BSH v. Caliber Range - Complaint

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BSH01-04:1322718_1:7-25-14 - 1 -

COMPLAINT

Wayne W. Call, Bar No. 56676 [email protected] Scott P. Shaw, Bar No. 223592 [email protected] Cardon B. Smith, Bar No. 277532 [email protected] CALL & JENSEN A Professional Corporation 610 Newport Center Drive, Suite 700 Newport Beach, CA 92660 Tel: (949) 717-3000 Fax: (949) 717-3100

Attorneys for Plaintiff BSH Home Appliances Corporation

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

BSH HOME APPLIANCES CORPORATION, a Delaware corporation,

Plaintiff,

vs. CALIBER RANGE CORPORATION, a California corporation; DOES 1 through 10, inclusive,

Defendants.

Case No. 14-cv-5821 COMPLAINT FOR

1. FEDERAL TRADEMARK INFRINGEMENT



4. FEDERAL FALSE DESIGNATION OF ORIGIN

5. DESIGN PATENT INFRINGEMENT

6. CALIFORNIA COMMON LAW TRADEMARK INFRINGEMENT

7. UNFAIR COMPETITION AND UNFAIR BUSINESS PRACTICES

DEMAND FOR JURY TRIAL

Case 2:14-cv-05821 Document 1 Filed 07/25/14 Page 1 of 15 Page ID #:1

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COMPLAINT

Plaintiff BSH Home Appliances Corporation (“BSH”), by and through its

attorneys of record, complains against Caliber Range Corporation (“Caliber” or

“Defendant”), and alleges as follows:

NATURE OF THE ACTION

1. By this Complaint, BSH seeks injunctive relief, damages, and other

remedies provided by law to remedy injuries caused by Caliber’s conduct of infringing

Plaintiff’s distinctive trademarks, misappropriating Plaintiff’s patent rights, and for

Caliber’s unfair competition and unfair business practices in violation of California and

United States laws.

2. BSH’s primary business has been the manufacture and sale of home

appliances, including but not limited to, domestic and home cooking appliances. BSH

is a fully-owned subsidiary of Bosch and Siemens Home Appliance Group, the third

largest appliance manufacturer in the world.

3. BSH acquired Thermador Corp. in the 1990s, which had been making

kitchen appliances for over 75 years, along with Thermador Corp.’s well recognized

brands including, but not limited to, THERMADOR and THERMADOR

PROFESSIONAL. Today, BSH enjoys a nationwide reputation for excellence for its

domestic and home cooking and other appliance products, which have been marketed

under numerous trademarks in interstate commerce in the United States and in other

countries.

4. As detailed below, BSH has established distinctive trademark rights in

THERMADOR and THERMADOR PROFESSIONAL products, as well as a family of

trademark rights using the name STAR for BSH’s products and services. BSH also has

distinctive trademark rights in a distinctive star symbol, which consist of a five-pointed

star with truncated tips.

5. In a deliberate attempt to trade on the acclaim of BSH’s appliances and the

goodwill developed by BSH in its THERMADOR or THERMADOR

PROFESSIONAL marks, Caliber is using the marks “THERMASHELL” and


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COMPLAINT

“THERMASHELL PRO” for Caliber’s products. Caliber is also using the marks

“STELLAR” and “STELLAR PRO” to trade off BSH’s goodwill in its STAR

trademarks for similar products. To make matters worse, Caliber is also using a five-

pointed star design with truncated tips. Caliber’s Star Design has the same unique five-

point star design with truncated tips as BSH’s signature trademark.

6. Caliber’s actions are intentional and willful, and Caliber’s products are

likely to cause consumer confusion over source, sponsorship, affiliation, endorsement,

and/or association with BSH’s trademark and patent rights. Caliber has prior

knowledge of BSH’s products and distinctive intellectual property rights. In fact,

Caliber’s president and vice-president both previously worked for Dynamic Cooking

Systems (“DCS”)—a direct competitor of Thermador and Bosch and a former sub-

contractor of Thermador. Caliber is now attempting to trade off BSH’s goodwill and

reputation by adopting words and designs that will cause consumers to falsely believe

that BSH is affiliated with, or is connected in some way with Caliber.

PARTIES

7. BSH is and was at all times mentioned in this Complaint a corporation of

the State of Delaware, with places of business at 1901 Main Street, Suite 600, Irvine,

California 92614, and 100 Bosch Boulevard, New Bern, North Carolina 28562.

8. On information and belief, Defendant Caliber is a corporation of the State

of California, which has a place of business at 17812 Metzler Lane, Huntington Beach,

California 92647.

9. Plaintiff is unaware of the true names and capacities of defendants sued as

Does 1-10, inclusive, and therefore sues these Defendants by such fictitious names.

Plaintiff is informed and believes, and on the basis of that information and belief

alleges, that at all times mentioned in this Complaint, Does 1-10 were the agents and

employees of their co-defendants or otherwise responsible for the conduct complained

of herein, and in doing the things alleged in this Complaint were acting within the

course and scope of that agency and employment or were otherwise responsible for the


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COMPLAINT

damages complained of by Plaintiff. Plaintiff will amend this Complaint to allege their

names and capacities when ascertained.

JURISDICTION AND VENUE

10. This is an action for federal trademark infringement pursuant to 15 U.S.C.

§ 1114, federal false designation of origin pursuant to 15 U.S.C. § 1125, patent

infringement pursuant to 35 U.S.C. § 271, California common law trademark

infringement under California Business & Professions Code § 14200 et seq., and unfair

competition and unfair business practices under California Business & Professions

Code § 17200 et seq.

11. The Court has jurisdiction under 15 U.S.C. §§ 1121, 1125; and 28 U.S.C.

§§ 1331 and 1338 in that this case arises under the trademark laws of the United States,

15 U.S.C. §§ 1051 et seq., and patent laws. The Court has jurisdiction over state unfair

competition claims herein pursuant to 28 U.S.C. § 1338(b) because these claims are

joined with a substantial and related claim arising under the trademark laws of the

United States.

12. Venue is proper in this district under 28 U.S.C. § 1391(b) and (c) in that

Caliber is subject to personal jurisdiction in this district, Caliber resides in this district, a

substantial part of the events giving rise to the claim occurred in this district, and

Caliber has targeted their harm and injury to Plaintiff who has a place of business in this

district.

13. Caliber is subject to personal jurisdiction in this district under Federal

Rules of Civil Procedure Rule 4(k)(1)(A) and California Code of Civil Procedure

§ 410.10. Caliber is domiciled in this state and is doing continuous and systematic

business in this judicial district.

BSH’S INTELLECTUAL PROPERTY RIGHTS

14. For many years, BSH has marketed its products and services all around

the world using its Star Design, STAR, THERMADOR, and THERMADOR

PROFESSIONAL trademarks. In addition to obtaining common law rights to exclusive


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COMPLAINT

use of these marks, BSH owns several federal trademark registrations, including but not

limited to: U.S. Registration Nos. 2362875, 3829556, 3829558, 4212541, 4259358,

1144768, 1197124, 1853576, 3477069, 3002017, 4223077 and 4265875.

15. BSH’s STAR trademark and Star Design trademark rights date back to the

1990s, and the THERMADOR trademark rights date back to the 1920s.

16. Since the adoption and first use of its Star Design, STAR, THERMADOR,

and THERMADOR PROFESSIONAL trademarks, BSH (including its predecessors)

has expended substantial amounts of money, time, and effort to promote and advertise

its products and services around the world using its distinctive Star Design, STAR,

THERMADOR, and THERMADOR PROFESSIONAL trademarks. As a result of such

efforts, BSH has established an outstanding reputation in the minds of customers as to

the excellence of the quality of home appliance products and services sold and offered

in connection with the Star Design, STAR, THERMADOR, and THERMADOR

PROFESSIONAL trademarks.

17. Also, by virtue of these activities, BSH owns the entire right, title and

interest in and to the Star Design, STAR, THERMADOR, and THERMADOR

PROFESSIONAL trademarks, as well as the goodwill of the business with which those

marks have been used. Through the distribution, advertising, and sale of its products

under or in connection with the Star Design, STAR, THERMADOR, and

THERMADOR PROFESSIONAL trademarks, BSH has created substantial goodwill in

those marks. Consequently, the general public has become aware that the Star Design,

STAR, THERMADOR, and THERMADOR PROFESSIONAL trademarks indicate

origin, sponsorship by, or other connection with a single source, BSH.

18. BSH uses the THERMADOR brand and trademark in commerce. This

word mark has been registered on the Principal Register and assigned United States

Registration Nos. 1,144,768 (issued December 30, 1980); 1,197,124 (issued June 8,

1982); and 3,002,017 (issued September 27, 2005). Copies of these registrations are

attached hereto as Exhibit “A”, Exhibit “B”, and Exhibit “C” respectively. These


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COMPLAINT

trademarks have become incontestable under Section 15 of the Lanham Act, 15 U.S.C.

§ 1065.

19. BSH also uses in commerce the THERMADOR PROFESSIONAL

trademark. This word mark has been registered on the Principal Register as United

States Registration No. 1853576 (issued September 13, 1994). A copy of this

registration is attached hereto as Exhibit “D”. Trademark Registration No. 1853576 has

become incontestable under Section 15 of the Lanham Act, 15 U.S.C. § 1065.

20. BSH also owns a registration for THERMADOR. AN AMERICAN ICON

trademark. This trademark has been registered on the Principal Register as United

States Registration No. 3,477,069 (issued July 29, 2008). A copy of this registration is

attached hereto and made a part of the Complaint as Exhibit “E”.

21. BSH also uses in commerce the THERMADOR & Star Design trademark.

This trademark has been registered on the Principal Register as United States

Registration Nos. 4,223,077 (issued October 9, 2012) and 4,265,875 (issued December

25, 2012). Copies of these registrations are attached hereto as Exhibit “F” and Exhibit

“G”, respectively.

22. BSH also uses in commerce the STAR trademark. This trademark has

been registered upon the Principal Register as United States Registration No. 2,362,875

(issued June 27, 2000). A copy of this registration is attached hereto as Exhibit “H”.

Trademark Registration No. 2,362,875 has become incontestable under Section 15 of

the Lanham Act, 15 U.S.C. § 1065.

23. BSH also uses in commerce the STAR PARTNER trademark. This mark

has been registered upon the Principal Register as United States Registration No.

3,829,556 (issued August 3, 2010). A copy of this registration is attached hereto as

Exhibit “I”.

24. BSH also uses in commerce the STAR PARTNER & design trademark.

This mark has been registered upon the Principal Register as United States Registration


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COMPLAINT

No. 3,829,558 (issued August 3, 2010). A copy of this registration is attached hereto as

Exhibit “J”.

25. BSH also uses in commerce the STAR SPEED trademark. This trademark

has been registered upon the Principal Register as United States Registration No.

4,247,197 (issued November 20, 2012). A copy of this registration is attached hereto as

Exhibit “K”.

26. BSH also uses in commerce the Star Design trademark. This trademark

has been registered upon the Principal Register as United States Registration Nos.

4,212,541 (issued September 25, 2012) and 4,259,358 (issued December 11, 2012).

Copies of these registrations are attached hereto as Exhibit “L” and Exhibit “M”,

respectively.

27. BSH has exclusively used its Star Design, which is in the shape of a five-

pointed star with trunctated tips, as the shape for the burners on its burners for many

years. BSH’s star-shaped burner is highly distinctive, and serves to identify all products

using such a star-shape as coming from BSH. When used as a gas burner, consumers

immediately recognize the Star Design as being associated only with BSH. This same

Star Design is further protected as a Design Patent. (Exhibit “N”).

CALIBER’S WILLFUL INFRINGEMENT

28. Caliber is using designs and trademarks that are highly similar to BSH’s

trademarks, and which are likely to cause confusion, or to cause mistake, or to deceive

as to the affiliation, connection, or association of Caliber with BSH, or as to the origin,

sponsorship, or approval of Caliber’s goods, services, or commercial activities by BSH.

These infringing trademarks include the word marks STELLAR and STELLAR PRO in

place of BSH’s STAR, STAR PARTNER, and THERMADOR PROFESSIONAL

trademarks; the word marks THERMASHELL and THERMASHELL PRO in place of

BSH’s THERMADOR and THERMADOR PROFESSIONAL trademarks; and a gas

burner shaped as a five-pointed star with truncated tips that is nearly identical to BSH’s

Star Design. Caliber calls its star-shaped burner the “Stellar™ top burner” and “Stellar


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COMPLAINT

Pro™ Power Top Burner,” whereas BSH calls its star-shaped burner the “Star®

Burner.” These actions constitute willful infringement and an attempt to trade upon

BSH’s goodwill.

29. Without BSH’s consent, Caliber has been offering for sale and selling

products within this district and throughout the United States under trademarks which

are likely to cause confusion, or to cause mistake, or to deceive as to the affiliation,

connection, or association of Caliber with BSH, or as to the origin, sponsorship, or

approval of Caliber’s goods, services, or commercial activities by BSH.

30. Caliber’s products are marketed and sold in similar channels of trade to

consumers seeking cooking appliances or grills. In fact, the parties are apparently

scheduled to showcase their products in an upcoming trade show early next year.

31. Caliber’s products and BSH’s products are related goods. There is no

business affiliation between the two companies. Because both parties’ products are

related, consumers may think that BSH licensed or authorized Caliber to use BSH’s

intellectual property rights, which is not true. Caliber’s infringing uses on related

products came only after BSH had established its rights in commerce for its products

and developed the reputation that goes with these distinctive marks.

32. Subsequent to BSH’s use and registration of its Star Design and STAR

trademarks, Caliber commenced use of a Star design on its STELLAR PRO burner

products that infringes BSH’s exclusive rights to the Star Design under US Registration

Nos. 4212541 and 4259358. Caliber knowingly created a Star design that copies the

distinctive BSH Star Design with the five-point star design with truncated tips.

33. There is no reason for Caliber to adopt a five-point star design with

truncated tips other than to trade upon BSH’s goodwill.

34. Caliber would have and could have easily designed a burner with fingers

dissimilar from BSH’s distinctive five-pointed star with truncated tips. BSH’s design is

protected by a Design Patent that provided BSH with exclusive rights.


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COMPLAINT

35. Caliber also is using in commerce the STELLAR and STELLAR PRO

trademarks which infringe BSH’s rights to its registered STAR marks, US Registration

Nos. 2,362,875, 3,829,556, 3,829,558 and 4,247,197.

36. Caliber also is using in commerce the THERMASHELL and

THERMASHELL PRO trademarks which infringe BSH’s rights to its registered

THERMADOR and THERMADOR PROFESSIONAL trademarks, US Registration

Nos. 1144768, 1197124, 1853576, 3477069, 3002017, 4223077 and 4265875.

37. Caliber’s use of its Star design, STELLAR, STELLAR PRO,

THERMASHELL, and THERMASHELL PRO trademarks is aimed at trading on the

good will associated with BSH’s famous Star Design, STAR trademarks,

THERMADOR, and THERMADOR PROFESSIONAL trademarks. Caliber began this

unlawful conduct after BSH had begun using its distinctive trademarks in commerce.

FIRST CAUSE OF ACTION

(FEDERAL TRADEMARK INFRINGEMENT [15 U.S.C. § 1114])

(Infringement of STAR marks)

38. BSH re-alleges and incorporates herein the allegations of paragraphs 1-37.

39. Caliber’s use of the marks STELLAR and STELLAR PRO in connection

with its products is likely to cause consumer confusion with BSH’s STAR trademark

rights.

40. Unless Caliber’s use is enjoined, BSH will continue to suffer injury and

damage. Caliber’s infringement is intentional and willful and BSH is entitled to an

injunction, actual damages, and profit disgorgement from Caliber based on its sales of

infringing products.

41. Caliber’s actions render this an exceptional case, further entitling BSH to

recovery of its attorneys’ fees and costs of suit as detailed in 15 U.S.C. § 1117.

/ / /

/ / /


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COMPLAINT

SECOND CAUSE OF ACTION


(Infringement of THERMADOR marks)


43. Caliber’s use of the marks THERMASHELL and THERMASHELL PRO

in connection with its products is likely to cause consumer confusion with BSH’s

THERMADOR and THERMADOR PROFESSIONAL trademark rights.







THIRD CAUSE OF ACTION


(Infringement of Star Design Trademark)


47. Caliber’s use of the five-pointed star with truncated tips on its products is

likely to cause consumer confusion with BSH’s Star Design trademark rights.







/ / /

/ / /


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COMPLAINT

FOURTH CAUSE OF ACTION

(FEDERAL FALSE DESIGNATION OF ORIGIN [15 U.S.C. § 1125(a)])

50. BSH realleges and incorporates herein the allegations of paragraphs 1-49,

inclusive.

51. Caliber’s use of its Star design, “blue flame” marketing materials,

STELLAR, STELLAR PRO, THERMASHELL, and/or THERMASHELL PRO

trademarks in connection with its products constitutes a false designation of origin

which is likely to cause consumer confusion over sponsorship, endorsement, affiliation,

connection, or association with BSH.







FIFTH CAUSE OF ACTION

(DESIGN PATENT INFRINGEMENT [35 U.S.C. § 271])


inclusive.

55. BSH is the owner of all right, title, and interest in and to the Design Patent

for its Star Design.

56. Caliber has knowingly and intentionally manufactured, caused to be

produced, distributed, offered for sale, and sold a substantially similar product, as

described above, that infringes on BSH’s Design Patent rights.



injunction, actual damages, profit disgorgement from Caliber based on its sales of

infringing products, attorneys’ fees, and possibly treble damages.


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COMPLAINT

SIXTH CAUSE OF ACTION

(CALIFORNIA COMMON LAW TRADEMARK

INFRINGEMENT [Cal. Bus. & Prof. Code § 14200 et seq.])


inclusive.

59. BSH has developed substantial California common law rights in and to its

Star Design, STAR, THERMADOR, and THERMADOR PROFESSIONAL

trademarked products as fully described herein.

60. Caliber has infringed BSH’s trademarks by using similar marks in

commerce in the state of California in a way that is likely to cause confusion as to

BSH’s association, affiliation, sponsorship or endorsement of Caliber and its products.

61. Caliber’s infringement is intentional and willful and BSH is entitled to an

injunction, actual damages, profit disgorgement, and punitive damages from Caliber

based on its sales of infringing products.

SEVENTH CAUSE OF ACTION

(CALIFORNIA UNFAIR COMPETITION AND UNFAIR BUSINESS

PRACTICES [Cal. Bus. & Prof. Code § 17200 et seq.])


inclusive.

63. Caliber’s conduct alleged herein constitutes trademark infringement, false

designation of origin, and unfair competition under 15 U.S.C. § 1051 et seq. and Cal.

Bus. & Prof. Code § 14200 et seq. Caliber’s conduct thus constitutes willful and

deliberate unfair competition in wanton disregard of BSH’s valuable intellectual

property rights.

64. Caliber’s conduct has directly and proximately caused and will continue to

cause BSH substantial and irreparable injury, including customer confusion, injury to its

reputation, and diminution in value of its intellectual property, and unless restrained,


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COMPLAINT

will continue to seriously and irreparably impair further the value of the BSH brand and

marks, for which there is no adequate remedy at law.

65. The harm to BSH and to members of the general public outweighs the

utility of Caliber’s business practices.

66. The unlawful, unfair, and fraudulent business practices of Caliber, as

described in this Complaint, present a continuing threat to members of the public in that

they are likely to cause confusion as to the source of Caliber’s products in that the

general public is likely to believe that Caliber’s products originate from, or are affiliated

or associated with Plaintiff, or are otherwise sponsored or endorsed by Plaintiff.

67. As a direct and proximate result of Caliber’s wrongful acts as alleged in

this Complaint, Caliber obtained unlawful profits to the detriment of BSH.

68. Unless restrained, Caliber will continue the acts and conduct set forth in

this cause of action, to BSH’s great and irreparable injury, for which damages will not

afford adequate relief. BSH is therefore entitled to an injunction prohibiting Caliber’s

wrongful acts.

69. Caliber committed the wrongful acts willfully, intending to gain business

and a share of the market at the expense of BSH’s profits and market share while

creating customer confusion regarding the source of goods bearing the BSH marks.

Caliber’s conduct justifies an award of exemplary damages.

70. Upon proof, BSH is entitled to recover its costs, including attorneys’ fees,

under California Code of Civil Procedure Section 1021.5.

PRAYER FOR RELIEF

For these reasons, BSH Home Appliances Corporation respectfully requests that

this Court enter judgment in its favor and grant the following relief:

A. Actual damages according to proof;

B. Profit disgorgement from Caliber’s sales of infringing products;

C. Injunctive relief preventing Caliber from engaging in further sales of

infringing products;


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COMPLAINT

D. Punitive or exemplary damages, including but not limited to treble

damages as a result of Defendant’s willful infringement;

E. Reasonable attorneys’ fees and costs of suit;

F. Pre-judgment interest on all amounts claimed as permitted by law; and

G. Such other and further relief as this Court may deem just and appropriate.

Dated: July 25, 2014 CALL & JENSEN A Professional Corporation

Wayne Call Scott P. Shaw Cardon B. Smith By:/s/ Scott P. Shaw

Scott P. Shaw



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COMPLAINT

DEMAND FOR JURY TRIAL

BSH Home Appliances Corporation demands a trial by jury on all issues so

triable pursuant to Federal Rule of Civil Procedure 38. Dated: July 25, 2014 CALL & JENSEN A Professional Corporation

Wayne Call Scott P. Shaw Cardon B. Smith By:/s/ Scott P. Shaw

Scott P. Shaw



EXHIBIT A

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Case 2:14-cv-05821 Document 1-1 Filed 07/25/14 Page 1 of 34 Page ID #:16

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EXHIBIT B

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EXHIBIT C

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EXHIBIT D

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EXHIBIT E

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EXHIBIT F

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EXHIBIT G

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EXHIBIT H

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EXHIBIT I

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EXHIBIT J

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EXHIBIT K

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EXHIBIT L

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EXHIBIT M

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EXHIBIT N

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Documents

BSH v. Caliber Range - Complaint