Case 2:20-cv-01629 Document 1 Filed 02/19/20 Page 1 of 13 Page ID #:1

1
Stephen M. Doniger, Esq. (SBN 179314)
stephen@donigerlawfirm.com
2 Scott Alan Burroughs, Esq. (SBN 235718)
3 scott@donigerlawfirm.com
Trevor W. Barrett (SBN 287174)
4 tbarrett@donigerlawfirm.com
5 Justin M. Gomes (SBN 301793)
jgomes@donigerlawfirm.com
6 DONIGER / BURROUGHS
7 603 Rose Avenue
Venice, California 90291
8 Telephone: (310) 590-1820
9
Attorneys for Plaintiff
10

11 UNITED STATES DISTRICT COURT

12 CENTRAL DISTRICT OF CALIFORNIA
13
JASMIN LARIAN LLC, a Delaware Case No.:
14
limited liability company doing business
15 as “CULT GAIA,” PLAINTIFF’S COMPLAINT FOR:
16 1. DESIGN PATENT
Plaintiff, INFRINGEMENT - U.S.
17 PATENT NO. US D826,554 S
vs. 2. DESIGN PATENT
18 INFRINGEMENT - U.S.
PATENT NO. US D828,021 S
19 THE RED DRESS BOUTIQUE, INC., a
20 Georgia Corporation; and DOES 1-10,
Jury Trial Demanded
21 Defendants.
22

23

24 Plaintiff, JASMIN LARIAN LLC d/b/a CULT GAIA (“CULT GAIA”), by and

25 through its undersigned attorneys, hereby prays to this honorable Court for relief

26 based on the following:

27

28 1
COMPLAINT
 Case 2:20-cv-01629 Document 1 Filed 02/19/20 Page 2 of 13 Page ID #:2

1 INTRODUCTION
2 CULT GAIA designs, markets, and sells artistic apparel and accessories
3 around the world. It has been creating beautiful and unique heirloom pieces of artistic
4 clothing and accessories since 2012. CULT GAIA is now an inimitable lifestyle
5 brand that purveys an array of fashionable and artistic products, including high-
6 quality handbags.
7 Two of CULT GAIA’s handbags, each of which is covered by design patent,
8 are at issue here. GAIA’s business is predicated on the ownership of its intellectual
9 property, including its design patents, and it spends a considerable amount of time
10 and resources creating marketable and aesthetically appealing pieces featuring these
11 designs. Indeed, CULT GAIA’s intellectual property rights are important to its brand,
12 its success, and its competitive position.
13 The defendants in this case have undercut CULT GAIA’s competitive position
14 and infringed CULT GAIA’s rights in its patented designs by developing, importing,
15 and selling without permission products substantially the same if not virtually
16 identical to the ornamental designs of CULT GAIA’s bag designs, as presented
17 hereinbelow.
18 JURISDICTION AND VENUE
19 1. This is a civil action for design patent infringement arising under the patent
20 laws of the United States 35 U.S.C. §§ 100 et seq., including 35 U.S.C. § 271.
21 2. This Court has federal question jurisdiction under 28 U.S.C. § 1331 and
22 1338 (a) and (b).
23 3. Venue in this judicial district is proper under 28 U.S.C. § 1391(c) and
24 1400(a) in that this is the judicial district in which a substantial part of the acts and
25 omissions giving rise to the claims occurred.
26 4. This Court has personal jurisdiction over Defendants because Defendants
27 have purposely availed themselves of the privileges and benefits of the laws of the
28 2
COMPLAINT
 Case 2:20-cv-01629 Document 1 Filed 02/19/20 Page 3 of 13 Page ID #:3

1 state of California. Defendants do, and have done, substantial business in this
2 judicial District, including, inter alia,: (i) regularly doing business or soliciting
3 business by virtue of Defendants’ nationwide sales and offers to sell through
4 interactive and commercial website(s) which direct(s) Defendants’ services and
5 products to California residents; and (ii) engaging in other persistent courses of
6 conduct, and/or deriving substantial revenue from products and/or services provided
7 to persons in this District and State. This Court’s exercise of personal jurisdiction
8 over Defendants is consistent with the Constitutions of the United States and the
9 state of California.
10 PARTIES
11 5. Plaintiff CULT GAIA is a limited liability company duly organized and
12 existing under the laws of the State of Delaware, with its principal place of business
13 in Los Angeles, California.
14 6. Defendant The Red Dress Boutique, Inc. (“Red Dress”) is a Georgia
15 corporation with its principal place of business located at 147 College Avenue,
16 Athens, GA 30601, and is doing business in and with the State of California.
17 7. CULT GAIA is unaware of the true names and capacities of the defendants
18 sued herein as DOES 1 through 10, inclusive, and for that reason, sue defendant(s)
19 under such fictitious names. CULT GAIA is informed and believes and based
20 thereon alleges that such fictitiously named defendants are responsible in some
21 manner for the occurrences alleged herein, and that CULT GAIA’s damages as
22 herein alleged were proximately caused by the conduct of said defendants. CULT
23 GAIA will seek to amend the complaint when the names and capacities of such
24 fictitiously named defendants are ascertained. As alleged herein, the term
25 “Defendants” shall mean all named defendants and all fictitiously named defendants.
26 8. CULT GAIA is informed and believes and based thereon alleges that
27 Defendants, at all times relevant to this action, were the agents, servants, partners,
28 3
COMPLAINT
 Case 2:20-cv-01629 Document 1 Filed 02/19/20 Page 4 of 13 Page ID #:4

1 joint venturers and employees of each of the other Defendants and, in doing the acts
2 alleged herein, were acting with the knowledge and consent of each of the other
3 defendants in this action. Alternatively, at all times mentioned herein, each of the
4 defendants conspired with each other to commit the wrongful acts complained of
5 herein. Although not all of the defendants may have committed all of the acts of the
6 conspiracy or were members of the conspiracy at all times during its existence, each
7 defendant knowingly performed one or more acts in direct furtherance of the
8 objectives of the conspiracy. Therefore, each defendant is additionally liable for the
9 acts of his or her or its co-conspirators.
10 CLAIM FOR RELIEF – DESIGN PATENT INFRINGEMENT OF U.S.
11 PATENT NO. US D826,554 S
12 (Against All Defendants)
13 9. On August 28, 2018, CULT GAIA obtained U.S. Patent No. US D826,554
14 S (“the ‘554 patent”). A true copy of the ‘554 patent is attached hereto as Exhibit 1.
15 10. CULT GAIA is the owner by assignment of the ‘554 patent with full and
16 exclusive right to bring suit to enforce the ‘554 patent.
17 11. The ‘554 patent generally relates to the CULT GAIA product entitled the
18 “Big Natural.” Exemplary Figures from the Big Natural patent are reproduced
19 below.
20

21

22

23

24

25

26 ///
27 ///
28 4
COMPLAINT
 Case 2:20-cv-01629 Document 1 Filed 02/19/20 Page 5 of 13 Page ID #:5

8
9

10

11

12 12. On information and belief, the Defendants have been and are infringing,
13 contributing to infringement, and/or inducing others to infringe the ‘554 patent by
14 making, using, offering for sale, selling or importing handbags that read on and thus
15 infringe the ‘554 patent. These infringing handbags include, but are not limited to,
16 products published and offered for sale by Red Dress as the “Getting it Together
17 Large Japanese Bamboo Square Bag” and “Getting it Together Small Japanese
18 Bamboo Square Bag.” True and correct reproductions of such infringing products
19 are provided below.
20

21

22

23

24

25

26 ///
27 ///
28 5
COMPLAINT
 Case 2:20-cv-01629 Document 1 Filed 02/19/20 Page 6 of 13 Page ID #:6

1 Getting it Together Large Japanese Getting it Together Small Japanese

Bamboo Square Bag Bamboo Square Bag
2

8
9

10

11

12
13. As can be seen above, the overall appearance of the above large and small
13
infringing products are substantially the same as CULT GAIA’s patented Big
14
Natural bag design. An ordinary observer will perceive the overall appearance of
15
these designs to be substantially the same.
16
14. Notable substantial similarities between the Big Natural design and
17
infringing product designs include the solid wood top handle portion including
18
proportion and shape of handle space, distinctive slatted bamboo front, back and
19
siding, layered bamboo base, as well as the overall shape and proportion of the bag.
20
15. CULT GAIA is informed and believes, and thereon alleges, that
21
Defendants are sophisticated entities in the fashion and apparel industries and are
22
uniquely aware of the existence of design patents associated with accessories such as
23
CULT GAIA’s unique and proprietary bags. Despite this, Defendants recklessly
24
utilized CULT GAIA’s patented Big Natural design. Certain Defendants, with
25
knowledge of the infringing nature of the product, ordered, manufactured, sold and
26
distributed the infringing accessories to their customers with the specific intention of
27

28 6
COMPLAINT
 Case 2:20-cv-01629 Document 1 Filed 02/19/20 Page 7 of 13 Page ID #:7

1 encouraging the further manufacture, sale, and distribution of the infringing product
2 and the infringement of the ‘554 patent inherent therein. Defendants’ acts of
3 infringement have occurred within this district and elsewhere throughout the United
4 States.
5 16.Given the widespread popularity and recognition of CULT GAIA’s
6 products, CULT GAIA avers and hereon alleges that Defendants had knowledge of
7 CULT GAIA’s rights as to the ‘554 patent before this suit and before CULT GAIA
8 provided express notice of its rights in writing, and Defendants intentionally copied
9 said design on their own brand of products in an effort to pass them off as if they
10 originated, are associated with, are affiliated with, are sponsored by, are authorized
11 by, or are approved by CULT GAIA.
12 17.On information and belief, the Defendants have willfully infringed the ‘554
13 patents by continuing their acts of infringement after being on notice of the patent.
14 18.CULT GAIA owns all right, title, and interest in, and has the right to sue
15 and recover for past, present, and future infringement of, the design patent related to
16 its Big Natural design. The USPTO duly and legally issued the ‘554 patent in
17 connection with this bag design.
18 19. In violation of 35 U.S.C. §271, Defendants have infringed and are
19 continuing to infringe, literally and/or under the doctrine of equivalents, the ‘554
20 patent by making, using, importing, offering for sale, and/or selling products,
21 including but not limited to those identified hereinabove, that infringes the ‘554
22 patent, and/or by inducing or contributing to the infringement of the ‘554 patent by
23 others. All elements of the design of the corresponding infringing product are
24 substantially the same if not virtually identical to the ornamental designs of CULT
25 GAIA’s Big Natural design. Attached hereto as Exhibit 3 are true and correct
26 images of Red Dress offering for sale the above-referenced infringing products in its
27 website https://www.reddressboutique.com.
28 7
COMPLAINT
 Case 2:20-cv-01629 Document 1 Filed 02/19/20 Page 8 of 13 Page ID #:8

1 20. The infringing products have no substantial non-infringing uses.

2 21. CULT GAIA has marked its patented material per 35 U.S.C. § 287(a) with
3 the ‘554 patent identifiers since approximately September, 2018. As such,
4 Defendants, and each of them, had constructive notice, both through this marking
5 and CULT GAIA’s Federal patent registrations, of CULT GAIA’s patent rights.
6 Defendant’s, and each of their, exploitation of the patented material with such notice
7 constitutes willful infringement.
8 22. CULT GAIA has been damaged and will continue to sustain damages as a
9 result of the Defendants’ infringement. CULT GAIA is entitled to recover damages
10 sustained as a result of Defendants’ wrongful acts in an amount to be proven at trial.
11 23. Defendants have willfully infringed the ‘554 patent, entitling CULT GAIA
12 to increased damages under 35 U.S.C. § 284 and to attorneys’ fees and costs incurred
13 in prosecuting this action under 35 U.S.C. § 285. Alternatively, CULT GAIA is
14 entitled to recover Defendants’ total profits from their sale of the infringing products
15 under 35 U.S.C. § 289. CULT GAIA is further entitled to injunctive relief
16 prohibiting Defendants from infringing the ‘554 patent under 35 U.S.C. § 289.
17 CLAIM FOR RELIEF – DESIGN PATENT INFRINGEMENT OF U.S.
18 PATENT NO. US D828,021 S
19 24. On September 11, 2018, CULT GAIA obtained U.S. Patent No. US
20 D828,021 S (“the ‘021 patent”). A true copy of the ‘021 patent is attached hereto as
21 Exhibit 2.
22 25. CULT GAIA is the owner by assignment of the ‘021 patent with full and
23 exclusive right to bring suit to enforce the ‘021 patent.
24 26. The ‘021 patent generally relates to a CULT GAIA product called the
25 “Luna Bag.” Exemplary Figures from the Luna Bag patent are reproduced below.
26

27

28 8
COMPLAINT
 Case 2:20-cv-01629 Document 1 Filed 02/19/20 Page 9 of 13 Page ID #:9

8
9

10

11

12 27. On information and belief, the Defendants have been and are infringing,
13 contributing to infringement, and/or inducing others to infringe the ‘021 patent by
14 making using, offering for sale, selling or importing handbags that read on and thus
15 infringe the ‘021 patent. These infringing handbags include, but are not limited to,
16 products published and offered for sale by Red Dress as the “Around Again Round
17 Bamboo Purse.” True and correct reproductions of such infringing products are
18 provided below.
19

20

21

22

23

24

25

26 ///
27 ///
28 9
COMPLAINT
 Case 2:20-cv-01629 Document 1 Filed 02/19/20 Page 10 of 13 Page ID #:10

1 Around Again Round Bamboo Purse

8
9

10

11

12

13

14
28. As can be seen above, the overall appearance of the above infringing
15
products are substantially the same as CULT GAIA’s patented Luna Bag design. An
16
ordinary observer will perceive the overall appearance of these designs to be
17
substantially the same.
18
29. Notable substantial similarities between the Luna Bag design and
19
infringing product design include the spacing, placement, and proportion of the
20
wood top flap panel, appearance, spacing, placement, and proportion of the
21
distinctive tri-level circular set of bamboo slats on the front and back, central circular
22
cut-out motif present on the front and back, as well as the overall shape and
23
proportion of the entire bag.
24
30. CULT GAIA is informed and believes, and thereon alleges, that
25
Defendants are sophisticated entities in the fashion and apparel industries and are
26
uniquely aware of the existence of patents that protect accessories such as CULT
27

28 10
COMPLAINT
 Case 2:20-cv-01629 Document 1 Filed 02/19/20 Page 11 of 13 Page ID #:11

1 GAIA’s bags. Despite this, Defendants recklessly utilized CULT GAIA’s unique and
2 patented Luna Bag design. Certain Defendants, with knowledge of the infringing
3 nature of the product, ordered, manufactured, sold and distributed the infringing
4 products to their customers with the specific intention of encouraging the further
5 manufacture, sale, and distribution of the infringing product and the infringement of
6 the ‘021 patent inherent therein. Defendants’ acts of infringement have occurred
7 within this district and elsewhere throughout the United States.
8 31.Given the widespread popularity and recognition of CULT GAIA’s
9 products, CULT GAIA avers and hereon alleges that Defendants had knowledge of
10 CULT GAIA’s rights as to the ‘021 patent before this suit and before CULT GAIA
11 provided express notice of its rights in writing, and Defendants intentionally copied
12 said design on their own brand of products in an effort to pass them off as if they
13 originated, are associated with, are affiliated with, are sponsored by, are authorized
14 by, or are approved by CULT GAIA.
15 32.On information and belief, the Defendants have willfully infringed the ‘021
16 patent by continuing their acts of infringement after being on notice of the patent.
17 33.CULT GAIA owns all right, title, and interest in, and has the right to sue
18 and recover for past, present, and future infringement of, the design patents related to
19 its Luna Bag design. The USPTO duly and legally issued the ‘021 patent in
20 connection with these bag designs.
21 34. In violation of 35 U.S.C. §271, Defendants have infringed and are
22 continuing to infringe, literally and/or under the doctrine of equivalents, the ‘021
23 patent by making, using, importing, offering for sale, and/or selling products,
24 including but not limited to those identified hereinabove, that infringes the ‘021
25 patent, and/or by inducing or contributing to the infringement of the ‘021 patent by
26 others. The designs of each corresponding infringing product are substantially the
27 same if not virtually identical to the ornamental designs of CULT GAIA’s Big
28 11
COMPLAINT
 Case 2:20-cv-01629 Document 1 Filed 02/19/20 Page 12 of 13 Page ID #:12

1 Natural and Luna Bag designs. Attached hereto as Exhibit 3 are true and correct
2 images of Red Dress offering for sale the above-referenced infringing products in its
3 website https://www.reddressboutique.com.
4 35. The infringing products have no substantial non-infringing uses.
5 36. CULT GAIA has marked its patented material per 35 U.S.C. § 287(a) with
6 the ‘021 patent identifiers since approximately September, 2018. As such,
7 Defendants, and each of them, had constructive notice, both through this marking
8 and CULT GAIA’s Federal patent registrations, of CULT GAIA’s patent rights.
9 Defendant’s, and each of their, exploitation of the patented material with such notice
10 constitutes willful infringement.
11 37. CULT GAIA has been damaged and will continue to sustain damages as a
12 result of the Defendants’ infringement. CULT GAIA is entitled to recover damages
13 sustained as a result of Defendants’ wrongful acts in an amount to be proven at trial.
14 38. Defendants have willfully infringed the ‘021 Design Patent, entitling
15 CULT GAIA to increased damages under 35 U.S.C. § 284 and to attorneys’ fees and
16 costs incurred in prosecuting this action under 35 U.S.C. § 285. Alternatively,
17 CULT GAIA is entitled to recover Defendants’ total profits from their sale of the
18 infringing products under 35 U.S.C. § 289. CULT GAIA is further entitled to
19 injunctive relief prohibiting Defendants from infringing the ‘021 patent under 35
20 U.S.C. § 289.
21 PRAYER FOR RELIEF
22 Wherefore, Plaintiff prays for judgment as follows:
23 Against All Defendants
24 a. That Defendants, their agents and employees, all parent and subsidiary
25 corporations, all assignees and successors in interest, and those persons
26 in active participation with Defendants, be enjoined from infringing
27 Plaintiff’s ‘554 and ‘021 patents in any manner;
28 12
COMPLAINT
 Case 2:20-cv-01629 Document 1 Filed 02/19/20 Page 13 of 13 Page ID #:13

1 b. an award of damages under 35 U.S.C. § 287 for Defendants’

2 infringements of Plaintiff’s ‘554 and ‘021 patents;
3 c. a trebling of damages pursuant to 35 U.S.C. § 284;
4 d. an award of attorney fees pursuant to 35 U.S.C. § 285;
5 e. That Plaintiff be awarded pre-judgment interest as allowed by law;
6 f. That Plaintiff be awarded the costs of this action; and
7 g. That Plaintiff be awarded such further legal and equitable relief as the
8 Court deems proper.
9 A TRIAL BY JURY PURSUANT TO FED. R. CIV. P. 38 AND
10 CONSTITUTIONAL AMENDMENT SEVEN IS HEREBY DEMANDED.
11

12 Respectfully submitted,
13

14 Dated: February 19, 2020 By: /s/ Scott Alan Burroughs

15
Scott Alan Burroughs, Esq.
Trevor W. Barrett, Esq.
16 Justin M. Gomes, Esq.
17 DONIGER / BURROUGHS
Attorneys for Plaintiff
18

19

20

21

22

23

24

25

26

27

28 13
COMPLAINT
Case 2:20-cv-01629 Document 1-1 Filed 02/19/20 Page 1 of 7 Page ID #:14

EXHIBIT 1
Case 2:20-cv-01629 Document 1-1 Filed 02/19/20 Page 2 of 7 Page ID #:15
Case 2:20-cv-01629 Document 1-1 Filed 02/19/20 Page 3 of 7 Page ID #:16
Case 2:20-cv-01629 Document 1-1 Filed 02/19/20 Page 4 of 7 Page ID #:17
Case 2:20-cv-01629 Document 1-1 Filed 02/19/20 Page 5 of 7 Page ID #:18
Case 2:20-cv-01629 Document 1-1 Filed 02/19/20 Page 6 of 7 Page ID #:19
Case 2:20-cv-01629 Document 1-1 Filed 02/19/20 Page 7 of 7 Page ID #:20
Case 2:20-cv-01629 Document 1-2 Filed 02/19/20 Page 1 of 7 Page ID #:21

EXHIBIT 2
Case 2:20-cv-01629 Document 1-2 Filed 02/19/20 Page 2 of 7 Page ID #:22
Case 2:20-cv-01629 Document 1-2 Filed 02/19/20 Page 3 of 7 Page ID #:23
Case 2:20-cv-01629 Document 1-2 Filed 02/19/20 Page 4 of 7 Page ID #:24
Case 2:20-cv-01629 Document 1-2 Filed 02/19/20 Page 5 of 7 Page ID #:25
Case 2:20-cv-01629 Document 1-2 Filed 02/19/20 Page 6 of 7 Page ID #:26
Case 2:20-cv-01629 Document 1-2 Filed 02/19/20 Page 7 of 7 Page ID #:27
Case 2:20-cv-01629 Document 1-3 Filed 02/19/20 Page 1 of 20 Page ID #:28

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