1 Case :-cv-00-nc Document Filed 0// Page of Los Angeles, California 00 Telephone: Peter L. Haviland (SBN Scott S. Humphreys (SBN 0 BALLARD SPAHR LLP Los Angeles, CA 00-0 Telephone:.0.00 Facsimile:.0.0 Attorneys for Plaintiff ALLSTATE INSURANCE COMPANY UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA ALLSTATE INSURANCE COMPANY, v. Plaintiff, ROTEM SABAG; an individual; LOCKSMITH SERVICES, INC.; a California corporation; and and DOES through inclusive Defendants. Case No. :-cv- SUMMARY OF THE ACTION COMPLAINT FOR TRADEMARK INFRINGEMENT DEMAND FOR JURY TRIAL Allstate Insurance Company ( Allstate brings this action for trademark infringement against Defendants Rotem Sabag and Locksmith Services, Inc. ("Defendants". Defendants have brazenly infringed Allstate's incontestable, federally-registered trademarks -- including Allstate's famous "cupped hands" and slant-"a" design marks -- to market Defendants' services on their websites < and < Defendants' bad faith registration of these domains and willful infringement of Allstate's famous marks are obvious attempts to capitalize on the brand reputation of Allstate s marks to divert traffic to its websites, confuse consumers regarding the source of the services provided, and unlawfully profit from the substantial goodwill associated with Allstate's marks.
2 Case :-cv-00-nc Document Filed 0// Page of Los Angeles, California 00 Telephone:.0.00 Allstate accordingly seeks an order from this Court that Defendants: (i be permanently enjoined from further use of Allstate's marks, including but not limited to use on their websites < and < (ii disgorge all profits gained from their use of the websites and infringement of Allstate's marks; and (iii pay Allstate treble damages and attorneys' fees. JURISDICTION AND VENUE. This Court has subject matter jurisdiction under the Lanham Act, U.S.C. et seq. and pursuant to U.S.C. and (a.. Personal jurisdiction vests because at all relevant times Defendants have been doing business in this judicial district; have engaged in wrongful acts causing injury in this State; and because Defendants are citizens of this State and reside in this judicial district.. Venue is proper in this district pursuant to U.S.C. (b( and (. INTRADISTRICT ASSIGNMENT. This is an Intellectual Property Action to be assigned on a district-wide basis pursuant to Civil L.R. -(c. PARTIES. Allstate Insurance Company is a corporation organized and existing under the laws of the State of Illinois, with its principal place of business in Northbrook, Illinois.. Defendant Rotem Sabag ("Sabag" is the registrant of the infringing websites 0 < and < Sabag attempted to conceal her/his identity from Allstate by using a so-called domain privacy service to register the domains, causing ICANN's database to list the registrant as "Domain Privacy Service FBO Registrant." Sabag is a citizen of California who conducts business in San Jose, California.. Defendant Locksmith Services, Inc. ("Locksmith " is a California corporation registered to do business at 0 South Market Street # 0, San Jose, CA. True and correct copies of the official domain name registrations from the WHOIS database maintained by the Internet Corporation for Assigned Names and Numbers ("ICANN" last accessed January, 0, which identify Rotem Sabag as registrant of the websites < and < are attached hereto as Exhibits and, respectively.
3 Case :-cv-00-nc Document Filed 0// Page of Los Angeles, California 00 Telephone: On information and belief, Locksmith is a closely-held corporation that is controlled entirely or in substantial part by Sabag and that conducts the business and provides the services advertised on the websites.. Does through are persons and/or entities whose true names and capacities are unknown to Plaintiff and who participated in, conspired with, and/or caused Defendants to infringe Allstate's trademark rights as alleged herein and who are otherwise responsible and liable to Allstate for the wrongful acts alleged herein. Allstate will amend this Complaint to allege the true names and capacities of said defendants as soon as they become known. FACTUAL ALLEGATIONS Allstate s Famous and Distinctive Trademarks. Allstate was founded years ago in as part of Sears, Roebuck & Co. In, Allstate became an independent, 0 percent publicly-held corporation and has since grown to become the nation s largest publicly-held personal lines insurer and a FORTUNE 0 company having more than 0,000 employees and representatives. Allstate and its affiliates protect approximately million households through auto, home, life and other insurance offered through its Allstate and related brand names.. Since its inception, Allstate has continually used a number of trademarks which encompass "ALLSTATE" and is widely known through its famous You re In Good Hands With Allstate slogan and its famous and distinctive "cupped hands" and slant-"a" design marks.. Allstate owns more than 0 active U.S. trademark registrations and applications (dating to. These include the marks "ALLSTATE" as well as various iterations of Allstate's famous and distinctive "cupped hands" and slant-"a" design marks for a wide range of goods and services, including but not limited to automobile and home insurance, motor club services, and emergency roadside services. Allstate also owns substantial common law rights to marks which encompass "ALLSTATE" and numerous U.S. state law registrations. Allstate also owns numerous trademark registrations and/or common law rights encompassing "ALLSTATE" in a number of foreign jurisdictions including but not limited to Canada, the European Union and
4 Case :-cv-00-nc Document Filed 0// Page of India. All of these registrations and rights (U.S., state or foreign are collectively referred to herein as the "ALLSTATE Marks.". Relevant examples of the "ALLSTATE Marks" which are federally-registered with the United States Patent and Trademark Office (USPTO include, but are not limited to: Los Angeles, California 00 Telephone: Mark ALLSTATE (standard character mark (from specimen submitted to USPTO Reg. Number Reg. Date Goods and Services, // For: Services to motorist members, including assistance on planning auto trips, emergency road service benefits, legal service benefit in event of traffic violation charges, accident insurance, and arranging for world-wide tours, in Class 0 0, /0/ For: Insurance Underwriting Services in Class (Int. Cl.,0, 0//00. For: Motor club services, namely, emergency roadside services, in Class (U.S. Cls. 0, and For: Motor club services, namely, emergency automobile towing, providing assistance with planning trips, namely, providing travel information for members, in Class (U.S. Cls. 0 and ALLSTATE ROADSIDE SERVICES (standard character mark,0, 0/0/0. For: Providing emergency road service for motorists, in Class (U.S. Cls. 0,, and For: Emergency vehicle towing services for motorists, in Class (U.S. Cls. 0 and (from specimen submitted to USPTO
5 Case :-cv-00-nc Document Filed 0// Page of Los Angeles, California 00 Telephone: ALLSTATE DEALER SERVICES (standard character mark (from specimen submitted to USPTO,,0 0//0 For: Insurance underwriting services in the field of auto protection in Class (U.S. Cls. 0, and For: Automotive maintenance and repair; emergency roadside assistance services, namely, responding to calls for roadside assistance, flat tire changing, emergency fuel supplying, and battery jump starting, in Class (U.S. Cls. 0, and,0,0 0//0. For: Insurance Services in Class. For: Providing emergency road service for motorists, namely, flat tire changing, emergency fuel supplying, and battery jump starting, in Class (U.S. Cls. 0, and. For: Emergency vehicle towing services for motorists in Class (U.S. Cls. 0 and,, //0 For: Financing and loan services in Class (U.S. Class 0, and.,00, 0//0 For: Insurance services, namely, underwriting, issuance and administration of property, liability and casualty insurance, in Class (U.S. Cls. 0, and.. The ALLSTATE Marks, including the famous and distinctive "cupped hands" and slant-"a" design marks, are prominently displayed on Allstate's website, which is itself a trademark registered by the USPTO on October, 00 (Registration No.. The website receives, on average, million visits a month. True and correct copies of the foregoing Allstate trademark registrations and relevant specimens submitted to the USPTO are attached hereto as Exhibits to, respectively.
6 Case :-cv-00-nc Document Filed 0// Page of Los Angeles, California 00 Telephone: Allstate is also the registrant of thousands of other website domain names featuring the ALLSTATE Marks, for example: "allstate.net" (; "allstate.org" (; "allstateinsurance.com" (00; "allstatelifeinsurance.com" (00; "allstateinsurancecompany.com" (00; "insurance-allstate.com" (00; "car-insurance-allstate.com" (00.. Allstate has, since its inception, expended hundreds of millions of dollars on advertising and promoting the ALLSTATE Marks. Allstate has, for example, been prominently featured as a sponsor of popular sporting events and through various longer-term sponsorships of college football, college basketball, and professional soccer. Allstate has also won many awards, including: Corporate World's Most Ethical Company 0 and 0 the Ethisphere Institute The World's Most Admired Companies 0 Fortune Magazine; Allstate ranked # in Property and Casualty Insurance 0 Happiest Companies in America for 0 - CareerBliss Flame of Life Award - The National Safety Council, for efforts to reduce teen traffic accident deaths (0 Top 0 Military Friendly Employers 0 MilitaryFriendly.com Best Places to Work for Recent Grads 0 ConnectEDU Innovation Decade Award, Business Innovation Award, and # on 0 InformationWeek Elite 0 List InformationWeek Magazine CIO 0 Award 0 CIO 0 Elite Suren Gupta Insurance Technology Magazine Data Impact Award for Pervasive User Adoption 0 Cloudera Diversity Top 0 Employers 0 th Annual STEM Workforce Diversity Magazine Reader Survey Top Best Places to Work for New Grads 0 Symplicity Corporation Top Corporation for Women Business Executives, 0 and 0 Women s Business Enterprise National Council (WBENC Top 0 Companies for Executive Women 0 National Association for Female Executives (NAFE Top 0 Companies for Diversity 0 DiversityInc. Magazine (-time award winner Top 0 Companies for Executive Women 0 National Association for Female Executives (NAFE 0 Best Companies for Diversity 0 Black Enterprise Magazine Top Best Companies for Supplier Diversity 0 Black Enterprise Magazine
7 Case :-cv-00-nc Document Filed 0// Page of Los Angeles, California 00 Telephone: Out Front Best Places for Women & Diverse Managers to Work 0 Diversity MBA Working Mother 0 Best Companies 0-0 Working Mother Magazine Best Companies for Multicultural Women 00-0, 0 Working Mother Magazine 0 Best Companies for Latinas to Work -0 LATINA Style Magazine; Allstate has won this award for consecutive years Corporate Responsibility Corporate Social Responsibility Leadership Award 0 Financial Services Roundtable 0 Best Corporate Citizens 0 Corporate Responsibility Magazine Top 0 Green Companies in the United States, Newsweek Magazine (00-0, 0-0 Carbon Disclosure Project: S&P 00 Carbon Disclosure Leadership Index (00, 0-0 S&P 00 Carbon Performance Leadership Index (0 The Civic 0 0; Allstate ranked # among S&P 00 companies. As a result of Allstate s substantial marketing efforts, charitable contributions, civic stewardship, and continuous use of its marks in connection with the outstanding goods and services that it provides, the ALLSTATE Marks have become famous in the minds of consumers.. Because of the fame and renown of Allstate and the ALLSTATE Marks, cybersquatters frequently seek to register domain names featuring the name "Allstate." Allstate has recovered many domain names from cybersquatters, including but not limited to: carinsuranceallstate.com (Allstate Ins. Co. v. Fundacion Private Whois / Domain Administrator, FA (NAF Jan., 0; allstateinsurancequotes.org (Allstate Ins. Co. v. Jeremy Ehrenthal / East Coast Health Ins., FA 0 (NAF Feb., 0; allstateflod.com (Allstate Ins. Co. v. Whois Privacy Service, D0-0 (WIPO March, 0; allstatefiancial.com, allstatefinacial.com, myallstatefinancal.com, myallstatefinancail.com and myallstatefiancial.com (Allstate Ins. Co. v. Mike Morgan, FA 0 (NAF March, 0; allstateinteractivequote.us and allstatenet.us (Allstate Ins. Co. v. Integrated Capital Group, FA (NAF July, 0; and
8 Case :-cv-00-nc Document Filed 0// Page of Los Angeles, California 00 Telephone: allstatescottsdale.com (Allstate Ins. Co. v. Sean Olivier, FA 00 (NAF July, 0. The USPTO has also recognized the fame of the ALLSTATE Marks. For example, in a USPTO office action denying registration of a third party s proposed mark YOU'RE IN GOOD HANDS WITH ALLDAT (U.S. Serial No. 00, the USPTO stated: Although Allstate is not connected with the goods and/or services provided by applicant under the applied-for mark, Allstate and the Good Hands marks are so famous that consumers would presume a connection.. Allstate, in connection with its famous and distinctive ALLSTATE Marks, including its "Allstate Motor Club" and "Good Hands Rescue " products and/or programs, provides a number of / automotive services to consumers, including towing, jumpstarts and locksmith assistance for lockouts. Defendants' Willful, Bad Faith Infringement of Allstate's Famous Marks, Including the "Cupped Hands" and Slant-"A" Design Marks 0. Defendants are the registrants, owners and/or operators of the domain names and websites < and < According to the official ICANN WHOIS database, the domain names were registered on June, 0, and August, 0, respectively. Defendant Sabag attempted to conceal her/his identity from Allstate by using a so-called domain privacy service to register the domains, which caused the registrant to be listed as "Domain Privacy Service FBO Registrant" in ICANN's WHOIS database.. Since registration, Defendants have used the domain names and website content commercially to advertise the sale of nationwide locksmith and garage door services, which are competitive with and/or confusingly similar to the automotive and insurance services, including locksmith services, that Allstate provides to its customers in connection with the ALLSTATE Marks. Printouts from the websites < and < last accessed January, 0 are attached hereto as Exhibits and, respectively.
9 Case :-cv-00-nc Document Filed 0// Page of. The < website promotes Defendants' competing locksmith services using the name "Allstate" and an identical, counterfeit copy of Allstate's famous and distinctive "cupped hands" design mark, as excerpted from the website below: Los Angeles, California 00 Telephone: The < website likewise promotes Defendants' services using the name "Allstate" in a font, style and color identical to Allstate's famous and distinctive slant-"a" design mark as excerpted from the website, below:
10 Case :-cv-00-nc Document Filed 0// Page of Los Angeles, California 00 Telephone: Defendants' websites are not affiliated with or sponsored by Allstate, and Allstate has not authorized Defendants to use the ALLSTATE Marks, including the famous and distinctive "cupped hands" and slant-"a" design marks, on Defendants' websites or otherwise.. Defendants' unauthorized use of the name "Allstate" in its website domains and on the content of its websites, and in particular the counterfeit replication of the ALLSTATE Marks on its websites has resulted in actual instances of consumer confusion with Allstate's related goods and services, causing damage to Allstate including to its reputation, and is likely to continue to cause consumer confusion, to cause mistake, and/or to deceive customers and potential customers of the parties with respect to some affiliation, connection, or association with Allstate or as to the origin, sponsorship, or approval of the products and/or services offered on Defendants' websites.. Defendants' unauthorized use of the ALLSTATE Marks has enabled Defendants to unlawfully trade on, and to receive the benefit of, the goodwill built up by Allstate over many years, and to gain acceptance for the services sold in connection with the websites.. Defendants unauthorized use of the ALLSTATE Marks is likely to cause dilution by blurring and dilution by tarnishing Allstate s famous and distinctive marks.. Unless Defendants' willful acts of trademark infringement are restrained by the Court, those acts will continue to cause irreparable injury to Allstate and the public for which there is no adequate remedy at law. FIRST CLAIM FOR RELIEF Trademark Infringement and Unfair Competition, Lanham Act U.S.C. et seq. 0. Allstate repeats, realleges, and incorporates by reference the allegations in paragraphs through as though fully set forth herein.. Allstate is the owner of the federally registered ALLSTATE Marks, many of which are incontestable pursuant to U.S.C., for a wide range of goods and services, including in connection with the / roadside locksmith assistance services and car and home insurance services it provides.
11 Case :-cv-00-nc Document Filed 0// Page of Los Angeles, California 00 Telephone: Allstate's use of the ALLSTATE Marks in commerce prior to Defendants' use of the ALLSTATE Marks on Defendants' websites < and < established Allstate s superior rights to enforce the ALLSTATE Marks against Defendants.. Pursuant to U.S.C., Allstate's federal registrations provided constructive notice of the ALLSTATE Marks to Defendants, and give Allstate legal priority over Defendants as to any subsequent use of the ALLSTATE Marks, including the name "Allstate" and the "cupped hands" and slant-"a" design marks in Defendants' domain names and on Defendants' websites.. Defendants' commercial marketing of its goods and services on its websites, which are offered in the same channels of commerce and to the same class of consumers as the services associated with the ALLSTATE Marks, is aimed at and occurs across state lines and via the internet to consumers in all fifty states.. Allstate has not authorized nor consented to Defendants' use of its federally registered ALLSTATE Marks in the domain names themselves or in the content of the websites < and < Defendants' use of the name "Allstate" in its domain names, and blatant copying of Allstate's famous and distinctive "cupped hands" and slant-"a" design marks on its websites, has already resulted in actual instances of consumer confusion and is likely to continue to cause confusion or mistake among ordinary consumers about the source, sponsorship, affiliation, connection, association and/or approval of the goods and services offered by Defendants, by creating the false, deceiving, and/or misleading impression that such goods and services are created by Allstate, and/or are sponsored by, affiliated with or approved by Allstate. Such confusingly similar use constitutes trademark infringement and unfair competition in violation of the Lanham Act, U.S.C. ( and (a.. As a direct and proximate cause of each of Defendants' acts as alleged herein, Allstate has suffered and will continue to suffer damages.. Allstate is entitled to disgorgement of all of Defendants' profits relating to their bad faith, willful infringement of the ALLSTATE Marks, all damages sustained by Allstate in amounts
12 Case :-cv-00-nc Document Filed 0// Page of Los Angeles, California 00 Telephone: to be proven at trial, and the costs of this action. Allstate is also entitled to recover treble damages and its reasonable attorneys fees because Defendants' acts have been malicious, fraudulent, deliberate and willful and intended to benefit Defendants at Allstate s expense.. Defendants' wrongful conduct has caused and will continue to cause Allstate to suffer irreparable injury for which no adequate remedy at law exists. Accordingly, Allstate is entitled to an order permanently enjoining Defendants (i from any further use of the ALLSTATE Marks, including but not limited to Allstate's famous and distinctive "cupped hands" and slant-"a" design marks, in connection with the goods and services provided by Defendants, as well as in any domain names or on any websites owned or controlled by Defendants, and (ii from any other acts of infringement of any of the ALLSTATE Marks. SECOND CLAIM FOR RELIEF Dilution of Famous Mark Trademark Dilution Revision Act, U.S.C. (c 0. Allstate repeats, realleges, and incorporates by reference the allegations in paragraphs through as though fully set forth herein.. The ALLSTATE Marks, and in particular the "cupped hands" and slant-"a" design marks, are widely recognized by the general consuming public as a designation of the source of the services provided by Allstate, and are distinctive and famous within the meaning of the Trademark Dilution Revision Act of 00, U.S.C. (c.. Defendants' unauthorized commercial use of the name "Allstate" in its domains < and < and blatant copying of Allstate's famous and distinctive "cupped hands" and slant-"a" design marks to market its services on those websites, have diluted and/or are likely to cause dilution by blurring and/or dilution by tarnishment of Allstate s famous and distinctive marks.. Because Defendants willfully intended to trade on Allstate s reputation and the consuming public s recognition of the famous ALLSTATE Marks and/or willfully intended to cause dilution of and harm to the reputation of Allstate and the famous ALLSTATE Marks, Allstate is entitled to disgorgement of all of Defendants' profits relating to their bad faith, willful
13 Case :-cv-00-nc Document Filed 0// Page of Los Angeles, California 00 Telephone:.0.00 acts as alleged herein, all damages sustained by Allstate in amounts to be proven at trial, and the costs of this action. Allstate is also entitled to recover treble damages and its reasonable attorneys fees because Defendants' acts have been malicious, fraudulent, deliberate and willful and intended to benefit Defendants at Allstate s expense.. Defendants' wrongful conduct has caused and will continue to cause Allstate to suffer irreparable injury for which no adequate remedy at law exists. Accordingly, Allstate is entitled to an order permanently enjoining Defendants from (i any further use of the ALLSTATE Marks, including but not limited to Allstate's famous and distinctive "cupped hands" and slant-"a" design marks in connection with the goods and services provided by Defendants as well as in any domain names or on any websites owned or controlled by Defendants, and (ii any other acts of infringement of any of the ALLSTATE Marks. PRAYER FOR RELIEF WHEREFORE, Allstate respectfully requests that the Court enter an Order: A. Permanently enjoining Defendants and their agents, officers, representatives, employees, successors, assigns, attorneys, and all others acting for, with, by or under authority from Defendants, or in concert or participation with Defendants, and each of them from: i. Engaging in any and all acts of infringement of Allstate's registered marks; ii. Using the word or mark "Allstate" in any manner or form, in any spelling variants, alone or with other terms; 0 iii. Using the Allstate "cupped hands" design mark and/or the Allstate slant-"a" design mark in any manner or form; iv. Performing any other acts that are likely to lead the public to believe that goods or services sold or offered by Defendants are in any manner licensed, sponsored, or authorized by Allstate; B. Requiring Defendants to terminate use of and/or transfer to Allstate the domain names < and <
14 Case :-cv-00-nc Document Filed 0// Page of C. Awarding the following: i. Disgorgement of all profits and advantages gained from or in connection with Defendants' use of the mark "Allstate" and/or use of the websites < and < ii. iii. iv. All damages sustained by Allstate in an amount to be proven at trial; Treble damages; The costs of this action; v. Reasonable attorneys fees; vi. Pre- and Post-Judgment Interest as allowed by law; Los Angeles, California 00 Telephone: D. Granting such other and further relief as the Court deems just and proper. DEMAND FOR JURY TRIAL Pursuant to Rule of the Federal Rules of Civil Procedure, Plaintiff demands a trial by jury on all issues triable by right to a jury. Dated: January, 0 Respectfully submitted, By: /s/ Peter L. Haviland Peter L. Haviland Scott S. Humphreys BALLARD SPAHR LLP Los Angeles, CA 00 Telephone: ( 0-00 Facsimile: ( 0-0 Attorneys for Plaintiff ALLSTATE INSURANCE COMPANY
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