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Act, 15 U.S.C. 1114(1); unfair competition under Section 43(a) of the Lanham Act, 15 U.S.C.
1125(a); trademark dilution under Section 43(c) of the Lanham Act, 15 U.S.C. 1125(c);
deceptive and unfair trade practices under Section 349 of the New York General Business Law;
trademark dilution under Section 360-l of the New York General Business Law; and trademark
infringement and unfair competition under the common law of New York. Chanel seeks
injunctive relief, an accounting of Defendants profits flowing from her use of the infringing
marks, damages, attorneys fees, and such other relief as the Court deems just and proper.
PARTIES
2. Plaintiff Chanel, Inc. is a corporation organized and existing under the laws of the
State of New York with a principal place of business at 9 West 57th Street, New York, New
York 10019.
3. Upon information and belief, Defendant J eanine Heller is an individual doing
business as What About Yves. Defendant resides at 250 Bowery, #3E, New York, New York
10012 and maintains a showroom in this district at 263 Eleventh Avenue, Floor 5, New York,
New York 10001.
JURISDICTION AND VENUE
4. This Court has jurisdiction over the subject matter of this action pursuant to
Section 39 of the Lanham Act, 15 U.S.C. 1121, and under Sections 1331, 1338(a) and 1338(b)
of the J udicial Code, 28 U.S.C. 1331, 1338(a) and 1338(b). The Court has supplemental
jurisdiction over the state law claims under Section 1367(a) of the J udicial Code, 28 U.S.C.
1367(a).
5. Venue is proper in this district pursuant to Sections 1391(b) and (c) of the J udicial
Code, 28 U.S.C. 1391(b) and (c) because Defendant is a resident of and transacts business in
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this district, because Defendant has substantial contacts with this district, and because a
substantial portion of the events at issue have arisen and will arise in this judicial district and
Chanel is suffering harm in this judicial district.
6. This Court has personal jurisdiction over Defendant under Sections 301 and/or
302 of the New York Civil Practice Laws and Rules because (i) Defendant resides in this state
and/or continuously and systematically conducts, transacts and solicits business in this district,
(ii) Defendant operates an interactive and commercial website at www.whataboutyves.com
through which she sells the infringing goods complained of herein to residents of this district and
otherwise ships products into this district for purposes of resale, (iii) Defendant has committed
tortious acts within this district by advertising and selling her infringing goods here, and (iv) the
events giving rise to this Complaint occurred in this state and/or had effects in this state.
FACTS COMMON TO ALL
CLAIMS FOR RELIEF
A. Chanels Business and Use of the Famous CC Monogram Mark
7. Chanel is a premier manufacturer and seller of a wide variety of luxury consumer
products and is a recognized leader in the field of fashion and beauty.
8. Among the trademarks long used by Chanel to identify its goods is a design mark
consisting of two interlocking back-to-back letter Cs as follows:
or
(together the CC Monogram mark).
9. Chanel has used the CC Monogram mark for more than eight decades in United
States commerce.
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10. Today, the CC Monogram mark is reproduced on hundreds of millions of dollars
worth of consumer goods each year spanning the full range of Chanels product line, including
clothing, shoes, handbags, wallets, jewelry, accessories, beauty products, and eyewear. Products
bearing or sold under the CC Monogram mark are available throughout the United States in
department stores, through authorized retailers on the Internet, and through Chanels own
website and stand-alone boutiques.
11. Chanels yearly sales of products bearing or sold under the CC Monogram mark
in the United States total in the hundreds of millions of dollars. All products bearing the CC
Monogram mark are renowned for their high quality and are identified and recognized as being
exclusively from Chanel by virtue of their use of the CC Monogram mark. Indeed, Chanel
consistently appears year after year in the Womens Wear Daily list of the 100 best known brands
in the fashion industry.
12. In addition to appearing on Chanels products, the CC Monogram mark is used on
collateral material, such as packaging, hangers, labels and hangtags. The CC Monogram mark
also is featured prominently in advertisements that regularly appear in nationally-distributed
magazines that are seen by hundreds of millions of people.
13. The recognition of the CC Monogram mark among the public at large is enhanced
not only by Chanels own advertising efforts but also by fashion editorial and press coverage of
Chanel that frequently highlights products bearing the CC Monogram mark. Such unsolicited
press coverage reaches hundreds of millions of consumers. By way of example only, the CC
Monogram mark has been referred to as famous by national publications such as The
Washington Post, Womens Wear Daily, The Dallas Morning News and has been referred to as
iconic by The Los Angeles Times.
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14. The CC Monogram mark has become extraordinarily well known across all social
and demographic groups, from urban rappers to New York society to Oscar-winning actors. As
a result, products bearing the CC Monogram mark are in demand by consumers of all ages and
from all demographics.
15. For decades, Chanel has highlighted the CC Monogram mark on its products,
making the mark the central focus of jewelry, clothing, and accessories.
16. By way of example only, Chanel featured the CC Monogram mark on tank tops
and tank top-style blouses in its Spring/Summer 2011 and 2013 collections, featured the CC
Monogram mark on t-shirt style dresses in its Spring/Summer 2012 collection, and featured the
CC Monogram on t-shirts in its Cruise 2009 collection. Attached hereto as Exhibit A are true
and correct copies of photographs of Chanel t-shirts, tank tops, tank top-style blouses, and t-shirt
style dresses featuring the CC Monogram mark.
17. Chanels has presented the CC Monogram on products in various forms, including
with other imagery. By way of example only, Chanels Tete De Mort line of jewelry depicted
the CC Monogram mark affixed above crossed-bones. Attached hereto as Exhibit B are true and
correct images of the Tete De Mort jewelry line and other jewelry items that depict the CC
Monogram with other design elements.
18. Chanel owns numerous federal trademark registrations for the CC Monogram
mark in connection with a variety of goods and services. In connection with clothing alone,
Chanel owns, inter alia, U.S. Reg. No. 1,241,264 for suits, jackets, skirts, dresses, pants,
blouses, tunics, sweaters, cardigans, tee-shirts, coats, raincoats, scarves, shoes and boots in
International Class 25; U.S. Reg. No. 1,271,876 for clothing, namely coats, dresses, blouses,
raincoats, suits, skirts, cardigans, sweaters, pants, jackets, blazers and shoes in International
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Class 25; and U.S. Reg. No. 4,241,822 for clothing, namely coats, jackets, dresses, tops,
blouses, sweaters, cardigans, skirts, vests, pants, jeans, belts, swim wear, beach cover-ups, hats,
sun visors, scarves, shawls, ties, gloves, footwear, hosiery and socks in International Class 25.
19. The above-listed registrations are valid, subsisting, in full force and effect and
constitute prima facie evidence of the validity of the mark and of Chanels ownership and
exclusive right to use the mark in connection with the identified goods pursuant to 7(b) of the
Lanham Act, 15 U.S.C. 1057(b). Moreover, U.S. Reg. Nos. 1,241,264 and 1,271,876 are
incontestable pursuant to 15 of the Lanham Act, 15 U.S.C. 1065, and serve as conclusive
evidence of Chanels ownership of the marks and of its exclusive right to use the marks in
commerce in connection with all of the goods identified in the registrations. See 15 U.S.C.
1115(b). Attached hereto as Exhibit C are true and correct printouts from the U.S. Patent and
Trademark Office database reflecting these three registrations for the CC Monogram mark. As a
matter of law, these registrations serve to place Defendant on constructive notice of Chanels
rights in the CC Monogram mark. See 15 U.S.C. 1072.
20. Because of Chanels exclusive and extensive use of the CC Monogram mark, the
CC Monogram mark has acquired enormous value and has become famous among the
consuming public and trade as identifying and distinguishing Chanel exclusively and uniquely as
the source of products available under or bearing the mark. In fact, Courts and other tribunals
have repeatedly recognized the fame of the CC Monogram mark.
B. Defendants Unlawful Conduct
21. Upon information and belief, Defendant J eanine Heller d/b/a What About Yves
(Defendant) designs, distributes and sells clothing, including t-shirts and sweatshirts in
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interstate commerce. Defendant established her business in 2013. The focus of her clothing has
consistently been on high end luxury brands.
22. Upon information and belief, Defendant sells her clothing both to other retailers,
including but not limited to fashion retailer Kitson, through her own website operated at
http://www.whataboutyves.com, and through other third-party websites.
23. Upon information and belief, Defendant is displaying, offering for sale and selling
on her website, and selling to third-party retailers, a t-shirt and a sweatshirt bearing Chanels CC
Monogram mark with an image of the animated ghost commonly associated with the motion
picture Ghostbusters, owned by Paramount Pictures. Annexed hereto has Exhibit D is a true and
correct printout from Defendants website at http://www.whataboutyves.com showing the design,
which design also is shown here:

24. Defendant describes these clothing items as having a Ghostbusters x Chanel
design as shown in Exhibit E, a true and correct printout from Defendants Tumblr webpage at
http://what-about-yves.tumblr.com. Moreover, via Twitter, Defendant announced the sweatshirt
as the Official Chanel X Ghostbusters Sweatshirt Design Release, as shown in Exhibit F, a
true and correct of a Tweet by Defendant.

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25. Upon information and belief, Defendant is not making any comment about the CC
Monogram used in the Infringing Logo, nor is she transforming the mark. Rather, she has
applied the clearly recognizable CC Monogram mark to her own clothing precisely because of
the iconic status of the mark, with knowledge of its association with Chanel, in order to call to
mind Chanel. Indeed, the fact that Defendants description of her products bearing the CC
Monogram specifically refers to Chanel evidences her knowledge of the unique association of
the CC Monogram with Plaintiff.
26. The primary designation of source on the clothing items shown and referenced in
Paragraph 23 is Chanels CC Monogram mark. The ghost design element that has been added
to Chanels CC Monogram mark does not and cannot differentiate the mark Defendant is using
for its clothing from the registered CC Monogram mark used by Chanel for its goods, and on
information and belief, Defendants intent is to trade on this association.
27. Further, because the ghost design depicted in the Infringing Logo is a design
element of a federally registered trademark of Paramount Pictures, consumers likely will assume
that the shirt represents a joint promotion of Chanel and Paramount Pictures. Defendants
statement that the design is the official release only furthers that misimpression.
28. Defendant is not associated or affiliated with Chanel and has never been
authorized or otherwise licensed to use the Infringing Logo, the CC Monogram mark or any
other confusingly similar variation of the CC Monogram in connection with the sale or offering
for sale of any goods.
29. Defendants use of the Infringing Logo, which incorporates the CC Monogram in
its entirety, is with full knowledge of Chanels exclusive rights to the CC Monogram mark, with
knowledge of the iconic status of the CC Monogram mark, with knowledge that the CC
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Monogram mark is associated exclusively with products of Chanel, and with the full and
knowing intent of trading on Chanels rights in the CC Monogram mark. Indeed, Defendants
obvious knowledge of Chanels rights in the CC Monogram mark is evidenced by the fact that
Defendant refers to its Infringing Logo by reference to Chanel.
30. As a matter of law, Defendant was on constructive notice of Chanels rights in the
CC Monogram mark based on Chanels registrations therefore. Defendant was also on actual
notice of Chanels rights to and interest in the CC Monogram mark and of the worldwide fame of
that mark prior to her use of that mark. Indeed, Defendant chose to use the CC Monogram mark
in connection with clothing because of the very fame of that mark and her knowledge that
consumers desire goods bearing Chanels CC Monogram mark.
31. Defendants unauthorized use of the CC Monogram mark in her Infringing Logo
on clothing is with a deliberate intent to ride on the fame and goodwill of Chanels CC
Monogram mark and with the deliberate intent to create a false impression as to the source or
sponsorship of Defendants goods or to otherwise compete unfairly with Chanel. The goodwill
that Chanel has built up in its brand through years of substantial investment and effort is put at
risk by virtue of Defendants appropriation of the CC Monogram mark to sell and advertise her
own products.
32. Defendants use of the CC Monogram mark in the Infringing Logo is not for
purposes of parody. Defendant is not using the CC Monogram mark to make a statement about
Chanel or its products, but rather is simply exploiting the commercial value of the CC
Monogram mark for her commercial benefit and to otherwise trade on Chanels reputation.
Rather than being transformative, Defendants use is entirely exploitive.
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33. As a result of Defendants use of the CC Monogram mark or confusingly similar
variations thereof, Chanel is being irreparably harmed by the existence and sale of Defendants
products.
34. Defendants acts are likely to injure Chanels goodwill and reputation. The use
by Defendant of Chanels CC Monogram in the Infringing Logo mark unfairly and unlawfully
wrests from Chanel control over its valuable trademark and reputation. Consumers will assume
that Chanel intended to associate its brand with the Ghostbusters motion picture, which is not the
case. Chanel has no control over the quality of Defendants products which are, upon
information and belief, inferior to the products Chanel sells under its CC Monogram mark. As a
result, Chanels extremely valuable reputation is put in jeopardy and may be permanently
damaged.
35. Defendants conduct has caused and, unless enjoined by this Court, will continue
to cause irreparable injury to Chanel. Chanel has no adequate remedy at law.
FIRST CLAIM FOR RELIEF:
TRADEMARK INFRINGEMENT (15 U.S.C. 1114(1))

36. Chanel repeats and realleges each of the allegations set forth in paragraphs 1
through 35 above as if fully set forth herein.
37. Defendants unauthorized use of the Infringing Logo, which consists primarily of
the CC Monogram mark in its entirety, for goods identical or related to those provided by Chanel
is likely to cause confusion, or to cause mistake or to deceive Defendants customers, potential
consumers, and/or the public as to the source or sponsorship of Defendants goods. Consumers
are likely to be misled into believing that Defendants products are manufactured by, licensed by,
sponsored by, approved by or otherwise associated with Chanel.
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38. Upon information and belief, Defendant was on both actual and constructive
notice of Chanels exclusive rights in the registered CC Monogram mark prior to her own use of
the CC Monogram mark in the Infringing Logo. Defendants use of Chanels CC Monogram
trademark in the Infringing Logo is willful, in bad faith, and with full knowledge of the goodwill
and reputation associated with the CC Monogram mark, and with full knowledge that Defendant
has no right, license or authority to use the CC Monogram or any other mark confusingly similar
thereto.
39. Defendants acts are intended to reap the benefit of the goodwill that Chanel has
created in its CC Monogram trademark and constitutes infringement of Chanels federally-
registered trademark in violation of Section 32(1) of the Lanham Act, 15 U.S.C. 1114(1).
40. Defendants conduct has caused and is causing immediate and irreparable injury
to Chanel and, unless enjoined by this Court, will continue to both damage Chanel and deceive
the public. Chanel has no adequate remedy at law.
SECOND CLAIM FOR RELIEF:
FEDERAL UNFAIR COMPETITION (15 U.S.C. 1125(a))

41. Chanel repeats and realleges paragraphs 1 through 40 above as if fully set forth
herein.
42. Defendants use of Chanels CC Monogram mark in the Infringing Logo
constitutes a false designation of origin and a false representation with respect to the origin of
Defendants goods. Defendants use of Chanels CC Monogram mark is likely to cause
confusion, mistake, or deception as to the source of Defendants goods and is likely to create the
false impression that Defendant is affiliated with Chanel or that her goods are authorized,
sponsored, endorsed, licensed by, or affiliated with Chanel.
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43. Defendants actions constitute unfair competition in violation of Section 43(a) of
the Lanham Act, 15 U.S.C. 1125(a).
44. Defendants use of the CC Monogram mark in the Infringing Logo in connection
with her own clothing destroys the value, exclusivity and reputation of the CC Monogram mark.
45. Defendants conduct has caused and is causing immediate and irreparable injury
to Chanel and will continue both to damage Chanel and to deceive the public unless enjoined by
this Court. Chanel has no adequate remedy at law.
THIRD CLAIM FOR RELIEF:
FEDERAL TRADEMARK DILUTION (15 U.S.C. 1125(c))
46. Chanel repeats and realleges paragraphs 1 through 45 above as if fully set forth
herein.
47. As a result of extensive use and promotion of the CC Monogram mark and the
goods offered thereunder by Chanel for decades, the CC Monogram mark is famous throughout
the United States, is highly distinctive of Chanels goods and is widely recognized among the
consuming public as a designation of source of Chanels goods. The CC Monogram mark
became famous long before Defendant commenced her unauthorized use of the CC Monogram
mark as described herein.
48. Defendants commercial use of the CC Monogram mark in connection with the
sale of clothing is diluting Chanels famous CC Monogram mark by impairing the
distinctiveness of the CC Monogram mark, thereby lessening the capacity of that mark to
identify and distinguish Chanel exclusively.
49. Defendants commercial use of the CC Monogram mark in connection with the
sale of clothing is diluting Chanels famous CC Monogram mark by harming the reputation of
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the CC Monogram markassociating it with what Defendants inferior productsthereby
damaging the good reputation of Chanel and its CC Monogram mark.
50. Upon information and belief, the foregoing acts were done willfully and
deliberately, commencing long after Chanels CC Monogram mark became famous, and with an
intent to reap the benefit of Chanels goodwill and dilute the distinctiveness of and tarnish
Chanels CC Monogram mark in violation of Section 43(c) of the Lanham Act, 15 U.S.C.
1125(c).
51. Defendants conduct has caused and is causing immediate and irreparable injury
to Chanel and will continue to damage Chanel unless enjoined by this Court. Chanel has no
adequate remedy at law.
FOURTH CLAIM FOR RELIEF:
TRADEMARK INFRINGEMENT AND
UNFAIR COMPETITION UNDER NEW YORK COMMON LAW

52. Chanel repeats and realleges paragraphs 1 through 49 above as if fully set forth
herein.
53. Defendant has used the CC Monogram mark in the Infringing Logo with full
knowledge of Chanels prior rights in the CC Monogram mark and of the fame and success of
Chanels products sold under and bearing that designation. Defendants use of Chanels mark is
for the willful and calculated purpose of misappropriating and trading on Chanels goodwill and
business reputation. Furthermore, Defendant has used Chanels mark for the willful and
calculated purpose of causing confusion and mistake among the public and of deceiving the
public as to the nature and origin of Defendants products in violation of Chanels rights under
the common law of the state of New York.
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54. Upon information and belief, Defendant was on notice of Chanels exclusive
rights in the CC Monogram mark before adopting the confusingly similar Infringing Logo by
virtue of Chanels open sale and use of the CC Monogram mark and by virtue of Chanels
numerous federal trademark registrations for the mark. As a result, Defendants adoption of a
confusingly similar mark to the CC Monogram mark is willful, in bad faith and with full
knowledge of Chanels prior use of, exclusive rights in and ownership of the CC Monogram
mark, and with full knowledge of the reputation and goodwill associated with that mark. By
using Chanels CC Monogram mark without authorization, Defendant has been unjustly enriched
and Chanel has been damaged.
55. The aforesaid conduct of Defendant constitutes unfair competition and trademark
infringement under the common law of the State of New York.
56. Defendants conduct has caused and is causing immediate and irreparable injury
to Chanel and will continue to both damage Chanel and to deceive the public unless enjoined by
this Court. Chanel has no adequate remedy at law.
FIFTH CLAIM FOR RELIEF:
VIOLATION OF THE NEW YORK DECEPTIVE AND
UNFAIR TRADE PRACTICES ACT (N.Y. General Business Law 349)
57. Chanel repeats and realleges paragraphs 1 through 56 above as if fully set forth
herein.
58. Defendants unauthorized use of the CC Monogram mark in the Infringing Logo
has the capacity to deceive and is deceiving the public as to the source or sponsorship of
Defendants goods. As a result, the public will be damaged.
59. Defendants conduct is willful and in knowing disregard of Chanels rights.
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60. Defendant has been and is engaged in deceptive acts or practices in the conduct of
a business, trade or commerce in violation of Section 349 of the New York General Business
Law.
61. Defendants conduct has caused and is causing immediate and irreparable injury
to Chanel and will continue to both damage Chanel and to deceive the public unless enjoined by
this Court. Chanel has no adequate remedy at law.
SIXTH CLAIM FOR RELIEF:
TRADEMARK DILUTION UNDER NEW YORK LAW
(N.Y. General Business Law 360-l)

62. Chanel repeats and realleges paragraphs 1 through 61 above as if fully set forth
herein.
63. As a result of extensive use and promotion of the CC Monogram mark and the
goods offered thereunder by Chanel for decades, the CC Monogram mark is famous throughout
the United States, is highly distinctive of Chanels goods and is widely recognized among the
consuming public as a designation of source of Chanels goods. The CC Monogram mark
became famous long before Defendant commenced her unauthorized use of the CC Monogram
mark as described herein.
64. Defendants unauthorized use the CC Monogram mark is diluting and is likely to
continue diluting such mark by blurring the distinctiveness thereof and by tarnishment, and is
likely to injure Chanels business reputation in that it has removed Chanels reputation from its
own control and that deficiencies in or complaints about Defendants goods will redound to the
harm of Chanel, all in violation of Section 360-l of the General Business Law of the State of
New York.
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65. Defendants conduct has caused and is causing immediate and irreparable injury
to Chanel and will continue to both damage Chanel and to deceive the public unless enjoined by
this Court. Chanel has no adequate remedy at law.
* * *
WHEREFORE, Plaintiff Chanel, Inc. respectfully demands judgment as follows:
1) That a permanent injunction be issued enjoining Defendant, any partners,
employees or agents of Defendant, and any entity, company or business owned or controlled by
Defendant, as well as the officers, agents, privies, shareholders, principals, directors, licensees,
attorneys, servants, employees, affiliates, subsidiaries, successors and assigns of any such entity,
company or business, and all those persons in concert or participation with any of them, from:
(a) using the CC Monogram mark, or any simulation, reproduction, copy, colorable
imitation or confusingly similar variation of Chanels CC Monogram mark in or
as part of a design, logo, or trademark or using such a mark in or on any product,
including but not limited to the Infringing Logo, or otherwise using such a mark
in connection with the importation, promotion, advertisement, sale, offering for
sale, manufacture, production or distribution of any business, product or service;
(b) processing, packaging or transporting any product bearing the CC Monogram
mark, or any mark that is a simulation, reproduction, copy, colorable imitation or
confusingly similar variation of the CC Monogram mark, including but not
limited to the Infringing Logo;
(c) selling, offering, distributing, disseminating or otherwise providing any
product that bears the CC Monogram mark or any mark that is a simulation,
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reproduction, copy, colorable imitation or confusingly similar variation of the
CC Monogram mark, including but not limited to the Infringing Logo;
(d) using any false designation of origin or false description (including, without
limitation, any letters or symbols), or performing any act, which can, or is
likely to, lead members of the trade or public to believe that Defendant is
associated with Chanel or that any product imported, manufactured,
distributed, or sold by Defendant is in any manner associated or connected
with Chanel, or is authorized, licensed, sponsored or otherwise approved by
Chanel;
(e) engaging in any other activity constituting unfair competition with Chanel,
constituting an infringement of the CC Monogram mark, or diluting the CC
Monogram mark;
(f) applying to register or registering in the United States Patent and Trademark
Office, in any state trademark registry, or in the United States Copyright
Office any mark or design consisting in whole or in part of the CC Monogram
mark, including but not limited to the Infringing Logo, or consisting in whole
or in part of any simulation, reproduction, copy, colorable imitation or
confusingly similar variation of the CC Monogram mark or otherwise taking
any other action designed to give Defendant any claim of rights in or to the
CC Monogram mark;
(g) transferring, consigning, selling, shipping or otherwise moving any goods,
packaging or other materials in Defendants possession, custody or control
bearing the CC Monogram mark or any mark that is a simulation, reproduction,
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copy, colorable imitation or confusingly similar variation of the CC Monogram
mark, including but not limited to the Infringing Logo;
(h) disposing, destroying, altering, moving, removing, concealing, tampering with or
in any manner secreting any business records, including computer records of any
kind, including invoices, correspondence, books of accounts, receipts or other
documentation relating or referring in any manner to the manufacture,
advertising, receiving, acquisition, importation, promotion, display, purchase,
sale, offer for sale or distribution of any merchandise bearing the CC Monogram
mark or any mark that is a simulation, reproduction, copy, colorable imitation or
confusingly similar variation of the CC Monogram mark; and
(i) assisting, aiding or abetting any other person or business entity in engaging in
or performing any of the activities referred to in subparagraphs (a) through (h)
above.
2) Directing that Defendant deliver up to Chanels attorneys for destruction all
goods, labels, tags, signs, stationery, prints, packages, promotional and marketing materials,
advertisements and other materials (a) currently in her possession or under her control or (b)
recalled by Defendant pursuant to any order of the Court or otherwise, incorporating, featuring or
bearing the CC Monogram mark or that incorporate, feature or bear any simulation,
reproduction, copy, colorable imitation or confusingly similar variation of the CC Monogram
mark, including but not limited to the Infringing Logo, and all plates, molds, matrices and other
means of making the same.
3) Directing such other relief as the Court may deem appropriate to prevent the
public from deriving the erroneous impression that any product manufactured, sold or otherwise
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circulated or promoted by Defendant within the United States is authorized by Chanel or related
in any way to Chanel or that Defendant is otherwise affiliated with Chanel.
4) Directing that Defendant file with the Court and serve upon Chanels counsel
within thirty (30) days after entry of judgment a report in writing under oath, setting forth in
detail the manner and form in which she has complied with the above.
5) Awarding Chanel such damages it has sustained or will sustain by reason of
Defendants acts of trademark infringement, trademark dilution and unfair competition.
6) Awarding Chanel all gains, profits, property and advantages derived by Defendant
from her unlawful conduct and, pursuant to 15 U.S.C. 1117, awarding Chanel an amount up to
three times the amount of actual damages sustained as a result of Defendants violation of the
Lanham Act.
7) Awarding to Chanel exemplary and punitive damages to deter any further willful
infringement as the Court finds appropriate.
8) Awarding to Chanel its costs and disbursements incurred in this action, including
reasonable attorneys fees pursuant to 15 U.S.C. 1117(a).
9) Awarding to Chanel interest, including pre-judgment interest on the foregoing
sums.

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