DOCUMENTS FIG. 4 is a perspective view thereof as seen from the top, front
and left side;
5,056,222 A * 10/1991 Miller et al . ................... 30/77
5,313,705 A * 5/1994 Rivers et al . ................... 30/50
FIG. 5 is a left side elevational view thereof, the right side
5,456,009 A * 10/1995 Wexler .......................... 30/77 elevation being a mirror image thereof;
D516,243 S * 2/2006 Nakasuka .................... D28/47 FIG. 6 is a rear elevational view thereof; and,
D526,089 S * 8/2006 Fischer et al ................. D28/47
7,200,942 B2 * 4/2007 Richard ....................... 30/526
FIG. 7 is a front elevational view thereof.
D566,897 S * 4/2008 Lee ............................. D28/46
D588,744 S * 3/2009 Fischer et al ................. D28/47 1 Claim, 3 Drawing Sheets
sari
MR
w
M
2
CD
CD
0)
U-
N
w
M
2
CD
CD
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U.S. Patent Nov. 24, 2009 Sheet 3 of 3 US D604,904 S
Fig. 5
Fig. 6
Fig. 7
Fig. 8
UNITED STATES PATENT AND TRADEMARK OFFICE
CERTIFICATE OF CORRECTION
PATENT NO. : Des. 604,904 S Page 1 of 1
APPLICATION NO. : 29/325197
DATED : November 24, 2009
INVENTOR(S) : Brian Patrick Watson
It is certified that error appears in the above-identified patent and that said Letters Patent is hereby corrected as shown below:
Cover Page
Under the description of figures insert --Fig. 8 is a top plan view thereof--.
Signed and Sealed this
Fifth Day of January, 2010
David J. Kappos
Director of the United States Patent and Trademark Office
EXHIBIT E
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EXHIBIT I
DINSMORE & SHOHL LLP

255 East Fifth Street ^ Suite 1900
Cincinnati, OH 45202
www.dinsmore.com
Karen K. Gaunt
(513) 977-8503 (direct) ^ (513) 977-8141 (fax)
karen.gaunt@dinsmore.com
January 20, 2017
Via FedEx
and Email (paypal@shnoop.com)
Mr. Menachem Grossman
Schnoop.com
1408 60th Street
Brooklyn, NY 11219
Re: Stolen Gillette Fusion ProGlide Razor Blades Offered for Sale by Schnoop.com on
eBay, Pennywise and Schnoop.com Websites
Dear Mr. Grossman:
This firm is counsel to The Gillette Company (Gillette) and The Procter & Gamble
Company (P&G) in each companys trademark, intellectual property and brand enforcement
matters. As you likely know, Gillette and P&G own numerous trademarks, copyrights, patents,
trade secrets, logos and proprietary designs used in connection with each companys products.
As legal counsel to Gillette, I write in reference to your online activities at, but not
limited to, the following sites:
1. http://www.ebay.com/itm/Gillette-Fusion-ProGlide-Manual-Mens-Razor-Blade-
Refill-Cartridges-8-Ct-BULK-/172463482519?_trkparms=5373%3A0%7C5374%3AFeatured
2. https://www.shnoop.com/home/5447-gillette-fusion-proglide-manual-men-s-razor-
blade-refill-cartridges-16-ct.html
3. https://www.pennywise.biz/home/5447-gillette-fusion-proglide-manual-men-s-razor-
blade-refill-cartridges-16-ct.html
More specifically, these are sites where Schnoop.com is selling Gillette Fusion ProGlide razor
cartridges. After purchase and inspection of these products sold by Schnoop.com, Gillette has
determined that the Gillette products Schnoop.com is selling are stolen goods.
I have enclosed screenshots of the offers in question as shown on eBay, Schnoop, and
Pennywise. Please see Exhibit A.
Gillette was able to track these specific units as stolen property. We hope that it is your
companys policy not to provide stolen products to consumers. To that end, we hereby demand
that Schnoop.com take the following steps immediately:
January 20, 2017
Page 2
1. Cease and desist from all further sales or offers for sale of the products in
question on all websites and in any and all other venues.
2. Provide to me all supplier information concerning these stolen razor cartridges,

including, but not limited to, the names, addresses, contact information, websites, and other
information concerning the party from whom Schnoop.com obtained these products.
3. Provide all invoices, purchase orders, shipping documents, and all other
documentation in your possession concerning these goods.
4. Inform us as to remaining inventory and ship all remaining units to the

following address:
Roxanne Murphy
Gillette/P&G
One Gillette Park
Boston, Massachusetts 02117
5. Keep all documents and records: do not destroy any evidence.
6. Finally, please also notify the undersigned of any and all other websites and/or
sales venues where Schnoop.com has sold or is selling these goods, and provide the
undersigned with full information concerning the total number of units of those goods which
your company previously obtained.
Please note that it is imperative that you do not tip off your source for these stolen
goods, thereby hindering Gillettes investigation and leaving Schnoop.com as the only
identifiable party responsible for this criminal activity. Finally, all offers for sale of these stolen
goods must be taken down immediately. The penalties for trafficking in stolen goods can be
quite severe. Having been put on notice of the criminal nature of these goods, I trust that
Schnoop.com will cooperate fully with Gillette in this matter.
This letter does not and is not intended to provide an exhaustive description of the
rights and remedies available to Gillette, all of which are hereby expressly reserved as to
Schnoop.com or any other party. Please respond to this letter by January 27, 2017, or we will
be forced to consider other options for recourse, which may include legal action.
Very truly yours,
Karen K. Gaunt
KKG:rgb
Enclosures
cc: The Gillette Company
10935832v1
Exhibit A
JS 44 (Rev. 08/16) CIVIL COVER SHEET
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEX7'PAGE OF THIS FORM)
I. (a) PLAINTIFFS sEURTAIVp

The Gillette Company, LLC Menachem Grossman
One Gillette Park, Boston, MA 02127 1408 60th St., Brooklyn, NY11219
(b) County of Residence of First Listed Plaintiff Suffolk County of Residence of First Listed Defendant Kings
(EXCEPT IN LIS PLAINTIFF CASES) (IN US PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.
1rrri Ecr,Address, and Telephone Number)

Di 1ci 9.116^1.tenh(Ti nn601V4i{661=71' he Silber Law Firm LLC
255 E. Fifth Street, Suite 1900 11 Broadway, Suite 715
Cincinnati, OH 45202,(513)977-8200 New York, NY 10004,(212)765-4567
II. BASIS OF JURISDICTION (Place an "X"in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES(Place an "X" in One Boxfor Plaintiff
(For Diversity Cases Only) *Defendant)
and One Box.
0 1 U.S. Government 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.& Government Not a Party) Citizen of This State 0 1 0 1 Incorporated or Principal Place 0 4 04
of Business In This State
171 2 U.S. Government CI 4 Diversity Citizen of Another State CI 2 CI 2 Incorporated and Principal Place 0 5 05
Defendant (Indicate Citizenship ofParties in Item III) of Business In Another State
Citizen or Subject of a CI 3 CI 3 Foreign Nation 0 6 06

Foreign Country
Click here
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
0 110 Insurance PERSONAL INJURY PERSONAL INJURY 0 625 Drug Related Seizure 0 422 Appeal 28 USC 158 0 375 False Claims Act
CI 120 Marine 0 310 Airplane 0 365 Personal injury - of Property 21 USC 881 0 423 Withdrawal CI 376 Qui Tam (31 USC
0 130 Miller Act 0 315 Airplane Product Product Liability CI 690 Other 28 USC 157 3729(a))
0 140 Negotiable Instrument Liability 0 367 Health Care/ CI 400 State Reapportionment
0 150 Recovery of Overpayment CI 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS CI 410 Antitrust
& Enforcement of Judgment Slander Personal Injury CI 820 Copyrights 0 430 Banks and Banking
CI 151 Medicare Act 0 330 Federal Employers' Product Liability CI 830 Patent 0 450 Commerce
CI 152 Recovery of Defaulted Liability CI 368 Asbestos Personal K 840 Trademark 0 460 Deportation
Student Loans 0 340 Marine Injury Product 0 470 Racketeer Influenced and
(Excludes Veterans) CI 345 Marine Product Liability LABOR SOCIAL SECURITY Corrupt Organizations
CI 153 Recover),of Overpayment Liability PERSONAL PROPERTY CI 710 Fair Labor Standards Cl 861 HIA (1395f0 0 480 Consumer Credit
of Veteran's Benefits 0 350 Motor Vehicle 0 370 Other Fraud Act 0 862 Black Lung(923) CI 490 Cable/Sat TV
Cl 160 Stockholders' Suits CI 355 Motor Vehicle CI 371 Truth in Lending CI 720 Labor/Management CI 863 DIWC/DIWW (405(g)) 0 850 Securities/Commodities/
0 190 Other Contract Product Liability 0 380 Other Personal Relations CI 864 SSID Title XVI Exchange
CI 195 Contract Product Liability 0 360 Other Personal Property Damage 0 740 Railway Labor Act 0 865 RSI(405(g)) 0 890 Other Statutory Actions
CI 196 Franchise Injury CI 385 Property Damage CI 751 Family and Medical 0 891 Agricultural Acts
Cl 362 Personal Injury - Product Liability Leave Act 0 893 Environmental Matters
Medical Malpractice 0 790 Other Labor Litigation 0 895 Freedom of Information
REAL PROPERTY CIVII, RIG1ITS PRISONER PETITIONS 0 791 Employee Retirement FEDERAL TAX SUITS Act
1
0 210 Land Condemnation 0 440 Other Civil Rights IIa beas Corpus: Income Security Act 0 870 Taxes(U.S. Plaintiff 0 896 Arbitration
0 220 Foreclosure CI 441 Voting CI 463 Alien Detainee or Defendant) 0 899 Administrative Procedure
CI 230 Rent Lease & Ejectment 0 442 Employment 01 510 Motions to Vacate 0 871 IRSThird Party Act/Review or Appeal of
0 240 Torts to Land 0 443 Housing/ Sentence 26 USC 7609 Agency Decision
0 245 Tort Product Liability Accommodations 0 530 General 0 950 Constitutionality of
0 290 All Other Real Property 0 445 Amer. w/Disabilities - 0 535 Death Penalty IMMIGRATION State Statutes
Employment Other: 0 462 Naturalization Application
0 446 Amer. w/Disabilities - CI 540 Mandamus & Other 0 465 Other Immigration
Other CI 550 Civil Rights Actions
0 448 Education CI 555 Prison Condition
0 560 Civil Detainee -
Conditions of
Confinement
V. ORIGIN (Place an "X" in One Box Only)

X1 Original n2 Removed from 0 3 Remanded from 0 4 Reinstated or 0 5 Transferred from 0 6 Multidistrict 0 8 Multidistrict
Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation -
(specify) Transfer Direct File
Cite the U.S. Civil Statute under which you are filing(Do not citejurisdictional statutes unless diversity):
28 USC 1331 et seq., 35 USC 271 et seq., 15 USC 1114 et seq.
VI. CAUSE OF ACTION Brief description of cause:
Trademark and US Design Patent infringement, conversion, unjust enrichment
REQUESTED IN El DEMAND $ CHECK YES only if demanded in complaint:
VII. CHECK IF THIS IS A CLASS ACTION
UNDER RULE 23, F.R.Cv.P. JURY DEMAND: X Yes 0 No
COMPLAINT:
VIII. RELATED CASE(S)
(See instructions):
IF ANY JUDGE DOCKET NUMBER
DATE SIGN URE

44tf/lziTT
OF A E OF RECORD
112..)Y
04/13/2017 '
FOR OFFICE USE ONLY
RECEIPT # AMOUNT APPLYING IFP JUDGE MAG. JUDGE

AO 398(Rev. 01/09) Notice of a Lawsuit and Request to Waive Service of a Summons

for the
Eastern District of New York
The Gillette Company, LLC,

Plaintiff
v. Civil Action No. 17-CV-2236
Shnoop.com, et al.,
Defendant
NOTICE OF A LAWSUIT AND REQUEST TO WAIVE SERVICE OF A SUMMONS
To: Menachem Grossman, as an individual

(Name ofthe defendant or - ifthe defendant is a corporation, partnership, or association - an officer or agent authorized to receive service)
Why are you getting this?
A lawsuit has been filed against you, or the entity you represent, in this court under the number shown above.
A copy of the complaint is attached.
This is not a summons,or an official notice from the court. It is a request that, to avoid expenses, you waive formal
service of a summons by signing and returning the enclosed waiver. To avoid these expenses, you must return the signed
waiver within 30 days (give at least 30 days, or at least 60 days ifthe defendant is outside anyjudicial district ofthe United States)
from the date shown below, which is the date this notice was sent. Two copies ofthe waiver form are enclosed, along with
a stamped, self-addressed envelope or other prepaid means for returning one copy. You may keep the other copy.
What happens next?
If you return the signed waiver,I will file it with the court. The action will then proceed as if you had been served
on the date the waiver is filed, but no summons will be served on you and you will have 60 days from the date this notice
is sent(see the date below)to answer the complaint(or 90 days if this notice is sent to you outside any judicial district of
the United States).
If you do not return the signed waiver within the time indicated, I will arrange to have the summons and complaint
served on you. And I will ask the court to require you, or the entity you represent, to pay the expenses of making service.
Please read the enclosed statement about the duty to avoid unnecessary expenses.
I certify that this request is being sent to you on the date below.
Date: 04/13/2017 ,
\,__,6ignature ofthe attorney or unrepresented party
Govinda M. Davis
Printed name
Dinsmore & Shohl LLP
255 E. Fifth Street, Suite 1900
Cincinnati, Ohio 45202
Address
govinda.davisAdinsmore.com
E-mail address
513-977-8200
Telephone number
AO 398(Rev. 01/09) Notice of a Lawsuit and Request to Waive Service of a Summons

for the
Eastern District of New York
The Gillette Company, LLC,

Plaintiff
v. Civil Action No. 17-CV-2236
Shnoop.com, et al.,
Defendant
NOTICE OF A LAWSUIT AND REQUEST TO WAIVE SERVICE OF A SUMMONS
To: Shnoop.com Corp., Menachem Grossman, officer

(Name ofthe defendant or - ifthe defendant is a corporation, partnership, or association - an officer or agent authorized to receive service)
Why are you getting this?
A lawsuit has been filed against you, or the entity you represent, in this court under the number shown above.
A copy of the complaint is attached.
This is not a summons,or an official notice from the court. It is a request that, to avoid expenses, you waive formal
service of a summons by signing and returning the enclosed waiver. To avoid these expenses, you must return the signed
waiver within 30 days (give at least 30 days, or at least 60 days ifthe defendant is outside anyjudicial district ofthe United States)
from the date shown below, which is the date this notice was sent. Two copies ofthe waiver form are enclosed, along with
a stamped, self-addressed envelope or other prepaid means for returning one copy. You may keep the other copy.
What happens next?
If you return the signed waiver, I will file it with the court. The action will then proceed as if you had been served
on the date the waiver is filed, but no summons will be served on you and you will have 60 days from the date this notice
is sent (see the date below)to answer the complaint(or 90 days if this notice is sent to you outside any judicial district of
the United States).
If you do not return the signed waiver within the time indicated, I will arrange to have the summons and complaint
served on you. And I will ask the court to require you, or the entity you represent, to pay the expenses of making service.
Please read the enclosed statement about the duty to avoid unnecessary expenses.
I certify that this request is being sent to you on the date below.
Date: 04/13/2017
Signature ofthe attorney or unrepresented party
Govinda M. Davis
Printed name
Dinsmore & Shohl LLP
255 E. Fifth Street, Suite 1900
Cincinnati, Ohio 45202
Address
govinda.davis@dinsmore.com
E-mail address
513-977-8200
Telephone number
AO 399 (01/09) Waiver of the Service of Summons

for the
Eastern District
__________ of New
District York
of __________
The Gillette Company, LLC , )

Plaintiff )
v. ) Civil Action No. 17-CV-2236
Shnoop.com Corp. and Menachem Grossman , )
Defendant )
WAIVER OF THE SERVICE OF SUMMONS
To: Meyer Y. Silber, Esq.

(Name of the plaintiffs attorney or unrepresented plaintiff)
I have received your request to waive service of a summons in this action along with a copy of the complaint,
two copies of this waiver form, and a prepaid means of returning one signed copy of the form to you.
I, or the entity I represent, agree to save the expense of serving a summons and complaint in this case.
I understand that I, or the entity I represent, will keep all defenses or objections to the lawsuit, the courts
jurisdiction, and the venue of the action, but that I waive any objections to the absence of a summons or of service.
I also understand that I, or the entity I represent, must file and serve an answer or a motion under Rule 12 within
60 days from 04/13/2017 , the date when this request was sent (or 90 days if it was sent outside the
United States). If I fail to do so, a default judgment will be entered against me or the entity I represent.
Date:
Signature of the attorney or unrepresented party
Printed name of party waiving service of summons Printed name
Address
E-mail address
Telephone number
Duty to Avoid Unnecessary Expenses of Serving a Summons
Rule 4 of the Federal Rules of Civil Procedure requires certain defendants to cooperate in saving unnecessary expenses of serving a summons
and complaint. A defendant who is located in the United States and who fails to return a signed waiver of service requested by a plaintiff located in
the United States will be required to pay the expenses of service, unless the defendant shows good cause for the failure.
Good cause does not include a belief that the lawsuit is groundless, or that it has been brought in an improper venue, or that the court has
no jurisdiction over this matter or over the defendant or the defendants property.
If the waiver is signed and returned, you can still make these and all other defenses and objections, but you cannot object to the absence of
a summons or of service.
If you waive service, then you must, within the time specified on the waiver form, serve an answer or a motion under Rule 12 on the plaintiff
and file a copy with the court. By signing and returning the waiver form, you are allowed more time to respond than if a summons had been served.

The Gillette Company v. SHNOOP - COM Corp. - Complaint

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Case 1:17-cv-02236 Document 1 Filed 04/13/17 Page 1 of 17 PageID #: 1

UNITED STATES DISTRICT COURT

THE GILLETTE COMPANY LLC )

COMPLAINT AND JURY DEMAND

and defendant Menachem Grossman (hereinafter Mr. Grossman) (collectively, the

3. Upon information and belief, SHNOOP.COM was initially incorporated in the

state of New York on or around October 26, 2007.

4. Upon information and belief, Menachem Grossman is a resident of the state of

and Principal Executive Officer of SHNOOP.

JURISDICTION AND VENUE

271 and Lanham Act, 15 U.S.C. 1114 and 15 U.S.C. 1125.

and the amount in question exceeds $75,000.00.

10. Venue is proper pursuant to 28 U.S.C. 1391.

A. Overview of Plaintiff Gillette

and shaving products.

brand (including Fusion and Fusion ProGlideTM brands).

nonfunctional, and distinctive product designs.

famous family of Gillette trademarks for a variety of goods.

safety razor blades in International Class 8, US Class 23 (hereinafter the GILLETTE

valid, subsisting, and incontestable.

attached hereto as Exhibit B. This registration is valid, subsisting, and incontestable.

razors, razor blades, razor cartridges, and razor dispensers.

attached hereto as Exhibit C.

attached hereto as Exhibit D.

design that embodies the design of the 904 Patent.

avoiding product liability claims.

are not packaged for retail sale.

indicating a November 20, 2016 production date.

opened for inspection there.

B. Overview of Defendant SHNOOP.COM Corp.s Sale of Gillette Fusion ProGlide

shnoop.com, schnoop.com (which redirects to shnoop.com), and pennywise.biz.

for the same product.

ProGlide razor blades from shnoop.com.

Street, Brooklyn, New York 11219.

on the razor blades indicated a November 20, 2016 production date.

for the same product.

ProGlide razor blades from pennywise.biz.

Street, Brooklyn, New York 11219.

on the razor blades indicated a November 20, 2016 production date.

went missing from Gillettes shipment and were presumed stolen.

C. Overview of Defendant SHNOOP.COM Corp. and/or Defendant Menachem

sale and sells a variety of products on the website ebay.com.

Attached as Exhibit G is a screen shot from ebay.com indicating such.

incorporation of SHNOOP.COM Corp.

username shnoopcom. Attached as Exhibit H is a screen shot of a listing of Gillette Fusion

sale, stacked in green plastic trays.

ProGlide razor blades from ebay.com.

Street, Brooklyn, New York 11219.

on the razor blades indicated a November 20, 2016 production date.

D. GILLETTES COMMUNICATION WITH DEFENDANTS

copy of the letter is attached hereto as Exhibit I.

paying value to, Gillette.

66. Gillette restates and realleges paragraphs 1-65.

MARK, which is valid, enforceable, and uncontestable.

unauthorized goods on shnoop.com, pennywise.biz, and ebay.com.

manner of use and other information relevant to these goods.

authorization, approval, or license by Gillette.

72. As a direct and proximate result of Defendants actions, Gillette is entitled to

costs and its reasonable attorneys fees, pursuant to 15 U.S.C. 1117(a).

pursuant to 15 U.S.C. 1116, against further infringement by Defendants.

Defendants illegal and unauthorized acts.

75. Gillette restates and realleges paragraphs 1-74.

which is valid, enforceable, and uncontestable.