FREE DOWNLOAD: Complaint - Coach, INC., et al. v. The Buyer's Market, Inc., an Illinois Corporation, d/b/a Buyer's Flea Market, et al., Case 1:10-cv-03781 (N.D. Ill.)

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

COACH, INC. and COACH SERVICES, INC.,

Plaintiffs,                                             Case No.

v.

THE BUYER'S MARKET, INC., AN ILLINOIS

CORPORATION, d/b/a BUYER'S FLEA

MARKET, and DOES 1 through100,

Defendants.

COMPLAINT

Plaintiffs Coach, Inc. and Coach Services, Inc. (hereinafter collectively referred to as "Coach" or "Plaintiffs"), through their undersigned counsel, for their complaint against The Buyer's Market, Inc., an Illinois coiporation, d/b/a Buyer's Flea Market ("Buyer's Market"), and DOES 1 through 100 (hereinafter collectively refened to as "Defendants") allege as follows:

Nature of the Action

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).

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