Gordon v. Drape Creative - Honey Badger Don't Give A Shit PDF

Case 2:15-cv-04905-JFW-PLA Document 32 Filed 12/22/15 Page 1 of 114 Page ID #:261
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Daniel L. Reback (SBN 239884)

Email: dreback@kranesmith.com
Jeremy Smith LSBN 242430)
Email: jsmithkranesmith.com
Benjamin J. Smith (SBN 266712)
Email: bsmithbanesmith.com
KRANE & ST1ITH, APC
16255 Ventura Boulevard, Suite 600
Encino, CA 91436
Tel: (818) 382-4000
Fax: (818) 382-4001
7 Attorneys for Plaintiffi

CHRISTOPHER GORDON
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9
UNITED STATES DISTRICT COURT
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CENTRAL DESTRICT OF CALIFORNIA
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12 CHRISTOPHER GORDON, an
individual,
Case No. CV 15-04905 JFW (PLAx)
I,
Hon. John F. Walter, presiding
ii
Plaintiff,
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FIRST AMENDED COMPLAINT

FOR:
vs.
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DRAPE CREATE VE, INC., a Missouri

16 corRoration; PAPYRUS-RECYCLED
GREETINGS, INC., an Illinois
17 corporation; and DOES 1 to 10,
inclusive,
18
Defendants.
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1. TRADEMARK
INFRINGEMENT [15 U.S.C.
1114 et seq.
2. TRADEMA K
INFRINGEMENT [California law];
3. FEDERAL UNFAIR
COMPETITION AND FALSE
DESIGNATION OF ORIGIN [15
U.S.C. l 125(a)]; and
4. UNFAIR COMPETITION
[California law]
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21
DEMAND FOR JURY TRIAL
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1
Plaintiff CHRISTOPHER GORDON (Plaintiff) alleges as follows:

INTRODUCTION
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Plaintiff is a comedic narrator who, on January 18, 2011, published a video on

YouTube that consisted of his original narration humorously describing the traits of a
5
6
honey badger. The video went viral and has generated more than 76 million views
7 on YouTube. In the video, Plaintiffs original expressions and jokes include the
8
phrases Honey Badger Dont Care, and Honey Badger Dont Give a Shit, among
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others. Plaintiffs original expressions have gained a tremendous amount of notoriety,
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and his expressions have been referred to in commercials, television shows,
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magazines, and throughout the internet, and by numerous celebnties. Plaintiff
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copyrighted his narration and trademarked HONEY BADGER DONT CARE under
15 four separate registration numbers for various classes ofgoods, including, inter a/ia, t
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shins, audio books, computer application software and plush toys. Plaintiff has also
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18 produced, advertised, and sold merchandise, including greeting cards, bearing his
19 expressions and trademarks of Honey Badger Dont Care and Honey Badger Dont
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Give a Shit since soon after the video was published, and he continues to sell and
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22 license greeting cards bearing his expressions and marks today.
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Upon information and belief, Defendant Drape Creative, Inc. and Defendant
Papyrus-Recycled Greetings, Inc. collaborated to manufacture, distribute, sell and
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26 advertise several different greeting cards that copied Plaintiffs expression and
27 trademark, Honey Badger Dont Give a Shit. Defendants unauthorized sales of
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-7FIRST AMENDED COMPLAINT
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greeting cards bearing Plaintiffs trademark and expressions, coupled with their
intentional deceptive business practices to create customer conftision, which actually
3
happened here, constitute, inter a/ia, willftil trademark infringement and unfair
5 competition.
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JURISDICTION AND VENUE
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1.
This is a civil action arising under the Trademark Laws of the United
9 States, 15 U.S.C.
10
1051, et seq.
This Court has subject matter jurisdiction pursuant
to 28 U.S.C. l331 and 1338.
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12
2.
This Court has supplemental jurisdiction over the claims in this
13 Complaint that arise under California law pursuant to 28 U.S.C. 1367(a) because the
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state law claims are so related to the federal claims that they font part of the same
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16 case or controversy and derive from a common nucleus of operative facts.
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3.
Venue is proper in this Court pursuant to 28 U.S.C. 139l(b) and
1400(a). At all times relevant hereto, Plaintiff has been a resident of Los Angeles,
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20 California. The infringing products which are the subject of this litigation have been
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distributed and offered for distribution in the Central District of California, and the
Defendants transact business in the Central District of California. Defendants have
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24 extensive contacts with, and conduct business within, this District; have placed
25 products into the stream of commerce in this District; and have caused tortious injury
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to Plaintiff in this District.
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-3FIRST AMENDED COMPLMNT
PARTIES
4.
Plaintiff is an individual residing in Los Angeles, California.
5.
Plaintiff is informed and believes, and thereon alleges, that Defendant
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4
5 Drape Creative, Inc. (DCI) is a Missouri corporation that is subject to the

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jurisdiction of this Court.
DCI, which does business as Tomato Cards, designs
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greeting cards and conducts its business on the internet at dcistudios.com.
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6.
Plaintiff is informed and believes, and thereon alleges, that Defendant
Papyrus-Recycled Greetings, Inc. (Recycled Greetings) is an Illinois corporation
II
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that is subject to thejurisdiction of this Court. Recycled Greetings produces and sells
13 greeting cards and conducts its business on the internet at prureetins.com.

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According to its website, DCI is [k]nown for their clever humor and
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16 depth of design and more than 20,000,000 of their cards are sold annually, making
17 DCI the largest contributor to Defendant Recycled Greetings. Plaintiff is informed
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and believes, and thereon alleges, that Defendant DCI and Defendant Recycled
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20 Greetings (collectively, Defendants) authorized, directed, participated in,
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contributed to, ratified, and/or accepted the benefits of the wrongful acts as alleged
herein.
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8.
The true names and capacities, whether individual, corporate, associate or
25 otherwise of defendants DOES 1 through 10, inclusive, are unknown to Plaintiff who
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therefore sues said defendants by such fictitious names. Plaintiff is infonTled and
28 believes and based thereon alleges that each of the fictitiously named defendants is
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responsible in some manner for the events, acts, occurrences and liabilities alleged and
referred to herein. Some of the DOE defendants include the retailers who sold the
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infringing greeting cards, however, Plaintiff currently does not know their identities.
5 Plaintiff will seek leave to amend this Complaint to allege the true names and
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capacities of these DOE defendants when the same are ascertained.
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SUBSTANTIVE ALLEGATIONS
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Plaintiff and His Video, Copyright a id Traden, ark
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Plaintiff is a comedian, narrator, writer, and actor, and is commonly
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known by his alias, Randall.

10.
On January 18, 2011, Plaintiff published a video (the Video) on
YouTube that consisted of his original narration humorously describing the traits of a
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16 honey badger) The Video, titled The Crazy Nastyass Honey Badger (original
17 narration by RandalQ, became an instant hit. The Video went viral and is one of
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the most popular videos ever uploaded onto YouTube. To date, the Video has
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20 generated more than 76 million views on YouTube. The Video and subsequent
21 phenomenon have been covered by internet blogs such as the H1(ffihzgton Post (which
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proclaimed Honey Badger Dont Care [as] the best nature video of all time) as well
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24 as by entertainment and news outlets from Forbes to the New York Observer to TMZ.
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11.
In the Video, among Plaintiffs original expressions and jokes are that
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The Video is available at https://www.youtube.corn/watch?v=4r7wHMg5Yig
the HONEY BADGER DONT CARE and the HONEY BADGER DONT GIVE
2
A SHIT. Specifically regarding the phrase Honey Badger Dont Give a Shit
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(HBDGS), Plaintiff recites that expression verbatim or similarly four (4) different
5 times in the Video.

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(Video at 0:24; 0:35; 1:18; and 1:30.)
Plaintiffs original
expressions (and others contained in the Video) have gained a tremendous amount of
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notoriety, and his expressions have been referred to in commercials, television shows,
9 magazines, and throughout the internet.

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12.
Plaintiff is the owner of trademark registrations for HONEY BADGER
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DONT CARE (the Mark). Plaintiff registered the Mark with the United States
13 Patent and Trademark Office (USPTO) for various classes of goods under the
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following Registration Numbers: 4,505,781; 4,419,079; 4,419,081; and 4,281,472.
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16 Attached hereto as Exhibit A are true and correct copies of the Trademark
17 Registrations.
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13.
Initially, the USPTO rejected Plaintiffs trademark application on the
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20 grounds that Plaintiffs usage of the Mark was ornamental and did not function as a
21 trademark to identify Plaintiff as the source of his goods. Plaintiff responded to the
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USPTO, detailing why the Mark was an indicator ofsource. In his Response to Office
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Action sent to the USPTO, Plaintiff included screenshots of his Video and website,
25 provided specimens showing the various goods he sold using the Mark, and cited law
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in support of his argument that the Mark was not merely ornamental but served as a
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28 source identifier. Attached hereto as Exhibit B is a true and correct copy ofPlaintiffls
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Response to Office Action sent to the USPTO. The USPTO considered the evidence,
reversed its initial decision, and issued Plaintiff the trademark registrations.
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14.
After the Video was published, Plaintiff produced and sold goods,
5 including, inter a/ia, t-shirts, sweatshirts, bumper stickers, hats, mugs and plush dolls
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that displayed his Mark and expressions. Plaintiff has also selectively licensed his
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intellectual property rights to third parties in order to monetize the profitability of his
9 Marks.
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15.
In about February 2011, since soon after the Video was made, Plaintiff
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began using the HBDGS mark as a trademark on goods. Plaintiffused, and uses, the
13 HBDGS mark as a source identifier on numerous products, including: mens t-shirts;

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womens t-shirts; womens tank tops; baby bodysuits; infant t-shirts; hats; coffee
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16 mugs; keychains; magnets; stickers; mugs; plates; aprons; buttons; mouse pads; and
17 posters. Attached hereto as Exhibit C are true and correct copies of advertisements
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for some of Plaintiffs authorized goods bearing his HBDGS mark.
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16.
Specifically, Plaintiff also produced and sold greeting cards and
21 postcards that displayed both his trademarks and expressions of Honey Badger Dont
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Care and HBDGS. For example, attached hereto as Exhibit D is a true and correct
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24 copy of an advertisement for one of Plaintiffs authorized postcards bearing his
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HBDGS mark. In addition, attached hereto as Exhibit E are true and correct copies of
some of Plaintiffs authorized greeting cards bearing his Mark. Some of Plaintiffs
28 authorized greeting cards state, Honey Badger Dont Care!!! About Christmas and
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Honey badger dont care about St. Patricks Day. (Ex. E.) As alleged herein,
Defendants unauthorized greeting cards are confusingly similar to Plaintiffs
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authorized greeting cards. Plaintiff continues to sell such greeting cards and postcards
5 today.
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17.
Plaintiff primarily advertises his goods bearing his Marks, including
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greeting cards, on the internet. Sales of Plaintiffs merchandise bearing his Marks
9 have been substantial, with a majority of the sales occurring via the internet.
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18.
Plaintiffs trademark is inherently distinctive and/or has acquired
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secondary meaning as to the source of all products advertised, marketed, sold, or used
13 in connection with his trademark and derivations thereof

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The Mark and its
derivations are instantly recognizable as being associated with Plaintiff (i.e. Randall).
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16 The Mark and/or its derivations have appeared in Plaintiffs Video, and have since
17 been displayed on numerous advertisements and goods that Plaintiff promotes.
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Plaintiff even authored a book titled Honey Badger Don t Care: Randall Guide to
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20 Crazy Nastyass Animals, and launched a mobile app titled The Honey Badger Dont
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Care.
19.
Plaintiff has expended a significant amount oftime and effort in making
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24 his Marks well-known to the public. Plaintiff has promoted his Marks by, inter aIm,
25 advertising it in connection with his products, making guest appearances in media
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outlets, and publicizing the Marks through social media platforms.

20.
As a result of the foregoing, including, but not limited to, the extensive
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advertisements, promotions, sales, and enormous popularity of the Marks, the public
has come to exclusively identify the Mark and its derivations with Plaintiff. Among
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other things, Plaintiff, his expressions, and/or his Mark have appeared or been alluded
5 to in a Wonderful Pistachios commercial duringDancing with the Stars, in an episode
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of the popular television show America s Got Talent, in an episode of the hit
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television series Glee by the shows famous cheerleading coach Sue Sylvester (Jane
9 Lynch), in a Vogue profile of celebrity recording artist Taylor Swift, and on the
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Howard Stern radio show (Baba Booey). Plaintiffs expressions and Mark are famous
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distinctive under applicable law, including within the meaning of 15 U.S.C.
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1125(c)(1)and 1127.
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Defendants Unlawful Activities and Willful Infringem cut
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21.
Defendants are competitors of Plaintiff as they also produce and sell
17 greeting cards.
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22.
Defendants created, produced, distributed and sold greeting cards that
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20 bore: Plaintiffs expressions that were copied verbatim from Plaintiffs Video;
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derivations of Plaintiffs Mark; and phrases confusingly similar to Plaintiffs Mark.
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For instance, Defendants sold multiple variations of greeting cards that stated, Honey
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24 Badger dont give a shit, a clear reference to, and improper use and trading off of
25 Plaintiffs Mark. Defendants greeting cards are confusingly similar to Plaintiffs
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authorized cards. For instance, some of Defendants greeting cards state, Halloween
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28 is Here. Honey Badger dont give a shit. and Its Your Birthday! Honey Badger
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Dont Give A Sh*T. Attached hereto as Exhibit F are true and correct copies of
some of Defendants infringing greeting cards. Defendants produced and sold these
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greeting cards throughout the United States, including California. Defendants began
5 selling the infringing greeting cards after Plaintiff used the Honey Badger Dont Care
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and HBDGS marks in commerce.
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23.
Defendants unlawful use of Plaintiffs trademark and their unfair
9 competition enabled them to reap financial success, as Defendants produced and sold
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greeting cards in various formats, all with derivations of Plaintiffs trademark.
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Defendants sales of the infringing cards were substantial, as the cards were sold in
13 numerous retail stores throughout the country.

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24.
In producing and selling the infringing cards, Defendants intended to
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capitalize on Plaintiffs Mark, trample upon his intellectual property rights, and cause
17 customer confusion in the process. Actual customer confusion occurred, as Plaintiff

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(i.e., Randall) received inquiries from his admirers who asked Plaintiff whether the
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20 greeting cards were his own and customers believed Defendants cards were affiliated
21 with Plaintiff
Consumers actually inferred a connection between Defendants
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greeting cards and Plaintiff Some examples include one of Plaintiffs admirers
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24 tweeting he saw a line of Defendants greeting cards and stating Defendants were
25 riding off your name, and another admirer who sent Plaintiff photocopies of
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Defendants cards and said, I hope youre getting royalties from this stuff Another
28 consumer bought Defendants cards, tweeted to Plaintiff a photo ofDefendants cards

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and stated, @Randallsanimals look what we found in beliefthe consumer purchased

one of Plaintiffs authorized greeting cards. Attached hereto as Exhibit G is a true
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and correct copy of one of the tweets received by Plaintiff concerning Defendants
5 cards. The cards were not authorized by Plaintift though they misleadingly appeared
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tobe.
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25.
Defendants intentional and deceitful acts of unfair competition and use
9 of the Marks have caused confusion, and are likely to do so in the future, and have
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caused mistake and deception as to the affiliation or association of the Defendants
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with Plaintiff, and asto the origin, sponsorship, or approval of the Defendants goods
13 by Plaintiff Plaintiffhas neither authorized nor consented to the use by Defendants of

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the Mark, any colorable imitation of it, or any mark confusingly similar to it.
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26.
Plaintiff is informed and believes, and thereon alleges, the Defendants
17 purpose in utilizing the Marks is an attempt to benefit unfairly from the valuable
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goodwill and extreme popularity of the Marks, which was established at great expense
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20 and effort by Plaintiff Defendants use of Plaintiffs HBDGS mark was a clear
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attempt to steer customers its way and confuse them as to the source of the goods, for
commercial gain. Defendants unlawfully capitalized off Plaintiffs goodwill and
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24 intellectual property rights.
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27.
On information and belief, notwithstanding Plaintiffs written demand
that Defendant cease and desist from selling the infringing cards, Defendant continued
28 to sell the infringing cards in intentional disregard of Plaintiffs rights.

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FIRST CLAIM
(Trademark Infringement under 15 U.S.C. 1114 etseq. Against All
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Defendants)
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28.
Plaintiff repeats, repleads and realleges the allegations contained in
Paragraphs 1 through 27, as though fully set forth herein.
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29.
The aforesaid acts of Defendants constitute infringement of the Mark
9 underl5U.S.C.*lll4etsecj.
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30.
As a direct and proximate result of Defendants wrongful acts, Plaintiff
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suffered and continues to suffer and/or is likely to suffer damage to his trademark,
12 has
13 reputation, and goodwill. Defendants will continue to use the Mark and will cause
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irreparable damage to Plaintiff. Plaintiff has no adequate remedy at law and is entitled
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16 to an injunction restraining Defendants and their officers, agents, employees, and all
17 persons acting in concert with them, from engaging in further acts of infringement.
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31.
Plaintiff is further entitled to recover from Defendants the actual damages
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20 that he sustained and/or is likely to sustain as a result of Defendants wrongful acts.
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Plaintiff is presently unable to ascertain the full extent of the monetary damages that
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he has sustained and/or is likely to sustain by reason of Defendants acts of trademark

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24 infringement.
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32.
Plaintiff is further entitled to recover from Defendants the gains, profits,
and advantages that Defendants have obtained as a result of their wrongful acts.
28 Plaintiff is presentlyunable to ascertain the extent ofthe gains, profits, and advantages
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that Defendants have realized by reason of their acts of trademark infringement.

33.
Because ofthe willifil nature ofthe wrongifil acts of Defendants, Plaintiff
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is entitled to all remedies available under 15 U.S.C. 1 117 and 1118, including but
5 not limited to an award of treble damages and increased profits pursuant to 15 U.S.C.
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1117.
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34.
Plaintiff also is entitled to recover his attorneys fees and costs of suit
9 pursuantto 15U.S.C.1117.
SECOND CLAIM
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(Trademark Infringement under California Common Law Against All
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Defendants)
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35.
Plaintiff repeats, repleads and realleges paragraphs 1 through 34,
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16 inclusive, of this Complaint and incorporates the same herein by the reference as
17 though set forth in hill.
36.
Defendants use of the Marks without Plaintiffs consent constitutes
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20 trademark infringement and unfair competition in violation of California common law
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in that, among other things, such use is likely to cause confusion, deception, and
mistake among the consuming public as to the source, approval or sponsorship of the
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24 goods offered by Defendants.
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37.
Defendants acts were designed to trade upon Plaintiffs reputation and
goodwill by causing confusion and mistake among consumers and the public.
28 Plaintiff is entitled to preliminary and permanent injunctions restraining and enjoining

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Defendants and their officers, agents, affiliates, vendors, partners and employees, and
all persons acting in concert with Defendants, from using in commerce Plaintiffs
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federally registered Mark and its derivations and his common law rights in same.
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38.
As a direct and proximate result of Defendants willful and intentional
actions, Plaintiff has suffered damages in an amount to be determined at trial.
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Because of the willful nature of Defendants wrongful acts, Plaintiff is entitled to an
9 award of punitive damages.

THIRD CLAIM
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(Federal Unfair Competition and False Designation of Origin in Violation of
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15 U.S.C. 1125(a) Against All Defendants)

39.
Plaintiff repeats, repleads and realleges the allegations contained in
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16 Paragraphs I through 38, as though fully set forth herein.
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40.
Defendants acts as alleged above constitute unfair competition and a
false designation of origin which have caused confusion, mistake, deception as to the
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20 affiliation, connection or association ofDefendants with Plaintiff and as to the origin,
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sponsorship, or approval of Defendants goods, services and/or activities by Plaintiff

and are likely to do so in the future, in violation of the Lanham Act, 15 U.s.c.
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24 1125(a).
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41.
As a direct and proximate result of Defendants wrongful acts, Plaintiff
has suffered and continues to suffer and is likely to suffer damage to his reputation,
28 goodwill, and to the Marks. Defendants will continuethe activities alleged herein and
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will cause irreparable damage to Plaintiff. Plaintiff has no adequate remedy at law
and is entitled to an injunction restraining Defendants, their officers, agents, affiliates,
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vendors, partners and employees, and all persons acting in concert with Defendants,
5 from engaging in thrther acts of unfair competition, deceitftil acts using the Marks,
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and false designation of origin and false affiliation and association.
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42.
Plaintiff is thither entitled to recover from Defendants the actual damages
9 that he sustained and/or is likely to sustain as a result of Defendants wrongthl and

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devious acts. Plaintiff is presently unable to ascertain the MI extent of the monetary
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damages that he has suffered and/or is likely to sustain by reason of Defendants acts
13 of unfair competition and false designation of origin and false affiliation and
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association.
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43.
Plaintiff is further entitled to recover from Defendants the gains, profits,
17 and advantages they have obtained as a result of their wrongftil and malicious acts.
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Plaintiff is presently unable to ascertain the extent of the gains, profits, and advantages
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20 that Defendants have realized by reason of their acts of unfair competition and false
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designation of origin and false affiliation and association.
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44.
Because ofthe willthl nature of the wrongthl acts of Defendants, Plaintiff
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24 is entitled to an award of treble damages and increased profits pursuant to 15 U.s.c.
25 1117.
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45.
Plaintiff is also entitled to recover his attorneys fees and costs of suit
28 pursuantto 15U.S.c.l117.
FOURTH CLAIM
(Unfair Competition Against All Defendants)
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46.
Plaintiff repeats, repleads and realleges paragraphs I through 45,
5 inclusive, of this Complaint and incorporates the same herein by the reference as
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though set forth in full.
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47.
Defendants actions constitute unfair competition under the statutory law
9 ofCalifomia, including California Business and Professions Code section 17200, c/

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seq., and under the common law of the State of California.
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48.
The acts and conduct of Defendants complained of herein have caused
13 Plaintiff irreparable injury, and will, unless retrained, further impair the value of his
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Marks, intellectual property rights, reputation, and goodwill. Plaintiffhas no adequate
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16 remedy at law.
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49.
Plaintiff is informed and believes that Defendants have unlawfully
obtained profits through their acts of unfair competition. Defendants should be forced
20 to disgorge such unlawful profits to Plaintiff

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50.
Plaintiff is further entitled to recover from Defendants his actual damages
sustained as a result of Defendants wrongful acts. Plaintiff is presently unable to
24 ascertain the full extent of the monetary damages he has suffered by reason of
25 Defendants acts of unfair competition.
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51.
Because ofthe willful nature of Defendants wrongful acts, Plaintiff is
28 entitled to an award of punitive damages.

PRAYER FOR RELIEF

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WHEREFORE, Plaintiff prays for judgment against Defendants and each of
3
them as follows:
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1.
That Defendants have (i) infringed the Mark under 15 U.S.C. 1114 et
seq.; (ii) infringed the Marks under California law; and (iii) engaged in unfair
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8
competition, and violated California Business and Professions Code section 17200 et
9 seq.
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2.
That each of the above acts were willthl.
3.
That Plaintiff be awarded (i) all profits of Defendants, (ii) all of his
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13 damages, (iii) statutory damages available under the law including 15 U.S.C. 1117, if
14
elected, (iv) treble damages, (v) punitive damages, (vi) disgorgement and restitution of
15
1 6 all benefits received by Defendants arising from their infringement as provided by
17 law, and/or (vii) enhanced damages for Defendants willifil infringement as provided
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in 15 U.S.C. 1117, the sum of which will be proven at the time of trial.
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4.
That Defendants, their officers, agents, servants, affiliates, partners,
vendors, employees and attorneys, and those persons in active concert or participation
with them, be preliminarily and permanently enjoined from:
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26
a.
Using Plaintiffs expression and mark HONEY BADGER

DONT CARE or any colorable imitation thereof, or any other
expression or mark likely to cause conffision, mistake, or
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26
deception, in connection with the sale, offering for sale,

distribution, manufacturing, advertising, or promotion of their

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goods or services;
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b.
Using any false designation of origin or false description that

can, or is likely to, lead the public to believe that any product
manufactured, distributed, sold, offered for sale, or advertised by
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Defendant are in any manner associated or connected with
Plaintiff is sold, manufactured, licensed, sponsored, or approved
10
or authorized by Plaintiffi and
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c.
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Engaging in any other activity constituting an infringement of

Plaintiffs trademark rights or otherwise unfairly competing with
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Plaintiff
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5.
That Defendants be directed to deliver up to Plaintiffall products bearing
17 the Mark, any copy, simulation, variation or colorable imitations ofthe Mark, and any
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documents or tangiblethings that discuss, describe, mention or relate to such products.
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6.
That Defendants file with the Court and serve upon Plaintiffs counsel
within thirty (30) days after entry ofjudgment a report in writing under oath setting
forth in detail the manner and form in which Defendants have complied with the
24 requirements of the injunction.

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7.
That Defendants be required to pay to Plaintiff all of his costs,
disbursements, and attorneys fees in this action.

8.
For prejudgment interest.

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9.
For such other relief as the Court deems proper.
DATED: December 22, 201 5
Respectfully submitted,
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KRANE & SMITH, APC
By:________
DANIEL L. REBACK
Attorneys for Plaintiff, Christopher
Gordon
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DEMAND FOR JURY TRIAL

Plaintiff CHRISTOPHER GORDON hereby demands ajuty trial in this
3
action.
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DATED: December 22, 2015
Respectfully submitted,
KRANE & SMITH, APC
By:D
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ii
12
DANIEL L. REBACK
Attorneys for Plaintiff, Christopher
Gordon
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EXHIBIT A
r14lttb
,tate of
tiiitrb &tatS 3atent anb trabeiiiarft @Ifict
HONEY BADGER DONT CARE
Reg. No. 4,505,781

Registered Apr. 1,2014
IntCL: 25
TRADEMARK
PRINCIPAL REGIStER
CIIRISTOPIIER 1 GORDON (UNiTED STATES INDIVIDUAL)
CO SANA ITAKIMOr K&I flAWS

P0, (lOX 1115
ChICAGO, IL 606901135
FOR CLOTHING, NAKIEflT.SIIIRTS,TANK TOPS. ONE rIECE GARMENT[OR INFAN1S
ANI) 101)1)11 KS, I I)NG-SI II VI SIIIKIS,CAPS, IN ClASS 23 (hIS Cl S flANl) 19)
rIRST USE 2-23-1011 IN COMMERCE 2-23.2011
lilt MAR). CONSISIS 01 SIANDAIW CIEAHACI LRS WIIIIOUI CLAIM 10 ANY PAR
ECU1AR row STYLE. SIZE. OR COLOR
SN 85347r,67, HI Ui) 10-14-2011
SCOW 91013, EXAMINING ATtORNEY
%-cS.z& ,t
Dlrnt*r *111w Unlid Slum
Psi,ni ,nd Tnd,mark Offln
Pcp.*Iy
EXHIBIT A
,tatt ,f ZtWezy
.tiiiftb stateS 3Patent aub lErabentark Office
hONEY BADGER DONT CARE
Reg. No. 4,281,472

Registered Jan. 29, 2013
InICI.: 21
CIIRiSTOPFIER 2 GORDON (UNITED STATES INDIVIDUAL)

COSANA IIAKIM or K&i.GATrS
PD BOX IllS
CHICAGO, IL 600JGI 135
FOR MUGS, IN CLASS 21 (U S CLS 2.13.23.29,30.33. 1OAND SD)
TRADEMARK
FIRSI USE 10.1-2011.1W COSthIERUL 10-7-2011
PRINCIPAL REGISTER
Jill MARK CONSIS] S (H S IANI)Aki) CIIARACI I Its

IICLLAR I 0{I. S IVLL, SILL OR COLOR
SEP. NO gS-449,921HLED 10-18-2011
SCOl I 1111111. I XAM1NINGAI ORNI Y
hI S(jn
mM ..3 T,.j.ir.sIL 4r.r
%4
III 10111 ClAIM II) ANY PAR
ttcb tatc of
Initeb tates 3jatent aub JLrabeuiark Dffirt
Reg. No. 4,419,081

Registered Oct. 15, 2013
InLCL: 28
TRADEMARK
PRINCIPAL REGISTER
CHRISTOPHER Z GORDON (UNtTED STATES INDIVIDUAL)

CO SANA IIAKIM or KM GAITS
IO IIOX I 115
CHICAGO. IL 6069011)5
FOR (BASED ONUSE) CIIfflSThIAS ThEE ORNAMENT5AND DECORATIONS. TALKING
1)011 SANP P1 IISII 1(315. IN ClASS 28(1 S (IS 22. 21. 3(AND SI))
FIRST USE I0.2-2D1I.IN COMMERCE 103-2011
IIIL MARK C0tSI5IS UI SIANDAHI) CIIAHACILRS WI 1110W CLAIM 10 ANY PAR
11CULAR roNT. STYLE, SIZE. OR COLOR
SN 85119923. HI FO ID- 18-2011
SCOIT BIBfl. EXAMINING AUORNEY
Vfl fl Iia
12 r.a . ..lna,
tatc of
Inittb tak% 9atent anti !Erabcniark @ffice
Reg. No.4,419,079
Registered Oct. 15, 2013
Tnt CI.: 9
CIIRJSTOPIIER Z GORDON (UNITED STATUS INDIVIDUAL)

CO SANA TIAKiNI or K&I GAITS
PC) IIOX 1115
CHICAGO. IL 60690! 135
TRADEMARK
FOR AUDIO BOOKS IN ThE FIELD OF COMEDY PARODY AND SA11RE, COMPUTER
AiPI CAl ION 51*1 WAHI I OR P.11)1111 I IIIONI S IORIAIII.I MI DR PIAVI KS,
IIANDIIELD CO?.1IUIERS, NAMELY 501 IWARh [OR PlAYING GAMES. IN CLASS 9
(US. CLS 21. 23, 26. JGAND3S)
PRINCIPAL REGISTER
I IRSI USL 12.0.2011. IN COMMLRCL 12-0.201 I

flIE MARK CONSISTS OF STANDARD CIIARAaERS WIflIOU ClAIM TO ANY PAR
TWIll AR FONT. SWI F. S17F. OR CIN OR
SN 85147668. FILED 10-14-201 I
scott BITiTI, EXAMINING AttORNEY
&Ad
EXHIBIT B
FTC Form
93/i
9 20ri5i
.osr rEo
07Th
Response to Office Action
The table below presents the data as entered.

Input Field
SERIAL
NUMBER
Entered
85447667
LAW OFFICE 109
MARK SECTION
http://tess2.uspto.gov/ImageAgent/lmageAgentProxy?getlmage=85447667
MARK
ELEMENT
STANDARI)
ChARACTERS
YES
USPTO
GENERATED
IMAGE
YES
MARK
STATEMENT
The mark consists of standard characters, without claim to any particular font style, size
or color.
ARGUMENT(S)
IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
Applicant:
Christopher Z. Gordon
Mark:
Serial No.
85/447,667
Examining
Attorney:
Scott K. Bibb
Law Office 109
Commissioner for Trademarks

P.O. Box 1451
Alexandria, VA 22313- L451
RESPONSE TO OFFICE ACTION OF FEBRUARY 9.2012

The applicant, Christopher Z. Gordon (Applicant), by its attorneys, responds to the Office Actioi
of February 9,2012 as follows:
EXHIBIT B
I.
INTRODUCTEON
Applicant filed to register the mark HONEY BADGER DONT CARE for the following goods, a
amended herein, clothing, namely, c-shirts, tank tops, one piece garment for infants and toddlers (based oi
use); long-sleeve shirts, caps: and pajamas (based on intent to use) in Class 25. In an Office Action datei
February 9,2012, the Examining Attorney refused registration of Applicants mark pursuant to IS U.S.C
105 1-52, 1127 on the grounds that the mark as used on the specimen submitted for the clothing, namely
t-shirts, tank tops, one piece garment for infants and toddlers is merely a decorative or ornamental featur
of the goods.
Applicant respectfully disagrees with the Examining Attorneys conclusion that its HONE
BADGER DONT CARE mark is a merely ornamental feature of Applicants goods. Instead, Applican
submits that the mark is an indicator of source for the identified goods.
THE MARK HONEY BADGER DONT CARE

IS A SOURCE IDENTIFIER
If an applicant establishes that the proposed mark serves as an indicator of secondary source, th
matter is registrable on the Principal Register. TMEP 1202.03(c). In order to demonstrate thi
secondary-source function, the applicant may submit evidence that the proposed mark would bi
recognized as a mark through use with goods or services other than those identified in the application. Id.
Applicant submitted a screenshot from its online store showing use of the mark in connection wit]
clothing, namely, t-shirts, tank tops, one piece garment for infants and toddlers, as a specimen in support o
Applicants assertion of the 1(a) basis for its clothing, namely, t-shirts, tank tops, one piece garment fo
infants and toddlers. The Examining Attorney objected to the specimen on the grounds that the mark wa
merely an ornamental feature of the goods.. Applicant submits that its HONEY BADGER DONT CARl
mark is a source identifier of Applicants clothing. Indeed, Applicant uses the mark HONEY BADGEE
DONT CARE in connection with several other goods, as shown in the specimen and as discussed below.
Moreover, just because a mark is visually pleasing or serves in some way to ornament the good
does not render it unregistrable if the mark is also inherently distinctive
In re Tire Mart, Inc., Seria
No. 78292388 (not precedential) (citing In re Swift & Co., 106 U.S.P.Q. 286. 288 (CCPA 1955), Fo
example, in In re Paramount Pictures Corn,, the Board held that MORK & MINDY was registrable fo
decals because the applicant had a television series of that name and had previously registered MORK
MINDY for various goods and services. 213 U.S.P.Q. 1111, 1112 (TTAB 1982); TMEP 1202.03(c). Thi
Board found that while MORK & MINDY was pan of the ornamentation of the decal, the primar
significance of MORK & MINDY to a prospective purchaser of decals was to indicate source or origin i:
the proprietor of the television series and its principal characters. ffl.
Applicant submits that its HONEY BADGER DONT CARE mark is not mere ornamentation bul
similar to the terms MORK & MINDY in In re Paramount Pictures Corp.. the mark references a well
known media phenomenon created by Applicant and serves as a source identifier for Applicants goods
Applicant is the creator of the viral video The crazy Nastyass Honey Badger, a wildlife narration abou
the honey badger animal, which has received more than 48 million hits on YouTube.com (available a
httpi/www.youtube.com/watch?v=4r7wHMg5Yjg; screenshot attached as Exhibit A). One of the mos
ve1l-known lines from the video is Thoney badger dont care. See Exhibit B (screenshot of Applicants
website, page 2).
Most importantly, Applicant now uses HONEY BADGER DONT CARE as a trademark. As show
in the specimen submitted, the mark is used as a source identifier in connection with decals, mugs, dolls
and Christmas tree ornaments, among other items. See Exhibit C (screenshot of Applicants online store
Amazon.com screenshot showing doll for sale), Applicant also offers a wall calendar under the mark, am
sells a smart phone application under the HONEY BADGER DONT CARE mark. See Exhibit D
Additionally. Applicant is offering books under the HONEY BADGER DONT CARE mark. See Exhibi
E. Like the Mark & Mindy characters in In re Paramount Pictures Corp., the terms HONEY BADGEF
DONT CARE are frequently featured in AppLicants video and used as a trademark in connection wit!
other goods. Therefore, the primary significance of the mark to purchasers of Applicants clothing
namely, i-shins, tank tops, one piece garment for infants and toddlers, will be to indicate origin i:
Applicant, the proprieLor of the Internet video.
Because the mark serves as a source identifier, rather than mere ornamentation, Applican
respectfully submits that the mark should be approved for registration.
CONCLUSION
In view of the foregoing. Applicant respectfully submits that the subject application is therefore
appropriate for publication. Favorable action in this regard is respectfully requested.
EVEDENCE SECTION
EVIDENCE FILE NAME(S)
ORIGINAL
PDF FILE
cvi 691745820-142906257
YouTube.pdf
CONVERTED
PDF FILE(S)
(2 pages)
\\TICRS\EXPORT 1 6\IMAGEOUT16\854\476\85447667\xm11OA0OO2.JPG
tyass Honey Badger
original narration by Randall
\\TICRS\EXPORT 1 6\IMAGEOUT 16\854\476\85447667\xml 1\ROA0003.JPG

PDF FILE
CONVERTED
IDF FILE(S)
(12 pages)
evi 69 1745820-142906257
Exhibit B
Randall s Honey Badger
About.pdf
\\TICRS\EXPORT16\IIvIAGEOUTI 6\854\476\85447667\xml RRQA0004JPG

\\TICRS\EXPORTI6UMAGEOUT16\854\476\8544766Thcm1 1\ROA0005.JPG
\\TICRS\EXPORTI6\IIvIAGEQUT15\854\476\85447667\xml 1\ROA0006.JPG
\\TICRS\EXPORTI6\IMAGEOUTI6\854\476\85447667\xml 1\ROA0007.JPG
\\TICRS\EXPORT 1 6\IMAGEOUT 16\854\476\85447667\xml 1\ROA0008.JPG
\\TICRS\EXPORT 1 6JMAGEOUT I 6\854\476\85447667\xml 1\ROA0009.JPG
\\TICRS\EXPORT 1 6UMAGEOUT 16\854\476\85447667\xml 1\ROAOO I d.JPG
\\TICRS\EXPORT 1 6\IMAGEOUTI6\854\476\85447667\xml 1\ROAOOI 1 .JPG
\\TICRS\EXPORTI 6\IMAGEOUTI 6\854\476\85447667\xml 1\ROAOOI 2.JPG
\\TICRS\EXPORTI6\IMAGEOUTI 6\854\476\85447667\xml l\ROAOOI 3.JPG
\\TICRS\EXPORTI 6\IMAGEOUT I 6\854\476\85447667\xml 1\ROAOO 14.JPG

\\TICRS\EXPORTI6\IMAGEOUT I 6\854\476\85447667\xml
PDFFILE
evi 691745820-142906257
Exhibit C
Online store
flROAOOI5.WG
dolkpdf
CONVERTED
PI)F FILE(S)
\\TICRS\EXPORTI 6\IMAGEOUTI 6\854\476\85447667\xmll\.ROAOO16.JPG
(6 pages)
\\TICRS\EXPORT1 6UMAGEOUT16\854\476\85447667\xml 1\ROAOOI7JPG

\VFICRS\EXPORTI6\IIvIAGEOUT16\854\476\85447667\xml 1\ROAOOI 8.JPG
\\TICRS\EXPORTI6\EvIAGEQUTI6\854\476\85447667\xml RROAOO 19.JPG
\\T[CRS\EXPORTI 6WvIAGEOUTI6\854\476\85447667Vxm1 I\ROAOO2O.JPG
\\TICRS\EXPORTI 6\IMAGEOUTI 6\854\476\85447667\xml I\ROAOO2 I .JPG
evi 691745820-142906257
CONVERTED
PDF FILE(S)
(II pages)
Exhibit D
Calendar and Apps.ndf
\\TICRS\EXPORT 1 6\IMAQEOUTI 6\854\476\85447667\xml 1\R0A0022.JPG

\\TICRS\EXPORTI6\IMAGEOUT1 6\854\476\85447667\xml 1\R0A0023.JPG
\\TICRS\EXPORT16\IMAGEOUT 1 6\854\476\85447667\xml I\ROAOO24JPG
\\TICRS\EXPORTI6UMAGEOUT 16\854\476\85447667\xml I\R0A0025.JPG
\\TICRS\EXPORT16UMAGEOUT I 6\854\476\85447667\xml 1\ROAOO26.JPG
\\TICRS\EXPORTI6UMAGEOUT I 6\854\476\85447667\xml 1\ROAOO27.JPG
[\\TICRS\EXPORTI 6\IMAGEOUT 1 6\854\476\85447667\xml 1\R0A0028.JPG
\\TICRS\EXPORT1 6JMAGEOUT 1 6\854\476\85447667\xml 1\R0A0029.JPG
\\TICRS\EXPORT1 6\IMAGEOUT 1 6\854\476\8544766Axm1 1\ROAOO3O.JPG
\\TICRS\EXPORTI6\IMAGEOUTI 6\854\476\85447667\xml 1\ROAOO3I .JPG
\\TICRS\EXPORTI6WvIAGEOUTI 6\854\476\85447667\xmll\ROAOO32.JPO
ORIGINAL
PDF FILE
evi 691745820-142906257
Exhibit E
Honey Badger Don t Care Book.pdf
CON VERTE I)
PDF FILE(S)
(6 pages)
\\TICRS\EORT16\Th4AGEOUT 16\854\476\85447667\xml 1\R0A0033.JPG

\\TJCRS\EXPORT1 6\Th1AGEOUT I 6\854\476\85447667\xml flROAOO34.WG
\\TICRS\EXPORT1 6\Th4AGEOUT1 6\854\476\85447667\xml 1\R0A0035 .JPG
\\TICRS\EXPORT 1 6\IMAGEOUT 1 6\854\476\85447667\xml 1\R0A0036.JPG

\VIICRS\EXPORT 1 6\IMAGEOUT I 6\854\476\85447667\xml I \ROAOO37.JPG
\\TICRS\EXPORT I 6\IMAGEOUT I 6\854\476\85447667\xml l\ROAO03RJPG
Exhbit A screenshot of YouTube.com; Exhibit B screenshot of Applicants website;
Exhibit C screenshot of Applicants online store; Exhibit D screenshots of Applicant;
wall calendar and smart phone application; Exlubit E Amazoncom screenshot of
Applicants book has been attached
-
DLS(RIPTION
FILE
GOODS AND/OR SERVICES SECTION (current)

INTERNATIONAL
(lASS
015
I
DESCRIPTION
(Based on use) Clothing, namely. t-shins. tank tops, onesies; (Based on intent to use) Long-sleeve shins,
caps; and pajamas
FILING BASIS
Section 1(a)
FIRST USE
ANY WhERE
At least as early as 02/24/2011
I)ATE
FIRST USE IN
COMMERCE
DATE
FILING BASIS
Section 1(b)
GOODS ANI)/OR SERVICES SECTION (proposed)

INTERNATIONAL
(LASS
05
TRACKEI) TEXT DESCRIPTION
Ba
ca t:
Cknhin. nnmch. t shin1, tank tops, onc is; (Based on use) Clothinu. namely. tshins.
tank tops, one piece uarment for infants and toddlers; (Based on intent to use) Long-sleeve shins, caps; and
pajamas
FINAL I)ESCRIPTION
(Based on use) Clothing, namely, t-shirts, tank tops, one piece garment for infants and toddlers; (Based on
intent to use) Long-sleeve shirts, caps; and pajamas
FILIN(; BASIS
Section 1(a)
FIRST USE
ANYWHERE
DATE
FIRST USE IN
COMMERCE
DATE
FILING BASIS
Section 1(b)
SIGNATURE SECTION
RESPONSE
15(GNATURE
/ Si1 /
SIGNATORYS
NAME
Sana Hakim
SIGNATORYS
POSITION
Attorney of record, Illinois bar member
SIGNATORYS
PHONE NUMBER
3 L-807-4350
DATE SIGNED
0810912012
AUTHORIZED
SIGNATORY
YES
FILING INFORMATION SECTION

Aug09 15:43:12 EDT 2012
SUBMIT DATE
Thu
TEAS STAMP
USPTOIROA-XX.XXX.XX.XX-20
120809154312782247-854476
67-4909aed I dl 2ceeec3e2e4d
72db585ed-N/A-N/A-201 2080
9152955980940
?OFr fl3Fr:92;1:
cue,.
C6eIe,Exc V 111
Response to Office Action

To the Commissioner for Trademarks:
Application serial no. 8514767 HONEY BADGER DONT CARE(Standard Characters, see
http://tess2.uspto.gov/lmageAgenUlmageAgentProxy?getlmage=85447667) has been amended as follows:
ARGUMENT(S)
In response to the substantive refusal(s), please note the following:
IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
Applicant:
Christopher Z. Gordon
Mark:
Serial No.
85/447,667
Examining
Attorney:
Scott K. Bibb
109
Law Office
Commissioner for Trademarks

P.O. Box 1451
Alexandria, VA 22313-1451
RESPONSE TO OFFICE ACTION OF FEBRUARY 9,2012
The applicant, Christopher Z. Gordon (Applicant), by its attorneys, responds to the Office Action
of February 9,2012 as follows:
I.
INTRODUCTION
Applicant filed to register the mark HONEY BADGER DONT CARE for the following goods, as
amended herein, clothing, namely, t-shins, Lank tops, one piece garment for infants and toddlers (based
on use); long-sleeve shirts, caps; and pajamas (based on intent to use) in Class 25. In an Office Action
dated February 9, 2012, the Examining Attorney refused registration of Applicants mark pursuant to 15
U.S.C. 1051-52, 1127 on the grounds that the mark as used on the specimen submitted for the clothing,
namely, t-shirts, tank tops, one piece garment for infants and toddlers is merely a decorative or ornamental
feature of the goods.
Applicant respectfully disagrees with the Examining Attorneys conclusion that its HONEY
BADGER DONT CARE mark is a merely ornamental feature of Applicants goods. Instead, Applicant
submits that the mark is an indicator of source for the identified goods.
II.
THE MARK HONEY BADGER DONT CARE
IS A SOURCE IDENTIFIER
If an applicant establishes that the proposed mark serves as an indicator of secondary source.
matter is registrable on the Principal Register. TMEP 1202.03(c). In order to demonstrate
secondary-source function, the applicant may submit evidence that the proposed mark would
recognized as a mark through use with goods or services other than those identified in the application.
the
the
be
Id.
Applicant submitted a screenshot from its online store showing use of the mark in connection with
clothing, namely, t-shins. tank tops, one piece garment for infants and toddlers, as a specimen in support
of Applicants assertion of the 1(a) basis for its clothing, namely, t-shirts, tank tops, one piece garment for
infants and toddlers. The Examining Attorney objected to the specimen on the grounds that the mark was
merely an ornamental feature of the goods. Applicant submits that its HONEY BADGER DONT CARE
mark is a source identifier of Applicants clothing. Indeed, Applicant uses the mark HONEY BADGER
DONT CARE in connection with several other goods, as shown in the specimen and as discussed below.
Moreover, just because a mark is visually pleasing or serves in some way to ornament the
goods does not render it unregistrable if the mark is also inherently distinctive
In re Tire Mart, Inc.,
Serial No. 78292388 (not precedential) (citing In re Swift & Co., 106 U.S.P.Q. 286, 288 (CCPA 1955).
For example, in In re Paramount Pictures Corp., the Board held that MORK & MINDY was registrable
for decals because the applicant had a television series of that name and had previously registered MORK
& MINDY for various goods and services. 213 U.S.P.Q. 1111, 1112 (TTAB 1982); TMEP 1202.03(c).
The Board found that while MORK & MINDY was part of the ornamentation of the decal, the primary
significance of MORK & MINDY to a prospective purchaser of decals was to indicate source or origin in
the proprietor of the television series and its principal characters. Id.
Applicant submits that its HONEY BADGER DONT CARE mark is not mere ornamentation but,
similar to the terms MORK & MINDY in In re Paramount Pictures Corp., the mark references a wellknown media phenomenon created by Applicant and serves as a source identifier for Applicants goods.
Applicant is the creator of the viral video The Crazy Nastyass Honey Badger, a wildlife narration about
the honey badger animal, which has received more than 48 million hits on YouTube.com (available at
http:/fwww.youtube.com/watch?v=4r7wHMg5Yjg; screenshot attached as Exhibit A). One of the most
well-known lines from the video is honey badger dont care. See Exhibit B (screenshot of Applicants
website, page 2).
Most importantly, Applicant now uses HONEY BADGER DONT CARE as a trademark. As
shown in the specimen submitted, the mark is used as a source identifier in connection with decals, mugs,
dolls, and Christmas tree ornaments, among other items. See Exhibit C (screenshot of Applicants online
store; Amazon.com screenshot showing doll for sale). Applicant also offers a wall calendar under the
mark, and sells a smart phone application under the HONEY BADGER DONT CARE mark. See
Exhibit ft Additionally, Applicant is offering books under the HONEY BADGER DONT CARE mark.
See Exhibit E. Like the Mork & Mindy characters in In re Paramount Pictures Corn., the terms HONEY
BADGER DONT CARE are frequently featured in Applicants video and used as a trademark in
connection with other goods. Therefore, the primary significance of the mark to purchasers of Applicants
clothing, namely, t-shirts. tank tops, one piece garment for infants and toddlers, will be to indicate origin
in Applicant, the proprietor of the Internet video.
Because the mark serves as a source identifier, rather than mere ornamentation, Applicant
respectfully submits that the mark should be approved for registration.
III.
CONCLUSION
in view of the foregoing, Applicant respectfully submits that the subject application is therefore
appropriate for publication. Favorable action in this regard is respectfully requested.
EVIDENCE
Evidence in the nature of Exhbit A screenshot of YouTube.com; Exhibit B screenshot of Applicants
website: Exhibit C screenshot of Applicants online store; Exhibit D screenshots of Applicants wall
calendar and smart phone application; Exhibit E Amazon.com screenshot of Applicants book has been
attached has been attached.
Original PDF file:
cvi 69l745S20-l42906257
tvass Honey Badger original narration by Randall
YouTube.pdf
Converted PDF file(s) ( 2 pages)
Evidence-I
Evidence-2
Original PDF file:
cvi 69l745820-l42906257 Exhibit B Randall s Honey Badger
About.pdf
Converted PDF file(s) ( t2 pages)
Evidence-i
Evidence-2
Evidence-3
Evidence-4
Evidence-5
Evidence-6
Evidence-7
Evidence-8
-
Evidence-9
Evidence- 10
Evidence- I 1
Evidence- 12
Original PDF file:
cvi 691745820-142906257 Exhibit C
Evidence-I
Evidence-2
Evidence-3
Evidence-4
Evidence-S
Evidence-6
Original PDF file:
cvi 691745820-142906257 Exhibit D
Converted PDF file(s) (II pages)
Evidence-I
Evidence-2
Evidence-3
Evidence-4
Evidence-S
Evidence-6
Evidence-7
Evidence-8
Evidence-9
Evidence-b
Evidence-Il
Original PDF file:
cvi 691745820-142906257 Exhibit B
Evidence-I
Evidence-2
Evidence-3
Evidence-4
Evidence-S
Evidence-6
.
Online store
dolLpdf
Calendar and Apps.pdf
Honey Badger Don t Care Book.pdf
CLASSIFICATION AND LISTING OF GOODS/SERVICES

Applicant proposes to amend the following class of goods/services in the application:
Current: Class 025 for (Based on use) Clothing, namely, i-shins, tank tops, onesies; (Based on intent to
use) Long-sleeve shirts, caps; and pajamas
Original Filing Basis:
Filing Basis: Section 1(b), Intent to Use: For a trademark or service mark application: As of the
application filing date, the applicant had a bona fide intention, and was entitled, to use the mark in
commerce on or in connection with the identified goods/services in the application. Fora collective
trademark, collective service mark, or collective membership mark application: As of the application
filing date, the applicant had a bona fide intention, and was entitled, to exercise legitimate control over the
use of the mark in commerce by members on or in connection with the identified goods/services/collective
membership organization. For a certification mark application: As of the application filing date, the
applicant had a bona fide intention, and was entitled, to exercise legitimate control over the use of the
mark in commerce by authorized users in connection with the identified goods/services, and the applicant
will not engage in the production or marketing of the goods/services to which the mark is applied, except
to advertise or promote recognition of the certification program or of the goods/services that meet the
certification standards of the applicant.
Filing Basis: Section 1(a), Use in Commerce: The applicant is using the mark in commerce, or the
applicants related company or licensee is using the mark in commerce, on or in connection with the
identified goods and/or services. 15 U.S.C. Section 1051(a), as amended. The mark was first used at least
as early as 02/24/2011 and first used in commerce at least as early as 02/24/2011 ,and is now in use in
such commerce.
Proposed:
Tracked Text Description: ( Bw,ed on u:c) Clothing, namely, t shirts, tank tops, onics; (Based on use)
Clothing, namely. t-shirts. tank tops, one piece garment for infants and toddlers; (Based on intent to use)
Long-sleeve shirts, caps; and pajamas
Class 025 for (Based on use) Clothing, namely, t-shirts, tank tops, one piece garment for infants and
toddlers; (Based on intent to use) Long-sleeve shirts, caps; and pajamas
Filing Basis: Section 1(b), Intent to Use: For a trademark or service mark application: As of the
application filing date, the applicant had a bona Me intention, and was entitled, to use the mark in
commerce on or in connection with the identified goods/services in the application. For a collective
trademark, collective service mark, or collective membership mark application: As of the application
filing date, the applicant had a bona fide intention, and was entitled, to exercise legitimate control over the
use of the mark in commerce by members on or in connection with the identified goods/services/collective
membership organization. For a certification mark application: As of the application filing date, the
applicant had a bona fide intention, and was entitled, to exercise legitimate control over the use of the
mark in commerce by authorized users in connection with the identified goods/services, and the applicant
will not engage in the production or marketing of the goods/services to which the mark is applied, except
to advertise or promote recognition of the certification program or of the goods/services that meet the
certification standards of the applicant.
Filing Basis: Section 1(a), Use in Commerce: The applicant is using the mark in commerce, or the
applicants related company or licensee is using the mark in commerce, on or in connection with the
identified goods and/or services. 15 U.S.C. Section 1051(a), as amended. The mark was first used at least
as early as 02/24/2011 and first used in commerce at least as early as 02/24/2011 ,and is now in use in
such commerce.
SIGNATURE(S)
Response Signature
Signature: /sh/ Date: 08/09/2012
Signatorys Name: Sana Hakim
Signatorys Position: Attorney of record, Illinois bar member
Signatorys Phone Number: 312-807-4350
The signatory has confirmed that he/she is an attorney who is a member in good standing of the bar of the
highest court of a U.S. state, which includes the District of Columbia, Puerto Rico, and other federal
territories and possessions; and he/she is currently the applicants attorney or an associate thereof; and to
the best of his/her knowledge, if prior to his/her appointment another U.S. attorney or a Canadian
attorney/agent not currently associated with his/her company/firm previously represented the applicant in
this matter: (I) the Lipplicant has filed or is concurrently filing a signed revocation of or substitute power
of attorney with the USPTO; (2) the USPTO has granted the request of the prior representative to
withdraw; (3) the applicant has filed a power of attorney appointing him/her in this matter; or (4) the
applicants appointed U.S. attorney or Canadian attorney/agent has filed a power of attorney appointing
him/her as an associate attorney in this matter.
Serial Number: 85147667

Internet Transmission Date: Thu Aug09 15:43:12 EDT 2012
TEAS Starnp: USPTO/ROA-XX.XXX.XX.XX-201 20809154312782
247-85447667-49o9aedldl2ceeec3e2e4d72dbs
85ed-N/A-N/A-201 20809152955980940

The Crazy Nastyass Honey Badger (original
natTation
by Randall)
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The Crazy Nastyass Honey Badger (original narration by Randall)
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Randalls Honey Badger I About
Page 1 of 12
RANDALCS KONE1 BADGER

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To email Randall click here and fill out the contact form.
The Honey Badger is a viral video featuring nature documentary footage with voiceover narration provided
by Randall, a self-proclaimed animal lover who has since launched a successful YouTube series of similar
videos. The Honey Badger video gained a great deal of popularity in early 2011 for its sassy commentary
and irreverent personification of the mammals.
Origin
The video, titled The Crazy Nastyass Honey Badger (original narration by Randall), was uploaded by
YouTuber czgl23 on January 18th, 2011. The video features original footage taken from a National
Geographic special on the ornery and tough honey badgers, which aired in 2007.
http://randallshoneybadger.comlaboutl
8;82012

RandalUs Honey Badger I About
Page 2 of 12
Between its online debut on January 18th, 2011 and December 2011, Randalls Honey Badger video racked
up more than 26 million views and spawned a cult following on YouTube. By the end of the year, his channel
had over 40,992,000 upload views, averaging out to 20,074 views a day. Randalls highly memorabe quotes
such as honey badger dont give a shit or Thoney badger dont care. coupled with his passionate
interpretation of the animals adventures made the video an instant hit.
Towards the end of January 2011, the honey badger video was covered by Internet humor blogs like
Urlesque, Huffington Post, Funny Or Die, and BuzzFeed as well as mainstream entertainment news sites
like PopCwnch and TMZ.
Randalls honey badger narration also inspired a variety of image macros, remixes and tribute videos
centered around catchphrases from The video. Meanwhile, sites and stores like Hot Topic sought to
capitalize on the viral status of honey badgers by launching several t-shifts and other merchandise with
pictures of honey badgers and Randall quotes.
On April 19th, a brief reference to a honey badger appeared on the popular TV series Glee, most likely
alluding to Randalls video:
http://randallshoneybadger.com/aboutl
8 8,20 12

Randalls Honey Badger About
Page 3 of 12
Notable Examples
Wild Wild World of Animals
Inspired by the viral spread and positive reception of his honey badger video, Randall created a VouTube
series titled Randalls Wild Wild World of Animals using similar documentary footage of wild animals.
Episodes included The Miracle of the Daffy Jesus Lizard, The Great White Sea-Monster and The
Slowass Sloth among others.
Mainstream Media
On February 22nd, 2011! Randall created a video in collaboration with MovieFone in which he provided
http randa llshonevbadger.cozn!abouti
S 520l2

Page 4 of 12
commentaries in a round-up review on 2011 Oscar nominees using the same style of voiceover from the
honey badger commentary:
In March 2011, Huffington Post published an exclusive video titled The Pigs of Wall Street featuring
Randalls commentaries on the greed of the U.S. financial industry.
In mid-March, Australian rugby player Nick Cummins stated to the press that his new, more agressive
tackling style was inspired by the honey badger after watching a wildlife documentary.Although he never
specifically mentions the Randall video, the timing of his announcement suggests that it may have been the
documentary to which he was referring.
Commercial Features
Grasshopper
On May 31st, Randall released a commercial for Grasshopper in which he provides a voiceover in similar
style of other videos. In June 2011, Microsofts search engine Bing released an update to the tools they
make available to webmasters and SEQ experts. They called the update Honey Badger.
MythBusters
On July 24th, the Discovery Channel released a promo titled MythBusters: Randalls Busters which
previewed scenes from the upcoming season of Mythbusters narrated by Randall in his stereotypical style.
http://iandallshoneybadger,com/ahout,
8.8 0 12

Randalls Honey Badger I About
Page 5 of 12
Bankrupting America
On August 17th, 2011, Bankrupting America, a campaign started by the nonpartisan, nonprofit project Public
Notice, launched a PSA video titled Crazy Washington Honey Badgers on YouTube, featuring Randalls
voice explaining the debt crisis and the recent showdown in Congress:
Wonderful Pistachios
On September 30th, 2011, a TV commercial for the snack company Wonderful Pistachios starring a honey
badger with familiar voiceover by Randall debuted on YcuTube and aired during the broadcast of ABC
series Dancing With The Stars. The clip features the fearless animal cracking open pistachios with a
hap :f/randal lshoneyh adge r. corn/about
8.82012

Rundalls Honey Badger j About
Page 6 of 12
narration by RandalL Since its launch in 2010, the ad campaign for Wonderful Pistachios has featured a
number of Internet sensations and pop culture icons such as Keyboard Cat, Angry Birds and the Annoying
Orange orange.
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Upon the release of the video on VouTube, several news publications like Forbes, MSNBC, and
Entertainment Weekly wrote articles about the commercialization of the honey badger
Football
On January 6th, 2012, CSN Bay Area reported that the San Francisco 49ers head coach Jim Harbaugh had
been using the honey badger video as a motivational tool.
http://randallshoneybadger.comlabouil
8:8:2012

Page 7 of l2
On January 10th, The Washington Post published an article in which the honey badger narrator Randall
compared LSUs cornerback Tyrann ft Mathieu, nicknamed Honey Badger. to lhe animal itself:
He just plays with such head and vigor, Randall said. Its just very exciting. To me, that
embodies the honey badger. He just takes whatever he wants and nothing is going to stop
him.
Animated Series
On January 17th, 2012, the entertainment blog Hollywood Reporter published an article about Canadian
production company Six Eleven Medias plans to develop a Honey Badger animated series.
httpJ/randallshoneybadger.coin/ahout;
8820I2

Iage S of 12
The project, which soon will be pitched to broadcast and cable networks, will follow an animated Randall,
who is the chief professor of life sciences at a dysfunctional university. His course will feature his trademark
color-commentary on documentary footage of topics related to science and the animal kingdom while
forming an unusual bond with his student, fellow professors and the University mascot, Honey, a nastya
honey badger.
The story was subsequently posted to The Daily What which pointed out that a Honey Badger book and
several Phone apps were already available.
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Randalls
14 Talking Honey Badger Dont Care Doll Adult Version s14&nted* : Toys
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Randalls 14 Talking Honey Badger Dont

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Product Features
Rare Talking Honey Badger Doll from Randall
It comes In its own packing/travel case with all sorts of warning signs an it, cu: Honey Badger may just make a snack of your finger
stupid (LDL)....
Honey Badger is approsimately 7 inches tall and around 14 inches long
To make Honey Badgsr talk, you just pinch its left front paw tor the paw on your right side if you are looking directly at it,) Of course
everyone knows a real Honey Badger doesnt speak, so Randall speaks for it end says seversi P-rated Adult quotes that you may have
heard while watching The Honey Badger Video from Randall on Vourube.
Randalls
Talking Honey Badger Dont Care Doll
Adult Version R-Rated
http://www.arnazon.coi&Randalls-Talking-Badger-Version-R-Rated!dp/80087Q8 I lO,rePns... 8:3.201 2

RandalPs
14 Talking Honey Badger Dont Care Doll
Adult Version 1t-Rated0 : Toys
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Product Details
shipping Weight: 12,8 ounces (View sbioolno rates and oolicies)
ASIN: BOOS7QBIID
Manufacturer recommended age: lB years and up
Amazon Beet Sellers Rank: #24,984 In Toys & Games (See Too 100 in Toys & Games)
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Product Features
Rare Talking Honey Badger Doll from Randall
It comes in its own packing/travel case with all sorts of warning signs on it, cur Honey Badger may yuon
stupid LOLl,...
make
a snack of your ringer
Honey Badger is approximately 7 inches tall and around 13 inches long

To make Honey Badger talk, you just pinch its left front paw (or the paw on your right side iF you are looking directly at it. I Of Course
everyone knows a real Honey Badger doesnt speak, so Randall speaks for it and seys several R-rated Adult quotes that you may have
heard while watching The Honey Badger Video from Randall on YouTube.
Randalls Talking Honey Badger Dont Care Doll
Adult Version R-Rated5
http:i/nvw.arnazon.conilRandal1s-Thlkrng-Badger-Version-R-RatedJdp/B0O87QX II C) refws... 8/3/2012

Randalls
14 Talking Honey Badger Dont Care Doll Adult Version uitRated* : Toys
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...
Product Details
Shipping Weight: 12.8
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ASIN: B008?QS11O
Manufacturer recommended age: lB years and up
Amazon Best Sellers Rank: #24984 In Toys B Games (See Too 100 In Toys S Games)
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Product Description
Randalls
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Randalls - 14 Talking Honey Badger Dont Care Doll - Adult Version *R1tated* Toys
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RandalPs
14 Talking Honey Badger Dont Care Doll Adult Version *RRated:Toys

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Amazon.com: Honey Badger Dont Care: Randalls Guide to Crazy. Nastyass Animals (97... Page 1 of 6
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Honey Badger Dont Care: Randalls Guide to

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Book Description
Pub nasa Dote 3.nu.ry 24, 2002
Sweet 3esusa rotojs wi:d ife sock for adus: The morcnymcua Rardal, narrator
one You Tube sensat on (23 MOLLOGN v:ews) 7ne
new vs se oF nature. In Honey Sadcer Do.: Carei:rn). Panda,l oretents adosen crazy. bocass
Crazy lattyaso Honey Badger, is the n
animals of the w2d kingdcrt as ony Raroal: osuld. Dont be stupid--buy this book
Frequently
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Randall
telci,ta,
512.59
sisgg520g9
Editorial Reviews
About the Author
Born and raised in New York City, Randall started narraLng at an early age. Randalls father was a cameraman for Marion Perktnas Mutual
of Omahas Wild Kingdom. Randall is a graduate of both St Olafs College in Nortbfield, Minnesota, and the Exotic Animal Training and
Management Program at Moorpark Coliege In Moorpark, California. Randall currensly resides In Los Angeles and lives with three loving cats,
Product Details
Hardcover: SD pages
Publisher: Andrews McMeel PublIshing (January 24, 2012)
Language: English
iSBN 10:1440410650
g78-s44g4sg613
Dimensions: 3.1 t 0.4 x 10 inches
ISBN-IS:
Product
Shipping WeighEr 15.2 puncea (View shipoino rates and policies)

Average Custonier Review:
(13 customer reviews)
Amazon Best Sellers Rank: 30,204 in Books (See Too 100 in Books)
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Customer Reviews
5 elan
3tlar
From Outliers to Outlander

Download 2 FREE njd,ntruuks
atlar
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Most Helpful Customer Reviews

Its? le p.api. found me lsirse,ng revIew heiptkl
Nasty, disguslina (and sometimes ouddlyl critters January 24. 20:2
*dwtftwresst
OyTChhs
Fomel Hardcover
I came late to Randalls poputar YouTube video The Crazy Nassyasa Honey Badger but I
got a kick out of it when I finally saw it, as did, it seems, millions of other people In Honey
Badger Dont Care, Randall uses the same flippant tone to introduce the reader to the honey
badger and nine other (allegedly nastyass) members of the anImal kingdom An Introduction
suggests that conser/atlonists should welcome the attention that Randall is bringing to these
Most Recent Customer Reviews
http://www.amazon.com/Honey-Badger-Dont-Care-Randalls/dp114494 I 9658/refrsr_l_2?ie...
8.3.2012

Amazon.com: Honey Badger Dont Care: Randalls Guide to Crazy, Nastyass Animals (97... Page 3 of 6
not-so-cuddly species, but the books really about humor rather than the preservation of
enimals wed rather not meet ins dark alley There is nonetheless an informative, proconservationist quality to much of Randalls commentary; ft isnt all about disgusting animal
behavior
Freakish-looking beasts that are subjects of Randalls commentary Inolude the aye-aye, the
Tasmanian devil, and the sotenodon Some of the animals, Including the wombat, the
opossum, and the Amsncan bullfrog, are only moderately nastyass. Randall Features some
animals that dont seem nasty at all the emperor tamarin (which lunches on grapes and has a
very coot mustache), the pink fairy armadillo, the tattler a weirdly cute, timid little primate),
and the sloth. Readers who are hoping to find ten animals that are as revolting as the honey
badger might be disappointed StIll. Randall manages to poke fun at even the cuddly critters,
always in a good-natured way.
Honey Badger Dont Care is filled with Impressive photographs, many of which are enhanced
wilt, doodles, costumes, and cartoon-style dialog balloons, Randairs description of the
animals and their behaviors Is educational, it not exactly the stuff or zoology leelbooks.
Reader, who object to foul language should be warned that theres very little language in this
book that isnt foul Thats part of what gives the book its attitude. This isnt a nature book for
kiddies. Adults who dont mind adult language and who appreciate the humor found in nature
should have a fun time wish Honey Badger Dont Care
Comment I Was this rev em helpful to foul
Yes
The Fifteen Minuses Stan....,, NOW! Jasusry 27. 2512

vpdrvcicu
ro,msi Hardcover
Since no one is ever satisfied with lust a email measure of fame. internet sensation Randall
seeks so shake off the shackles of narrating funny animal videos by branching out into the
literary world, with HONEY BADGER DONT CARE RANDALLS GUIDE TO CRAZY
NASTYASS ANIMALS While to book does provides few chuckles, reading Randalie
outrageous comments isnt the same as HEARING Randalre outrageous comments..., The
voice is SD% of the joke HONEY SADDER DONT CARE is an amusing time-waster, but I
wouldnt really urge anyone to spend money on it, espedaily since all of his videos are
available for free, and are Funnier
Was this review kelpfsl to you1 Yesi
Puulisfled
motre far by Carla Kelleher
dollars, but Its a good conversation piece

Read more
Published 2 months ego by ikeygiil4
Informative and Entertaining

Honey Badger Dont Care is my current favorite
book Not only did I learn eboul animals I didnt
even know existed, I had a good laugh in the
procesa Read more
Published 4 martha ago ty Tracey
My 12 year old thinks Its funny...
Fly 12 year old thinks its funny. Might not be a
book for young childern bewareil There Is also
video on youtube ,ith this Honey Badger
PublIshed 5 montha ags by PUaflir
[No]
off people found Ike foliovlsg revIew heiptui

By Daniel V. Reilly
Crazy funny book
I bought thIs book as a gift for a friend who loves

she online video, but, before mailed it wanted
to glance through it. I ended up readirg the
whole bockmy mother did too Pesd more
Foul Langage- Great Pictures

Honey Badger Dont Care by Randall
Pictures 5 STARS
language I STAR
Educational 4 STARS
I have never seen or heard about the ytube
video so I vas lust thinking. Read more
Pubiiorad 5 mcnits ago by 9 Laney
Not bad at all (mists caveats).
Honey Badger Dont Cart is quits funny and
enjoyable. fts a fun animal books for adults.
which is where the caveats come in The books
Is formatted In bright and fun colors Read more
Puslisked 5 mrsths ago by rlores2s is
No
Honey Badger Dont Care,,, but
sf1 peor..
r:iii:2 Is,
rns, ng rev.. heiptul
Why arent more people giving this 5 asars7t?t Its awesometit

January27 2012
By RscheiMcwosderful
Published S montha ego by chibINeko
Formal. Hardcover
This book is genuinely clever and is such s good laugh. If you didnt like Randalls original
youtube video, then you wont like this book (and youre obviously mazy since hes hilarious).
Hilarious, witty, and informative Loved ltl
ctmmenf t Wea this levi. e helpful to you?
dot
Honey badger might not care that its become an
internet sensation end no a must-read book,
but you absolutely wily Read more
[,!!J
Na
Honey Badger Dons Care

This book is HILARIOUS! I wasnt prepared for
hwy funny this was going to be As usual I was
going to read just a few pages beFore going to
bed, and then! find myself on the.. Read more
Publlsnea e morisa ego by Muzette Weston
esee elI 13 customer revIews
Wile iscttsttiriei eviec
Crude, Lewd, and Craaa,,,,but

thoroughty enssnaining.
After watching The Crazy Nastyass Honey
Badger on Youtube, I had to buy this book I
asked myself if the 3 minute video was epic,
bow much more epic can the book be?
Read more
Published e essths ego by Zack
Honey Badger Dons Care
Honey Badger Dont Care Is a wildlife book for
adults If crude language bother, you then this
book isnt for you, othenvite I think it is a great
way to learn about badass Read more
Published e minim ego by Jo
.
liup:/iwvw.amazon.comIFloney-Badger-Domn-Care-RandnIlsfdp/l4494l 965S.refsr l_2?ie,,,
83/2Ol2

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Search Customer Reviews
LZ
F
O,,we,thth.,p,e&ntsre.w
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HONEY BAD5ER
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CERTIFICATE OF FILING/SERVICE
2
I hereby certif5 that on December 22, 2015, counsel for Plaintiff Christopher
3
Gordon electronically filed the foregoing document with the Clerk of the Court by
5 using the Courts CM/ECF system. The electronic case filing system xviii be sending
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a Notice of Electronic Filing to all attorneys of record who have consented to
7
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Dated: December 22, 2015

Daniel L. Reback
12
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Case No. CV 15-04905 JFW (PLAx)

Gordon v. Drape Creative - Honey Badger Don't Give A Shit PDF

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Case 2:15-cv-04905-JFW-PLA Document 32 Filed 12/22/15 Page 1 of 114 Page ID #:261

Daniel L. Reback (SBN 239884)

7 Attorneys for Plaintiffi

UNITED STATES DISTRICT COURT

CENTRAL DESTRICT OF CALIFORNIA

Case No. CV 15-04905 JFW (PLAx)

Hon. John F. Walter, presiding

FIRST AMENDED COMPLAINT

DRAPE CREATE VE, INC., a Missouri

DEMAND FOR JURY TRIAL

FIRST AMENDED COMPLAINT

Case 2:15-cv-04905-JFW-PLA Document 32 Filed 12/22/15 Page 2 of 114 Page ID #:262

Plaintiff CHRISTOPHER GORDON (Plaintiff) alleges as follows:

Plaintiff is a comedic narrator who, on January 18, 2011, published a video on

others. Plaintiffs original expressions have gained a tremendous amount of notoriety,

and his expressions have been referred to in commercials, television shows,

magazines, and throughout the internet, and by numerous celebnties. Plaintiff

Case 2:15-cv-04905-JFW-PLA Document 32 Filed 12/22/15 Page 3 of 114 Page ID #:263

JURISDICTION AND VENUE

This Court has subject matter jurisdiction pursuant

to 28 U.S.C. l331 and 1338.

This Court has supplemental jurisdiction over the claims in this

Venue is proper in this Court pursuant to 28 U.S.C. 139l(b) and

Case 2:15-cv-04905-JFW-PLA Document 32 Filed 12/22/15 Page 4 of 114 Page ID #:264

Plaintiff is an individual residing in Los Angeles, California.

Plaintiff is informed and believes, and thereon alleges, that Defendant

5 Drape Creative, Inc. (DCI) is a Missouri corporation that is subject to the

jurisdiction of this Court.

DCI, which does business as Tomato Cards, designs

greeting cards and conducts its business on the internet at dcistudios.com.

Plaintiff is informed and believes, and thereon alleges, that Defendant

Papyrus-Recycled Greetings, Inc. (Recycled Greetings) is an Illinois corporation

13 greeting cards and conducts its business on the internet at prureetins.com.

The true names and capacities, whether individual, corporate, associate or

Case 2:15-cv-04905-JFW-PLA Document 32 Filed 12/22/15 Page 5 of 114 Page ID #:265

capacities of these DOE defendants when the same are ascertained.

Plaintiff and His Video, Copyright a id Traden, ark

Plaintiff is a comedian, narrator, writer, and actor, and is commonly

known by his alias, Randall.

On January 18, 2011, Plaintiff published a video (the Video) on

The Video is available at https://www.youtube.corn/watch?v=4r7wHMg5Yig

-5FIRST AMENDED COMPLAINT

Case 2:15-cv-04905-JFW-PLA Document 32 Filed 12/22/15 Page 6 of 114 Page ID #:266

5 times in the Video.

(Video at 0:24; 0:35; 1:18; and 1:30.)

9 magazines, and throughout the internet.

Plaintiff is the owner of trademark registrations for HONEY BADGER

following Registration Numbers: 4,505,781; 4,419,079; 4,419,081; and 4,281,472.

Initially, the USPTO rejected Plaintiffs trademark application on the

Case 2:15-cv-04905-JFW-PLA Document 32 Filed 12/22/15 Page 7 of 114 Page ID #:267

13 HBDGS mark as a source identifier on numerous products, including: mens t-shirts;

for some of Plaintiffs authorized goods bearing his HBDGS mark.

Specifically, Plaintiff also produced and sold greeting cards and

Case 2:15-cv-04905-JFW-PLA Document 32 Filed 12/22/15 Page 8 of 114 Page ID #:268

Plaintiff primarily advertises his goods bearing his Marks, including

Plaintiffs trademark is inherently distinctive and/or has acquired

13 in connection with his trademark and derivations thereof

The Mark and its

Plaintiff has expended a significant amount oftime and effort in making

outlets, and publicizing the Marks through social media platforms.

Case 2:15-cv-04905-JFW-PLA Document 32 Filed 12/22/15 Page 9 of 114 Page ID #:269

Defendants Unlawful Activities and Willful Infringem cut