Case 2:33-Av-00001 Document 16756 Filed 12/10/12 Page 1 of 66 Pageid: 375649

Case 2:33-av-00001 Document 16756 Filed 12/10/12 Page 1 of 66 PageID: 375649

JON FALLON, ESQ. (JF2851) MANDELBAUM SALSBURG P.C. ATTORNEYS FOR PLAINTIFF 155 PROSPECT AVENUE WEST ORANGE, NEW JERSEY 07052 973.736.4600 (MAIN OFFICE) 732.637.9733 (DIRECT) [email protected] (EMAIL)

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

------X

I’M STILL ME, LLC;

Plaintiff,

v. Civil Action No.: ______QUINTESSENTIAL TOTS, LLC d/b/a ITZY RITZY; ALL AROUND THE HOUSE; COMPLAINT AND DEMAND FOR BABY BROWNS; JURY TRIAL BABY HALF OFF; GEOFFREY, LLC d/b/a BABIES R US; BUY BUY BABY, INC. COMFY BUMMY; COTTON BABIES, INC.; FEBRUARY WON, INC. d/b/a ECOMOM.COM; GRUNTY BABY BOUTIQUE; HEALTHY COTTAGE; I LOVE NATURAL BABY; KOHLS ILLINOIS, INC.; MY NATURAL BABY BOUTIQUE; NESSALEE BABY; TINYDIPITY.COM; WAYFAIR, LLC; WILD CHILD; WRAPABLES.COM; JOHN SMITH, an individual; and ABC COMPANIES; Defendants. ------X Case 2:33-av-00001 Document 16756 Filed 12/10/12 Page 2 of 66 PageID: 375650

I’M STILL ME, LLC v. QUINTESSENTIAL TOTS, LLC, et al. Complaint and Demand for Jury Trial

COMPLAINT AND DEMAND FOR JURY TRIAL

Plaintiff I’m Still Me, LLC (hereinafter “Plaintiff”), by and through its counsel,

Jon Fallon, Esq., of Mandelbaum Salsburg, P.C., complain against Quintessential Tots,

LLC d/b/a Itzy Ritzy, and a number of its vendors, customers and/or distributors

(collectively hereinafter “Defendants”), John Smith and ABC Companies, and alleges upon knowledge as to itself and otherwise upon information and belief as follows:

NATURE OF THE ACTION

1. This is an action for (1) Patent Infringement under 35 U.S.C. § 271(a), (2)

Trade Dress Infringement under 15 U.S.C. § 1125 (a), (3) Unfair Competition

under 15 U.S.C. § 1125 (a), and(4) Unfair Competition under New Jersey

Common Law.

JURISDICTION AND VENUE

2. This Court has subject matter jurisdiction over all causes of actions set forth

herein based upon 15 U.S.C. § 1121, 28 U.S.C. §§ 1331, 1338(a) and 1338(b),

and pursuant to the supplemental jurisdiction of this Court for all non-federal

causes of action under 28 U.S.C. § 1367.

3. This Court has personal jurisdiction over Defendants by virtue of, inter alia,

(a) each Defendant having numerous business relations within the state of

New Jersey and conducting regular and continuous business transactions

therewith, giving it the requisite minimum contacts with the state required to

be subject to jurisdiction therein; (b) commission of tortious acts by all

Defendants within the State of New Jersey and within this Judicial District;

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I’M STILL ME, LLC v. QUINTESSENTIAL TOTS, LLC, et al. Complaint and Demand for Jury Trial

and (c) regular and continuous transaction of business, including the tortious

acts complained of herein, within and/or directed at the State of New Jersey

and this Judicial District.

4. Venue is proper in this judicial district and division pursuant to 28 U.S.C.

§ 1391(b) and (c).

THE PARTIES TO THE COMPLAINT

5. Plaintiff I’m Still Me, LLC is a Connecticut Limited Liability Company with

its principal place of business at 85 Hill Road, Redding, CT 06896

6. Defendant Quintessential Tots, LLC d/b/a Itzy Ritzy (hereinafter “Itzy

Ritzy”) is believed to be an Illinois Corporation, having a principal place of

business at 1665 Quincy Avenue, Unit 179, Naperville, IL 60540.

7. Defendant All Around the House is company having a principal place of

business at 70264 Hwy. 99, Summerfield, KS 66541.

8. Defendant Baby Browns is company having a principal place of business at

7111 W 151st St, Suite 33, Overland Park, KS 66223.

9. Defendant Baby Half Off is a company having a principal place of business at

1743 S. Horne, #200, Mesa, AZ 85204.

10. Defendant Geoffrey, LLC is a Delaware limited liability company having a

principal place of business at 1 Geoffrey Way, Wayne, NJ 07470.

11. Defendant Buy Buy Baby, Inc. is a New York corporation having a principal

place of business at 895 East Gate Boulevard, Garden City, NY 11530.

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I’M STILL ME, LLC v. QUINTESSENTIAL TOTS, LLC, et al. Complaint and Demand for Jury Trial

12. Defendant Comfy Bummy is a company having a principal place of business

at 231 S. Washington Street, Naperville, IL 60540.

13. Defendant Cotton Babies, Inc., is a Missouri corporation having a principal

place of business at 6116 Baumgartner, St. Louis, MO 63129.

14. Defendant February Won, Inc. d/b/a ecomom.com is a California

corporation having a principal place of business at 8737 Venice Boulevard,

Suite 101, Los Angeles, CA 90034.

15. Defendant Grunty Baby Boutique is a company having a principal place of

business at 3331 California Road; Seaside, CA 93955.

16. Defendant Healthy Cottage is a Massachusetts company having a principal

place of business at 22 Stratton Road, Grafton, MA 01519.

17. Defendant I Love Natural Baby is a company having a principal place of

business at 11 College Street, Greenville, SC 29601.

18. Defendant Kohl’s Illinois, Inc. is a Delaware Corporation having a principal

place of business at N56 W17000 Ridgewood Drive, Menomonee Falls, WI,

53051.

19. Defendant My Natural Baby Boutique is a company having a principal place

of business at 120 Somerset Drive, Suffern, NC 10901.

20. Defendant Nessalee Baby is a New Jersey company having a principal place

of business at 346 Mounts Corner Drive, Freehold, NJ 07728.

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I’M STILL ME, LLC v. QUINTESSENTIAL TOTS, LLC, et al. Complaint and Demand for Jury Trial

21. Defendant TinyDipity.com is a company having an unknown address, whose

information is available through its website administrator having an address

at 11400 W. Olympic Blvd. Suite 200, Los Angeles, CA 90064.

22. Defendant Wayfair, LLC is a Massachusetts limited liability company, having

a principal place of business at 177 Huntington Avenue, Suite 6000, Boston,

MA 02115.

23. Defendant Wild Child is a Massachusetts company having a principal place

of business at 5 Medford Street, Arlington, MA 02474.

24. Defendant Wrappables.com is a company having a principal place of

business at 5696 Stewart Avenue, Fremont, CA 94538.

25. Defendant John Smith is a fictitious person whose present identity and

address is unknown who has also violated Plaintiffs’ rights as set forth

herein, or who assisted, conspired, or otherwise cooperated with the other

Defendants in the acts complained of herein.

26. Defendants ABC Companies are fictitious entities whose present identity and

address is unknown, who have also violated Plaintiffs’ rights as set forth

herein, or who assisted, conspired, or otherwise cooperated with the other

Defendants in the acts complained of herein.

BACKGROUND

27. On November 10, 2008, Design Patent Application Serial No. 29/327,649 (the

“’649 Application”) was filed at the United States Patent and Trademark

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I’M STILL ME, LLC v. QUINTESSENTIAL TOTS, LLC, et al. Complaint and Demand for Jury Trial

Office (“USPTO”) by inventors Sandra Wright and Mackenzie Wright-

Sullivan, under the title “Protective Garment”. Less than one year later, on

November 3, 2009, the ‘649 Application issued as United States Design Patent

No. D603,142 (the “’142 Patent”), a copy of which is attached hereto as Exhibit

28. Plaintiff is the exclusive owner, by assignment, of the ‘142 Patent and has the

right to sue and recover damages for infringement thereof.

29. Plaintiff properly marks all patented products in accordance with 35 U.S.C.

§ 287, where appropriate.

30. At least as early as November 2009, Plaintiff has been advertising and

disclosing its novel design for a protective garment, more commonly

identified as a combination bib, burp cloth and bath cloth for babies.

31. Defendant Itzy Ritzy is a manufacturer, distributer and retailer of baby

products. Itzy Ritzy claims to offer a stylish and modern collection of baby,

toddler and lifestyle accessories. One of Itzy Ritzy’s products, sold under the

name “Bitzy,” is identified as a bib, burp and bath cloth, and embodies the

novel aesthetic design of Plaintiff’s patented protective garment (hereinafter

“Infringing Products.”) Upon information and belief, the Infringing Products

were introduced to market sometime in 2011.

32. Each of the other Defendants named herein have made, used, imported,

offered for sale or sold the Infringing Products made by Defendant Itzy Ritzy.

Evidence exhibiting each of the Defendant’s respective websites offering the

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I’M STILL ME, LLC v. QUINTESSENTIAL TOTS, LLC, et al. Complaint and Demand for Jury Trial

Infringing Products for sale, is attached hereto as Exhibit B. Note: in light of

Plaintiff’s demand notices to Defendant Itzy Ritzy, some of the Defendant’s

websites currently show the Infringing Products as unavailable or

backordered; however, Plaintiff had previously confirmed such products

were actually offered for sale and sold by each of such named Defendants.

33. Plaintiff reached out to Defendant Itzy Ritzy in early 2012 in efforts to resolve

this dispute. After numerous back and forth email exchanges, in or around

June 2012, Defendant Itzy Ritzy agreed to cease all sales of the Infringing

Products, but refused to compensate Plaintiff for any past infringement, and

refused to instruct its customers and retail partners to cease selling the

Infringing Products. Accordingly, Plaintiff has filed this Complaint to obtain

the necessary remedies to protect its valuable intellectual property assets.

FIRST CAUSE OF ACTION

PATENT INFRINGEMENT UNDER 35 U.S.C. § 271(a)

34. Paragraphs 1 through 33 are realleged and incorporated herein by reference.

35. The claim of the ‘142 Patent is presumed valid pursuant to 35 U.S.C. § 282,

and is valid.

36. Defendants in violation of 35 U.S.C. § 271(a), have infringed and are currently

infringing, contributorily infringing and/or inducing a third party to infringe,

the claim of the ‘142 Patent, either literally or under the Doctrine of

Equivalents, by causing to be made, using, offering to sell, selling and/or

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I’M STILL ME, LLC v. QUINTESSENTIAL TOTS, LLC, et al. Complaint and Demand for Jury Trial

importing into the United States, without license or authority, within this

Judicial District and elsewhere, the Infringing Products, which are covered by

the ‘142 Patent, and/or contributing towards and/or inducing a third party

to do the same.

37. Defendants intentionally caused to be made, used, offered to sell, sold and/or

imported into the United States the Infringing Products, with actual

knowledge, and/or knowledge imputed to it, that such products embody the

claim of the ‘142 Patent.

38. Defendants have infringed, and upon information and belief, will continue to

infringe, the claims of the ‘142 Patent by the use, manufacture, offer for sale,

sale, and/or importation of the Infringing Products.

39. As a result of the Defendants’ actions, Plaintiff has suffered injury, including

irreparable injury, and damages, including lost profits, reasonable royalties,

and other damages as set forth herein.

SECOND CAUSE OF ACTION

TRADE DRESS INFRINGEMENT UNDER 15 U.S.C. § 1125

40. Paragraphs 1 through 39 are realleged and incorporated herein by reference.

41. Plaintiff has expended significant resources promoting its products covered

by its ‘142 Patent, sold under the brand “OopC!,”and the exclusive rights to

the such aesthetic appearance covered by the claims therein. In view of the

associated niche market, most persons and businesses in the baby garment

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I’M STILL ME, LLC v. QUINTESSENTIAL TOTS, LLC, et al. Complaint and Demand for Jury Trial

protection industry are aware of Plaintiff’s patented aesthetic appearance and

its rights under the ‘142 Patent. Accordingly, the aesthetic appearance of

Plaintiff’s patented products have an inherently distinctive trade dress, or in

the alternative, an acquired distinctive trade dress, in the relevant

marketplace.

42. The Defendants’ use of the Infringing Products, through sale, offering for

sale, and the like, is likely to deceive relevant consumers in the stair

retreading industry as to the Defendants’ affiliation with Plaintiff, or as to a

sponsorship or an approval of the Infringing Products by Plaintiff.

43. The Defendants will, if not preliminary and permanently enjoined by the

Court, continue its acts of trade dress infringement as set forth in the Lanham

Act, thereby deceiving the public, trading on the exclusive rights granted to

Plaintiff by virtue of its trade dress rights.

44. As a result of the Defendants’ collective actions, Plaintiff has suffered injury,

including irreparable injury, and damages, including lost profits, reasonable

royalties, and other damages as set forth herein.

THIRD CAUSE OF ACTION

UNFAIR COMPETITION UNDER 15 U.S.C. § 1125(a)

45. Paragraphs 1 through 44 are realleged and incorporated herein by reference.

46. Plaintiff has expended significant resources promoting its products covered

by its ‘142 Patent, and the exclusive rights to such aesthetic appearance

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I’M STILL ME, LLC v. QUINTESSENTIAL TOTS, LLC, et al. Complaint and Demand for Jury Trial

covered by the claims therein. In view of the associated niche market, most

persons and businesses in the baby garment protection industry are aware of

Plaintiff’s patented aesthetic appearance and its rights under the ‘142 Patent.

47. The Defendants collective actions regarding the Infringing Products, as

described herein, are likely to have misled, and will continue to mislead

many persons in the stair retreading industry to believe the Defendants have

received permission, license, or other consent from Plaintiff to make, use, sell,

offer for sale, or import into the United States, the Infringing Products.

48. The Defendants’ use of the Infringing Products, through sale, offering for

sale, and the like, is likely to deceive relevant consumers in the stair

retreading industry as to the Defendants’ affiliation with Plaintiff, or as to a

sponsorship or an approval of the Infringing Products by Plaintiff.

49. The Defendants will, if not preliminary and permanently enjoined by the

Court, continue its acts of unfair competition as set forth in the Lanham Act,

thereby deceiving the public, trading on the exclusive rights granted to

Plaintiff in the form of the ‘142 Patent, and causing Plaintiff immediate and

irreparable harm, damage and injury.

50. As a result of the Defendants’ collective actions, Plaintiff has suffered injury,

including irreparable injury, and damages, including lost profits, reasonable

royalties, and other damages as set forth herein.

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I’M STILL ME, LLC v. QUINTESSENTIAL TOTS, LLC, et al. Complaint and Demand for Jury Trial

FOURTH CAUSE OF ACTION

UNFAIR COMPETITION UNDER NEW JERSEY COMMON LAW

51. Paragraphs 1 through 50 are realleged and incorporated herein by reference.

52. The aforementioned collective acts of the Defendants constitute unfair

competition and unfair business practices contrary to the common laws of

New Jersey.

53. The Defendants will, if not preliminary and permanently enjoined by the

Court, continue its acts of unfair competition as defined by the common laws

of New Jersey, thereby deceiving the public, trading on the exclusive rights

granted to Plaintiff in the form of the ‘142 Patent, and causing Plaintiff

immediate and irreparable harm, damage and injury.

54. As a result of the Defendants’ collective actions, Plaintiff has suffered injury,

including irreparable injury, and damages, including lost profits, reasonable

royalties, and other damages as set forth herein.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff demands judgment against each of the defendants as follows:

A. a permanent injunction restraining Defendants, their respective officers,

agents, servants, employees, attorneys, and those in active concert or

participation with them, or any of them who receive actual notice of the order

by personal service or otherwise, from:

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I’M STILL ME, LLC v. QUINTESSENTIAL TOTS, LLC, et al. Complaint and Demand for Jury Trial

1. making, using, selling, offering for sale, or importing into the United

States, the Infringing Products; and

2. assisting or inducing others to make, use, sell, offer for sale, or import into

the United States, the Infringing Products;

B. an award of damages for Defendants’ acts of liability under 35 U.S.C. § 271, in

accordance 35 U.S.C. § 284, and in particular, an award of damages adequate

to compensate for the infringement but in no event less than a reasonable

royalty for the use made of the Infringing Products, together with interest

and costs as fixed by the Court;

C. an award of increased damages under 35 U.S.C. § 284, including three times

the amount found or assessed in paragraph (B) above;

D. an award of damages inclusive of any actual damages suffered by Plaintiff as

a result of Defendants’ liability stated hereinabove, including arising out of

Defendants’ liability arising out of Counts I – IV, and other Counts that may

be added at a later date once additional information is obtained;

E. an award of damages from Defendants for their liability under § 43(a) of the

Lanham Act, including any profits made by Defendants in connection with its

unlawful activity, any damages sustained by Plaintiff as a result of

Defendants’ unlawful activity, and any costs incurred with pursuing this

Action, including Court costs, attorney’s fees, and additional costs related

thereto, pursuant to 15 U.S.C. § 1117(a);

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I’M STILL ME, LLC v. QUINTESSENTIAL TOTS, LLC, et al. Complaint and Demand for Jury Trial

F. an award of all damages incurred, directly or indirectly, as a result of

Defendants’ unlawful acts set forth herein, said damages to be trebled at the

discretion of the Court pursuant to N.J.S.A. 56:4-2;

G. a determination by the Court that Defendants’ unlawful actions set forth

herein are exceptional, warranting an award of damages to Plaintiffs for all

reasonable attorney’s fees incurred by Plaintiffs, pursuant to 35 U.S.C. § 285

and 15 U.S.C. § 1117(a);

H. an award of prejudgment and post-judgment interest and costs of suit;

I. an award of punitive damages in an amount to be determined by the Court,

but not less than $500,000.00, for Defendants’ deliberate and willful acts;

J. an award of actual and compensatory damages in an amount not presently

known, but to be computed during the pendency of this action; and

K. an award of any such other and further relief as this Court deems just and

equitable.

Respectfully submitted,

Date: December 10, 2012 By:/s/ Jon Fallon /

JON FALLON, ESQ. (JF2851) MANDELBAUM SALSBURG P.C. ATTORNEYS FOR PLAINTIFF 155 PROSPECT AVENUE WEST ORANGE, NEW JERSEY 07052 973.736.4600 (MAIN OFFICE) 732.637.9733 (DIRECT) [email protected] (EMAIL)

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CERTIFICATION PURSUANT TO LOCAL CIVIL RULE 11.2 The undersigned hereby certifies, pursuant to Local Civil Rule 11.2, that with respect to the matter in controversy herein, neither plaintiff nor plaintiff’s attorney is aware of any other action pending in any court, or any pending arbitration or administrative proceeding, to which this matter is subject.

Respectfully submitted,

Date: December 10, 2012 By:/s/ Jon Fallon /

JON FALLON, ESQ. (JF2851) MANDELBAUM SALSBURG P.C. ATTORNEYS FOR PLAINTIFF 155 PROSPECT AVENUE WEST ORANGE, NEW JERSEY 07052 973.736.4600 (MAIN OFFICE) 732.637.9733 (DIRECT) [email protected] (EMAIL)

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I’M STILL ME, LLC v. QUINTESSENTIAL TOTS, LLC, et al. Complaint and Demand for Jury Trial

CERTIFICATION PURSUANT TO FEDERAL RULE OF CIVIL PROCEDURE 7.1 The undersigned hereby certifies, pursuant to Federal Rule of Civil Procedure

7.1, that with respect to the matter in controversy herein, Plaintiff does not have any

parent corporation, nor have any publicly held corporation owning 10% or more of its

stock.

Respectfully submitted,

Date: December 10, 2012 By:/s/ Jon Fallon /

JON FALLON, ESQ. (JF2851) MANDELBAUM SALSBURG P.C. ATTORNEYS FOR PLAINTIFF 155 PROSPECT AVENUE WEST ORANGE, NEW JERSEY 07052 973.736.4600 (MAIN OFFICE) 732.637.9733 (DIRECT) [email protected] (EMAIL)

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I’M STILL ME, LLC v. QUINTESSENTIAL TOTS, LLC, et al. Complaint and Demand for Jury Trial

EXHIBIT A

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I’M STILL ME, LLC v. QUINTESSENTIAL TOTS, LLC, et al. Complaint and Demand for Jury Trial

EXHIBIT B

Bitzy by Itzy Ritzy Bib, Burp and Bath Cloth 3 uses in 1 Fresh Bloom Page 1 of 1 Case 2:33-av-00001 Document 16756 Filed 12/10/12 Page 22 of 66 PageID: 375670

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Bitzy by Itzy Ritzy Bib, Burp and Bath Cloth 3 uses in 1 Fresh Bloom

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Description Reviews

Bitzy – Bib, Burp and Bath Cloth

Designed for busy moms, the versatile Bitzy multi-tasks with style. Featuring super-soft layers of eco-friendly bamboo rayon and absorbent cotton, this ingenious product can be used as a bib, burp cloth or washcloth. The adaptable Bitzy saves space in your diaper bag, and it saves you precious time spent with your baby rather than searching through multiple items for just the one that you need.

At 20 inches in length, with a tapered and contoured shape, the Bitzy makes a great burp cloth. The cloth grows with your baby, and when she’s ready for a bib, simply snaps around her neck, providing a stylish bib with full coverage. It’s soft, absorbent fabric also works wonders at bath time.

Beautiful custom designed, trademark Itzy Ritzy fabrics and its inventive design make the Bitzy a designer original. Perhaps that’s why it is a favorite of modern mothers throughout not only the United States but also Canada, Asia, Europe, Australia and the Mideast. Even celebrities love the Bitzy. Angelina Jolie, Nicole Richie and Pink are just a few of the famous moms who are fans of Itzy Ritzy’s innovative products. Featured on “Good Morning America,” the “Today” show and in Parents magazine, the company has also won multiple awards from Cribsie, Red Tricycle and Baby and Children’s Product News.

• Comfortable and absorbent layers of eco-friendly bamboo rayon and cotton • May be utilized as a bib, burp cloth or washcloth • Machine washable • Line dry recommended • 9 inches wide by 20.5 inches long • Durable, rust-free plastic snaps

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■ Glitzy Gals Washable Nursing Pads™ are reusable, comfortable and luxurious! ■ Designer 100% cotton top layer lined with interior and bottom layers of absorbent, eco-friendly bamboo rayon. ■ 4 ⅝” in diameter - perfect size to do their job without adding bulk. ■ Say goodbye to itchy, expensive disposable nursing and breastfeeding pads! ■ Double up for heavy letdown or nighttime wear. ■ Six-piece/3 Pair box set ■ The perfect chic and eco-friendly gift for expecting moms, baby showers, or as a little treat for yourself! ■ Done nursing? Suds up in the tub...Glitzy Gals are perfect for small hands & baby's tender skin...kids get a kick out of the funky fabrics too!

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Print Page Email A Friend Itzy Ritzy Bib, Burp and Bath Cloth - Rodeo Drive This item is available online only By: Itzy Ritzy Our Price: $12.99

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Product Description The Bitzy, 3 in 1 bib, burp and wash cloth by Itzy Ritzy is eco-friendly and grows with your baby! This versatile, multi-use cloth was designed to meet every busy mom's needs! Generously sized at over 20 inches in length, the Bitzy features a tapered contoured shape that provides perfect coverage for burping, feeding or washing baby. Use the versatile Bitzy as a bib by snapping the ends together or use in the bath as a washcloth.

Made with baby's comfort in mind, this handy accessory has layers of soft absorbent bamboo rayon and cotton. Itzy Ritzy products are made with the highest quality workmanship using 100% machine washable cotton and are CPSIA certified safe for baby. The Bitzy is trimmed with custom designed fabrics exclusive to Itzy Ritzy. Product Washing Instructions: Machine wash in cold water with like colors, no bleach. Line dry recommended. Product Dimensions: 9-inches length x 20.5-inches wide.

At Itzy Ritzy, we believe that parenting in style is possible. Our collection is designed to provide families with smart and stylish solutions to everyday parenting challenges. From multi-purpose designs that empower and chic prints that inspire, to eco-friendly solutions that raise consciousness, we've reinvented practical luxury for modern families around the world while remaining true to our core vision of keeping things simple. Itzy Ritzy has been featured on The Today Show and Good Morning America and is the winner of the 2011 Red Tricycle Totally Awesome Awards and back-to-back winner of the Best New Product by Baby & Children's Product News.

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Itzy Ritzy Bib, Burp and Itzy Ritzy Bib, Burp and Itzy Ritzy Bib, Burp and Itzy Ritzy Bib, Burp and Itzy Ritzy Bib, Burp and Bath Cloth - Little Miss Bath Cloth - Avocado Bath Cloth - Licorice Bath Cloth - Modern Bath Cloth - Fresh Zig Zag Damask Swirl Floral Bloom

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Product Reviews This product is no longer available. Continue shopping at buybuy BABY. accessories accessories itzy ritzy accessories Itzy Ritzy™ Bitzy™ Bib, Burp & Bath Cloth - Licorice accessories aisle fixtures Swirl & Baby Bamboo attitude bodysuits The Bitzy™ has multiple uses to grow with your baby, transforming between a burp baby cloth, bib and a wash cloth! The cloth is made from Bamboo Rayon trimmed in 100% baby accessories designer cotton. The Bamboo Rayon is soft, absorbent and comfortable. It features a baby food tapered contoured shape for perfect coverage and measures 9" x 20 1/2". It also has baby shoes rust-free plastic snaps to ensure cloth stays in place. Machine washable. bags bakeware bakeware 1 / 1 (100%) customers would recommend this product to a friend. ball bins basic hosiery Customer Reviews for Itzy Ritzy™ Bitzy™ Bib, Burp & Bath Cloth - Licorice Swirl & Baby Bamboo basic layette bathing bathing Rating: 5 beach Best Bib bedding - juvenile May 29, 2012 BabyK from Glenview, IL bibs This is my favorite bib and I feel it's better than the Aiden and Anais blankets Parental Status: Parent (who has great swaddle blankets). I love that it has bamboo in there blocks Number of Children: 2 and it's super soft for my kids' sensitive skin. Both of my kids have books Would you recommend? Yes thick necks and this bib fits just right. I like how it can be converted booster seats from a bib to a burp cloth or even a security blanket. I have these booster seats bibs in other designs and always give 'em as gifts. It is pricey but so bouncer worth it! I've washed 'em way too many times but they still look boxed toys great! boy athletic boy license Share this review: breast feeding carriers carters changing table covers chemicals christening christmas closet-storage college convertible carseats cooking electrics core branded haircare crib fashion bedding crib open stock bedding dec hardware diaper pails diapers double strollers dvds electronic & music electronic & music entertainers eye & ear care feeding first aid food prep formula framed art-wall decor

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• Features • Description • Sizing • Product Care • More Info

• Multiple uses to grow with your baby, transforming between a burp cloth, bib and wash cloth! • Bamboo Rayon trimmed in 100% designer cotton fabric • Generous 9" x 20.5" size • Tapered contour shape for perfect coverage • Rust-free plastic snaps ensure bib stays in place

This innovative bib has multiple uses to grow with your baby, transforming between a burp cloth, bib and wash cloth! Made from bamboo rayon and trimmed in 100% designer cotton fabric, it is soft, absorbent and comfortable. The tapered, contoured shape is the perfect coverage and the rust-free plastic snaps ensure the bib stays in place.

Generous 9" x 20.5" size

Machine washable

Made in the USA

Rating [short_review] [long_review] Reviewed by: [user_name] from [user_city]. [user_email] on [review_date]

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0 0 Cloth Diaper 101 Baby Style a comprehensive resource Baby Bling about cloth diapers! Baby Shoes Click to enlarge Baby Clothing Baby Socks Baby Bibs Product Description Diapering bumGenius The Itzy Ritzy Bitzy has multiple uses to grow with your baby transforming from a burp cloth to a bib and to Econobum wash cloth. Made from Bamboo Rayon and trimmed in 100% designer cotton you and your baby can by Flip System stylish and functional. Bamboo rayon is soft, comfortable & absorbent. The tapered contoured shape and generous 9" x 20.5" sizing allow for perfect coverage, no matter how you use it, and the rust free snaps FuzziBunz® ensure bib stays in place. The Itzy Ritzy Bitzy is simple to use and machine washable. Cloth Diapers Organic Diapers Pocket Inserts Diaper Packages Diaper Covers Diaper Accessories Baby Wipes Potty Training Swim Diapers Used Diapers Avocado Damask and Avocado Damask and Avocado Damask Advocacy Gear Baby Babmboo Baby Bamboo Uses Swatch Baby Gear Baby Carriers Carrier Accessories Strollers Carseats Traveling Baby Sleeping Baby Pacifiers/Teethers Feeding Food Fresh Bloom and Fresh Bloom and Fresh Bloom Uses Pumps & Supplies Baby Babmboo Baby Bamboo Bottle Feeding Swatch Sippy Cups Baby Proofing Bath Time Diaper Bags

http://www.cottonbabies.com/product_info.php?products_id=3263 11/23/2012 Itzy Ritzy Bitzy Bib, Burp & Bath Cloth - Natural Body Care - Cotton Babies Cloth Diap... Page 2 of 3 Case 2:33-av-00001 Document 16756 Filed 12/10/12 Page 40 of 66 PageID: 375688

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Itzy Ritzy Bitzy Bib, Burp & Bath Cloth Reviews (2)

Write a review of this product! Rating: [5 of 5 Stars!] Reviewed by Kate on Monday 02 April, 2012

I absolutely love these bibs. My son spits up a lot and most of the bibs we tried were just too small and not absorbant enough. These cover a lot of area and can be used as an over the shoulder burb cloth or bib. They are a must have.

http://www.cottonbabies.com/product_info.php?products_id=3263 11/23/2012 Itzy Ritzy Bitzy Bib, Burp & Bath Cloth - Natural Body Care - Cotton Babies Cloth Diap... Page 3 of 3 Case 2:33-av-00001 Document 16756 Filed 12/10/12 Page 41 of 66 PageID: 375689

Rating: [4 of 5 Stars!] Reviewed by Stacy on Thursday 22 March, 2012

This product was great for my child with reflux, I could use it as a burp cloth and then if he didn't spit up I could stick it on him as a bib in his exersauser and it would protect his clothes when he did spit up...I knew it was coming so he might as well look cute doing it :)

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bumGenius, Flip & Econobum are products of Cotton Babies, Inc 6116 Baumgartner Crossing, St. Louis, MO 63129 - 888.332.2243

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Soft, absorbent and comfortable bamboo rayon trimmed in 100% cotton fabric.

9” x 20.5”

• Generous size with tapered contoured shape for perfect coverage 3-in-1 • Multiple uses to grow with child: burp cloth, bib and wash cloth • Rust-free snaps • Machine washable

http://www.ecomom.com/itzy-ritzy-bitzy-bib-burp-bath-cloth-rodeo-drive.html 11/23/2012 ecomom.com | Itzy Ritzy Bitzy Bib, Burp & Bath Cloth - Rodeo Drive Page 2 of 2 Case 2:33-av-00001 Document 16756 Filed 12/10/12 Page 43 of 66 PageID: 375691

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Product Description

Multiple uses to grow with your baby, transforming between a burp cloth, bib and wash cloth!

Bamboo Rayon trimmed in 100% designer cotton fabric

Bamboo Rayon is soft, absorbent, & comfortable

Generous 9" x 20.5" size

Tapered contoured shape for perfect coverage

Rust-free plastic snaps ensure bib stays in place

Machine washable

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Itzy Ritzy Bitzy Bib, Burp and Bath Cloth, BC8066 1 (Modern Floral) Quantity: by Itzy Ritzy Yes, I want FREE Two-Day Shipping with Amazon Prime Be the first to review this item | (0)

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Only 2 left in stock. Sold by The Healthy Cottage and Fulfilled by Amazon. Gift-wrap available.

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Product Features

 3-uses-in-1-diaper bag must have-absorbent-contoured shape-hidden rust-free snaps

 Grows with your baby, transforming between a burp cloth, bib and wash cloth

 Cloth is made from Bamboo Rayon, trimmed in 100% designer cotton

 Measures:9" x 20 1/2"

 Machine washable

Product Specifications Part Number BC8066 Item Package Quantity 1

Product Description

The Itzy Ritzy BC8024 Bitzy 3-in-1 bib, burp and wash cloth is eco-friendly and grows with your baby. This versatile, multi-use cloth was designed to meet every busy mom's needs. Generously sized at over 20-inches in length, the Bitzy features a tapered contoured shape that provides perfect coverage for burping, feeding or washing baby. Use the versatile Bitzy as a bib by snapping the ends together or use in the bath as a washcloth. Made with baby's comfort in mind, this handy accessory has layers of soft absorbent bamboo rayon and cotton. The Bitzy is trimmed with custom designed fabrics exclusive to Itzy Ritzy. Avocado Damask is a stylish unisex print in green and white. Product Washing Instructions: Machine wash in cold water with like colors, no bleach. Line dry recommended. Product Dimensions: 9-inches by 20.5-inches.

Product Details Shipping Weight: 6.4 ounces (View shipping rates and policies) ASIN: B008BIMNX0 Item model number: BC8066 Average Customer Review: Be the first to review this item

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http://www.amazon.com/Itzy-Ritzy-BC8066-Modern-Floral/dp/B008BIMNX0 11/23/2012 Amazon.com: Itzy Ritzy Bitzy Bib, Burp and Bath Cloth, BC8066 (Modern Floral): Hom... Page 2 of 3 Case 2:33-av-00001 Document 16756 Filed 12/10/12 Page 47 of 66 PageID: 375695

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I Love Natural Baby » Store » Nursing and Feeding » Itzy Ritzy Bitzy Bib, Burp and Bath Cloth

■ Multiple uses to grow with your baby, transforming cloth diapers babywearing nursing & feeding apparel & accessories toys bath & grooming for mama sale between a burp cloth, bib and wash cloth! ■ Bamboo Rayon trimmed in 100% designer cotton fabric ■ Bamboo Rayon is soft, absorbent, & comfortable ■ Generous 9" x 20.5" size ■ Tapered contoured shape for perfect coverage ■ Rust-free plastic snaps ensure bib stays in place ■ Machine washable

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Bitzy™ Bib, Burp & Bath Cloth

• Multiple uses to grow with your baby, transforming between a burp cloth, bib and wash cloth! • Bamboo Rayon trimmed in 100% designer cotton fabric • Bamboo Rayon is soft, absorbent, & comfortable • Generous 9" x 20.5" size • Tapered contoured shape for perfect coverage • Rust-free plastic snaps ensure bib stays in place • Machine washable

Bitzy in Bitzy in Bitzy in Fresh Bloom & Baby Bamboo Modern Floral & Baby Bamboo Licorice Swirl & Baby Bamboo $12.99 $12.99 $12.99

Bitzy in Bitzy in Bitzy in Avocado Damask & Baby Black & Baby Bamboo Little Miss Zig Zag & Baby Bamboo $12.99 Bamboo $12.99 $12.99 (backordered)

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Sign Up privacy policy Bitzy in Bitzy in Rodeo Drive & Baby Bamboo Social Circle Blue & Baby $12.99 (backordered) Bamboo $12.99

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Itzy Ritzy Avocado Damask Bib, Burp & Bath Cloth sale $13.50 regular $15.00 quantity: 1 Like 0 sale $13.50

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Product Questions & Answers

Be the first to ask a question e-mail to a friend Itzy Bitzy cloths provide versatility. From feeding time to bath time, this Itzy Bitzy bib, burp and wash cloth is an everyday essential. Shop our full line of baby accessories at Kohls.com. In avocado. • Tapered, contoured shape offers perfect coverage. • CPSIA certification allows safe use. •Details: • 9"H x 20.5"W MORE TO CONSIDER • Ages birth to 2 years

• Rayon/cotton • Machine wash More Views •Imported Learn what you need to get ready for baby here. • Promotional offers available online at Kohls.com may vary from those offered in Kohl's stores. Prince Lionheart Warmies Reusable Cloth Wipes

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http://www.kohls.com/upgrade/webstore/product_page.jsp?PRODUCT%3C%3Eprd_id=... 11/23/2012 Natural Bitzy Bib, Burp & Bath Cloth Page 1 of 2 Case 2:33-av-00001 Document 16756 Filed 12/10/12 Page 53 of 66 PageID: 375701

While Supplies Last Sale! Clothing Here Comes the SUN! Blankets Meal Time Teethers & Soothers Bath Time Skin So Soft On-the-Go Binkie/ Blankie Bungee Gift Sets for Baby Nuts! about Laundry Wet Bags Toys Bamboo Plush Monkey Aminals Dolls $27.99 $14.99 Dandelion Eco Friendly

Home Gift Certificates Gift Registry Bitzy™ Bib, Burp & Bath Order Tracking Cloth Testimonials $12.99 $6.99 Why Buy Organic Good Read Our Friends Causes We Believe In Bitzy™ Bib, Burp & Bath Cloth Customer Service Contact Us Privacy Policy This versatile Natural Bamboo Bib, Burp and Bath Cloth will have multiple uses to grow with your baby, transforming between a burp cloth, bib and wash cloth! A Whale Watching Wet Bag • Bamboo Rayon trimmed in 100% designer cotton fabric (blue or pink) • Bamboo Rayon is soft, absorbent, & comfortable $21.99 $10.99 View Your Cart • Generous 9" x 20.5" size • Tapered contoured shape for perfect coverage • Rust-free plastic snaps ensure bib stays in place • Machine washable • Coordinates perfectly with our wet bags

Go Green with Baby Bamboo: • Baby bamboo is an eco-friendly fabric, as bamboo is sustainable Go and grown without pesticides and fungicides. • The soft, smooth texture is exceptional for babies' tender skin • Naturally anti-bacterial, anti-microbial, and deodorizing. Bamboo needs no harsh Share chemicals that can irritate tender skin; its own natural ingredient, BAMBOO KUN prevents bacteria Like 0 growth. • Bamboo fabric even has an inherent UV protection factor • Our baby bamboo fabric looks and feels like Silk, but it is much more practical as it is machine washable! • Bitzy Burpers utilize remnant fabric that would otherwise go to waste – yet another way to reduce, reuse, recycle & go All Natural Disposable green! Compressed Wipes Tube & Refill Set Itzy Ritzy is all the rage in Hollywood! Celebrities like you love Itzy Ritzy, including these Celebrity $8.99 $4.99 Moms and Dads: Rebecca Romijn, Jerry O'Connell, Halle Berry, Nicole Kidman, Angelina Jolie, Brad Pitt, Melissa Joan Hart, Marissa Jaret Winokur, Sean “Diddy” Combs, Gwen Stefani & Nicole Richie!

Price: Was $12.99 Sale! $6.99 Color: Urban Jungle Blue Qty:

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Everything Organic & Natural For Your Baby

100% Certified Cotton or 100% Natural Bamboo Baby Clothes & Accessories, Non Toxic Teething Jewelry, Safe for your Baby or a PBA-Free Baby Bottle with Anti-Colic Nipple, You Will Find it in My Natural Baby Boutique. The varieties of our Organic Products make it easy to create an Eco Friendly gift basket for someone special in your life. We offer gift registry and gift certificates.

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OrbitBaby - Sidekick Qty: 1 Add to Cart Stroller Board $119.99 Feeding time never looked this good! Each Itzy Ritzy Bitzy can be used MORE VIEWS as bib with the attached snaps, doubles as a burp cloth and also makes a fantastic wash cloth - without compromising style.

Description Specs Designer Info Tags Reviews

• Made of bamboo • Accented with Itzy Ritzy print • Washable • Eco-friendly

http://www.nessaleebaby.com/itzy-ritzy-bitzy-burp-and-wash-cloths.html 11/23/2012 Itzy Ritzy Bitzy Bib, Burp & Bath Cloth in Social Circle Pink Page 1 of 4 Case 2:33-av-00001 Document 16756 Filed 12/10/12 Page 56 of 66 PageID: 375704

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Itzy Ritzy Bitzy Bib, Burp & Bath Cloth in Social Circle Pink

$25

1 in stock

SKU: BC8057. Category: Bib, Bath & Burp Cloths, Brands, Cool Finds, Itzy Ritzy, Mealtime. Tags: burpy bib pink baby.

Product Description

Itzy Ritzy Bitzy Bib, Burp & Bath Cloth in Social Circle Pink

Every new parent needs burp cloths and bibs, and this bamboo rayon burpy bib trimmed in 100% designer cotton fabric does triple duty as a 3-in-1. Its unique design provides maximum coverage for both you and your baby. Drape it around baby’s neck or fasten with a simple snap in the back.

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Why it’s a Tinydipity pick:

Tapered contoured shape for perfect coverage.

Rust-free plastic snaps ensure bib stays in place.

We love the versatility and durability of these burp cloth/bib hybrids – and they come in lovely, modern patterns to boot!

Size 9” x 20.5”

Designed in USA

Machine washable

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