UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF INDIANA 

FORT WAYNE DIVISION 

NORTH ATLANTIC OPERATING COMPANY, 

INC.; and NATIONAL TOBACCO COMPANY, 

L.P., 

Plaintiffs, 

v. 

KPC DISTRIBUTOR INC; KULDEEP SINGH; 

PARAMJIT SINGH; CHARANJIT SINGH; 

BURGER’S, INC., D.B.A. BURGER DAIRY; 

JGM STORES INC., D.B.A. BURGER DAIRY II; 

KIRANDEEP, INC., D.B.A. CRESCENT 

CORNER EXPRESS; KSL STORES INC., D.B.A. 

GET 2 GO #10; KSL HOLDINGS INC., D.B.A. 

GET 2 GO #13; COLISEUM QUICK MART INC., 

A.K.A. GET 2 GO #15; CALHOUN STORE INC., 

A.K.A. GET 2 GO 16; KPC BROTHERS INC., 

A.K.A. GET 2 GO 17, D.B.A. GET 2 GO; GET 2 

GO 18; VIRK BROTHERS ENTERPRISES INC., 

A.K.A. GET 2 GO 19, D.B.A. SHELL GET 2 GO 

#19; JAT BOYZ STORES INC., A.K.A. HARLAN 

QUICK STOP; KPC INVESTMENTS LLC, 

A.K.A. ICEWAY EXPRESS; JOHN DOES 1-10; 

AND XYZ COMPANIES 1-10, 

Defendants. 

CIVIL ACTION NO. 1:16-cv-00307 

COMPLAINT 

JURY TRIAL DEMANDED 

Plaintiff North Atlantic Operating Company, Inc. (“NAOC”), and its affiliated company 

Plaintiff National Tobacco Company, L.P. (“NTC”) (together, “North Atlantic”), by and through 

their attorneys, hereby bring this civil action against Defendants KPC Distributor Inc.; Kuldeep 

Singh; Paramjit Singh; Charanjit Singh; Burger’s, Inc., d.b.a. Burger Dairy; JGM Stores Inc., 

d.b.a. Burger Dairy II; Kirandeep, Inc., d.b.a. Crescent Corner Express; KSL Stores Inc., d.b.a. 

Get 2 Go #10; KSL Holdings Inc., d.b.a. Get 2 Go #13; Coliseum Quick Mart Inc., a.k.a. Get 2 

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Go #15; Calhoun Store Inc., a.k.a. Get 2 Go 16; KPC Brothers Inc., a.k.a. Get 2 Go 17, d.b.a. Get 

2 Go; Get 2 Go 18; Virk Brothers Enterprises Inc., a.k.a. Get 2 Go 19, d.b.a. Shell Get 2 Go #19; 

JAT Boyz Stores Inc., a.k.a. Harlan Quick Stop; KPC Investments LLC, a.k.a. Iceway Express; 

John Does 1-10; and XYZ Companies 1-10, (collectively, “Defendants”). In support thereof, 

North Atlantic alleges and states as follows: 

NATURE OF THE ACTION

1. This is an anti-counterfeiting action against those who manufacture, import, sell, 

and/or otherwise distribute counterfeit versions of North Atlantic’s highly popular ZIG-ZAG® 

cigarette paper products (defined as roll-your-own cigarette papers and accessories) in Indiana. 

2. As detailed below, the Defendants are distributing counterfeit versions of North 

Atlantic’s ZIG-ZAG® and NAOC® Trademarks (defined herein) and copyrighted text on 

cigarette paper products and packaging that look identical to North Atlantic products, but that are 

not distributed by North Atlantic. In reality, these counterfeit products are inferior, cheaper 

versions sold without any known quality control or authorization. 

3. The products Defendants distribute are not real, but in fact are cheap counterfeit 

knockoffs that can be distinguished from North Atlantic’s authentic products on sight alone—

once one knows what to look for. Ordinary consumers, however, are being duped into 

purchasing fake products at the point of sale. 

4. North Atlantic has collected and analyzed samples of Defendants’ purported ZIGZAG products, their packaging, and their contents, and it has confirmed in each case the 

counterfeit nature of those products, packaging, and contents. 

5. North Atlantic’s authentic ZIG-ZAG® cigarette paper products are subject to the 

highest quality control standards. By contrast, counterfeit ZIG-ZAG® brand products are 

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distributed with no known safety or quality control standards. It is impossible for North Atlantic 

to verify the conditions under which the counterfeit products are manufactured and stored. As 

such, North Atlantic has irretrievably lost the ability to control the quality and relative safety of 

products that appear to be sold under its brand. 

6. North Atlantic has expended significant financial and human capital investigating 

the Defendants and their counterfeiting. As detailed below, North Atlantic believes Defendants 

are large-scale distributors responsible for manufacturing and/or importing the counterfeit 

products into the United States, and for distributing the products to consumers at the wholesale 

and retail levels. 

7. North Atlantic brings the instant lawsuit to protect itself and consumers from: 

a. Trademark infringement, in violation of Section 32 of the Lanham Act (15 U.S.C. 

§ 1114); 

b. False designation of origin, and trademark and trade dress infringement, in 

violation of Section 43 of the Lanham Act (15 U.S.C. § 1125(a)); 

c. Copyright infringement, in violation of the Copyright Act of 1976 (17 U.S.C. §§ 

101 et seq.); and 

d. Trademark infringement and unfair competition under Indiana common law. 

THE PARTIES 

The Plaintiffs 

8. Plaintiff NAOC is a corporation organized and existing under the laws of the 

State of Delaware with an office and principal place of business at 5201 Interchange Way, 

Louisville, Kentucky 40229. 

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9. Plaintiff NTC is a limited partnership organized and existing under the laws of the 

State of Delaware with an office and principal place of business at 5201 Interchange Way, 

Louisville, Kentucky 40229. 

10. Together, NAOC and NTC are the exclusive United States licensees of the worldfamous ZIG-ZAG® brand cigarette paper products. As such, they have full right and authority 

to enforce the ZIG-ZAG® intellectual property rights defined herein. 

The Defendants 

11. Defendant KPC Distributor Inc. is an Indiana for-profit corporation with an 

address and wholesale store at 3212 N Wells Street, Fort Wayne, Indiana 46808 (“KPC 

Distributor”). 

12. Defendant KPC Distributor is involved in the sale and/or other distribution of 

counterfeit ZIG-ZAG® cigarette paper products to Indiana consumers. 

13. Upon information and belief, Defendant KPC Distributor is owned and/or 

operated by three individuals who use Defendant KPC Distributor as a vehicle for their own 

infringement: (i) Defendant Kuldeep Singh, (ii) Defendant Paramjit Singh; and (iii) Defendant 

Charanjit Singh. 

14. Defendant Kuldeep Singh is an Indiana citizen residing at 1011 Coral Isle Cove, 

Fort Wayne, Indiana 46845 and/or 10819 Baldham Pass, Fort Wayne, Indiana 46845. 

15. Defendant Kuldeep Singh is an incorporator of Defendant KPC Distributor and is 

involved in the sale and/or other distribution of counterfeit ZIG-ZAG® cigarette paper products 

to Indiana consumers. 

16. Defendant Paramjit Singh is an Indiana citizen residing at 1011 Coral Isle Cove, 

Fort Wayne, Indiana 46845. 

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17. Defendant Paramjit Singh is an incorporator and the registered agent of Defendant 

KPC Distributor, and is involved in the sale and/or other distribution of counterfeit ZIG-ZAG® 

cigarette paper products to Indiana consumers. 

18. Defendant Charanjit Singh is an Indiana citizen residing at 1011 Coral Isle Cove, 

Fort Wayne, Indiana 46845 and/or 6901 Endicott Drive, Fort Wayne, Indiana 46808. 

19. Defendant Charanjit Singh is an incorporator and the secretary of Defendant KPC 

Distributor, and is involved in the sale and/or other distribution of counterfeit ZIG-ZAG® 

Orange to Indiana consumers. 

20. Alone or together, Defendants Kuldeep Singh, Paramjit Singh, and Charanjit 

Singh own and/or operate other retail and wholesale stores in Indiana that have also been selling 

or otherwise distributing counterfeit ZIG-ZAG® cigarette paper products, including: 

a. Defendant Burger’s, Inc., d.b.a. Burger Dairy (“Burger Dairy”), an Indiana 

corporation with an address at 1412 N. Wells, Fort Wayne, Indiana 46808. 

b. Defendant JGM Stores Inc., d.b.a. Burger Dairy II (“Burger Dairy II”), an Indiana 

for-profit corporation with an address and retail store at 1450 Saint Joe Blvd., Fort 

Wayne, Indiana 46805. 

c. Defendant Kirandeep, Inc., d.b.a. Crescent Corner Express (“Crescent Corner 

Express”), an Indiana for-profit corporation with an address and retail store at 

1202 E State Blvd., Fort Wayne, Indiana 46805. 

d. Defendant KSL Stores Inc., d.b.a. Get 2 Go #10 (“Get 2 Go 10”), an Indiana forprofit corporation with an address and retail store at 422 Spring Street, Fort 

Wayne, Indiana 46808. 

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e. Defendant KSL Holdings Inc., d.b.a. Get 2 Go #13 (“Get 2 Go 13”), an Indiana 

for-profit corporation with an address and retail store at 8717 US-24 West, Fort 

Wayne, Indiana 46804. 

f. Defendant Coliseum Quick Mart Inc., a.k.a. Get 2 Go #15 (“Get 2 Go 15”), an 

Indiana for-profit corporation with an address and retail store at 3116 W Coliseum 

Blvd., Fort Wayne, Indiana 46808. 

g. Defendant Calhoun Store Inc., a.k.a. Get 2 Go 16 (“Get 2 Go 16”), an Indiana forprofit corporation with an address and retail store at 4832 S Calhoun Street, Fort 

Wayne, Indiana 46807. 

h. Defendant KPC Brothers Inc., a.k.a. Get 2 Go 17, d.b.a. Get 2 Go (“Get 2 Go 

17”), an Indiana for-profit corporation with an address and retail store at 1817 W 

Main Street, Fort Wayne, Indiana 46808. 

i. Defendant Get 2 Go 18, upon information and belief, an Indiana corporation with 

an address and retail store at 720 E Tillman Road, Fort Wayne, Indiana 46816. 

j. Defendant Virk Brothers Enterprises Inc., a.k.a. Get 2 Go 19, d.b.a. Shell Get 2 

Go #19 (“Get 2 Go 19”), an Indiana for-profit corporation with an address and 

retail store at 4935 Bluffton Road, Fort Wayne, Indiana 46809. 

k. Defendant JAT Boyz Stores Inc., a.k.a. Harlan Quick Stop (“Harlan Quick Stop”), 

an Indiana for-profit corporation with an address and retail store at 17013 State 

Road 37, Harlan, Indiana 46743. 

l. Defendant KPC Investments LLC, a.k.a. Iceway Express (“Iceway Express”), an 

Indiana limited liability corporation with an address and retail store at 3996 

Iceway, Fort Wayne, Indiana 46805. 

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The John Doe and XYZ Company Defendants 

21. North Atlantic has reason to believe that other individuals and companies assist 

the above-named Defendants in their counterfeiting, and that there are other individuals 

employed by and/or other companies affiliated with the Defendants that are also distributing 

counterfeit ZIG-ZAG® cigarette paper products to Indiana consumers. North Atlantic does not 

know these individuals’/companies’ true names and capacities. Therefore, North Atlantic sues 

them as John Does #1-10 and XYZ Companies #1-10, inclusive. North Atlantic will amend this 

Complaint to allege the true names and capacities of these entities when/if it ascertains the same. 

JURISDICTION AND VENUE 

22. This Court has subject matter jurisdiction over North Atlantic’s Lanham Act 

claims pursuant to 28 U.S.C. §§ 1331, 1338, and 15 U.S.C. § 1121. 

23. This Court has subject matter jurisdiction over North Atlantic’s Indiana commonlaw claims pursuant to 28 U.S.C. § 1338(b) and 28 U.S.C. § 1367(a). 

24. Personal jurisdiction is proper in this judicial district because each Defendant 

resides and/or is domiciled here; has its registered address and principal place of business here; 

and/or has had continuous, systematic, and substantial contacts within the state of Indiana, 

including doing business in Indiana and directing sales of counterfeit products to Indiana 

consumers. 

25. Venue is proper in this judicial district pursuant to 28 U.S.C. § 1391, in that a 

majority of Defendants reside here and a substantial portion of the events giving rise to the 

claims in this Complaint occurred here. 

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FACTUAL ALLEGATIONS

North Atlantic’s ZIG-ZAG® Brand Products 

26. Since 1938, North Atlantic and its predecessor-in-interest have continuously 

distributed ZIG-ZAG® brand cigarette paper products in the United States. In fact, in 1997, 

North Atlantic was established to be the exclusive United States distributor of authentic ZIGZAG® brand cigarette paper products. 

27. Authentic ZIG-ZAG® brand cigarette paper products come in several varieties, 

which differ in thickness, quality of paper, size, and the like. 

28. Among the cigarette paper products distributed by North Atlantic in the United 

States are ZIG-ZAG® 1 1⁄4 Size French Orange (“ZIG-ZAG® Orange”), shown below: 

 ZIG-ZAG® Orange 

29. Authentic ZIG-ZAG® Orange cigarette paper products are described as easy 

rolling, slow-burning classic papers. 

30. All authentic ZIG-ZAG® Orange cigarette paper products are manufactured in 

France using the highest-quality ingredients. 

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31. All authentic ZIG-ZAG® Orange cigarette paper products are imported into the 

United States by North Atlantic through one particular port of entry. Thereupon, North Atlantic 

subjects them to strict and exacting quality control tests. 

32. North Atlantic continually strives to ensure that all of its authentic ZIG-ZAG® 

brand products, including ZIG-ZAG® Orange: 

a. Are of uniform high quality; 

b. Meet with North Atlantic’s precise quality standards; and 

c. Properly display the ZIG-ZAG® and NAOC® Trademarks (defined below) and 

other source identifiers. 

33. If the products pass North Atlantic’s rigorous inspection, then they are sold 

directly to North Atlantic’s “direct accounts” (for the most part, variety wholesale distributors 

throughout the United States). 

34. North Atlantic’s direct accounts distribute the authentic products to retailers and, 

in some cases, other wholesale distributors. 

35. Ultimately, the authentic products are purchased and used by United States 

consumers, who attribute to them a high degree of quality and brand goodwill. 

North Atlantic’s ZIG-ZAG® and NAOC® Trademarks 

36. As described below, all authentic ZIG-ZAG® Orange cigarette paper products 

distributed by North Atlantic in the United States have continuously displayed the following 

valid and subsisting trademarks marks, which appear on the Principal Register in the United 

States Patent and Trademark Office (“USPTO”), and which have become incontestable: 

a. Registration No. 610,530 for ZIG-ZAG (stylized) 

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b. Registration No. 1,127,946 for ZIG-ZAG (text) 

c. Registration No. 2,169,540 for the Smoking Man Design (circle border) 

d. Registration No. 2,169,549 for the Smoking Man Design (no border) 

(together, the “ZIG-ZAG® Trademarks”) (true and correct copies of the records from the 

USPTO denoting the federal trademark registrations for the ZIG-ZAG® Trademarks are attached 

hereto as Exhibit A). 

37. North Atlantic holds exclusive distribution rights to cigarette paper products 

bearing the ZIG-ZAG® Trademarks pursuant to an exclusive trademark licensing/distribution 

agreement with French company Bolloré, S.A., the trademark owner. 

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38. North Atlantic also owns federal trademark registration for the following NORTH 

ATLANTIC OPERATING COMPANY, INC. and Gear Design trademarks, which appear on the 

Principal Register in the USPTO: 

a. Registration Nos. 2,664,694 and 2,664,695 

b. Registration Nos. 2,610,473 and 2,635,446 

(together, the “NAOC® Trademarks) (true and correct copies of the records from the USPTO 

denoting the federal trademark registrations for the NAOC® Trademarks are attached hereto as 

Exhibit B). 

39. Like the ZIG-ZAG® Trademarks, the NAOC® Trademarks have continuously 

appeared on all authentic ZIG-ZAG® Orange cigarette paper products distributed by North 

Atlantic in the United States. 

40. Because of its tremendous sales history, and because of the exclusive, lengthy, 

and extensive use of the ZIG-ZAG® and NAOC® Trademarks on goods of superior quality, 

North Atlantic has developed substantial goodwill and a reputation as the exclusive source of 

high-quality ZIG-ZAG® brand cigarette paper products in the United States. 

41. North Atlantic has also become well known, nationwide, as the exclusive and 

only source of authentic ZIG-ZAG® brand cigarette paper products—including ZIG-ZAG® 

Orange—and United States consumers naturally associate those products with North Atlantic. 

42. Thus, the ZIG-ZAG® and NAOC® Trademarks have become famous as a matter 

of law. 

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North Atlantic’s NAOC© Copyright 

43. North Atlantic also owns a federal copyright registration for the visual 

material/computer graphic entitled, “North Atlantic Operating Company, Inc.” (the “NAOC© 

Copyright”), a true and correct copy of which is annexed hereto as Exhibit C. 

44. Currently, and at all relevant times, North Atlantic has been the proprietor of all 

rights, title, and interest in and to the NAOC© Copyright. 

45. The NAOC© Copyright also appears on all authentic ZIG-ZAG® Orange 

cigarette paper products distributed by North Atlantic in the United States. 

North Atlantic’s Highly Distinctive Product Packaging 

46. The product packaging for North Atlantic’s authentic ZIG-ZAG® Orange is also 

highly distinctive. 

47. As illustrated below, North Atlantic’s authentic ZIG-ZAG® Orange product 

packaging features: (a) the ZIG-ZAG® and NAOC® Trademarks, (b) the NAOC© Copyright, 

(c) gold-fill lettering and design elements, (d) French phrases such as “Qualite Superieure” and 

“Braunstein Freres France,” and (e) the express statement that such products are “Distributed by 

North Atlantic Operating Company, Inc.” 

 Booklet (inside) 

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 Booklet (cover) 

(ZIG-ZAG® Trademarks, including ZIG-ZAG® (stylized) and Smoking Man Design; 

the NAOC® Trademarks, including the Gear Design; and the NAOC© Copyright) 

 Carton (top view) 

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 Carton (side view)

 (ZIG-ZAG® and NAOC® Trademarks and NAOC© Copyright) 

(viewed together, the “ZIG-ZAG® Orange Trade Dress”) (8 1⁄2” x 11” versions of the above 

photographs are annexed hereto as Exhibit D). 

48. Currently, and at all relevant times, North Atlantic has used the ZIG-ZAG® 

Orange Trade Dress in commerce in the United States. 

49. The ZIG-ZAG® Orange Trade Dress is arbitrary, non-functional, and highly 

distinctive. 

50. The ZIG-ZAG® Orange Trade Dress has been extensively and continuously used 

by North Atlantic, is inherently distinctive, and/or has become distinctive through the acquisition 

of secondary meaning. 

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51. Upon information and belief, United States consumers who see the ZIG-ZAG® 

Orange Trade Dress immediately associate it with North Atlantic as a source identifier and do 

not associate it with any other source. 

Defendants’ Willful Infringing Activities 

52. Based on North Atlantic’s investigation to date, the Defendants herein are 

engaged in a widespread, unlawful scheme of acquiring, selling, and/or otherwise distributing 

counterfeit ZIG-ZAG® cigarette paper products, specifically, counterfeit ZIG-ZAG® Orange. 

53. Upon information and belief, Defendants’ misconduct in engaging in this 

counterfeiting scheme is willful. 

54. The key to Defendants’ scheme is the sale of products that use packaging that 

simulates the packaging of authentic ZIG-ZAG® Orange cigarette paper products distributed by 

North Atlantic, namely, packaging that bears virtually identical reproductions of the ZIG-ZAG® 

and NAOC® Trademarks and unauthorized, unlicensed copies of the NAOC© Copyright, and 

that looks like the ZIG-ZAG® Orange Trade Dress. 

55. Although authentic and counterfeit products appear similar at first glance, a close 

inspection reveals numerous differences. 

56. While authentic ZIG-ZAG® brand products distributed by North Atlantic are 

subject to strict and exacting quality control standards, the counterfeit ZIG-ZAG® products are 

not subject to any known quality control standards. As a result, North Atlantic cannot vouch for 

the safety or quality of the counterfeit products, as they have not, by definition, been subjected to 

any of North Atlantic’s quality control tests. 

57. North Atlantic also cannot tell what conditions the counterfeit products have been 

subjected to, and it cannot vouch for the quality of the ingredients used to manufacture them 

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(even though they are distributed in packaging displaying North Atlantic’s registered and 

licensed trademark and the phrase “Distributed by North Atlantic Operating Company, Inc.”). 

58. None of the Defendants are authorized or licensed to sell or distribute any 

infringing products bearing the ZIG-ZAG® or NAOC® Trademarks; nor are any of the 

Defendants authorized or licensed to sell or distribute any product packaging that simulates 

North Atlantic’s ZIG-ZAG® Orange Trade Dress or that displays reproductions or exact copies 

of the NAOC© Copyright. Nevertheless, North Atlantic has caught them doing so, in violation 

of North Atlantic’s rights and to the detriment of Indiana consumers. 

Defendants’ Sale/Distribution of Counterfeit Products 

59. Defendants have been willfully selling and distributing counterfeit ZIG-ZAG® 

Orange cigarette paper products to Indiana consumers. 

60. Defendants have sold dozens of cartons and hundreds of booklets of confirmed 

counterfeit ZIG-ZAG® Orange to undercover North Atlantic representatives—and these are just 

the sales North Atlantic knows about. Extrapolating from these sales, Defendants’ distribution 

of counterfeit ZIG-ZAG® Orange is on a much larger scale. 

61. Between March 2016 and the present, North Atlantic obtained no less than eight 

(8) cartons of purported ZIG-ZAG® Orange directly from Defendant KPC Distributor. Through 

inspection and analysis of the particular products, North Atlantic conclusively determined that 

the products, their packaging, and their contents are counterfeit. Therefore, by definition, the 

products/packaging/contents have not been subject to North Atlantic’s rigorous quality control 

standards, and North Atlantic has no way of verifying their quality or relative safety. 

62. Between March 2016 and the present, North Atlantic obtained no less than three 

(3) booklets of purported ZIG-ZAG® Orange directly from Defendant Burger Dairy II. Through 

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inspection and analysis, North Atlantic conclusively determined that the particular products, their 

packaging, and their contents are counterfeit. Therefore, by definition, the 

products/packaging/content have not been subject to North Atlantic’s rigorous quality control 

standards, and North Atlantic has no way of verifying their quality or relative safety. 

63. Between March 2016 and the present, North Atlantic obtained no less than two 

(2) booklets of purported ZIG-ZAG® Orange directly from Defendant Burger Dairy. Through 

inspection and analysis, North Atlantic conclusively determined that the particular products, their 

packaging, and their contents are counterfeit. Therefore, by definition, the 

products/packaging/contents have not been subject to North Atlantic’s rigorous quality control 

standards, and North Atlantic has no way of verifying their quality or relative safety. 

64. Between March 2016 and the present, North Atlantic obtained no less than three 

(3) booklets of purported ZIG-ZAG® Orange directly from Defendant Crescent Corner Express. 

Through inspection and analysis, North Atlantic conclusively determined that the particular 

products, their packaging, and their contents are counterfeit. Therefore, by definition, the 

products/packaging/contents have not been subject to North Atlantic’s rigorous quality control 

standards, and North Atlantic has no way of verifying their quality or relative safety. 

65. Between March 2016 and the present, North Atlantic obtained no less than three 

(3) booklets of purported ZIG-ZAG® Orange directly from Defendant Crescent Corner Express. 

Through inspection and analysis, North Atlantic conclusively determined that the particular 

products, their packaging, and their contents are counterfeit. Therefore, by definition, the 

products/packaging/contents have not been subject to North Atlantic’s rigorous quality control 

standards, and North Atlantic has no way of verifying their quality or relative safety. 

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66. Between March 2016 and the present, North Atlantic obtained no less than three 

(3) booklets of purported ZIG-ZAG® Orange directly from Defendant Get 2 Go 10. Through 

inspection and analysis, North Atlantic conclusively determined that the particular products, their 

packaging, and their contents are counterfeit. Therefore, by definition, the 

products/packaging/contents have not been subject to North Atlantic’s rigorous quality control 

standards, and North Atlantic has no way of verifying their quality or relative safety. 

67. Between March 2016 and the present, North Atlantic obtained no less than two 

(2) booklets of purported ZIG-ZAG® Orange directly from Defendant Get 2 Go 13. Through 

inspection and analysis, North Atlantic conclusively determined that the particular products, their 

packaging, and their contents are counterfeit. Therefore, by definition, the 

products/packaging/contents have not been subject to North Atlantic’s rigorous quality control 

standards, and North Atlantic has no way of verifying their quality or relative safety. 

68. Between March 2016 and the present, North Atlantic obtained no less than three 

(3) booklets of purported ZIG-ZAG® Orange directly from Defendant Get 2 Go 15. Through 

inspection and analysis, North Atlantic conclusively determined that the particular products, their 

packaging, and their contents are counterfeit. Therefore, by definition, the 

products/packaging/contents have not been subject to North Atlantic’s rigorous quality control 

standards, and North Atlantic has no way of verifying their quality or relative safety. 

69. Between March 2016 and the present, North Atlantic obtained no less than three 

(3) booklets of purported ZIG-ZAG® Orange directly from Defendant Get 2 Go 16. Through 

inspection and analysis, North Atlantic conclusively determined that the particular products, their 

packaging, and their contents are counterfeit. Therefore, by definition, the 

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products/packaging/contents have not been subject to North Atlantic’s rigorous quality control 

standards, and North Atlantic has no way of verifying their quality or relative safety. 

70. Between March 2016 and the present, North Atlantic obtained no less than three 

(3) booklets of purported ZIG-ZAG® Orange directly from Defendant Get 2 Go 17. Through 

inspection and analysis, North Atlantic conclusively determined that the particular products, their 

packaging, and their contents are counterfeit. Therefore, by definition, the 

products/packaging/contents have not been subject to North Atlantic’s rigorous quality control 

standards, and North Atlantic has no way of verifying their quality or relative safety. 

71. Between March 2016 and the present, North Atlantic obtained no less than three 

(3) booklets of purported ZIG-ZAG® Orange directly from Defendant Get 2 Go 18. Through 

inspection and analysis, North Atlantic conclusively determined that the particular products, their 

packaging, and their contents are counterfeit. Therefore, by definition, the 

products/packaging/contents have not been subject to North Atlantic’s rigorous quality control 

standards, and North Atlantic has no way of verifying their quality or relative safety. 

72. Between March 2016 and the present, North Atlantic obtained no less than three 

(3) booklets of purported ZIG-ZAG® Orange directly from Defendant Get 2 Go 19. Through 

inspection and analysis, North Atlantic conclusively determined that the particular products, their 

packaging, and their contents are counterfeit. Therefore, by definition, the 

products/packaging/contents have not been subject to North Atlantic’s rigorous quality control 

standards, and North Atlantic has no way of verifying their quality or relative safety. 

73. Between March 2016 and the present, North Atlantic obtained no less than two 

(2) booklets of purported ZIG-ZAG® Orange directly from Defendant Harlan Quick Stop. 

Through inspection and analysis, North Atlantic conclusively determined that the particular 

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products, their packaging, and their contents are counterfeit. Therefore, by definition, the 

products/packaging/contents have not been subject to North Atlantic’s rigorous quality control 

standards, and North Atlantic has no way of verifying their quality or relative safety. 

74. Between March 2016 and the present, North Atlantic obtained no less than three 

(3) booklets of purported ZIG-ZAG® Orange directly from Defendant Iceway Express. Through 

inspection and analysis, North Atlantic conclusively determined that the particular products, their 

packaging, and their contents are counterfeit. Therefore, by definition, the 

products/packaging/contents have not been subject to North Atlantic’s rigorous quality control 

standards, and North Atlantic has no way of verifying their quality or relative safety. 

The Defendants’ Conduct is Willful 

75. Defendants know they are importing, manufacturing, selling, and/or otherwise 

distributing counterfeit versions of the famous ZIG-ZAG® Orange cigarette paper products. 

76. The circumstances of the purchases and sales of such products underscores the 

products’ counterfeit nature. 

77. Moreover, Defendants are demonstrating their knowledge by failing to keep 

accurate business records and refusing to provide customers with receipts. On more than one 

occasion, Defendant KPC Distributor refused to provide a North Atlantic representative, acting 

undercover, with a receipt. When the representative insisted, Defendant KPC Distributor ripped 

the receipt in two pieces, keeping the piece that displayed Defendant KPC Distributor’s contact 

information for itself. 

The Irreparable Harm to North Atlantic 

78. Defendants’ willful misconduct, described above, is depriving North Atlantic of 

the absolute right to control the quality of products distributed using its ZIG-ZAG® and 

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NAOC® Trademarks and NAOC© Copyright. 

79. Thus, the Defendants are jeopardizing the enormous goodwill and value 

associated with those Trademarks and the NAOC© Copyright, which North Atlantic and/or its 

predecessor-in-interest have built up over the past century. 

80. Defendants’ willful misconduct is also damaging the goodwill and value 

associated with the ZIG-ZAG® Orange Trade Dress, which is highly-distinctive and associated 

exclusively with North Atlantic in consumers’ minds. 

81. Exacerbating the risk of injury to North Atlantic, Defendants’ counterfeit products 

are of a vastly inferior quality compared with North Atlantic’s authentic ZIG-ZAG® brand 

products. Consumers deceived by Defendants’ simulated ZIG-ZAG® Orange products and 

packaging have and will purchase Defendants’ counterfeit products instead of North Atlantic’s 

authentic products. As a result, consumers are likely to think less favorably of North Atlantic 

than if they had purchased North Atlantic’s high-quality authentic products, as they no doubt 

intended to do. 

82. As a direct and proximate result of the foregoing, North Atlantic has suffered and, 

unless Defendants’ conduct is enjoined by this Court, will continue to suffer, actual economic 

damages in the form of lost sales, revenues, and profits, and immediate and irreparable harm to 

its trademarks, copyright, Trade Dress, and goodwill, for which it has no adequate remedy at 

law. 

FIRST CLAIM FOR RELIEF 

FEDERAL TRADEMARK INFRINGEMENT (15 U.S.C. § 1114) 

83. North Atlantic realleges and incorporates by reference each and every allegation 

contained in paragraphs 1 through 82 above, as though fully set forth herein. 

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84. In violation of 15 U.S.C. § 1114, Defendants, independently and in conspiracy 

with one another, used in commerce, without North Atlantic’s consent, either a reproduction, 

counterfeit, copy, or colorable imitation of the ZIG-ZAG® and NAOC® Trademarks on and in 

connection with the sale, offering for sale, distribution, or advertising of counterfeit ZIG-ZAG® 

Orange cigarette paper products, which is likely to cause confusion, or to cause mistake, or to 

deceive consumers. 

85. Defendants’ actions constitute willful infringement of North Atlantic’s exclusive 

rights in and to the ZIG-ZAG® and NAOC® Trademarks, which are registered on the Principal 

Register in the United States Patent and Trademark Office, and which North Atlantic either owns 

or has the exclusive right to use and enforce in the United States. 

86. As a direct and proximate result of Defendants’ willful misconduct, North 

Atlantic has suffered irreparable harm to the value and goodwill associated with the ZIG-ZAG® 

and NAOC® Trademarks, and their reputation in the industry. Unless Defendants are restrained 

from further infringement of the ZIG-ZAG® and NAOC® Trademarks, North Atlantic (and 

consumers) will continue to be irreparably harmed. 

87. North Atlantic has absolutely no adequate remedy at law that will compensate it 

for the continued, irreparable harm that they will suffer if Defendants’ willful misconduct is 

allowed to continue. 

88. As a direct and proximate result of Defendants’ willful misconduct, North 

Atlantic has suffered damages to the valuable NAOC® Trademarks and ZIG-ZAG® Orange 

Trade Dress and other damages in an amount not yet known, but to be proved at trial. North 

Atlantic is also entitled to statutory damages, trebled damages, and/or its reasonable attorneys’ 

fees, at North Atlantic’s option. 

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SECOND CLAIM FOR RELIEF 

FALSE DESIGNATION OF ORIGIN AND 

TRADEMARK/TRADE DRESS INFRINGEMENT (15 U.S.C. § 1225(a)) 

89. North Atlantic realleges and incorporates by reference each and every allegation 

contained in paragraphs 1 through 88 above, as though fully set forth herein. 

90. In violation of 15 U.S.C. § 1125(a), Defendants, independently and in conspiracy 

with one another, in connection with the counterfeit ZIG-ZAG® Orange cigarette paper 

products, used in commerce a slogan, trade dress, word, term, name, symbol, or device, or any 

combination thereof, or a false designation of origin, false or misleading description of fact, or 

false or misleading representation of fact, which was and is likely to cause confusion or to cause 

mistake, or to deceive consumers as to an affiliation, connection, or association with North 

Atlantic. Without limitation, Defendants have willfully infringed North Atlantic’s exclusive 

rights in and to the ZIG-ZAG® and NAOC® Trademarks, the ZIG-ZAG® Orange Trade Dress, 

and associated common law rights. 

91. As a direct and proximate result of Defendants’ willful misconduct, North 

Atlantic has suffered and is suffering irreparable harm to the value and goodwill associated with 

the ZIG-ZAG® and NAOC® Trademarks, the ZIG-ZAG® Orange Trade Dress, and associated 

common law rights, and to North Atlantic’s reputation as a distributor of high-quality ZIGZAG® brand cigarette paper products. 

92. Unless Defendants are restrained from further infringement of the ZIG-ZAG® 

and NAOC® Trademarks, the ZIG-ZAG® Orange Trade Dress, and associated common law 

rights, North Atlantic will continue to be irreparably harmed. 

93. North Atlantic has absolutely no adequate remedy at law that will compensate for 

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the continued and irreparable harm they have suffered, and will continue to suffer, if Defendants’ 

willful misconduct is allowed to continue. 

94. As a direct and proximate result of Defendants’ willful misconduct, North 

Atlantic has suffered damages to the valuable ZIG-ZAG® and NAOC® Trademarks, the ZIGZAG® Orange Trade Dress, and associated common law rights, along with other damages in an 

amount not yet known but to be proved at trial. 

THIRD CLAIM FOR RELIEF 

FEDERAL COPYRIGHT INFRINGEMENT (17 U.S.C. §§ 101 et seq.) 

95. North Atlantic realleges and incorporates by reference each and every allegation 

contained in paragraphs 1 through 94 above, as though fully set forth herein. 

96. Currently, and at all relevant times, North Atlantic has been the sole proprietor of 

all rights, title, and interest in and to the NAOC© Copyright. 

97. As provided by 17 U.S.C. § 106, North Atlantic has the exclusive right to, among 

other things, reproduce, distribute, publicly display, and create derivative works from the 

NAOC© Copyright. 

98. North Atlantic has registered its claim to copyright before the United States 

Copyright Office. To wit, North Atlantic possesses a copyright registration certificate for the 

NAOC© Copyright dated October 11, 2002. 

99. Defendants, acting independently and in conspiracy with one another, have 

directly infringed the NAOC© Copyright by unlawfully reproducing, transmitting, distributing, 

publicly displaying, and/or creating derivative works based on the NAOC© Copyright, in 

violation of North Atlantic’s exclusive rights under 17 U.S.C. § 106. 

100. Upon information and belief, the foregoing actions of Defendants in violation of 

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North Atlantic’s rights have been willful and intentional, executed with full knowledge of North 

Atlantic’s exclusive rights in the NAOC© Copyright and in conscious disregard of those rights. 

101. North Atlantic is entitled to recover from Defendants the profits that Defendants 

obtained through infringements of the NAOC© Copyright, as well as North Atlantic’s damages 

from those infringements, or, at North Atlantic’s election, statutory damages pursuant to 17 

U.S.C. § 504. 

102. North Atlantic is also entitled to recover costs and attorneys’ fees from 

Defendants pursuant to 17 U.S.C. § 505. 

103. Defendants’ willful infringements of North Atlantic’s NAOC© Copyright has 

caused, and unless enjoined by this Court, will continue to cause, irreparable injury to North 

Atlantic, which is not fully compensable in monetary damages. North Atlantic is therefore 

entitled to preliminary and permanent injunctions prohibiting Defendants from further infringing 

North Atlantic’s NAOC© Copyright. 

FOURTH CLAIM FOR RELIEF 

COMMON LAW UNFAIR COMPETITION

104. North Atlantic realleges and incorporates by reference each and every allegation 

contained in paragraphs 1 through 103 above, as though fully set forth herein. 

105. In violation of the common law of the State of Indiana and elsewhere, 

Defendants, independently and in conspiracy with one another, have unfairly competed with 

North Atlantic by selling counterfeit ZIG-ZAG® Orange cigarette paper products. 

106. Defendants’ unauthorized use of North Atlantic’s marks tends to cause confusion, 

mistake, and/or deception among consumers as to the source, quality, and nature of the goods. 

107. Upon information and belief, Defendants have made and will continue to make 

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substantial profits to which they are not entitled. Unless Defendants’ willful misconduct is 

restrained, North Atlantic will continue to be irreparably harmed as set forth above. 

108. North Atlantic has absolutely no adequate remedy at law that will compensate for 

the continued and irreparable harm they will suffer if Defendants’ willful misconduct is allowed 

to continue. 

109. As a direct and proximate result of Defendants’ unfair competition, North Atlantic 

has suffered damages to the valuable ZIG-ZAG® and NAOC® Trademarks, the NAOC© 

Copyright, the ZIG-ZAG® Orange Trade Dress, and its associated common law rights, and it has 

suffered other damages in an amount not yet known but to be proved at trial. 

FIFTH CLAIM FOR RELIEF 

COMMON LAW TRADEMARK INFRINGEMENT

110. North Atlantic realleges and incorporates by reference each and every allegation 

contained in paragraphs 1 through 109 above, as though fully set forth herein. 

111. In violation of the common law of the State of Indiana, Defendants, independently 

and in conspiracy with one another, used in commerce, without North Atlantic’s consent, either a 

reproduction, counterfeit, copy, or colorable imitation of the ZIG-ZAG® and NAOC® 

Trademarks on and in connection with the sale, offering for sale, distribution, or advertising of 

counterfeit ZIG-ZAG® Orange cigarette paper products, which is likely to cause confusion, or to 

cause mistake, or to deceive consumers. 

112. Defendants’ goods are identical to those goods with which the ZIG-ZAG® and 

NAOC® marks are used and registered. 

113. Defendants’ unauthorized use of the ZIG-ZAG® and NAOC® marks is likely to 

cause, and has caused, consumers to believe, mistakenly, that Defendants’ goods are endorsed by 

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or associated with North Atlantic, when in fact they are not. 

114. Upon information and belief, Defendants have and continue to intentionally 

misuse the ZIG-ZAG® and NAOC® marks to convey an immediate commercial impression that 

Defendants are associated with North Atlantic. 

115. Defendant’s actions constitute willful infringement of North Atlantic’s exclusive 

rights in and to the ZIG-ZAG® and NAOC® Trademarks, which North Atlantic either owns or 

has the exclusive right to use and enforce in the United States. 

116. As a direct and proximate result of Defendants’ willful misconduct, North 

Atlantic has suffered irreparable harm to the value and goodwill associated with the ZIG-ZAG® 

and NAOC® Trademarks, and their reputation in the industry. Unless Defendants are restrained 

from further infringement of the ZIG-ZAG® and NAOC® Trademarks, North Atlantic (and 

consumers) will continue to be irreparably harmed. 

117. North Atlantic has absolutely no adequate remedy at law that will compensate it 

for the continued, irreparable harm that they will suffer if Defendants’ willful misconduct is 

allowed to continue. 

PRAYER FOR RELIEF 

WHEREFORE, North Atlantic demands judgment against Defendants as follows: 

1. For judgment that: 

a. Defendants have violated Section 32 of the Lanham Act, 15 U.S.C. § 1114; 

b. Defendants have violated Section 43 of the Lanham Act, 15 U.S.C. § 1125(a); 

c. Defendants have violated the Copyright Act of 1976, 17 U.S.C. § 101 et seq.; 

d. Defendants have unfairly competed with North Atlantic, in violation of 

Indiana common law; 

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e. Defendants have infringed on North Atlantic’s Trademarks, in violation of 

Indiana common law; and 

f. In all instances, Defendants acted in bad faith, willfully, intentionally, and/or 

in malicious disregard of North Atlantic’s lawfully protected rights. 

2. For an order preliminarily and permanently enjoining Defendants, their affiliates, 

subsidiaries, parents, and their respective officers, agents, servants, attorneys, and 

employees, and all persons in active concert or participation with them, and 

mandating that Defendants forever cease and desist and refrain from, anywhere in the 

world: 

a. Directly or indirectly importing, manufacturing, distributing, advertising, 

promoting, making, purchasing, offering for sale, or selling any counterfeit 

ZIG-ZAG® brand cigarette paper products, including but not limited to ZIGZAG® Orange, or any ZIG-ZAG® brand products not sold under the 

authority of North Atlantic, or any packaging for same, containing or 

displaying infringing ZIG-ZAG® or NAOC® Trademarks or the NAOC© 

Copyright, or any colorable imitation thereof, or simulating the ZIG-ZAG® 

Orange Trade Dress; 

b. Selling or passing off, or inducing or enabling others to sell or pass off, any of 

North Atlantic’s products, or products not authorized by North Atlantic, not 

produced, imported, and distributed under the control or supervision of North 

Atlantic, and/or approved for sale in the United States, under the ZIG-ZAG® 

or NAOC® Trademarks or the NAOC© Copyright or the ZIG-ZAG® Orange 

Trade Dress; 

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c. Committing any acts calculated to cause purchasers to believe that counterfeit 

or infringing ZIG-ZAG® brand cigarette paper products are sold under the 

control or supervision of North Atlantic, when they are not; 

d. In any way infringing or damaging the ZIG-ZAG® or NAOC® Trademarks, 

the NAOC© Copyright, or the ZIG-ZAG® Orange Trade Dress, or associated 

common law rights; 

e. Importing, shipping, delivering, distributing, returning, or otherwise disposing 

of, in any manner, products or inventory not authorized by North Atlantic to 

be sold or offered for sale in the United States bearing the ZIG-ZAG® or 

NAOC® Trademarks, the NAOC© Copyright, or ZIG-ZAG® Orange Trade 

Dress; 

f. Otherwise unfairly competing with North Atlantic in any manner; 

g. Attempting, causing, or assisting any of the above-described acts, including 

but not limited to enabling others to conduct the scheme described above, or 

by passing along information to others to allow them to do so; and 

h. Destroying or disposing of any documents, records, or electronically-stored 

information related to the import, manufacture, distribution, advertisement, 

promotion, making, purchase, offer to sell, or sale of any product that has 

been or is intended to be sold in packaging containing the ZIG-ZAG® or 

NAOC® Trademarks or the NAOC© Copyright or simulating the ZIG-ZAG® 

Orange Trade Dress. 

3. For an order enjoining Defendants and their agents, employees, representatives, 

successors, and assigns from forming or causing to be formed any corporation, 

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partnership, or other entity that engages in any of the conduct described above. 

4. For an order requiring Defendants to cooperate with North Atlantic in good faith in its 

investigation of counterfeit sales at their retail and wholesale establishments, 

including, without limitation by: 

a. Permitting North Atlantic representatives or their designees to conduct 

inspections of Defendants’ inventories of cigarette paper products to 

determine whether any cigarette paper products bearing the ZIG-ZAG® or 

NAOC® Trademarks or the NAOC© Copyright, or housed in any packaging 

simulating the ZIG-ZAG® Orange Trade Dress, are counterfeit, and to retain 

possession of any such counterfeit products; 

b. Responding to reasonable requests for information about Defendants’ 

source(s) of ZIG-ZAG® brand cigarette paper products; and 

c. Cooperating with North Atlantic representatives or their designees in their 

investigations of any source(s) of ZIG-ZAG® brand cigarette paper products. 

5. For an order: 

a. Requiring Defendants to account for and pay over to North Atlantic all profits 

derived from their wrongful misconduct to the full extent provided for by 

Section 35(a) of the Lanham Act, 15 U.S.C. § 1117(a); 

b. Requiring Defendants to account for and pay to North Atlantic enhanced 

damages resulting from their wrongful misconduct to the full extent provided 

for by Section 35(b) of the Lanham Act, 15 U.S.C. § 1117(b); 

c. Awarding North Atlantic damages, or statutory damages in an amount not less 

than $2 million ($2,000,000) per trademark pursuant to Section 35(c) of the 

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Lanham Act, 15 U.S.C. § 1117(c); 

d. Requiring Defendants to account for and pay to North Atlantic all profits 

derived from their wrongful misconduct, to the full extent provided for by the 

Copyright Act, 17 U.S.C. § 504; 

e. Awarding North Atlantic damages, or statutory damages in an amount not less 

than $150,000 per infringement of the NAOC© Copyright which occurred 

after the filing of its copyright application against each of the Defendants 

separately and jointly; 

f. Awarding North Atlantic damages to the full extent provided by Indiana state 

law; 

g. Awarding North Atlantic its costs of suit, including reasonable attorneys’ fees; 

and 

h. Awarding such other and further relief as this Court deems just and proper. 

DEMAND FOR JURY TRIAL

 North Atlantic hereby demands a trial by jury on all claims and issues so triable. 

Date: August 17, 2016 Respectfully submitted, 

 By: s/ Gregory W. Pottorff 

Adam Arceneaux, Atty. No. 17219-49 

Gregory W. Pottorff, Atty. No. 30089-49 

ICE MILLER 

One American Square, Suite 2900 

Indianapolis, Indiana 46282 

Tel.: 317-236-5963 

Fax: 317-592-4642 

Gregory.Pottorff@icemiller.com 

Adam.Arceneaux@icemiller.com 

 

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Of Counsel: 

VENABLE LLP 

Marcella Ballard, Esq. (to be admitted pro hac vice) 

Victoria R. Danta, Esq. (to be admitted pro hac vice) 

1270 Avenue of the Americas, 25th Floor 

New York, NY 10020 

Tel.: 212-370-6248 

Fax: 212-307-5598 

MBallard@Venable.com 

VDanta@Venable.com 

Attorneys for Plaintiffs North Atlantic Operating 

Company, Inc. and National Tobacco Company, 

L.P. 

I\10808011.1 

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