20190920 Joealexander V DMA-ADWEEK-COFFEE.Pdf
Case 3:19-cv-00688 Document 1 Filed 09/19/19 Page 1 of 55 PagelD# 1 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division JOE ALEXANDER ) ) Plaintiff, ) ) 3: 19-cv-688 V. ) Case No. ) ) TRIAL BY JURY DIET MADISON A VENUE ) IS DEMANDED OMA DOE DEFENDANTS 1-17 ) ADWEEK, LLC ) ) -and- ) ) PA TRICK COFFEE ) ) Defendants. ) COMPLAINT Plaintiff, Joe Alexander, by counsel, files the following Complaint against Defendants, Diet Madison Avenue ("OMA"), OMA Doe Defendants 1-17, Adweek, LLC ("Adweek") and Patrick Coffee ("Coffee"), jointly and severally. Plaintiff seeks (a) compensatory damages and punitive damages in the sum of $25,350,000.00, (b) plus prejudgment interest on the principal sum awarded by the Jury from November 21, 2017 to the date of Judgment, and ( c) court costs and expenses - arising out of the Defendants' tortious interference with contract, tortious interference with prospective economic advantage, common law conspiracy, defamation and intentional inflictionof emotional distress. 1 Case 3:19-cv-00688 Document 1 Filed 09/19/19 Page 2 of 55 PagelD# 2 I. INTRODUCTION [https://www.ispot.tv/ad/Ag03/geico-the-wisconsin ("Fifteen minutes could save you 15% or more on car insurance"). The GEICO Gecko has become a force to be reckoned with in the advertising world and was voted America's favorite advertising icon in 2005. GEICO's small green friend has traveled the country spreading the good news about GEICO and has captivated audiences of all ages. The idea for the Gecko grew from a creative session at GEICO's ad agency, The Martin Agency in Richmond, Virginia.
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