Deckers v. Target - Complaint (Yoga Sling Trade Dress)

Case 2:19-cv-06203 Document 1 Filed 07/18/19 Page 1 of 17 Page ID #:1
1 Brent H. Blakely (SBN 157292)

bblakely@blakelylawgroup.com
2 Jessica C. Covington (SBN 301816)
jcovington@blakelylawgroup.com
3 BLAKELY LAW GROUP
1334 Parkview Avenue, Suite 280
4 Manhattan Beach, California 90266
Telephone: (310) 546-7400
5 Facsimile: (310) 546-7401
6 Attorneys for Plaintiff
Deckers Outdoor Corporation
7
8
9 UNITED STATES DISTRICT COURT
10 CENTRAL DISTRICT OF CALIFORNIA
11
12
DECKERS OUTDOOR ) CASE NO.
13 CORPORATION, a Delaware )
Corporation, ) PLAINTIFF’S COMPLAINT FOR
14 ) DAMAGES AND EQUITABLE
Plaintiff, ) RELIEF:
15 v. )
) 1. TRADE DRESS INFRINGEMENT -
16 TARGET CORPORATION, a ) YOGA SLING TRADE DRESS;
Minnesota Corporation; and DOES 1- )
17 10, inclusive, ) 2. TRADEMARK INFRINGEMENT
) OF AN UNREGISTERED MARK;
18 )
Defendants. ) 3. TRADE DRESS INFRINGEMENT
19 ) UNDER CALIFORNIA COMMON
) LAW;
20 )
) 4. TRADEMARK INFRINGEMENT
21 ) UNDER CALIFORNIA COMMON
) LAW;
22 )
) 5. UNFAIR COMPETITION UNDER
23 ) CALIFORNIA COMMON LAW;
)
24 ) 6. UNFAIR COMPETITION IN
) VIOLATION OF CAL. BUS. &
25 ) PROF. CODE § 17200, et seq..
)
26 )
) JURY TRIAL DEMANDED
27
28
1 Plaintiff Deckers Outdoor Corporation for its claims against Defendant

2 Target Corporation respectfully alleges as follows:
3 JURISDICTION AND VENUE
4 1. Plaintiff Deckers Outdoor Corporation (“Deckers” or “Plaintiff”) files this
5 action against Defendant Target Corporation (“Defendant”) for trade dress
6 infringement and trademark infringement of an unregistered mark under the Lanham
7 Trademark Act of 1946, 15 U.S.C. §1051 et seq. (the “Lanham Act”) and for related
8 claims under California common and state law. This Court has subject matter
9 jurisdiction over the claims alleged in this action pursuant to 28 U.S.C. §§ 1331, 1338.
10 2. This Court has personal jurisdiction over Defendant because Defendant
11 maintains multiple stores and/or offices and regularly conducts business within this
12 judicial district.
13 3. This action arises out of wrongful acts by Defendant within this judicial
14 district and Plaintiff is located and has been injured in this judicial district by
15 Defendant’s alleged wrongful acts. Venue is proper in this district pursuant to 28
16 U.S.C. § 1391 because the claims asserted arise in this district.
17 THE PARTIES
18 4. Plaintiff Deckers Outdoor Corporation is a corporation organized and
19 existing under the laws of the state of Delaware with an office and principal place of
20 business in Goleta, California. Deckers has been engaged in the design, distribution,
21 marketing, offering for sale, and sale of footwear since 1975. Deckers owns several
22 brands of footwear including UGG®, Koolaburra ®, Teva ®, Sanuk® and Hoka One
23 One®.
24 5. Upon information and belief, Defendant Target Corporation is a
25 corporation organized and existing under the laws of the state of Minnesota with an
26 office and principal place of business located at 1000 Nicollet Mall, Minneapolis,
27 Minnesota 55403.
28 6. Deckers is unaware of the names and true capacities of Defendants,
2
COMPLAINT FOR DAMAGES AND EQUITABLE RELIEF
1 whether individual, corporate and/or partnership entities named herein as DOES 1

2 through 10, inclusive, and therefore sues them by their fictitious names. Deckers will
3 seek leave to amend this complaint when their true names and capacities are
4 ascertained. Deckers is informed and believes and based thereon alleges that said
5 Defendant and DOES 1 through 10, inclusive, are in some manner responsible for the
6 wrongs alleged herein, and that at all times referenced each was the agent and servant
7 of the other Defendant and was acting within the course and scope of said agency and
8 employment.
9 7. Deckers is informed and believes, and based thereon alleges, that at all
10 relevant times herein, Defendant and DOES 1 through 10, inclusive, knew or
11 reasonably should have known of the acts and behavior alleged herein and the damages
12 caused thereby, and by their inaction ratified and encouraged such acts and behavior.
13 Deckers further alleges that Defendants and DOES 1 through 10, inclusive, have a
14 non-delegable duty to prevent or not further such acts and the behavior described
15 herein, which duty Defendant and DOES 1 though 10, inclusive, failed and/or refused
16 to perform.
17 ALLEGATIONS COMMON TO ALL CAUSES OF ACTION
18 A. Deckers’ Sanuk® Brand and YOGA SLING Sandal
19 8. In July 2011, Deckers completed the acquisition of the Sanuk® brand, a
20 lifestyle footwear brand rooted in surf culture but embraced by an eclectic mix of
21 style-savvy optimists.
22 9. The Sanuk® brand is known for its YOGA SLING sandal, which
23 combines comfort with a chic, unique style sandal made with soft fabric sling straps.
24 10. The Sanuk YOGA SLING was introduced in 2013 and its appearance is
25 unique and distinctive, consisting of a combination of the following non-functional
26 elements (“YOGA SLING Trade Dress”):
27 • Thong-type sandal with a generally flat sole;
28 • Foot bed is comprised of soft material;
3
1 • Sling strap formed by a loop of fabric extending from a toe post around
2 the heel and back to the toe post;
3 • An instep strap extending from the lateral side of the sole across the instep
4 to the medial side of the sole;
5 • The instep strap and the sling strap appear unconnected and the instep
6 strap overlaps the sling strap;
7 • Both the sling strap and the instep strap are formed of a soft fabric having
8 an exaggerated width; and
9 • Binding at the top of the toe post.
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15 11. The YOGA SLING Trade Dress, which is a composite of the above-
16 referenced features, is non-functional in its entirety, visually distinctive, and is unique
17 in the footwear industry.
18 12. The design of the YOGA SLING Trade Dress is neither essential to its
19 use or purpose nor does it affect the cost or quality of the sandal. There are numerous
20 other designs available that are equally feasible and efficient, none of which
21 necessitate copying or imitating the YOGA SLING Trade Dress. The aforesaid
22 combination of features provides no cost advantages to the manufacturer or utilitarian
23 advantages to the consumer. These features, in combination, serve only to render
24 Deckers’ YOGA SLING sandal distinct and recognizable as goods originating from
25 Deckers’ Sanuk® brand.
26 13. The YOGA SLING Trade Dress has achieved a high degree of consumer
27 recognition and secondary meaning, which serves to identify Deckers as the source of
28 footwear featuring said trade dress.
4
1 14. The YOGA SLING Trade Dress is one of the most well recognized and
2 commercially successful styles of Deckers’ Sanuk® brand of footwear. Additionally,
3 it was nominated in 2013 and 2014 as a SIMA “Footwear Product of the Year.”
4 15. Deckers has spent substantial time, effort, and money in designing,
5 developing, advertising, promoting, and marketing the Sanuk® YOGA SLING sandal
6 and has sold over one hundred million dollars worth of said style of sandals.
7 16. Due to its long use, extensive sales, and significant advertising and
8 promotional activities, Deckers’ YOGA SLING trade dress has achieved widespread
9 acceptance and recognition among the consuming public and trade throughout the
10 United States.
11 B. Defendant’s Infringement of Deckers’ YOGA SLING Trade Dress
12 17. Upon information and belief, Target is engaged in the retail sale of a wide
13 range of apparel and footwear. Target’s retail stores are located nationwide, including
14 within this judicial district. Target’s products can also be purchased online at
15 www.target.com, which is also available to consumers nationwide.
16 18. The present lawsuit arises from Defendant’s willful infringement of
17 Deckers’ Sanuk® “YOGA SLING Trade Dress” by its CAT AND JACK® brand of
18 fabric thong sandals that bear a nearly identical design (“Accused Products”). Said
19 Accused Products were discovered and purchased from www.target.com and were
20 shipped to a location within this judicial district.
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Cat & Jack®
26 Deckers’ Sanuk® “Yoga Sling” Sandal “Girls’ Liv Yoga Mat Flip Flop” Sandal
27 19. Deckers has not granted a license or any other form of permission to
28 Defendant with respect to any of its trademarks, design patents, trade dress, or other
5
1 intellectual property.
2 20. Deckers is informed and believes and herein alleges that Defendant is a
3 competitor and has copied Deckers’ YOGA SLING Trade Dress in an effort to exploit
4 Deckers’ reputation in the market.
5 21. Deckers is informed and believes and herein alleges that Defendant has
6 acted in bad faith and that Defendant’s acts have misled and confused and were
7 intended to cause confusion, or to cause mistake, or to deceive as to the affiliation,
8 connection, or association of Defendant’s products with Deckers, or as to the origin,
9 sponsorship, or approval of the Accused Products by Deckers.
10 FIRST CLAIM FOR RELIEF
11 (Trade Dress Infringement of YOGA SLING Trade Dress - 15 U.S.C. § 1125)
12 22. Deckers incorporates herein by reference the averments of the preceding
13 paragraphs as though fully set forth herein.
14 23. The YOGA SLING Trade Dress is non-functional in its entirety, visually
15 distinctive, and is unique in the footwear industry.
16 24. The design of the YOGA SLING Trade Dress is neither essential to its
17 use or purpose nor does it affect the cost or quality of the sandal. There are numerous
18 other designs available that are equally feasible and efficient, none of which
19 necessitate copying or imitating the YOGA SLING Trade Dress. The aforesaid
20 combination of features provides no cost advantages to the manufacturer or utilitarian
21 advantages to the consumer. These features, in combination, serve only to render
22 Deckers’ Sanuk® YOGA SLING sandal distinct and recognizable as goods originating
23 from Deckers’ Sanuk ® brand.
24 25. The YOGA SLING Trade Dress has achieved a high degree of consumer
25 recognition and secondary meaning, which serves to identify Deckers as the source of
26 footwear featuring said trade dress.
27 26. Deckers has spent substantial time, effort, and money in designing,
28 developing, advertising, promoting, and marketing the Sanuk® YOGA SLING sandal
6
1 and has sold over one hundred million dollars worth of said style of sandals.
2 27. The YOGA SLING Trade Dress is one of the most well recognized and
3 commercially successful styles of Deckers’ Sanuk® brand of footwear.
4 28. Due to its long use, extensive sales, and significant advertising and
5 promotional activities, Deckers’ YOGA SLING Trade Dress has achieved widespread
6 acceptance and recognition among the consuming public and trade throughout the
7 United States.
8 29. There are numerous other sandal designs in the footwear industry, none of
9 which necessitate copying or imitating the YOGA SLING Trade Dress. However, due
10 to the popularity and consumer recognition achieved by the YOGA SLING sandal,
11 said design has often been the subject of infringement by third-parties, including by
12 Defendant.
13 30. Deckers is informed and believes and herein alleges that Defendant is a
14 competitor and has copied Deckers’ YOGA SLING Trade Dress in an effort to exploit
15 Deckers’ reputation in the market.
16 31. The Accused Products produced, distributed, advertised and offered for
17 sale by Defendant bear nearly identical reproductions of the YOGA SLING Trade
18 Dress, such as to cause a likelihood of confusion as to the source, sponsorship or
19 approval by Deckers of Defendant’s products.
20 32. Defendant’s use of Deckers’ YOGA SLING Trade Dress is without
21 Deckers’ permission or authority and in total disregard of Deckers’ rights to control its
23 33. Defendant’s use of Deckers’ YOGA SLING Trade Dress is likely to lead
24 to and result in confusion, mistake or deception, and is likely to cause the public to
25 believe that Defendant’s products are produced, sponsored, authorized, or licensed by
26 or are otherwise connected or affiliated with Deckers, all to the detriment of Deckers.
27 34. Deckers has no adequate remedy at law.
28 35. In light of the foregoing, Deckers is entitled to injunctive relief
7
1 prohibiting Defendant from using Deckers’ YOGA SLING Trade Dress, or any
2 designs confusingly similar thereto, and to recover all damages, including attorneys’
3 fees, that Deckers has sustained and will sustain, and all gains, profits and advantages
4 obtained by Defendant as a result of its infringing acts alleged above in an amount not
5 yet known, as well as the costs of this action.
6 SECOND CLAIM FOR RELIEF
7 (Trademark Infringement of an Unregistered Trademark – 15 U.S.C. § 1125(a))
10 37. The Yoga Sling Common Law Trademark was first used by Deckers in
11 interstate commerce at least as early as 2013 and is distinctive and exclusively owned
12 and used by Deckers. As the result of significant sales and substantial investment in
13 multi-media advertising and promotion by Deckers, in the United States and
14 throughout the world as part of a long term and carefully planned marketing program,
15 the Yoga Sling Common Law Trademark serves to identify Deckers to the consuming
16 public as the source of the footwear on which the Yoga Sling Common Law
17 Trademark is displayed. Consumers directly associate the Yoga Sling Common Law
18 Trademark with Deckers, the Sanuk® brand, and with merchandise of the highest
19 quality. As such, the Yoga Sling Common Law Trademark has developed strong
20 secondary meaning and is of inestimable value to Deckers.
21 38. Through many years of use in interstate commerce, Deckers has
22 established common law trademark protection for its inherently distinctive Yoga Sling
23 Common Law Trademark used on Deckers’ footwear.
24 39. As a direct result of the continuous and exclusive use of the Yoga Sling
25 Common Law Trademark in interstate commerce, Deckers has established significant
26 good will and consumer expectation regarding the high quality and source of Deckers’
27 merchandise including, inter alia, women’s accessories, displaying said mark.
28 40. Deckers has dedicated substantial monetary expenditures and resources to
8
1 support its Yoga Sling sandal, bearing the Yoga Sling Common Law Trademark, by
2 way of extensive advertising and promotional efforts through diverse media in the
3 United States as well as internationally.
4 41. Defendant, in connection with the distribution, production, distribution,
5 advertisement, offer for sale and/or sale of its own footwear has utilized Deckers Yoga
6 Sling Common Law Trademark, such as to cause a likelihood of confusion as to the
7 source, sponsorship or approval by Deckers of Defendant’s products. Indeed, under its
8 in-house brand, Shade & Shore, Defendant has a named its own sandal the “Women’s
9 Tashi Yoga Sling Thong Sandal,” as shown below.
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24 42. Defendant’s use of the Yoga Sling Common Law Trademark in
25 connection with its own sandal creates a high likelihood of confusion amongst
26 consumers, which is especially damaging to the good will established in the Yoga
27 Sling Common Law Trademark and Deckers’ reputation for high-quality products.
28 43. Defendant’s use of the Yoga Sling Common Law Trademark is without
9
1 Deckers’ permission or authority and in total disregard of Deckers’ rights to control its
3 44. Defendant’s use of the Yoga Sling Common Law Trademark is likely to
4 lead to and result in confusion, mistake or deception, and is likely to cause the public
5 to believe that Defendant’s products are produced, sponsored, authorized, or licensed
6 by or that are otherwise connected or affiliated with Deckers, all to the detriment of
7 Deckers.
8 45. Deckers has no adequate remedy at law.
10 prohibiting Defendant from using Deckers’ Yoga Sling Common Law Trademark, or
11 any marks confusingly similar thereto, and to recover all damages, including attorneys’
12 fees, that Deckers has sustained and will sustain, and all gains, profits and advantages
14 yet known, as well as the costs of this action.
15 THIRD CLAIM FOR RELIEF
16 (Trade Dress Infringement Under California Common Law)
19 48. Deckers has common law rights to the YOGA SLING Trade Dress in the
20 state of California due to its extensive promotion and sale of products bearing said
21 trade dress within the state of California.
22 49. Deckers’ YOGA SLING Trade Dress has achieved a high degree of
23 consumer recognition and secondary meaning nationwide and within the state of
24 California, which serves to identify Deckers as the source of the high-quality goods
25 upon which the design appears.
26 50. Defendant’s infringement of the YOGA SLING Trade Dress constitutes
27 common law trade dress infringement in violation of the common law of the State of
28 California.
10
1 51. Defendant’s unauthorized use of Deckers’ YOGA SLING Trade Dress

2 has caused and is likely to cause confusion as to the source of Defendant’s products,
3 all to the detriment of Deckers.
4 52. Defendant’s acts are willful, deliberate, and intended to confuse the public
5 and to injure Deckers.
6 53. Deckers has no adequate remedy at law to compensate it fully for the
7 damages that have been caused and which will continue to be caused by Defendant’s
8 infringing conduct, unless it is enjoined by this Court.
9 54. The conduct herein complained of was extreme, outrageous, and was
10 inflicted on Deckers in reckless disregard of Deckers’ rights. Said conduct was
11 despicable and harmful to Deckers and as such supports an award of exemplary and
12 punitive damages in an amount sufficient to punish and make an example of
13 Defendant, and to deter it from similar conduct in the future.
15 prohibiting Defendant from infringing the YOGA SLING Trade Dress, and to recover
16 all damages, including attorneys’ fees, that Deckers has sustained and will sustain, and
17 all gains, profits and advantages obtained by Defendant as a result of its infringing acts
18 alleged above in an amount not yet known, and the costs of this action.
19 FOURTH CLAIM FOR RELIEF
20 (Trademark Infringement Under California Common Law)
23 57. Deckers has common law rights to the Yoga Sling Common Law
24 Trademark in the state of California due to its extensive promotion and sale of
25 products in connection with said mark the state of California.
26 58. Deckers’ Yoga Sling Common Law Trademark has achieved a high
27 degree of consumer recognition and secondary meaning nationwide and within the
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1 state of California, which serves to identify Deckers as the source of the high-quality
2 products on which the mark appears.
3 59. Defendant’s infringement of the Yoga Sling Common Law Trademark
4 constitutes common law trade dress infringement in violation of the common law of
5 the State of California.
6 60. Defendant’s unauthorized use of Deckers’ Yoga Sling Common Law
7 Trademark has caused and is likely to cause confusion as to the source of Defendant’s
8 products, all to the detriment of Deckers.
20 prohibiting Defendant from infringing the Yoga Sling Common Law Trademark, and
21 to recover all damages, including attorneys’ fees, that Deckers has sustained and will
22 sustain, and all gains, profits and advantages obtained by Defendant as a result of its
23 infringing acts alleged above in an amount not yet known, and the costs of this action.
24 FIFTH CLAIM FOR RELIEF
25 (Unfair Competition Under California Common Law)
28 66. Defendant’s infringement of the YOGA SLING Trade Dress and Yoga
12
1 Sling Common Law Trademark constitutes unfair competition in violation of the

2 common law of the State of California.
3 67. Deckers has invested a substantial amount of time, skill and money in
4 developing its footwear styles and trademarks.
5 68. Upon information and belief, Defendant is a competitor of Deckers and
6 has copied Deckers’ footwear styles and trademarks in an effort to exploit Deckers’
7 reputation in the market. Defendant misappropriated and used Deckers’ footwear styles
8 and name at little or no cost to Defendant.
9 69. Defendant’s misappropriation and use of Deckers’ footwear styles and
10 trademark is without the authorization or consent of Deckers; and Deckers has been
11 injured by the Defendant’s conduct.
12 70. Defendant’s infringing acts are intended to capitalize on Deckers’
13 goodwill associated therewith for Defendant’s own pecuniary gain. Deckers has
14 expended substantial time, resources and effort to obtain an excellent reputation for its
15 brands of footwear. As a result of Deckers’ efforts, Defendant is now unjustly enriched
16 and is benefiting from property rights that rightfully belong to Deckers.
28 prohibiting Defendant from infringing the YOGA SLING Trade Dress and the Yoga
13
1 Sling Common Law Trademark, and to recover all damages, including attorneys’ fees,
2 that Deckers has sustained and will sustain, and all gains, profits and advantages
4 yet known, and the costs of this action.
5 SIXTH CLAIM FOR RELIEF
6 (Unfair Competition Under California Unfair Business Practices Act, Cal. Bus. &
7 Prof. Code, § 17200, et. seq.)
10 76. Defendant’s appropriation, adoption and use of the YOGA SLING Trade
11 Dress and Yoga Sling Common Law Trademark in connection with the sale and
12 offering for sale of footwear is likely to confuse or mislead consumers into believing
13 that Defendant’s goods are authorized, licensed, affiliated, sponsored, and/or approved
14 by Deckers, thus constituting a violation of the California Unfair Business Practices
15 Act, Cal. Bus. & Prof. Code, § 17200, et. seq.
16 77. The deceptive, unfair and fraudulent practices set forth herein have been
17 undertaken with knowledge by Defendant willfully with the intention of causing harm
18 to Deckers and for the calculated purpose of misappropriating Deckers’ goodwill and
19 business reputation.
20 78. Defendant’s of Deckers’ YOGA SLING Trade Dress and Yoga Sling
21 Common Law Trademark has deprived Deckers of the right to control the use of its
23 79. As a direct and proximate result of Defendant’s unlawful infringement,
24 Deckers has suffered damages and will continue to suffer damages in an amount that is
25 not presently ascertainable but will be proven at trial. Deckers is entitled to all
26 available relief provided for in California Unfair Business Practices Act, Cal. Bus. &
27 Prof. Code, § 17200, et. seq. including permanent injunctive relief.
28
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1 PRAYER FOR RELIEF

2 WHEREFORE, Plaintiff Deckers Outdoor Corporation respectfully prays for
3 judgment against Defendant Target Corporation as follows:
4 1. A Judgment that Defendant has infringed Deckers’ YOGA SLING Trade
5 Dress in violation of 15 U.S.C. § 1125 and that Defendant’s infringement was willful;
6 2. An order granting temporary, preliminary and permanent injunctive relief
7 restraining and enjoining Defendant, its agents, servants, employees, officers,
8 associates, attorneys, and all persons acting by, through, or in concert with any of
9 them, are hereby temporarily, preliminarily, and permanently enjoined from using
10 Deckers’ intellectual property, including, but not limited to:
11 a. manufacturing, importing, advertising, marketing, promoting,
12 supplying, distributing, offering for sale, or selling the Accused Products or any other
13 products which bear Deckers’ YOGA SLING Trade Dress, or designs confusingly
14 similar thereto;
15 b. engaging in any other activity constituting unfair competition with
16 Deckers, or acts and practices that deceive consumers, the public, and/or trade,
17 including without limitation, the use of designations and design elements used or
18 owned by or associated with Deckers; and
19 c. committing any other act which falsely represents or which has the
20 effect of falsely representing that the goods and services of Defendant are licensed by,
21 authorized by, offered by, produced by, sponsored by, or in any other way associated
22 with Deckers;
23 3. Ordering Defendant to recall from any distributors and retailers and to
24 deliver to Deckers for destruction or other disposition all remaining inventory of all
25 Accused Products and related items, including all advertisements, promotional and
26 marketing materials therefore, as well as means of making same;
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1 4. Ordering Defendant to file with this Court and serve on Deckers within
2 thirty (30) days after entry of the injunction a report in writing, under oath setting forth
3 in detail the manner and form in which Defendant has complied with the injunction;
4 5. Ordering an accounting by Defendant of all gains, profits and advantages
5 derived from its wrongful acts pursuant to 15 U.S.C. § 1117(a);
6 6. Awarding Deckers all of Defendant’s profits and all damages sustained by
7 Deckers as a result of Defendant’s wrongful acts, and such other compensatory
8 damages as the Court determines to be fair and appropriate;
9 7. Awarding enhanced damages;
10 8. Finding that this is an exceptional case under 15 U.S.C. § 1117 and
11 awarding attorneys’ fees there under;
12 9. Awarding applicable interest, costs, disbursements and attorneys’ fees;
13 10. Awarding Deckers’ punitive damages in connection with its claims under
14 California law; and
15 11. Such other relief as may be just and proper.
16
17 Dated: July 18, 2019 BLAKELY LAW GROUP
18
19 By: _______________________________
Brent H. Blakely
20 Jessica C. Covington
Attorneys for Plaintiff
21 Deckers Outdoor Corporation
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1 DEMAND FOR JURY TRIAL

2 Pursuant to Rule 38(b) of the Federal Rules of Civil Procedure, Plaintiff Deckers
3 Outdoor Corporation hereby demands a trial by jury as to all claims in this litigation.
4
5 Dated: July 18, 2019 BLAKELY LAW GROUP
6
7 By: _______________________________
Brent H. Blakely
8 Jessica C. Covington
Attorneys for Plaintiff
9 Deckers Outdoor Corporation
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Case 2:19-cv-06203 Document 1 Filed 07/18/19 Page 1 of 17 Page ID #:1

1 Brent H. Blakely (SBN 157292)

1 Plaintiff Deckers Outdoor Corporation for its claims against Defendant

1 whether individual, corporate and/or partnership entities named herein as DOES 1

1 51. Defendant’s unauthorized use of Deckers’ YOGA SLING Trade Dress

1 Sling Common Law Trademark constitutes unfair competition in violation of the

1 PRAYER FOR RELIEF

1 DEMAND FOR JURY TRIAL

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