macy's inc. v. strategic marks

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AMSTER, ROTHSTEIN & EBENSTEIN LLPANTHONY F. LO CICERO, NY SBN [email protected] ROTHSTEIN, NY [email protected] PEKOWSKY, NY [email protected] CAPASSO, NY SBN 4766283jcapassoarelaw.com90 Park AvenueNew York, NY 10016Telephone: (212) 336-8000Facsimile: (212) 336-8001(Pro Hac Vice Applications Forthcoming)HANSON BRIDGETT LLPGARNER K. WENG, SBN 191462gwenghansonbridgett.cornCHRISTOPHER S. WALTERS, [email protected] Market Street, 26th FloorSan Francisco, California 94105Telephone: (415) 777-3200Facsimile:415) 541-9366Attorneys for Plaintiffs MACYS, INC. andMACYS.COM , INC.

UNITED STATES DISTRICT COURTNORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCOD1jMACYS, INC. and MACYS.COM , INC.,

Plaintiffs,V.

STRATEGIC MARKS, LLC,Defendant.

Case No.COMPLAINT FOR TRADEMARKINFRINGEMENT, FALSE DESIGNATIONOF O RIGIN, DILUTION, AND U NFAIRCOMPETITIONDEMAND FOR JURY TRIAL


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NATURE OF THE ACTION1. This is an Action for trademark infringement, false designation of origin,

unfair competition, and dilution arising under the Lanham Act, 15 U.S.C. 1051 et seq.,and federal and State common law. Defendant has willfully and unlawfully infringed theHeritage Marks (as defined below) with the clear and unmistakable intent and effect ofcausing confusion, mistake, and deception among customers and potential customers.

2. Macys is the owner and user of the following world famous marks for retailstore and online retail store services, clothing and related products: ABRAHAM &STRAUS, A&S, THE BROADWAY, JORDAN MARSH, BULLOCKS, ROBINSONS-MAY,FILENES, and THE BON MARCHE (collectively and individually, the "Heritage Marks").

3. The Heritage Marks have been used, inter a/ia, in the following stylizedformats (collectively and individually, the "Macys Famous Stylized Nameplates"):

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U L : L ~lu L N -MAY

I F 1 1 L I E N fE S4. This Complaint asserts claims against Defendant arising from Defendants

trademark infringement, unfair competition, and dilution of the Heritage Marks and MacysFamous Stylized Nameplates.

5. Macys asks this Court to enjoin the infringement, dilution, and Unfaircompetition caused by Defendants wrongful activities and to compensate Macys for thedamages which Defendant has caused and the unjust enrichment it has received.

THE PARTIES6. Plaintiff Macys, Inc. is a corporation organized and existing under the laws

of the State of Delaware with a principal place of business at 7 West Seventh Street,Cincinnati, OH 45202 and operates several Macys department stores within this Judicial

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1.pon information and belief, Defendant Strategic Marks is a limited liability2 I company organized and existing under the laws of the State of California, with a place of3 I business at 25 Ridgeview, Irvine, CA 92603.4URISDICTION AND VENUE5.his is an action for trademark infringement, false designation of origin,6 trademark dilution, and unfair competition arising under the Trademark Act of 1946, 157 U.S.C. 1051 et. seq.; trademark infringement, false designation of origin, and unfair8 competition arising under the common law of the State of California; and statutory dilution9 and unfair competition under the laws of the State of California. This Court has

10 jurisdiction over the subject matter of this action under the Trademark Act of 1946, 1511 U.S.C. 1121 and the Judicial Code, 28 U.S.C. 1331 and 1338. This Court has12 supplemental jurisdiction over the state law claims pursuant to 28 U.S.C. 1367, which13 arise out of the same nucleus of operative fact as the substantial Federal law claims to14 which they are joined.150.efendant Strategic Marks is subject to this Courts personal jurisdiction16 pursuant to Local Rule 3-5 and Rule 4 of the Federal Rules of Civil Procedure because it17 does business in this Judicial District, including offering infringing products that contain18 the Heritage Marks within this State and in this District, and expressly aiming the acts19 alleged in this Complaint at this District.20

1.enue is proper in this judicial district under 28 U.S.C. 1391, among other21 things because the injury caused by the acts alleged in this Complaint was felt in this22 District.23NTRADISTRICT ASSIGNMENT


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1 a/ia, numerous MACYS retail department stores throughout the country, including in this2 State. Macys also operates an online retail store at www.macys.com .34.acys is the owner of various retail stores under marks other than4 MACYS, including but not limited to the Heritage Marks, which are described as follows:5)ORDAN MARSH, a prominent New England department store6 initially located in Boston was founded by Benjamin L. Marsh and Eben Jordan in7 approximately 1851.8)ULLOCKS, a prominent west coast department store initially9 located in Los Angeles was founded by John G. Bullock in 1907.

10)OBINSONS-MAY stores from the west coast trace their history11 back to the opening of the J.W. Robinson Company in 1881. The Los Angeles-based12 store catered to an upscale clientele and quickly branched out to multiple locations.13)ILENES, a prominent New England department store initially14 located in Boston was established in 1852 by William Filene.15)BRAHAM & STRAUS, also known as A&S, was founded in16 Brooklyn in 1893 and quickly grew from a small dry goods shop to a prominent17 department store.18)HE BROADWAY, a southwest store, was initially established in Los19 Angeles in 1896 and transformed into one of the most successful department store

20 chains in Southern California.21)HE BON MARCHE was initially established in Seattle in 1890 and22 expanded throughout the Northwest becoming a staple in malls and shopping centers.235.he Heritage Marks, by reason of the high quality retail and other services


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1 value to Macys.26.laintiff Macys, Inc. is the owner of, inter a/ia, the following U.S. trademark3 and service mark registrations for the Heritage Marks (collectively and individually,4 "Macys Registrations"):5)ILENES, U.S. Trademark Registration No. 1,960,415, issued6arch 5, 1996, for retail department store services.7)OBINSONS-MAY, U.S. Trademark Registration No. 1,793,132,8ssued September 14, 1993, for retail department store services.9)AY, U.S. Trademark Registration No. 1,728,405, issued October107, 1992, for retail department store services.

ill True and correct copies of Macys Registrations are attached hereto as Exhibit A.127.he Heritage Marks, by virtue of their wide renown, have developed a13 secondary meaning and significance in the minds of the trade and the purchasing public,14 such that the retail department store services, online retail store services, and related15 goods and services offered thereunder are immediately identified with Plaintiffs by the16 purchasing public.178 .acys has not abandoned its Heritage Marks.189.acys is using its Heritage Marks in United States commerce, including but19 not limited to within its Macys.com website.200.acys has taken active, affirmative, and successful steps to retain andItAl foster the goodwill of the Heritage Marks.221 .he relevant consuming public recognizes that the Heritage Marks are23 trademarks and service marks indicating a single source of origin.


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14.ong after Plaintiffs adoption and use of the Heritage Marks for retail2 department store services, online retail store services, and related goods and services,3 Defendant applied to federally register marks identical to the Heritage Marks for identical4 services (the "Infringing Marks").

55 .efendant has applied for the following U.S. registrations for the Infringing6 II Marks:

7).S. Trademark Application Serial No. 85137185, filed September8 24, 2010, for the Infringing Mark ROBINSONS for, inter al/a, retail department store and9 on-line retail department store services.

10).S. Trademark Application Serial No. 85137191, filed September1 1 24, 2010, for the Infringing Mark THE BROADWAY for, inter al/a, retail department store12 and on-line retail department store services.

13).S. Trademark Application Serial No. 851 37181, filed September14 24, 2010, for the Infringing Mark MAY COMPANY for, inter a/ia, retail department storeIll and on-line retail department store services.d).S. Trademark Application Serial No. 85137194, filed September

17 24, 2010, for the Infringing Mark ABRAHAM AND STRAUS for, inter al/a, retail18 department store and on-line retail department store services.

19).S. Trademark Application Serial No. 85137183, filed September20 24, 2010, for the Infringing Mark JORDAN MARSH for, inter a/ia, retail department store21 and on-line retail department store services.

22).S. Trademark Application Serial No. 85136164, filed September23 23, 2010, for the Infringing Mark BULLOCKS DEPARTMENT STORE for, inter a/ia, retail


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h).S. Trademark Application Serial No. 85137193, filed September24, 2010, for the Infringing Mark THE BON MARCHE for, inter alia, retail departmentstore and on-line retail department store services.

26 . Defendant offers for sale and sells products bearing the Infringing Marks onits website, www.retrodepartmentstores.com , using typestyles which are intentionallyidentical to those used by Macys for its corresponding Heritage Marks. Attached to thisComplaint as Exhibit B is a true and correct copy of the home page of Defendantswww.retrodepartmentstores.com website showing use of the Infringing Marks in theinfringing typestyles.

27 . Defendants typestyles include but are not limited to the following:

ASL

MAY COMPANY


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123456braham & Straus788 .efendant has indicated its intent to use the Infringing Marks for services9 which are identical to services Macys provides - i.e., retail department store services and

10 online retail store services featuring clothing and clothing accessories, cosmetics and11 fragrances, jewelry and home furnishings.129.efendant has stated that its intention is to use Heritage Marks precisely13 because they are famous. Defendant wrote:14trategic Mark LLCs goal is to bring back the old shoppingexperiences and brands you remember.15160.efendant has advertised the Infringing Marks using Macys most iconic17 historic flagship stores, in an apparent attempt to clothe themselves in the associated18 goodwill. Attached to this Complaint as Exhibit C is a representative page from19 Defendants www.retrodepartmentstores.com website which advertises BULLOCKS and20 shows a movie entitled "Bullocks Wilshire, Los Angeles 1930s", with actual footage of21 the famous Bullocks location.221.he use by Defendant of the Infringing Marks has been willful and without23 the consent of Macys.


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create the impression that Defendants goods and services are conducted by or inassociation with Macys (e.g., Defendant may have become part of Plaintiffs storefamily).

3 4 . Upon information and belief, Defendant was aware of Macys proprietaryI rights in the Heritage Marks before Defendant began using the Infringing Marks.

3 5 . Upon information and belief, Defendant is intentionally trying to usurp theI existing and residual goodwill and secondary meaning Of the Heritage Marks.I Defendants web site states:

Now, through Retro Departmentstores.com , we w illbring back nine of the great department stores of the20th century: Joseph Magnin, Bullocks, May,Robinsons May, Jordan Marsh, Filenes, TheBroadway, The BonMarche, and Abraham & Strauss,and re-build and restore these well-loved brands.

I See Exhibit D attached hereto.FIRST CLAIM FOR RELIEF

INFRINGEMENT OF FEDERALLY REGISTERED TRADEMARKS15 U.S.C. 1114

3 6 . Macys incorporates by reference as if fully set forth herein the avermentscontained within the preceding paragraphs 1 through 35, inclusive.

3 7 . Defendant infringes trademarks registered in the United States Patent andI Trademark Office, in violation of the Trademark Act of 1946, 15 U.S.C. 1051, et seq.,particularly under 15 U.S.C. 1114(1).

3 8 . Defendants use of the Infringing Marks is likely to cause confusion andmistake in the minds of the purchasing public, and in particular, tends to and does falsely


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1 intentional.20.s a direct and proximate result of Defendants illegal activities as alleged3 above, Macys has been severely damaged. Defendants acts in infringing Plaintiffs4 Registrations have caused, and will continue to cause, irreparable harm to Plaintiffs5 unless enjoined by this Court.6ECOND CLAIM FOR RELIEF7ALSE DESIGNATION OF ORIGIN AND UNFAIR COMPETITION

15 U.S.C. 1125(a)891.acys incorporates by reference as if fully set forth herein the averments

10 contained within the preceding paragraphs 1 through.40, inclusive.

112 .his Claim arises under the provisions of the Trademark Act of 1946, 15

12 I U.S.C. 1051 et. seq., particularly under U.S.C. 1125(a), and alleges the use in13 commerce of false designations of origin and false descriptions and representations.143.efendants use of the Infringing Marks is likely to create confusion and to15 deceive consumers as to the source of origin, sponsorship and/or authorization of16 Defendants business.174.s more fully set forth above, the Heritage Marks have come to have a18 secondary meaning indicative of origin, relationship, sponsorship, and/or association with19 Plaintiffs. The purchasing public is likely to mistakenly attribute to Plaintiffs the use by20 Defendant of the Infringing Marks as a source of origin, authorization, affiliation, and/or21 sponsorship for Defendants retail department store services, online retail store services,22 and related goods and services and, therefore, to use Defendants services and purchase23 Defendants products in that erroneous belief.


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I and promotion, misrepresents the nature, characteristics, qualities and origin of2 Defendants retail department store services, online retail store services, and related3 goods and services and commercial activities, within the meaning and in violation of 154 U.S.C. 1125(a).56.s a direct and proximate result of Defendants illegal activities as alleged6 above, Macys has been severely damaged. Defendants aforesaid acts have caused,7 and will continue to cause, irreparable harm to Macys unless enjoined by this Court.8HIRD CLAIM FOR RELIEF9EDERAL TRADEMARK DILUTION15 U.S.C. 1125(c)10

117.acys incorporates by reference as if fully set forth herein the averments12 contained within the preceding paragraphs 1 through 46, inclusive.138 .his Claim arises under the provisions of the Trademark Act of 1946, 1514 U.S.C. 1051 et. seq., particularly under 15 U.S.C. 1125(c), and alleges the15 commercial use in commerce by Defendant of the Heritage Marks, resulting in dilution16 thereof.179 .s a result of Macys extensive advertising and promotional efforts, the18 Heritage Marks are recognized nationwide by the trade and purchasing public as19 synonymous with the highest quality goods and services.

50 . The Heritage Marks are famous marks that are of inestimable value toMacys and are relied upon by the trade and the purchasing public to identify anddesignate Macys retail department store services, online retail store services, andrelated goods and services and to distinguish them from the goods and services of

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1 in each case many decades after Macys began use of the corresponding Heritage2 1 Marks.33.efendants store services are of inferior quality, and therefore tarnish4 Macys goodwill in the Heritage Marks.54.pon information and belief, Defendants commercial use of the Infringing6 Marks is continuing with the willful intent to trade upon Plaintiffs reputation and to cause7 dilution of the Heritage Marks, all to the detriment and damage of Plaintiffs.El5.efendants use of the Infringing Marks has caused and/or is likely to cause9 dilution by blurring and/or dilution by tarnishment of the Heritage Marks.

106.s a direct and proximate result of Defendants illegal activities as allegedabove, Plaintiffs have been severely damaged. Defendants aforesaid acts in diluting theHeritage Marks have caused, and will continue to cause, irreparable harm to Plaintiffsunless enjoined by this Court.

FOURTH CLAIM FOR RELIEFCOMMON LAW TRADEMARK INFRINGEMENT AND UNFAIR COMPETITION

57. Macys incorporates by reference as if fully set forth herein the avermentsI contained within the preceding paragraphs 1 through 56, inclusive.

58. This Claim arises under the common law of the State of California andalleges willful and intentional common law trademark infringement and unfair competition

I by Defendant.59. As more fully alleged above, the use by Defendant of the Infringing Marks

I constitutes passing off, unfair methods of competition, unconscionable acts andpractices, and unfair and deceptive acts and practices wherein Defendants conduct is

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II law of the State of California.60. As a direct and proximate result of Defendants illegal activities as alleged

above, Plaintiffs have been severely damaged. Defendants aforesaid acts of unfaircompetition have caused, and will continue to cause, irreparable harm to Plaintiffs unlessenjoined by this Court.

FIFTH CLAIM FOR RELIEFSTATE STATUTORY DILUTIONCalifornia Business and Professions Code 14247

61. Macys incorporates by reference as if fully set forth herein the avermentscontained within the preceding paragraphs 1 through 60, inclusive.

62. The above-described acts and conduct by Defendantncluding withoutlimitation its use of the Infringing Marksare likely to injure the reputation of Macys anddilute the distinctive quality of its famous marks in violation of Section 14247 of theCalifornia Business & Professions Code.

63. By reason of these wrongful acts and conduct Defendant, Macys hassuffered and will suffer damage. Additionally, these wrongful acts and omissions byDefendant have caused, and unless restrained and enjoined by this Court will continue tocause, serious irreparable injury and damage to Macys, the goodwill associated with itsmarks, and to the public. Macys is therefore entitled to injunctive relief, as requested inthis action.

SIXTH CLAIM FOR RELIEFSTATE STATUTORY UNFAIR COMPETITION

California Business and Professions Code 17200 et seq.

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1 above also constitute "unlawful, unfair, or fraudulent business act[s] or practice[s] and2 unfair, deceptive, untrue, or misleading advertising" within the meaning of California3 Business and Professions Code 17200 et seq. Defendants acts and conduct are4 wrongful, knowing, willing, and malicious and constitute unfair competition under5 II California State law.

67.s a direct and proximate result of Defendants illegal activities as allegedabove, Plaintiffs have been severely damaged. Defendants aforesaid acts of unfaircompetition have caused, and will continue to cause, irreparable harm to Plaintiffs unlessenjoined by this Court.

PRAYER FOR RELIEFWHEREFORE, Plaintiffs demand judgment as follows:1 .hat a preliminary and permanent injunction be issued enjoining Defendant

and its agents, servants, employees, attorneys, and all persons in active concert orparticipation with them:

(a ) from using the Heritage Marks or any marks confusingly similarthereto in connection with sale or offering of goods and services;

(b ) from using any logo, trade name, trademark, or service mark, whichmay be calculated to falsely represent or which has the effect offalsely representing that goods and/or services of Defendant aresponsored by, authorized by or in any way associated with Plaintiffs;

(c ) from using the Infringing Marks or from otherwise infringing ordiluting the Heritage Marks; and

(d ) from otherwise unfairly competing with Plaintiffs or infringing

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1.hat Defendant be enjoined from any use of the Infringing Marks on goods2 which are offered for sale or sold.3.hat Defendant be required to pay to Plaintiffs such damages as Plaintiffs4 have sustained as a consequence of Defendants unfair competition and infringement of5 Plaintiffs registered and common law Heritage Marks, and to account to Plaintiffs for all6 gains, profits and advantages derived by Defendant by virtue of its infringement, and/or7 that Plaintiffs be awarded Defendants profits pursuant to 15 U.S.C. 1117 and state8 common and statutory law.9.hat the monetary award to Plaintiffs be increased based on willful

10 infringement pursuant to 15 U.S.C. 1117.11.hat the Court find that the circumstances of the case merit an award of12 damages to Plaintiffs in the amount of three (3) times the amount found as actual13 damages, as specifically provided in 15 U.S.C. 1117.1 4.hat the Court find this case to be exceptional and award reasonable15 attorneys fees to the Plaintiffs.1 6.or such other and further relief as to the Court may deem just and proper17 under the circumstances.1 81 9ATED: December2011ANSON BRIDGETT LLP2021y:22ARN R K. WENGCHRIS OPHER S. W ERS23for PlaintiffsYS, INC. and


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1 DEMAND FOR JURY TRIAL2 Plaintiffs MacyTs, Inc. and Macys.com , Inc. hereby demand a trial by jury of all3 claims so triable.4 DATED: December, 2011 HANSON BRIDGETT LLPB______7 GAR ERK.WECHRI TOP. WA TERS8 or eys forintiffsYS, INC. andMACYS.COM I910

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EXHIBIT A


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EXHIBIT B

Page 1 of 1Retro Department Stores


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Strategic Mark LLCs goal is to bring back the old shopping experiences and brands you remember.Look for a really cool shopping experience coming soon that will bring back choice, selection and service to shopping.

Something we believe has been lost.

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EXHIBIT C



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Bullock'sBullock's was founded in 1907 at Seventh & Broadway in downtown LosAngeles by John G. Bullock. In 1944 Bullock's acquired I. Magnin & Co.This was followed by the acquisition of the then public-owned Bullock's/I.

Magnin organization in 1964 by Federated Department Stores. In the1970s, to differentiate itself from the full-line Bullock's stores, the veryexclusive Wilshire location dropped its apostrophe, became Bullocks

Wilshire, and began its own expansion.

Bullock's, Bullocks Wilshire, and I. Magnin retained their autonomy underFederated, as well as their carriage-trade niche, with I. Magnin expandinginto the Chicago and Washington, D.C. metropolitan areas and Bullock's

opening stores in Phoenix, Las Vegas and Northern California. In 1983however, Federated shut the Bullock's North division and sold most of its

locations to a Seattle, Washington upstart: Nordstrom. In 1996followingthe acquisition of Broadway Stores, Inc.Federated consolidated all its

traditional department-store business in California under the Macy'snameplate, ending 89 years of Bullock's.

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Like 81 people like this.

Copyright 2011 :: Retro Department Stores

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EXHIBIT D



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Abraham & StraussAbraham & Straus (or A&S) was a major New York City departmentstore, based in Brooklyn. Founded in 1865, in 1929 it became part of

Federated Department Stores, which eliminated the A&S brand shortlyafter its 1994 acquisition of R.H. Macy & Company. Most A&S storestook the Macy's name, although a few became part of Stern's, another

Federated division that offered lower-end goods than did Macy's or A&S.

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EXHIBIT E



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Jordan MarshJordan Marsh & Company (or Jordan Marsh) was a department store inBoston, Massachusetts, which grew to be a major regional chain in theNew England area of the United States. In 1996, the last of the JordanMarsh stores were converted to Macy's. The store was formerly part ofAllied Stores and then Federated Department Stores (now Macy's, Inc.).Allied also operated a separate group of stores in Florida called Jordan

Marsh Florida, which were disbanded in 1991.

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EXHIBIT F



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May CompanyThe Robinsons-May name was created in 1993 when the former middle-to-low-brow May Company California consolidated with their carriage-tradecorporate sibling JW Robinson's. Both chains had operated exclusively inSouthern California until 1989 when May Department Stores dissolved its

Goldwaters division, based in Scottsdale, Arizona, and apportioned itsPhoenix metropolitan and Las Vegas, Nevada, stores between the still

separate JW Robinson's and May Company California. In 1993 Robinsons-May absorbed the Tucson-area locations of sister division Foley's, whichwere themselves the remains of the former Levy's stores. Robinsons-Maywas further consolidated with Portland, Oregon-based Meier & Frank in2002, which retained its individual nameplate, but merged its primary

headquarters into Robinsons-May's in North Hollywood.

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EXHIBIT G



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The Bon Marche

The Bon March, whose name means "the good deal" or "the goodmarket", was the name chosen for a department store launched in Seattle,

Washington, United States, in 1890 by Edward Nordhoff. The namecomes from Le Bon March, a noted Paris retailer and one of the world'sfirst department stores, founded 40 years earlier. A solid middle-range

store, The Bon served largely working-class Seattle well; branches wereadded in several Northwestern cities. Among them were Spokane,

Tacoma, Yakima, Kennewick, Longview, Walla Walla, Olympia, andBellingham, Washington, and Boise, Idaho. Commonly known to

customers as The Bon, the company dropped the March from their namein the late 1970s before returning it in the mid-1980s.

The Bon was known for their catchy jingles, such as the following to thetune of "The Banana Boat Song": "Day-o, One Day Sale, One day only at

The Bon March! Save 20, 30, 40 percent (example savings)! Saturdayonly at the Bon Marche. Prices are down in every department! Saturday

only at the Bon Marche!..." This jingle continued after the name waschanged to Bon Macy's, with the appropriate changes.

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EXHIBIT H



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The Broadway

The Broadway was a mid-level department store chain headquartered inLos Angeles, California. Founded in 1896 by English born Arthur Letts,Sr., who later went on to develop Holmby Hills, The Broadway became

one of the dominant retailers in Southern California and the Southwest. In1996 the chain was acquired by Federated Department Stores and themajority of locations were converted to the Macy's nameplate. Several

stores in affluent areas where Macy's already had locations were closed,refurbished and reopened as Bloomingdale's, while Federated sold many

of the remaining stores to Sears.

Though the chain had been closed for over seven years, The Broadway

Building in Hollywood, including its iconic "The Broadway" sign wasfeatured in the climactic final scenes of 2003's Hollywood Homicidemovie starring Harrison Ford.

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EXHIBIT I



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About

Weve heard it countless times before remember the good ole dayswhen it was a treat to shop at our local department store? We miss

those details, such as Joseph Magnins Wolves Den, Jordan Marshsdelicious blueberry muffins, and The Bon Marches catchy jingle.

Bringing Back Nine StoresNow, through Retro Departmentstores.com, we will bring back nineof the great department stores of the 20th century: Joseph Magnin,

Bullocks, May, Robinsons May, Jordan Marsh, Filenes, TheBroadway, The Bon Marche, and Abraham & Strauss, and re-build

and restore these well-loved brands.

The PlanYoull see these stores first as part of this nostalgic virtual mall.

Then we plan to branch out with unique accessories at smallboutiques, followed by exclusive apparel by up and coming

designers, and then ultimately with actual Brick and Mortar storesthroughout the United States with a full line-up of products. Werethrilled to be able to bring back a little part of Americana home so

watch this space for more updates!


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macy's inc. v. strategic marks

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