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IN THE UNITED STATES DISTRICT
FOR THE NORTHERN DISTRICT OF
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and COACH SERVICES, INC.,
CHICAGO, d/b/a NEW MAXWELL
CONG WU, XIAO YANG,
and DOES 1
Plaintiffs Coach, Inc.
and Coach Services, Inc. (hereinafter collectively referred to as “Coach” or
“Plaintiffs”), through their undersigned counsel, for their complaint against
City of Chicago d/b/a New Maxwell Street Market, Cong Wu (“Defendant Wu”), Xiao
Yang (“Defendant Yang”),and DOES 1 through 100 (hereinafter collectively
referred to as “Defendants”) allege as follows:
Nature of the
1. This is an action
for trademark infringement, trade dress infringement, and counterfeiting under
the Lanham Act (15 U.S.C. §§ 1114, 1116, 1117, 1125(a) and (c)); copyright
infringement under the United States Copyright Act (17 U.S.C. § 501 et seq.);
trademark infringement, unfair competition and unjust enrichment under Illinois
common law; trademark dilution under Illinois common law and the Illinois
Anti-Dilution Act (765 ILCS 1035/15); and
unfair competition under the Illinois Consumer Fraud and Deceptive Business
Practices Act (815 ILCS 505).
Please click on the link at the top of the post to view or download
the entire complaint from Coach, INC., et al. v. City of Chicago, d/b/a New Maxwell Street Mark, et al., Case 1:10-cv-03108 (N.D. Ill.).