round star v. creativity soccer stars - super soccer stars trademark non-compete complaint.pdf

8/10/2019 Round Star v. Creativity Soccer Stars - SUPER SOCCER STARS trademark non-compete complaint.pdf

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James D. Weinberger ([email protected])

Jason

D. Jones ([email protected])

FROSS ZELNICK LEHRMAN ZISSU, P.C.

866

United Nations Plaza

New York, New York 10017

Tel: (212)813-5900

Fax: (212)813-5901

Attorneys

for

Round Star Inc

UNITED

STATES DISTRICT

COURT

EASTERN DISTRICT OF NEW

YORK

ROUND STAR, INC.

Plaintiff,

CREATIVITY SOCCERSTARSLLCand

YVENER GUERRIER,

Defendants.

M

CV14-6

Civil

Action

No.:

COMP

JURY

TRI L

C

OREN

Plaintiff

Round Star,

Inc. (hereinafter Plaintiff or Super Soccer S

plaint

against Defendants

Creativity

Soccer Stars LLC ( Creativity

So

Yvener Guerrier

( Guerrier ) (Creativity Soccer

Stars

and

Guerrier

are

refe

hereinafteras Defendants ),respectfullyalleges:

INTRODUCT ION

om


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following

his

termination with

Super

Soccer

Stars, almost

immediately form

Stars and, through

this entity,

began operating a

competing children s

socce

mark CREATIVITY SOCCER STARS in New York City in an

attempt

to r

Stars coattails and

to unfairly benefit

from the renown ofthe SUPER SOC

and program.

Moreover, Guerrier s

operation of the CREATIVITY SOCC

(as

well

as

his

solicitation

of

other former Super Soccer

Stars

coaches to

jo

SOCCER STARS

program) is aviolation ofhis employment agreement wi

which

prohibits

him

from operating

a

competing soccer coaching business i

New

York

City area

for

aperiod

of time

following

his termination

from

Su

from

soliciting

former

Super Soccer

Stars

employees

to

join

a

competing b

2. Accordingly, Super Soccer Stars asserts

claims

for trademar

Section

32(1)

ofthe Lanham

Act,

15U.S.C.

1114(1); unfair competition

the

Lanham

Act, 15

U.S.C.

1125(a);

trademark infringement and unfair c

common law ofNew York; trademark dilution under Section 360-/

ofthe

N

Business

Law; and

breach of

contract.

Super Soccer

Stars seeks

injunctive

ofDefendants

profits

flowing from their use ofthe infringing

marks,

dama

andsuchotherreliefas the

Court deems

just and

proper.

P RT IES

3. Plaintiff, Round

Star,

Inc., is acorporation

organized

under


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New

York

11236.

5. Upon information and belief,

Defendant Yvener

Guerrier

is

a

resident of

New

York and resides at 9215 Avenue A, Brooklyn, New York

information

and

belief, Guerrier is

an

owner and/or principal ofCreativity

S

responsible

for and

controls

the

business

ofCreativity Soccer Stars.

TTTmsniCTION

AND

VENUE

6. This Court has jurisdiction over

the

subject

matter

of

this

act

Section 39 ofthe Lanham Act, 15 U.S.C. 1121, and under Sections 1331,

ofthe Judicial

Code, 28

U.S.C. 1331,

1338(a)

and

1338(b). The Court h

jurisdiction

over

the

state law claims under Section

1367(a)

ofthe

Judicial

1367(a).

7. Venue is proper in this district pursuant

to

Sections 1391 (b)

Code,

28

U.S.C. 1391(b) and (c), because each Defendant

resides

in this

to personal jurisdiction in this district due to their

transacting ofbusiness h

Defendant

has

substantial

contacts

with

this

district, and because

a

substan

events at

issue

have arisen and will arise

in

this judicial district and

Super

S

suffering harm in

this

judicial district.

8. This Court has personal

jurisdiction

over each Defendant un

and/or 302 ofthe New York Civil Practice Laws

and Rules

because (i) eac


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FArTS COMMON TO

ALL

ALLEGATIONS

A. Super Soccer Stars

Business

and Use ofthe SUPER SOCCER S

9. Since

at least as early as September of

2000,

Super Soccer S

soccer

classes,

camps and clinics for children

under

the mark SUPER SOCC

United States,

mainly in

the tri-state

New

York area.

10.

Super Soccer

Stars

goal

is

to

teach children soccer skills

in

competitive, educational environment as well

as

to provide the highest-qual

for children

of

all ages.

11.

To

further

its goal, Super Soccer

Stars

has developed and us

coaching program structure that has largely contributed

to

its

great

success.

Super

Soccer

Stars website explains, all SUPER SOCCER STARS classes

based on age-specific curricula created by acombination ofearly childhoo

behavioral specialists to

guarantee

that each child

is learning

and having a

the

whistle blows. A

true

and

correct

copy ofawebpage from

Super

Socc

www suversoccer

stars com website is

attached

hereto asExhibit

A.

12. As part of

aSuper Soccer

Stars

class,

clinic or camp, childr

and other gifts branded with the SUPER SOCCER

STARS

mark, and all c

SOCCER STARS-branded soccer balls, goals,

coaches

uniforms, and

trai

13. Through long and continuous use,

and

asignificant investm


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14.

In

addition

to

its common law rights

in the

SUPER SOCCER

Super

Soccer Stars is

the owner ofU.S. Trademark Registration

No.

2,674,4

SOCCER

STARS and Design for educational services, namely providing s

instruction services

to

others

in International Class 41, clothing, namely t-

International

Class 25, and sports

equipment,

namely

soccer

balls

in Inter

This

registration

is

valid,

subsisting,

and

in

full

force and

effect.

In

addition

incontestable as to

all goods and

services

listed

therein under Section 15 of

U.S.C.

1065,

meaning that the

registration

is

conclusive

evidence

of Supe

exclusive

right to use the SUPER

SOCCER STARS mark

in commerce

on

the

goods or

services listed in

the

registration,

as

provided by Section

33(b)

15 U.S.C. 1115(b). Aprintout from the United States Patent

and

Tradem

database

reflecting

the

registration identified above is attached hereto

as

Ex

B. Super

Soccer

Stars Employee Agreements

15.

Super Soccer Stars

proprietary coaching

program discussed

inter alia confidential facts, formulas,

methods ofoperation, curricula,

and

16. When an

employee is

hired by

Super Soccer Stars

to

coach

STARS

classes,

clinics

and/or camps, Super Soccer Stars is required

to

sha

Super

Soccer Stars proprietary

coaching program, including such

confiden

methods ofoperation, curricula, and printed materials.


6/31

Stars

employee

during

the term

of their employment with Super Soccer Star

competing

soccer coaching business.

19. The Super Soccer Stars Employee Agreement also

prohibits

Soccer

Stars employee,

following their termination with Super Soccer

Stars

children s

soccer or children s movement and from forming any business

engages

in

the

business

of

children s

soccer or

children s

movement in

any

York City or

the

100 miles

surrounding

New

York

City within the

18 mont

her

termination from Super Soccer Stars unless he or she

obtains

written ap

Soccer Stars. Likewise, the Super Soccer Stars Employee Agreement

proh

Soccer

Stars employee within

18

months

of

his or her termination

from

hiri

hire

any current

or

former employee of

Super Soccer

Stars

to work at a

com

soccer business.

C. Defendants Infringing Use ofCREATIVITY

SOCCER

STARS

Breach

of

His

Super

Soccer

Stars

Employee Agreement

20. In July 2013, Guerrier contacted Super Soccer Stars

via

its w

coach position in the

SUPER SOCCER

STARS

program.

21.

In

response to Guerrier s on-line application, Super Soccer

Programs, Mr. Dean Simpson,

telephoned

Guerrier

in early September

201

telephone interview. During this telephone call, and before Guerrier

signe

Employee Agreement or was hired by Super Soccer Stars,

Mr.

Simpson ad


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STARS program since Guerrier explained

that

he saw the SUPER SOCCER

many places and had

coached

teams playing against SUPER SOCCER

STA

23.

On both

his on-line

application and

during

his

telephone

inte

Simpson, Guerrier assured Super

Soccer

Stars that,

if

he

was

hired, he woul

of availability to coach SUPER SOCCER

STARS

classes, including availab

school

hours

everydayofthe

week.

24.

Super Soccer Stars decided

to

hire

Guerrier as an assistant

co

September 13,

2013,

Guerrier

came

to Super Soccer Stars office and signe

Stars Employee Agreement which included the terms discussed

in

paragrap

25.

Between September

13, 2013

and

October

1,

2013,

Guerrier

SOCCER

STARS classes inNewYorkCity.

26. Almost

immediately after Super Soccer

Stars

hired Guerrier

contrary to Guerrier s representations during the interview process, Guerrie

Soccer Stars

with

only

limited availability

to coach

Super

Soccer Stars clas

example, after Super Soccer Stars

hired

Guerrier, he informed Super Socce

available

to

coach

at

times that he already told Mr. Simpson

he was

availab

some after-school

hours.


Guerrier s

subsequently-revea

availability was

due

to the fact that Guerrier continued to

coach

for the Bro


8/31

29. Upon information and belief, on October

25,2013 (little

more

after his employment

with

Super

Soccer

Stars ended), Guerrier

formed Defe

Soccer Stars

and,

though this entity, began operating

(and

currently still ope

soccer program under

the

mark

CREATIVITY

SOCCER

STARS,

which

bu

Brooklyn borough ofNew

York

City.

30. Upon information and belief, on October 30, 2013, (less than

employment

with

Super

Soccer

Stars

ended), Guerrier purchased

the

domai

www creativitvsoccerstars com

which

is

where

Defendants offer

and prom

CREATIVITY SOCCER STARS program.

31.

According to

their

website,

Defendants

CREATIVITY SO

program offers soccer classes and

clinics

that are open to

welcome

[sic] al

2year old

and

up and

is

a program with soccer activities that are fun, dev

appropriate for children to

stimulate

their

movement

and

spatial

awareness,

peers, learn

the

wonderful

game

of

soccer,

[and]

develop teamwork.

A

tru

a

webpage

from Defendants www creativtvsoccerstars com website is atta

Exhibit C.

In

other words, under their CREATIVITY SOCCER STARS

m

services identical to

(and

competitive with) Plaintiffs SUPER SOCCER S

32. Upon information

and

belief,

Defendants

currently (and stil

covered

by

Guerrier s

Super Soccer Stars Employee

Agreement)

employ

a


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America ( NSCAA )

course

that

was

held at

aSuper

Soccer Stars

facility in

October andearly

November

2013.

33. Super Soccer Stars has not authorized or consented to Defend

CREATIVITY SOCCER STARS

mark or

to

Guerrier s operation

of and

em

CREATIVITY SOCCER STARS program.

34.

In

using

the

mark

CREATIVITY SOCCER STARS - amar

similar

to

Plaintiffs

SUPER SOCCER STARS mark in connection with

classes

services that

are

identical to

and/or

highly related to

goods

and se

Super Soccer Stars under the SUPER SOCCER STARS mark

-

Defendan

willful

disregard

ofthe

laws

protecting

Plaintiffs

rights in

its SUPER SOC

and have undermined and

are

continuing

to

undermine

the

value

ofthe SUP

STARS mark as an

indicator of activities,

goods

and services

that

emanate

Stars.

35.

Defendants infringing

acts

are

likely

to

deceive, mislead

an

concerning

the source or sponsorship of Defendants CREATIVITY SOCC

leading

consumers

to

mistakenly believe that Defendants CREATIVITY S

services come from, or are

otherwise sponsored

by, affiliated with, or

appr

Stars.

36.

Defendants unauthorized use ofthe CREATIVITY SOCCE


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t-shirt that

Super Soccer Stars

coaches wear in

the same

colors

(even though

hundreds

of

available coaching shirt options to

choose

from)

and Defendant

classes the exact same

brand and model of

soccer goals used

by

Super Socc

classes. Such willful

infringement

is also evidenced

by the

fact

that

the

con

.

creativitvsoccerstars

com website copies extensively from Super Socc

WWW

WWW

supersoccerstars com

website.

By

way

of

example,

Defendants

rrpntivitvsoccerstars com

website

bears a large, rotating set of

color

im

playing soccer

that

is substantially similar in

size,

placement and content to

images

featured near

the top

ofSuper Soccer

Stars www super

soccerstars

37.

Based

on

Guerrier s

admitted prior knowledge

of

Plaintiffs

STARS

program and

his

employment with Super Soccer Stars,

Defendants

Super Soccer Stars

rights

to and interest

in

the SUPER SOCCER STARS

ofthe confusingly similar CREATIVITY

SOCCER

STARS mark.

As

am

Defendants were on constructive notice

of

Plaintiff

s

rights in

the

SUPER S

mark based on

Plaintiffs registration for

the same as provided by Section 2

15 U.S.C. 1072.

38. The

use

by

Defendants ofa

mark confusingly similar

to the

STARS

mark

unfairly and unlawfully wrests from Super Soccer

Stars cont

and

reputation. Super Soccer Stars

has

no

control

over the quality

of

Defe


11/31

39.

Accordingly, the goodwill that Plaintiffhas

built up

in its SU

STARS mark through years ofsubstantial investment and effort

is

put

at

risk

Defendants use ofthe confusingly similar CREATIVITY SOCCER STARS

promote its owncompeting soccerprogram.

40. Defendants conduct has caused and, unless enjoined by

this

to

cause, irreparable

injury

to

Plaintiff.

Plaintiff

has

no

adequate remedy

at

C O U N T I

Federal

Trademark

Infringement

By

Both Defendants- 15

U.S

41. Super Soccer Stars repeats and incorporates

by reference

the

paragraphs 1through 40 above

as

if

set

forth fully herein.

42. Defendants unauthorized use ofthe

CREATIVITY

SOCCE

services identical

or

related to those provided by Super Soccer Stars is

likel

or to

cause mistake,

or to

deceive

Defendants customers, potential consum

as to the source or sponsorship

of

Defendants

services.

Consumers

are

lik

believing that

Defendants

services are provided by,

licensed

by, sponsored

otherwise associated with Super Soccer Stars.


Defendants

were on

both

actua

notice

of

Super

Soccer Stars exclusive rights

in the

registered

SUPER SOC

prior

to

their own use ofthe CREATIVITY

SOCCER

STARS mark. Defe

infringing

CREATIVITY SOCCER STARS mark is willful,

in

bad

faith, a


12/31

44. Defendants acts

are

intended

to

reap the benefit ofthe goodw

Soccer

Stars

has

created

in its

SUPER SOCCER

STARS

trademark and con

of

Plaintiff

s

federally-registered

trademark

in

violation ofSection

32(1) of

U.S.C. 1114(1).

45.

Defendants conduct has

caused

and is causing

immediate

an

to

Super Soccer Stars and, unless enjoined by this Court, will continue

to

bo

Soccer

Stars and

deceive

the public. Super Soccer Stars has no

adequate re

C OU N T II

Federal

Unfair

Competition

By Both Defendants - 15 U.S.C.

46. Super Soccer Stars repeats and realleges paragraphs

1

throug

set forth herein.

47. Defendants

use

ofthe CREATIVTY SOCCER STARS ma

designation

of origin

and afalse

representation

with respect to the

origin

of

Defendants use ofthe CREATIVITY SOCCER STARS mark

is likely

to

c

mistake, or deception as to the source of

Defendants

services and is

likely

impression

that

Defendants

are affiliated with Super Soccer Stars or that th

authorized, sponsored, endorsed,

licensed by, or affiliated

with Super Socc

48.

Defendants

actions

constitute unfair competition

in

violatio

the LanhamAct, 15U.S.C. 1125(a).

49.

Defendants

conduct has caused and

is

causing

immediate a


13/31

COUNT

II I

Common Law Trademark

Infringement

and Unfair Competition

By

50.

Super Soccer Stars

repeats

and

realleges paragraphs

1

throug

se t forth herein.

51. Defendants

have

used the confusingly similar

CREATIVITY

mark with full knowledge of Super Soccer

Stars

prior rights in

the SUPER

mark

and

ofthe

success and renown

of

Super Soccer

Stars

services sold un

SUPER

SOCCER STARS

mark. Defendants use ofa

mark

confusingly si

Stars mark is for the willful and calculated purpose of

misappropriating

an

Soccer Stars goodwill and business reputation. Furthermore, Defendants h

confusingly similar

to Super Soccer Stars mark for

the

willful

and

calcula

confusion

and mistake among the

public

and

of

deceiving the

public as to t

ofDefendants services in violation ofSuper

Soccer

Stars rights

under the

state

of

New

York.

52. Upon information and belief, Defendants were on

notice

of

exclusive rights in the

SUPER

SOCCER STARS mark before adopting

the

CREATIVITY SOCCER STARS mark

by virtue

ofGuerrier s employmen

Stars

and

by virtue

of

Super Soccer

Stars

federal trademark

registration

fo

SOCCER

STARS mark.

As aresult, Defendants adoption ofaconfusing

SUPER

SOCCER

STARS mark is willful, in bad faith and

with

full know


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53. The aforesaid conduct ofDefendants constitutes

unfair comp

infringement

under the common law

ofthe

State

of

New York.

54. Defendants conduct has caused

and

is causing immediate an

to

Super Soccer Stars

and will continue to both damage Super Soccer

Stars

public unless enjoined by this

Court.

Super Soccer Stars

has

no adequate re

COUNT

IV

Dilution Under

New

York

Law

By

Both

DefendantsN.Y.

Gen. B

55.

Super

Soccer

Stars

repeats

and

realleges paragraphs

1

throug

set forth herein.

56. As

a

result

of

extensive use and promotion ofthe SUPER SO

and the

services

offered thereunder by Super Soccer Stars for more than

a

d

SOCCER

STARS

mark

is

highly distinctive of

Super Soccer Stars

service

recognized

among the

consuming public

as

a

designation

of

source

of

Supe

services.

The

SUPER SOCCER

STARS

mark

was

distinctive

and widely

Defendants commenced their

unauthorized

use ofthe substantially

similar

SOCCERSTARSmark as described herein.

57. Defendants unauthorized use the CREATIVITY SOCCER

diluting and

is

likely

to

continue

diluting

the SUPER SOCCER

STARS

m

distinctiveness thereof and is

likely

to injure Super Soccer

Stars

business

removed Super

Soccer

Stars

reputation

from its own control and that

defi


15/31

public unless enjoined by this Court. Super Soccer Stars has no adequate re

COUNT

V

(Breach of Contract by Guerrier)

59.

Super Soccer Stars repeats and realleges paragraphs 1throug

set forth herein.

60. Guerrier

entered

into a Super

Soccer

Stars

Employee

Agreem

13,

2013 and isboundby the terms of thatcontract.

61. Less than one month

after

his employment with Super Socce

Guerrier

formed and began operating (and

still operates)

Creativity

Soccer

entity that

engages

in children s soccer

instruction

in Brooklyn, New

York.

direct

violation

ofthe terms of Guerrier's

Super

Soccer Stars Employee

Ag

62. Through his

CREATIVITY

SOCCER STARS business,

Gu

employs Mr. Sidorski,

a

former

Super Soccer

Stars coach who

Guerrier

kne

Super Soccer

Stars

employee,

by virtue of

working

with Mr. Sidorski

at Su

partneringwith

Mr.

Sidorski

at an NSCAA course taken bybothmen at aS

facility. Such conduct is in

direct

violation ofthe terms ofGuerrier s Supe

Employee Agreement.

63.

Theaforesaid conduct of Guerrier constitutes breachof

con

64.

As

a direct and proximate result of

Guerrier s breach

ofcon

Stars

has suffered

and

continues

to

suffer immediate

and

irreparable injury


16/31

WHEREFORE, PlaintiffRound Star,

Inc.

respectfully demands jud

1)

That a

permanent

injunction

be issued enjoining Defendants

jo

and any oftheir officers, agents, privies, shareholders, principals, directors,

servants, employees,

affiliates,

subsidiaries, successors and assigns,

and

all

concert orparticipation with

any

of

them,

and any entity owned orcontrolle

by any ofthe Defendants,

from:

(a) imitating, copying ormaking unauthorized use ofthemark

STARS, orany

simulation,

reproduction, copy,

colorable i

confusingly similar

variation ofthe SUPER SOCCER STA

CREATIVITY SOCCER

STARS

(anysuchmark, a Proh

as part of

any

corporate name, trademark, service mark, do

name, business

name,

fictitious name, or

otherwise

present

includes inwhole orinparta Prohibited Mark onorin con

goods,

businesses

or

services offered

by

Defendants

or

the

promotion thereof;

(b)

using aProhibited Mark to refer to

or

describe any produc

offered byor

on

behalf ofDefendants orany individual, en

party affiliatedwith Defendants;

(c)

using a

Prohibited

Mark in

or as part

of

any

domain name,


17/31

(d) applying to register or registering in theUnited States Pate

Office, or in anystatetrademark registry, anyProhibited

M

CREATIVITY SOCCER STARS

mark;

(e)

using

a Prohibited Mark in connection with thepromotion,

offering for saleor the provisionof any goods or services;

(f)

engaging in any other activity constituting unfair competiti

constituting an infringement ofthe

SUPER SOCCER STA

(g) instructing, assisting,

aiding or abetting any

other person

o

engaging

inorperforming anyofthe activities referred toi

through (f) above.

2)

Directing that Defendants deliver up

to Super

Soccer Stars a

destruction all goods, labels, tags,

signs,

stationery, prints, packages, promo

materials,

advertisements

and

other materials

currently in

their possession

o

incorporating, featuring

or

bearing

the CREATIVITY SOCCER

STARS

m

incorporate,

feature

or

bear any

simulation, reproduction, copy, colorable im

confusingly similar

variation

ofthe SUPER SOCCER STARS

mark.

3)

Directing

such

other relief as the

Court

may

deem

appropria

public from

deriving the erroneous

impression that any

service

offered

or p

Defendants within the UnitedStates is authorizedby Super SoccerStars or


18/31

5)

That

an

injunction

be

issued enjoining

Guerrier, and any ofhis

shareholders, principals, directors, licensees,

attorneys,

servants, employees

subsidiaries, successors andassigns, andall those persons in concert or part

and any

entity

owned or

controlled

inwhole orin

part

byhim,

from

instruc

or children's movement classes or from operating a business thatoffers the

of

New

York City or

within 100

miles of

any

Super Soccer Stars

location

o

City

until the

expiration ofGuerrier s

obligations under

his Super

Soccer

S

Agreement

on

April

1,

2015 and

from

otherwise engaging in any other con

breach

of

Guerrier's Super Soccer Stars Employee Agreement.

6)

Awarding

Super

Soccer

Stars such damages

it

has

sustained

reasonof Defendants' acts of trademark infringement andunfair competitio

breach o f

contract.

7)

Awarding Super Soccer Stars all gains, profits, property and

by

Defendants

from

their

unlawful

conduct

and,

pursuant

to

15

U.S.C.

11

Soccer Stars an amount

up

to three times the amount ofactual damages sus

Defendants violation ofthe

Lanham Act.

8)

Awarding

to

Super Soccer Stars exemplary and punitive

dam

further willful trademark infringement as theCourtfinds appropriate.

9) Awarding to

Super

Soccer

Stars

its costs and disbursements


19/31

11)

Awarding to Super

Soccer

Stars such

other

and further relief

deem

just

and proper.

JURY TR I L DEM ND

Plaintiff demands a jury trial in this action.

FROSS

ZELNICK LEHRMAN Z

Dated: November 13, 2014 By:

James/ty

Weinberger

(jweinb/rier@

Jason V Jones (jjones@fross^lnick.

866

United Na tions Plaza

New

York,

New

York

10017

Tel: (212)813-5900

Fax: (212)813-5901

Attorneys

for l intiffRound Star

In


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round star v. creativity soccer stars - super soccer stars trademark non-compete complaint.pdf

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