1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

VIP PRODUCTS L.L.C., )

 an Arizona limited liability company, )

Plaintiff, )

) 

vs. )

)

SNUGGLE PET PRODUCTS LLC, )

 a Michigan limited liability company, )

Defendant. ) )

Marvin A. Glazer (AZ Bar No. 5885)

CAHILL GLAZER PLC

2141 E. Highland Avenue, Suite 155

Phoenix, Arizona 85016-4762

Ph. (602) 956-7000

Fax (602) 495-9475

email: mglazer@cvglaw.com

Attorneys for Plaintiff

VIP PRODUCTS L.L.C.

IN THE UNITED STATES DISTRICT COURT

DISTRICT OF ARIZONA

Civil No.

COMPLAINT FOR

TRADEMARK

INFRINGEMENT, UNFAIR

COMPETITION,

AND JURY DEMAND

Plaintiff VIP PRODUCTS L.L.C. (hereinafter, “Plaintiff”), for its Complaint

against Defendant Snuggle Pet Products LLC, doing business under the assumed business

name “Smart Pet Love” (hereinafter, “Defendant”), states and alleges the following: 

1. This is an action for trademark infringement and unfair competition under

Federal and Arizona state law, and for false designation of origin, false or misleading

description or representation of facts, and unfair competition under the Federal

Trademark Act (15 U.S.C. § 1051 et seq.). 

2. This court has jurisdiction over the subject matter of this civil action under

28 U.S.C. §1331 and 28 U.S.C. § 1338(a) and (b), and 15 U.S.C. §1121(a). Supplemental

subject matter jurisdiction over the claim for unfair competition under Arizona law is

provided by 28 U.S.C. §§1338(b) and 1367(a).

Case 2:17-cv-04685-DGC Document 1 Filed 12/18/17 Page 1 of 15
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

3. Venue in this judicial district is proper under 28 U.S.C. §1391(b) and (c).

4. Plaintiff VIP Products L.L.C. is an Arizona limited liability company

having a principal business address of 16515 S. 40th Street, Suite 121, Phoenix, Arizona

85048.

5. Upon information and belief, Defendant is a Michigan limited liability

company, and has a principal business address at 41180 Vincenti Ct., Novi, Michigan

48375.

6. Upon information and belief, Defendant does business under its corporate

name and under the assumed business name Smart Pet Love.

7. Upon information and belief, Defendant maintains an Internet web site

having the domain address www.smartpetlove.com.

8. Defendant offers a product line of “Happiness Products” for sale on its web

site at the web page having the domain address shown below:

https://www.smartpetlove.com/product-category/happiness-category/?v=7516fd43adaa

9. Each of the “Happiness Products” offered for sale on the above-described

“Happiness Products” web page is displayed with a price and a symbol of a shopping cart

for placing such item in the buyer’s online shopping cart.

10. After placing one or more items in the online shopping cart, a customer may

proceed to “checkout” to enter billing information and shipping information, and to make

an online payment for the products purchased.

11. This Court may properly assert personal jurisdiction over Defendant.

Count 1 - Infringement of Plaintiff’s “MIGHTY” Trademark

12. Plaintiff repeats and realleges Paragraphs 1-11 as if fully set forth herein.

13. Plaintiff manufactures and distributes products for pets, including dog toys.

14. Plaintiff is the owner of United States Trademark Registration No.

3,512,293, registered October 7, 2008 on the Principal Register, for the trademark

- 2 -

Case 2:17-cv-04685-DGC Document 1 Filed 12/18/17 Page 2 of 15
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

MIGHTY®, in International Class 028, for pet toys.

15. A true copy of the Certificate of Registration for U.S. Trademark Reg. No.

3,512,293 is attached hereto as Exhibit 1.

16. On November 6, 2013, the Trademark Office issued a Notice of Acceptance

And Acknowledgment of §§8 & 15 Declaration for U.S. Trademark Reg. No. 3,512,293.

17. Plaintiff’s right to exclusive use of its MIGHTY® trademark for pet toys in

commerce is incontestable within the meaning of 15 U.S.C. §1065.

18. Since at least 2007, Plaintiff has continuously used the trademark

MIGHTY® in interstate commerce to identify pet toys originating with Plaintiff.

19. Plaintiff manufactures, markets, distributes and sells an extensive line of

dog toys under its MIGHTY® trademark.

20. Each of the dog toys distributed by Plaintiff under its MIGHTY® trademark

is shipped with a product tag secured thereto, and indicating that such trademark is

federally registered; a true copy of one such product tag is attached hereto as Exhibit 2.

21. Defendant is making, distributing, offering to sell, and, upon information

and belief, selling a line of dog toys called the “MIGHTY MIGHTS” series, shown at

Defendant’s Internet web page having the domain address shown below:

https://www.smartpetlove.com/product-category/mighty-mights/?v=7516fd43adaa

22. The image inserted below page was captured on December 14, 2017 from

Defendant’s Internet web page having the web address set forth in Paragraph 21 above:

23. As shown in the image above, Defendant has identified four of its dog toys

as “Mighty Tiger”, “Mighty Monkey”, “Mighty Rabbit” and “Mighty Lion” (hereinafter,

- 3 -

Case 2:17-cv-04685-DGC Document 1 Filed 12/18/17 Page 3 of 15
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

“Defendant’s Mighty Toys”).

24. Defendant attaches packaging to Defendant’s

Mighty Toys, including a header card and a tag.

25. In the image inserted to the right, which shows

one of Defendant’s “Mighty Lion” dog toys, the header card

extends above the lion’s head, and the tag is attached below

the lion’s arm.

26. In the image inserted to the right, the header

card bears the designation “Mighty Might”, while the “tag

bears the word “MIGHTY” displayed in white capital block

letters, resembling the format of the word “MIGHTY” on

Plaintiff’s header card shown in attached Exhibit 2; the tag

also includes the word “Mights” depicted less prominently when compared with the word

“MIGHTY”.

27. Upon information and belief, Defendant has offered for sale, and sold,

Defendant’s Mighty Toys in commerce, directly to consumers, and through distributors

including Amazon.com, Chewy.com, and WholesalePet.com, for resale to consumers,

within the District of Arizona and elsewhere.

28. Plaintiff VIP also offers dog toys under its registered “MIGHTY”

trademark, including dog toys in the form of a rabbit, a monkey, and a lion.

29. The designation “Mighty” used by Defendant to promote and sell

Defendant’s Mighty Toys is confusingly similar to Plaintiff’s federally registered

trademark MIGHTY® for pet toys.

30. Plaintiff and Defendant are competitors in the field of pet toys.

31. Plaintiff’s MIGHTY® dog toys, and Defendant’s Mighty Toys, are

marketed and sold to the same class of consumers, including dog owners.

32. Defendant’s Mighty Toys are competitive goods relative to Plaintiff’s

- 4 -

Case 2:17-cv-04685-DGC Document 1 Filed 12/18/17 Page 4 of 15
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

MIGHTY® dog toys.

33. Plaintiff’s MIGHTY® dog toys are offered for sale on Plaintiff’s Internet

web page having the web address shown below:

www.vipproducts.com/retail/files/index.php/categories/view/217/mighty-dog-toys.

34. Plaintiff’s MIGHTY® dog toys are also offered for sale through Internetbased distributors, including Amazon.com.

35. As shown by the image inserted at the top of the following page, which

shows a portion of the search results for a search conducted on the Amazon.com web site

on December 14, 2017, using the key words “dog toys mighty”, the second page of such

results displayed of one of Defendant’s Mighty Toys (the “Mighty Monkey”) right

between two of Plaintiff’s MIGHTY® dog toys (namely, Plaintiff’s farm piglet and

Plaintiff’s dragon hydra):

36. Plaintiff’s MIGHTY® dog toys and Defendant’s Mighty Toys are marketed

and sold through the same channels of trade.

37. Defendant’s prominent use of the designation “Mighty” to promote and sell

Defendant’s Mighty Toys is likely to cause confusion, or to cause mistake, or to deceive,

- 5 -

Case 2:17-cv-04685-DGC Document 1 Filed 12/18/17 Page 5 of 15
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

the public into believing that Defendant’s Mighty Toys originate with, are sponsored by,

or affiliated with Plaintiff.

38. Plaintiff has never licensed, agreed to, or otherwise consented to,

Defendant’s use of the confusingly similar legend “Mighty” on dog toys.

39. Plaintiff’s U.S. Trademark Registration No. 3,512,293 for the mark

MIGHTY® is prima facie evidence of the validity of the registered mark and of the

registration of the mark, of Plaintiff’s ownership of the mark, and of Plaintiff’s exclusive

right to use the registered mark in commerce on or in connection with pet toys; 15 U.S.C.

§1115. 

40. Defendant’s use in commerce, distribution, promotion, offering for sale, and

sale, of Defendant’s Mighty Toys, in conjunction with the designation “Mighty”, is an

infringement of Plaintiff’s federally-registered trademark MIGHTY® for pet toys, in

violation of 15 U.S.C. §1114.

41. Defendant’s use in commerce, distribution, promotion, offering for sale, and

sale of Defendant’s Mighty Toys, in conjunction with the designation “Mighty”, also

constitutes false designation of origin, false description, and unfair competition, in

violation of 15 U.S.C. § 1125(a).

42. The above-alleged acts by Defendant further constitute common law

trademark infringement and unfair competition under the established common law of the

State of Arizona.

43. Defendant’s acts of false designation of origin, false descriptions, unfair

competition, and trademark infringement, in violation of §1114 and 15 U.S.C. § 1125(a),

and the common law of Arizona, have caused and will continue to cause damage and

irreparable harm to Plaintiff and are likely to continue unabated unless enjoined by this

Court. Plaintiff has no fully adequate remedy at law.

Count 2 - Infringement of Plaintiff’s “TUFFY” Trademark

- 6 -

Case 2:17-cv-04685-DGC Document 1 Filed 12/18/17 Page 6 of 15
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

44. Plaintiff repeats and realleges Paragraphs 1-43 as if fully set forth herein.

45. Plaintiff is the owner, by assignment, of United States Trademark

Registration No. 1,558,243, registered September 26, 1989 on the Principal Register, for

the trademark TUFFY®, in International Class 028, for pet toys.

46. A true copy of the Certificate of Registration for U.S. Trademark Reg. No.

1,558,243 is attached hereto as Exhibit 3.

47. Upon information and belief, Plaintiff’s predecessor in interest began using

the mark TUFFY® on dog toys sold in interstate commerce in 1983.

48. Plaintiff acquired ownership by assignment of the trademark TUFFY® for

use on dog toys, including U.S. Trademark Reg. No. 1,558,243 and all common law

rights in the mark, on March 19, 2008, such assignment being recorded in the U.S. Patent

and Trademark Office on August 21, 2008.

49. Plaintiff renewed U.S. Trademark Reg. No. 1,558,243 with the U.S. Patent

and Trademark Office on September 26, 2009 under 15 U.S.C. §1059.

50. Plaintiff’s right to exclusive use of its TUFFY® trademark for pet toys in

commerce is incontestable within the meaning of 15 U.S.C. §1065.

51. Since at least 2008, Plaintiff itself has continuously used the trademark

TUFFY® in interstate commerce to identify pet toys originating with Plaintiff.

52. Plaintiff manufactures, markets, distributes and sells an extensive line of

dog toys under its TUFFY® trademark.

53. Each of the dog toys distributed by Plaintiff under its TUFFY® trademark is

shipped with a product tag secured thereto, and indicating that such trademark is federally

registered; a true copy of such a product tag is attached hereto as Exhibit 4.

54. Defendant is making, distributing, offering to sell, and, upon information

and belief, selling a line of dog toys called the “Tender Tuffs” series (hereinafter,

“Defendant's Tender Tuff Toys”.

55. Defendant's Tender Tuff Toys are being marketed by Defendant itself on its

- 7 -

Case 2:17-cv-04685-DGC Document 1 Filed 12/18/17 Page 7 of 15
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

web site at the web address www.smartpetlove.com/shop/?v=7516fd43adaa.

56. Defendant’s Tender Tuff Toys

and are also being marketed by Internet-based

distributor Amazon.com; such products are

displayed at the web address: 

www.amazon.com/s/ref=sr_in_-2_p_89_44?fs

t=as%3Aoff&rh=n%3A2619533011%2Cn%3

A!2619534011%2Cn%3A2975312011%2Cn

%3A2975413011%2Cp_89%3ASmart+Pet+L

ove&bbn=2975413011&ie=UTF8&qid=1513

365687&rnid=2528832011.

57. The image of the Tender Tuffs

Flying Duck inserted to the right was captured on December 15, 2017 from the web

address set forth immediately above.

58. Defendant’s Tender Tuff Toys and are

also being marketed by Internet-based distributor

Chewy.com; such products are among those displayed

at the web address: 

https://www.chewy.com/s?rh=c%3A288%2Cc%3A31

5%2Cbrand_facet%3ASmart+Pet+Love%2Cc%3A320

59. The image of the Tender Tuff Flying

Blue Octopus inserted to the right was captured on

December 15, 2017 from the web address set forth

immediately above.

60. Defendant’s Tender Tuff Toys and are also being marketed by

Internet-based distributor WholesalePet.com; such products are among those displayed at

- 8 -

Case 2:17-cv-04685-DGC Document 1 Filed 12/18/17 Page 8 of 15
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

the web address:

https://wholesalepet.com/Search/Brand/4106.

61. The image of the Tender Tuff Pterosaur

inserted to the right was captured on December 15, 2017

from the web address set forth immediately above.

62. Within its line of dog toys sold under its

TUFFY® trademark, Plaintiff also sells a plush duck toy. Plaintiff’s TUFFY® brand

Dudley Duck is shown in the image inserted to the right.

63. Plaintiff’s TUFFY® brand Dudley Duck is

offered for sale on Plaintiff’s web site

www.vipproducts.com/retail/files/index.php/.

64. Plaintiff’s TUFFY® brand Dudley Duck is

also offered for sale on the Amazon.com web site at the

web address shown below:

www.amazon.com/Tuffy-Jr-Dudley-Duck-Dog/dp/B00DGJ8SCY/ref=sr_1_1?ie=UTF8&

qid=1513369060&sr=8-1&keywords=vip%2Bdog%2Btoy%2Bduck&th=1

65. Plaintiff’s TUFFY® brand Dudley Duck is also offered for sale on the

WholesalePet.com web site at the web address https://wholesalepet.com/Product/50441.

66. Within its line of dog toys sold under its

TUFFY® trademark, Plaintiff also sells a plush octopus

toy. Plaintiff’s TUFFY® brand Ocean Creatures

Octopus is shown in the image inserted to the right.

67. Plaintiff’s TUFFY® brand Ocean

Creatures Octopus is offered for sale on Plaintiff’s web

site at the web address

https://www.vipproducts.com/retail/files/index.php/categories/view/51/ocean-creatures/pr

oduct:70

- 9 -

Case 2:17-cv-04685-DGC Document 1 Filed 12/18/17 Page 9 of 15
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

68. Plaintiff’s TUFFY® brand Ocean Creatures Octopus is also offered for sale

on the Amazon.com web site at the web address shown below:

https://www.amazon.com/Tuffy-Ocean-Creature-Small-Octopus/dp/B000NVDEY0/ref=s

r_1_1?s=pet-supplies&ie=UTF8&qid=1513370654&sr=1-1&keywords=vip+dog+toy+oc

topus

69. Plaintiff’s TUFFY® brand Ocean Creatures Octopus is also offered for sale

on the Chewy.com web site at the web address shown below: 

https://www.chewy.com/tuffys-ocean-creatures-lil-oscar-dog/dp/39256

70. Plaintiff’s TUFFY® brand Ocean Creatures Octopus is also offered for sale

on the WholesalePet.com web site at the web address shown below:

https://wholesalepet.com/Product/49469

71. Within its line of dog toys sold under

its TUFFY® trademark, Plaintiff also sells plush

dinosaur toys. Plaintiff’s TUFFY® brand Dinosaur

Pteradactyl is shown in the image inserted to the

right.

72. Plaintiff’s TUFFY® brand Pteradactyl is offered for sale on Plaintiff’s web

site at the web address shown below:

www.vipproducts.com/retail/files/index.php/categories/view/119/dinosaurs/product:354

73. Plaintiff’s TUFFY® brand Pteradactyl is also offered for sale on the

Amazon.com web site at the web address shown below:

https://www.amazon.com/TUFFY-T-D-Tera-Tuffy-Dinosaur-Pteradactyl/dp/B000WFMC

J0/ref=sr_1_fkmr0_1?s=pet-supplies&ie=UTF8&qid=1513371976&sr=1-1-fkmr0&keyw

ords=vip+dog+toy+pteradactyl

74. Plaintiff’s TUFFY® brand Pteradactyl is also offered for sale on the

Chewy.com web site at the web address shown below: 

https://www.chewy.com/tuffys-pterodactyl-dino-dog-toy/dp/39243

- 10 -

Case 2:17-cv-04685-DGC Document 1 Filed 12/18/17 Page 10 of 15
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

75. Plaintiff’s TUFFY® brand Pteradactyl is also offered for sale on the

WholesalePet.com web site at the web address shown below: 

https://wholesalepet.com/Product/8967

76. Many of Defendant’s Tender Tuff Toys includes a black band, or webbing,

overlying outer seams of the toy.

77. Those of Defendant’s Tender Tuff Toys shown below each includes such

black webbing:

78. The black webbing shown above causes those of the Defendant’s Tender

Tuff Toys shown above to closely resemble similar dog toys sold under Plaintiff’s

TUFFY® brand:

- 11 -

Case 2:17-cv-04685-DGC Document 1 Filed 12/18/17 Page 11 of 15
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

79. Upon information and belief, Defendant has offered for sale, and sold,

Defendant’s Tender Tuff Toys in commerce, directly to consumers, and through

distributors including Amazon.com, Chewy.com, and WholesalePet.com, for resale to

consumers, within the District of Arizona and elsewhere.

80. The designation “Tender Tuff” used by Defendant to promote and sell

Defendant’s Tender Tuff Toys is confusingly similar to Plaintiff’s federally registered

trademark TUFFY®.

81. Plaintiff and Defendant are competitors in the field of pet toys.

82. Plaintiff’s TUFFY® dog toys, and Defendant’s Tender Tuff Toys, are

marketed and sold to the same class of consumers, including dog owners.

83. Defendant’s Tender Tuff Toys are competitive goods relative to Plaintiff’s

TUFFY® brand dog toys.

84. Plaintiff’s TUFFY® dog toys and Defendant’s Tender Tuff Toys are

marketed and sold through the same channels of trade.

85. Defendant’s prominent use of the designation “Tuff” and/or “Tender Tuff”

to promote and sell Defendant’s Tender Tuff Toys is likely to cause confusion, or to cause

mistake, or to deceive, the public into believing that Defendant’s Tender Tuff Toys

originate with, are sponsored by, or affiliated with Plaintiff.

86. Plaintiff has never licensed, agreed to, or otherwise consented to,

Defendant’s use of the confusingly similar legend “Tuff” and/or “Tender Tuff” on dog

toys.

87. Plaintiff’s U.S. Trademark Registration No. 1,558,243 for the mark TUFFY®

is prima facie evidence of the validity of the registered mark and of the registration of the

mark, of Plaintiff’s ownership of the mark, and of Plaintiff’s exclusive right to use the

registered mark in commerce on or in connection with pet toys; 15 U.S.C. §1115. 

88. Defendant’s use in commerce, distribution, promotion, offering for sale, and

sale of Defendant’s Tender Tuff Toys, in conjunction with the designation “Tuff” and/or

- 12 -

Case 2:17-cv-04685-DGC Document 1 Filed 12/18/17 Page 12 of 15
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

“Tender Tuff”, also constitutes false designation of origin, false description, and unfair

competition, in violation of 15 U.S.C. § 1125(a).

89. Defendant’s use of similar trade dress, including black accent webbing, on

dog toys resembling dog toys sold by Plaintiff, and sold under a confusingly similar

trademark, also constitutes federal unfair competition, and false designation of origin, in

violation of 15 U.S.C. § 1125(a).

90. The above-alleged acts by Defendant further constitute common law

trademark infringement and unfair competition under the established common law of the

State of Arizona.

91. Defendant’s acts of false designation of origin, false descriptions, unfair

competition, and trademark infringement, in violation of §1114 and 15 U.S.C. § 1125(a),

and the common law of Arizona, have caused and will continue to cause damage and

irreparable harm to Plaintiff and are likely to continue unabated unless enjoined by this

Court. Plaintiff has no fully adequate remedy at law.

WHEREFORE, Plaintiff requests: 

(1) That the Court preliminarily and permanently enjoin Defendant and its

employees, agents, representatives, successors, and assigns and all persons in active

concert or participation with them, from: (a) using Plaintiff’s trademarks “MIGHTY”,

“TUFFY”, the confusingly similar variations “Mighty Mights”, “Tuff”, “Tender Tuff”,

“Tender Tuffs”, and/or any colorable imitations thereof, in conjunction with the

distribution, promotion, display, offering for sale and/or sale of pet toys, including dog

toys; and (b) otherwise unfairly competing with Plaintiff in the manner alleged herein; 15

U.S.C. §1116.

(2) That the Court order that all product labels, signs, prints, packages, wrappers,

receptacles, marketing materials, and advertisements in the possession of Defendant, and

bearing the legend “Mighty”, “Mighty Mights”, “Tuff”, “Tender Tuff”, and/or “Tender

- 13 -

Case 2:17-cv-04685-DGC Document 1 Filed 12/18/17 Page 13 of 15
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Tuffs”, and all plates, molds, matrices, and other means of making the same, to be

delivered up and destroyed; 15 U.S.C. §1118.

(3) That the Court order Defendant to pay to Plaintiff such damages sustained by

Plaintiff and to account for and pay to Plaintiff such profits realized by Defendant as the

law allows: (a) in consequence of Defendant’s acts of federal false designation of origin,

false descriptions, unfair competition, and trademark infringement; 15 U.S.C. §§1114,

1117, and (b) in consequence of Defendant’s acts of state trademark infringement and

unfair competition.

(4) That the Court find that the circumstances and actions of Defendant are

sufficient to merit an award of exemplary damages to Plaintiff in the amount of three times

the amount found as actual damages; 15 U.S.C. §1117.

(5) That the Court order Defendant to pay Plaintiff its costs and expenses related

to this action; 15 U.S.C. §1117.

(6) That the Court order Defendant to pay Plaintiff its attorneys’ fees related to

this action; 15 U.S.C. §1117.

(7) That the Court award such other and further relief as the Court deems

appropriate. 

JURY TRIAL DEMAND

Plaintiff requests a trial by jury on all issues so triable in accord with Rule 38 of the

Federal Rules of Civil Procedure.

- 14 -

Case 2:17-cv-04685-DGC Document 1 Filed 12/18/17 Page 14 of 15
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

Respectfully submitted,

 December 18, 2017 By: /s/Marvin A. Glazer 

Date Marvin A. Glazer, Esq.

CAHILL GLAZER PLC

2141 E. Highland Ave., Suite 155

Phoenix, Arizona 85016-4762

Ph. 602-956-7000

Fax 602-495-9475

Email: mglazer@cvglaw.com

Attorneys for Plaintiff

VIP PRODUCTS L.L.C.

CERTIFICATE OF FILING/SERVICE

I HEREBY CERTIFY that on this 18 day of December, 2017, I electronically filed

the foregoing COMPLAINT FOR TRADEMARK INFRINGEMENT, UNFAIR 

COMPETITION, AND JURY DEMAND, including attached Exhibits 1-4, with the Clerk

of the Court by using the CM/ECF system.

/s/Marvin A. Glazer

Attorney

- 15 -

Case 2:17-cv-04685-DGC Document 1 Filed 12/18/17 Page 15 of 15