Deckers v. American Camel - Complaint

Case 2:20-cv-04384 Document 1 Filed 05/14/20 Page 1 of 15 Page ID #:1
1 Brent H. Blakely (SBN 157292)

bblakely@blakelylawgroup.com
2 Mark S. Zhai (SBN 287988)
mzhai@blakelylawgroup.com
3 Colby A. Meagle (SBN 328594)
cmeagle@blakelylawgroup.com
4 BLAKELY LAW GROUP
1334 Parkview Avenue, Suite 280
5 Manhattan Beach, California 90266
Telephone: (310) 546-7400
6 Facsimile: (310) 546-7401
7 Attorneys for Plaintiff
Deckers Outdoor Corporation
8
9 UNITED STATES DISTRICT COURT
10 CENTRAL DISTRICT OF CALIFORNIA
11
DECKERS OUTDOOR ) CASE NO.:
12 CORPORATION, a Delaware )
Corporation, ) COMPLAINT FOR DAMAGES AND
13 ) EQUITABLE RELIEF:
Plaintiff, )
14 ) 1. TRADE DRESS INFRINGEMENT
)
15 v. ) 2. TRADE DRESS INFRINGEMENT
) UNDER CALIFORNIA COMMON
16 ) LAW
AMERICAN CAMEL )
17 INTERNATIONAL INVEST ) 3. UNFAIR COMPETITION IN
ENTERPRISE LTD, a California ) VIOLATION OF CAL. BUS. &
18 Corporation; and DOES 1-10, inclusive, ) PROF. CODE, § 17200
)
19 ) 4. UNFAIR COMPETITION UNDER
Defendants. ) CALIFORNIA COMMON LAW
20 )
) 5. PATENT INFRINGEMENT OF
21 ) U.S. PAT. NO. D704,425
)
22 )
) JURY TRIAL DEMANDED
23 )
24
25
26
27
28
1
COMPLAINT FOR DAMAGES AND EQUITABLE RELIEF
1 Plaintiff Deckers Outdoor Corporation (“Deckers” or “Plaintiff”) for its

2 Complaint against Defendants American Camel International Invest Enterprise
3 LTD (“Camel”) and DOES 1-10 (collectively “Defendants”) alleges as follows:
4 JURISDICTION AND VENUE
5 1. This action arises out of Defendants’ complicit and unlawful acts
6 constituting trade dress infringement and unfair competition in violation of the
7 Lanham Trademark Act of 1946, 15 U.S.C. § 1051, et seq. (the “Lanham Act”), patent
8 infringement arising under the patent laws of the United States, 35 U.S.C. § 1, et seq.
9 and violations of statutory and common law of the state of California.
10 2. This Court has subject matter jurisdiction over the federal claims asserted
11 in this action under 28 U.S.C. §§ 1331 and 1338(a) and supplemental jurisdiction over
12 Plaintiff’s state law claims pursuant to 28 U.S.C. § 1367(a) because they are so related
13 to the federal claims that they form part of the same case or controversy.
14 3. This Court has personal jurisdiction over Defendants because Defendants
15 reside and conduct continuous and systematic business in this district, placed
16 infringing products in the stream of commerce directed to residents of this district,
17 derived commercial benefits from the sale of infringing products and caused injuries
18 to Plaintiff within the Central District of California.
19 4. Venue is proper under 28 U.S.C. §§ 1391 (b)-(c) because a substantial
20 part of the events giving rise to the claims occurred in this judicial district, and 28
21 U.S.C. § 1400(b) because Defendants committed acts of infringement and have a
22 regular and established place of business in this judicial district.
23 THE PARTIES
24 5. Plaintiff Deckers Outdoor Corporation is a corporation organized and
25 existing under the laws of the state of Delaware with an office and principal place of
26 business located in Goleta, California. Deckers designs and markets footwear
27 products under a number of well-known brands, including UGG® products covered
28 by the intellectual property asserted in this Complaint.
2
1 6. Upon information and belief, Defendant American Camel International

2 Invest Enterprise LTD is a corporation organized and existing under the laws of the
3 state of California with an office and principal place of business located at 8718
4 Longden Ave, San Gabriel, CA 91775.
5 7. Deckers is informed and believes that, together with Camel, other
6 individuals and entities currently named as DOES 1-10 may also be responsible in one
7 manner or another for the wrongs alleged herein, in that at all relevant times, each one
8 (including Camel) was the agent and servant of the others and acting within the course
9 and scope of said agency and employment. These other individuals and entities are
10 sued under fictitious names DOES 1-10 because their true names and capacities are
11 currently unknown to Deckers. Deckers will seek leave to amend this Complaint
12 when their true names and capacities are ascertained.
13 ALLEGATIONS COMMON TO ALL CAUSES OF ACTION
14 A. Deckers’ UGG® Brand
15 8. Deckers has been engaged in the design, distribution, marketing, offering
16 for sale, and sale of footwear since 1975. Deckers owns and markets its footwear
17 products under several distinctive trademarked brands, including UGG®,
18 Koolaburra®, Teva®, Sanuk®, and Hoka One One®.
19 9. Deckers’ UGG® brand is one of the most well-recognized premium
20 comfort-leisure shoe brands in the United States. Since 1979, when the UGG® brand
21 was founded, the popularity of UGG® footwear has steadily grown in the U.S. and
22 around the world. UGG® footwear has been and remains highly coveted today by
23 consumers as one of the most popular and recognizable symbols of luxury and style.
24 10. For example, in 2000, UGG® boots were featured on Oprah’s Favorite
25 Things® where Oprah emphatically declared on national television how much she
26 “LOOOOOVES her UGG boots.” Since then, the popularity of UGG® footwear has
27 grown exponentially, with celebrities such as Kate Hudson, Sarah Jessica Parker, and
28 Tom Brady among a myriad of others regularly seen wearing UGG® sheepskin boots
3
1 and other footwear products.

2 11. The world-wide recognition as a “premium” brand and the overwhelming
3 popularity of the UGG® brand is due to Deckers’ continuous commitment to quality
4 and excellence. Today, Deckers’ footwear products under the UGG® brand are
5 widely available and sold to consumers in every state, including California, through
6 UGG® Concept Stores, authorized brick-and-mortar retailers, as well as on the
7 internet at www.ugg.com.
8 B. Defendants’ Infringing Activities
9 12. This lawsuit arises from Defendants’ design, manufacture, distribution,
10 advertisement, marketing, offering for sale, and sale of footwear products (the
11 “Accused Products”) that infringe upon Deckers’ “Bailey Bow Trade Dress” and U.S.
12 Pat. No. D704,425.
13 13. Upon information and belief, Defendants are engaged in the manufacture,
14 design, advertisement, marketing, distribution, offer for sale, and/or sale of apparel,
15 accessories and footwear for women under the name “CAMEL CROWN.”
16 14. Upon information and belief, Camel is a competitor, and Defendants
17 introduced Accused Products into the stream of commerce in an effort to exploit
18 Deckers’ goodwill and the reputation of the UGG® Bailey Bow Boot.
19 15. Deckers has not granted a license or given Defendants any other form of
20 permission to Defendants with respect to its trademarks, trade dresses, or patents.
21 16. Upon information and belief, Defendants designed, manufactured,
22 advertised, marketed, distributed, offered for sale, and/or sold Accused Products, an
23 exemplar of which is shown in the photograph below.
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1
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3
4
5
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8 Example of a “Camel Crown” Accused Product
9 17. Upon information and belief, Defendants have acted in bad faith and
10 Defendants’ unlawful acts have misled and confused, and were intended to cause
11 confusion, or to cause mistake, or to deceive as to the affiliation, connection, or
12 association of the Accused Products with Deckers, and the origin, sponsorship, or
13 approval of the Accused Products by Deckers.
14 18. Upon information and belief, Defendants may have sold additional
15 products that infringe upon Deckers’ design patents and/or trade dresses.
16 FIRST CLAIM FOR RELIEF
17 (Trade Dress Infringement - 15 U.S.C. § 1125(a))
18 19. Deckers incorporates by reference each and every one of the preceding
19 paragraphs as though fully set forth herein.
20 20. In 2011, Deckers introduced the UGG® Bailey Bow Boot, marketed and
21 featuring the design elements protected under the “Bailey Bow Trade Dress.” The
22 Bailey Bow Trade Dress is unique and inherently distinctive, and comprised of the
23 following non-functional elements:
24 a. Classic suede boot styling made famous by the UGG® brand;
25 b. A smooth boot shaft that has a vertical slit opening at the back of
26 the shaft;
27 c. Exposed fleece-type lining edging the top of the boot shaft and
28 along the medial and lateral side edges of the vertical slit opening;
5
1 d. A tongue at the back of the boot shaft, underlying and closing the
2 vertical slit opening; and
3 e. One or more bows prominently featured at the rear of the boot
4 shaft (depending on the height of the boot) extending between the medial and
5 lateral sides of the shaft over the tongue.
6 21. The Bailey Bow Trade Dress, which is a composite of the above-
7 referenced features, is non-functional in its entirety, visually distinctive, and unique in
8 the footwear industry; examples of its distinctive appearance as a whole are shown in
9 the photographs below:
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18 22. The design of the Bailey Bow Trade Dress is neither essential to its use
or purpose, nor does it affect the cost or quality of the shoe. There are numerous other
19
designs available that are equally feasible and efficient, none of which necessitate
20
copying or imitating the Bailey Bow Trade Dress. The combination of features
21
comprising the Bailey Bow Trade Dress provides no cost advantages to the
22
manufacturer or utilitarian advantages to the consumer. These features, in
23
combination, serve only to render UGG® Bailey Bow Boots, the embodiment of the
24
Bailey Bow Trade Dress, as a distinct and recognizable product originating from
25
Deckers.
26
23. UGG® Bailey Bow Boots, the embodiment of the Bailey Bow Trade
27
Dress, is one of the most well-recognized and commercially successful styles of
28
6
1 UGG® brand of footwear, having been featured in many of Deckers’ advertising and
2 promotional materials as well as in various trade publications. UGG® Bailey Bow
3 Boots have received a large volume of unsolicited media attention, for example,
4 through various celebrities seen wearing UGG® Bailey Bow Boots and graced the
5 pages of many popular magazines nationwide and internationally.
6 24. Deckers has spent substantial time, effort, and money in designing,
7 developing, advertising, promoting, and marketing the UGG® brand and its line of
8 footwear embodying the Bailey Bow Trade Dress. Deckers spends millions of dollars
9 annually on advertising of UGG® products, including footwear embodying the Bailey
10 Bow Trade Dress.
11 25. Due to its long use, extensive sales, and significant advertising and
12 promotional activities, Deckers’ Bailey Bow Trade Dress has achieved widespread
13 acceptance and recognition among the consuming public and trade throughout the
14 United States. Indeed, Deckers has sold millions of dollars’ worth of UGG® Bailey
15 Bow Boots, the embodiment of the Bailey Bow Trade Dress. Accordingly, the Bailey
16 Bow Trade Dress has achieved a high degree of consumer recognition and secondary
17 meaning, which serves to identify Deckers as the exclusive source of footwear
18 featuring said trade dress.
19 26. Upon information and belief, Camel is a competitor and Defendants
20 introduced Accused Products into the stream of commerce in an effort to exploit
21 Deckers’ goodwill and the reputation of the UGG® Bailey Bow Boot.
22 27. The Accused Products produced, distributed, advertised and offered for
23 sale by Defendants bear confusingly similar reproductions of the Bailey Bow Trade
24 Dress, such as to cause a likelihood of confusion as to the source, sponsorship or
25 approval by Deckers of Camel’s products.
26 28. Defendants’ use of the Bailey Bow Trade Dress is without Deckers’
27 permission or authority and in total disregard of Deckers’ rights to control its
28 intellectual property. There are numerous other shoe designs in the footwear industry,
7
1 none of which necessitate copying or imitating the Bailey Bow Trade Dress.
2 29. Defendants’ use of the Bailey Bow Trade Dress is likely to lead to and
3 result in confusion, mistake or deception, and is likely to cause the public to believe
4 that Accused Products are produced, sponsored, authorized, or licensed by or are
5 otherwise connected or affiliated with Deckers.
6 30. As a direct and proximate result of the foregoing acts, Deckers has
7 suffered and will continue to suffer significant injuries in an amount to be determined
8 at trial. Deckers is entitled to recover all damages, including attorneys’ fees, that it
9 has sustained and will sustain, and all gains, profits and advantages obtained by
10 Defendants as a result of its infringing acts.
11 31. Furthermore, unless Defendants’ unlawful acts are enjoined by this
12 Court, there is no adequate remedy at law that can fully compensate Deckers for the
13 harm caused by Defendants’ infringement, which is ongoing. Accordingly, Deckers is
14 entitled to injunctive relief prohibiting Defendants from continuing to infringe the
15 Bailey Bow Trade Dress, or any designs confusingly similar thereto.
16 SECOND CLAIM FOR RELIEF
17 (Trade Dress Infringement – California Common Law)
20 33. Defendants’ infringement of the Bailey Bow Trade Dress also constitutes
21 trade dress infringement under common law of the state of California.
22 34. The Accused Products produced, distributed, advertised and offered for
23 sale by Defendants bear confusingly similar reproductions of the Bailey Bow Trade
24 Dress, such as to cause a likelihood of confusion as to the source, sponsorship or
25 approval by Deckers of Camel’s products. Defendants’ unauthorized use of the
26 Bailey Bow Trade Dress has caused and is likely to cause confusion as to the source
27 of Accused Products among consumers.
8

2 at trial. Deckers is entitled to recover all damages, including attorneys’ fees, that it
3 has sustained on account of Defendants’ infringement, and all gains, profits and
4 advantages obtained by Defendants as a result of its unlawful acts.
5 36. Defendants’ unlawful acts were willful, deliberate, and intended to cause
6 confusion among the public, taken in reckless disregard of Deckers’ rights. As such,
7 an award of exemplary and punitive damages is necessary in an amount sufficient to
8 deter similar misconduct in the future.
11 damages caused by Defendants’ infringement, which is ongoing. Accordingly,
12 Deckers is entitled to injunctive relief prohibiting Defendants from continuing to
13 infringe the Bailey Bow Trade Dress, or any designs confusingly similar thereto.
14 THIRD CLAIM FOR RELIEF
15 (Unfair Competition in Violation of Cal. Bus. & Prof. Code, § 17200 et. seq.)
18 39. Defendants’ misappropriation and unauthorized use of the Bailey Bow
19 Trade Dress to promote the Accused Products is likely to confuse or mislead
20 consumers into believing that such products are authorized, licensed, affiliated,
21 sponsored, and/or approved by Deckers, constituting deceptive, unfair, and fraudulent
22 business practices and unfair competition in violation of the California Unfair
23 Business Practices Act, Cal. Bus. & Prof. Code, § 17200, et. seq.
24 40. Upon information and belief, Defendants’ deceptive, unfair, and
25 fraudulent business practices were willfully undertaken with full knowledge of the
26 Bailey Bow Trade Dress and with the intent to misappropriate Deckers’ goodwill and
27 reputation established in the UGG® Bailey Bow Boot.
9

2 at trial. Deckers is entitled to all available relief provided for under the California
3 Unfair Business Practices Act, Cal. Bus. & Prof. Code, § 17200 et. seq., including an
4 accounting and disgorgement of all illicit profits that Defendants made on account of
5 its deceptive, unfair, and fraudulent business practices. Furthermore, because there
6 has no adequate remedy at law for Defendants’ ongoing unlawful conduct, Deckers is
7 entitled to injunctive relief prohibiting Defendants from unfair competition.
8 FOURTH CLAIM FOR RELIEF
9 (Unfair Competition – California Common Law)
12 43. Defendants’ misappropriation and unauthorized use of the Bailey Bow
13 Trade Dress to promote the Accused Products also constitutes unfair competition in
14 violation of common law of the state of California.
15 44. Deckers has expended substantial time, resources and effort in creating
16 and developing UGG® footwear, including the UGG® Bailey Bow Boot, the
17 embodiment of the Bailey Bow Trade Dress, which consumers recognize as
18 originating from Deckers.
19 45. Upon information and belief, Defendants introduced Accused Products
20 into the stream of commerce in order to exploit Deckers’ goodwill and the reputation
21 established in the UGG® Bailey Bow Boot for Defendants’ own pecuniary gain.
22 Defendants’ unauthorized use of the Bailey Bow Trade Dress resulted in Defendants
23 unfairly benefitting from Deckers’ goodwill and the reputation established in the
24 UGG® Bailey Bow Boot.
25 46. Upon information and belief, Defendants’ unlawful acts are willful,
26 deliberate, and intended to cause confusion among the public and taken in reckless
27 disregard of Deckers’ rights. As such, an award of exemplary and punitive damages is
28 necessary in an amount sufficient to deter similar misconduct in the future.
10
3 at trial. Deckers is entitled to recover all damages, including attorneys’ fees, that
4 Deckers has sustained on account of Defendants’ unfair competition, and all gains,
5 profits and advantages obtained by Defendants as a result of its unlawful acts.
6 Furthermore, because Deckers has no adequate remedy at law for Defendants’
7 ongoing unlawful conduct, Deckers is entitled to injunctive relief prohibiting
8 Defendants from unfair competition.
9 FIFTH CLAIM FOR RELIEF
10 (Patent Infringement – U.S. Pat. No. D704,425)
13 49. In order to protect its valuable brands, Deckers owns a number of patents
14 covering various styles of footwear it markets, including the footwear products
15 identified herein. These patents include U.S. Pat. No. D704,425 (“the ’425 Patent”)
16 issued on May 13, 2014, a true and correct copy of which is attached hereto as
17 Exhibit A and incorporated herein.
18 50. Deckers is the owner by assignment of all rights, title and interest in and
19 to the ’425 Patent and Deckers has marked substantially all footwear products
20 embodying the design with “Pat. No. D704,425” on a product label in compliance
21 with 35 U.S.C. § 287, putting Defendants on notice of the ’425 Patent.
22 51. Defendants have produced, distributed, advertised, marketed, offered for
23 sale, and/or sold within the United States, and/or have imported into the United States
24 Accused Products which bear a design that infringes upon the design of the ’425
25 Patent, in violation of 35 U.S.C. § 271.
26 52. Deckers has not granted a license or given Defendants any form of
27 permission to the ’425 Patent. Defendants’ infringement of the ’425 Patent is without
28 Deckers’ permission or authority and in total disregard of Deckers’ intellectual
11
1 property rights.
4 at trial. Deckers is entitled to recover all damages sustained on account of
5 Defendants’ infringement, and all gains, profits and advantages obtained by
6 Defendants under 35 U.S.C. §§ 284 and 289.
7 54. Upon information and belief, Defendants’ infringing acts were willful,
8 deliberate, and taken in reckless disregard of the ’425 Patent despite having been put
9 on notice through Deckers’ patent marking. Defendants took these actions despite an
10 objectively high likelihood that such actions constituted infringement of the ’425
11 Patent. Defendants’ willful acts render this an exceptional case, such that Deckers is
12 entitled to enhanced damages and reasonable attorney fees under 35 U.S.C. § 284.
15 harm caused by Defendants’ infringement of the ’425 Patent, which is ongoing.
16 Accordingly, Deckers is entitled to injunctive relief under 35 U.S.C. § 283 prohibiting
17 Defendants from continuing to infringe the ’425 Patent.
18 PRAYER FOR RELIEF
19 WHEREFORE, Plaintiff Deckers Outdoor Corporation respectfully prays for
20 judgment against Defendants American Camel International Invest Enterprise LTD
21 and DOES 1-10 as follows:
22 1. A judgment that Defendants infringed Deckers’ Bailey Bow Trade Dress
23 and U.S. Pat. No. D704,425;
24 2. An order permanently enjoining and restraining Defendants, their agents,
25 servants, employees, officers, associates, and all persons acting in concert with any of
26 them from infringing Deckers’ intellectual property at issue, including but not limited
27 to infringing acts such as:
28
12
1 a. manufacturing, importing, advertising, marketing, promoting,

2 supplying, distributing, offering for sale, or selling Accused Products or any
3 other products that bear an identical or confusingly similar design as Deckers’
4 Bailey Bow Trade Dress;
5 b. manufacturing, importing, advertising, marketing, promoting,
6 supplying, distributing, offering for sale, or selling Accused Products or any
7 other products that infringe the ’425 Patent;
8 c. engaging in any other activity constituting unfair competition with
9 Deckers, or acts and practices that deceive consumers, the public, and/or trade,
10 including without limitation, the use of designations and design elements used
11 or owned by or associated with Deckers; and
12 d. committing any other act which falsely represents or which has
13 the effect of falsely representing goods and services of Defendants are
14 licensed, authorized, offered, produced, sponsored, or in any other way
15 associated with Deckers;
16 3. An order requiring Defendants to recall from any distributors and
17 retailers and to deliver to Deckers for destruction any Accused Products, including the
18 means of making such products;
19 4. An order requiring Defendants to file with this Court and serve on
20 Deckers within thirty (30) days after entry of the injunction, a report in writing and
21 under oath setting forth the manner in which Defendants complied with the injunction;
22 5. An order for an accounting of all gains, profits and advantages derived by
23 Defendants on account of the unlawful acts complained of herein pursuant to 15
24 U.S.C. § 1117(a), Cal. Bus. & Prof. Code, § 17200 et. seq., and any other applicable
25 federal statute or California state and common law;
26 6. An award of damages equal to Defendants’ profits and all damages
27 sustained by Deckers as a result of Defendants’ wrongful acts;
28 7. An award of damages equal to treble Defendants’ profits or Deckers’
13
1 damages, whichever is greater, on account of Defendants’ willful infringement;

2 8. An award of punitive damages and Deckers’ costs, attorneys’ fees, and
3 interest as allowed under all applicable federal statutes and California state laws; and
4 9. All other relief that the Court may deem just and proper.
5
6 Dated: May 14, 2020 BLAKELY LAW GROUP
7
8 By: _/s/ Mark S. Zhai_________
Brent H. Blakely
9 Mark S. Zhai
Colby A. Meagle
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1 DEMAND FOR JURY TRIAL

2 Pursuant to Rule 38(b) of the Federal Rules of Civil Procedure, Plaintiff Deckers
3 Outdoor Corporation hereby demands a trial by jury as to all claims in this litigation.
4
5 Dated: May 14, 2020 BLAKELY LAW GROUP
6
7 By: _/s/ Mark S. Zhai_________
Brent H. Blakely
8 Mark S. Zhai
Colby A. Meagle
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Case 2:20-cv-04384 Document 1-1 Filed 05/14/20 Page 1 of 8 Page ID #:16
EXHIBIT A
USOOD704425S
(12) MacIntyre
United States Design Patent (10) Patent No.: USD704,425 S
(45) Date of Patent: . May 13, 2014
(54) FOOTWEAR UPPER UGG Australia Bailey Bow model, www.uggaustralia.com, https://
web.archive.org/web/2012 1002051839/http://www.uggaustralia.
(71) Applicant: Deckers Outdoor Corporation, Goleta, com/womens-bailey-bow-sheepskin-boot 1002954.default.pd.html;
CA (US) Oct. 2, 2012, see images.
(72) Inventor: Jennifer MacIntyre, Santa Barbara, CA UGG Australia Bailey Bow Tall model, www.uggaustralia.com,
https://web.archive.org/web/201210 15074327/http://www.ug
(US) gaustralia.com/womens-bailey-bow-tall/3388, default.pd.html; Oct.
(73) Assignee: Deckers Outdoor Corporation, Goleta, 15, 2012, see images.
CA (US)
(**) Term: 14 Years * cited by examiner
(21) Appl. No. 29/471,634 Primary Examiner — Robert M Spear
Assistant Examiner — Rashida C McCoy
(22) Filed: Nov. 4, 2013 (74) Attorney, Agent, or Firm — Greer, Burns & Crain, Ltd.
(51) LOC (10) Cl. ................................................ 02-04
(52) U.S. Cl.
USPC ........................................................... D2/970
(58) Field of Classification Search (57) CLAM
USPC .......... D2/896, 900, 909-911, 943, 946, 969, The ornamental design for a footwear upper, as shown and
D2/970,974; 36/83, 1.5, 2 R, 109, 3 A, described.
36/7.1 R, 45, 52, 112, 100
See application file for complete search history.
DESCRIPTION
(56) References Cited
U.S. PATENT DOCUMENTS FIG. 1 is a front perspective view of a footwear upper showing
my new design;
D76,233 S * 9, 1928 Golden ..........................D2/900 FIG. 2 is a rear perspective view thereof;
D164,667 S * 10/1951 Bingham, Jr. ...D2/912 FIG. 3 is a side elevational view thereof;
D284.805 S * 7/1986 Smith .......... ...D2,900 FIG. 4 is an opposite side elevational view thereof;
D439,030 S * 3/2001 Bernath ... ...D2,900
D529,269 S * 10/2006 Belley et al. . D2/970 FIG. 5 is a front elevational view thereof
D599,999 S * 9/2009 MacIntyre ... D2/970 FIG. 6 is a rear elevational view thereof;
D616,190 S * 5/2010 MacIntyre ... D2/970 FIG. 7 is a top plan view thereof; and,
D646,475 S * 10/2011 Boncutter ...................... D2/970 FIG. 8 is a bottom plan view thereof.
OTHER PUBLICATIONS The broken lines in FIGS. 1-8 represent portions of the foot
wear that form no part of the claimed design. The dot-dash
UGG Australia Mini Bailey Button model, www.uggaustralia.com, lines which define the bounds of the claimed design form no
https://web.archive.org/web/20121016124321/http://www.ug part thereof.
gaustralia.com/womens-mini-bailey-button-boots/3352.default.pd.
html; Oct. 16, 2012, see images. 1 Claim, 6 Drawing Sheets
U.S. Patent May 13, 2014 Sheet 1 of 6 USD704,425 S






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Case 2:20-cv-04384 Document 1 Filed 05/14/20 Page 1 of 15 Page ID #:1

1 Brent H. Blakely (SBN 157292)

1 Plaintiff Deckers Outdoor Corporation (“Deckers” or “Plaintiff”) for its

1 6. Upon information and belief, Defendant American Camel International

1 and other footwear products.

1 suffered and will continue to suffer significant injuries in an amount to be determined

1 suffered and will continue to suffer significant injuries in an amount to be determined

1 a. manufacturing, importing, advertising, marketing, promoting,

1 damages, whichever is greater, on account of Defendants’ willful infringement;

1 DEMAND FOR JURY TRIAL

U.S. Patent May 13, 2014 Sheet 1 of 6 USD704,425 S

U.S. Patent May 13, 2014 Sheet 2 of 6 USD704,425 S

U.S. Patent May 13, 2014 Sheet 3 of 6 USD704,425 S

U.S. Patent May 13, 2014 Sheet 4 of 6 USD704,425 S

U.S. Patent May 13, 2014 Sheet 5 of 6 USD704,425 S

U.S. Patent May 13, 2014 Sheet 6 of 6 USD704,425 S

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