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LINK SNACKS, INC.,



v.

JOHN DOES 1-100










Plaintiff,

Defendants.





Court File No. ____________________




COMPLAINT



(Jury Trial Demanded)




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CASE 0:13-cv-00604-JNE-JSM Document 1 Filed 03/15/13 Page 1 of 17

IN THE UNITED STATES DISTRICT COURT

DISTRICT OF MINNESOTA

Plaintiff Link Snacks, Inc. (“Link Snacks”) for its Complaint against Defendants John

Does 1-100, individuals and/or entities selling products via the website www.ebay.com, states:

THE PARTIES

1.

Link Snacks is a corporation in good standing organized under the laws of the

State of Wisconsin, having its principal place of business at 1 Snack Food Lane, Minong,

Wisconsin 54859 and marketing operations at 110 North 5th Street, Suite 700, Minneapolis,

Minnesota 55403-1631. Link Snacks is a multinational manufacturer and marketer of a wide

variety of snack products, including beef jerky products. Link Snacks sells its beef jerky under

the JACK LINK’S brand. The JACK LINK’S brand is among the best known and most trusted

brands in the beef jerky snack food market.

2.

Defendants are persons, companies, or entities doing business in Minnesota and

elsewhere listing and/or selling unofficial coupons via www.ebay.com. The coupons incorporate

Link Snacks’ JACK LINK’S trademarks. Defendants were not and are not authorized to use

Link Snacks’ trademark or to sell the unauthorized coupons.

CASE 0:13-cv-00604-JNE-JSM Document 1 Filed 03/15/13 Page 2 of 17

3.

The Defendants are assigned a user name by www.ebay.com when offering

products via that website. Some of the Defendants go by the user names treynolds8484,

nicole1249, jtown995, jazzzyjess, riversidez, vintagepostcardshop, amandaityybitty2006,

one2own, 2extreme2pay, kbli2841, kuponkweenmom, 4hzkare, kimmyadams2011, danielretired,

bulllsrus, misst1955, kingislandz, fireman582wp, windstreamz, billhowell2424, jaynewebb,

jimmyz9988, abu_101, pcox1225, hauser0_60, couponsaves2013, texasjimbob,

mogooddeals4less, fishing-101, mrud1x, 1960annieoliver, savesmoney2, eagerbecorp,

jeff111*jeff, ilovebabyv, sue6230, volturenpal, oterryoliver, mhoadley0414, capone33006,

wonny-sports, anrooks2012, supper3, kendrakendra4, njeasylife01, and mhoadley0414. Listings

from other Defendants were not available based on the removal by eBay. Link Snacks will

supplement that information once it becomes available.

4.

The identity and domiciles of the Defendants are presently unknown to Link

Snacks because the Defendants do not list their real names or full contact information on eBay.

Once the identities and contact information of these Defendants is known to Link Snacks, this

Complaint will be amended to name them and their locations.

5.

All of the Defendants are doing business in interstate commerce over the Internet,

are accepting payments online and are either involved in offering to sell infringing products to

Minnesota residents, selling infringing products to Minnesota residents, or are shipping

infringing products to Minnesota residents. Information via eBay shows at least some of

Defendants list Minnesota as their location. All of the Defendants have availed themselves of

the privilege of regularly transacting business with Minnesota residents, businesses and

individuals.

6.

Based on the similarity of the coupons at issue, Defendants have likely engaged in

joint conduct amounting to an interstate scheme to infringe on Link Snacks’ trademarks.

 

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CASE 0:13-cv-00604-JNE-JSM Document 1 Filed 03/15/13 Page 3 of 17

THE NATURE OF THE ACTION

7.

This is an action for trademark infringement, unfair competition and

counterfeiting under the Lanham Act, 15 U.S.C. 1051 et seq.; deceptive trade practices arising

under the Minnesota Deceptive Trade Practices Act, Minn. Stat. § 325D.44 et seq., unlawful

trade practices under the Minnesota Unlawful Trade Practices Act, Minn. Stat. § 325D.09 et seq.,

and common law trademark infringement and unfair competition.

JURISDICTION AND VENUE

8.

This Court has original jurisdiction over the federal claims pursuant to 15 U.S.C.

§ 1121 and 28 U.S.C. §§ 1331, 1338(a) and (b). It has subject matter jurisdiction over the

supplemental state claims pursuant to 28 U.S.C. § 1367(a) and 28 U.S.C. § 1332. The parties are

citizens of different states and the value of the interests Link Snacks seeks to protect exceeds the

sum of $75,000, exclusive of interests and costs.

9.

The Court has personal jurisdiction over Defendants under Minn. Stat. § 543.19

because, on information and belief, Defendants either reside in this district or conduct business in

this district through www.ebay.com. Through that Internet website, Defendants offer to sell,

sell, and market the products accused of infringing. The conduct of the Defendants causes harm

and injury to Link Snacks in Minnesota and elsewhere.

10.

Venue is proper in this District pursuant to 28 U.S.C. § 1391(b).



LINK SNACKS’ TRADEMARKS

11.

Link Snacks manufactures and sells snack products, including beef jerky

products. Link Snacks sells its beef jerky products under the name JACK LINK’S.

12.

Since at least as early as May of 1985, Link Snacks has sold meat snacks under

the JACK LINK’S brand. The JACK LINK’S brand is exceedingly strong and famous. The

 

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CASE 0:13-cv-00604-JNE-JSM Document 1 Filed 03/15/13 Page 4 of 17

United States Patent and Trademark Office issued Registration No. 2,147,622 for use of JACK

LINK’S on meat snacks on March 31, 1998. Ex. A. The registration is incontestable.

13.

Since at least as early as May of 2005, Link Snacks has sold meat snacks under

the stylized logo:



The United States Patent and Trademark Office issued Registration No. 3,123,509 for use of the

stylized JACK LINK’S mark on meat snacks on August 1, 2006. Ex. B. This registration is

incontestable.

14.

Link Snacks has also sold various meat snack products under derivatives of its

JACK LINK’S and stylized JACK LINK’S trademarks. Those marks include JACK LINK’S

SNACK FOODS (Reg. No. 1,910,274 for meat snacks); JACK LINK’S PICKLED PETE (Reg.

No. 1,872,666 for meat snacks, pickled eggs and pickles); JACK LINK’S SMOKEHOUSE (Reg.

No. 3,609,589 for meat snacks); JACK LINK’S CLASSICS (Reg. No. 3,963,166 for meat

snacks); JACK LINK (Reg. No. 3,257,182 for meat snacks); JACK LINK’S PREMIUM CUTS

(Reg. No. 3,276,640 for meat snacks); and JACK LINK FAMILY QUALITY GUARANTEE

SINCE 1885 and design (Reg. No. 3,287,149 for meat snacks). Registrations of those marks,

some of which are incontestable, are attached as Exhibit C.

15.

The Link Snacks trademarks described in paragraphs 11-14 are collectively

referred to as the “JACK LINK’S Marks.”



 

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CASE 0:13-cv-00604-JNE-JSM Document 1 Filed 03/15/13 Page 5 of 17

16.

Link Snacks has carefully nurtured the goodwill associated with the JACK

LINK SNACKS’ BUSINESS



LINK’S Marks. Link Snacks has invested significantly in promoting these trademarks and in

assuring that the trademarks are associated with high quality products. Through Link Snacks’

extensive efforts, the JACK LINK’S brand and the stylized JACK LINK’S logo marks have

come to represent high quality meat snacks. The JACK LINK’S Marks are among the best

known in the meat snack field and are extremely valuable.

17.

Link Snacks has used the JACK LINK’S Marks in advertising, on the Internet, in

print and other promotional materials and on packaging associated with meat snacks. Link

Snacks’ extensive use and promotion of the JACK LINK’S Marks has created highly distinctive

trademarks that are widely recognized by the consuming public as identifying Link Snacks as the

source of the meat snacks associated with the marks. The JACK LINK’S Marks are extremely

valuable commercial assets because of the substantial goodwill associated with them.

18.

In addition to the advertising, marketing, and promotion identified above, Link

Snacks markets its meat snack products under the JACK LINK’S Marks through offering

coupons for its products sold in connection with the JACK LINK’S Marks. Examples of official

coupons offered for the JACK LINK’S brand meat snacks products are set forth below:

 



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CASE 0:13-cv-00604-JNE-JSM Document 1 Filed 03/15/13 Page 6 of 17

19.

The legitimate and official JACK LINK’S brand coupons display JACK LINK’S

meat snacks packaging in full color, have an expiration date, and contain a holographic security

strip. A closer look at the holographic security strip is below:

20.

The only genuine coupons that offer free JACK LINK’S meat snack products

come from Link Snacks’ consumer relations. Link Snacks does not permit third parties to re-

print the coupons.



UNLAWFUL CONDUCT BY DEFENDANT

21.

Defendants are listing, offering for sale, and selling unofficial coupons that bear

the JACK LINK’S Marks that were not provided by Link Snacks. A sample of one of the

unofficial coupons offered via www.eBay.com is set forth below:



 

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CASE 0:13-cv-00604-JNE-JSM Document 1 Filed 03/15/13 Page 7 of 17

22.

Link Snacks offered a coupon similar to the one identified above in 2009. Link

Snacks, however, no longer offers that coupon.

23.

The unofficial coupons contain no expiration date, have no holographic strip, and

are not printed with the JACK LINK’S color packaging. The unofficial coupons are also often

printed on shiny or glossy white paper.

24.

The Defendants’ use of the JACK LINK’S Marks in connection with the

unofficial coupons deceives consumers and potential consumers into believing that they are

purchasing legitimate and official coupons offered by Link Snacks. Because the coupons are in

fact not official, they may not be accepted by retailers, which causes harm to the public and to

Link Snacks.

25.

Link Snacks has repeatedly requested that eBay remove the unofficial coupons

from its website at www.ebay.com. Further, Link Snacks has written to many of the Defendants

via the communication system on www.ebay.com informing those Defendants that they do not

have the right to offer unofficial coupons.

26.

eBay has removed several of the listings. However, based on the number of

listings of unofficial coupons, some have been and continue to be sold to consumers. In turn,

those consumers have attempted to redeem those coupons at retail locations for JACK LINK’S

brand meat snack products.

27.

Link Snacks has notified retail stores of the fake coupons that are identified

above. Stores are instructed that the coupons are not legitimate. Certain stores have posted

notices at the checkout that the coupons are fraudulent and will not be accepted.

28.

Facebook.com has posted a public service announcement regarding the fake

coupons at issue in this lawsuit. The public service announcement is located at:

 

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https://www.facebook.com/media/set/?set=a.10150491014330325.422293.112132410324&type

=3 and informs consumers that coupons are fraudulent.

29.

By listing, offering to sell, and selling unofficial coupons, the Defendants are

harming the public, Link Snacks and its JACK LINK’S Marks. Consumers who are denied the

use of the coupons lose the money they spent to acquire the unofficial coupons. Further, they are

likely to believe that Link Snacks offered the coupons, which harms Link Snacks’ reputation and

goodwill.

30.

The Defendants’ sale of the unofficial coupons has also resulted in thousands of

dollars of fake coupons being redeemed at retail locations. Once the coupon is redeemed, Link

Snacks must pay the retail establishment or be charged additional penalties even if the coupon

was not official or legitimate.

31.

As shown herein, the Defendants’ unofficial coupons contain a confusingly

similar logo to the JACK LINK’S Marks. Other components of the coupons also give the false

impression the coupon is from Link Snacks. The unofficial coupons give an overall impression

that the coupons are offered by Link Snacks.

32.

The Defendants’ conduct described herein, all of which occurs in interstate

commerce, was not authorized by Link Snacks.

33.

The Defendants’ conduct evidences a persistent and intentional scheme to derive

financial benefit from the JACK LINK’S Marks and to harm Link Snacks. The Defendants

copied the JACK LINK’S Marks and created confusingly similar coupons that were offered to

consumers in interstate commerce. The Defendants also promoted the unofficial coupons as

being from Link Snacks.



 

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CASE 0:13-cv-00604-JNE-JSM Document 1 Filed 03/15/13 Page 9 of 17

INFRINGEMENT/ COUNTERFEITING OF REGISTERED TRADEMARKS UNDER

FIRST CLAIM FOR RELIEF

THE LANHAM ACT



34.

35.

Link Snacks repeats the allegations of paragraphs 1-33 of this Complaint.

Defendants’ use of the JACK LINK’S Marks and derivatives of those marks is

likely to cause confusion, mistake, or deception as to the source of origin of Defendants’

coupons in that customers and potential customers are likely to believe that the coupons provided

by Defendants under these marks are provided by, sponsored by, approved by, licensed by,

affiliated or associated with, or in some other way legitimately connected to Link Snacks.

36.

The fake coupons offered by the Defendants are substantially identical to coupons

previously offered by Link Snacks. Further, the fake coupons offered by the Defendants use

trademarks and logos that are identical to the JACK LINK’S Marks. Therefore, the fake coupons

are likely to cause confusion.

37.

The Defendants, by copying Link Snacks’ marks in connection with the fake

coupons, intentionally used a mark or designation knowing that mark or designation was a

counterfeit mark in connection with the sale, offer to sell, or distribution of goods or services.

38.

Further, by selling the fake coupons via third party eBay, the Defendants provided

the goods and services necessary to commission the violation of using a mark or designation in

connection with the sale, offer to sell, or distribution of goods or services, knowing that mark or

designation was a counterfeit mark.

39.

The JACK LINK’S Marks are registered on the Principal Register of the United

States Patent and Trademark Office and are used in commerce by Link Snacks. Defendants’ use

of these marks as a spurious designation of origin constitutes counterfeiting and is likely to cause

confusion, mistake, or deception in that customers and potential customers are likely to believe

 

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CASE 0:13-cv-00604-JNE-JSM Document 1 Filed 03/15/13 Page 10 of 17

there is sponsorship, approval, licensing, affiliation, association, or some legitimate connection

between the products provided under the counterfeit marks and Link Snacks.

40.

Defendants’ improper association of authentic JACK LINK’S brand in connection

with the marketing and promotion associated with the offerings of their fake coupons is also

likely to confuse potential consumers searching for JACK LINK’S brand meat snacks.

Defendants’ improper association is likely to cause confusion, mistake, or deception in that

customers and potential customers are likely to believe there is sponsorship, approval, licensing,

affiliation, association, or some legitimate connection between the products provided by the

Defendants and Link Snacks.

41.

42.

Defendants’ described conduct is willful.

As a direct and proximate result of the likely confusion, mistake, or deception,

Link Snacks has suffered, and will continue to suffer, irreparable harm if Defendants’ described

conduct is not enjoined.

43.

The likely confusion, mistake, or deception caused by the Defendants violates

Section 32(1) of the Lanham Act, 15 U.S.C. § 1114(1).

44.

Pursuant to 15 U.S.C. § 1117, Link Snacks is entitled to recover statutory

damages not exceeding $2,000,000 for each counterfeit mark used, Link Snacks’ damages and

all of Defendants’ profits as well as the cost of this action. The intentional nature of Defendants’

unlawful acts renders this an “exceptional case,” entitling Link Snacks to an award of attorneys'

fees under 15 U.S.C. § 1117(a).

FALSE DESIGNATION OF ORIGIN UNDER THE LANHAM ACT

SECOND CLAIM FOR RELIEF

45.

Link Snacks repeats the allegations of paragraphs 1-44 of this Complaint.

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CASE 0:13-cv-00604-JNE-JSM Document 1 Filed 03/15/13 Page 11 of 17

46.

Defendants’ use of the JACK LINK’S Marks and derivatives of those marks is

likely to cause confusion, mistake, or deception as to the source of origin of Defendants’

coupons in that customers and potential customers are likely to believe that the coupons provided

by Defendants under these marks are provided by, sponsored by, approved by, licensed by,

affiliated or associated with, or in some other way legitimately connected to Link Snacks.

47.

Defendants’ improper association of JACK LINK’S brand, marks, and logo with

their coupons is likely to confuse potential consumers searching for legitimate JACK LINK’S

coupons. Defendants’ improper association is likely to cause confusion, mistake, or deception in

that customers and potential customers are likely to believe there is sponsorship, approval,

licensing, affiliation, association, or some legitimate connection between the products provided

by Defendants and Link Snacks.

48.

Defendants’ promotion of fake coupons with the JACK LINK’S Marks is also

likely to cause confusion, mistake, or deception in that observers, customers and potential

customers are likely to believe there is sponsorship, approval, licensing, affiliation, association,

or some legitimate connection between the promotion of the coupons provided by Defendants

and Link Snacks.

49.

As a direct and proximate result of the likely confusion, mistake, or deception,

Link Snacks has suffered and will continue to suffer irreparable harm if Defendants’ described

conduct is not enjoined.

50.

The likely confusion, mistake, or deception caused by Defendants violates 15

U.S.C. § 1125(a).

51.

Pursuant to 15 U.S.C. § 1117, Link Snacks is entitled to recover Link Snacks’

damages and all of Defendants’ profits as well as the costs of this action. The intentional nature

 

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CASE 0:13-cv-00604-JNE-JSM Document 1 Filed 03/15/13 Page 12 of 17

of Defendants’ unlawful acts renders this an “exceptional case,” entitling Link Snacks to an

award of attorneys' fees under 15 U.S.C. § 1117(a).

THIRD CLAIM FOR RELIEF

DECEPTIVE TRADE PRACTICES – MINN. STAT. 325D.44



52.

Link Snacks repeats and incorporates herein the allegations of paragraphs 1-51 of

this Complaint.

53.

Defendants have engaged in deceptive trade practices in violation of Minn. Stat.

§ 325D.44, including Minn. Stat. § 325D.44(1)-(5), because their use of the JACK LINK’S

Marks and derivatives of those marks is likely to cause confusion, mistake, or deception as to the

source of origin of Defendants’ coupons in that customers and potential customers are likely to

believe that the coupons Defendants provide under the JACK LINK’S Marks and derivatives of

those marks are provided by, sponsored by, approved by, licensed by, affiliated or associated

with, or in some other way legitimately connected to Link Snacks.

54.

Link Snacks has standing under Minn. Stat. § 8.32(3)(a) to bring this cause of

action because Link Snacks brings this cause of action for the public benefit. In particular and in

addition to the facts addressed above, consumers who purchase Defendants’ unofficial coupons

may not be redeemable at retail locations because those locations have been instructed not to

accept them. The Defendants’ actions are causing harm to the public.

55.

As a direct and proximate result of the likely confusion, mistake, or deception,

Link Snacks has suffered and will continue to suffer irreparable harm to the public and Link

Snacks if Defendants’ described conduct is not enjoined.

56.

Pursuant to Minn. Stat. § 325D.45, Link Snacks is entitled to an injunction, its

costs, and attorneys’ fees.

 

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CASE 0:13-cv-00604-JNE-JSM Document 1 Filed 03/15/13 Page 13 of 17

UNLAWFUL TRADE PRACTICES ACT – MINN. STAT. § 325D.15

FOURTH CLAIM FOR RELIEF

57.

Link Snacks repeats and incorporates herein the allegations of paragraphs 1-56 of

this Complaint.

58.

Defendants have engaged in unlawful trade practices in violation of Minn. Stat.

§ 325D.09 et seq. because their use of the JACK LINK’S Marks and derivatives of those marks

is likely to cause confusion, mistake, or deception as to the source of origin of Defendants’

coupons in that customers and potential customers are likely to believe that the coupons provided

by Defendants under the JACK LINK’S Marks and derivatives of those marks are provided by,

sponsored by, approved by, licensed by, affiliated or associated with, or in some other way

legitimately connected to Link Snacks.

59.

As a direct and proximate result of the likely confusion, mistake, or deception,

Link Snacks has suffered and will continue to suffer irreparable harm if Defendants’ described

conduct is not enjoined.

60.

Pursuant to Minn. Stat. § 325D.15 and § 8.31, Subd. 3a, Link Snacks is entitled to

an injunction, damages, costs, disbursements, and reasonable attorney’s fees.

FIFTH CLAIM FOR RELIEF

COMMON LAW TRADEMARK INFRINGEMENT



61.

Link Snacks repeats and incorporates herein the allegations of paragraphs 1-60 of

this Complaint.

62.

63.

The JACK LINK’S Marks are distinctive and famous.

Defendants’ use of the JACK LINK’S Marks and derivatives of those marks is

likely to cause confusion, mistake, or deception as to the source of origin of Defendants’

coupons in that customers and potential customers are likely to believe that the coupons provided

under the JACK LINK’S Marks and derivatives of those marks are provided by, sponsored by,

 

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approved by, licensed by, affiliated or associated with, or in some other way legitimately

connected to Link Snacks.

64.

65.

Defendants’ acts constitute trademark infringement under the common law.

Defendants acted in willful, deliberate, and/or intentional disregard of Link

Snacks’ rights.

66.

Link Snacks has suffered irreparable harm, for which it has no adequate remedy at

law, and will continue to suffer irreparable injury unless and until Defendants’ infringing acts are

enjoined by this Court.



SIXTH CLAIM FOR RELIEF

COMMON LAW UNFAIR COMPETITION

67.

Link Snacks repeats and incorporates herein the allegations of paragraphs 1-66 of

this Complaint.

68.

Defendants’ conduct constitutes unfair competition in violation of Link Snacks’

rights.



69.

As a direct and proximate result of Defendants’ unfair competition, Link Snacks

has suffered and will continue to suffer irreparable harm if Defendants’ conduct is not enjoined.

70.

Defendants acted in willful, deliberate and/or intentional disregard of Link

Snacks’ rights.

71.

Link Snacks has suffered irreparable harm, for which it has no adequate remedy at

law, and will continue to suffer irreparable injury unless and until Defendants’ unfair

competition is enjoined by this Court.

72.

Link Snacks respectfully requests a jury trial for this matter.



 

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WHEREFORE, Link Snacks respectfully requests judgment against the Defendants as

PRAYER FOR RELIEF

follows:

A.

That each Defendant and all agents, servants, employees, attorneys,

representatives, related companies, and all those in privity with or acting in concert with

any Defendant, be preliminarily and permanently enjoined and restrained from directly or

indirectly:

1.

Using Link Snacks JACK LINK’S Marks or any other name or mark

confusingly similar thereto, on, or in association with goods or services not

originating with Link Snacks;

2.

Performing any actions or using any words, names, styles, titles, logos, or

marks which are likely to cause confusion or mistake, or to deceive; or to

otherwise mislead the trade or the public into believing that the Defendants and

Link Snacks are in some way connected, affiliated, or associated with one

another, or that Defendants’ products originate with Link Snacks or are offered

with the approval, consent, authorization, or under the supervision of Link

Snacks;

3.

Using any words, names, styles, titles, or marks which create a likelihood

of injury to the business reputation of Link Snacks or the goodwill associated

therewith; and

4.

Using any trade practice whatsoever, including those complained of

herein, which tend to unfairly compete with or injure Link Snacks’ business or

goodwill.

 

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B.

For an Order requiring each Defendant to submit a report in writing and

under oath to the Court and Link Snacks within thirty (30) days of the service on each

Defendant of the injunctive order setting forth in detail the manner and form by which

such Defendant has complied with the injunction.

C.

That each Defendant be required to deliver up for destruction all goods,

components for goods, packaging, stationery, signage, advertisements, brochures,

promotional materials, and all other materials of any kind bearing the JACK LINK’S

Marks or any simulation, reproduction, copy or colorable imitation of the JACK LINK’S

Marks, including, but not limited to, coupons and electronic copies of coupons bearing

the JACK LINK’S Marks.

D.

That Defendants be required to pay to Link Snacks all of Link Snacks’

litigation expenses, including reasonable attorneys’ fees and the costs of this action.

E.

Awarding Link Snacks all damages permitted by 15 U.S.C. § 1117(a),

trebled.

F.

G.

Awarding Link Snacks damages pursuant to 15 U.S.C. § 1117(c).

Awarding Link Snacks its damages caused by Defendants’ common law

trademark infringement in an amount to be established at trial.

H.

Awarding Link Snacks such further relief as this Court deems just and

proper.











 

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Dated: March 15, 2013


 

 

MERCHANT & GOULD


By: s/ William D. Schultz



Scott W. Johnston (MN# 247558)
William D. Schultz (MN# 323482)

3200 IDS Center
80 South Eighth Street
Minneapolis, MN 55402-2215
Telephone: (612) 332-5300
Facsimile: (612) 332-9081

[email protected]
[email protected]


Attorneys for Plaintiff Link Snacks, Inc.

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