Case3:15-cv-02751-HRL Document1 Filed06/18/15 Page1 of 13

1 SPENCER HOSIE (CA Bar No. 101777)

shosie@hosielaw.com
2 DIANE S. RICE (CA Bar No. 118303)
drice@hosielaw.com
3 ANTHONY K. LEE (CA Bar No. 156018)
alee@hosielaw.com
4 DARRELL R. ATKINSON (CA Bar No. 280564)
datkinson@hosielaw.com
5
HOSIE RICE LLP
th
6 600 Montgomery Street, 34 Floor
San Francisco, CA 94111
7 (415) 247-6000 Tel.
(415) 247-6001 Fax
8
Attorneys for Plaintiff
9
GLOBAL ALLIES, LLC
10
11
12

UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF CALIFORNIA

13
14 GLOBAL ALLIES, LLC,
15

Case No. ___________________

Plaintiff,

16 v.
17 JL FURNISHINGS LLC; JL FURNISHINGS
EAST LLC; and LONE MEADOW, LLC
18
Defendants.
19

ORIGINAL COMPLAINT AND

DEMAND FOR JURY TRIAL

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ORIGINAL COMPLAINT AND JURY DEMAND

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Plaintiff Global Allies, LLC (Global Allies or Plaintiff) hereby files its complaint

2 against defendant JL Furnishings LLC (JLF), JL Furnishings East LLC (JLF East), and
3 Lone Meadow, LLC (Lone Meadow) (collectively Defendants) for patent infringement.
4 For its complaint, Plaintiff alleges on personal knowledge as to its own acts and on
5

information and belief as to all other matters, as follows:

PARTIES

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8
9
10

1.

Global Allies is a limited liability company organized under the laws of the

State of California, with its principal place of business in Lockeford, California.

2.

JLF is a limited liability company organized under the laws of the State of

11 California, with its principal place of business in Los Angeles County, California.
12
13

3.

JLF East is a limited liability company organized under the laws of the State

of California, with its principal place of business in Los Angeles County, California. JLF

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East is registered to do business in North Carolina and has a place of business there.

15
16

4.

Lone Meadow is a limited liability company organized under the laws of the

17 State of California, with its principal place of business in Los Angeles County, California.
JURISDICTION AND VENUE

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19

5.

This complaint asserts a cause of action for patent infringement under the

20 Patent Act, 35 U.S.C. 271. This Court has subject matter jurisdiction over this matter by
21
virtue of 28 U.S.C. 1331 and 28 U.S.C. 1338(a).
22
6.
This Court has personal jurisdiction over JLF, because JLF is incorporated in
23
California, has a place of business in California, has an agent for service of process in
24
25 California, and provides products and services in California.
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ORIGINAL COMPLAINT AND JURY DEMAND

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7.

This Court has personal jurisdiction over JLF East, because JLF East is

2 incorporated in California, has a place of business in California, has an agent for service of
3 process in California, and provides products and services in California.
4
5
6

8.

This Court has personal jurisdiction over Lone Meadow, because Lone

Meadow is incorporated in California, has a place of business in California, has an agent for
service of process in California, and provides products and services in California.

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9.

8
9

Venue is proper in this Court by virtue of 28 U.S.C. 1391(c) and (d) and 35

U.S.C. 289, in that: Defendants do substantial and regular business in this district such that

10 Defendants reside here; Defendants may be found in this district and have committed acts of
11 infringement in this district; Defendants have introduced infringing products into the stream
12 of commerce with the expectation that they will be purchased and used in this district; and
13

this Court has jurisdiction over all the parties.

14
10.

The website www.jlfurnishings.com offered/exposed for sale the infringing

15
16

product. See I, B below. The website makes use of multiple business names. For

17 example, the website makes reference to JLF/lone meadow (aka JL Furnishings), JLF
18 Lone Meadow LLC, JL Furnishings, Lone Meadow LLC, and JLF Collections. All
19 three defendants use, operate and/or own the website www.jlfurnishings.com. The website
20 lists both addresses in California and North Carolina.
21
INTRADISTRICT ASSIGNMENT
22
11.
Pursuant to Civil LR 3-2(c), this case should be subject to district-wide
23
assignment because it is an Intellectual Property Action.
24
25 I.

STATEMENT OF FACTS.

26

A.

The Plaintiff Global Allies and Its Patented Task Chairs.

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ORIGINAL COMPLAINT AND JURY DEMAND

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Case3:15-cv-02751-HRL Document1 Filed06/18/15 Page4 of 13

12.

Plaintiff Global Allies is an innovative company that specializes in supplying

2 high-end, strikingly designed furniture to the hospitality (hotel) market, as described below.
3

13.

Over the past decade, Global Allies has invested significantly in product

4 research, design, and development to yield novel, market-defining designs. It owns a number
5
6

of important design patents, including the patent asserted here.

14.

There are several important hospitality design shows held annually in the

7
8
9

domestic United States. These shows bring vendors and customers together, and give buyers
the opportunity to consider and review competing product lines. The three principal

10 hospitality design shows held annually are the Hospitality Design Show in Las Vegas, the
11 BDNY show in New York, and the BD West show in Southern California.
12
13

15.

A corporate hotel owner may have various brands. These brands are

frequently referred to as flags. For example, Hilton Hotels has a brand/flag in Hilton, and

14
a separate brand/flag in Doubletree. The major domestic hotel corporations typically have

15
16

what is referred to as a brand standard for their various brands. For example, a particular

17 vendors furniture product selected and endorsed by the hotel corporation for use in
18 properties bearing a particular flag. The selection of a particular vendor and product as being
19 included in a hotel chains brand standard matters: it is a striking endorsement of quality and
20 novelty, and reflects the hotel buyers conviction that that vendors furnishings will support
21
and enhance the hotel brand.
22
16.
Even absent selecting and publishing brand standards, hotel corporations
23
frequently recommend particular vendors products for flagged hotels.
24
25

17.

Given its innovative and patented designs, and the underlying quality of its

26 products, Global Allies has met with considerable success in becoming part of the brand
27 standard for major domestic and international hotel chains. Global Allies task chairs, the
28
ORIGINAL COMPLAINT AND JURY DEMAND

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Case3:15-cv-02751-HRL Document1 Filed06/18/15 Page5 of 13

product at issue here, are part of the brand standard for several major domestic hotel chains.

2 For example, Hilton Hotels has numerous brands which identify Global Allies and its
3 products as constituting part of the brand standard, including the Hilton, Doubletree, and
4 Embassy Suites flagged hotels. To illustrate further, Starwood Hotels is and has been a
5
6

significant Global Allies customer, and Starwood identifies Global Allies task chairs as part
of the Starwood Brand Standards program, including for such top tier hotels as the Sheraton,

7
8
9

and Four Points by Sheraton, Aloft, and further recommended for their St Regis, Le
Meridian, Westin and W Hotels to name a few. In addition, Global Allies patented task

10 chairs are also recommended for use by other hotel corporations for their flagged properties.
11

18.

Global Allies success in the hospitality market reflects, in significant part,

12 their products innovative design, a design that distinguishes and separates the Global Allies
13

task chairs from competitive chairs in the hospitality industry.

14
19.

One such innovative design is reflected in U.S. Design Patent No. D622,987,

15
16

filed April 8, 2010 and issued September 7, 2010 (the 987 Patent). This patent is attached

17 hereto as Exhibit A. Global Allies refers to this design and task chair as the Coronado Task
18 Chair (herein Coronado).
19

20.

Reproduced below is an exemplary figure describing the claimed Coronado

20 design:
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ORIGINAL COMPLAINT AND JURY DEMAND

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Case3:15-cv-02751-HRL Document1 Filed06/18/15 Page6 of 13

1
2
3
4
5
6
987 Patent, Fig. 1.

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8

21.

In 2013 Global Allies filed suit in this district for infringement of the 987

9 Patent against Charter Furniture Corp. and Lodging by Liberty, Inc., dba Charter Furniture.
10
11

The prior suit on the 987 Patent was styled Global Allies, LLC. v. Charter Furniture Corp.
and Lodging by Liberty, Inc., Case No. 5:13-cv-00651-EJD (N.D. Cal.). This prior suit was

12
13
14

settled with Charter Furniture Corp. and Lodging by Liberty, Inc., taking a license to the 987
Patent. Global Allies has also secured other cease and desist agreements from other

15 infringing parties.
16

B.

Defendants Knock Off the Coronado Task Chair.

17

22.

Defendants have either offered to sale or actually sold task chairs that infringe

18

Global Allies 987 Patent. Defendants infringing activities span the country and include

19
offering infringing products through their website, as illustrated, by example, below.

20
21

23.

Defendants were awarded a project to produce chairs for the yet to open

22 Westin Denver International Airport Hotel. In obtaining this project, Defendants submitted a
23 visually identical copy of the Coronado Task Chair. Defendants intend to complete this
24 project through the production, delivery, and installation of chairs that knockoff Global
25 Allies Coronado task chair.
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ORIGINAL COMPLAINT AND JURY DEMAND

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24.

In 2014, Defendants presented this knockoff chair at the BD West show and in

2 fact stated to the Hilton Brand manager that Defendants could supply them this chair and at a
3 lower price. At this trade show, the president of Global Allies saw the infringing chair, and
4 approached the C.E.O. of the Defendants various companies. Through its president, Global
5
6

Allies informed the Defendants C.E.O. that their chair infringed the Coronado patent, and
was a direct knockoff. Global Allies demanded that the Defendants cease and desist making,

7
8
9

selling, and offering to sell the chair. In this conversation, the Global Allies president told
the Defendants C.E.O. that the Coronado chair was a patented design. The Defendants

10 C.E.O. responded that the Defendants used different manufacturing mechanisms to make
11 their infringing chair, to which Global Allies responded that the means of construction were
12 immaterial, given that the Defendants was a replica of the patented Global Allies chair, and
13
14

so infringed the design patent. The chair design Defendants submitted is visually identical to
Global Allies patented design.

15
16

25.

In 2015, Plaintiff learned that Defendants had produced, shipped and installed

17 chairs that apply Global Allies Coronado patented design at the Onyx Hotel Boston (a
18 Kimpton Hotel). Reproduced below are three images showing the knockoff chair installed at
19 the Onyx Hotel Boston. The last of the images shows a label affixed to the underside of the
20 chair that clearly identifies Defendants as the manufacturer.
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ORIGINAL COMPLAINT AND JURY DEMAND

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Case3:15-cv-02751-HRL Document1 Filed06/18/15 Page8 of 13

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26.

Plaintiff also learned, in 2015, that Defendants were offering a knockoff that

15 applied Global Allies Coronado patented design on their website. An image of the website
16 page offering the knockoff chair is attached hereto as Exhibit B and incorporated herein by
17
18

reference.
27.

In every instance Defendants knockoff chairs are essentially indistinguishable

19
20
21
22

from the patented Coronado chair, such that an ordinary observer would confuse the two
visually.
C.

Defendants Refuse to Cease and Desist From Knocking Off the

Coronado Task Chair.

28.

Plaintiff tried to resolve the issue of Defendants infringing activity short of

23
24

25 litigation.
26

29.

On March 13, 2015 Global Allies counsel sent Defendants founder and

27 President, Jeffery Lazar, a cease and desist letter. The March 13, 2015 letter enclosed both
28
ORIGINAL COMPLAINT AND JURY DEMAND

Case No. __________________

Case3:15-cv-02751-HRL Document1 Filed06/18/15 Page9 of 13

am image of Defendants website with the infringing offering and a copy of the 987 Patent,

2 and both it and a follow-up April 2, 2015 letter requested that Defendants confirm their
3 cessation of all infringing activity.
4
5
6

30.

Mr. Lazar responded in writing on May 26, 2015. While Mr. Lazar claimed

that JLF Collections does not copy Global Allies chairs, nor does [his] company have an
interest or intent to do so, and that [a]s a courtesy to [the Global Allies managing partners]

7
8
9

as friends he had the website image removed until he could investigate further, he
conspicuously failed to confirm that Defendants would cease and desist their infringing

10 activities.
11

31.

On May 26, 2015 Global Allies counsel sent Defendants a letter pointing out

12 Mr. Lazars omission and again asking that they confirm that they would cease and desist
13

from infringing activity.

14
32.

The next day, May 27, 2015, Mr. Lazar responded in writing with a reiteration

15
16

that JLF Collections does not copy Global Allies chairs, but without any commitment that

17 Defendants would cease and desist from infringing activity.

18

33.

The fact is that Defendants have offered for sale, sold, produced and

19 manufactured chairs that apply the design protected by Global Allies 987 Patent and intend
20 to continue to do so. Faced with Defendants infringing activities and the inability to secure a
21
cease and desist assurance from Defendants, Global Allies brought this suit.
22
COUNT I
23
PATENT INFRINGEMENT
24
(The 987 Patent)
25
34.
Global Allies incorporates and realleges, as though fully set forth herein, the
26
allegations contained in paragraphs 1-33 above.
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ORIGINAL COMPLAINT AND JURY DEMAND

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Case3:15-cv-02751-HRL Document1 Filed06/18/15 Page10 of 13

35.

On September 7, 2010, United States Patent No. D622,987 S (the 987

2 Patent) entitled Task Chair was duly and legally issued. A true and correct copy of the
3 987 Patent is attached as Exhibit A (and incorporated herein by reference).
4
5
6

36.

Isaac Kubryk is the inventor of the 987 Patent. The 987 Patent has been

assigned to Plaintiff. Plaintiff Global Allies is the sole legal and rightful owner of the 987
Patent.

7
37.

8
9

Defendants make, use, import, expose for sale, offer to sell, and/or sell

products that infringe the 987 Patent through applying the patented design and/or colorable

10 imitations thereof to articles of manufacture, as alleged above in paragraphs 22 through 27.

11 This conduct constitutes infringement under 35 U.S.C. 271(a).
12
13
14

38.

Defendants infringement of the 987 Patent is willful. Defendants were on

notice that their activities infringed Global Allies patented design since at least the 2014 BD
West show. Global Allies president informed Defendants C.E.O. that Defendants chair

15
16

was an infringing knockoff at the 2014 BD West show. Further, Defendants were provided

17 with a copy of the 987 Patent in March 2015 by Plaintiffs counsel. Yet, Defendants
18 continue to make, use, expose for sale, offer for sale and/or sell chairs that infringe the 987
19 Patent.
20
21

39.

As a result of the infringement by Defendants, Plaintiff has been damaged,

and will continue to be damaged, until Defendants are enjoined from further acts of

22
23
24

infringement.
40.

Defendants will continue to infringe unless enjoined by this Court. Plaintiff

25 faces real, substantial and irreparable damage and injury of a continuing nature from
26 infringement for which Plaintiff has no adequate remedy at law.
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ORIGINAL COMPLAINT AND JURY DEMAND

Case No. __________________

Case3:15-cv-02751-HRL Document1 Filed06/18/15 Page11 of 13

PRAYER FOR RELIEF

1
2

WHEREFORE, Plaintiff prays for entry of judgment:

A.

that the patent-in-suit is valid and enforceable;

B.

that Defendants have infringed the claim of the patent-in-suit;

C.

that Defendants infringement of the claim of the patent-in-suit was willful;

D.

that Defendants account for and pay to Plaintiff all damages caused by the

5
6
7
8
9
10

infringement of the patent-in-suit, which by statute can be Defendants total profits, but
which, also by statute, can be no less than reasonable royalties;
E.

that the damage to Plaintiff be increased by three times the amount found or

11 assessed pursuant to 35 U.S.C. 284 and that Defendants account for and pay to Plaintiff the
12 increased amount;
13

F.

that this Court issue a preliminary and final injunction enjoining Defendants,

14
their officers, agents, servants, employees and attorneys, and any other person in active

15
16

concert or participation with them, from continuing the acts herein complained of, and more

17 particularly, that Defendants and such other persons be permanently enjoined and restrained
18 from further infringing the 987 Patent;
19

G.

that Plaintiff be granted pre-judgment and post-judgment interest on the

20 damages caused to it by reason of Defendants infringement of the patent-in-suit;

21
H.
that this Court require Defendants to file with this Court, within thirty (30)
22
days after entry of final judgment, a written statement under oath setting forth in detail the
23
manner in which Defendants have complied with the injunction;
24
25

I.

that this be adjudged an exceptional case and the Plaintiff be awarded its

26 attorneys fees in this action pursuant to 35 U.S.C. 285;

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ORIGINAL COMPLAINT AND JURY DEMAND

10

Case No. __________________

Case3:15-cv-02751-HRL Document1 Filed06/18/15 Page12 of 13

J.

that this Court award Plaintiff its costs and disbursements in this civil action,

2 including reasonable attorneys fees; and

3

K.

that Plaintiff be granted such other and further relief as the Court may deem

4 just and proper under the current circumstances.

5
6

Dated: June 18, 2015

Respectfully submitted,

7
8
9
10
11
12
13
14
15
16
17
18

/s/ Spencer Hosie___________________________

SPENCER HOSIE (CA Bar No. 101777)
shosie@hosielaw.com
DIANE S. RICE (CA Bar No. 118303)
drice@hosielaw.com
ANTHONY K. LEE (CA Bar No. 156018)
alee@hosielaw.com
DARRELL R. ATKINSON (CA Bar No. 280564)
datkinson@hosielaw.com
HOSIE RICE LLP
Transamerica Pyramid
600 Montgomery Street, 34th Floor
San Francisco, CA 94111
(415) 247-6000 Tel.
(415) 247-6001 Fax
Attorneys for Plaintiff
GLOBAL ALLIES, LLC

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ORIGINAL COMPLAINT AND JURY DEMAND

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Case No. __________________

Case3:15-cv-02751-HRL Document1 Filed06/18/15 Page13 of 13

DEMAND FOR JURY TRIAL

1
2

Plaintiff, by its undersigned attorneys, demands a trial by jury on all issues so triable.

3 Dated: June 18, 2015

Respectfully submitted,

4
5
6
7
8
9
10
11
12

/s/ Spencer Hosie___________________________

SPENCER HOSIE (CA Bar No. 101777)
shosie@hosielaw.com
DIANE S. RICE (CA Bar No. 118303)
drice@hosielaw.com
ANTHONY K. LEE (CA Bar No. 156018)
alee@hosielaw.com
DARRELL R. ATKINSON (CA Bar No. 280564)
datkinson@hosielaw.com
HOSIE RICE LLP
Transamerica Pyramid
600 Montgomery Street, 34th Floor
San Francisco, CA 94111
(415) 247-6000 Tel.
(415) 247-6001 Fax

13
14

Attorneys for Plaintiff

GLOBAL ALLIES, LLC

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ORIGINAL COMPLAINT AND JURY DEMAND

12

Case No. __________________

Case3:15-cv-02751-HRL Document1-1 Filed06/18/15 Page1 of 7

EXHIBIT A

Case3:15-cv-02751-HRL Document1-1 Filed06/18/15 Page2 of 7

Illlll llllllll Ill lllll llllll llll lllll lllll 111111111111111111111111111111111

USOOD622987S

c12)

United States Design Patent

(10)

Kubryk

(45)

(54)

TASK CHAIR

(76)

Inventor:

Patent No.:
Date of Patent:

D493,642 S

US D622,987 S

**

Sep. 7, 2010

8/2004 Maran ......................... D6/500

* cited by examiner

Isaac Kubryk, 18251 Hwy. 88,

Lockeford, CA (US) 95237

Primary Examiner-Mimosa De
(74) Attorney, Agent, or Firm-Audrey A. Millemann;
Weintraub Genshlea Chedial

(**)

Term:

(21)

Appl. No.: 29/349,498

(57)

(22)

Filed:

The ornamental design for a task chair, as shown and

described.

(51)
(52)
(58)

LOC (9) Cl. .................................................. 06-01

U.S. Cl. ....................................................... D6/500
Field of Classification Search .......... D6/334-336,
D6/364, 365, 366, 367, 374, 375, 376, 379,
D6/380, 500-502, 601; 297/411.2, 411.28,
297/452.19, 452.26, 452.29, 452.32, 452.35,
297/452.48
See application file for complete search history.

14 Years

Apr. 8, 2010

(56)

DESCRIPTION
FIG. 1 is a perspective view of a task chair, looking toward the
right front corner, showing my new design;
FIG. 2 is a front view thereof;
FIG. 3 is a back view thereof;
FIG. 4 is a right side view thereof;
FIG. 5 is a top view thereof; and,

References Cited

FIG. 6 is a bottom view thereof.

U.S. PATENT DOCUMENTS

D328,395 S
D351,069 S
D370,805 S

*
*
*

CLAIM

The broken lines shown in the drawing are for illustrative

purposes only and form no part of the claimed design.

8/1992 Neuser ........................ D6/366

10/1994 Orlandini et al. ............. D6/366
6/1996 McDiarmid .................. D6/502

. .. ..

1 Claim, 5 Drawing Sheets

.....

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Case3:15-cv-02751-HRL Document1-1 Filed06/18/15 Page3 of 7

U.S. Patent

Sep.7,2010

Sheet 1of5

VS D622,987 S

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Case3:15-cv-02751-HRL Document1-1 Filed06/18/15 Page4 of 7

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Sheet 2 of 5

Sep.7,2010

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U.S. Patent

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Sheet 3 of 5

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Case3:15-cv-02751-HRL Document1-1 Filed06/18/15 Page6 of 7

U.S. Patent

Sep.7,2010

Sheet 4 of 5

US D622,987 S

FIG. 4

Case3:15-cv-02751-HRL Document1-1 Filed06/18/15 Page7 of 7

U.S. Patent

US D622,987 S

Sheet 5 of 5

Sep.7,2010

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Case3:15-cv-02751-HRL Document1-2 Filed06/18/15 Page1 of 2

Exhibit B

12-40279SP - JL Furniture

Case3:15-cv-02751-HRL Document1-2 Filed06/18/15 Page2 of 2

Page 1of1

AmPficon Made
world RenoNned

12-40279SP : Desk Chairs

Dimensions US

Downloads

W 19.75" x D 23.25" x H 24-28"

View Hi-Res Color Image

SH: 17-21"

View Hi-Res B&W Image

SD: 19"
Dimensions Metric

CREATE A CHAR.RETTE

W 501.65mm x D 590.55mm x H 609.6-711.2mm

SH: 431.8-533.4mm

~.OD

TO EXISTING CHARRETTE

SD: 482.6mm

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Copyright 2015 JLF Lone Meadow LLC

http://www.jlfurnishings.com/furniture/1620

3/13/2015

Case3:15-cv-02751-HRL Document1-3 Filed06/18/15 Page1 of 1

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Spencer Hosie, Anthony K. Lee, Darrell R. Atkinson, Diane S. Rice
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06/18/2015

/s/ Spencer Hosie

Spencer Hosie, Attorneys for Plaintiff

IX. DIVISIONAL ASSIGNMENT (Civil L.R. 3-2)

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