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Edwin F. McPherson - State Bar No. 106084
emcDherson@mcphersonrane.com
Tracy13. Rane - State Bar No. 192959
trane@mcDhersonrane.com
Mcpherson rane llp
1801 Century Park East, 24th Floor
Los Angeles, CA 90067
Tel: (310)553-8833
Fax:(310)553-9233
John D. Wilson Jr.
wilson@,wsca.com
Alfred E Donohue
donohue@wscd.com _^^T
WILSON SMITH COCHRAN DICKERSON
901 Fifth Avenue, Suite 1700
Seattle, WA 98164
Tel: (206)623-4100
Fax: (206)623-9273
Attorneys for Plaintiff
EXPERIENCE HENDRIX, LLC
UNITED
FOR THE CENTRAL
EXPERIENCE HENDRIX, LLC, a
Washington Limited Liability
Company,
Plaintiff,
vs.
ZABELL ENTERTAINMENT, LLC,;
California Limited Liability Company;
TOMZOTOS, an individual; and THE
JAMES MARSHALL HENDRIX
FOUNDATION d/b/a JIMI HENDRIX
FOUNDATION, a Washington
Corporation,
Defendants.
STATES DISTRICT COURT
DISTRICT OF CALIFORNIA
r
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CASE NeviA-07865HwM
COMPLAINT FOR:
1. TRADEMARK
INFRINGEMENT
2. CONTRIBUTORY
TRADEMARK
INFRINGEMENT
JURY TRIAL DEMANDED
Complaint
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Experience Hendrix, L.L.C. (hereinafter
Zabell Entertainment, LLC, Tom Zotos,
Foundation dba Jimi Hendrix Foundation
follows:
"Plaintiff), for its Complaint against
and The James Marshall Hendrix
(hereinafter "Defendants"), states as
SUMM, IRY OF CLAIMS
THE HENDRIX FAMILY'S COMMITMENT TO PRESERVING JIMI
HENDRIX'S MUSICAL AND CULTURAL LEGACY AND ITS VALID
SENIOR TRADEMARKS PROTECTING THAT LEGACY
1. Jimi Hendrix was a famous
died in 1970. James Allen "AT Hendrii
Hendrix died in 2002.
2. The Jimi Hendrix estate
musical compositions, audio-visual worKs
photographs, and other properties and ri
agreements, Al Hendrix assigned his rig
of Jimi Hendrix to Plaintiff and its
("Authentic") in 1995. Thereafter,
Jimi Hendrix's musical compositions
3. Plaintiff owns original sourld
tapes for Jimi Hendrix's major albums,
produces audio and audiovisual product^
these products and related rights throug
are commercially available and sold to t
website www.iimihendrix.com.
4. Authentic licenses, sells,
numerous types, owns the website www
musician, guitar player, and celebrity. Jimi
was Jimi's father and sole heir. Al
included, without limitation, sound recordings,
, copyrights, trademarks, writings,
*hts of Jimi Hendrix. By written
its personally and as sole heir to the estate
subsidiary company Authentic Hendrix, LLC
Plaintiff has been the owner and administrator of
related copyrights, and all trademarks,
and audiovisual recordings and master
ive concerts and other works. Plaintiff
derived from these recordings and license
Hout the world, and Jimi Hendrix's works
le general public. Plaintiff owns the
and
and oversees Jimi Hendrix merchandise of
authentichendrix.com, and licenses Jimi
Hendrix merchandise, which is promoted throughout the world.
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Complaint
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5. Together, Plaintiff and
administer, and license, in the United
and artistic properties of the late Jimi
services related to Jimi Hendrix, using
trademarks, service marks, trade names
and services are marketed and promotec
Internet websites, retail stores, and 1
industry venues, events andpublication^
6. Al Hendrix and his close
been singularly committed to preservin
artistic legacy. The Jimi Hendrix family
licensed, and tastefully marketed Jimi's
related merchandise throughout the world
the Hendrix family companies' continued
and his works are well known, and he
7. Since 1996 or earlier,
companies have used, federally registered
marks, trade names, and logos ("Hendri|x
related promotional merchandise and
through catalog sales and Internet websites
Hendrix Marks include the federally
"THE JIMI HENDRIX EXPERIENCE'
HENDRIX", and "AUTHENTIC
Authentic own, sell, market, promote,
Stjates and overseas, the music, recordings,
Hendrix, and promotional merchandise and
federally registered and common law
and logos. Plaintiffs and Authentic's goods
to the general consuming public through
licensee sales, and through entertainment
ft mily members and their companies have
Jimi Hendrix's musical, cultural, and
companies have owned, managed,
music, recordings, artistic properties and
. As a result of Jimi's unique talents, and
stewardship and promotion, Jimi Hendrix
continues to enjoy celebrity status.
owned, and the Hendrix family
and common law trademarks, service
Marks") to sell Jimi Hendrix's music and
services to the general consuming public
, retail stores, and licensee sales. The
trademarks: "JIMI HENDRIX",
, "HENDRIX", "EXPERIENCE
", and the following design marks:
Plaintiff has
registered
HENDRIX
///
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///
Complaint
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*'
A*!*;
HENDRIX HENDRIX
8. Through substantial and
services under the Hendrix Marks for
companies have been the recognized
services. The Hendrix Marks are well-
States and elsewhere.
9. Additionally, by their
educational events, and private touring
emphasizing the cultural and artistic leg
companies have intentionally associated
innovative spirit, and musical and artistic
10. Plaintiff owns registered
the United States Patent and Trademark
which are incontestable pursuant to 15
of the allegations herein: U.S. Regi
clothing in Class 25); 2,245,408 ("
telephone and online ordering services
neai
u
colntinuous sales and promotion of goods and
rly two decades, the Hendrix family
source of Jimi Hendrix-related goods and
ktnown by consumers throughout the United
sponsorship andpromotion of charitable and
music, art and multimedia events
icy of Jimi Hendrix, the Hendrix family
their Hendrix Marks with Jimi Hendrix's
talent.
Hendrix Marks onthePrincipal Register of
Office (hereinafter, "USPTO"), many of
.S.C. Section 1065, including for purposes
istratfon Nos. 2,322,761 ("JIMI HENDRIX" for
AUTHENTIC HENDRIX" for mail order,
n Class 35); 2,245,409 ("EXPERIENCE
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Complaint
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namely HENDRIX" for printed materials,
2,250,912 ("EXPERIENCE HENDRIX
sound recordings, in Class 9); 2,383,500
services, in Class 41); 2,987,556 ("EXP
services, in Class 41); 2,997,676 ("JIMI
and music publishing, in Class 41); 3,0C
(signature logo), for online services (
3,001,465 ("JIMI HENDRIX AND
(posters, books, etc.) and related goods,
("JIMIHENDRIX.COM" for online
("JIMIHENDRIX.COM AND DESIGN
services, in Class 41); 3,072,909 ("
bust logo) for online retail store services
services, in Class 35); 3,334,862 ("
(headshot logo) for printed matter (post
Class 16); 3,302,117 ("AUTHENTIC
for clothing, in Class 25); 3,302,110 ("
records, DVDs, in Class 9); 3,409,133 (
3,302,118 ("HENDRIX" for clothing, ir
AND DESIGN" (signature logo) for clo
HENDRIX AND DESIGN" (combined
16); 3,328,579 "JIMI HENDRIX AND
logo) for t-shirts, in Class 25); and 3,25(j>
EXPERIENCE" for clothing, in Class
trademarks referenced in this paragraph
"Registrations," and the marks shown
"Registered Marks".
11. The Registrations are valid
magazines and posters, in Class 16);
AND DESIGN" (bust logo) for musical
("JIMI HENDRIX" for entertainment
iRIENCE HENDRIX" for entertainment
HENDRIX" for online services (website)
1,464 ("JIMI HENDRIX AND DESIGN"
) and music publishing, in Class 41);
(signature logo), for printed matter
in Class 16); 2,998,059
ite) services, in Class 41); 2,998,058
" (signature logo) for online (website)
DESIGN" (Jimi Hendrix
telephone order and online ordering
HENDRIX AND DESIGN"
, photographs, etc.) and related goods, in
HENDRIX AND DESIGN" (headshot logo)
LENDRIX" for compact discs, phonograph
HENDRIX" for stickers, in Class 16);
Class 25); 3,306,892 ("JIMI HENDRIX
hing, in Class 25); 3,328,587 "JIMI
bust and signature logo) for posters, in Class
DESIGN" (combined bust and signature
,776 ("THE JIMI HENDRIX
. Collectively the US registered
10 herein shall be referred to as the
thlerein shall be referred to collectively as the
website)
DESIGN'
(website
MISCELLANEOUS
AUTHENTIC
crs,
2-5)
and continuing.
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12. Plaintiff has referred to anc
"A Jimi Hendrix Family Company,"
Plaintiffs letterhead, showing the
Jimi Hendrix Family Company" is
13. Plaintiff uses, licenses,
in connection with a broad range of g<
14. Plaintiff has spent a
associating its Hendrix Marks with the
Family"- endorsed music, products, and
marketed itself in interstate commerce as
at least as early as 1996. A copy of
company's logos, and the prominent slogan "A
attac led as Exhibit 1.
advertises and promotes the Registered Marks
and services,
considerable amount of time, effort and money
plaintiffs authorized and "Jimi Hendrix
services.
sinse
pods
DEFENDANTS'
15. In July 2014, Defendants Zbbell
("Zotos Defendants") began to promote
infringing Hendrix Marks (see Exhibit 2j)
bust logo:
16. On information and belief,
on the advertised Jimi Hendrix products
at www.zabellentertainment.com. See
17. On information and belief,
Zabell and is responsible for the day to
directed the infringing conduct, he profi
personally responsible for the acts of
INFRINGING ACTS
Entertainment, LLC and Tom Zotos
t-shirts and posters for sale bearing
, including a Jimi Hendrix "headshot" or
the Zotos Defendants designed the images
and offered to sell them on Zabell's website
Hxhibit 3.
Defendant Zotos is the owner of Defendant
day operations of Zabell, and personally
:s from the infringement, and he is otherwise
infringement alleged herein.
Complaint
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18. On information and belief,
promotional materials, websites, labels
coordinated by Defendant Zotos, and
confuse the public, and to unjustly profilt
Plaintiffs Hendrix Marks and business.
19. Defendant Zotos on his website
client "The Estate of Jimi Hendrix,"
with the Plaintiff and its goodwill.
20. Plaintiff authorized the use
on a t-shirt produced and promoted by
Foundation for a charitable purpose.
www.zabellentertainment.com, Defenddnt
Foundation's logo in connection with P
logos of the t-shirt's authorized sponsork
Cafe), thus falsely and deceptively leadib
Foundation was involved with the Plain
21. As a result, Defendant Zotds
www.zabellentertainment.com, falsely
the sale of the t-shirt authorized by Plaiiitiff
mark) were connected to or benefited th
Foundation (hereinafter "Foundation").
22. Defendant Zabell's website
activities for the sale of "apparel, art
authorized products.
23. Defendant Foundation
of Hendrix Marks by the Zotos Defendants
and selling the products created by the
marks.
Defendant Zabell's marketing and
products, containers, and statements are
constitute a joint and concerted effort to
from the goodwill associated with
ite www.tomzotos.net falsely listed as his
intending to promote his association cleirly
of its Jimi Hendrix "signature" logo for use
Hard Rock Cafe and the Fender Music
Defendants prominently displayed, on
The James Marshall Hendrix
aintiff s authorized t-shirt and alongside the
(Fender Music Foundation and Hard Rock
g the public to believe that the Defendant
iffs activities. See Exhibit 3.
, on his website
deceptively suggests that proceeds from
(and bearing its registered signature
2 Defendant James Marshall Hendrix
tie
Tie
nd
falsely and deceptively links its infringing
and collectibles" to Plaintiffs legitimate pruts
authorized the unauthorized and infringing uses
, and itself is using the Hendrix Marks
2|otos Defendants bearing the infringing
Complaint
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24. Defendant Foundation is
www.jirnihendrixl .comand www.jimih|endrixfoundation
elsewhere, including:
25. Plaintiff has not granted au
to use the Hendrix Marks or any similar
26. Defendants are not
directors, or members of Plaintiff is a
companies.
27. Plaintiff has not granted au
registration, use or ownership of the dorhain
bearing infringing marks at, www.jimihknd
28. Plaintiff has objected to and
objections to the unauthorized uses
Hendrix and other indicia owned by Pla
29. The Foundation website www
following notice:
"1988 - 2014. "Jimi Hendtfx'
signature, Jimi Hendrix head bust
Hendrix Foundation", "Jimi Henarix
Hendrix Foundation" and any
for charitable purposes, all URL'
"Foundation" and/or "James Marshall
Trademarks of The James Marshall
contents of this website 1988
Foundation 501(c)(3). All Rights
u$ing infringing marks on its websites at
com and on Facebook and
horization or permission to the Defendants
marks for any purpose,
sanctioned by Plaintiff. None of the officers,
dilrector or participant in Defendant
horization or permission for the
name, or the sale of, merchandise
rixl .com. See Exhibit 4.
put the Defendants on written notice of its
of th[e similar "headshot" or bust logo of Jimi
ntiff.
jimihendrixfoundation.com bears the
", "Jimi Hendrix", stylized
image/logo, "James Marshall
Foundation", "James Marshall
of the Jimi Hendrix name or image
s containing "Jimi Hendrix" and
Hendrix" and "Foundation" are
Hendrix Foundation. The entire
2014 James (Jimi) Marshall Hendrix
Reserved."
uso
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30. The Defendants own no U.
"JIMI HENDRIX (FOUNDATION)" or
(FOUNDATION)". The Foundation
website, contrary to federal law, and
using "JIMI HENDRIX" and the "JIMI
actions and statements likely are or will
31. Defendants claim they are
a permission granted by Al Hendrix to
terminated or been revoked, and which
and such claims are thus false and
association with Al Hendrix and the
32. By the above actions, it is
license the Hendrix Marks, or confusingly
sold and marketed in interstate commerce
33. Defendants have created
materials, and labeled their products anc
has caused confusion, and is likely to
as to the source, sponsorship, affiliation
services with those of Plaintiff, and to
are not limited to:
a. Defendants' uses
HENDRIX EXPERIENCE" and
confusion with Plaintiffs Hendrh
HENDRIX", "EXPERIENCE
EXPERIENCE", including Hendrix
USPTO.
b. Defendants' use
or "headshot," as part of or separate
S. registered trademarks bearing the name
"JAMES MARSHALL HENDRIX
the symbol "" next to its logo on its
rights to all marks and domain names
HENDRIX" signature and bust logos, which
be confusing to the consuming public.
Authorized to use infringing marks based on
I,eon Hendrix in the 1980's, which has
<|ioes not cover the activities of Defendants,
ing because of Plaintiff s long-standing
family,
cjlear Defendants use and intend to use and
ly similar marks, for products and services
, and contrary to the rights of Plaintiff,
distributed marketing and promotional
licensed products in such a way that likely
to cause confusion in the marketplace
and connection of Defendants' products and
harm Plaintiff. Defendants' acts include, but
of "JIMI HENDRIX", and "JIMI
either indicia creates a likelihood of
Marks, including, but not limited to, "JIMI
HENDRIX", and "THE JIMI HENDRIX
Marks that are registered with the
US2S
claims
confij sin
Hendrix
and
continue
of a graphical design of Jimi Hendrix's bust
from the words "JIMI HENDRIX
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FOUNDATION" (with "JIMI HENDRIX" most prominently displayed)
creates a likelihood of confusion with Plaintiffs HendrixMarks, including
Plaintiffs registered stylized graphical mark of a bust or "headshot" logo, and
the combination of the Hendrix Marks used by Plaintiff.
c. Defendants' use of and claims to rights to the entire signature
of Jimi Hendrix (in a close or near identical approximation of Plaintiff s
signature logo) is likely to confuse consumers.
d. Defendants' statements that the Defendants' actions and the
Foundation is supported and endc rsed by Al Hendrix and the Hendrix Family
is confusing and inaccurate and will cause confusion as to the source of
Defendants' products and services by suggesting that Defendant Foundation
is Plaintiff, or is owned, sponsored, or endorsed by Plaintiff.
THE PARTIES
34. Plaintiff Experience Hendr x, L.L.C. is a limited liability company,
licensed to do business in Washington, with a principal place of business at 14501
Interurban Avenue South, Seattle, Washington, 98168. Plaintiff owns the federal
trademark Registrations alleged herein.
35. Defendant Zabell Entertainnent, LLC ("Zabell") is a California limited
liability company located at 10866 Wilsiire Blvd., Suite 890, Los Angeles, CA
90024, and is controlled by Defendant Tom Zotos.
36. On information and belief, Defendant Tom Zotos ("Zotos") is the
primary member and manager of Defendant Zabell and controls and directs
Defendant Zabell.
37. Defendant The James Mars lall Hendrix Foundation dba Jimi Hendrix
Foundation is a Washington nonprofit corporation, formed on or about January 28,
2003, after Al Hendrix died. The current President/CEO is Joe Rosignolo, who
resides at 12625 Danielson Ct, Suite 104, Poway, CA 92064.
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Complaint
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JURISDICT ON AND VENUE
38. This is a suit for trademark
infringement, and arises under the
trademark laws of the United States, namely Title 15 of the United States Code and
more particularly 15 U.S.C. 1114 and
15 U.S.C. 1116-18, inclusive. This
Court has jurisdiction under the provisions of 15 U.S.C. 1121 and 28 U.S.C.
1338(a) and 1338 (b). Venue is proper in this District under 28 U.S.C. 1391(b)
and 1391(c).
39. Defendant Zabell is a California limited liability company and, on
information and belief, Defendant Zotos is the principal and owner of Defendant
Zabell, and is responsible for the day to
directed the infringing conduct, profits
personally responsible for the acts of in
Foundation is doing business in and out
Joe Rosignolo who resides in Poway, Cilifornia.
40. Defendants offer to sell and do sell "JIMI HENDRIX" branded
merchandise, including posters and t-sh rts, throughthe Internet and otherwise,
throughout the U.S. On information and belief, Defendants have placed infringing
products into the stream of commerce, with knowledge or intent that those products
would be sold or distributed in the State of California.
FIRST CLA1M FOR RELIEF
day operations of Zabell, and personally
k>m the infringement, and is otherwise
ringement alleged herein. Defendant
of the State of California, through its CEO
41.
(For Federal Trademark Ir fringement, 15 U.S.C. 1114-
Against All Defendants)
Plaintiffrealleges andincoiporates Paragraphs 1through 40, as though
fully set forth herein.
42. Plaintiffhas adopted and us ed in interstate commerce the Registered
Marks for a broad range of goods and services, including: clothing andaccessories,
musical recordings (e.g., CDs) andvideos (e.g., DVDs), printedmatter (e.g., books,
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postcards, and posters), and online (website) and entertainment services. Such
Registered Marks are well-known, and ttiey have been used continuously since long
prior to Defendants' use of the Hendrix Marks, or the incorporation of the
Defendant companies.
43. The Registrations are primafacie evidence of Plaintiff s exclusive
rights in and ownership of the marks shown therein throughout the United States,
and the validity and the registrations of such marks. The Registrations set forth in
paragraph 10 above are incontestable and are "conclusive evidence" of Experience's
exclusive right to use such registered msrks on the goods and services listed in those
registrations under 15 U.S.C. sec. 1115(:>).
44. Defendants' uses of the Hendrix Marks, and other marks and indicia of
origin which are confusingly similar to tie Registered Marks, are not authorized by
Plaintiff, are likely to cause confusion, to cause mistake and to deceive as to the
source of the goods and services offered by Defendants, in that consumers will
likely associate Defendants' products and services with Plaintiff, to the detriment of
Plaintiff.
45. Defendants' infringing conduct is intentional, willful, and designed to
mislead, deceive and confuse the consuming public, and to capitalize on the
goodwill associated with Plaintiffs Reg: stered Marks, and is intended to palm off
Defendants' goods as those of Plaintiff.
46. Plaintiff has provided written notice to Defendants of Plaintiffs
Registrations and rights, but Defendants have refused to cease their infringing acts.
By virtue of their unauthorized uses of the Hendrix Marks and other marks similar
to Plaintiffs Registered Marks in interstate commerce, and the likelihood of such
uses to cause confusion, to cause mistake or to deceive, Defendants have violated,
and continue to violate, the rights of Plaintiff under the U.S. Trademark Act, giving
rise to a cause of action under 15 U.S.C. 1114(1).
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47. Unless enjoined and restra
to engage in such unlawful conduct.
Defendants will continue their infring
15 U.S.C. 1114. Plaintiff therefore
relief precluding Defendants from
use, reference to or association with the
other injunctive relief as may be
infringement of its rights in and to the
48. Plaintiff further alleges tha
Defendants' infringing actions as allege
damages, as well as Defendants' profits
damages. Attorney fees are authorized
articles is authorized by 15 U.S.C. 11
Defendants to withdraw and abandon
that have been filed, if any, and not to
on Plaintiffs rights.
ned by this Court, Defendants will continue
Plaintiff has no adequate remedy at law inthat
conduct, as alleged above, in violation of
preliminary and permanent injunctive
acts of infringement and from any further
Registered Marks. Plaintiff seeks such
and appropriate to protect further
gistered Marks.
: it has been damaged as a result of
herein. Plaintiff is entitled to recover its
treble damages and corrective advertising
)y U.S.C. 1117. Destruction of infringing
8. Plaintiff requests that the Court order the
applications to register the Hendrix Marks
further applications for marks infringing
ing
seeks
further
reasonable
Pet
ed
any
file
SECOND CLAIM FOR RELIEF
(For Contributory Trademark Infringement
49. Plaintiff realleges and incoi(porate
fully set forth herein.
50. Defendant Zotos is, on infohnation
controlling the infringing activities of Defendant
51. By reason of the actions afdresaid
Registered Marks by Defendant Zabell
or authority of Defendant Zotos.
52. Upon informationand belief
caused the infringement of Plaintiff s Hejndrix
has
Against Defendant Zotos)
s Paragraphs 1 through 48, as though
and belief, personally directing or
Zabell, or benefiting by such acts,
id, the infringement of Plaintiffs
been directed by, and under the control
', Zotos has contributorily infringed or
Marks, all to the detriment of
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Plaintiff. The infringements by Zotos
irreparably harm Plaintiff, have been willlful
this Court. Damages, including for contective
authorized by 15 U.S.C. 1117. Destruction
o|f Plaintiffs rights in its Hendrix Marks will
, and will continue unless enjoined by
advertising, and attorneys' fees are
of infringing articles is authorized by
15 U.S.C. 1118.
WHEREFORE, Plaintiffs jj>rays for judgment against Defendants, and
each of them, as follows:
AS TO THE FIRST CLAIM FOR RFXIEF
1. For treble the amount of
sustained and will sustain as a
Hendrix Marks, together with interest
amount to be proved at trial;
2. For an accounting by
profits, and advantages derived by them
Hendrix Marks;
3. For an Order requiring
Plaintiff all gains, profits, and advantag
based upon their infringement of the
4. For a temporary, prelimin
the powers granted to this Court under 1
Defendants (and their distributors,
from directly or indirectly using the
or slogan similar to the Hendrix Marks
or to deceive. And that this Court,
1118, order that all labels, signs, print$
and advertisements in the possession or
employees, agents, related parties and li
compensatory damages that Plaintiff has
consequeince of Defendants' infringement of the
thereon at the maximum legal rate, in an
Defendants, and each of them, of all gains,
, based upon their infringement of the
Defendants, and each of them, toturn over to
$s derived by Defendants, and each of them,
Hebdrix Marks;
ary, and permanent injunction pursuant to
5 U.S.C. 1116, enjoining and restraining
employees, agents, related parties and licensees)
Hendrix Marks or any other mark, word, name,
>|vhich is likely to cause confusion, mistake
pursuant to the power granted it under 15 U.S.C.
, packages, wrappers, receptacles, websites,
control of Defendants (or their distributors,
oensees) bearing the infringing marks, and
14-
Complaint
H sis
Z ,_- z
2,
Ah w '
y o .
1
2
3
4
5
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7
8
9
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12
13
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28
all plates, molds, matrices and other meians
up and destroyed. And that this Court
any registrations or pending application^
domain names infringing the rights of P|laintiff;
5. For reasonable attorneys'
6. For punitive andexemplary
damages against Defendants, jointly and
amount to be determined at trial by reason
of making the same, shall be delivered
cfrder the Defendants to withdraw or abandon
with the USPTO or elsewhere for marks or
lintiff;
fees in an amount to be proved at trial;
damages and corrective advertising
severally, and in favor of Plaintiff in an
of Defendants' palming off.
AS TO THE SECOND CLAIM FOR RELIEF:
7. For treble the amount
sustained and will sustain as a
Hendrix Marks, together with interest tl
amount to be proved at trial;
8. For an accounting by Defendants
profits, and advantages derived bythem],
Hendrix Marks;
9. For an Order requiring
Plaintiff all gains, profits, and advantag
based upon their infringement of the Hehdrix
10. For a temporary, preliminary
the powers granted to this Court under
Defendants (andtheir distributors, employees
from directly or indirectly using the Heiidrix
or slogan similar to the Hendrix Marks
or to deceive. And that this Court
1118, order that all labels, signs, print$
and advertisements in the possession or
of compensatory damages that Plaintiff has
consequence of Defendants' infringement of the
ereon at the maximum legal rate, in an
, and each of them, of all gains,
based upon their infringement of the
Defendants, and each of them, toturn over to
derived by Defendants, and each of them,
Marks;
, and permanent injunction pursuant to
U.S.C. 1116, enjoining and restraining
, agents, related parties and licensees)
Marks or any other mark, word, name,
jvhich is likely to cause confusion, mistake
pursuant to the power granted it under 15 U.S.C.
, packages, wrappers, receptacles, websites,
control of Defendants (or their distributors,
;es
-15-
Complaint
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
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25
26
27
28
employees, agents, related parties and
all plates, molds, matrices and other meftns
up and destroyed. And that this Court
any registrations or pending application^
domain names infringing the rights of P
11. For reasonable attorneys'
12. For punitive and exemplary
damages against Defendants, jointly anc
amount to be determined at trial by
licensees) bearing the infringing marks, and
of making the same, shall be delivered
the Defendants to withdraw or abandon
with the USPTO or elsewhere for marks or
aintiff;
fees in an amount to be proved at trial;
damages and corrective advertising
severally, and in favor of Plaintiff in an
of Defendants' palming off.
order
reason
AS TO ALL CLAIMS FOR RELIEF
13. For costs of suit herein inburred;
14. For such other and furthei relief as the Court deems just and proper.
Dated: October 9, 2014 Edwin F. McPherson
Tracy B. Rane
Mcpherson rane llp
John D. Wilson. Jr.
Alfred E. Dononue
WILSON SMITH COCHRAN
DICKERSON
16-
FTMcPHERSUN
Attorneys for Plaintiff
Experience Hendrix, LLC
Complaint

^H
1 DEMAND F<)R JURY TRIAL
2 Plaintiff EXPERIENCE HENDR X, LLC hereby demands a trial by jury in
3 this case.
4
5
6
Dated: October 9, 2014 Edwin F. McPherson
Tracy B. Rane
Mcpherson rane llp
7
8
John D. Wilson. Jr.
Alfred E. Dononue
WILSON SMITH COCHRAN
DICKERSON
9
^<>^
10
11
12
edwimtTmcpherson
Attorneys for Plaintiff
Experience Hendrix, LLC
13
14
15
16
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23
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-17-
Complaint
^M
S/f II
EXHIBIT "1
%
>**'*
HENDRIX
~A JIMI UMm FAMILY COMPANY'
WV US OK lilt iwetvtr
www.jimihendrix.com
e
EXHIBIT 1
jA
Experience Hendrix, L.L.C.
PO Box 88070
Seattle. WA 98138
Tel: ,20G' 241 5464 iJIMI)
Fax: (206; 241-5477
^H|
//<*ll
EXHIBIT "2
&P
atusi lom^xnos ueouts jiim nenurix ijegacy <u)uecnon: i-anirts ana... nttp
EXHIBIT
.7/scoaix.convnew/amst-tDm-zotos-deDias-jimi-hendrix-legacy-coll...
lof3
Artist Tom Zotos Debuts
Jimi Hendrix Legacy
Collection: T-Shirts ahd 3-D
Posters to Benefit Jinfii
Hendrix Foundation
July 16, 2014 A admin & * Comments Off
Artist/publisher Tom Zotos
created a new collection of
images on 3D enhanced prints
and high end t-shirts that
highlight the historic places and
timeline that led to Jimi
Hendrix's meteoric rise iih the
late 60's
PR Newswire
LOS ANGELES, July 16, 2014
LOSANGELES, July 16, 2014/PRNewswire/ Tom Zotos team
Hendrix Foundation to exclusively offer his newest collection
and t-shirts to fans at www.jimihendrixl .com. Agenerous port
proceeds will benefit the Jimi Hendrix Foundation, a non-profit
organization founded by Jimi's father, "Al" Hendrix. Zotos is krpown
philanthropic B2Bcollaborations that benefit charities. His la
raised multi-millions for three prominent charities.
s up with the Jimi
of 3D poster art
ion of the
charitable
for
>t endeavor
Commercial Print
Folding Carton
Web 2 Print
Designers & Brand Owners
News & Events
Support
Company
Contact Us
fr
10/2/2014 4:36 PM
atusi lomzxnos ucduis jiiiu ncuuiiA txgauylAjucuLiuii. i-omiis aiiu... iai]).//si;<juiA.i;oiiviicw/arusi-ioni-zuLos-ueowii-jimi-ncnurix-iegacy-coii
^A
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2 of3
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Supporting the Musical Passion of Children
"Sales of the Jimi Hendrix posters and t-shirts will support
program 'Music For Life,'" said Joe Rosignolo, President/CEO
Foundation, "dedicated to benefitting children with a musica
image, illustrated by Zotos, "I've Got A Guitar", celebrates Jim
15 when his dad, Al, gave him his first electric guitar. Jimi
guitar!" which echoed throughout the neighborhood.
thj foundation's
Df the Jimi Hendrix
passion." One
i Hendrix at age
I've got a yelled
45th Anniversary of Woodstock
To celebrate the 45th anniversary of Woodstock, a cultural
influenced generations, Zotos graphically captured the perform
"Star Spangled Banner" in his 60's inspired "Star Spangled Jim
of limited edition posters and t-shirts highlight Jimi Hendrix's
pivotal performances at Monterey Pop Festival, Hollywood
Hall, and includes a commemorative, '"Scuse Me", that pays
to Jimi's short but inspirational career.
tquchstone that
anceof the
i". The collection
greatest and
, Royal Albert
final homage
BdwI,
the-
Digital Printing Enhancement
"ScodixOn Top" is being used for the first time on a collectib
artist Tom Zotos. The first three posters in the collection featlu
revolutionary 3D effect using "Scodix On Top", a new and uni 3
that enhances the artwork to transcend personal senses bey and
Developed by Scodix Ltd., the new digital enhancement techn
look-and-feel to high-quality artwork that stimulates human
provides depthto imagery. The breakthrough Scodix SENSET| experience is
now available through high-end commercial printing operations worldwide.
For more information visitwww.scodix.com.
Fans can receive the eNewsletter announcing special Jimi Hendrix events and
news happenings all over the world by subscribing at www.JiiniHendrixl .com.
"Like" @www.Facebook.com/jamesmarshalhendrix1 site to sjtay tuned to all
e art print by
res the
ue technology
just sight,
ique adds a 3D
senses and
T.%
10/2/2014 4:36 PM
miuh lornzxuus ucuuis jiuu ncuuiix ixgaty wmcuuuiL i-auirw auu... mi3://scoaix.convnew/arast-iom-20tos-QeDUts-jimi-nenarix-iegacy-coll
the newest social media buzz onJimi Hendrix art, apparel, ahd Foundation
programs.
About Zotos
Tom Zotos is the legendary pioneer behindthe Interpretive
Movement and the artist, publisher, and secret weapon beh nd
Bros, Lucasfilm, and the Walt Disney Company. An intrepid
birth and veteran inthe world of art publishing, Zotos directed
some of the most revealing and thought provoking images
including "The Art of Walt Disney" collection (1986) and the"
tribute toMel Blanc (1991-92), thehighest grossing lithograp|h
animation art. Today, Zotos has applied his savvymarketing
skills to "Social Innovation" or as he calls it, 'The Art of Social
terms broadly cover the concept of new ways to give back
by using branded art products with collaboration between
story of an innovator using both images and lifeas a med
illustrated legacies and entrepreneurial precedents.
Contact George Guebelli
310-593-3833
Email
Licensed Art
the Warner
ntrepreneur from
and published
the last 25 years
speechless"
in the history of
and art direction
nnovation". Both
improve society
panies. His is a
, creating
cf
and
com
Jiun
Photo - http://photos.prnewswire.com/prnh/20140715/1274' 2
Photo-http://photos.prnewswire.com/prnh/20140715/1274;
SOURCE Tom Zotos
Read more: http://www.digitaljoumal.eom/pr/2057970#ixzz3;'ihW2AB0
&
10/2/2014 4:36 PM
arm rtenanx smnes un lop oime <om Anniversary oi wooastock fos... nt p://wmtmeytxnnitcorn/news/fjy44-jimi-hendrix-shines-top-45th-an.

lof4
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Jimi Hendrix Shines On Top of the 45th
Anniversary of Woodstock Posters Printed by
Scodix
Wednesday, August 13,2014
Press release from the issuing company
Alegacy collection ofJimi Hendrix posters, which incorporate a
breakthroughprinting process featuring a revolutionary 3D effect, are
now available
LOS ANGELES, CA - To celebrate the 45th anniversary of Woodstock,
a cultural touchstone that influenced generations, Zotos has graphically
captured the performance ofthe "Star Spangled Banner" in the
'60s-inspired "Star Spangled Jimi" poster. The collection of limited-
edition posters highlight Jimi Hendrix' greatest and pivotal performances
at Monterey Pop Festival, Hollywood Bowl, and Royal Albert Hall, and
includes a commemorative, "'Scuse Me," a graphic homage which pays
tribute to Jimi's short but inspirational career. The collection of never
before seen posters are available at wwwjimihendrix 1.com.
The posters are printed using a breakthrough Scodix SENSE printing
process which is being used for the first time on a collectible art print by
Zotos. The first three posters in the collection feature the revolutionary
3D effect using "Scodix On Top," a unique new technology that
enhances the artwork to transcend personal senses beyond mere sight.
Developed by Scodix Ltd., the new digital enhancement technique adds
a 3D look and feel shine to high-quality artwork of the posters that
stimulates human senses to provide depth to the imagery. The Scodix
SENSE experience is now available through high-end commercial
printing operations worldwide.
All Jimi Hendrix fans around the world must check out these art posters
at wwwjimihendrix I.com. Plus, there is a charity element attached to
any purchase at the website. "Sales ofthe Jimi Hendrix posters will
support the Jimi Hendrix Foundation's Music For Life program,
dedicated to benefitting children with a musical passion," said Joe
Rosignolo, President/CEO of the Jimi Hendrix Foundation. "One image,
'I've Got A Guitar.' illustrated by Zotos, celebrates Jimi Hendrix at age
^^
Share Tl is
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10/2/2014 4:45 PM
ami rtenanx amnes un lop oi ine torn Anniversary or wooastock r*os.
!of4
15. When his dad, Al, gave himhisfirst electric guitar, Jimiyelled,
'I'vegot a guitar!'which echoed throughout the neighborhood."
Limited Discount Available
Use Coupon Code - WOODSTOCK45 to get a 20% discount, good only
through the Woodstock Anniversary month of August 2014. A FREE
SHIPPING in the US offer is also available only
at www.jimihendrix l.cpm. Fans can own a piece ofJimi Hendrix's
historic rise and also be a part of a warm hearted good cause by ordering
a poster from anywhere in the world.
3 Email | A. Print | IP Order Reprints
Post a Comment
Topost a comment LogIn or Become a Member,dpingsp is simpleand
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an
10/2/2014 4:45 PM

//"HI
EXHIBIT "3
^
Consulting
^B
EXHIBIT:
ZABELL
Consulting
Our Services Super User 11 Apr 2014
Our agency is world renowned for its wide array of
design, product licensing, web design and development
innovation.
creative capabilities, including graphic
, branding and the new era of social
Zotos Is
Set to
Tom Zotos, Publisher / Artist, CEO of ZABELL En :ertainment, LLC
Generate Over $20 Million in T-shirt Sales
http://zabellentertainment.com/consulting[07/30/2014 1:21:26PM]
3rt
Consulting
0
In Tribute to Rock Legend Jimi Hendrix
$20 Million plus in t-shirt s ales were generated by
the Hard Rock International via a social
innovation idea originated by Tom Zotos,
Publisher / Artist, with the goal to benefit charity.
Tom Zotos has the "license?" to do it again.
Los Angeles, CA.- Tom Zotos motivatec
and Hendrix to collaborate and "give back"
Hard Rock's charitable division to put the iconic
a generous portion of
MUSIC
FOUNDATION
corporate giants Hard Rock, Fender,
to charity in a big way. He convinced
Jimi Hendrix on one t-shirt to give
sales to charity.
'{Hendrix
imi
toundati
This is the biggest selling t-shirt in our
year history," said a Hard Rock
pjokesperson at the Orlando
uarters. This time, Zotos has
ejsigned a collection of new Hendrix art
' will adorn apparel, art prints, and
dllectibles.
V
http://zabellentertainment.com/consultingt07/30/2014 1:21:26 PM]
///Ill
EXHIBIT "4
3
Prints
iu
https://www.jimihendrixl.com/jmh-store/all-categories/prints[09/05/2014 12:11:0: PM]
Prints
#
https://www.jimihendrixl.com/jmh-store/all-categories/printsI09/05/2014 12:11:0: PM]
Prints
^A
footer follow
newsletter
Subscribe
i m 1
foundation
^
https://www.jimihendrixl.com/jmh-store/all-categories/prints[09/05/2014 12:11:0: PM]
Prints
^
https://wwwjimihendrixl.com/jmh-store/all-categories/prints?start=9[09/05/2014 12:11:54 PM]
Prints
Q
footer info
footer follow
newsletter
Subscribe
imi
foundation
^
https://www.jimihendrixl.com/jmh-store/all-categories/pri nts?start=9[09/05/2014 12:11:54 PM]
T-Shirts
<1
https://www.jimihendrixl.com/jmh-store/all-categories/t-shirtsI09/05/2014 12:16:' 10 PM]
T-Shirts
*t
https://www.jimihendrixl.com/jmh-store/all-categories/t-shirtsE09/05/2014 12:16: K) PM]
T-Shirts
#
https://www.iimihendrixl.com/jmh-store/all-categories/t-shirtsE09/05/2014 12:16: to PM]
v J
STATE UNITED STATES DISTRICT COURT, CENTRAL DISTRICT OF CALIFORNIA
CIVIL COVER SHEET
CALIf
I. (a) PLAINTIFFS ( Check box if you arerepresenting yourself Q )
EXPERIENCE HENDRIX, LLC, a Washington Limited Liability Company
(b) County of Residence of First Listed Plaintiff King,WA
(EXCEPTIN U.S. PLAINTIFF CASES)
(c) Attorneys (Firm Name, Address andTelephone Number) Ifyou are
representing yourself, provide the same information.
Edwin F. McPherson
Tracy B. Rane
McPherson Rane, LLP
1801 CenturyParkEast, 24th Floor, Los Angeles,CA 90067
DE :ENDANTS ( Check box ifyou arerepresenting yourself Q )
ZAE ELL ENTERTAINMENT, LLC, a California Limited Liability Company; TOM ZOTOS,
an i idividual; and THEJAMES MARSHALLHENDRIXFOUNDATIONd/b/a JIMI
HEr]lDRIX FOUNDATION, aWashington Corporation
CoJintyof Residence of First ListedDefendant Los Angeles
UN(I.S. PLAINTIFF CASESONLY)
Att Drneys (Firm Name, Address and Telephone Number) Ifyou are
rep esenting yourself, provide the same information.
III. CITIZENSHIP OF PRINCIPAL PARTIES-For DiversityCases Only
an Xin one box for plaintiff and one for defendant)
PTF DEF , _, n , n,
Incorporated or Principal Place
of Business in this State
II. BASIS OF JURISDICTION (Place an Xin one box only.)
I I1. U.S. Government [x] 3. Federal Question (U.S.
Plaintiff Government Not a Party)
(Place
Citizen of Tti
Citizen of Arlother
1
3
rx] i
^
PTF
^
DEF
H 4
5
&
I I 2. U.S. Government
Defendant
I 14. Diversity (Indicate Citizenship
of Parties in Item III)
IV. ORIGIN (Place an Xin one box only.)
is State
State
bject of a Citizen or Si
Foreign CoLntry
Incorporated and Principal Place
of Business in Another State
I I 3 Foreign Nation
a s
6
X
1. Original
Proceeding

2. Removed from
State Court

3. Remanded from
Appellate Court

4. Reinstai ed or
Reopen ;d
5. Transferred from Another
District (Specify)
6. Multi-
I I District
Litigation
V. REQUESTED IN COMPLAINT: JURY DEMAND: [x] Yes No
CLASS ACTION under F.R.Cv.P. 23: QYes [x] No
(Iheck "Yes" only if demanded in complaint.)
N ONEY DEMANDED IN COMPLAINT: $
VI. CAUSE OFACTION(Cite theU.S. Civil Statute under which you are filing and writ^
15 USC1114 and 15 USC1116-18, inclusive, Trademark and Contributory Trademark Infria
a brief statement of cause. Do not cite jurisdictional statutes unless diversity.)
dement; 15 USC 1121; 28 USC 1338(a) and 1338(b); 28 USC 1391(b) and 1391(c)
VII. NATURE OF SUIT (Place an Xin one box only).
OTHER STATUTES
375 False Claims Act
r-, 400 State
L-l Reapportionment
410 Antitrust
Q 430 Banks and Banking
450 Commerce/ICC
Rates/Etc.
460 Deportation
rI 470 Racketeer Influ-
II enced &Corrupt Org.
Q 480 Consumer Credit
490 Cable/SatTV
850 Securities/Com
modities/Exchange
r-, 890 Other Statutory
II Actions
891 Agricultural Acts
i1 893 Environmental
lJ Matters
I| 895 Freedom of Info.
II Act
896 Arbitration
899 Admin. Procedures
Q Act/Review of Appealof
Agency Decision
II 950 Constitutionality of
II State Statutes
FOR OFFICE USE ONLY:
CV-71 (06/14)
CONTRACT
Q 110Insurance
120Marine
130Miller Act
i| 140 Negotiable
II Instrument
150 Recovery of
I I Overpayment &
Enforcement of
Judgment
151 MedicareAct
152 Recovery of
DefaultedStudent
Loan (Excl. Vet.)
153 Recovery of
| | Overpayment of
Vet. Benefits
ii 160 Stockholders'
II Suits
[| 190 Other
Contract
ii 195 Contract
II Product Liability
fj 196Franchise
REAL PROPERTY
Q 210 Land
Condemnation
220Foreclosure
230 Rent Lease &

Ejectment
REAL PROPERTY CONT.

240 Torts to Land

245 Tort Product
Liability
290 All Other Real
Property
TORTS
PERSONAL INJURY
[J 310 Airplane
315 Airplane
Product Liability

320 Assault, Libel &

Slander
ii 330 Fed. Employers'
II Liability
340 Marine
345 Marine Product
Liability
350MotorVehicle
355 Motor Vehicle
Product Liability
360 Other Personal
Injury
362 Personal Injury-
Med Malpratice
365 Personal Injury-
Product Liability
367 Health Care/
Pharmaceutical
Personal Injury
Product Liability
368 Asbestos
I I Personal Injury
Product Liability

IMA IGRATION

462 I Jaturalization
Appl cation
Other
gration Actions
465
Imm
TORTS
PERSOIIAL PROPERTY
3700ther Fraud
371
380

n 385h
ll Prod
ruth in Lending
Other Personal
Property Damage
roperty Damage
jet Liability
BANKRUPTCY
n 422
L-1 USC
n 423
L-1 USC
Appeal 28
158
Withdrawal 28
157
CIVIL RIGHTS
Other Civil Rights
' 'oting
440
441
442
443
(mployment
Housing/
Accommodations
445
Disabil
Em
446
Disaiii
American with
ities-
p oyment
American with
ilities-Other
Q 448 Education
PRISONER PETITIONS
Habeas Corpus:
| | 463 Alien Detainee
I1 510Motions to Vacate
II Sentence
530General
535 Death Penalty
Other:
540Mandamus/Other
550Civil Rights
II 555 Prison Condition
560 Civil Detainee
I I Conditions of
Confinement
FORFEITURE/PENALTY
625 Drug Related
I I Seizure of Property 21
USC 881
690Other
LABOR
710 Fair Labor Standards
Act
720 Labor/Mgmt.
Relations
740 Railway Labor Act
751 Family and Medical
Leave Act
790 Other Labor
Litigation
791 Employee Ret. Inc.
Security Act
Case Number:
>duct Liability l i_
CV14-0786B
CIVIL COVER! HEET
PROPERTY RIGHTS
820 Copyrights
830 Patent
840 Trademark
SOCIAL SECURITY
861 HIA(1395ff)
862 Black Lung(923)
863DIWC/DIWW (405 (g))
864 SSID Title XVI
865 RSI (405 (g))
FEDERAL TAX SUITS
870 Taxes (U.S. Plaintiff or
Defendant)
871 IRS-Third Party 26 USC
7609
Page 1 of 3
UNITED STATES DISTRICT COURT, CENTRAL
CIVIL COVER
VIII. VENUE: Youranswers to the questions below willdetermine the divisionof the Qourt
to change, in accordance with the Court's General Orders, upon review by the Court of you
DISTRICT OF CALIFORNIA
SHEET
to which this case will be initially assigned. This initial assignment is subject
Complaint or Notice of Removal.
QUESTION A: Was this case removed
from state court?
Yes \x\ No
If "no, "skip to Question B. If "yes," check the
box to the right that applies, enter the
corresponding division in response to
Question E, below, and continue from there.
STATE CASE WAS PENDING Ih THE COUNTY OF: INITIAL DIVISION IN CACD IS:
| | Los Angeles, Ventura, Santa Barbara, or ian LuisObispo Western
QUESTION B: Is the United States, or
one of its agencies or employees, a
PLAINTIFF in this action?
Yes \x\ No
If"no," skip to Question C. If"yes," answer
Question B.1, at right.
QUESTION C: Is the United States, or
one of its agencies or employees, a
DEFENDANT in this action?
Yes [x] No
If"no, "skip to Question D. If"yes," answer
Question C.I, at right.
| | Orange
| | Riverside or San Bernardino
B.1. Do 50% or more of the defendants who
the district reside in Orange Co.?
check one ofthe boxes tothe right J
reside in
B.2. Do 50% or more of the defendants who reside in
the district reside in Riverside and/or San Ber nardino
Counties? (Consider the two counties togetr er.)
check one of the boxes to the right .
C.I. Do 50% or more of the plaintiffs who refide in the
district reside in Orange Co.?
check oneofthe boxes tothe right ^^T
C.2. Do 50% or more of the plaintiffs who re ;ide in the
district reside in Riverside and/or San Bernardino
Counties? (Consider the two counties togeti er.
check oneoftheboxes totheright ^
Southern
Eastern
YES. Your case will initially be assigned to the Southern Division.
| | Enter "Southern" in response to Question E, below, and continue
from there.
| | NO. Continue to Question B.2.
YES. Your case will initially be assigned to the Eastern Division.
| | Enter "Eastern" in response to Question E,below, and continue
from there.
NO. Your case will initially be assigned to the Western Division.
| | Enter "Western" in response to Question E, below, and continue
from there.
YES. Your case will initially be assigned to the Southern Division.
| | Enter "Southern" in response to Question E, below, and continue
from there.
| | NO. Continue to Question C.2.
YES. Your case will initially be assigned to the Eastern Division.
| | Enter "Eastern" in response to Question E, below, and continue
from there.
NO. Your case will initially be assigned to the Western Division.
| | Enter "Western" in response to Question E,below, and continue
from there.
QUESTIOND: Location of plaintiffs and defendants?
Orange County
B.
Riverside or San
Bernardino County
C.
Los Angeles, Ventura,
Santa Barbara, or San
Luis Obispo County
Indicate the location(s) in which 50% or more of plaintiffs who residein this district
reside. (Check up to two boxes, or leave blank if none of these choices apply.)
Indicate the location(s) in which 50% or more of defendants who reside in this
district reside. (Checkup to two boxes, or leave blank if none of these choices
apply.)
D.I. Is there at least one answer in Column A?
Yes [x] No
If"yes,"your case will initially be assigned to the
SOUTHERN DIVISION.
Enter "Southern" in response to Question E, below, and continue from there.
If "no," gotoquestion D2 tothe right. ^^^
QUESTION E: Initial Division?
Enter the initial division determined by Question A, B, C, or Dabove:
QUESTION F: Northern Counties?

s
D.2. Is there at least one answer in Column B?
Yes [x] No
If"yes," your case will initially be assigned to the
EASTERN DIVISION.
Enter "Eastern" in response to Question E, below.
If"no," your case will be assigned to the WESTERN DIVISION.
Enter "Western" in response to Question E, below.
INITIAL DIVISION IN CACD
WESTERN
I
Do 50% or more of plaintiffs or defendants in this district reside in Ventura, Santa Barbara, orSan Luis Obispo counties? Q Yes [x] No
CV-71 (06/14) CIVIL COVER 5 HEET Page 2 of 3
K
UNITED STATES DISTRICT COURT, CENTRAL DISTRICT OF CALIFORNIA
CIVIL COVER SHEET
IX(a). IDENTICAL CASES: Has this action been previously filed in this court?
Ifyes, list case number(s):
[x] NO Q YES
IX(b). RELATED CASES: Is this case related (as defined below) to any cases |
Ifyes, list case number(s):
pr< viously filed in this court?
[X] NO YES
Civil cases are related when they:
A. Arise from thesame orclosely related transactions, happening
B. Call for determination ofthesame orsubstantially related or
C. For other reasons would entail substantial duplication oflabor
Check all boxes that apply. That cases may involve the same patent,
related.
or event;
lar questions of law and fact; or
if heard by different judges.
rademark, or copyright is not, in itself, sufficient to deem cases
sim
X. SIGNATURE OF ATTORNEY
(OR SELF-REPRESENTED LITIGANT):
Notice to Counsel/Parties: The submission ofthis Civil Cover Sheet is required
neither replaces nor supplements the filing andservice of pleadings orother
more detailed instructions, see separate instructionsheet (CV-071 A).
DATE: OCTOBER 9, 2014
b / Local Rule 3-1. ThisFormCV-71 and the informationcontained herein
papers as required by law, except as provided by local rules of court. For
Key to Statistical codes relatingto Social SecurityCases:
Nature of Suit Code Abbreviation
Substantive Statement of Cauie of Action
All claims for health insurance benefits (Melicare)
includeclaimsby hospitals,skilled nursing
(42 U.S.C. 1935 FF(b
861 HIA
862 BL
863 DIWC
863 DIWW
864 SSID
865 RSI
CV-71 (06/14)
All claims for "BlackLung" benefits under Ti
923)
All claims filed by insured workers for disab(i
all claims filed for child's insurance benefits
All claims filed for widows or widowers insu
amended. (42 U.S.C. 405 (g))
All claims for supplemental security income
amended.
:are) under Title 18,PartA, of the Social Security Act, as amended. Also,
1acilities, etc., for certification asproviders ofservices under theprogram.
le4, PartB, ofthe Federal Coal Mine Health andSafety Act of 1969. (30 U.S.C.
ityinsurance benefits underTitle 2ofthe Social Security Act, asamended; plus
Dased on disability. (42 U.S.C. 405 (g))
ancebenefits basedondisability underTitle 2ofthe Social Security Act, as
payments based upondisability filed underTitle 16ofthe Social Security Act, as
All claims for retirement (old age) and sun
(42 U.S.C. 405 (g))
rvi\ ors benefitsunder Title 2 of the Social Security Act, as amended.
CIVIL COVER SHI ET
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