20SMCV00878

Assigned for all purposes to: Santa Monica Courthouse, Judicial Officer: H. Ford III

Electronically FILED by Superior Court of California, County of Los Angeles on 07/01/2020 11:26 AM Sherri R. Carter, Executive Officer/Clerk of Court, by S. Watson,Deputy Clerk

FARHAD NOVIAN (SBN 118129)

1 SHARON RAMINFARD (SBN 278548)
NOVIAN & NOVIAN, LLP
2 1801 Century Park East, Suite 1201
Los Angeles, CA 90067
3 Telephone: (310) 553-1222
Facsimile: (310) 553-0222
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Attorneys for Plaintiff DMH Aesthetics, LLC
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8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
9 FOR THE COUNTY OF LOS ANGELES
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11 DMH Aesthetics, LLC, a California limited ) Case No.:
12 liability company, )
) PLAINTIFF’S COMPLAINT FOR:
13 Plaintiff, ) 1. Trademark Infringement
) 2. Trademark Dilution
14 vs. ) 3. Trade Dress Infringement
15 ) 4. Trade Dress Dilution
Goodskin Clinics, an unknown California ) 5. Unfair Competition
16 business entity; Lisa B. Goodman, )
individually and as trustee of the Lisa B. )
17 Goodman Separate Property Trust; Lauren )
18 Pack, an individual; Leif Rogers, an )
individual, and DOES 1 through 50, inclusive, )
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Defendants. )
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COMPLAINT
 1 Plaintiff DMH Aesthetics, LLC (“Plaintiff”), complaining of the defendants Goodskin Clinics, an
2 unknown California business entity; Lisa B. Goodman, individually and as trustee of the Lisa B. Goodman
3 Separate Property Trust (the “Goodman Trust”); Lauren Pack, an individual; Leif Rogers, an individual
4 (collectively, Goodskin Clinics, Lisa B. Goodman, as trustee of the Goodman Trust, Lisa B. Goodman,
5 Lauren Pack, and Leif Rogers; and DOES 1 through 50, inclusive (collectively, “Defendants”),
6 respectfully alleges as follows:
7 THE PARTIES
8 1. Plaintiff DMH Aesthetics, LLC (“Plaintiff”) is a California limited liability company with
9 its principal place of business in the County of Los Angeles, State of California.
10 2. Plaintiff is informed and believes, and thereon alleges, that Defendant Goodskin Clinics
11 (“Goodskin”) is, and at all relevant times was, an unknown California business entity doing business
12 within the jurisdiction of this Court. Upon information and belief, Goodskin’s principal place of business
13 is in Los Angeles, California.
14 3. Plaintiff is informed and believes, and thereon alleges, that Defendant Lisa B. Goodman is
15 an individual domiciled in and, at all relevant times, conducting business in the County of Los Angeles,
16 State of California. Plaintiff is informed and believes, and thereon alleges that Lisa B. Goodman, at all
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relevant times, was and continues to be an owner, officer, director, and/or manager of Goodskin, as well
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as trustee of the Goodman Trust.
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4. Plaintiff is informed and believes, and thereon alleges, that Defendant Lauren Pack is an
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individual domiciled in and, at all relevant times, conducting business in the County of Los Angeles, State
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of California. Plaintiff is informed and believes, and thereon alleges that Lauren Pack, at all relevant times,
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was and continues to be an owner, officer, director, and/or manager of Goodskin.
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5. Plaintiff is informed and believes, and thereon alleges, that Defendant Leif Rogers is an
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individual domiciled in and, at all relevant times, conducting business in the County of Los Angeles, State
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of California. Plaintiff is informed and believes, and thereon alleges that Leif Rogers, at all relevant times,
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was and continues to be an owner, officer, director, and/or manager of Goodskin.
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6. The true names or capacities, whether individual, corporate, associate or otherwise, of
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COMPLAINT
 1 Defendants Does 1 through 50, inclusive, are unknown to Plaintiff, which therefore sues said defendants
2 by such fictitious names. Plaintiff is informed and believes and based thereon alleges that each defendant
3 herein designated as a Doe is responsible in some manner for the events, acts and happenings referred to
4 herein, and, accordingly, Plaintiff will amend this complaint to show such true names and capacities when
5 the same have been ascertained.
6 7. Upon information and belief, at all times mentioned herein, Defendants, and each of them,
7 were agents, servants, representatives, joint venturers, partners, alter egos and/or employees of said co-
8 defendants, and in doing the things hereinafter alleged, were acting within the course and scope of their
9 authority as agents, servants, representatives, joint venturers, partners, alter egos and/or employees and
10 with the permission and consent of said co-defendants, each co-defendant having ratified the acts of the
11 other co-defendant.
12 8. Upon information and belief, Defendants are the alter egos of each other, are characterized
13 by a unity of interest in ownership and control among themselves such that any individuality and
14 separateness between them have ceased; that each is, and at all relevant times was, a mere shell
15 instrumentality and conduit through which the other said defendants carried on their business; and that
16 Defendants completely controlled, dominated, managed, and operated each other's business to such an
17 extent that any individuality or separateness of these defendants does not and did not exist, and
18 intermingled the assets of each to suit the convenience of themselves in order to evade payment of
19 obligations and legal liability.
20 9. Upon information and belief, adherence to the fiction of separate existence of the
21 Defendants as entities distinct and separate from one another would promote injustice in that some of
22 these defendants have used the other defendants as a mere shell, simply to transfer the earnings of one
23 another while attempting to avoid legal liability. As such, Plaintiff is informed and believes, and on such
24 information and belief alleges, that Defendants are the alter egos of each other and are responsible in
25 damages to Plaintiff to the full extent of all other said defendants' liability.
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COMPLAINT
 1 FACTUAL BACKGROUND
2 10. Plaintiff manages a medical clinic specializing in cosmetic and aesthetic treatments for
3 high-profile clientele and celebrities.
4 11. In connection with its business, in or about late 2018, Plaintiff designed a unique face shield
5 with distinctive built in LED colored lights (“Plaintiff’s Shield”):
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20 12. Plaintiff’s Shield has special settings that cause the display of three different colors of lights
21 (red, blue, and amber).
22 13. In February 2019, Plaintiff began advertising, displaying, and selling Plaintiff’s Shield in
23 commerce throughout the United States including, but not limited to, on Plaintiff’s website,
24 dmhaesthetics.com, and social media pages.
25 14. Since February 2019, Plaintiff’s Shield was advertised, displayed and sold in connection
26 with Plaintiff’s DMH AESTHETICS word mark and stylized mark (in gold foil) as well various other
27 stylized design marks including, but not limited to, the following shield design (“Shield Logo”):

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COMPLAINT
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9 15. Plaintiff’s DMH AESTHETICS marks and the Shield Logo (collectively, the
10 “Trademarks”) appear repeatedly on Plaintiff’s product packaging, website, social media, and other
11 marketing and advertising materials for Plaintiff’s Shield. The Shield Logo is displayed in various colors
12 and is most frequently used in a very specific pinkish red tone. For instance, the Shield Logo is
13 prominently displayed in the red tone on the front of each box for Plaintiff’s Shield. The Shield Logo is
14 also commonly displayed in the three colors red, blue, and yellow, side-by-side. Examples of the various
15 displays of Plaintiff’s Shield Logo can be seen on the mockup box for Plaintiff’s Shield:
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COMPLAINT
 1 16. In addition to its Trademarks, Plaintiff has continuously used its trade dress including, but
2 not limited to, the trade dress in the distinctive design of Plaintiff’s Shield and Plaintiff’s product
3 packaging (“Trade Dress”) as a source identifier for Plaintiff’s goods and services, since at least as early
4 as February 2019.
5 17. Since February 2019, Plaintiff has continuously sold, licensed, or otherwise exploited
6 Plaintiff’s Shield to Plaintiff’s clients and third-party retailers.
7 18. Plaintiff’s Shield quickly gained popularity and fame as numerous celebrities posted
8 pictures and videos displaying Plaintiff’s Shield on their social media pages. The pictures and videos
9 posted by these celebrities often also displayed the box or other product packaging for Plaintiff’s Shield,
10 making Plaintiff’s Trademarks and Trade Dress clearly visible by the viewers.
11 19. On or about April 20, 2020, Plaintiff entered into an exclusive third-party retailer
12 agreement, granting the retailer the right to market, promote and exclusively sell Plaintiff’s Shield.
13 20. Soon thereafter, Plaintiff’s Shield gained even more success and fame, as more celebrities
14 (some with over 150 million followers) began posting pictures and videos of Plaintiff’s Shield and/or
15 packaging on their personal Instagram pages.
16 21. In or about June 2020, Plaintiff learned that Defendants were unlawfully selling face
17 shields that looked identical to or otherwise confusingly similar to Plaintiff’s Shield (the “Infringing
18 Shields”).
19 22. Not only did Defendants unlawfully display and sell the Infringing Shields, but Defendants
20 also blatantly copied Plaintiff’s product packaging, including Plaintiff’s well-known Shield Logo (in the
21 same exact colors as Plaintiff) as well as Plaintiff’s signature gold foil lettering. (The Infringing Shields
22 and their product packaging, including the boxes and materials therein, are collectively referred to herein
23 as “Infringing Products”).
24 23. Defendants, and each of them, have displayed, marketed, and offered Infringing Products
25 on their websites and social media pages (namely Instagram) including but not limited to Defendants’ web
26 domain, goodskinclinics.com, and Instagram page, goodskinclinics.
27 24. Defendants have also repeatedly used and, upon information and belief, continue to use,

28 photographs and videos of Plaintiff’s celebrity business affiliates, endorsers, and/or friends (without their

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COMPLAINT
 1 or Plaintiff’s knowledge or permission) that display Plaintiff’s Shield, the Trademarks and/or Trade Dress.
2 25. In addition, upon information and belief, Defendants directly pursued, and continue to
3 pursue, the customers of Plaintiff and/or Plaintiff’s authorized retailers with targeted Internet and social
4 media advertisements.
5 26. Furthermore, Defendants intentionally led third parties to believe that the Infringing
6 Products are the same as Plaintiff’s Shields, that Plaintiff is the source of the Infringing Shields, and that
7 the Defendants are affiliated with Plaintiff. In fact, Defendants explicitly stated in an Instagram post, that
8 the Infringing Shields “are the same exact ones” as Plaintiff’s Shields. Defendants even went so far as to
9 direct their followers to Plaintiff’s own website for more information on the shield by stating, “For more
10 information on the mask, go to https://www.dmhaesthetics.com/product/light-shield/”.
11 27. On or about May 28, 2020, Plaintiff, through its counsel, delivered via email, Federal
12 Express, and personal delivery a letter to Defendants on or about May 28, 2020. In the letter, Plaintiff
13 informed Defendants of their unlawful conduct and the infringing nature of the Infringing Shields and the
14 Infringing Products. Plaintiff expressly demanded, among other things, that Defendants immediately cease
15 and desist from using, copying, reproducing, distributing, displaying, ordering, purchasing,
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manufacturing, offering for sale or advertising the Infringing Products in any way. Plaintiff also
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demanded that Defendants provide Plaintiff’s counsel with a written accounting of each and every use of
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the Infringing Products Defendants, and any person or entity working with or for Defendants, and to
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provide Plaintiff’s counsel with the names, addresses, and contact information for the manufacturers,
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stores, websites, and companies used by Defendants in connection with the Infringing Products. Plaintiff
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further demanded that Defendants provide Plaintiff’s counsel with copies of all sales receipts, invoices,
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customer records, accounting records, and inventories of and relating to the Infringing Products.
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28. To date, Plaintiff has not received any of the information or documents requested from
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25 Defendants. In addition, to date, each of the Defendants continue to advertise, display, and sell the

26 Infringing Products and continues to infringe upon Plaintiff’s Trademarks and Trade Dress.

27 29. Plaintiff received a letter dated June 1, 2020, from counsel representing Defendants Lisa

28 B. Goodman, Lauren Pack, and Leif Rogers. Said counsel confirmed receipt of Plaintiff’s cease and desist

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COMPLAINT
 1 letter and admitted to the wrongful conduct. Nonetheless, Defendants did not provide and, to date, still
2 have not provided any of the information or documents requested of them. Instead, Defendants continue
3 to advertise, display, and sell the Infringing Products and continue to infringe upon Plaintiff’s trademark,
4 trade dress, and copyrights related to Plaintiff’s Shield.
5 30. Upon information and belief, Defendants, and each of them, have and, to date, still are
6 manufacturing, advertising, promoting, displaying, shipping, offering for sale, selling, and/or distributing
7 Infringing Products at least throughout the United States, including but not limited to within this judicial
8 district.
9 31. Upon information and belief, Defendants, and each of them, have and continue to infringe
10 upon and dilute Plaintiff’s Trademarks and Trade Dress, at least throughout the United States, including
11 but not limited to within this judicial district.
12 32. Upon information and belief, Defendants are engaging in such unlawful conduct in an
13 attempt to unlawfully benefit from Plaintiff’s fame and success. Defendants have willfully and unlawfully
14 diverted Plaintiff’s current and prospective clients to Defendants’ own benefit and misled and confused
15 customers to believe that Defendants are affiliated with Plaintiff.
16 33. As a result of Defendants’ wrongful conduct, Defendants have caused and, unless
17 restrained, will continue to cause great and irreparable injury to Plaintiff, Plaintiff’s business, and to the
18 goodwill and reputation of Plaintiff.
19 34. Therefore, Plaintiff had no choice but to file this lawsuit to prevent further harm to its
20 business and seek damages, injunctive relief, and other appropriate remedies.
21 FIRST CAUSE OF ACTION
22 (Trademark Infringement – Against All Defendants and Does 1-50)
23 35. Plaintiff hereby realleges and incorporates the allegations contained in the preceding
24 paragraphs as if fully set forth herein.
25 36. Since at least as early as February 2019, Plaintiff has continuously used its Trademarks,
26 including but not limited to, DMH AESTHETICS and the Shield Logo, in commerce throughout all of the
27 United States, including this judicial district, in connection with and as a source identifier for Plaintiff’s
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COMPLAINT
 1 goods and services.
2 37. As a result, Plaintiff has established common law trademark rights in its Trademarks.
3 38. Defendants have made use of Plaintiff’s Trademarks, without Plaintiff’s consent,
4 knowledge, or authority.
5 39. Defendants’ unauthorized use of Plaintiff’s Trademarks in connection with Defendants’
6 marketing and sales of the Infringing Products constitutes infringement of Plaintiff’s common law
7 trademark rights, misappropriates the valuable goodwill developed by Plaintiff in the mark, and is likely
8 to cause (and has actually caused) confusion, mistake, and/or deception among the relevant public as to
9 the source of Defendants’ goods and services or their affiliation, sponsorship or approval of Defendants’
10 Infringing Products by Plaintiff and/or Plaintiff’s business affiliates, advertisers, and retailers.
11 40. Defendants’ acts constitute the use in commerce of false designations of origin and false
12 and/or misleading descriptions or representations, tending to describe and/or represent, in a false or
13 misleading fashion, Defendants’ products as those of Plaintiff’s.
14 41. Plaintiff has earlier established, superior rights in its Trademarks.
15 42. Defendants are aware of Plaintiff’s use and corresponding rights in the Trademarks.
16 Defendants’ aforementioned acts constitute the use of Plaintiff’s exact Trademarks for identical or
17 substantially similar goods and services, amounting to willful infringement of Plaintiff’s trademark rights.
18 43. Defendants acts of willful infringement of Plaintiff’s rights in the Trademarks have caused
19 and, unless restrained, will continue to cause great and irreparable injury to Plaintiff, Plaintiff’s business,
20 Plaintiff’s business relationship with its retailers, and to the goodwill and reputation of Plaintiff, leaving
21 Plaintiff no adequate remedy at law.
22 44. Defendant’s acts are the proximate cause of such injury and damage.
23 45. By reason of the foregoing, Plaintiff is entitled to preliminary and permanent injunctive
24 relief against Defendants, and anyone acting in concert with Defendants, to restrain further acts of
25 infringement of Plaintiff’s rights and, after trial, to recover any damages proven to have been caused by
26 reason of Defendant’s aforesaid acts of infringement and any enhanced damages justified by the willful
27 and intentional nature of such acts.

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COMPLAINT
 1 SECOND CAUSE OF ACTION
2 (Trade Mark Dilution – Against All Defendants and Does 1-50)
3 46. Plaintiff hereby realleges and incorporates the allegations contained in the preceding
4 paragraphs as if fully set forth herein.
5 47. Plaintiffs’ Trademarks are famous and distinctive and have garnered widespread publicity
6 and public recognition in California and nationwide.
7 48. Defendants’ use of the Trademarks in connection with the manufacture, advertisement,
8 promotion, display, shipment, offering for sale, sale, and distribution of the Infringing Products began
9 after the Trademarks became well-known, distinctive, and famous in California and throughout the United
10 States.
11 49. Defendants’ unlawful use of the Trademarks dilutes the distinctive quality of the
12 Trademarks and lessens the capacity of the Trademarks to serve as a unique identifier of Plaintiff’s
13 products, in violation of Cal. Bus. & Prof. Code § 14247.
14 50. Upon information and belief, Defendants willfully intended to trade on the reputation and
15 goodwill associated with the Trade Dress and to cause dilution of the Trademarks.
16 51. Defendants’ dilution has caused and, unless restrained and enjoined by this Court, will
17 persist and will continue to cause great and irreparable injury to Plaintiff, Plaintiff’s business, and to the
18 goodwill and reputation of Plaintiff, leaving Plaintiff no adequate remedy at law.
19 52. Defendant’s acts are the proximate cause of such injury and damage.
20 53. By reason of the foregoing, Plaintiff is entitled to preliminary and permanent injunctive
21 relief against Defendants, and anyone acting in concert with Defendants, to restrain further acts of
22 infringement of Plaintiff’s rights and, after trial, to recover any damages proven to have been caused by
23 reason of Defendant’s aforesaid acts of dilution and any enhanced damages justified by the willful and
24 intentional nature of such acts.
25 THIRD CAUSE OF ACTION
26 (Trade Dress Infringement – Against All Defendants and Does 1-50)

27 54. Plaintiff hereby realleges and incorporates the allegations contained in the preceding

28 paragraphs as if fully set forth herein.

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COMPLAINT
 1 55. Since at least as early as February 2019, Plaintiff has continuously used its Trade Dress,
2 including but not limited to, the trade dress in Plaintiff’s Shield and Plaintiff’s product packaging, in
3 commerce throughout all of the United States including this judicial district, in connection with and as a
4 source identifier for Plaintiff’s goods and services.
5 56. As a result, Plaintiff has established common law trade dress rights in its Trade Dress.
6 57. Plaintiff’s Trade Dress is inherently distinctive and/or has acquired distinctiveness and
7 secondary meaning resulting from the great recognition and attention that Plaintiff’s Shield has attained
8 and the frequent celebrity posts of photographs and videos displaying Plaintiff’s Trade Dress.
9 58. Defendants have made use of Plaintiff’s Trade Dress, without Plaintiff’s consent,
10 knowledge, or authority.
11 59. Defendants’ unauthorized use of Plaintiff’s Trade Dress in connection with Defendants’
12 marketing and sales of the Infringing Products constitutes infringement of Plaintiff’s common law trade
13 dress rights, misappropriates the valuable goodwill developed by Plaintiff in the Trade Dress, and is likely
14 to cause (and has actually caused) confusion, mistake, and/or deception among the relevant public as to
15 the source of Defendants’ goods and services or their affiliation, sponsorship or approval of Defendants’
16 Infringing Products by Plaintiff and/or Plaintiff’s business affiliates, advertisers, and retailers.
17 60. Defendants’ acts constitute the use in commerce of false designations of origin and false
18 and/or misleading descriptions or representations, tending to describe and/or represent, in a false or
19 misleading fashion, Defendants’ products as those of Plaintiff’s, resulting in blurring and/or tarnishment
20 of Plaintiffs’ Trade Dress.
21 61. Plaintiff has earlier established, superior rights in its Trade Dress.
22 62. Defendants are aware of Plaintiff’s use and corresponding rights in the Trade Dress.
23 Defendants’ aforementioned acts constitute the use of Plaintiff’s Trade Dress for identical or substantially
24 similar goods and services, amounting to willful infringement of Plaintiff’s trade dress rights.
25 63. Defendants acts of willful infringement of Plaintiff’s rights in the Trade Dress have caused
26 and, unless restrained, will continue to cause great and irreparable injury to Plaintiff, Plaintiff’s business,
27 Plaintiff’s business relationship with its retailers, and to the goodwill and reputation of Plaintiff, leaving

28 Plaintiff no adequate remedy at law.

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COMPLAINT
 1 64. Defendant’s acts are the proximate cause of such injury and damage.
2 65. By reason of the foregoing, Plaintiff is entitled to preliminary and permanent injunctive
3 relief against Defendants, and anyone acting in concert with Defendants, to restrain further acts of
4 infringement of Plaintiff’s rights and, after trial, to recover any damages proven to have been caused by
5 reason of Defendant’s aforesaid acts of infringement and any enhanced damages justified by the willful
6 and intentional nature of such acts.
7 FOURTH CAUSE OF ACTION
8 (Trade Dress Dilution under California Business & Professions Code Section 14247
9 – Against All Defendants and Does 1-50)
10 66. Plaintiff hereby realleges and incorporates the allegations contained in the preceding
11 paragraphs as if fully set forth herein.
12 67. Plaintiffs’ Trade Dress is famous and distinctive and have garnered widespread publicity
13 and public recognition in California and nationwide.
14 68. Defendants’ use of the Trade Dress in connection with the manufacture, advertisement,
15 promotion, display, shipment, offering for sale, sale, and distribution of the Infringing Products began
16 after the Trade Dress became well-known, distinctive, and famous in California and throughout the United
17 States.
18 69. Defendants’ unlawful use of the Trade Dress dilutes the distinctive quality of the Trade
19 Dress and lessens the capacity of the Trade Dress to serve as a unique identifier of Plaintiff’s products, in
20 violation of Cal. Bus. & Prof. Code § 14247.
21 70. Upon information and belief, Defendants willfully intended to trade on the reputation and
22 goodwill associated with the Trade Dress and to cause dilution of the Trade Dress.
23 71. Defendants’ dilution has caused and, unless restrained and enjoined by this Court, will
24 persist and will continue to cause great and irreparable injury to Plaintiff, Plaintiff’s business, and to the
25 goodwill and reputation of Plaintiff, leaving Plaintiff no adequate remedy at law.
26 72. Defendant’s acts are the proximate cause of such injury and damage.
27 73. By reason of the foregoing, Plaintiff is entitled to preliminary and permanent injunctive

28 relief against Defendants, and anyone acting in concert with Defendants, to restrain further acts of

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COMPLAINT
 1 infringement of Plaintiff’s rights and, after trial, to recover any damages proven to have been caused by
2 reason of Defendant’s aforesaid acts of dilution and any enhanced damages justified by the willful and
3 intentional nature of such acts.
4 FIFTH CAUSE OF ACTION
5 (Unfair Competition, California Business & Professions Code § 17200
6 – Against All Defendants and Does 1-50)
7 74. Plaintiff hereby realleges and incorporates the allegations contained in the preceding
8 paragraphs as if fully set forth herein.
9 75. Defendants’ conduct, as alleged herein, is unlawful and Defendants engaged in such
10 conduct without privilege, justification or excuse.
11 76. Defendants’ misconduct constitutes an “unlawful, unfair or fraudulent business act or
12 practice” in violation of California Business & Professions Code § 17200 et seq.
13 77. Defendants’ conduct has directly and proximately caused and will continue to cause
14 Plaintiff substantial and irreparable injury, including customer confusion, injury to its reputation, and
15 diminution in value of its intellectual property, and unless restrained, will continue to seriously and
16 irreparably impair further the value of Plaintiffs Trademarks and Trade Dress, for which there is no
17 adequate remedy at law.
18 78. In light of the foregoing, Plaintiff is entitled to an injunction under Cal. Bus. & Prof. Code
19 §§ 17200 et seq. restraining Defendants from engaging in further such unlawful conduct, as well as
20 restitution of those amounts unlawfully obtained by Defendants through their wrongful conduct.
21 PRAYER FOR RELIEF
22 WHEREFORE, Plaintiff prays for judgment in favor of Plaintiff and against Defendants:
23 A. That Defendants and their respective owners, officers, agents, servants, employees, and
24 attorneys, and all other persons in active concert or participation with them, be preliminarily and then
25 permanently restrained and enjoined from:
26 1. Manufacturing, advertising, promoting, displaying, shipping, offering for sale, selling, or
27 distributing the Infringing Products;

28 2. Manufacturing, advertising, promoting, displaying, shipping, offering for sale, selling, or

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COMPLAINT
 1 distributing any other face shield or face mask bearing Plaintiff’s Trademarks or Trade
2 Dress, or any other copy, reproduction, or colorable imitation thereof, or any other mark or
3 trade dress that is confusingly similar thereto; and
4 3. Doing any other act or thing that is likely to cause persons to believe that Defendants’
5 goods or commercial activities originate with, or are licensed, sponsored, or authorized by,
6 Plaintiff;
7 B. That Defendants be ordered, jointly and severally, to account for and pay to Plaintiff all of
8 their profits from the sale of the Infringing Products or any other products bearing the Trademarks or
9 Trade Dress;
10 C. Compensatory, punitive, exemplary, consequential, incidental, and/or special damages, in
11 an amount to be determined at trial;
12 D. Restitution;
13 E. Pre-judgment and post-judgment interest;
14 F. Costs of suit incurred herein, including attorney's fees and expenses; and
15 G. Such other and further relief as the Court deems just and proper.
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DATED: June 29, 2020 NOVIAN & NOVIAN, LLP
17 Attorneys at Law
18
By: /s/ Farhad Novian
19 FARHAD NOVIAN
20 SHARON RAMINFARD

21 Attorneys for Plaintiff DMH Aesthetics, LLC

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COMPLAINT