Groupie Answer With Counterclaims 8-28-12

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

GROUPME, INC., Civil Action No.: 12 CV 5362 (KBF)
Plaintiff, ANSWER AND COUNTERCLAIMS
-against- JURY TRIAL DEMANDED
GROUPIE LLC,
Defendant.
Defendant Groupie LLC ("Defendant"), by and through its attorneys, Olshan Frome
Wolosky LLP, hereby answers the "Declaratory Judgment Complaint" ("Complaint") of Plaintiff
Groupme, Inc. ("Plaintiff') and alleges as follows:
INTRODUCTION
Over a year after Defendant launched its GROUPIE application for group messaging on
Apple's iTunes App Store, Plaintiff launched its GROUPME application for a virtually identical
type of product and service. The GROUPME and GROUPIE products and services are and have
been virtually identical in purpose, form and function; free to download; and marketed through
the same chmmels of trade, and offer substitutable functionality and target substantially the same
demographic audience. The marks are only one letter apart, use the same root word, and have
phonetically similar and rhyming second syllables. Unsurprisingly, there is evidence of actual
confusion caused by Plaintiffs use of the mark GROUPME.
In an effort to avoid these facts and convince the Court that Plaintiff is entitled to a
declaration that its subsequently adopted mark GROUPME does not infringe Defendant's
GROUPIE mark, Plaintiffs Complaint alleges a false three-part story. First, the Complaint
falsely paints Defendant's principals as opportunists trying to extort money from Plaintiff
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Case 1:12-cv-05362-KBF Document 17 Filed 08/28/12 Page 1 of 24
because it was acquired by Skype Technologies, S.A. or a related entity ("Skype") in August
2011. However, the Complaint also undermines this false portrait by disclosing, correctly, that
Defendant filed its Notice of Opposition to Plaintiffs GROUPME trademark application before
Skype's acquisition of Plaintiff and announcement of the acquisition. In fact, Defendant
commenced the opposition to protect its valuable rights in its registered mark GROUPIE.
The second part of the Complaint's story, i.e., that the users of the GROUPME and
GROUPIE products and services are supposedly very different, is also false. Plaintiffs
GROUPME social networking service is not principally used by the traditional flip cell phone
users, as the Complaint infers, but rather by users of smart phones and similar devices, such as
iPhones and other iOS devices. Users of iPhones and iOS devices are the same consumers that
use Defendant's GROUPIE product and service. Nor is it true that, while the GROUP ME
product and service is principally addressed to friends and family, the GROUPIE product and
service is mainly directed toward those who seek to link with strangers who share a passion.
The story's third element, that Defendant is a two-person start-up with little success,
whose mark thereby deserves no respect, is not only legally incorrect but also factually false.
Defendant's founders have spent large sums of money, and have expended, with Defendant's
other developers, thousands of hours in developing the GROUPIE product and service that is
regularly used by tens of thousands of devoted users. While Defendant does not have an
advertising budget such as the one that Skype can ensure for Plaintiff, that does not mean that
Defendant is without valuable, protectable rights in its trademark.
The Court should deny Plaintiff the relief that its Complaint seeks, and should instead, as
requested in Defendant's counterclaims, permanently enjoin Plaintiff from using the infringing
mark GROUPME.
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The Responses to the Numbered Paragraphs in the Complaint
1. Defendant denies having knowledge or information sufficient to form a belief as
to the truth of the allegations in the first two sentences in paragraph 1 of the Complaint, and
otherwise denies each and every allegation contained in paragraph 1 of the Complaint.
2. Defendant denies each and every allegation contained in paragraph 2 of the
Complaint, except admits that, in the Complaint, Plaintiff requests "[a] declaration that
Plaintiffs use of the GroupMe mark does not constitute an infringement of any trademark right
of Defendant".
Complaint, except admits that the Complaint requests "[a]n Order directing the Commissioner of
Patents and Trademarks to cancel U.S. Registration No. 3,723,588" on the purported and false
ground that "the mark shown in the registration is merely descriptive".
4. Defendant admits the allegations contained in paragraph 4 of the Complaint upon
information and belief.
5. Defendant admits the allegations contained in paragraph 5 of the Complaint.
6. Paragraph 6 of the Complaint alleges only legal conclusions as to which no
response is required, but, to preserve its rights, Defendant denies each and every allegation
contained in paragraph 6 of the Complaint.
7. Paragraph 7 of the Complaint alleges only legal conclusions as to which no
response is required.
to the truth of the allegations in paragraph 8 of the Complaint, except admits that Defendant
maintains a place of business in the Southern District of New York.
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to the truth of the allegations in paragraph 9 of the Complaint, but admits, upon information and
belief, that Plaintiff was founded in or around May 2010 by Jared Hecht and Steve Martocci.
Complaint, except admits, upon information and belief, that GROUPME is a social networking
service by which users can send a group message to all members of a group of users
simultaneously by SMS, push technology and other methods of data delivery. Defendant avers
that Plaintiffs allegation in paragraph 10 of the Complaint that the GROUPME service "enables
its users to create unique groups comprised of family, friends, coworkers, or other individuals in
their real life" is misleading because it suggests that groups of GROUPME users consist only of
family, friends, and coworkers and not users who met through the GROUPME application,
Twitter, or other mediums.
11 . Defendant denies having knowledge or information sufficient to form a belief as
to the truth of the allegations in paragraph 11 of the Complaint, but admits, upon information and
belief that the GROUP ME product and service was inspired by a project conceived at the
TechCrunch Disrupt Hackathon.
12. Defendant denies the allegation in paragraph 12 of the Complaint that Plaintiff
"has developed significant intellectual property rights . .. in its GroupMe brand", and otherwise
denies having knowledge or information sufficient to form a belief as to the truth of the
allegations in paragraph 12 of the Complaint.
to the truth of the allegations in paragraph 13 of the Complaint, except admits that (a) according
to the website of the United States Patent and Trademark Office ("USPTO"), on July 26, 2010,
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- - ~ ----- --------
Plaintiff filed an intent to use trademark application for the word mark GROUP ME in
International Classes 35, 36, 38, 42 and 45 and that the trademark examining attorney did not
cite any conflicting marks that would bar registration during the examination phase, and (b)
according to the USPTO website, on July 11, 2012, Plaintiff filed an application based on
claimed use for the following mark in International Class 9, which has not been examined by the
USPTO to date: 9 groupme.
to the truth of the allegations in paragraph 14 of the Complaint, except admits, upon information
and belief, sometimes Plaintiff uses the following: 9 groupme.
Complaint and avers that the mark GROUP ME is not always used as alleged in said paragraph.
16. Defendant admits, upon information and belief, the allegations in paragraph 16 of
the Complaint.
and belief, that sometimes the following logo is used in close proximity to the GROUP ME
mark.
and belief, that it has been publicly reported that Skype acquired Plaintiff in August 2011.
19. Defendant denies the allegation contained in paragraph 19 of the Complaint that
"the Groupme service [is] vastly different from Defendant's Groupie [service]" and otherwise
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denies having knowledge or information sufficient to form a belief as to the truth of the
allegations in paragraph 19 of the Complaint.
Complaint, except admits that Leo Efstathiou ("Efstathiou") resides and works in the State of
New York, Jordan Adler ("Adler") principally resides in the State of New Jersey and currently
works both in the State of New Jersey and the State of New York, and that in addition to working
for Defendant, both principals of Defendant perform and have performed services for other
persons.
Complaint, except admits that Defendant is the owner of U.S. Trademark Registration No.
3,723,588 for the mark GROUPIE in International Class 9 for the following goods: "Computer
application software for mobile phones" and said registration issued on December 8, 2009.
Complaint, except admits that Defendant has been continuously using the GROUPIE mark in
interstate commerce since September 2009.
Complaint, except admits that Defendant's product and service is an application focused on
group messaging called GROUPIE and that, while this application and service, among other
things, permits users to create and join groups dedicated to a particular passion or interest, the
application and service also permits users to create, join, manage and communicate with a group
of existing friends, family members, coworkers and other individuals.
Complaint.
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the truth of the allegations in paragraph 25 of the Complaint, except admits that Defendant's
GROUPIE application is compatible with Apple iOS devices and any smartphone with access to
a compatible internet browser, and the application can be accessed at www.groupie.co or
downloaded through the iTunes App Store, or by following the link on Defendant's website,
www.groupie.co, to the iTunes App Store.
Complaint, except admits that Defendant's distinctive logo appears in close proximity to the
GROUPIE Mark in one place on Defendant's website.
Complaint, and avers that some of Defendant's promotions state that "Groupie is the easiest way
to connect with people who share your interests and hobbies. Join and create groups, meet new
people and stay in touch with friends."
30. Defendant denies each and every allegation continued in paragraph 30 of the
Complaint, except admits that it has advised various persons of the opposition proceeding
Defendant has brought against Plaintiffs intent to use trademark application in the USPTO for
the word mark GROUPME (the "Opposition Proceeding").
31 . Defendant admits the allegations contained in paragraph 31 of the Complaint, but
denies that said paragraph contains all of the contents of the letter to which said paragraph refers
and respectfully refers the Court to the letter for all of its contents.
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Complaint, and avers that the paragraph paraphrases rather than quotes what was actually stated,
but admits that in May 2012, for purposes of the Opposition Proceeding, Plaintiff took the
deposition of Defendant pursuant to Federal Rule of Civil Procedure 30(b)(6), and Defendant has
been damaged and continues to be damaged by Plaintiff's use of the mark GROUPME, and
Defendant refers the Court to the deposition transcript for its contents.
Complaint, except admits that Plaintiff's use of the mark GROUPME infringes Defendant's
rights in its mark GROUPIE and that if Plaintiff is investing more in the mark GROUPME, it has
undertaken such with full knowledge of Defendant' s superior rights.
34. Defendant denies the allegations contained in paragraph 34 of the Complaint and
avers that while Group is a word in the English language and other parties use the word "group"
with other words in connection with social networking and have federal registrations, these
companies' services are markedly different than Defendant's product and service and the marks
are sufficiently different from Defendant' s mark GROUPIE. Defendant further avers that, to the
extent there may be other persons that use marks that begin with "group" for applications
accessible on the iTunes App Store that also feature group messaging, such marks are not as
similar as GROUPIE and GROUP ME as (a) these two marks are both one word with two
syllables, (b) not only is the first word in both marks the word "group" but also the second
syllable in each mark rhymes with the second syllable in the other mark, (c) the GROUPME and
GROUPIE marks differ only by one letter, and (d) both GROUPME and GROUPIE are used in
connection with the same types of products and services, share the same channels of trade, have
often appeared side by side in search results on the ITunes App Store, and share many
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functionalities. Defendant further avers that the cited "Groupies v1.0" application was only
released in April 2012, and that Defendant has taken steps to stop that unauthorized use.
to the truth of the allegations in paragraph 35 of the Complaint, but admits that it has not
opposed or sought to cancel any of the registrations cited in paragraph 35 of the Complaint as
these marks are sufficiently different from GROUPIE and/or the companies do not use their
marks for products and services the same as or close to Defendant's GROUPIE product and
serVIce.
Complaint.
Complaint, except admits that various dictionaries contain definitions of the word "groupie."
Complaint.
Complaint.
Complaint.
Complaint and avers that the word "groupie" is widely and principally defined to mean "a fan of
a rock group who usually follows the group around on concert tours." See, e.g., groupie,
Merriam Webster Online Collegiate Dictionary, http://www.melTiam
webster.com/dictionary/groupie (last visited August 27, 2012).
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Complaint, except admits that Defendant's GROUPIE mark is used in connection with its
GROUPIE application which can be used by family members, friends, coworkers, and others to
communicate about anything.
43. With respect to the allegations contained in paragraph 43 of the Complaint,
Defendant (a) avers that the allegation that "[a]n actual case or controversy exists between
Plaintiff and Defendant" constitutes a legal conclusion as to which no response is required and
(b) denies having knowledge sufficient to form a belief as to the truth of the allegations
contained in paragraph 43 of the Complaint, except admits that Defendant has maintained and
continues to maintain that Plaintiffs mark GROUPME, in whatever form Plaintiff uses it,
infringes Defendant' s rights in its mark GROUPIE, and an attorney for Defendant sent a letter in
December 2011 to Plaintiff's counsel to which Defendant respectfully refers the Court for its
contents.
to the truth of the allegations in paragraph 44 of the Complaint.
AS TO THE "FIRST CAUSE OF ACTION"
45. In answer to paragraph 45 of the Complaint, Defendant repeats and realleges each
of the allegations contained in paragraphs 1 through 44 in this Answer as though fully set forth
herein.
Complaint.
Complaint.
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AS TO THE "SECOND CAUSE OF ACTION"
48 . In answer to paragraph 48 of the Complaint, Defendant repeats and realleges each
of the allegations contained in paragraphs 1 through 47 in this Answer as though fully set forth
herein
49. Defendant denies each and every allegation contained in Paragraph 49 of the
Complaint.
FIRST AFFIRMATIVE DEFENSE
50. The Complaint fails to state a claim against Defendant upon which relief may be
granted.
SECOND AFFIRMATIVE DEFENSE
51. Plaintiff is barred from seeking the relief requested in the Complaint because
Defendant's GROUPIE trademark is not merely descriptive.
THIRD AFFIRMATIVE DEFENSE
52. Plaintiff is barred from seeking the relief requested in the Complaint by virtue of
the likelihood of confusion and the actual confusion between the GROUP ME and GROUPIE
trademarks.
FOURTH AFFIRMATIVE DEFENSE
53. Plaintiff is barred from seeking the relief requested in the Complaint by Plaintiffs
bad faith and/or fraud.
FIFTH AFFIRMATIVE DEFENSE
54. Plaintiff is barred from any recovery under the Complaint because Plaintiff s own
wrongful conduct was the sole and proximate cause of Plaintiffs alleged uncertainty over its
GROUPME trademark.
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SIXTH AFFIRMATIVE DEFENSE
55. Plaintiffs claims are barred because the conduct of Defendant was justified under
the circumstances, in that Defendant did what was reasonably necessary to protect its legitimate
intellectual property rights.
SEVENTH AFFIRMATIVE DEFENSE
56. Defendant reserves the right to rely on any additional defenses to the Complaint
that become available or apparent during discovery proceedings in this action, and respectfully
reserves the right to amend this Answer for the purpose of asserting such defenses.
COUNTERCLAIMS
Defendant, by and through its attorneys, Olshan Frome Wolosky LLP, alleges on
knowledge as to its own acts and otherwise on information and belief as follows:
NATURE OF COUNTERCLAIMS
57. The following counterclaims are for trademark infringement, false designation of
origin, and unfair competition in violation of the laws of the United States and the State of New
York. Defendant seeks an injunction, damages and related relief.
JURISDICTION AND VENUE
58. This Court has jurisdiction over these counterclaims pursuant to 15 U.S.c. 1121
and 28 U.S.C. 1331, 1332, 1338 and 1367. Defendant's counterclaims are predicated upon
the Lanham Trademark Act of 1946, as amended, 15 U.S.C. 1051, et seq., and the statutory and
common law of the State of New York.
59. Venue is proper in this district pursuant to 28 U.S.C. 1391 (b) and (c).
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PARTIES
60. Defendant is a New Jersey limited liability company organized and existing under
the laws of the State of New Jersey with its principal office at 180 Tekening Drive, Tenafly, New
Jersey.
61. Upon information and belief, Plaintiff is a Delaware Corporation with a principal
place of business located at 26 West 1i
h
Street, Suite 1002, New York, New York 10011.
BACKGROUND
Defendant's Business and the GROUPIE Trademark
62. Defendant offers a social networking and group messaging application and
service to the public under the mark GROUPIE (the "GROUPIE Mark"), which was initially
developed by Adler and Efstathiou in 2009. The GROUPIE service allows users to send group
messages to friends, family, coworkers and others through the use of the GROUPIE application.
63. On December 1,2008, Adler filed an intent to use trademark application for the
GROUPIE Mark in International Class 009 for "Computer application software for mobile
phones" (the "GROUPIE Trademark Application").
64. No substantive office actions were issued against the GROUPIE Mark during the
prosecution of the GROUPIE Trademark Application; rather only a procedural one was issued
regarding additional information that was needed as to Defendant's organizational status. An
Examiner's Amendment was issued in response to this office action, stating the following entity
information: "The applicant is identified as Groupie LLC, a limited liability company organized
under the laws of New Jersey."
65. The GROUPIE Mark registered in the name of Defendant on December 8, 2009
on the principal register as U.S. Registration No. 3723588 (the "GROUPIE Trademark
Registration"). A true and correct copy of the GROUPIE trademark registration certificate is
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attached hereto as Exhibit A. The foregoing registration is valid, subsisting and in full force and
effect.
66. As set forth in the GROUPIE Trademark Registration, Defendant began using the
GROUPIE Trademark on June 1, 2009 and began using the GROUPIE Mark in United States
commerce on September 25,2009.
67. Since at least as early as September 25, 2009, and prior to the acts of Plaintiff
alleged herein, Defendant has used the GROUPIE Mark throughout the United States and within
this judicial district in connection with its software products, in marketing and advertising
materials, and on its website, www.groupie.co. in connection with its social networking and
group messaging product and service. Thus, in addition to its federal trademark rights,
GROUPIE has exclusive common law rights in the GROUPIE Mark.
68. Defendant, through its founders, have invested significant sums of money in the
development, promotion and advertisement of the GROUPIE product and service and in the
establishment, growth and maintenance of the goodwill associated with the GROUPIE Mark.
69. Defendant's GROUPIE product and service cunently has tens of thousands of
users, and tens of thousands of messages are sent through the GROUPIE product and service
each day.
70. Cunently the GROUPIE product and service is available on any computer or
smartphone with a compatible internet browser or on Apple iOS devices. The GROUPIE
application can be downloaded through the iTunes App Store or by following the link on
Defendant's website, www.groupie.co, to the iTunes App Store. Defendant is in the process of
expanding the types of devices that its product and service are compatible with.
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71. As a result of Defendant' s advertising and promotional efforts, and the excellent
functionality and value of its GROUPIE application and service, the GROUPIE Mark has
acquired great value and recognition in the United States and is recognized and relied upon by
the relevant trade and consuming public as indicating a product and service originating from a
single source -Defendant. The GROUPIE Mark has become strong and distinctive, and is
entitled to broad protection against unfair and infringing uses.
Plaintiff
Plaintiff's Business and Infringing Acts
72. Plaintiff is a Delaware corporation which was founded in or around May 2010 by
Jared Hecht and Steve Martocci.
73. The GROUPME service was inspired by a project conceived at the TechCrunch
Disrupt Hackathon, which has been described as a conference where 300 hackers converge for a
day and a half long hack day before the conference itself starts.
74. Plaintiff was originally named MINDLESS DRIBBLE INC., but its name was
formally changed to GROUPME, INC. on March 25, 2011. On August 15,2011, Defendant
recorded said name change with the USPTO Assignment Services Division.
75. Long after Defendant began using the GROUPIE Mark, Plaintiff adopted and
used the designation GROUP ME in connection with Plaintiffs social networking and group
. .
messagmg serVIce.
76. According to Plaintiff, its service can be accessed through Plaintiffs website and
mobile web application, www.groupme.com; by downloading the GROUPME app on the
iPhone, Android, Windows Phone or Blackberry devices; by texting START to GROUP (47687)
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from a mobile phone; or by texting # to any 10 digit phone number that belongs to a GROUPME
group.
77. GROUPME and GROUPIE are confusingly similar as both are made up of one
word with two syllables, the second syllable in each of the marks rhymes with the second
syllable in the other mark, the two marks differ only in one letter, and the marks are used in the
same channels of trade, have often appeared in close proximity to each other, and are used for
products and services which are virtually identical in purpose, form and function.
78. Consumers are likely to be confused and have been confused by the similarity
between GROUPME and GROUPIE for the same or closely related products and services.
79. At times the following icon is used in connection with the GROUPME product
and service:
(the "GROUPME Icon").
80. When first introduced, the GROUPME Icon had a tan background color, as set
forth below:
81. Defendant uses the following icon with its blue background color with the
GROUPIE Mark:
82. Plaintiff has changed the background color of the GROUPME Icon to blue, a
color close to that used by Defendant for its icon.
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83. On the iTunes App Store, the GROUPIE application and the GROUPME
application have often been placed next to one another in a list of available applications in search
results.
84. A search for GROUPIE on Apple's iTunes App Store prompts the consumer to
consider whether he/she instead meant GROUPME, as evidenced in Exhibit B attached hereto.
85. A search for GROUPIE on www.Google.com. has often prompted the consumer
to consider whether he/she instead meant GROUPME, as evidenced in Exhibit C attached hereto,
or auto-forwarded the consumer to GROUPME search results, as evidenced in Exhibit D
attached hereto.
The GROUPME Trademark Applications
86. On July 26,2010, Groupme, then known as Mindless Dribble, filed an intent to
use trademark application in the USPTO for GROUPME in standard characters, Serial No.
85092723 (the "GROUPME Trademark Application"), for the following services:
Class 35: Advertising services; online advertising on an electronic or optical
communications network and on wireless and electronic mobile devices;
promoting the goods and services of others by placing advertisements and
promotional displays in an electronic site accessed through electronic or
optical communications networks and on wireless and electronic mobile
devices; advertising and promotion of websites for others; providing on
line directory information services featuring information regarding the
wireless communications and social networking services of others;
computerized database management
Class 36: Providing electronic processing of electronic funds transfer, ACH, credit
card, debit card, electronic check and electronic payments provided via an
electronic or optical communications network and on wireless and
electronic mobile devices
Class 38: Providing multiple-user access to computer networks for the transfer and
dissemination of a wide range of information; electronic transmission of
data, messages, images, and documents; providing on-line chat rooms and
electronic bulletin boards for transmission of messages among users with
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other electronic or optical communications network and wireless and
electronic mobile device in the field of general interest
Class 42: Computer services, namely, computer software development of web
applications for internet and wireless and electronic mobile device users;
providing temporary use of on-line non-downloadable software for
assisting in website development; providing temporary use of non
downloadable software for use in search engine optimization; providing
temporary use of non-downloadable software for use in analyzing online
and wireless and electronic mobile device user behavior; searching and
retrieving information, sites, and other resources available on electronic or
optical communications networks and via wireless and electronic
mobile devices for others; designing, creating, hosting, and maintenance
of websites for others; providing temporary use of a web-based software
for communications among users via a personalized webpage and wireless
and electronic mobile device interface
87. The GROUPME Trademark Application was published for opposition on May 3,
2011.
88. On May 31,2011, Defendant filed a request for an extension of time to oppose
the GROUP ME Trademark Application, which was granted.
89. On July 1, 2011, Defendant filed a Notice of Opposition before the Trademark
Trial and Appeal Board ("TTAB") against the GROUPME Trademark Application based on
priority and likelihood of confusion, pursuant to Section 2( d) of the Trademark Act, and the
opposition commenced thereby was assigned Opposition No. 91200478.
90. On or about August 21, 2011, after the commencement of the Opposition
Proceeding, Plaintiff was acquired by Skype. Plaintiffs website says that it "is now a proud
member of the Skype family."
91. Skype is a division of Microsoft Corp.
92. On July 11, 2012, despite the pending Opposition Proceeding, Plaintiff filed a
used based trademark application for the following GROUPME logo (the "GROUPME Logo"),
and assigned Serial No. 85674567, in International Class 9 for "software capable of causing
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transmission of a message from a message originator to multiple predefined recipients across a
wired and/or wireless network" :
9 g
rou
pme
93. Plaintiffs application to register the GROUPME Logo claims a first use date of
March 1,2011.
94. The GROUPME Logo application has not been examined by the USPTO
trademark examiner to date.
95 . The Opposition Proceeding was suspended on July 24, 2012 pending the outcome
of this action.
96. Plaintiffs uses ofthe mark GROUPME by itself or with the design set forth in
paragraph 92 herein (a) are likely to cause confusion and mistake among the consuming public
that Plaintiffs product and service originate with the source of the GROUPIE product and
service; (b) are likely to cause confusion and mistake among the consuming public that there is
some affiliation, connection or association of Plaintiff with the source of the GROUPIE product
and service; and/or (c) are likely to cause confusion and mistake among the consuming public
that Plaintiffs product and service are being offered to the consuming public with the
sponsorship or approval of the source of the GROUPIE product and service.
FIRST COUNTERCLAIM
(Trademark Infringement Under the Lanham Act, 15 U.S.c. 1114(a))
97. Defendant repeats and realleges each and every allegation contained in paragraphs
57 through 96 of the Counterclaims as though fully set forth herein.
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98. Plaintiff's uses of the mark GROUPME, with or without the design component,
infringe Defendant's registered trademark GROUPIE, as they are likely to lead the relevant
trade and public to associate Plaintiff's product and service with Defendant's business, product
and service, and are likely to cause confusion, mistake, or deception within the meaning of 15
u.s.c. 1114(a).
99. Plaintiff's acts complained of herein are willful and done with the intention of
causing confusion, mistake, or deception, or otherwise trading unfairly upon the valuable
goodwill built up by Defendant in its registered trademark GROUPIE.
100. Plaintiff's acts complained of herein jeopardize the goodwill symbolized by
Defendant's registered trademark, causing serious and irreparable injury to Defendant for which
it has no adequate remedy at law.
SECOND COUNTERCLAIM
(False Designation of Origin Under the Lanham Act, 15 U.S.c. 1125(a))
1 0 1. Defendant repeats and realleges each and every allegation contained in paragraphs
102. Plaintiff's uses of the mark GROUPME, with or without the design component,
infringe Defendant's rights in the GROUPIE Mark, as they are likely to cause confusion,
mistake, or deception as to the affiliation, connection, or association of Plaintiff's product and
service with Defendant, or as to the origin, sponsorship or approval of Plaintiff's product, service
or commercial activities in violation of Defendant's rights, within the meaning of 15 U.S.c.
1125(a).
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103. Plaintiff s acts complained of herein are willful and done with the intention of
causing confusion, mistake, or deception, or otherwise trading unfairly upon the valuable
goodwill built up in the GROUPIE Mark.
104. Plaintiffs acts complained of herein jeopardize the goodwill symbolized by the
GROUPIE trademark, causing serious and irreparable injury to Defendant for which it has no
adequate remedy at law.
THIRD COUNTERCLAIM
(Trademark Infringement and Unfair Competition
in Violation of New York Common Law)
105. Defendant repeats and realleges each and every allegation contained in paragraphs
106. Plaintiffs uses of the mark GROUPME, with or without the design component,
constitute trademark infringement and unfair competition in violation of the common law of
New York, as they are likely to cause confusion, or to cause mistake, or to deceive as to the
affiliation, connection, or association of Plaintiff s product and service with Defendant's product
and service, or as to the origin, sponsorship or approval of Plaintiff s product, service, or
commercial activity in violation of Defendant's rights.
107. Plaintiff has willfully engaged in acts of trademark infringement and unfair
competition.
108. Plaintiffs acts of trademark infringement and unfair competition have caused,
and if not restrained by this Court, will continue to cause Defendant serious and irreparable
injury for which Defendant has no adequate remedy at law.
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PRAYER FOR RELIEF
WHEREFORE, Defendant demands judgment against Plaintiff as follows:
A. Dismissing the Complaint with prejudice;
B. Permanently enjoining Plaintiff, its members, officers, agents, licensees, servants,
employees, attorneys and all other persons in active concert or participation with Plaintiff from:
(1) using the GROUPME trademark, with or without a design element,
or any other trademark confusingly similar to the GROUPIE Mark, in
connection with any social network, group messaging, or related product or
service;
(2) advertising, displaying, or promoting any product or service by
using the GROUPME trademark, with or without a design element, or any
other designation confusingly similar to the GROUPIE Mark;
(3) using the GROUPME trademark, with or without a design element,
or anything else confusingly similar to the GROUPIE Mark in or as part of an
application, domain name, blog name or username, or on any internet site; and
(4) holding out through the use of business or trade names, domain
names, or in any manner whatsoever, that Plaintiff or its products or services,
are in any way sponsored by, or associated or affiliated with Defendant or its
products or services.
C. That Plaintiff be required to make a detailed accounting to Defendant with respect
to all transactions in which Plaintiff used the GROUPME trademark, with or without a design
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element, including: (1) its gross revenues; and (2) its total profits generated, including a detailed
explanation of any alleged deductions to be made in the calculation of profits.
D. That Plaintiff be directed to pay over to Defendant all gains, profits and
advantages realized by Plaintiff from the provision of a product or service using the GROUP ME
trademark, with or without a design element, or any other designation confusingly similar to the
GROUPIE Mark, pursuant to 15 U.S.C. 1117, and that said amount be increased to an amount
the Court deems appropriate and just.
E. That Plaintiff be directed to pay over to Defendant its costs, disbursements, and
reasonable attorneys' fees and expenses.
F. That the Court retain jurisdiction of this action for the purpose of enabling
Defendant to apply to the Court at any time for such further orders and interpretation or
execution of any order entered in this action, for the modification of any such order, for the
enforcement or compliance therewith, and for the punishment of any violations thereof.
G. That Defendant have such other and further relief that the Court may deem just
and proper.
23
1772412-1
Dated: August 28,2012
OLSHAN FROME WOLOSKY LLP
By:
Thomas J. Fleming
Steven R. Gursky
Herbert C. Ross
Safia A. Anand
Park A venue Tower
65 East 55
th
Street
New York, New York 10022
(212) 451-2300
Attorneys for Defendant Groupie LLC
24
1772412-1
EXHIBIT A
Case 1:12-cv-05362-KBF Document 17-1 Filed 08/28/12 Page 1 of 2
-.
groupIe
Reg. No. 3,723,588 GROl]PIE LLC (NEW JERSEY LIMITEDLIABILITY COMPANY)
Registered Dec. 8,2009 180TEKENING DRIVE
TENAFLY, Nl 07.670
Int. CI.: 9 FOR: COMPUTER APPLICATION SOF1WAREFOR MOBILE PHONES, IN CLASS 9 (U.S.
CLS. 21,23,26, 36AND.38).
TaADEM!\RK FIRST USE.6-1-2009; IN COMMERCE 9-.25-2009.
PRINCIPAL REGISTER. ..
nm MARK CONSISTS OF S1ANDARD CHARACTERS WITHOUT CLAIMTO ANY PAR
TICULAR FONT, STYLE, SIZE, OR COLOR.
8N 77-623,421,.FILED 12-1-2008.
ALLISON HOLTZ, EXAMINING ATTORNEY
Uira.1ot of tht: United States PUk,frt wnl lltKb:mari'. Offiee
EXHIBITB
Search r: groupie
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Shannon Tweedls Attack of the ... Shannon Tweedls Attack of the
Games: Arcade Games: Action
Updated Jun 10, 2012 Updated Jun 18, 2012
96 Ratings 17 Ratings
Digital G Studios
Music
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a indicates an app designed for both iPhone and iPad
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240 Ratings
Shannon Tweedls Attack of the
Games: Action
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Shannon Tweedls Attack of the
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31 Ratings
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Music
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GROUPIES Groupies v1.0
Travel
Updated Apr 25. 2012
-- .-- ~
EXHIBIT C
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EXHIBITD
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phOne mrtnbCr for l. GroupMo is tOO beSt way to CNlt wkh overyono you
know.
GroupMa Android ADD Hit. Marllet Introduces Group Textinq and " .
www.androldpolco.corrY .. Jgrooprr&.ndrold, .. .
Nov 4, 2010 Tho i\torMt startup GroupMo, 0 company whi:h aims to provido an
oasy group toxtttg and conforon.co coln!g soMlon to thO masses, has just ,.,
Android Qyjck ADD - GroupM, I Android Central
WNW IIndroldcerlr.,cClflV8ndrold QUlCk app.-grOl.1pn'lll
by Jared DiPane in 2.387 GoogIo+ e lreleo Mae by Jared DiPane
Androld Quick App - GroupMo. By Jared OiPano 20 Mar 2011 9: 10 am.
group,.,. groupm02. Ever try to make plans wth 0 of flionds, and hovo
to aond the ...
GroupM. For Android Is Now Live I TechCrunch
tochcrunch corrJ201OJ11103Igroupme..for -androld-lS now INBI
New 3, 2010 Tccl'lCrunch Disrupt Hockotnon alumnus GroupMo has come out wtlh an
Androi d app today to auppkttnent as otromg, which liko sockll ..
GroupM. - Android
'NWW.ordrokizoom.com , Android Appt , Socill
3.794 votos Free Android
n DownlOad GraupM. for Android (500000 - 1000000 downlOOd5)
Iti;'iI GroupMG 19 0 ctoss piItform phOnO number based chat and SMSwkh push
not6::aUOrls.
grouomelAroupmHndrolckdk - GitHub

Group'" Android SDK - Road rrae ... TIliI opon sourco Androkt Itnry olows you
to l'ltograto GroupMo i"Ito your appicadon. Except os othol'Wiso ...
Featured ADO: Group M.lAndrold iOS Blackbeny, WPIl I HaiTea
hatoq eoml.. Jfooturod-app-group. .....ondrold- loo bIockborrywp71
Oct 15, 2011 Irl a br. nt IWo QPP caIad GroupMe. It can DO dOrNrmaded by anybody
an A ndroid dovee.IOS device. B1o.ckbtlrry. orW'ndows F'tlono 7.
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Mops
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Soarcn "" ow blackberry
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Shopping GroURM. BltckBtrry aRR I Group text & messaging BltckBtrry IPP
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Mota TtM> GroupMo opp brilg. group "xt<1g 10 your Blockbany. Group mes.ago thO poopIo
In your . 0 tOOt oro mporUlint to you, no matter what phOnO thoy havo.
Old Tappan, NJ
Bu ic Troubleshooting for BIICkBtny . GroupM. Support
Chango location
.. .. .
Oct 27.2011 MQko l uro you aro usi'lg tho rnosl up to dato version of tnc Blac:kBony
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Mota 100000n !DOlI
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Fob 25. 2011 GroupMo loto you o!lortlos' 1y group IOl<I wftI1 thO poopIo i1 your ilia
.. Wo'ra proud to announce tho boUl rolDaSo of our BlackBerry app, ;.all ...
Free GrpURM. - Download GroupM. - Free Appt from BllCkStrry .. .
Ippworld bIKkben'y.comtwobltorolcontontl31133
Fi'ld GroupMo for your BlockBarry Smartphono. Download GroupMo by GroupMo
from IlockBeny App Wortd & dilcovor """0 Appo ln thO Social N_kilg ,.
by G'DURM. - BI"""Btrry ADD World
appwortd.blackt..rry.corMolobtlor&'vendornSSO?tong=or
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Supponod Oovicos Maximum You hovo roached lhe maximum numbOr' of , ..
OoviCo RadiO 0 11 BlackBerry App World roqu'"II\aI your _ it. "
OrpURM. - BlICI!Btrry ApR World
appworld,blackMrry.com'wol>ltorolcor"."tlrovlowa131133?1ong--en
You /\OV. not onlOt'" thO corroci Black80ny dovit. peJ,_d. Try 0fIIDrt1g your
paSlWOl'd on your device. You cannot accoss BllICkBerry App Wottd an your
OrpURM. ADD For BleckBtrry Yemion 3 0 2 Be!""ed With New '"
blackborryrock . coml .. blackMrry .....1oo-3-0 2-rolo ...
Oct 17. 2011 Tno GroupMo team tot rna know rhOy'YOrOIOnOd II nevr ver.1On of thew
appllcltlon tor BlackBerry I manphono, . TI'\Ia IPP lots usors chat wI:h ..
FIM OrpURM. ApR For B1tckBtmr Smartphones UPdated To ..,
blockborryrocka.coml .. Jfr..
Sop 13. 2011 - OroupMo today ro"','" a naw YOIlton alb Iroo oppllclrllon ""
8'ackBorry Imaftpl'lOnOa. Tnil app aIOws uHl"11O MOd met... to eacl"l ..
Fi le Edi t View History Bookmarks Window Help I] @ (98\\ll Mon 9:55 PM
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I'i1GmOlii - Compose - j d ..' t grouPie,app website - c;oc
https :/ / www.google.com/search?ix - hea&sourceid - chrome&ie- UTF-8&q - groupie+app,\l hl- en&s cl ient - psy- ab&q -groupie+app+webs ite&pbx- l&oq- groupie+app+website&aq - f&aqi-q-w2&aql-&gs_sm- e&gs
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groopme.com/
Frco Group Messaging That Works On EYery Phon e. Sign Up Log In. Hom.pago.
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Moro
lew weeks ago - GroupMa Blog
bIog.groupme.com/postl842761765o4/groupmo-Ohroo-poill-oh
Aug 3. 2011 Gl'OupMo lots you o1I0rU00 sly group lOX! wth tho pcopIO n your lifo that
oro ... Now oyory thing you can do on the app Is passbiD on the w eb .
Old Tappan. NJ
Chango iccation
All roeutUi
GroupM. Blog
bIog.groupme.com/
Group. t:I/T)gI group mcssaghg and so rTlJch more to your phone. Group text wlh ..
Now evcrytlWtV you can dO on tho app is posstiD on the ..b . Stilrt and ...
Roiluoo soarchos
More search tools
Let U8m D!!!Iicjoate frpm the website . GroupMa Supoort
ho\>.groopme.com/ .. ..rrom__alto
I chOCk my groupma messages ttYough the a"., bill there's no way to reply ..
Googk) Latludo has thll ' corum . but GoogWJ's Disco .com I PP is not d oso to ".
Free GroupM. - Download Group'" . Free Appa from BlackBerry ...
oppworld. blackborTy .comlwobstcroiconlOntl3' '33
Fhd Group'" for your Bblck8erry SmartphonO. 00wrU000 Group'" by GroupMo
from BlackBerry App World & discover marc ." App World Web PIugil Error ".
GrouDMo Group Chatting ApD
4997020
Mar 18. 2011 To got stQrtod. download tho opproprlato app or usc tho Group'"
web,tle 10 ontOI' your ruJ.tnC and numbor. Then. enter names and numbers of ...
GroupMe Wins Best Group Messaging App at SXSWi The Next Web
thonextwob.comloppoi.. .Igroopme-wtns-besl-grOUJ)-......agI.
by Courtney Boyd My.,. . n '3.180 Googio. circlos More by CourtMy Boyd My..
Mar 16. 2011 I .'kO<!. Wtors your fovorte group mosoagng app? ROflIY to this
IWOCt tho II- 1 for Gl'OupMo 2 Beklga 3 Fast Society 4 Groupodfon} 5 _ r ."
GroupM. Gives Push Notifications A Big Hug. Also MaDS And ,, '
tochcrunch.comI2011/ ..Jgroupmo-push-no<Iicationomopo IounIQuar...
Mar 1, 2011 Ho oyorsocs the Bdlorill content at tho alte, to program 1M . Up
untl now, me Group'" .pp wo.s a way to aot up taxIng ...
GroupMe Jus! OyertJauled Its App To Include Dirvct Messaging And ..
artJc_.bu'Si'IOI'Nldor. corrV.. ...
Aug 3. 2011 - Tho Group'"team has announced the nawest roiBase of Its . pp, and
it's fuM of cool updates. Hore'. whot user. hav e 10 look forwnrd to on top .. .

Groupie Answer With Counterclaims 8-28-12

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