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IN THE UNITED STATES
FOR THE NORTHERN
DISTRICT OF ILLINOIS
and COACH SERVICES, INC.,
Plaintiffs, Case No.
CHARLIE'S OF ILLINOIS, INC.
CHARLIE'S FLEA MARKET,
SAI YUJ CHEN,
GING FANG CHEN, LIN MEI
YU, and DOES
Coach, Inc. and Coach Services, Inc. (hereinafter collectively referred to as
"Coach" or "Plaintiffs"), through their undersigned counsel,
for their complaint against Montana Charlie's of Illinois, Inc. d/b/a Montana
Charlie's Flea Market, Sai Yuj Chen ("Defendant Yuj Chen"), Ging Fang
Chen ("Defendant Fang Chen") and Lin Mei Yu ("Defendant Mei
Yu"),and DOES 1 through 100 (hereinafter collectively referred to as "Defendants")
allege as follows:
Nature of the Action
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. Montana Charlie's
of Illinois, INC. d/b/a Montana Charlie's Flea Market, et al., Case
1:10-cv-03751, (N.D. Ill.)