26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 ANITA WHITE, ANITA HAYWOOD, AND HILLARY SCOTT HAYWOOD, ANDHILLARY KELLEY, DAVID CHARLES LLC, A ENTERTAINMENT, LADY C C
ASE OMPLAINT N v. O .
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Plaintiff, Plaintiff, Defendants. The Honorable______WESTERN DISTRICT OF WASHINGTON WASHINGTON OF DISTRICT WESTERN UNITED STATES DISTRICT COURT UNITED STATES SEATTLE DIVISION DIVISION SEATTLE
W C T 1125(a)(1)(A); I C Case No.______JURY DEMAND JURY NFRINGEMENT NFRINGEMENT RADEMARK RADEMARK OMPETITION IN OMPLAINT FOR ASH .
§
19.86.020. I NFRINGEMENT
(2) U (1)
V NDER NDER
C IOLATION OF OF IOLATION
OMMON T RADEMARK 15 1700
U.S.C. L
; S AND AW EVENTH R
§ S EV EATTLE
(3) A .
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C (206) U COOLEY ., ODE NFAIR ,
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452-8700 452-8700
98101 98101 1900 1900
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26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 esnl uidcin vr ay neelm eas: i Ld A Lady (i) because: Antebellum Lady over jurisdiction personal controversy under ArticleIIIofthe United StatesConstitution here alleged claims all as insofar 1367 § U.S.C. 28 to pursuant supplemental has Court The 1125(a). § U.S.C. 15 under arising confusion and the erasure of her LADY A brand identity. Sheal confusion andtheerasureofherLADYAbrand used for nearly thirty years. Through this Complaint, Ms. Whit undertaken with willful disregard for Ms. White’s rights in her Lady Antebellum’s decision to replace the band name LADY ANTEBE u infringement trademark for Antebellum”) “Lady or “Defendants” H and Haywood, David Kelley, Charles LLC, Entertainment, A Lady 2300 CharlotteAvenue, Suite 103,Nashville,Tennessee37203. the of laws the under organized Brentwood, Tennessee. resident ofNashville,Tennessee. of Nashville, Tennessee. Kent, Washington. C COMPLAINT ASE N O 7. Plaintiff Anita White (“Ms.White” or “Plaintiff”) files this C 6. 1. 5. 4. 3. 2. .
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Case 2:20-cv-01360-RSMDocument1Filed09/15/20Page2of13 Plaintiff is informed and believes, and on that basis alleges, alleges, basis that on and believes, and informed is Plaintiff The Courthasoriginaljurisdi citi a is who individual an is A”) (“Lady White Anita Plaintiff eedn Ld A netimn, L (LE) s lmtd liabil limited a is (“LAE”) LLC Entertainment, A Lady Defendant cit a is who individual an is (“Scott”) Scott Hillary Defendant c a is who individual an is (“Haywood”) Haywood David Defendant (“Kelley Kelley Charles Defendant State of Tennessee with its pri its with Tennessee of State JURISDICTION THE PARTIES ction under 28 U.S.C. § 1331, as ction under28U.S.C.§1331,as 2.
”) is an individual who is a c is a who individual an is ”)
LADY A trademark, which she has . e seeks to protect against consumer ncipal place of business located at located business of place ncipal in form part of the same case or case same the of part form in leges as follows. jurisdiction over all other claims other all over jurisdiction
tblu cnut business conducts ntebellum omplaint againstDefendants dr eea ad tt law. state and federal nder LLUM with LADY A was lay ct (collectively Scott illary 1700 izen and resident of resident and izen
this isacivilaction S zen and resident of resident and zen that this Court has Court this that itizen and resident and itizen EVENTH S EATTLE t company ity A VE tzn and itizen (206) COOLEY ., ,
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26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 she performed under the LADY A ma A she performedunderthe LADY under thestagename trademarkA. and LADY States, including inUtah and Florida. of Washington and the Pacific Northwest. Ms. White also travel asLADYA. thousands ofperformances—always Ms. White’s performances. th embody to came name A LADY the before long not was it and A, perform under her given name. Shortly thereafter, she began pe held her White Ms. days, early those in singing about Shy 80s. C COMPLAINT herein. this district, and Ms. White was harmed in this district as a r unlawfu the of portion substantial a district, this in business district. State the in White Ms. to injury tortious caused has Antebellum jud this and Washington of State the with contacts in Antebellum’s asserted action of causes the (iii) district; judicial this to be advertised, promoted, and sold under the LADY A trademark within the State of Washington a ASE N O 10. 9. 13. 12. 11. 8.
.
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Ms. White began her career as a karaoke singer in Seattle, Wash Seattle, in singer karaoke a as career her began White Ms. an performed has White Anita Plaintiff years, thirty nearly For In the 2000s, as Ms. White conti White Ms. as 2000s, the In During the 90s, Ms. White performed as LADY A extensively throu doz with performed has White Ms. career, her of course the Over eu i poe i ti district this in proper is Venue nd this judicial district; (ii) FACTUAL rk acrosstheSouth,including T HE R
EAL EAL BACKGROUND nued to build her profile and t and profile her build to nued 3. eas Ld Atblu regula Antebellum Lady because
L ADY
A esult of the unlawful conduct described Lady Antebellum has caused its music l activities alleged herein occurred in in occurred herein alleged activities l hs opan aie u o Lady of out arise Complaint this ed for gigs elsewhere in the United United the in elsewhere gigs for ed rforming original music as LADY self out as “LADY A” rather than of Washington and this judicial this and Washington of in the State of Washington and inTennessee. ca dsrc; n (v Lady (iv) and district; icial e goodwill associated with associated goodwill e 1700
he LADY A brand, A LADY he S EVENTH d provided music provided d ington in the late late the in ington ens of bands, in bands, of ens ghout the State S EATTLE l conducts rly A VE (206) COOLEY ., ,
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26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 had its origin in a 2006 Franklin, Tennessee photoshoot, during band LadyAntebellum in 2006. and Germany. years that followed, Ms. White performed in the Netherlands, De The album wasnominated foraBlues MusicAward, andhelped to Band. which wasin 2006titled“CanIGetMyBreakfast?” putoutbyL Chicago BluesFestival, among others. W the Festival, Blues Waterfront the as such States, United the 2000s, whenshefirstbeganperfor States. Ms. White’s nationwide common law trademark rights dat trademar A LADY the under sales music and performances numerous performances have occurred; however, her rights also extend nat Paci the and Washington of State the in strong particularly are ri White’s Ms. 1990s. early the least at since mark A LADY the long, her of result a as services entertainment and music with Me.” as early as least at since States United the throughout mark A C COMPLAINT ASE N O 20. 19. 17. 16. 15. 14. 18. .
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Defendants have explained in inter in explained have Defendants Haywoo and Kelley, Scott, Defendants belief, and information On Ms. White’s music has been available for download and streaming “Blu released White Ms. 2010, In To date, Ms. White has released six albums as LADY A—the first For many years, Ms. White has regularly performed at music fest music at performed regularly has White Ms. years, many For Ms. White has accrued common law rights in the LADY A trademark ming extensivelyoutsideoft L ADY A NTEBELLUM 4. ez in the Key of Me” under the the under Me” of Key the in ez views that the name “LADY ANT “LADY name the that views
the release of “Bluez in the Key of Key the in “Bluez of release the which Defendants posed in period continuous, and prominent use of use prominent and continuous, he StateofWashington. fic Northwest, where most of her of most where Northwest, fic nmark, France, Sweden, Belgium, ionwide by virtue of Ms. White’s ady A and the Baby Blues Funk theBabyBluesFunk ady Aand inthrop Blues Festival, and the and Festival, Blues inthrop ghts in the LADY A trademark A LADY the in ghts e to at least as early as the early take hermusic abroad.Inthe k throughout the United the throughout k 1700
S EVENTH under the LADY ivals throughout ivals a limited release LADY A mark. mark. A LADY S in connection d formed the the formed d EATTLE EBELLUM” EBELLUM” A VE (206) COOLEY ., ,
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26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 C COMPLAINT intended toevoketheword “antebellum”ANTEBELLUM intheLADY On information andbelief,theim the following poster to promote aLadyAntebellum showinCary, to theCivil War, andis particularly associated with the pre-C to “before the war.” Today, the word is commonly used to refer ANTEBELLUM, andhavecome tobeknownbythatname. nostalgic.” it because “antebellum” word the to drawn was band the Haywood, “Lady name the suggested Kelley inspi on Drawing plantation. War pre-Civil a of front in dress ASE N O 23. 22. 21. .
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For example, oninformation an LADY trademark the The word “antebellum” derives from the Latin phrase under performed have Defendants then, Since agery oftheplantationand Un neelm” codn t one to According Antebellum.” d belief,in2010,OutbackConcer 5.
ivil War South. to the period of U.S. history prior ration from the shoot, Defendant shoot, the from ration ion and Confederate soldiers was Confederate soldierswas ion and North Carolina: ante bellum felt “kind of country and and country of “kind felt neve wt Defendant with interview mark. mark. 1700
S EVENTH , which translates ts commissioned S EATTLE A VE (206) COOLEY ., ,
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26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 the marketplace was overwhelming. Internet and social media se mediaInternet andsocial overwhelming. was marketplace the Millman at Rolling Stone magazine. f friends, from texts of series a from announcement Defendants’ marketing andpromotional materials. ANTEBELLUM LADY the displayed consistently and ANTEBELLUM, LADY prior toJune11,2020. A LADY performed as by fans. the “nickname” a A, LADY trademark the under perform thereafter decided todroptheword‘ante fr black closest our of some with conversations honest many and refl personal much “After that: represented Defendants account, trademark became apublic-relations liability that Defendants c African Americans and systemic racism more broadly, and sparked atten unprecedented drew death Floyd’s Mr. of footage traumatic African American, was suffocated by a police officer while bein glorification ofthepre-Civil War South. associa the to due controversy courted long has mark ANTEBELLUM C COMPLAINT ASE N O 31. 30. 29. 28. 26. 27. 25. 24. .
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The effect of the name change on Ms. White’s ability to disting to ability White’s Ms. on change name the of effect The same the on change name Antebellum’s Lady of learned White Ms. alway Defendants 2020, June to prior belief, and information On alleges, basis that on and believes, and informed is Plaintiff ANTE LADY the backdrop, this against belief, and information On n ue 1 22, n saeet otd y eedns o h ba the to Defendants by posted statement a in 2020, 11, June On a Floyd, George Mr. Minnesota, Minneapolis, in 2020 25, May On Plaintiff isfurtherinformed a L ADY bellum’ fromourname ..”D A NTEBELLUM nd believes, onthatbasis and a 6. C
O - OPTS
“L ADY ADY ould nolongerignore. efendants assertedthattheywould g restrained during his arrest. The ection, band discussion, prayer, discussion, band ection, arches for “Lady A,” which had A,” which “Lady for arches an explosion of public outrage. iends and colleagues, we have we colleagues, and iends A” tion to police violence against violence police to tion ollowed by a call from Ethan from call a by ollowed y purport to have been given been have to purport y tion of its mark with a a with mark its of tion 1700 that Defendants never Defendants that lleges, thattheLADY
S EVENTH uish her music in in music her uish s performed as as performed s S trademark in EATTLE ds Twitter nd’s 46-year old 46-year A VE BELLUM BELLUM (206) COOLEY ., ,
day as as day S WA UITE
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26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 C COMPLAINT Ms. White’sA brandhadbeenusurpedandsetonthepatht LADY r by dominated now were music, her for results returned readily promptly sendingMs. White adraft agreement. t but resolution, a reach to unable were parties The concerns. the that proposed Antebellum videoconference onJune15,2020todiscussMs.White’s concern Lady coexistence. of possibility contacted company management their change, name their announced of probonocounseltohelpherdefendtheLADYAbrand. and will continue to have, on her ability to perform as LADY A, attempted to resume negotiations with Lady Antebellum with the the with Antebellum Lady with negotiations resume to attempted bono) andtrademark filings forMs.White’sLADYAmark. th fact the (notwithstanding dispute parties’ the of resolution legal for reimbursement $10,000 to up and career her assist to no compensation toMs.White—onlythepromise thatLadyAntebel best agreement her wouldhaveallowedLady in not was counsel bono pro original her by negotiated exchange forcoexistence.Ms.White nevercommitted tosuch an e or work, White’s Ms. promoting Antebellum Lady of possibility Th Defendants. with resolution amicable an negotiate to sought ASE N O 32. 35. 34. 33. 37. 36. .
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Concerned about the impact that Lady Antebellum’s use of the LA In response to Defendants’draft M addressing of ways considered parties the meeting, the During Ms.White did not have to seek out Defendants. Shortly after D s Wie eand e po oo one a Coe LP wo pro whom LLP, Cooley at counsel bono pro new retained White Ms. In the days that followed, Ms. White came to believe that the a the that believe to came White Ms. followed, that days the In Antebellumto continue using agreement, Ms.White,through 7.
at Ms. White was represented pro fees associated with negotiating a negotiating with associated fees hat did not stop Defendants from from Defendants stop not did hat Ms. White secured the assistance arrangement. eferences to Lady Antebellum. Lady to eferences s, andMs.White agreed. aim of protecting the LADY A LADY the protecting of aim ven collaborating on a song, in in song, a on collaborating ven o erasure. the LADY A while providing providing while A the LADY neet. pcfcly the Specifically, interests. pris a dsusd the discussed had parties e lum would makelum bestefforts would Ms. White to discuss the discuss to White Ms. parties participate in a a in participate parties 1700
S EVENTH pro bono counsel, DY A mark had, greement being greement S EATTLE A . White’s s. VE (206) efendants COOLEY ., ,
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26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 inclusive, as if fully set forth here. in connectionwithmusic andente C COMPLAINT been overshadowedbythewell- lack limited, was use Defendants’ because only was it occurred, the To Amark. LADY alleged their alone let band, Defendants’ which rights, trademark law common superior possesses White Ms. trademark. “L fan-originated the of use make not did and A LADY as perform mark A services, andarerenderedthrough the same channelsoftrade. LADY parties’ the c in Antebellum, used are identical, are they that fact Lady the notwithstanding to According A. LADY 4,004,006, Nos. Registration U.S. of owner the is LAE Defendant trademark for music related offerings since as early as 2008. (the “DJComplaint”). declaratory judgment action against Ms. White in the Middle Dis settlement agreement withLadyAntebellum on July6,2020. p new White’s Ms. end, that To White. Ms. by established brand ASE N O 43. 42. 41. 40. 39. 38. .
__-cv-______-cv-____ Case 2:20-cv-01360-RSMDocument1Filed09/15/20Page8of13 (Trademark InfringementUnderLanhamAct, 15U.S.C.§1125(a)(1
Ms. White owns strong, nationwide common law rights in the trad s Wie elee ad noprts y eeec prgah 1 paragraphs reference by incorporates and realleges White Ms. On information and belief, even if Defendants had used LADY A a A LADY used had Defendants if even belief, and information On information on contrary, the To use have they that alleges Antebellum Lady Complaint, DJ the In Defend warning, without and offer, the to responding of Instead known LADY ANTEBELLUM mark. ANTEBELLUM known LADY rtainment services in the natu F IRST IRST C LAIM and belief, prior to June 2020, June to prior belief, and 8. F
OR R ELIEF
Lady Antebellum further alleges that onnection with the same goods and and goods same the with onnection
re ofmusical performances. trict of Tennessee on July 8, 2020 extent that any prior coexistence ed prominence, and would have would and prominence, ed ro bono counsel shared a draft a shared counsel bono ro 4,030,752, and 4,292,685 for for 4,292,685 and 4,030,752, rcd te xsec of existence the precede D A ncnm a a as nickname A” ADY 1700 Defendants did not did Defendants
S EVENTH emark LADY A d LADY A as a a as A LADY d s can coexist, coexist, can s )(A)) S s a trademark, a s EATTLE ns ie a filed ants hog 41, through A VE (206) COOLEY ., ,
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26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 has noadequate remedy atlaw. enjo not if above, alleged as acts Antebellum’s Lady trademark, inf for §1125(a)(1)(A). White Ms. to liable is Antebellum Lady such, As versa. regarding the source, sponsorship usurpation of Ms.White’s brand identity under theLADYAmark. associated otherwise is or by, endorsed by, sponsored is from, th believing into mistaken or confused be to public the causing Lady Antebellum’s use of the LADY A mark has injured and will c circumstances these Under use. of decades during developed has to saturatethemarketmark overwhelmand withtheirLADYA the interest confusion. identical an under Antebellum Lady from content to diverted now festivals throughoutthe United States. same channel of trade, namely via popular social media platform A trademark. LADY A trademark. LADY markin theLADYA allegedlyownedbyLadyAntebellum. C COMPLAINT ASE N O 44. 51. 50. 49. 48. 47. 46. 45. .
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Ms. White’s common law trademark rights in the LADY A mark pred s eosrtd y ay neelms eua t cae s o th of use cease to refusal Antebellum’s Lady by demonstrated As t deceive to likely is mark A LADY the of use Antebellum’s Lady ha resources popularity and Antebellum’s Lady time,same the At on and places market online in musicWhite’s Ms. seeking Those Both Lady Antebellum and Ms. White offer their products and ser mu sell and concerts perform White Ms. and Antebellum Lady Both Ms to identical is Antebellum Lady by used trademark A LADY The , and/or affiliation of Lady A 9.
ntebellum with Ms. White and vice with Defendants, resulting in the in resulting Defendants, with s, at concert venues, and at music at Ms. White’s music originates ined, will continue. Ms. White Ms. continue. will ined, reverse confusion is inevitable. is confusion reverse ontinue to injure Ms. White by
brandidentitythatMs.White mark, thereby causing initial causing thereby mark, igmn udr 5 U.S.C. 15 under ringement 1700
S EVENTH vices through the ve enabled them them enabled ve social media are are media social S EATTLE ate any rights sic under the under sic LD A LADY e A VE (206) e public he White’s . COOLEY ., ,
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26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 allegedly possesses. righ any predate which mark, A LADY the in rights trademark law inclusive, as if fully setforth here. law. remedies other all as well as actual damages, for compensation adequate remedy atlaw. A trademark. the form of lost sales, diminished brand identity, and diminuti constitutes common lawtrademark infringement underWashington S United the throughout and Washington of State within the both likely to lead to both initial interest confusion and reverse c mark. mark. o value the in diminution and identity, brand diminished sales, consist trial at proven be to amount an in damages incurred has C COMPLAINT ASE N O 59. 55. 54. 53. 58. 57. 56. 52. .
Case 2:20-cv-01360-RSMDocument1Filed09/15/20Page10of13 __-cv-______-cv-____
(U NFAIR s Wie elee ad noprts y eeec prgah 1 paragraphs reference by incorporates and realleges White Ms. Lady Antebellum’s knowing and willful use of the identical trad nati White’s Ms. infringe herein alleged acts Antebellum’s Lady s Wie elee ad noprts y eeec prgah 1 paragraphs reference by incorporates and realleges White Ms. In view of the foregoing, Ms. White is entitled to an injunctio Defendants’ acts as alleged above, if not enjoined, will contin Defendants’ conduct has caused and will continue to cause injur cause to continue will and caused has conduct Defendants’ Because of Lady Antebellum’s infringement of the LADY A tradema C OMPETITION IN (C OMMON OMMON S T ECOND ECOND L HIRD AW V IOLATION OF T C C RADEMARK LAIM LAIM 10. F
F OR OR R R R I EV
ELIEF NFRINGEMENT ELIEF . onfusion among the parties’ audiences,
C on and loss of goodwill in the LADY ODE
f and goodwill associated with the with associated goodwill and f
available under Washington State State Washington under available ing of, among other things, lost things, other among of, ing tates. Defendant’s conduct thus conductDefendant’s tates. W law. ASH ) s ht ay Antebellum Lady that ts .
§ 1700
19.86.020) n against Defendants, no has White Ms. ue.
S emark LADY A is EVENTH y to Ms. White in onwide common common onwide S rk, Ms. White EATTLE hog 58, through hog 52, through A VE (206) COOLEY ., ,
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26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 ucsos n neet ad l ohr esn atn i concert in permanentlyA trademark; enjoined fromusingtheLADY acting persons other all and interest, in successors sub and parent attorneys, employees, representatives, servants, C COMPLAINT § 19.86.020 remedies other all as well as damages, actual for compensation adequate remedy atlaw. A trademark. the form of lost sales, diminished brand identity, and diminuti unfair competition underRev.CodeWash§19.86.020. Defe States. United the throughout and Washington of State the to lead to both initial interest mark.A the LADY inclusive, as if fully setforth here. ASE N O d) c) a) b) W 64. 63. 62. 61. 60. .
Case 2:20-cv-01360-RSMDocument1Filed09/15/20Page11of13 __-cv-______-cv-____
HEREFORE
For disgorgement of profits att For disgorgement ofprofits For compensatory damages; For judgment infavorof Plaintiffoneachofher claims forre For injunctive relief; specifically, that Defendants and all of all and Defendants that specifically, relief; injunctive For In view of the foregoing, Ms. White is entitled to an injunctio Defendants’ acts as alleged above, if not enjoined, will contin injur cause to continue will and caused has conduct Defendants’ trademark identical the of use willful and knowing Defendants’ Defendant’s acts alleged herein i , Plaintiff prays for judgment asfollows: confusion and reverse confusio P RAYER RAYER * * * * ributable to infringing useoft F 11. nfringe Ms. White’s exclusive OR
R ELIEF
n among the parties’ fans, both within on and loss of goodwill in the LADY sidiary corporations, assigns and and assigns corporations, sidiary available under Rev. Code Wash Code Rev. under available ndant’s conduct thus constitutes constitutes thus conduct ndant’s ih t e rlmnrl and preliminarily be it with 1700 their officers, agents, he LADY A mark;A he LADY n against Defendants, no has White Ms. ue. lief;
S trademark rights in EVENTH LADY A is likely is A LADY y to Ms. White in S EATTLE A VE (206) COOLEY ., ,
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26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1 Dated: September 15,2020 C COMPLAINT ASE N O f) e) i) h) g) .
Case 2:20-cv-01360-RSMDocument1Filed09/15/20Page12of13 __-cv-______-cv-____
o a esnbe oat fe o ay ae o msc r musical or musicmark; rendered undertheLADYA of sales any for fee royalty reasonable a For For suchotherreliefas the courtdeems justandproper. For costsof suit;this and For pre-judgment andpost-judgment interest; For trebling anddamages;of thedisgorgement ofprofits Email: Fax: (202)842-7899 Tel.: (202)842-7800 Washington, D.C.20004-2446 1299 PennsylvaniaAvenueNW, 700 Suite Email: Fax: (206)452-8800 Tel.: (206)452-8700 Seattle, WA 98101-1355 1700 SeventhAvenue,Suite1900 COOLEY LLP Christopher B. Durbin(WSBA#41159) Judd D.Lauter( Email: Fax: (212)479-6275 Tel.: (212)479-6000 New York,NY10036 1114 AvenueoftheAmericas COOLEY LLP Joseph M.Drayton( Email: COOLEY Jane VanBenten( Brendan J. Hughes ( Palo Alto,CA 94304 3175 HanoverStreet COOLEY LLP /s/Christopher B.Durbin Respectfully submitted, 12.
[email protected] [email protected] [email protected] [email protected]
LLP pro hacvice pro hacvice pro hacvice pro hacvice 1700
befiled) to
befiled) to S EVENTH
to be filed) to be filed) filed) be to S performances EATTLE A VE (206) COOLEY ., ,
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26 25 24 23 22 21 20 19 18 17 16 15 14 13 12 11 10 9 8 7 6 5 4 3 2 1
C COMPLAINT ASE N O .
Case 2:20-cv-01360-RSMDocument1Filed09/15/20Page13of __-cv-______-cv-____ Email: Fax: (650)843-7400 Tel.: (650)843-5960 Counsel forPlaintiff 13.
A NITA NITA 1700
W
HITE S EVENTH
S EATTLE A VE (206) COOLEY ., ,
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