Trademark Trial and Appeal Board Electronic Filing System. http://estta.uspto.gov ESTTA Tracking number: ESTTA1113776 Filing date: 02/11/2021
IN THE UNITED STATES PATENT AND TRADEMARK OFFICE BEFORE THE TRADEMARK TRIAL AND APPEAL BOARD Proceeding 91246479 Party Plaintiff Paramount International Export Ltd Correspondence DANIELLE CRIONA Address ROLL LAW GROUP PC 11444 WEST OLYMPIC BLVD, 7TH FLOOR LOS ANGELES, CA 90064 UNITED STATES Primary Email: [email protected] 310-966-8771
Submission Plaintiff's Notice of Reliance Filer's Name Michael M. Vasseghi Filer's email [email protected], [email protected] Signature / Michael M. Vasseghi / Date 02/11/2021 Attachments Not Reliance.pdf(466255 bytes ) Chia Affidavit -redacted-public version - 1 of 2.pdf(5112008 bytes ) Chia Affidavit redacted-public version - 2 of 2.pdf(6071194 bytes ) IN THE UNITED STATES PATENT AND TRADEMARK OFFICE TRADEMARK TRIAL AND APPEAL BOARD
PARAMOUNT INTERNATIONAL Opposition No. 91246479 EXPORT, LTD., Mark: FIJI FIRE Opposer, Application Ser. No.: 88003425 v.
JENNIFER M. VAN WALDEN TA FIJI FIRE HOT SAUCE,
Applicant.
NOTICE OF RELIANCE
{3167545.1}
Opposer PARAMOUNT INTERNATIONAL EXPORT, LTD. (“PARAMOUNT”) submits of record in connection with this opposition proceeding copies of the documents set
forth below.
{3167545.1}
EXHIBIT DATE DOCUMENT RELEVANCE
1. 2021-02-05 TSDR Printout of status of FIJI mark, Registration Number Ownership of trademark 2703620.
2. 2021-02-05 TSDR Printout of status of FIJI (stylized) mark, Ownership of trademark Registration Number 3282520.
Date: February 11, 2021 PARAMOUNT INTERNATIONAL EXPORT, LTD.
By: / Michael M. Vasseghi, Esq. / Michael M. Vasseghi, Esq. 11444 West Olympic Blvd., 7th Floor Los Angeles, California 90064 Telephone: (310) 966-8400 Facsimile: (310) 966-8810 [email protected]
3
EXHIBIT 1 2/5/2021 Status Search SN 2703620
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Mark: FIJI
US Serial Number: 76162278 Application Filing Date: Nov. 10, 2000
US Registration Number: 2703620 Registration Date: Apr. 08, 2003
Register: Principal
Mark Type: Trademark
TM5 Common Status LIVE/REGISTRATION/Issued and Active Descriptor: The trademark application has been registered with the Offic
Status: The registration has been renewed.
Status Date: Apr. 30, 2013
Publication Date: Jan. 14, 2003
Mark Information
Mark Literal Elements: FIJI
Standard Character Claim: No
Mark Drawing Type: 1 - TYPESET WORD(S) /LETTER(S) /NUMBER(S)
Acquired Distinctiveness In whole Claim:
Related Properties Information
Claimed Ownership of US 2164851 Registrations:
Goods and Services
Note: The following symbols indicate that the registrant/owner has amended the goods/services: Brackets [..] indicate deleted goods/services; Double parenthesis ((..)) identify any goods/services not claimed in a Section 15 affidavit of incontestability; and Asterisks *..* identify additional (new) wording in the goods/services. For: NATURAL, SPRING AND ARTESIAN WATER FOR DRINKING Privacy - Terms https://tsdr.uspto.gov/#caseNumber=2703620&caseSearchType=US_APPLICATION&caseType=DEFAULT&searchType=documentSearch 1/3 2/5/2021 Status Search SN 2703620 International Class(es): 032 - Primary Class U.S Class(es): 045, 046, 048
Class Status: ACTIVE
Basis: 1(a)
First Use: May 16, 1997 Use in Commerce: May 17, 1997
Basis Information (Case Level)
Filed Use: Yes Currently Use: Yes
Filed ITU: No Currently ITU: No
Filed 44D: No Currently 44E: No
Filed 44E: No Currently 66A: No
Filed 66A: No Currently No Basis: No
Filed No Basis: No
Current Owner(s) Information
Owner Name: FIJI WATER COMPANY PTE. LTD.
Owner Address: 11444 WEST OLYMPIC BLVD., 10TH FLOOR LOS ANGELES, CALIFORNIA UNITED STATES 90064
Legal Entity Type: PRIVATE COMPANY LIMITED BY SHARES State or Country Where SINGAPORE Organized:
Attorney/Correspondence Information
Attorney of Record
Docket Number: 106340
Correspondent
Correspondent LATUNDA POWELL, TRADEMARK ADMINISTRATOR Name/Address: ROLL LAW GROUP P.C. 11444 W. OLYMPIC BLVD., 10TH FL. LOS ANGELES, CALIFORNIA UNITED STATES 90064
Domestic Representative - Not Found
Prosecution History
Date Description Proceeding Number
Jan. 13, 2021 AUTOMATIC UPDATE OF ASSIGNMENT OF OWNERSHIP
Jul. 30, 2018 NOTICE OF SUIT
Mar. 23, 2018 NOTICE OF SUIT
Apr. 10, 2014 COUNTERCLAIM OPP. NO. 999999 214967
Jan. 06, 2014 NOTICE OF SUIT
Apr. 30, 2013 NOTICE OF ACCEPTANCE OF SEC. 8 & 9 - MAILED
Apr. 30, 2013 REGISTERED AND RENEWED (FIRST RENEWAL - 10 YRS) 66607 Privacy - Terms https://tsdr.uspto.gov/#caseNumber=2703620&caseSearchType=US_APPLICATION&caseType=DEFAULT&searchType=documentSearch 2/3 2/5/2021 Status Search SN 2703620 Apr. 30, 2013 REGISTERED - SEC. 8 (10-YR) ACCEPTED/SEC. 9 GRANTED 66607
Apr. 26, 2013 CASE ASSIGNED TO POST REGISTRATION PARALEGAL 66607
Apr. 08, 2013 TEAS SECTION 8 & 9 RECEIVED
Apr. 08, 2013 TEAS CHANGE OF CORRESPONDENCE RECEIVED
Jun. 02, 2008 ATTORNEY/DOM.REP.REVOKED AND/OR APPOINTED
Jun. 02, 2008 TEAS REVOKE/APP/CHANGE ADDR OF ATTY/DOM REP RECEIVED
May 07, 2008 REGISTERED - SEC. 8 (6-YR) ACCEPTED & SEC. 15 ACK. 70132
Apr. 29, 2008 ASSIGNED TO PARALEGAL 70132
Apr. 10, 2008 TEAS SECTION 8 & 15 RECEIVED
Feb. 11, 2008 CASE FILE IN TICRS
May 10, 2006 AUTOMATIC UPDATE OF ASSIGNMENT OF OWNERSHIP
Apr. 08, 2003 REGISTERED-PRINCIPAL REGISTER
Jan. 14, 2003 PUBLISHED FOR OPPOSITION
Dec. 25, 2002 NOTICE OF PUBLICATION
Nov. 12, 2002 APPROVED FOR PUB - PRINCIPAL REGISTER
Oct. 28, 2002 CORRESPONDENCE RECEIVED IN LAW OFFICE
Oct. 28, 2002 PAPER RECEIVED
Sep. 05, 2002 FINAL REFUSAL MAILED
Jun. 10, 2002 ASSIGNED TO EXAMINER 73730
Oct. 02, 2001 CORRESPONDENCE RECEIVED IN LAW OFFICE
Oct. 09, 2001 CORRESPONDENCE RECEIVED IN LAW OFFICE
Apr. 02, 2001 NON-FINAL ACTION MAILED
Mar. 27, 2001 ASSIGNED TO EXAMINER 73726
TM Staff and Location Information
TM Staff Information - None File Location
Current Location: GENERIC WEB UPDATE Date in Location: Apr. 30, 2013
Assignment Abstract Of Title Information
Proceedings
Privacy - Terms https://tsdr.uspto.gov/#caseNumber=2703620&caseSearchType=US_APPLICATION&caseType=DEFAULT&searchType=documentSearch 3/3 EXHIBIT 2 2/5/2021 Status Search SN 3,282,520
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Mark: FIJI
US Serial Number: 78718517 Application Filing Date: Sep. 22, 2005
US Registration Number: 3282520 Registration Date: Aug. 21, 2007
Register: Principal
Mark Type: Trademark
TM5 Common Status LIVE/REGISTRATION/Issued and Active Descriptor: The trademark application has been registered with the Offic
Status: The registration has been renewed.
Status Date: Sep. 22, 2017
Publication Date: Jun. 05, 2007
Mark Information
Mark Literal Elements: FIJI
Standard Character Claim: No
Mark Drawing Type: 5 - AN ILLUSTRATION DRAWING WITH WORD(S) /LETTER(S)/ NUMBER(S) INSTYLIZED FORM
Color(s) Claimed: Color is not claimed as a feature of the mark.
Acquired Distinctiveness In whole Claim:
Related Properties Information
Claimed Ownership of US 2703620, 2703802, 2714973 and others Registrations:
Goods and Services
Note: Privacy - Terms https://tsdr.uspto.gov/#caseNumber=3,282,520&caseSearchType=US_APPLICATION&caseType=DEFAULT&searchType=statusSearch 1/4 2/5/2021 Status Search SN 3,282,520 The following symbols indicate that the registrant/owner has amended the goods/services: Brackets [..] indicate deleted goods/services; Double parenthesis ((..)) identify any goods/services not claimed in a Section 15 affidavit of incontestability; and Asterisks *..* identify additional (new) wording in the goods/services. For: Drinking Water; Natural Artesian Water
International Class(es): 032 - Primary Class U.S Class(es): 045, 046, 048
Class Status: ACTIVE
Basis: 1(a)
First Use: May 17, 1997 Use in Commerce: May 17, 1997
Basis Information (Case Level)
Filed Use: Yes Currently Use: Yes
Filed ITU: No Currently ITU: No
Filed 44D: No Currently 44E: No
Filed 44E: No Currently 66A: No
Filed 66A: No Currently No Basis: No
Filed No Basis: No
Current Owner(s) Information
Owner Name: FIJI WATER COMPANY PTE. LTD.
Owner Address: 11444 WEST OLYMPIC BLVD., 10TH FLOOR LOS ANGELES, CALIFORNIA UNITED STATES 90064
Legal Entity Type: PRIVATE COMPANY LIMITED BY SHARES State or Country Where SINGAPORE Organized:
Attorney/Correspondence Information
Attorney of Record
Attorney Name: Danielle M Criona Docket Number: 107059
Attorney Primary Email [email protected] Attorney Email Authorized: Yes Address:
Correspondent
Correspondent Danielle M Criona Name/Address: Roll Law Group P.C. 11444 W. OLYMPIC BLVD., 7TH FLOOR LOS ANGELES, CALIFORNIA UNITED STATES 90064
Correspondent e-mail: [email protected] [email protected] Correspondent e-mail Yes Authorized:
Domestic Representative - Not Found
Prosecution History Privacy - Terms https://tsdr.uspto.gov/#caseNumber=3,282,520&caseSearchType=US_APPLICATION&caseType=DEFAULT&searchType=statusSearch 2/4 2/5/2021 Status Search SN 3,282,520 Date Description Proceeding Number
Jan. 13, 2021 AUTOMATIC UPDATE OF ASSIGNMENT OF OWNERSHIP
Jul. 30, 2018 NOTICE OF SUIT
Mar. 23, 2018 NOTICE OF SUIT
Sep. 22, 2017 NOTICE OF ACCEPTANCE OF SEC. 8 & 9 - E-MAILED
Sep. 22, 2017 REGISTERED AND RENEWED (FIRST RENEWAL - 10 YRS) 69615
Sep. 22, 2017 REGISTERED - SEC. 8 (10-YR) ACCEPTED/SEC. 9 GRANTED 69615
Sep. 22, 2017 CASE ASSIGNED TO POST REGISTRATION PARALEGAL 69615
Aug. 15, 2017 TEAS SECTION 8 & 9 RECEIVED
Apr. 10, 2014 COUNTERCLAIM OPP. NO. 999999 214967
Jan. 06, 2014 NOTICE OF SUIT
Sep. 19, 2012 NOTICE OF ACCEPTANCE OF SEC. 8 & 15 - MAILED
Sep. 19, 2012 REGISTERED - SEC. 8 (6-YR) ACCEPTED & SEC. 15 ACK. 74886
Sep. 19, 2012 CASE ASSIGNED TO POST REGISTRATION PARALEGAL 74886
Aug. 23, 2012 TEAS SECTION 8 & 15 RECEIVED
Aug. 22, 2012 TEAS CHANGE OF CORRESPONDENCE RECEIVED
Aug. 21, 2007 REGISTERED-PRINCIPAL REGISTER
Jun. 05, 2007 PUBLISHED FOR OPPOSITION
May 23, 2007 ASSIGNED TO EXAMINER 83257
May 16, 2007 NOTICE OF PUBLICATION
Apr. 02, 2007 LAW OFFICE PUBLICATION REVIEW COMPLETED 78413
Apr. 02, 2007 APPROVED FOR PUB - PRINCIPAL REGISTER
Mar. 30, 2007 PREVIOUS ALLOWANCE COUNT WITHDRAWN
Mar. 30, 2007 APPROVED FOR PUB - PRINCIPAL REGISTER
Mar. 30, 2007 TEAS/EMAIL CORRESPONDENCE ENTERED 78413
Mar. 30, 2007 CORRESPONDENCE RECEIVED IN LAW OFFICE 78413
Mar. 30, 2007 ASSIGNED TO LIE 78413
Feb. 23, 2007 TEAS RESPONSE TO OFFICE ACTION RECEIVED
Feb. 21, 2007 ATTORNEY/DOM.REP.REVOKED AND/OR APPOINTED
Feb. 21, 2007 TEAS REVOKE/APP/CHANGE ADDR OF ATTY/DOM REP RECEIVED
Oct. 30, 2006 REPORT COMPLETED SUSPENSION CHECK CASE STILL SUSPENDED 70138
Oct. 25, 2006 AUTOMATIC UPDATE OF ASSIGNMENT OF OWNERSHIP
Mar. 27, 2006 LETTER OF SUSPENSION MAILED
Mar. 24, 2006 SUSPENSION LETTER WRITTEN 80802
Mar. 22, 2006 ASSIGNED TO EXAMINER 80802
Sep. 29, 2005 NEW APPLICATION ENTERED IN TRAM
TM Staff and Location Information
TM Staff Information - None Privacy - Terms https://tsdr.uspto.gov/#caseNumber=3,282,520&caseSearchType=US_APPLICATION&caseType=DEFAULT&searchType=statusSearch 3/4 2/5/2021 Status Search SN 3,282,520 File Location
Current Location: GENERIC WEB UPDATE Date in Location: Sep. 22, 2017
Assignment Abstract Of Title Information - Click to Load
Proceedings - Click to Load
Privacy - Terms https://tsdr.uspto.gov/#caseNumber=3,282,520&caseSearchType=US_APPLICATION&caseType=DEFAULT&searchType=statusSearch 4/4 CERTIFICATE OF SERVICE
I, Susan Bryant, hereby certify that a copy of this NOTICE OF RELIANCE has been served upon attorney for Applicant:
THOMAS E LEES THOMAS E LEES LLC 90 PHOADS CENTER DRIVE DAYTON, OH 45458 [email protected] [email protected] [email protected] Phone: 937-610-9888 by e-mail on this 11th day of February, 2021.
/ Susan Bryant / SUSAN BRYANT ROLL LAW GROUP PC 11444 West Olympic Boulevard Los Angeles, California 90064-1557 Telephone: (310) 966-8400 Facsimile: (310) 966-8810
4 IN THE UNITED STATES PATENT AND TRADEMARK OFFICE TRADEMARK TRIAL AND APPEAL BOARD
PARAMOUNT INTERNATIONAL Opposition No. 91246479 EXPORT, LTD., Mark: FIJI FIRE Opposer, Application Ser. No.: 88003425 v.
JENNIFER M. VAN WALDEN TA FIJI FIRE HOT SAUCE,
Applicant.
AFFIDAVIT OF CLARENCE CHIA - VOLUME 1 OF 2
I, Clarence Chia, declare as follows:
1. I am the Senior Vice President of Marketing, eCommerce and Direct to Consumer for Fiji Water Company LLC (“FIJI Water”). I have personal knowledge of the facts set forth herein and provide this testimony in support of Opposer’s Opposition to the Application of
Jennifer M. Van Walden for the FIJI FIRE standard character mark (“FIJI FIRE Mark”).
2. Fiji Water Company PTE Ltd. (“Opposer”) is the owner of the registered marks at issue in this case, namely FIJI (Reg. No. 2,703,620) and FIJI (stylized) (Reg. No. 3,282,520)
(collectively, the “FIJI Marks”).
3. FIJI Water has assigned its rights and interests in the FIJI Marks to Opposer.
Opposer has, in turn, licensed the rights for the FIJI Marks back to FIJI Water.
4. I have been employed by FIJI Water for approximately 10 years and with one of its affiliates for another 5 years. I am responsible for overseeing all aspects of FIJI Water’s marketing operations, and some of FIJI Water’s sales operations.
{3157531.1} 1 5. Opposer owns the standard character trademark FIJI (Registration No. 2,703,620) for natural, spring and artesian water for drinking, in Class 32.
6. Opposer owns the stylized trademark FIJI (Registration No. 3,282,520) for drinking water, natural artesian water, in Class 32.
7. A 24 pack of FIJI brand water, in the 500 ml size, sells for approximately $37.00 a case on the FIJI Water website. Single bottle servings of FIJI brand water is also available and are usually sold in the refrigerated section of stores, in restaurants and bars. The retail price for a single 500 ml bottle can vary depending on location, but ranges from about $1 to $3.
8. FIJI brand water is a relatively inexpensive product, and is an impulse purchase by ordinary consumers.
9. Sales of FIJI brand water in the United States commenced in 1997.
10. Since 1997 FIJI Water has been extensively producing, marketing, selling, and distributing its natural artesian bottled drinking water under the FIJI Marks.
11. FIJI Water uses the distinctive and famous FIJI Marks in all of its advertising and promotional activities.
12. FIJI Water established FIJI brand water's market presence in the United States through extensive internet advertising, billboard, and print in both trade and consumer publications. FIJI brand water has gained worldwide recognition, in part, through “A-lister”
Hollywood celebrities and musicians. Attached hereto as Exhibit A are examples of FIJI brand water’s various forms of advertising, which include online, print, and billboard advertising.
13. FIJI brand water is advertised on a variety of social media platforms, including
Facebook, Instagram, and Twitter. FIJI Water’s Facebook page has recorded almost seven hundred thousand “likes.” FIJI Water utilizes brand influencers to promote its brand on social
{3157531.1} 2 media sites. Attached hereto as Exhibit B are some examples of several influencer’s posts.
Attached hereto as Exhibit C are examples of FIJI water brand’s advertising on Facebook.
14. FIJI Water has also pursued direct marketing efforts to, and FIJI brand water is
sold in grocery, gourmet food, health food, and other specialty stores, delicatessens, restaurants,
hotels, museums, movie theatres, nightclubs, and health clubs throughout the world. In addition,
FIJI Water sells FIJI brand water directly through its website at https://store.fijiwater.com.
15. In addition to advertising and direct marketing, FIJI Water sponsors many
important and high profile charity events and contributes a portion of revenues from the sale of its FIJI brand water to educational programs, scholarships, and infrastructure improvements in the Islands of Fiji. The philanthropic work in the Islands of Fiji is carried out by the FIJI Water
Foundation (“FWF”). FWF’s work includes providing school grants, conservation efforts,
emergency relief and infrastructure rebuilding.
16. Fiji Water has sponsored or been affiliated with numerous events throughout the
United States including, but not limited to the Lacoste Desert Pool Party at Coachella from 2012
– 2013; amfAR New York Gala from 2012 – 2015 and 2017; Art of Elysium Heaven Gala, Los
Angeles, 2012; The Gotham Independent Film Awards, New York, from 2012 – 2018; Film
Independent Spirit Awards from 2012 – 2019; Screen Actor Guild Awards from 2012 – 2019;
The Peggy Siegal Company’s Screening of “JEFF Who Lives at Home”, New York, 2012;
Rodarte Runway Shows, New York, from 2012 – 2018; Marchesa Runway Shows, New York, from 2012 – 2016; “To the Wonder” Premiere, Los Angeles, 2013; “The Butler” Premiere, Los
Angeles, 2013; The Weinstein Company SAG Awards Party in 2013; Pre-Oscar Sony Pictures
Classic, Los Angeles, in 2014; The Weinstein Company Golden Globes party, Los Angeles from
2014 – 2017; amfAR LA Inspiration Gala from 2014, 2014, 2015 and 2017; OCRF Super
{3157531.1} 3 Saturday, Hamptons and Los Angeles from 2014 – 2016; New York Magazine Vulture Festival,
New York, in 2014 and 2018; STK Supper Suite for Tribeca Film Festival and DC Creative
Coalition Gala, New York and Washington DC, 2014; The Weinstein Company’s Premiere of
“Big Eyes”, 2014; Darin Pfeiffer presents “22 Jump” Street Premiere, New York, 2014; Darin
Pfeiffer presents “White Bird” in a Blizzard Screening, New York and Los Angeles, 2014; The
Cinema Society Presents “Guardians of the Galaxy”, New York, 2014; Bounce Sporting Club’s
World Cup Viewing Party, New York, 2014; Kiehl’s LifeRide for amfAR from 2014 – 2015;
The Hollywood Reporter’s Women in Entertainment Breakfast, Los Angeles, from 2015 – 2018;
American Cinematheque, Los Angeles, 2015; Film Society of Lincoln Center New York Film
Festival, New York, 2015 – 2017; The Weinstein Company Pre-Oscar Party, Los Angeles in
2015 – 2016; Variety’s Pre-Emmy Party, Los Angeles, 2015; Critic’s Choice Movie Awards,
Los Angeles, from 2015 – 2019; Spring Studios New York Fashion Week, New York, 2015; The
US Edition of the Lole White Tour, 2015; Emmy Awards Red Carpet and Governors Ball, Los
Angeles, from 2015 – 2019; The Weinstein Company’s Premiere of “Burnt”, New York, 2015;
Roundabout Theatre’s Opening Night of “Old Times” and “Therese Raquin”, New York, 2015;
Veuve Clicquot Polo Classic, Los Angeles, 2015; The Cinema Society Presents “Irrational Man”
Screening, New York, 2015; The Cinema Society Presents “Results” Screening, New York,
2015; American Film Institute Festival, Los Angeles, 2015; HFPA Golden Globe Awards, Los
Angeles, from 2015 – 2019; Miss Golden Globe Party, Los Angeles, from 2015 – 2019; Jason
Wu Runway Shows, New York, from 2015 – 2018; Altuzarra Runway Shows, New York, from
2015 – 2017; Rachel Zoe Fashion Presentation, New York, from 2015 – 2016; Darin Pfeiffer presents “Mike and Dave Need Weeding Dates” Screening, Los Angeles, 2016; Glamour
Magazine’s Women Rewriting Hollywood Luncheon, Park City, 2016; The Cinema Society
{3157531.1} 4 Presents “Marvel’s Captain America: Civil War” Screening, New York, 2016; The Cinema
Society Presents “Mother’s Day” Screening, New York, 2016; Gisele Bundchen’s Spring Fling
Pre Met Event, New York, 2016; 9th Annual Women in Film Pre-Oscar Cocktail Party, Los
Angeles, 2016; The Hollywood Reporter’s 4th Annual Oscar Nominees Night, Los Angeles,
2016; Republic Records Grammy Party in 2016 and 2019; Republic Records VMA Party, New
York and Los Angeles from 2016 – 2017; 70th Annual Tony Awards and Creative Arts Awards,
New York in 2016; Recording Academy 59th Annual Grammy Awards in 2016; Opening
Ceremony Runway Shows, New York, from 2016 – 2019; Town & Country Greenwich Polo
Event, Connecticut in 2016; Daily Front Row Fashion Media Awards, New Yok, 2016 and 2018;
44th AFI Life Achievement Award Gala Tribute, Los Angeles, 2016; Surf Lodge Wellness
Program, New York, from 2016 – 2017; Tracy Anderson 59th Street Studio Opening Party, New
York in 2017; Nobu’s 20th anniversary Event, New York, 2017; Alexander Wang Runway
Shows, New York, 2017 – 2019; REVOLVE in the Hamptons, New York, 2017; Raf Simons
S/S 18 Mens Runway Show, New York, 2017; Rebecca Minkoff Runway Show, New York,
2017; Darin Pfeiffer presents “Colossal” Screening, New York, 2017; The Cinema Society
Presents “Wakefield” Screening, New York, 2017; “Wind River” Premiere, Los Angeles, 2017;
3.1 Phillip Lim Runway Shows, New York, from 2017 – 2019; InStyle Magazine Awards, Los
Angeles, 2017 – 2018; REVOLVE Awards, Los Angeles, from 2017 – 2018; Billboard’s Women
in Music from 2017 – 2018; HFPA Golden Globe Celebration from 2018 – 2019; REVOLVE
Around the World, Los Angeles and New York, 2018; Entertainment Weekly Pre-Emmy Party,
Los Angeles, 2018; GQ Magazine Men of the Year Party and GQ Live, Los Angeles, 2018; The
Cinema Society Presents “Solo: A Star Wars Story” Screening, New York, 2018; Chase Weber’s
333 World Tour, Los Angeles and New York in 2018; Brunch and Burn with Erin Oprea,
{3157531.1} 5 Nashville, 2018; Self Portrait Runway Show, New York, 2018; Oscar de la Renta Runway
Shows, New York, from 2018 – 2019; The Cinema Society Presents “Mary Poppins Returns”
Screening, New York, 2018; Lionsgate “Robin Hood” Premiere, New York, 2018; Darin Pfeiffer presents “Wildlife” Screening, Los Angeles, 2018; Brandon Maxwell Runway Show, New York,
2019; Jonathan Cohen Runway Show, New York, 2019; John Elliot Runway Show, New York,
2019; Moschino Runway Show, Los Angeles, 2018 – 2019; MONSE Runway Shows, New
York, 2018 – 2019; FUNKSHION The Retreat, Austin, 2019; The Cinema Society Presents
“Captain Marvel” Screening, New York, 2019; Daily Front Row Fashion LA Awards, Los
Angeles, 2019; Good+Foundation 2019 Bash, New York, 2019; and the ATX Television
Festival, Austin, 2019.
17. FIJI brand water was the official water of the Film Independent Spirit Awards from 2013-2020, the Screen Actor Guild Awards from 2010-2020, the Critic’s Choice Movie
Awards from 2015-2020, the 70th Annual Tony Awards and Creative Art Awards in 2016, the
Recording Academy GRAMMY Awards in 2017, the Emmy Awards Red Carpet and Governors
Ball from 2014-2020, and the Annual Golden Globe Awards from 2015-2019.
18. FIJI Water's philosophy is to support worthwhile local community efforts and simultaneously share advice about healthy water.
19. On October 27, 2004, former Secretary of State Colin Powell presented the 2004
Award for Corporate Excellence to FIJI Water in Washington, DC. The award recognizes U.S. firms for their outstanding corporate citizenship, innovation and exemplary business practices, and for exhibiting the qualities of conscience, character and integrity.
20. In connection with the marketing of FIJI brand water in the United States, FIJI
Water also arranges for strategic placement of the unique FIJI brand water bottle and label
{3157531.1} 6 design in television shows and motion pictures. This product placement is a part of FIJI Water's strategy to establish and maintain in the mind of consumers that FIJI brand water is a status product.
21. FIJI® Brand water has been in television shows including “CSI New York,”
“Will & Grace,” “The Apprentice,” “Two and a Half Men,” “Keeping up with the Kardashians,”
“House of Cards,” “Fuller House,” “Younger,” “Girlfriend’s Guide to Divorce,” “Mom,”
“Billions,” “Pretty Little Liars,” “Are you There, Chelsea?,” “Ben and Kate,” “The Biggest
Loser,” “Dancing with the Stars,” “Game Change,” Hot in Cleveland,” “I Hate My Teenage
Daughter,” “Weeds,” “The Exes,” “Smash,” “The Office.” “90210,” Betas,” “Californication,”
The Crazy Ones,” “Dallas,” “Hello Ladies,” “Homeland,” “How I Met Your Mother,” “The
League,” “Necessary Roughness,” “Necessary Roughness,” “The New Normal,” “The
Newsroom,” “Parenthood,” Ray Donovan,” “Top Chef Seattle,” “Veep,” “Dream School,”
“Episodes,” “Girls,” “Inside Job,” “House of Lies,” “Hello Ladies: The Movie,” “Undateable,”
“Survivor’s Remorse,” “The Affair,” “Ballers,” “Blunt Talk,” “Black-ish,””Candidly Nicole,”
“Casual,” “Clipped,” “Kingdom,” “Nashville,” “Scream,” “Better Things,” “Bull,” “Chasing
Cameron,” “Chasing Destiny,” “Gilmore Girls,” “The Great Indoors,” “Insecure,” “Love,”
“Orange is The New Black,” “Roadies,” “Silicon Valley,” “Supergirl,” “This is Us,” “UnReal,”
“American Housewife,” “Big Little Lies,” “Difficult People,” “Portlandia,” “Search Party,” “The
Defiant Ones,” “Alone Together,” “Atlanta,” “Atypical,” “Champions,” “Dear White People,”
“Yellowstone”, “Famous in Love,” “Happy Together,” “Nobodies,” “Queen America,” “Queen
Sugar,” “The Contender,” “Broad City,” “Fam,” “Grace and Frankie,” “SMILF,” “The Fix,”
“Boomerang,” “Queer Eye,” and “She’s Gotta Have it.”
{3157531.1} 7 22. FIJI® Brand water has also been in motion pictures including “Some Girl,” “Are you Here,” “Life Partners,” “How to be Single,” “Mother’s Day,” and “Birdman or the
Unexpected Virtue of Ignorance,” “A Star is Born,” “Book Club,” “I Feel Pretty,” “Irreplaceable
You,” “Ocean’s 8,” “TAG,” and “What Men Want.”
23. President Obama was photographed drinking FIJI brand water during the 2008
United States Presidential election. In November 2017 President Trump sipped FIJI brand water during a press conference. The manner in which he drank from the bottle, became a much talked
about moment. The video of the President Trump’s “awkward water moment” has been viewed
on YouTube more than 2.3 million times. https://www.youtube.com/watch?v=0tkyqjvMrnU
24. Hip-Hop Artist and Fashion Designer, Kanye West, was the musical guest on
“Saturday Night Live” in September 2018 he had Rapper Lil Pump on with him to perform “I
Love It” while wearing a FIJI Water bottle costume.
https://www.youtube.com/watch?v=IL_h9m_-HlE
25. In 2019 during the “Bottle Cap Challenge,” Singer Lizzo made her attempt using
a FIJI Water bottle and posted to her Instagram account. This video was then picked up by
additional outlets such as Billboard, Harper’s Bazaar and Yahoo! (IG Video:
https://www.instagram.com/p/BzqKL01BTQR/?hl=en )
26. As a result of extensive marketing, sales and promotional efforts, that span more
than 18 years, FIJI Water brand water is now the number one premium brand of bottled water in
the United States.
A spreadsheet showing sales for
FIJI brand water, for each year from 2010 to 2020 is attached hereto as Exhibit D.
{3157531.1} 8 27. In 1999, FIJI brand water was awarded the American Tasting Award of
Excellence by the National Board of the American Tasting Institute.
28. In its March 2004 edition, Men's Health Magazine rated 10 premium bottled waters and FIJI brand water was ranked first, with a score of 19 out of a possible 20.
29. In addition, the unique design and pure quality of FIJI brand water has been the subject of articles in many major U.S. publications, including People magazine, The New York
Times, Glamour, US Weekly, USA Today, Men’s Health, Marie Claire, Variety and The Wall
Street Journal. Attached hereto as Exhibit E are examples of some non-solicited third party articles about FIJI brand water.
30. In 2015, FIJI Water presented the U.S. edition of The Lolë White Tour, a series of yoga events around the world. The annual Lolë White Tour was launched in 2011 by Montreal- based women’s active-wear and lifestyle brand Lolë, with the goal of building a global wellness movement. Since then, Lolë has united over 30,000 yoga lovers around the world.
31. In 2017, the electronica synth-pop band, City Owl - best known for their six-time
Platinum hit single “Fireflies” - wrote a song in which FIJI brand water was called out in the song’s chorus. In fact, the song is entitled “FIJI Water”. The official video of the song has been viewed more than 2.5 million times on YouTube. https://www.youtube.com/watch?v=DYRtvMIWXzE
32. In 2019, hop-hop recording artist, Peewee Longway also recorded a song about
FIJI brand water, also called “FIJI Water.” The official video of the song has been viewed more than 9.4 million times on YouTube. https://www.youtube.com/watch?v=QEzzjbC-fcw
33. Hip-hop recording artist, Quavo, released the official music video for his song
“How Bout That?” in 2018 with FIJI Water product and imagery on display throughout the
{3157531.1} 9 video. This music video has now garnered more than 14.3 million views on YouTube.
https://www.youtube.com/watch?v=EBjbtlhTCXc
34. Since 2005 FIJI Water has expended over in the marketing,
advertising, sales and promotion of its FIJI brand water product making it one of the leaders in
the worldwide bottled water industry. All of that amount was spent in the United States.
Documents showing the amount of advertising and marketing spend for the FIJI brand of water,
is attached hereto as Exhibits F and G.
35. In 2015 FIJI Water launched its “Untouched” television marketing
campaign which continues to run as of today. It consists of numerous, 15-second spots which
tell the story behind FIJI brand water’s unique mineral profile and refreshing taste. To date there
have been six different commercials made, with the most recent version being released in
September 2020.
36. FIJI Water’s “Untouched” commercial has run on numerous television networks including ABC, ABC Family, AMC, Bravo, CBS, Comedy Central, CW, Discovery, E!, ESPN,
ESPN 2, Esquire, Food Network, Fox, FX, IFC, LOGO, MTV, NBC, Pivot, POP, Sundance
Channel, Tennis Channel and USA and has run during programs, including but limited to, The
Bachelorette, Jimmy Kimmel Live, Big Brother, The Late Late Show, The Daily Show, Next
Top Model, Alaska Bush People, Keeping up with the Kardashians, American Ninja Warrior,
American Idol, The Mindy Project, Last Comic Standing, Saturday Night Live, The Tonight
Show, and The Voice.
37. Financial data for competitors is difficult to obtain. However,
{3157531.1} 10 38. The brand awareness for FIJI brand water i
like FIJI brand water. Furthermore, consumers have a higher brand affinity for FIJI and higher advertisement awareness of FIJI's ads than any of its competitors. Advertisement awareness is a consumer's ability to recall seeing any advertisement from a brand. Attached hereto as Exhibit His an internal presentation highlighting FIJI brand water's competitive edge.
39. Opposer's FIJI Marks are used exclusively with FIJI brand water. I am not aware of any other beverage company in the lJ.S. that uses FIJI as a brand name for its product.
40. Opposer does not license the FIJI Marks to other companies for use on other products .,
I declare under penalty of perjury under the Iaws of the United States of America that the foregoing is true and correct and that this declaration ｷ｡ ｾ ･｣ｵｴ･､＠ in Los I By:
February 11, 2021
{3157531.1} 11 ¡¢£¤£¥ A CONFIDENTIAL
¦§¨© © FIJI Water’s Influencer Campaign Highlights: #JustAddFIJI
INFLUENCER CATEGORIES: Fitness | Premium Lifestyle | Epicurean DEDICATED PLATFORMS: Instagram KEY DETAILS: 7 Influencers, August 2019 – March 2020, $260,000 budget
Evan Betts Charlotte McKinney Edgar Castrejon @evanfitness_nyc @charlottemckinney @edgarraw IG: 50.1 K Followers IG: 1.4MM Followers IG: 162K Followers
1 FIJI Water’s Influencer Program: #JustAddFIJI
Afiya Bennett Danielle Bernstein Julie ‘JAW$’ Nelson Conrad Louis @afiyabennett @weworewhat @jawsnelson @conradlouis IG: 231K Followers IG: 2.5M Followers IG: 36.1K Followers IG: 148K Followers
2 Additional Posts
3 C ｾ＠ FIJI Water {Default) 0 W Published by Sprinklt e · Dvcember 22, 2016 0 Silver and gold complement the finest water on Earth• @jack.designs .. -., ,.. f * * ＮＮ "ｾ＠ • • "... • /"" JI .. " ... .. " ..,,t>- :: . • .. * ,...... \... : ｾ＠ .. >t
• • .. * .. • * \. . . .,. * _____* ...... • .. .. 14 4,759 People ｒ ｾ｡｣ｨ･ ､＠ E.ngagamants Boost Post oo·· 4.6K 40 Comments 114 Shares
rD like 0 Comment 1¢ Share
Most Relevant • G Comment as FIJI Water
Doren ThatsMe Best H20 by far Like · Reply Mess-ige · 4y
cavavou vakacagicagl Best water EVER Like Reply Message 4y ｾ＠ FIJI Water (Default) 0 W Published by Salesforcc M.arketlng Cloud 0 · December 19, 2017 · 0 Earth's Finest Water"' deserves a sea glass coaster to match.
17 336 People Roached E1\9a9011ants 1.1.1+111 oo·· 2s9 13 Comments 34 Shares
rb like 0 Commrnt ｾ ｓｨ｡ｲ･＠
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Filtration Ptoducts The articles listed to this page are very interesting... Get more news at Filtration-Products.com
FILTRATION·PRODUCTS.COM Filtration Produc ts, Equipment, Supplies & Latest Industry / Market Data
like Reply Message 3y
oanlco Lastlm.ado What about Fiji water in the Philippines? like Reply Message 3y Edited
Jessica Bradney Jamie You should get some :; Like Reply Message 3y A FIJI Water {Default) o W Published by Salestorce Marketing Cloud e Novemb0< 29, 2018 0 Wherever you drink FIJI Water, you'll always k.now it began as tropical rain above the Fijian islands. #wheresyourwatertrom
167 95 People Reached Enga9 1Q 1nents Boost Post
OOti 73 4 Comments 18 Shares
rb like 0 Comm.ent /:!> Share
Most Relevant • 0 Comment as FIJI Water
Bruno Brunelli I love Like Rep1y Mes-sage 2y Glne> Ako Good water Like Reply Message 2y
Paul Puskadl for the greatest water in the world,.,.we are in south florida.,.,for your yacht etc,,,,[email protected]
Like RepJy fl.1essa-ge 2v ｾ＠ FIJI Water {Default) o W Publl.;hed by Satesfo(ce Ma1ketlng Cloud 9 ·October 30, 2019 · 0 FIJI Water takes you from gym to rainforest with natural minerals and eiectrolytes from our sustainable aquifer. #JustAddFIJI
9,592 463 Boost Post People Reached Engagernents
0 0 £ 91 12 Comments 11 Shares
rD like O Comment 1¢ Share
All Comments • G Comment as FIJI Water Davor Oaca Neira- Una Hrapovic jel i ti ovako samo Fiji? .,,, 1;11 • Like Reply Mes.sage See Translation d4v1 4 1 Reply
Nate Yaun I have the best water in the world. No need for all of that plastic waste.
like Reply Message 1y 0 1 View 5 more comments Write a comment.. . ｾ＠ FIJI Water (Default) 0 W Published by ｓ｡｢ｲ ｵ ｬｾ＠ Stetgiadis G · November 30, 2020 · 0 Since 2014, the FIJI Water Foundation has donated m ore than 185,000 children's books to help boost literacy in Fiji's 735 primary schools. This year we were proud to donate an additional $100,000 FJD worth of children's books t-0 Fijian schools with "Read to Lead" patron Mrs. Mary Bainimarama and Assistant Minister for Education, Honorable Joseph Nand. #ReadToLead #V1s1onFij1 #FlJIWaterFoundat1on "Donation llBooks
2,831 101 People Reached Engag@ments
0 0 41 4 Comments 3 Shares
rb Like O Comment ｾ ｓｨ｡ｲ･＠
Most Relevant •
@ Comment as FIJI Water
Murltokf Sera Fiji water??
Like ' Repl y Message 8w Fane Cinavllakeba Marie Kidd kere story ｢ｯｯｫ ｳ ｾ＠ i,;r great initiat ive like · Reply Message 8w Krishna Gounder Excellent work Fiji Water
Like · Reply · Message · Bw
Jos.ateki Young Vinadu riki Fijiwater • like · Reply Message Sw Write a comment. .. D CONFIDENTIAL
billboard.com Fiji 2018 Dee Lockett Oct 12, 2018
Under : Lil Pu p on Recording 'I Love It' With Kanye West and Breaking Through the SoundCloud Noise 10/12/2018 by Dee Lockett
Lil Pump is fried. It’s the day efore his Saturday Night Live debut alongside Kanye West, for which he will dress as a bottle of still Fiji ater to West’s sparkli g Perrier -- a reference to a line from their hit so g I Love It i hi h Ye o ks a ho for posturi g. It’s West’s iggest hit i years a d rivals the su ess of Pu p’s Gu i Ga g, which peaked at No. 3 on the Billboard Hot 100last December.
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Ar.corrtlnfJ ro TMZ, Ｑｨｾｖ＠ hAfJ::ln 5h;.:.rlnn thA nAwi; rll1rln9 Sup ;.r Sowl ｷｾｴ］ＺｫｐＮｮｲｬ＠ ｜Ｇｩｨ ｲ ｾｲＨＺ＠ ｾＮｨ･［＠ ｎＬＱｾＮ＠ hnokr:c1 11p fnr ｲＮｨｮ｜ﾷＮＧ ｾ＠ ••1n '1 ｃＢＺｖ｣ｮｾ＠ in t-11inn<"'!.1poli:.. AftC":r hc:r pcrtorroancc at ihc tv1axhn p.::irty, Cardi al/cgcclty· refused to return to 11cr VIP area l>e<.:i:JU::>i:- oi Un:: ｴｬｾｯＮｶｹ＠ µarly ｶ ｩ ｬＮｊｾＺ［ Ｎ＠ ｷｨｾｲＡＺＧ＠ liquur wa::> aln.:n<.Janl, TtllZ ｲｅＺＺｰｵ Ｚｬ ｾＮ＠ ｓｨｾ＠ opted to stay by the stage Instead, her team reportedly said, and sip FIJI waier for rhf; ｲａｾｲ＠ of ｔｨ ｾ＠ ｦ ｩ］Ｍ ｾｴ ｬ ｶ ｬｬ ｬｆＡｾ Ｎ＠
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Saint West and Reign Disick Dress Up as Kanye West and Lil Pump From 'I Love It' Video For Halloween Brooke Bajgrowicz
11/1/2018
Kardashian cousins North West and Penelope Disick similarly nodded the risqué rap tune, sporting outfits West and Pump wore during their Saturday Night Live performance Sept. 29. North freshened up as a Fiji water bottle while Disick chilled in a bottle of Perrier.
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Dai1vmm1 I Video .com
Hilary Duff heads back to work on Younger after death of dog Hilary Duff heads back to work in New York on Younger after death of dog. She wore a black down coat white collared shirt, phone and Fiji water.
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oailvmmt I Video .com
Olivia Wilde looks fit & tab after a visit to her gym in LA Actress Olivia Wilde gets in her daily wor! Material supplied by Daily Buzz, LLC to you may be used for non-commercial and internal review, analysis and research purposes only. Any editing, reproduction, modification, publication, rebroadcasting, public display or public distribution is forbidden and may violate U.S. and international copyright laws. This material may include printed documents and images, audio works, audio/visual works, content stored on electronic storage media such as CDs and DVDs, electronic communications, and electronic documents and other content attached to or accessible through such electronic communications. 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Material supplied by Daily Buzz, LLC to you may be used for non-commercial and internal review, analysis and research purposes only. Any editing, reproduction, modification, publication, rebroadcasting,https://people.com/tv/jax-taylor-shades-kourtney-kardashian-ex-younes-bendjima/ public display or public distribution is forbidden and may violate U.S. and international copyright laws. This material may include printed documents and images, audio works, audio/visual works, content stored on electronic storage media such as CDs and DVDs, electronic communications, and electronic documents and other content attached to or accessible through such electronic communications. By accepting, accessing and using the material, you agree to defend, indemnify and hold harmless 1 / 1 Daily Buzz, LLC for third-party claims of intellectual property infringement based upon your violation of the foregoing restrictions. people.com Fiji 2018 Robyn Merrett Nov 01, 2018 I Love It! Saint and North West Hilariously Dress Up as Dad Kanye and Lil Pump for Halloween Robyn Merrett November 01, 2018 05:38 Am Penelope, 6, wore Kanye’s sparkling water ensemble as North, 5, rocked Lil Pump’s Fiji water bottle look. Material supplied by Daily Buzz, LLC to you may be used for non-commercial and internal review, analysis and research purposes only. Any editing, reproduction, modification, publication, rebroadcasting,https://people.com/parents/saint-west-reign-disick-halloween-costume-kanye-west-lil-pump-i-love-it/ public display or public distribution is forbidden and may violate U.S. and international copyright laws. This material may include printed documents and images, audio works, audio/visual works, content stored on electronic storage media such as CDs and DVDs, electronic communications, and electronic documents and other content attached to or accessible through such electronic communications. 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IN THE UNITED STATES PATENT AND TRADEMARK OFFICE TRADEMARK TRIAL AND APPEAL BOARD PARAMOUNT INTERNATIONAL Opposition No. 91246479 EXPORT, LTD., Mark: FIJI FIRE Opposer, Application Ser. No.: 88003425 v. JENNIFER M. VAN WALDEN TA FIJI FIRE HOT SAUCE, Applicant. AFFIDAVIT OF CLARENCE CHIA - VOLUME 2 OF 2 {3157531.1} 1 vogue.com Fiji 2018 Arden Fanning Andrews Mar 04, 2018 'rOGUE There's an Amazing Twinning Thing Happening on the Street Style Beauty Scene • MARCH 4. 2018 2 :00 AM flllll. /11• ARDEN FANNING ANDREWS It starred in New Yo rk, where models-of-the-momenr Radhjka Nair and Adesuwa Aighewi posed in matching slicked-back styles as they skipped between fi ttings, and twin fashion bloggers Reese and Moll y Blutsrein coordinated d1eir chin-l ength cuts with a shared palette of burnt orange staples. In London, models Roza P and Lily Nova smiled as they sipped Fiji water bottles in tandem, still showcasing the duplicate bow-tied braids from Simone Rocha's ro mantic runway presentation. 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By accepting, accessing and using the material, you agree to defend, indemnify and hold harmless 1 / 1 Daily Buzz, LLC for third-party claims of intellectual property infringement based upon your violation of the foregoing restrictions. vogue.com Fiji 2018 Michael Bechler Dec 14, 2018 7 Hotels That Will Help You Achieve Your Ne Year’s Resolutions By Michael Bechler DECEMBER 14, 2018 12:27 PM If you’re co itti g to fit ess: Mondrian South Beach - Miami, Florida Whether you're participating in the Miami Marathon on January 27 or just looking to jumpstart a long-intended health kick, head to Mondrian South Beach. Their Runner's High package includes all of the essentials: a gym bag, fruit, and Fiji water upon arrival, along with a map to the city's best running routes and a spa credit for a much-deserved treat e t. Plus, you’ll get VIP access and reserved space in the new Nike Training Club each Saturday on the bayfront pool deck. 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Nalgene began by developing lab equipment, but according to product engineer Fernando Galiana, there ere ru ors floati g around about scientists taking the smaller, more o e ie t ottles out of the la a d usi g the o hikes a d e ursio s. The began to brand themselves as a camping supply company. Material supplied by Daily Buzz, LLC to you may be used for non-commercial and internal review, analysis and research purposes only. Any editing, reproduction, modification, publication, rebroadcasting,https://www.eater.com/2019/10/4/20895897/hydro-flask-water-bottle-status-symbol-high-school public display or public distribution is forbidden and may violate U.S. and international copyright laws. This material may include printed documents and images, audio works, audio/visual works, content stored on electronic storage media such as CDs and DVDs, electronic communications, and electronic documents and other content attached to or accessible through such electronic communications. 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It’s a fridge that looks al ost too curated, were it not for the packages of Oreo left on the counter. Don't worry about his health, though—those treats are for his daughter a d his ho ies. I do ’t fu k ith that shit, sa s T Dolla $ig . Material supplied by Daily Buzz, LLC to you may be used for non-commercial and internal review, analysis and research purposes only. Any editing, reproduction, modification, publication, rebroadcasting,https://www.menshealth.com/fitness/a28564285/ty-dolla-sign-diet-workout/ public display or public distribution is forbidden and may violate U.S. and international copyright laws. This material may include printed documents and images, audio works, audio/visual works, content stored on electronic storage media such as CDs and DVDs, electronic communications, and electronic documents and other content attached to or accessible through such electronic communications. 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They want you to slow it down for a second and revel in the moment. Time is money. Material supplied by Daily Buzz, LLC to you may be used for non-commercial and internal review, analysis and research purposes only. Any editing, reproduction, modification, publication, rebroadcasting,http://www.mtv.com/news/3132867/rick-ross-drake-gold-roses-song/ public display or public distribution is forbidden and may violate U.S. and international copyright laws. This material may include printed documents and images, audio works, audio/visual works, content stored on electronic storage media such as CDs and DVDs, electronic communications, and electronic documents and other content attached to or accessible through such electronic communications. 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This material may include printed documents and images, audio works, audio/visual works, content stored on electronic storage media such as CDs and DVDs, electronic communications, and electronic documents and other content attached to or accessible through such electronic communications. By accepting, accessing and using the material, you agree to defend, indemnify and hold harmless 1 / 2 Daily Buzz, LLC for third-party claims of intellectual property infringement based upon your violation of the foregoing restrictions. yahoo.com Fiji 2019 Corey Williams Oct 16, 2019 2. Fiji Fiji Water Price: $1.99 for a 17-ounce bottle Were we influenced by this brand’s beautiful bottle? Maybe. But all of our testers thought Fiji had a distinct flavor—it was minerally and almost earthy, but in a good way. One person said, “I feel richer drinking this.” Honestly, same. Material supplied by Daily Buzz, LLC to you may be used for non-commercial and internal review, analysis and research purposes only. 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We're going to need that skincare routine... by LAURA CAPON OCT 8, 2020 With her skin looking clearer than a bottle of Fiji water and and smoother than a slab of marble, she literally doesn't look a day over 19. Material supplied by Daily Buzz, LLC to you may be used for non-commercial and internal review, analysis and research purposes only. Any editing, reproduction, modification, publication, rebroadcasting,https://www.cosmopolitan.com/uk/beauty-hair/celebrity-hair-makeup/a34310421/ashanti-no-makeup-selfie/ public display or public distribution is forbidden and may violate U.S. and international copyright laws. This material may include printed documents and images, audio works, audio/visual works, content stored on electronic storage media such as CDs and DVDs, electronic communications, and electronic documents and other content attached to or accessible through such electronic communications. 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Unlike tap water, it comes straight out of the earth and into a bottle from natural sources. Think S.Pellegrino, which comes from the foothills of the Italian Alps, or Fiji Water, where the water gathers minerals as it filters through layers of volcanic rock in a rain forest. When choosing which kind to grab, there are many options at the grocery store that will be beneficial. It really just depends on your preference. Gellman prefers Perrier and S.Pellegrino for bubbling and Fiji for flat, and Minno is a fan of Topo Chico. “I love the taste and that it comes in glass bottles, which are environmentally-friendly. It also eliminates the risk of any release of chemicals from plastic bottles into the water,” she says. Material supplied by Daily Buzz, LLC to you may be used for non-commercial and internal review, analysis and research purposes only. 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Lisa Adams of LA Closets has designed many of their most famous wardrobes, including Khloe’s “sport closet,” with its shelf for kettlebells and a wood-paneled Fiji-water fridge. A closet design from Ms. Adams starts at $50k and goes up to over a million (thus the name of her former HGTV series, “Million Dollar Closets”). The client’s wish is her command: She has installed a stripper pole and a putting green in bespoke closets. Material supplied by Daily Buzz, LLC to you may be used for non-commercial and internal review, analysis and research purposes only. Any editing, reproduction, modification, publication, rebroadcasting,https://www.wsj.com/articles/when-did-custom-closets-become-the-ultimate-status-symbol-11601733617 public display or public distribution is forbidden and may violate U.S. and international copyright laws. 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Woman of the Decade winner Taylor Swift bonded with Woman of the Year Billie Eilish at the 14th annual Billboard Women in Music event, hosted by Hayley Kiyoko at The Palladium in Los Angeles on Dec. 14, where guests enjoyed FIJI water and JNSQ Wines. Material supplied by Daily Buzz, LLC to you may be used for non-commercial and internal review, analysis and research purposes only. Any editing, reproduction, modification, publication, rebroadcasting,https://www.etonline.com/star-sightings-taylor-swift-billie-eilish-bond-chrissy-teigen-john-legends-frozen-date-night-more public display or public distribution is forbidden and may violate U.S. and international copyright laws. This material may include printed documents and images, audio works, audio/visual works, content stored on electronic storage media such as CDs and DVDs, electronic communications, and electronic documents and other content attached to or accessible through such electronic communications. By accepting, accessing and using the material, you agree to defend, indemnify and hold harmless 1 / 1 Daily Buzz, LLC for third-party claims of intellectual property infringement based upon your violation of the foregoing restrictions. Life & Style Emmys 2019 Staff Mon, Oct 14, 2019 October 14, 2019 Material supplied by Daily Buzz, LLC to you may be used for non-commercial and internal review, analysis and research purposes only. Any editing, reproduction, modification, publication, rebroadcasting, public display or public distribution is forbidden and may violate U.S. and international copyright laws. This material may include printed documents and images, audio works, audio/visual works, content stored on electronic storage media such as CDs and DVDs, electronic communications, and electronic documents and other content attached to or accessible through such electronic communications. By accepting, accessing and using the material, you agree to defend, indemnify and hold harmless 1 / 1 Daily Buzz, LLC for third-party claims of intellectual property infringement based upon your violation of the foregoing restrictions. variety.com Emmys 2019 Angelique Jackson Sun, Sep 15, 2019 SEPTEMBER 15, 2019 1:33PM PT Why the Television Academy Plans to Donate Furnishings From the 71st Emmys Governors Ball By ANGELIQUE JACKSON But the philanthropic nature of the event, doesn’t mean there will be any less glamour or decadence at the event, which is held on the L.A. Live Event Deck rooftop, just yards from the Microsoft Theater in Downtown Los Angeles. This year’s Governor’s Ball takes on the theme of “Brilliance in Motion,”based around glittering fountains and rich colors of magenta, coral, purple, red and Emmys gold and will feature floral arrangements from LA Premier; food and beverage from official partners Ferrari Trento sparkling wines, Sterling Wines (who provide a personalized engraved magnum bottle to the Emmy winners as they get their trophies engraved), Lindt Chocolate and FIJI Water; while L’Oreal Paris provides on-site makeup touchups and Audi provides transportation in their fleet of vehicles. Material supplied by Daily Buzz, LLC to you may be used for non-commercial and internal review, analysis and research purposes only. Any editing, reproduction, modification, publication, rebroadcasting, public display or public distribution is forbidden and may violate U.S. and international copyright laws. This material may include printed documents and images, audio works, audio/visual works, content stored on electronic storage media such as CDs and DVDs, electronic communications, and electronic documents and other content attached to or accessible through such electronic communications. By accepting, accessing and using the material, you agree to defend, indemnify and hold harmless 1 / 1 Daily Buzz, LLC for third-party claims of intellectual property infringement based upon your violation of the foregoing restrictions. instyle.com MOSCHINO 2020 Resort Show Brandi Fowler Jun 09, 2019 The 10 Scariest Looks from Jeremy Scott's Moschino 2020 Resort Fashion Show By Brandi Fowler Updated: Jun 09, 2019 @ 4:05 pm It was just the beginning of the scary surprises of the night. The show kicked off as night fell, with guests seated in the middle of a dark street in a makeshift neighborhood, wrapped up in cozy black blankets and sipping FIJI water, as a woman dressed in white ran out of one of the houses screaming. Material supplied by Daily Buzz, LLC to you may be used for non-commercial and internal review, analysis and research purposes only. Any editing, reproduction, modification, publication, rebroadcasting,https://www.instyle.com/fashion/runway/moschino-2020-resort-fashion-show public display or public distribution is forbidden and may violate U.S. and international copyright laws. This material may include printed documents and images, audio works, audio/visual works, content stored on electronic storage media such as CDs and DVDs, electronic communications, and electronic documents and other content attached to or accessible through such electronic communications. By accepting, accessing and using the material, you agree to defend, indemnify and hold harmless 1 / 1 Daily Buzz, LLC for third-party claims of intellectual property infringement based upon your violation of the foregoing restrictions. usmagazine.com EMMYS 2020 Staff Sep 23, 2020 Farrah Abraham and Daughter Sophia Wore Matching Face Masks to Debbie Durkin’s Drive-Thru EcoLuxe Lounge and Endless Summer Festival Event September 23, 2020 By Us Weekly Staff — Jennifer Aniston ensured her dress was intact while holding a FIJI Water bottle before hitting the stage at the 2020 Emmy Awards. Material supplied by Daily Buzz, LLC to you may be used for non-commercial and internal review, analysis and research purposes only. Any editing, reproduction, modification, publication, rebroadcasting,https://www.usmagazine.com/celebrity-news/news/farrah-abraham-and-daughter-sophia-wore-matching-face-masks-in-l-a/ public display or public distribution is forbidden and may violate U.S. and international copyright laws. This material may include printed documents and images, audio works, audio/visual works, content stored on electronic storage media such as CDs and DVDs, electronic communications, and electronic documents and other content attached to or accessible through such electronic communications. By accepting, accessing and using the material, you agree to defend, indemnify and hold harmless 1 / 1 Daily Buzz, LLC for third-party claims of intellectual property infringement based upon your violation of the foregoing restrictions. !"!# F CONFIDENTIAL $%&'(') G CONFIDENTIAL *+,-.-/ H CONFIDENTIAL CERTIFICATE OF SERVICE I, Susan Bryant, hereby certify that a copy of this Affidavit of Clarence Chia has been served upon attorney for Applicant: THOMAS E LEES THOMAS E LEES LLC 90 PHOADS CENTER DRIVE DAYTON, OH 45458 [email protected] Phone: 937-610-9888 by e-mail on this 11th day of February, 2021. / Susan Bryant / Susan Bryant ROLL LAW GROUP PC 11444 West Olympic Boulevard Los Angeles, California 90064-1557 Telephone: (310) 966-8400 Facsimile: (310) 966-8810 {3157531.1} 12