Beruflich Dokumente
Kultur Dokumente
13
14 UNITED STATES DISTRICT COURT
15 DISTRICT OF NEVADA
16
17 SAMICK MUSIC CORPORATION, a ) Case No.
18 California corporation, )
) VERIFIED COMPLAINT FOR:
19 Plaintiff, )
) (1) FEDERAL TRADEMARK
20 v. ) INFRINGEMENT;
) (2) COMMON LAW TRADEMARK
21 PERSIS INTERNATIONAL, INC., a Nevada) INFRINGEMENT;
corporation, ) (3) FEDERAL TRADEMARK DILUTION;
22 ) (4) FEDERAL UNFAIR COMPETITION;
Defendant. ) (5) STATE AND COMMON LAW UNFAIR
23 ) COMPETITION
)
24 )
) JURY DEMAND
25 )
)
26 )
)
27 For its Complaint, Plaintiff SAMICK MUSIC CORPORATION (“Samick”) hereby
28 alleges and asserts as follows:
Case 3:09-cv-00197-LRH-VPC Document 1 Filed 04/15/2009 Page 2 of 15
10 Defendant’s past and present infringement and reimbursement of Samick’s attorneys’ fees and
SANTA MONICA, CALIFORNIA 90401-4110
11 costs for having to bring this suit to enforce its trademark rights.
CISLO & THOMAS LLP
12 I. THE PARTIES
∃ΩΩΡΥΘΗ∴ς ∆Ω /∆Ζ
1333 2nd Street
∃ΩΩΡΥΘΗ∴ς ∆Ω /∆Ζ
14 Tennessee.
15 3. Samick is informed and based thereon believes that Defendant is a Nevada
Telephone: (310) 451-0647
2
Case 3:09-cv-00197-LRH-VPC Document 1 Filed 04/15/2009 Page 3 of 15
10 Sohmer, a German immigrant in New York founded the Sohmer & Co., Inc. and adopted and
SANTA MONICA, CALIFORNIA 90401-4110
11 began using the SOHMER trademark on his pianos made with the highest craftsmanship. Sohmer
CISLO & THOMAS LLP
12 & Co., Inc. changed its name to Sohmer Corporation in 1989, merged with Mason & Hamlin Co.
∃ΩΩΡΥΘΗ∴ς ∆Ω /∆Ζ
1333 2nd Street
∃ΩΩΡΥΘΗ∴ς ∆Ω /∆Ζ
14 8. Samick is informed and based thereon believes that Burgett has been using the
15 SOHMER trademark on its pianos and related products and components therefor since at least as
Telephone: (310) 451-0647
16 early as 1996, when it acquired the SOHMER trademark, along with all of the assets of Mason &
17 Hamlin Co., including its original piano rim presses, the long-standing factory in Haverhill,
18 Massachusetts’ historic district, and a completely documented computer-based archive of the
19 authentic piano designs.
20 9. On or about 2002, Samick acquired the exclusive license to sell musical
21 instruments, namely pianos, using the SOHMER trademark. On March 11, 2009, Samick
22 acquired by assignment from Burgett, Inc. all rights, title, and interest in and to all of Burgett,
23 Inc.’s rights in the SOHMER trademarks and the business pertaining thereto. Accordingly, at all
24 times relevant to this action up until it acquired outright the foregoing SOHMER trademarks and
25 trademark applications, Samick was the exclusive licensee of the SOHMER trademarks.
26 10. Consequently and by written assignment, Samick is the current owner (by
27 assignment) of the following trademarks:
28 a. SOHMER (in stylized lettering);
3
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10 This trademark was previously the subject of U.S. Trademark Application Serial No.
SANTA MONICA, CALIFORNIA 90401-4110
11 76/535,595; but this application was subsequently deemed abandoned by United States Patent and
CISLO & THOMAS LLP
12 Trademark Office due to the failure of a predecessor-in-interest to timely file with the United
∃ΩΩΡΥΘΗ∴ς ∆Ω /∆Ζ
1333 2nd Street
∃ΩΩΡΥΘΗ∴ς ∆Ω /∆Ζ
14 The foregoing five (5) trademarks referenced in this paragraph are hereinafter collectively
15 referred to as the “SOHMER trademarks.” Attached hereto as Exhibits 1 through 5 are true and
Telephone: (310) 451-0647
16 correct copies of the Trademark Office records pertaining to these five previously registered
17 trademarks.
18 By written assignment, Samick is also the current owner and applicant of the following
19 federal trademark applications:
20 a. U.S. Trademark Application Serial No. 76/214,968 for SOHMER; and
21 b. U.S. Trademark Application Serial No. 76/546,304 for SOHMER &
22 CO.
23 On or about October 25, 2002, the United States Patent and Trademark Office erroneously
24 converted SOHMER Trademark Application Serial No. 76/214,968 to the Supplemental Register.
25 The United States Patent and Trademark Office ultimately reversed this error, found this
26 application allowable, the published it for opposition.
27 Samick’s two (2) pending trademark applications, Serial Nos. 76/214,968 and 76/546,304,
28 are hereinafter collectively referred to as the “SOHMER trademark applications.” Attached
4
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1 hereto as Exhibits 6 and 7 are true and correct copies of the Trademark Office records pertaining
2 to these two trademark applications.
3 11. Samick manufactures and sells musical instruments, namely high-end pianos, and
4 related products and components therefor under the SOHMER trademark. Samick has at all times
5 relevant to this action appropriately accompanied the SOHMER trademarks with the proper
6 trademark notice on all such pianos and on their labels, tags, and packaging. Samick is informed
7 and based thereon believes that Samick’s predecessors-in-interest also always appropriately
8 accompanied the SOHMER trademarks with the proper trademark notice on all such pianos and
9 on their labels, tags, and packaging.
Facsimile: (310) 394-4477
10 12. Although the trademark registrations have expired, they constitute further
SANTA MONICA, CALIFORNIA 90401-4110
11 evidence, along with the chain of title for each as recorded with the United States Patent and
CISLO & THOMAS LLP
12 Trademark Office, that Samick’s current commercial use of the SOHMER trademark justifiably
∃ΩΩΡΥΘΗ∴ς ∆Ω /∆Ζ
1333 2nd Street
∃ΩΩΡΥΘΗ∴ς ∆Ω /∆Ζ
13 relates back to 1872. In the more than 135 years since the humble beginning by Hugo Sohmer,
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14 Samick and its predecessors-in-interest developed SOHMER into one of the most revered
15 trademarks in the piano market.
Telephone: (310) 451-0647
5
Case 3:09-cv-00197-LRH-VPC Document 1 Filed 04/15/2009 Page 6 of 15
1 17. On or about January 15, 2003, Defendant offered for sale pianos under the
2 SOHMER trademark at the 2003 National Association of Music Merchants (“NAMM”) trade
3 show in Anaheim, California, January 15-18, 2003.
4 18. At the NAMM trade shows, Defendant displayed to the public pianos with the
5 SOHMER trademark on the surface and under a large banner that included the SOHMER
6 trademark in prominent letters.
7 19. According to the trade show directory, Defendant was advertising “Sohmer & Co.
8 Pianos,” “Sohmer Pianos,” and “Sohmer & Son Pianos,” showing the same mailing address as
9 Defendant’s pending trademark application.
Facsimile: (310) 394-4477
10 20. Samick is informed and based thereon believes that, on February 15, 2001, Edward
SANTA MONICA, CALIFORNIA 90401-4110
11 F. Richards filed a federal intent-to-use trademark application for SOHMER for pianos, which
CISLO & THOMAS LLP
12 was given U.S. Trademark Application Serial No. 76/210,248. Mr. Richards subsequently
∃ΩΩΡΥΘΗ∴ς ∆Ω /∆Ζ
1333 2nd Street
∃ΩΩΡΥΘΗ∴ς ∆Ω /∆Ζ
13 testified in writing and under oath to the United States Patent and Trademark Office that he first
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14 used SOHMER in commerce in connection with pianos on June 26, 2001. On or about October
15 8, 2002, Mr. Richards assigned his rights in the application to his company, the Defendant. On
Telephone: (310) 451-0647
16 September 26, 2002, the United States Patent and Trademark Office entered a notice of
17 suspension in Trademark Application Serial No. 76/210,248 pending the disposition of the above-
18 mentioned SOHMER Trademark Application Serial No. 76/214,968 owned by Samick. Attached
19 hereto as Exhibit 9 is a true and correct copy of the notice of suspension entered in this trademark
20 application.
21 21. On October 29, 2002, Samick sent a cease and desist letter to Defendant
22 demanding that they cease and desist from all further use of the SOHMER trademarks, and it
23 withdraw the improper trademark application before the United States Patent and Trademark
24 Office.
25 22. On October 19, 2004, Defendant filed a notice of opposition against Samick’s U.S.
26 Trademark Application Serial No. 76/214,968, which initiated Opposition Proceeding No.
27 91162715 before the Trademark Trial and Appeal Board. This opposition proceeding is still
28 pending, and consequently is preventing the federal re-registration of Samick’s U.S. Trademark
6
Case 3:09-cv-00197-LRH-VPC Document 1 Filed 04/15/2009 Page 7 of 15
1 Application Serial No. 76/214,968. The remainder of Defendant’s testimony period is scheduled
2 to re-open from May 5, 2009 to May 8, 2009, and Samick’s testimony period is scheduled to open
3 on June 7, 2009.
4 23. The United States Patent and Trademark Office has suspended examination of
5 U.S. Trademark Application Serial No. 76/546,304 pending the outcome of Defendant’s U.S.
6 Trademark Application Serial No. 76/210,248, which in turn is suspended pending the outcome
7 of Samick’s U.S. Trademark Application No. 76/214,968, the subject of Trademark Opposition
8 No. 91162715 initiated by Defendant before the Trademark Trial and Appeal Board. Since this
9 opposition proceeding is still pending, Defendant is preventing the federal re-registration of
Facsimile: (310) 394-4477
13 24. Samick repeats and alleges each and every allegation contained in paragraphs 1
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14 through 23 of this Complaint, and incorporates them herein as though set forth in full.
15 25. This claim is against Defendant for trademark infringement in violation of Section
Telephone: (310) 451-0647
7
Case 3:09-cv-00197-LRH-VPC Document 1 Filed 04/15/2009 Page 8 of 15
1 strength of plaintiff’s mark; defendant's intent in selecting its mark; likely degree of care of
2 purchasers; and evidence of actual confusion.
3 29. The SOHMER trademarks are very strong after years of successful marketing,
4 significant sales volume, critical acclaim, and widespread public recognition. Defendant likewise
5 sells pianos under the SOHMER trademarks and shares such similar marketing channels as to
6 cause a likelihood of confusion. These factors indicate that Defendant adopted the SOHMER
7 trademark intending to ride on the goodwill and reputation of Samick and its predecessors-in-
8 interest.
9 30. Samick is informed and based thereon alleges that, at all times relevant to this
Facsimile: (310) 394-4477
10 action, including when Defendant first adopted the SOHMER trademarks and commenced their
SANTA MONICA, CALIFORNIA 90401-4110
11 commercial use of the mark on pianos, Defendant knew of the prior adoption and widespread
CISLO & THOMAS LLP
12 commercial use of the SOHMER trademarks on pianos that Samick presently owns and knew of
∃ΩΩΡΥΘΗ∴ς ∆Ω /∆Ζ
1333 2nd Street
∃ΩΩΡΥΘΗ∴ς ∆Ω /∆Ζ
13 the valuable goodwill and reputation acquired by Samick in connection with the SOHMER
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16 31. Samick has no control over the composition and quality of the infringing pianos
17 sold by Defendant. Samick is informed and believes and on that basis alleges that Defendant’s
18 use of the SOHMER trademarks has caused confusion and mistake and the deception of
19 purchasers as to the source of origin of Defendant’s infringing products. Because of the
20 confusion as to the source engendered by Defendant’s unauthorized use of the SOHMER
21 trademarks, Samick’s valuable goodwill developed at great expense and effort by Samick is being
22 harmed and at risk of further damage.
23 32. The goodwill of Samick’s business under the SOHMER trademarks is of
24 enormous value, and Samick will suffer irreparable harm should Defendant’s infringement be
25 allowed to continue to the great detriment of its reputation and goodwill. Defendant’s
26 infringement will continue unless enjoined.
27 ///
28 ///
8
Case 3:09-cv-00197-LRH-VPC Document 1 Filed 04/15/2009 Page 9 of 15
10 infringing products.
SANTA MONICA, CALIFORNIA 90401-4110
12 Samick’s products so as to likely cause and has caused confusion regarding the source of
∃ΩΩΡΥΘΗ∴ς ∆Ω /∆Ζ
1333 2nd Street
∃ΩΩΡΥΘΗ∴ς ∆Ω /∆Ζ
13 Defendant’s products, in that purchasers thereof will be likely to associate or have associated such
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14 products with, as originating with, or as approved by Samick, all to the detriment of Samick.
15 37. Defendant’s infringement will continue unless enjoined.
Telephone: (310) 451-0647
9
Case 3:09-cv-00197-LRH-VPC Document 1 Filed 04/15/2009 Page 10 of 15
1 unless enjoined.
2 FOURTH CAUSE OF ACTION
3 FEDERAL UNFAIR COMPETITION
4 IN VIOLATION OF 15 U.S.C. § 1125(a)
5 42. Samick repeats and alleges each and every allegation contained in paragraphs 1
6 through 41 of this Complaint, and incorporates them herein as though set forth in full.
7 43. The SOHMER trademark has become uniquely associated with, and hence
8 identifies, Samick and its predecessors-in-interest. Defendant’s use of the SOHMER trademark
9 constitutes a false designation of origin, or a false representation. Further, it wrongfully and
Facsimile: (310) 394-4477
10 falsely designates Defendant’s products as originating from or connected with Samick and
SANTA MONICA, CALIFORNIA 90401-4110
12 44. The conduct of Defendant is likely to cause mistake, to deceive, and confuse
∃ΩΩΡΥΘΗ∴ς ∆Ω /∆Ζ
1333 2nd Street
∃ΩΩΡΥΘΗ∴ς ∆Ω /∆Ζ
13 members of the public who would be wrongfully led to believe that Defendant is associated with
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16 trademarks, has acted willfully and with full knowledge of Samick’s rights in the SOHMER
17 trademarks, and has used this false designation of origin and description in contravention of
18 15 U.S.C. § 1125(a).
19 46. The continued unauthorized use by Defendant of the confusingly similar
20 trademark in relation to the manufacture and sale of the pianos at issue is likely to cause
21 confusion and deception of the public and lead consumers and potential consumer to erroneously
22 associate the products of Defendant with Samick and/or to erroneously believe that the products
23 of Defendant are being placed upon the market with the consent and authority of Samick, as a
24 result of which the continue use by Defendant of the SOHMER trademarks has caused and,
25 unless restrained, will continue to cause serious and irreparable injury to Samick.
26 47. By reason of the foregoing, Samick has been injured in an amount not yet
27 ascertained.
28 ///
10
Case 3:09-cv-00197-LRH-VPC Document 1 Filed 04/15/2009 Page 11 of 15
10 its pianos sold under the SOHMER trademarks. It is only fair and legitimate that Samick be able
SANTA MONICA, CALIFORNIA 90401-4110
11 to continue its business without unfair, improper, unauthorized, and illegal interference by
CISLO & THOMAS LLP
14 purposefully directed at undercutting Samick’s legitimate business involving their pianos and
15 constitutes unfair competition in violation of the California Business and Professions Code,
Telephone: (310) 451-0647
11
Case 3:09-cv-00197-LRH-VPC Document 1 Filed 04/15/2009 Page 12 of 15
1 afford Samick adequate relief. Samick is therefore entitled to a preliminary injunction and a
2 permanent injunction against further infringing conduct by Defendant.
3 54. As a direct and proximate result of the aforesaid acts of unfair competition,
4 Defendant has wrongfully taken Samick’s profits and the benefit of their creativity and
5 investment of time, energy and money. Defendant should therefore disgorge all profits from the
6 sale of infringing products and further should be ordered to perform full restitution to Samick as a
7 consequence of Defendant’s infringing activities.
8 55. Samick is informed and believe that the use of the SOHMER trademarks by
9 Defendant was willful and with full knowledge of the unauthorized usage thereof.
Facsimile: (310) 394-4477
10 56. In doing the acts hereinabove alleged, Defendant has acted fraudulently,
SANTA MONICA, CALIFORNIA 90401-4110
12
Case 3:09-cv-00197-LRH-VPC Document 1 Filed 04/15/2009 Page 13 of 15
10 by Defendant’s infringements and unfair business practices, in an amount Samick proves at trial;
SANTA MONICA, CALIFORNIA 90401-4110
16 10. An order for attorneys’ fees and costs that Samick incurred in having to bring and
17 sustain this action for the legal enforcement of its trademark and business rights against
18 Defendant;
19 ///
20 ///
21 ///
22 ///
23 ///
24 ///
25 ///
26 ///
27 ///
28 ///
13
Case 3:09-cv-00197-LRH-VPC Document 1 Filed 04/15/2009 Page 14 of 15
1 11. Such other and further equitable and legal relief as the Court may deem
2 appropriate.
3
4 Respectfully submitted,
5 WATSON ROUNDS
6
7 Dated: April 15, 2009 /s/ Matthew D. Francis
Michael D. Rounds, Esq.
8
Matthew D. Francis, Esq.
9 5371 Kietzke Lane
Facsimile: (310) 394-4477
11 Of Counsel:
CISLO & THOMAS LLP
14
Case 3:09-cv-00197-LRH-VPC Document 1 Filed 04/15/2009 Page 15 of 15
JURY DEMAND
1
Plaintiff SAMICK MUSIC CORPORATION hereby demands a trial by jury as provided
2
by Rule 38(a) of the Federal Rules of Civil Procedure and by the Local Rules of this Court.
3
4
Respectfully submitted,
5
WATSON ROUNDS
6
7 Dated: April 15, 2009 /s/ Matthew D. Francis
8 Michael D. Rounds, Esq.
Matthew D. Francis, Esq.
9 5371 Kietzke Lane
Facsimile: (310) 394-4477
11
CISLO & THOMAS LLP
Of Counsel:
12 Daniel M. Cislo, Esq.
Kelly W. Cunningham, Esq.
∃ΩΩΡΥΘΗ∴ς ∆Ω /∆Ζ
1333 2nd Street
∃ΩΩΡΥΘΗ∴ς ∆Ω /∆Ζ
15
13th
Case 3:09-cv-00197-LRH-VPC Document 1-3 Filed 04/15/2009 Page 1 of 26
Exhibit 1
Exhibit 1
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Case 3:09-cv-00197-LRH-VPC Document 1-3 Filed 04/15/2009 Page 3 of 26
Exhibit 2
Exhibit 2
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Case 3:09-cv-00197-LRH-VPC Document 1-3 Filed 04/15/2009 Page 5 of 26
Exhibit 3
Exhibit 3
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Case 3:09-cv-00197-LRH-VPC Document 1-3 Filed 04/15/2009 Page 7 of 26
Exhibit 4
Exhibit 4
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Case 3:09-cv-00197-LRH-VPC Document 1-3 Filed 04/15/2009 Page 9 of 26
Exhibit 5
Exhibit 5
Trademark Electronic Search System (TESS) http://tess2.uspto.gov/bin/showfield?f=doc&state=4008:oth12k.2.1
Case 3:09-cv-00197-LRH-VPC Document 1-3 Filed 04/15/2009 Page 10 of 26
Un it e d St a t e s Pa t e n t a n d Tra de m a rk Office
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Trademark Electronic Search System (TESS) http://tess2.uspto.gov/bin/showfield?f=doc&state=4008:oth12k.2.1
Case 3:09-cv-00197-LRH-VPC Document 1-3 Filed 04/15/2009 Page 11 of 26
Live/Dead
DEAD
Indicator
Abandonment
August 6, 2004
Date
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Exhibit 6
Exhibit 6
Trademark Electronic Search System (TESS) http://tess2.uspto.gov/bin/showfield?f=doc&state=4001:hlv8jc.2.1
Case 3:09-cv-00197-LRH-VPC Document 1-3 Filed 04/15/2009 Page 13 of 26
Un it e d St a t e s Pa t e n t a n d Tra de m a rk Office
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Typed Drawing
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Exhibit 7
Exhibit 7
Trademark Electronic Search System (TESS) http://tess2.uspto.gov/bin/showfield?f=doc&state=4001:hlv8jc.3.1
Case 3:09-cv-00197-LRH-VPC Document 1-3 Filed 04/15/2009 Page 15 of 26
Un it e d St a t e s Pa t e n t a n d Tra de m a rk Office
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Typed Drawing
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Exhibit 8
Exhibit 8
SMC :: Samick Music Corp. http://smcmusic.com/
Case 3:09-cv-00197-LRH-VPC Document 1-3 Filed 04/15/2009 Page 17 of 26
Sam ick has alw ays adm ired Germ an innovat ion, engineering, and craft sm anship, and
is indeed proud t o be able t o offer a line of qualit y Germ an- m ade product s in addit ion SAMI CK Music Corp.
t o it s ext ensive line of product s current ly being m anufact ured in Korea, I ndonesia, and
t he Unit ed St at es of Am erica.
SEI LER pianos w ill be on display at t he NAMM Show in t he SAMI CK boot h locat ed in
room s 210 A&B. Addit ional new m odels w ill be showcased at t he upcom ing
Musikm esse in Frankfurt .
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SMC :: Samick Music Corp. http://smcmusic.com/
Case 3:09-cv-00197-LRH-VPC Document 1-3 Filed 04/15/2009 Page 18 of 26
Fret board act ion heat ed up at t he Greg Bennet t ‘NAMM Jam ’ held during t he annual
sum m er NAMM show in Nashville, Tennessee. The event w as dedicat ed t o and in
celebrat ion of com m unit y m usic st ores t hroughout t he count ry t hat cont inue t o serve
t heir local com m unit ies by providing m usical inst rum ent sales, service, and educat ion.
The j am t ook place at BB Kings Blues Club downt ow n and feat ured 2006 Guit ar World
Magazine ‘Guit ar Hero’ w inner Ladd Sm it h ( pict ured above) , w ho played his
cust om ized Greg Bennet t Form ula FA1. Ot her perform ing art ist s included Coles
Whalen, Jessie Lynn, Shaw n Michael Perry, Ravi, Roger Zim ish, Michell Chenard, St eve
Rut ledge and a host of m usic st ore ow ners w ho showed up t o have fun and show off
t heir chops.
J.S. Kim , head of SMC' s I nchon, Sout h Korea parent com pany Sam ick Musical
I nst rum ent s Com pany, Lt d. and Chairm an of SMC' s Board of Direct ors, explains t he
reasons behind t he m ove: " Over t he last decade w e have seen t he cost s of business
and m anufact uring increase in t he Pacific Rim count ries. The product ion of prem ium
value product s has now becom e viable in t he Unit ed St at es. Many Am erican
consum ers are looking for a bet t er qualit y product ."
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SMC :: Samick Music Corp. http://smcmusic.com/
Case 3:09-cv-00197-LRH-VPC Document 1-3 Filed 04/15/2009 Page 19 of 26
began t o build and sell a few vert ical pianos a week from a sm all
convert ed shop front . I t w asn' t long before t he com pany st art ed
m anufact uring upright pianos on a large scale. I n 1964 Sam ick becam e t he first
Korean com pany t o export pianos and by t he early 1970s, t he com pany had becom e a
large- scale m anufact urer wit h over 3,000 em ployees building pianos and guit ars.
I n t he years following, Sam ick focused on global expansion. I n 1978 t hey opened a
branch office in Los Angeles, California, follow ed by est ablishm ent of an office in
Düsseldorf, Germ any in 1980. Sales of Sam ick product s in t he Unit ed St at es grew
exponent ially and Sam ick soon announced t he developm ent of t heir Am erican
subsidiary, Sam ick Music Corporat ion in 1982.
Sam ick has alw ays been dedicat ed t o developing new product s and qualit y, st art ing in
1983 w it h a t echnical cooperat ion w it h Klaus Fenner, a piano designer and t echnician
from Germ any. Fenner w as renowned for designing t he Germ an I m perial Scale t hat
cont inues t o charact erize t he pianos of leading int ernat ional m anufact urers.
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Sohmer Pianos http://www.sohmerco.com/
Case 3:09-cv-00197-LRH-VPC Document 1-3 Filed 04/15/2009 Page 20 of 26
H u go So h m e r 18 4 5 – 19 13
Founder of Sohmer & Co. Pianos
At his death in 1931, Hugo Sohmer passed on his love for the piano
to his sons. Sohmer & Co. enjoyed family ownership for over one
hundred years until the company was sold in 1982.
© 2008 Sohmer & Co. - a division Samick Music Corporation Company | Grand Pianos | Vertical Pianos | Contact Us
1 of 1 4/14/2009 3:59 PM
Sohmer Pianos :: Grands http://www.sohmerco.com/grands.htm
Case 3:09-cv-00197-LRH-VPC Document 1-3 Filed 04/15/2009 Page 21 of 26
So h m e r Gra n d Pia n o s
Sohm er 5 0 T 5 ' 0 "
Av ailable in: Ebony Sat in, Mahogany , Walnut , and
Cher r y
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Sohmer Pianos :: Grands http://www.sohmerco.com/grands.htm
Case 3:09-cv-00197-LRH-VPC Document 1-3 Filed 04/15/2009 Page 22 of 26
Sohm er 7 7 F 5 ' 9 "
Av ailable in: Ebony Sat in, Mahogany , Walnut , and
Cher r y
© 2008 Sohmer & Co. - a division Samick Music Corporation Company | Grand Pianos | Vert ical Pianos | Cont act Us
2 of 2 4/14/2009 3:59 PM
Case 3:09-cv-00197-LRH-VPC Document 1-3 Filed 04/15/2009 Page 23 of 26
([ΚΛΕΛΩ
([ΚΛΕΛΩ
Case 3:09-cv-00197-LRH-VPC Document 1-3 Filed 04/15/2009 Page 24 of 26
Case 3:09-cv-00197-LRH-VPC Document 1-3 Filed 04/15/2009 Page 25 of 26
Case 3:09-cv-00197-LRH-VPC Document 1-3 Filed 04/15/2009 Page 26 of 26
EXHIBIT 2