Deckers v. SFY Global - Complaint

Case 2:17-cv-07148 Document 1 Filed 09/27/17 Page 1 of 32 Page ID #:1
1 Brent H. Blakely (SBN 157292)

bblakely@blakelylawgroup.com
2 Cindy Chan (SBN 247495)
cchan@blakelylawgroup.com
3 Jessica C. Covington (SBN 301816)
jcovington@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
12 DECKERS OUTDOOR ) CASE NO.
CORPORATION, a Delaware )
13 Corporation, ) COMPLAINT FOR DAMAGES AND
) EQUITABLE RELIEF:
14 Plaintiff, )
) 1. TRADE DRESS INFRINGEMENT;
15 v. )
) 2. TRADE DRESS INFRINGEMENT
16 SFY GLOBAL INC., a California ) UNDER CALIFORNIA COMMON
Corporation; and DOES 1-10, inclusive, ) LAW;
17 )
) 3. PATENT INFRINGEMENT U.S.
18 Defendants. ) PATENT NO. D599,999;
)
19 ) 4. PATENT INFRINGEMENT U.S.
) PATENT NO. D500,400;
20 )
) 5. UNFAIR COMPETITION
21 ) CALIFORNIA UNFAIR BUSINESS
) PRACTICES ACT, CAL. BUS. &
22 ) PROF. CODE, 17200, ET. SEQ.;
)
23 ) 6. UNFAIR COMPETITION UNDER
) CALIFORNIA COMMON LAW.
24 )
) JURY TRIAL DEMANDED
25 )
26 Plaintiff Deckers Outdoor Corporation for its claims against Defendant Sfy
27 Global Inc. respectfully alleges as follows:
28
1
COMPLAINT FOR DAMAGES AND EQUITABLE RELIEF
1 JURISDICTION AND VENUE

2 1. Plaintiff files this action against Defendant for trade dress infringement
3 and unfair competition under the Lanham Trademark Act of 1946, 15 U.S.C. 1051 et
4 seq. (the Lanham Act), patent infringement arising under the patent laws of the
5 United States, and for related claims under the statutory and common law of the state
6 of California. This Court has subject matter jurisdiction over the claims alleged in this
7 action pursuant to 28 U.S.C. 1331, 1338.
8 2. This Court has personal jurisdiction over Defendant because Defendant is
9 incorporated and has an established place of business in California.
10 3. This action arises out of wrongful acts by Defendant within this judicial
11 district and Plaintiff is located and has been injured in this judicial district by
12 Defendants alleged wrongful acts. Venue is proper in this district pursuant to 28
13 U.S.C. 1391 because the claims asserted arise in this district.
14 THE PARTIES
15 4. Plaintiff Deckers Outdoor Corporation (Deckers) is a corporation
16 organized and existing under the laws of the state of Delaware with an office and
17 principal place of business in Goleta, California. Deckers designs and markets
18 footwear identified by its many famous trademarks including its UGG trademark.
19 5. Upon information and belief, Defendant Sfy Global Inc. is a corporation
20 organized and existing under the laws of the state of California with an office and
21 principal place of business at 1100 Hatcher Ave., #C, City Of Industry, California
22 91748.
23 6. Deckers is unaware of the names and true capacities of Defendants,
24 whether individual, corporate and/or partnership entities named herein as DOES 1
25 through 10, inclusive, and therefore sues them by their fictitious names. Deckers will
26 seek leave to amend this complaint when their true names and capacities are
27 ascertained. Deckers is informed and believes and based thereon alleges that said
28 Defendant and DOES 1 through 10, inclusive, are in some manner responsible for the
2
1 wrongs alleged herein, and that at all times referenced each was the agent and servant
2 of the other Defendants and was acting within the course and scope of said agency and
3 employment.
4 7. Deckers is informed and believes, and based thereon alleges, that at all
5 relevant times herein, Defendant and DOES 1 through 10, inclusive, knew or
6 reasonably should have known of the acts and behavior alleged herein and the damages
7 caused thereby, and by their inaction ratified and encouraged such acts and behavior.
8 Deckers further alleges that Defendant and DOES 1 through 10, inclusive, have a non-
9 delegable duty to prevent or not further such acts and the behavior described herein,
10 which duty Defendant and DOES 1 through 10, inclusive, failed and/or refused to
11 perform.
12 ALLEGATIONS COMMON TO ALL CAUSES OF ACTION
13 A. DeckersUGG Brand
14 8. Deckers has been engaged in the design, distribution, marketing, offering
15 for sale, and sale of footwear since 1975. Deckers owns several brands of footwear
16 including UGG, Koolaburra, Teva, Sanuk, and Hoka One One.
17 9. DeckersUGG brand remains one of the most recognized and relevant
18 comfort shoe brands in the industry. Since 1978, when the UGG brand was founded,
19 the popularity of UGG boots has steadily grown across the nation and even the
20 globe. The UGG brand has always been and remains highly coveted by consumers.
21 This commitment to quality has helped to propel the UGG brand to its current,
22 overwhelming level of popularity and cemented its status as a luxury brand.
23 10. It has now been seventeen years since UGG boots were first featured on
24 Oprahs Favorite Things in the year 2000, and Oprah emphatically declared on
25 national television how much she LOOOOOVES her UGG boots.The popularity of
26 UGG brand footwear has grown exponentially since then with celebrities including
27 Kate Hudson and Sarah Jessica Parker among a myriad of others regularly donning
28
3
1 them. UGG sheepskin boots have become a high fashion luxury item and can be
2 found on fashion runways around the world.
3 11. DeckersUGG products are distributed and sold to consumers through
4 authorized retailers throughout the United States at point-of-sale and on the Internet,
5 including through its UGG Concept Stores and its website www.ugg.com.
6 B. Defendants Infringing Activities
7 12. Upon information and belief, Defendant Sfy Global Inc. is engaged in the
8 design, manufacture, distribution, advertisement, promotion, offering for sale, and/or
9 sale of a wide range of footwear for women and kids, including boots, booties, casual
10 shoes, ballerina shoes, sandals, thongs, dress shoes, evening shoes, open toes, pumps
11 and wedges.
12 13. Upon information and belief, Defendants products are advertised, offered
13 for sale, and sold to various retailers, wholesalers, and distributors nationwide and
14 within this judicial district.
15 14. The present lawsuit arises from Defendants willful infringement of
16 DeckersUGG boot designs, to which Deckers owns design patent and/or trade dress
17 rights, including rights to the UGG Bailey Buttonboot and Essential Outsole, by
18 certain footwear products advertised, offered for sale, and/or sold by Defendant
19 (Infringing Products).
20 15. Deckers is informed and believes and herein alleges that Defendant is a
21 competitor and has copied Deckersboot designs in an effort to exploit Deckers
22 reputation in the market.
23 16. Upon information and belief, Defendant may have sold additional
24 products that infringe upon Deckersdesign patents and trade dresses. Deckers may
25 seek leave to amend as additional information becomes available through discovery.
26 17. Deckers has not granted a license or any other form of permission to
27 Defendant with respect to its trademarks, design patents, trade dresses, or other
28 intellectual property.
4
1 18. Deckers is informed and believes and herein alleges that Defendant has
2 acted in bad faith and that Defendants acts have misled and confused and were
3 intended to cause confusion, or to cause mistake, or to deceive as to the affiliation,
4 connection, or association of Defendants Infringing Products with Deckers, or as to
5 the origin, sponsorship, or approval of Defendants Infringing Products by Deckers.
6 FIRST CLAIM FOR RELIEF
7 (Trade Dress Infringement - 15 U.S.C. 1125(a))
8 19. Deckers incorporates herein by reference the averments of the preceding
9 paragraphs as though fully set forth herein.
10 20. The UGG Bailey Button boot was introduced in 2009 and the Bailey
11 Button Boot Trade Dressis unique and distinctive, consisting of a combination of the
12 following non-functional elements:
13 i Classic suede boot styling made famous by the UGG brand;
14 i Overlapping of front and rear panels on the lateral side of the boot shaft;
15 i Curved top edges on the overlapping panels;
16 i Exposed fleece-type lining edging the overlapping panels and top of the
17 boot shaft; and
18 i One or more buttons (depending on the height of the boot) prominently
19 featured on the lateral side of the boot shaft adjacent the overlapping panels
20 (hereinafter Bailey Button Boot Trade Dress).
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1 21. The Bailey Button Boot Trade Dress, which is a composite of the above-
2 referenced features, is non-functional in its entirety, visually distinctive, and is unique
3 in the footwear industry.
4 22. The design of the Bailey Button Boot Trade Dress is neither essential to
5 its use or purpose nor does it affect the cost or quality of the boot. There are numerous
6 other designs available that are equally feasible and efficient, none of which
7 necessitate copying or imitating the Bailey Button Boot Trade Dress. The aforesaid
8 combination of features provides no cost advantages to the manufacturer or utilitarian
9 advantages to the consumer. These features, in combination, serve only to render
10 DeckersUGG Bailey Button boots distinct and recognizable as goods originating
11 from DeckersUGG brand.
12 23. The Bailey Button Boot Trade Dress is an original design by Deckers and
13 has achieved a high degree of consumer recognition and secondary meaning, which
14 serves to identify Deckers as the source of footwear featuring said trade dress.
15 24. The Bailey Button Boot Trade Dress is one of the most well-recognized
16 and commercially successful styles of DeckersUGG brand of footwear, having been
17 featured on Deckersadvertising and promotional materials as well as in various trade
18 publications. Furthermore, the Bailey Button Boot Trade Dress has been featured in
19 connection with various celebrities, has received a large volume of unsolicited media
20 attention, and has graced the pages of many popular magazines nationwide and
21 internationally.
22 25. Deckers has spent substantial time, effort, and money in designing,
23 developing, advertising, promoting, and marketing the UGG brand and its line of
24 footwear embodying the Bailey Button Boot Trade Dress. Deckers spends millions of
25 dollars annually on advertising of UGG products, which include products bearing the
26 Bailey Button Boot Trade Dress.
27 26. Deckers has sold hundreds of millions of dollars worth of UGG
28 products bearing the Bailey Button Boot Trade Dress.
6
1 27. Due to its long use, extensive sales, and significant advertising and
2 promotional activities, DeckersBailey Button Boot Trade Dress has achieved
3 widespread acceptance and recognition among the consuming public and trade
4 throughout the United States.
5 28. There are numerous other boot designs in the footwear industry, none of
6 which necessitate copying or imitating the Bailey Button Boot Trade Dress. However,
7 due to the popularity and consumer recognition achieved by the Bailey Button boot,
8 said design has often been the subject of infringement by third-parties, including
9 Defendant.
10 29. Deckers is informed and believes and herein alleges that Defendant is a
11 competitor and has copied DeckersBailey Button Boot Trade Dress in an effort to
12 exploit Deckersreputation in the market.
13 30. Amongst the Infringing Products produced, distributed, advertised and
14 offered for sale by Defendant are boots that bear nearly identical reproductions of the
15 Bailey Button Boot Trade Dress (see below), such as to cause a likelihood of confusion
16 as to the source, sponsorship or approval by Deckers of Defendants products.
17
18
19
20
21
22 31. Defendants use of DeckersBailey Button Boot Trade Dress is without
23 Deckerspermission or authority and in total disregard of Deckersrights to control its
24 intellectual property.
25 32. Defendants use of DeckersBailey Button Boot Trade Dress is likely to
26 lead to and result in confusion, mistake or deception, and is likely to cause the public
27 to believe that Defendants products are produced, sponsored, authorized, or licensed
28
7
1 by or are otherwise connected or affiliated with Deckers, all to the detriment of

2 Deckers.
3 33. Deckers has no adequate remedy at law.
4 34. In light of the foregoing, Deckers is entitled to injunctive relief
5 prohibiting Defendant from using DeckersBailey Button Boot Trade Dress, or any
6 designs confusingly similar thereto, and to recover all damages, including attorneys
7 fees, that Deckers has sustained and will sustain, and all gains, profits and advantages
8 obtained by Defendant as a result of its infringing acts alleged above in an amount not
9 yet known, as well as the costs of this action.
10 SECOND CLAIM FOR RELIEF
11 (Trade Dress Infringement under California Common Law)
14 36. Defendants infringement of the Bailey Button Boot Trade Dress
15 constitutes common law trade dress infringement in violation of the common law of
16 the state of California.
17 37. Defendants unauthorized use of the Bailey Button Boot Trade Dress has
18 caused and is likely to cause confusion as to the source of Defendants products, all to
19 the detriment of Deckers.
20 38. Defendants acts are willful, deliberate, and intended to confuse the public
21 and to injure Deckers.
22 39. Deckers has no adequate remedy at law to compensate it fully for the
23 damages that have been caused and which will continue to be caused by Defendants
24 infringing conduct, unless they are enjoined by this Court.
25 40. The conduct herein complained of was extreme, outrageous, and was
26 inflicted on Deckers in reckless disregard of Deckersrights. Said conduct was
27 despicable and harmful to Deckers and as such supports an award of exemplary and
28
8
1 punitive damages in an amount sufficient to punish and make an example of

2 Defendant, and to deter it from similar such conduct in the future.
4 prohibiting Defendant from infringing the Bailey Button Boot Trade Dress, and to
5 recover all damages, including attorneysfees, that Deckers has sustained and will
6 sustain, and all gains, profits and advantages obtained by Defendant as a result of its
7 infringing acts alleged above in an amount not yet known, and the costs of this action.
8 THIRD CLAIM FOR RELIEF
9 (Patent Infringement - U.S. Patent No. D599,999)
12 43. Deckers is the owner of numerous design patents to the various styles of
13 footwear it offers under its UGG brand. These design patents include but are not
14 limited to the Bailey Buttonboot (U.S. Patent No. D599,999 issued on September
15 15, 2009), a true and correct copy of which is attached hereto and incorporated herein
16 as Exhibit A (999 Patent).
17 44. Deckers is the owner by assignment of all right, title and interest in and to
18 the 999 Patent.
19 45. Defendant has used, caused to be produced, distributed, advertised,
20 marketed, offered for sale, sold within the United States, and/or has imported into the
21 United States footwear that is substantially similar to the 999 Patent (see below) in
22 direct violation of 35 U.S.C. 271.
23
24
25
26
27
28
9
1 46. Defendants aforesaid infringing acts are without Deckerspermission or

2 authority and are in total disregard of Deckersright to control its intellectual property.
3 47. As a direct and proximate result of Defendants infringing conduct,
4 Deckers has been injured and will continue to suffer injury to its business and
5 reputation unless Defendant is restrained by this Court from infringing Deckers999
6 Patent.
7 48. Defendants acts have damaged and will continue to damage Deckers, and
8 Deckers has no adequate remedy at law.
9 49. Deckers marks all footwear products embodying the design of the 999
10 Patent with Pat. No. 599,999on a product label in compliance with 35 U.S.C. 287.
11 50. Given the widespread popularity and recognition of DeckersBailey
12 Button boot and the patent notice provided on the products themselves, Deckers avers
13 and hereon alleges that Defendant had pre-suit knowledge of Deckersrights to the
14 999 Patent and intentionally copied said design on its own footwear products in an
15 effort to pass them off as if they originated, are associated with, are affiliated with, are
16 sponsored by, are authorized by, and/or are approved by Deckers.
17 51. On information and belief, Defendants acts herein complained of
18 constitute willful acts and intentional infringement of the 999 Patent.
20 prohibiting Defendant from infringing the 999 Patent and to recover damages
21 adequate to compensate for the infringement, including Defendants profits pursuant to
22 35 U.S.C. 289. Deckers is also entitled to recover any other damages as appropriate
23 pursuant to 35 U.S.C. 284.
24 FOURTH CLAIM FOR RELIEF
25 (Patent Infringement - U.S. Patent No. D500,400)
28
10
1 54. Deckers is the owner of numerous design patents to the various styles of
2 footwear and/or slippers it offers under its UGG brand. These design patents include
3 but are not limited to outsole designs, one of which is the Essential Outsole,U.S.
4 Patent No. D500,400 (issued on January 4, 2005), a true and correct copy of which is
5 attached hereto and incorporated herein as Exhibit B (400 Patent).
6 55. Deckers is the owner by assignment of all right, title and interest in and to
7 the 400 Patent.
8 56. Defendant has used, caused to be produced, distributed, advertised,
9 marketed, offered for sale, sold within the United States, and/or has imported into the
10 United States footwear that bear an outsole substantially similar to the 400 Patent (see
11 below) in direct violation of 35 U.S.C. 271.
12
13
14
15
16
17
18
19
20
21 57. Defendants aforesaid infringing acts are without Deckerspermission or
22 authority and are in total disregard of Deckersright to control its intellectual property.
23 58. As a direct and proximate result of Defendants infringing conduct,
24 Deckers has been injured and will continue to suffer injury to its business and
25 reputation unless Defendant is restrained by this Court from infringing Deckers400
26 Patent.
27 59. Defendants acts have damaged and will continue to damage Deckers, and
28 Deckers has no adequate remedy at law.
11
1 60. Deckers marks all footwear products embodying the design of the 400
2 Patent with Pat. No. D500,400on a product label in compliance with 35 U.S.C.
3 287.
4 61. Given the widespread popularity and recognition of DeckersUGG
5 products and the patent notice provided on the products themselves, Deckers avers and
6 hereon alleges that Defendant had pre-suit knowledge of Deckersrights to the 400
7 Patent and has intentionally copied said design on its own brand of products in an
8 effort to pass them off as if they originated, are associated with, are affiliated with, are
9 sponsored by, are authorized by, and/or are approved by Deckers.
10 62. On information and belief, Defendants acts herein complained of
11 constitute willful acts and intentional infringement of the 400 Patent.
13 prohibiting Defendant from infringing the 400 Patent and to recover damages
14 adequate to compensate for the infringement, including Defendants profits pursuant to
15 35 U.S.C. 289. Deckers is also entitled to recover any other damages as appropriate
16 pursuant to 35 U.S.C. 284.
17 FIFTH CLAIM FOR RELIEF
18 (Unfair Competition California Unfair Business Practices Act, Cal. Bus. & Prof.
19 Code, 17200, et. seq.)
22 65. Defendants appropriation, adoption and use of various UGG boot
23 designs, including the Bailey Button Boot Trade Dress, on its own footwear is likely to
24 confuse or mislead consumers into believing that Defendants goods are authorized,
25 licensed, affiliated, sponsored, and/or approved by Deckers, thus constituting a
26 violation of the California Unfair Business Practices Act, Cal. Bus. & Prof. Code,
27 17200, et. seq.
28
12
1 66. In fact, Defendant has misappropriated the reputation and goodwill

2 Deckers has established in its UGG Classicline of boots, which includes among
3 others the Bailey Button,Classic Short,and Classic Tallboots, by
4 manufacturing, causing to be manufactured/produced, distributing, marketing, offering
5 for sale, and/or selling its own line of nearly identical boots.
6
Genuine UGG Boots Boots Displayed on Defendants Website
7 (www.sfyusa.com)
8
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26 67. Indeed, Defendants intent to copy and misappropriate Deckers
27 reputation and goodwill established in its Classic line of boots is further evidenced by
28 its use of outsole designs that are identical to that of Deckerspatented outsole designs.
13
1 68. The deceptive, unfair and fraudulent practices set forth herein have been
2 undertaken with knowledge by Defendant willfully with the intention of causing harm
3 to Deckers and for the calculated purpose of misappropriating Deckersgoodwill and
4 business reputation.
5 69. Defendants acts have caused and will continue to cause irreparable injury
6 to Deckers. Deckers has no adequate remedy at law to compensate it fully for the
8 unlawful acts, unless it is enjoined by this Court.
9 70. In light of the foregoing, Deckers is entitled to all available relief
10 provided for in California Unfair Business Practices Act, Cal. Bus. & Prof. Code,
11 17200, et. seq. including permanent injunctive relief.
12 FOURTH CLAIM FOR RELIEF
13 (Unfair Competition Under California Common Law)
16 72. Defendants appropriation, adoption and use of various UGG boot
17 designs, including the Bailey Button Boot Trade Dress and patented outsole design, on
18 its own footwear constitutes unfair competition in violation of the common law of the
19 state of California.
20 73. Defendant is a competitor of Deckers and has copied Deckersboot
21 designs in an effort to exploit Deckersreputation in the market.
22 74. Defendants infringing acts were intended to capitalize on Deckers
23 goodwill associated therewith for Defendants own pecuniary gain. Deckers has
24 expended substantial time, resources and effort in creating and developing its unique
25 line of footwear that consumers recognize as originating from the UGG brand. As a
26 result of Deckersefforts, Defendant is now unjustly enriched and is benefiting from
27 property rights that rightfully belong to Deckers.
28
14
1 75. Defendants acts are willful, deliberate, and intended to confuse the public
2 and to injure Deckers.
3 76. Deckers has no adequate remedy at law to compensate it fully for the
5 infringing conduct, unless it is enjoined by this Court.
6 77. The conduct herein complained of was extreme, outrageous, and was
7 inflicted on Deckers in reckless disregard of Deckersrights. Said conduct was
8 despicable and harmful to Deckers and as such supports an award of exemplary and
9 punitive damages in an amount sufficient to punish and make an example of
10 Defendant, and to deter it from similar such conduct in the future.
11 PRAYER FOR RELIEF
12 WHEREFORE, Plaintiff Deckers Outdoor Corporation respectfully prays for
13 judgment against Defendant Sfy Global, Inc. as follows:
14 1. A Judgment that Defendant has infringed DeckersBailey Button Boot
15 Trade Dress and that said infringement was willful;
16 2. A Judgment that Defendant has infringed DeckersD599,999 and
17 D500,400 Patents and that said infringement was willful;
18 3. An order granting temporary, preliminary and permanent injunctive relief
19 restraining and enjoining Defendant, and its agents, servants, employees, officers,
20 associates, attorneys, and all persons acting by, through, or in concert with any of them
21 from using Deckersintellectual property, including, but not limited to:
22 a. manufacturing, importing, advertising, marketing, promoting,
23 supplying, distributing, offering for sale, or selling the Infringing Products or any other
24 products which bear DeckersBailey Button Boot Trade Dress and/or any designs
25 confusingly similar thereto;
26 b. manufacturing, importing, advertising, marketing, promoting,
27 supplying, distributing, offering for sale, or selling the Infringing Products or any other
28
15
1 products which infringe the D599,999 and D500,400 Patents and/or the overall
2 appearance thereof;
3 c. engaging in any other activity constituting unfair competition with
4 Deckers, or acts and practices that deceive consumers, the public, and/or trade,
5 including without limitation, the use of designations and design elements used or
6 owned by or associated with Deckers; and
7 d. committing any other act which falsely represents or which has the
8 effect of falsely representing that the goods and services of Defendant is licensed by,
9 authorized by, offered by, produced by, sponsored by, or in any other way associated
10 with Deckers;
11 4. Ordering Defendant to recall from any distributors and retailers and to
12 deliver to Deckers for destruction or other disposition all remaining inventory of all
13 Infringing Products and related items, including all advertisements, promotional and
14 marketing materials therefore, as well as means of making same;
15 5. Ordering Defendant to file with this Court and serve on Deckers within
16 thirty (30) days after entry of the injunction a report in writing, under oath setting forth
17 in detail the manner and form in which Defendant has complied with the injunction;
18 6. Ordering an accounting by Defendant of all gains, profits and advantages
19 derived from its wrongful acts pursuant to 15 U.S.C. 1117(a) and 35 U.S.C. 289;
20 7. Awarding Deckers all of Defendants profits and all damages sustained by
21 Deckers as a result of Defendants wrongful acts, and such other compensatory
22 damages as the Court determines to be fair and appropriate;
23 8. Awarding treble damages in the amount of Defendants profits or
24 Deckersdamages, whichever is greater, for willful infringement;
25 9. Awarding applicable interest, costs, disbursements and attorneysfees;
26 10. Awarding Deckers punitive damages in connection with its claims under
27 California law; and
28
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1 11. Such other relief as may be just and proper.

2
3 Dated: September 27, 2017 BLAKELY LAW GROUP
4
5
6 By: _______________________________
Brent H. Blakely
7 Cindy Chan
Jessica C. Covington
9
10
11 DEMAND FOR JURY TRIAL
12 Pursuant to Rule 38(b) of the Federal Rules of Civil Procedure, Plaintiff Deckers
13 Outdoor Corporation hereby demands a trial by jury as to all claims in this litigation.
14
15 Dated: September 27, 2017 BLAKELY LAW GROUP
16
17 By: _______________________________
Brent H. Blakely
18 Cindy Chan
Jessica C. Covington
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EXHIBIT A
EXHIBIT B

Deckers v. SFY Global - Complaint

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Case 2:17-cv-07148 Document 1 Filed 09/27/17 Page 1 of 32 Page ID #:1

1 Brent H. Blakely (SBN 157292)

1 JURISDICTION AND VENUE

1 by or are otherwise connected or affiliated with Deckers, all to the detriment of

1 punitive damages in an amount sufficient to punish and make an example of

1 46. Defendants aforesaid infringing acts are without Deckerspermission or

1 66. In fact, Defendant has misappropriated the reputation and goodwill

1 11. Such other relief as may be just and proper.

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