Case 2:18-cv-01601-JAK-FFM Document 1 Filed 02/27/18 Page 1 of 15 Page ID #:1

1 FARHAD NOVIAN (SBN 118129)

Farhad@[Link]
2 JOSEPH A. LOPEZ (SBN 268511)
3 Joseph@[Link]
SHARON RAMINFARD (SBN 278548)
4 Sharon@[Link]
5 NOVIAN & NOVIAN, LLP
1801 Century Park East, Suite 1201
6
Los Angeles, California 90067
7 Telephone: (310) 553-1222
8
Facsimile: (310) 553-0222

9 SHANON SLACK (SBN 316581)

10 Slack@[Link]
HANMIE BAK (SBN 309677)
11 Bak@[Link]
12 SLACK LAW GROUP APC
119 N. Fairfax Ave. #429
13 Los Angeles, CA 90036
14 Telephone: (213) 332-3721
15
Attorneys for Plaintiff CHAN-SUNG JUNG
16
17 UNITED STATES DISTRICT COURT

18 FOR THE CENTRAL DISTRICT OF CALIFORNIA

19 CHAN-SUNG JUNG, an individual, CASE NO.:

20
Plaintiff, COMPLAINT FOR:
21
1. Trademark Infringement Under § 32(1)
22 v. of the Lanham Act;
23 2. Violation of Civil Code § 3344 for
DBV DISTRIBUTION, INC., a Unauthorized Commercial Use of
24 Delaware corporation; and DOES 1-10, Likeness;
25 inclusive, 3. Violation of Plaintiff's Right of
Publicity;
26 Defendants. 4. Unfair Competition, False Designation
27 of Origin, Passing Off and False
Advertising Under Lanham Act § 43(a);
28

1
COMPLAINT
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1 5. Unfair Competition in Violation of Bus.

& Prof. Code § 17200, et seq.;
2 6. Common Law Trademark Infringement
3 and Unfair Competition
4 JURY TRIAL DEMANDED
5
6 JURISDICTION AND VENUE
7 1. The Court has original subject matter jurisdiction over plaintiff’s federal
8 claims pursuant to 28 U.S.C. §§ 1331, 1337(a), and 1338(a) since the complaint
9 involves issues arising under a federal statute, the Lanham Act. The Court has
10 original subject matter jurisdiction over Plaintiff’s federal claims arising under § 32(1)
11 of the Lanham Act. The Court also has original subject matter jurisdiction over
12 plaintiff’s federal claims pursuant to 28 U.S.C. § 1332(a)(1) because this action is
13 between citizens of different states and the amount in controversy exceeds $75,000.
14 The Court also has supplemental subject matter jurisdiction over plaintiff’s state law
15 claims under principles of pendent jurisdiction and pursuant to 28 U.S.C. § 1367(a).
16 2. This Court has personal jurisdiction over the defendants because the
17 events or omissions giving rise to the claim occurred, the tortious acts occurred, and a
18 substantial part of the injury took place and continues to take place, in this judicial
19 district.
20 3. Venue is proper in the United States District Court for the Central
21 District of California pursuant to 28 U.S.C §§ 1391(b), 1391(c), and 1400(a) as this is
22 a judicial district in which a substantial part of the events giving rise to the claims
23 occurred the tortious acts occurred, and a substantial part of the injury took place and
24 continues to take place.
25 PARTIES
26 4. Plaintiff Chan-Sung Jung (“Plaintiff”) is, and at all times relevant hereto
27 was, an individual and at all times relevant herein was and is doing business in this
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1 judicial district.
2 5. Upon information and belief, defendant DBV Distribution, Inc. (“DBV”)
3 is, and at all times relevant hereto was, a limited liability company organized and
4 existing under the laws of the State of Delaware and at all times relevant herein was
5 and is doing business in this judicial district.
6 6. Plaintiff is presently unaware of the true names and identities of Does 1-
7 10 and will seek leave to amend this complaint when their true names become known
8 to Plaintiff.
9 7. Plaintiff is informed and believes and based thereon alleges that in
10 committing the acts complained of herein, DBV and Does 1 through 10, inclusive
11 (collectively, “Defendants”), and each of them, acted in concert and conspiracy with
12 each other.
13 8. Plaintiff is informed and believes and based thereon alleges, that
14 Defendants are the alter egos of each other, are characterized by a unity of interest in
15 ownership and control among themselves such that any individuality and separateness
16 between them have ceased; that each is, and at all relevant times was, a mere shell
17 instrumentality and conduit through which the other defendants carried on their
18 business; and that these Defendants completely controlled, dominated, managed, and
19 operated each other's business to such an extent that any individuality or separateness
20 of the defendants does not and did not exist, and that defendants intermingled the
21 assets of each to suit the convenience of themselves in order to evade payment of
22 obligations and legal liability.
23 9. Plaintiff is informed and believes, and on such information and belief
24 alleges, that adherence to the fiction of separate existence of these Defendants as
25 entities distinct and separate from one another would promote injustice in that some of
26 these Defendants are inadequately capitalized, have used the other Defendants as a
27 mere shell, simply to transfer the earnings of one another while attempting to avoid
28 legal liability. As such, Plaintiff is informed and believes, and on such information

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1 and belief alleges, that the Defendants are the alter egos of each other and are
2 responsible in damages to Plaintiff, to the full extent of all other Defendants’ liability.
3 BACKGROUND
4 10. Chan-Sung Jung also known as the Korean Zombie (“Plaintiff”) is a
5 world famous mixed martial artist who has received prominent awards and accolades
6 as well as significant press in numerous publications around the world. Throughout
7 his successful career, Plaintiff has developed a strong following led by his reputation
8 and widespread popularity. In doing so, Plaintiff has carefully maintained his image,
9 likeness, publicity rights, trademarks, copyrights, and other intellectual property rights
10 (“Intellectual Property”). Plaintiff has selectively licensed his Intellectual Property,
11 whether registered or unregistered, for which he has received substantial commercial
12 benefit.
13 11. Plaintiff has commonly been known and referred to as the KOREAN
14 ZOMBIE, a trademark he has used in commerce in connection with the sale and
15 licensing of goods and services since at least 2007 (“Plaintiff’s Trademark”).
16 12. On January 8, 2013, Plaintiff was granted USPTO Trademark
17 Registration No. 4271642 for “KOREAN ZOMBIE” in International Class 25 for
18 “Hooded sweat shirts; Moisture-wicking sports shirts; Shirt fronts; Shirts; Shirts and
19 short-sleeved shirts; Short-sleeved shirts” and International Class 41 for
20 “Entertainment services in the nature of live mixed martial arts (MMA) events;
21 Organizing live mixed martial arts events and competitions; Presentation of mixed
22 martial arts (MMA) events; Providing classes, workshops, seminars and camps in the
23 fields of fitness, exercise, boxing, kick boxing and mixed martial arts”, bearing a date
24 of first use of June 24, 2007 (the “Registered Trademark”).
25 13. In or around December 2013 through January 2014, Defendants
26 approached Plaintiff, through his representative, seeking a license to use Plaintiff’s
27 image and Plaintiff’s Trademark on Defendants’ T-shirts. However, Defendants’
28 proposals were unequivocally rejected in writing by Plaintiff’s representative. At no

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1 time did Plaintiff agree to Defendants’ use of Plaintiff’s image, trademark, or any
2 other Intellectual Property in connection with Defendants’ goods or services.
3 14. To his surprise, in or about January 2018, Plaintiff learned that
4 Defendants were nonetheless selling T-shirts and other products (“Infringing
5 Products”) bearing a minimally altered version of Plaintiff’s image (“Infringing
6 Image”) and a variation of Plaintiff’s Trademark, displaying “VENUM ZOMBIE”
7 instead of “KOREAN ZOMBIE” (“Infringing Trademark”).
8 15. On or about February 8, 2018, Plaintiff, through his counsel, sent a letter
9 to Defendants demanding, among other things, that Defendants immediately cease and
10 desist from using, copying, reproducing, distributing, displaying, ordering,
11 purchasing, manufacturing, offering for sale or advertising products displaying
12 Plaintiff’s Intellectual Property in any way. Plaintiff also demanded that Defendants
13 provide Plaintiff’s counsel with a written accounting of each and every use of
14 Plaintiff’s Intellectual Property by Defendants, or any person or entity working with
15 or for Defendants to provide Plaintiff’s counsel with the names, addresses, and contact
16 information for the manufacturers, stores, websites, and companies used by
17 Defendants in relation with the Intellectual Property. Plaintiff further demanded that
18 Defendants provide Plaintiff’s counsel with copies of all sales receipts, invoices,
19 customer records, accounting records, and inventories of and relating to the use of
20 Plaintiff’s Intellectual Property.
21 16. To date, neither Plaintiff nor his counsel have received any response to
22 the February 8, 2018 letter.
23 17. Upon information and belief, Defendants and each of them have used
24 and, to date, continue to use Plaintiff’s image and likeness, trademark, and other
25 Intellectual Property without his consent in connection with the sale of Defendants’
26 Infringing Products.
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COMPLAINT
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1 FIRST CAUSE OF ACTION

2 (Trademark Infringement Under §32(1) of the Lanham Act - Against All
3 Defendants)
4 18. Plaintiff repeats, reiterates and re-alleges each and every allegation
5 contained in paragraphs designated 1 through 17, inclusive, of this Complaint, as if
6 fully set forth herein at length.
7 19. Plaintiff owns the trademark rights in the Registered Trademark, which
8 has acquired federal registration with the USPTO.
9 20. Defendants have used, and intend to continue to use the Infringing
10 Trademark, which is confusingly similar to the Registered Trademark, to capitalize on
11 Plaintiff’s goodwill associated therewith in order to attract customers.
12 21. Defendants' use of the Infringing Trademark, or other confusingly similar
13 imitations of Plaintiff’s Registered Trademark, is willful and deliberate and with an
14 intent to reap the benefit of Plaintiff’s goodwill.
15 22. Defendants' use of the Infringing Trademark, or other confusingly similar
16 imitations of Plaintiff’s Registered Trademark, is likely to continue to cause confusion
17 among the public about whether Plaintiff has authorized or endorsed the Defendants’
18 goods and services, and about whether Plaintiff is affiliated with the Defendants’
19
goods and services.
20
23. Defendants' use of the Infringing Trademark, or other confusingly similar
21
imitations of Plaintiff’s Registered Trademark, in connection with goods and services
22
unconnected to that of Plaintiff and without the authorization of Plaintiff infringes
23
Plaintiff’s exclusive rights in its trademark in violation of § 32(1) of the Lanham Act,
24
15 U. S.C. § 1114(1), in that the public is likely to be confused, deceived or mistaken
25
regarding the source or sponsorship of Defendants' goods and services, or to
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erroneously believe that Defendants' goods and services emanate from or are
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1 authorized by Plaintiff, or to believe that Plaintiff is the creator of, or has otherwise
2 affiliated with the Defendants’ goods and services.
3 24. Defendants’ actions, as alleged herein, constitute direct, contributory,
4 and/or vicarious trademark infringement.
5 25. Defendants' acts of trademark infringement have caused and are causing
6 great and irreparable injury to Plaintiff and to the Registered Trademark and to the
7 business and goodwill represented thereby, in an amount that cannot be ascertained at
8
this time and, unless restrained, will cause further irreparable injury, leaving Plaintiff
9
with no adequate remedy at law.
10
26. By reason of the foregoing, Plaintiff is entitled to injunctive relief against
11
Defendants permanently restraining further acts of trademark infringement and, after
12
trial, to recover any damages proven to have been caused by reason of Defendants'
13
aforesaid acts of trademark infringement, together with all other remedies available
14
under the Lanham Act, including, but not limited to, treble damages, disgorgement of
15
profits, costs, and attorney's fees.
16
SECOND CAUSE OF ACTION
17
(Violation of Civil Code § 3344 for Unauthorized Commercial Use of Likeness –
18
Against All Defendants)
19
27. Plaintiff repeats, reiterates and re-alleges each and every allegation
20
contained in paragraphs designated 1 through 26, inclusive, of this Complaint, as if
21
fully set forth herein at length.
22
28. Defendants and each of them, knowingly and without Plaintiff’s prior
23
consent, used Plaintiff’s image and likeness on and in connection with the sale of the
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Infringing Products.
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29. The use of Plaintiff’s image did not occur in connection with a news,
26
public affairs, or sports broadcast or account, or with a political campaign.
27
30. The unauthorized use and publication of Plaintiff’s image and likeness
28
was directly connected to Defendants’ commercial purpose. Plaintiff’s image and

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1 likeness was used for commercial purposes, to promote the branding, marketing, sales
2 and services offered by Defendants and each of them. None of the proceeds and/or
3 profits obtained from the Defendants’ wrongful use of Plaintiff’s likeness was ever
4 accounted for or paid to Plaintiff.
5 31. At no time did Plaintiff agree, consent, authorize, or grant any permission
6 for his image or likeness to appear in Defendants’ illegal uses of his likeness for
7 commercial gain or profit. Defendants knew, or should have known, that Plaintiff did
8 not agree, consent, authorize or grant any license or permission for his image or
9 likeness to appear on Defendants’ products, or for any other use by Defendants for
10 commercial gain or profit.
11 32. Defendants’ conduct was a substantial factor in causing Plaintiff harm.

12 Plaintiff has suffered economic damages in an amount yet unascertained but

13 according to proof at trial. Plaintiff, as part of his damages, is entitled to the gross

14 revenue attributable to such unauthorized use and all other damages allowed by law.

15 33. Plaintiff is entitled to the damages enumerated in California Civil Code

16 §3344, including reasonable attorney’s fees, disgorgement of profits, and punitive

17 damages.

18 THIRD CAUSE OF ACTION

19
(Violation of Plaintiff’s Right of Publicity – Against All Defendants)

20
34. Plaintiff repeats, reiterates and re-alleges each and every allegation

21
contained in paragraphs designated 1 through 33, inclusive, of this Complaint, as if

22
fully set forth herein at length.
35. Plaintiff has discovered that Defendants have used Plaintiff’s image and
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likeness in connection with the sale of Defendants’ Infringing Products.
24
36. Defendants’ use of Plaintiff’s image and likeness has been without
25
Plaintiff’s prior consent.
26
37. As a proximate result of Defendants’ wrongful conduct, Plaintiff has
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suffered economic damages in an amount yet unascertained but according to proof at
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1 trial.
2 38. Plaintiff, as part of his damages, is entitled to the gross revenue
3 attributable to such use of Plaintiff’s likeness, and to all other damages allowed by
4 law including punitive damages.
5 39. Defendants' acts have caused and are causing great and irreparable injury
6 to Plaintiff in an amount that cannot be ascertained at this time and, unless restrained,
7 will cause further irreparable injury, leaving Plaintiff with no adequate remedy at law.
8 40. By reason of the foregoing, Plaintiff is entitled to injunctive relief against
9 Defendants permanently restraining further violations and, after trial, to recover any
10 damages proven to have been caused by reason of Defendants' aforesaid acts, together
11 with all other remedies available.
12
FOURTH CAUSE OF ACTION
13
(Unfair Competition, False Designation of Origin, Passing Off and False
14
Advertising under Lanham Act § 43(a) - Against All Defendants)
15
41. Plaintiff repeats, reiterates and re-alleges each and every allegation
16
contained in paragraphs designated 1 through 40, inclusive, of this Complaint, as if
17
fully set forth herein at length.
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42. Plaintiff is the owner of the Registered Trademark.
19
43. The Registered Trademark is valid, entitled to protection and registered
20
with the USPTO.
21
44. Plaintiff has developed and maintained substantial secondary meaning in
22
the Plaintiff’s Trademark in the US and abroad.
23
45. Defendants have used, and intend to continue to use, Plaintiff’s
24
Trademark in the United States to capitalize on Plaintiff’s reputation in order to attract
25
customers.
26
46. Defendants’ use of Plaintiff’s Trademark is willful and deliberate and
27
with an intent to reap the benefit of Plaintiffs’ goodwill.
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47. Defendants’ use of the Plaintiff’s Trademark in the United States, or a

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1 colorable imitation thereof, in connection with its sales of products is likely to cause
2 confusion and has caused actual confusion among the public about whether Plaintiff
3 has authorized or endorsed Defendant’s products, and about whether Plaintiff is
4 affiliated with Defendants and their infringing products.
5 48. By engaging in the activities described above, Defendants have made and
6 are making false, deceptive and misleading statements constituting false designation
7 of origin, passing off, false advertising and unfair competition in violation of Section
8 43(a) of the Lanham Act, 15 U.S.C. §1125(a).
9 49. Defendants’ acts of unfair competition, false designation of origin,
10 passing off and false advertising are willful, deliberate and fraudulent, and without
11 extenuating circumstances, and with an intent to reap the benefit of Plaintiff’s name,
12 goodwill and reputation.
13 50. Defendants’ acts of unfair competition, false designation of origin,
14 passing off and false advertising have caused irreparable injury to Plaintiff’s goodwill
15 and reputation in an amount that cannot be ascertained at this time and, unless
16 restrained, will cause further irreparable injury, leaving Plaintiff with no adequate
17 remedy at law.
18 51. By reason of the foregoing, Plaintiff is entitled to injunctive relief against
19 Defendants, permanently restraining further acts of unfair competition, false
20 designation of origin, passing off and false advertising, and, after trial, to recover any
21 damages proven to have been caused by reason of Defendants’ aforesaid acts of unfair
22 competition, false designations of origin, passing off and false advertising, together
23 with all other remedies available under the Lanham Act, including, but not limited to,
24 treble damages, disgorgement of profits, costs and attorney's fees.
25 FIFTH CAUSE OF ACTION
26 (Unfair Competition in Violation of Bus. & Prof. Code § 17200, et seq. - Against
27 All Defendants)
28 52. Plaintiff repeats, reiterates and re-alleges each and every allegation

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1 contained in paragraphs designated 1 through 51, inclusive, of this Complaint, as if

2 fully set forth herein at length.
3 53. The actions of Defendants complained of herein constitute unfair
4 competition within the meaning of Cal. Bus. & Prof. Code, § 17200, et seq.
5 54. Defendants’ actions have caused and will likely continue to cause
6 confusion, mistake, and deception among consumers.
7 55. Defendants’ unfair competition has caused and will continue to cause
8 damage to Plaintiffs, including irreparable harm for which there is no adequate
9 remedy at law.
10 56. Pursuant to Cal. Bus. & Prof. Code, § 17203, Plaintiffs are entitled to
11 preliminary and permanent injunctive relief ordering Defendants to cease this unfair
12 competition.
13 57. Plaintiffs are further entitled to the disgorgement of any and all of
14 Defendants’ profits associated with this unfair competition.
15 SIXTH CAUSE OF ACTION
16 (Common Law Trademark Infringement and Unfair Competition - Against All
17 Defendants)
18 58. Plaintiff repeats, reiterates and re-alleges each and every allegation
19 contained in paragraphs designated 1 through 57, inclusive, of this Complaint, as if
20 fully set forth herein at length.
21 59. Plaintiff made use of Plaintiff’s Trademark as alleged herein.
22 60. Plaintiff has developed and maintained substantial secondary meaning in
23 Plaintiff’s Trademark in the US and abroad.
24 61. Defendants have used, and intend to continue to use, the Infringing
25 Trademark in connection with their sales of products to capitalize on Plaintiff’s
26 reputation in order to attract customers.
27 62. Defendants’ use of the Infringing Trademark is willful and deliberate and
28 with an intent to reap the benefit of Plaintiff’s goodwill.

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1 63. Defendants’ use of the Infringing Trademark in connection with the sales
2 of their products is likely to cause confusion among the public about whether Plaintiff
3 has authorized or endorsed the Defendants’ products, and about whether Plaintiff is
4 affiliated with Defendants and its infringing products.
5 64. Defendants’ actions, as alleged herein, constitute direct, contributory,
6 and/or vicarious common law trademark infringement and unfair competition.
7 65. Defendants’ acts of unfair competition are willful, deliberate and
8 fraudulent, and without extenuating circumstances, and with an intent to reap the
9 benefit of the Plaintiff’s name, goodwill and reputation.
10 66. Defendants’ acts of trademark infringement and unfair competition have
11 caused irreparable injury to Plaintiff’s goodwill and reputation in an amount that
12 cannot be ascertained at this time and, unless restrained, will cause further irreparable
13 injury, leaving Plaintiff with no adequate remedy at law.
14 67. By reason of the foregoing, Plaintiff is entitled to injunctive relief against
15 Defendants, permanently restraining further acts of trademark infringement and unfair
16 competition, and, after trial, to recover any damages proven to have been caused by
17 reason of Defendants’ aforesaid acts of trademark infringement and unfair
18 competition, together with all other remedies available under the law, including, but
19 not limited to, treble damages, disgorgement of profits, costs and attorney's fees.
20 PRAYER FOR RELIEF
21 WHEREFORE, Plaintiff respectfully demands the following relief against
22 Defendants, jointly and severally:
23 ON THE FIRST, FOURTH, AND SIXTH CAUSES OF ACTION
24 1. That Defendants, their agents, licensees, servants, representatives,
25 employees, attorneys, successors and assigns, and all those in active concert or
26 participation with any of them who receive notice of such judgment directly or
27 otherwise, be permanently enjoined from infringing Plaintiff’s Trademark, whether or
28 not registered, from falsely designating the origin, sponsorship of or affiliation of

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1 Defendants’ business or services, from unfairly competing with Plaintiff, from

2 diluting the distinctive quality of the Trademark.
3 2. Directing that Defendants account for all gains, profits, and advantages
4 derived from its acts of infringement;
5 3. Directing such other relief as the Court may deem appropriate to prevent
6 the public from deriving the erroneous impression that any goods or services provided
7 by or promoted by Defendants is authorized by Plaintiff or related in any way to
8 Plaintiff, its products or its services.
9 4. Awarding Plaintiff: (i) All of the Defendants’ profits, gains and
10 advantages derived from the unauthorized use of Plaintiff’s Trademark or any
11 imitation or simulation thereof, and that such sums be trebled; (ii) All damages
12 sustained by Plaintiffs by reason of Defendants' acts of trademark infringement,
13 dilution and unfair competition, and that such damages be trebled; (iii) Exemplary and
14 punitive damages as the court finds appropriate to deter any future willful conduct,
15 and (iv) Interest, including prejudgment interest, on the foregoing sums.
16 5. Awarding to Plaintiff its attorney’s fees and costs incurred by reason of
17 Defendants’ violations;
18 6. Directing such other relief as the Court may deem appropriate to prevent
19 the Defendants from participating in this or other trademark infringements.
20 ON THE SECOND CAUSE OF ACTION
21 1. For injunctive relief;
22 2. For the greater of $750 per unauthorized use, or the actual damages
23 suffered as a result of the unauthorized use in an amount according to proof at trial;
24 3. For any profits from the unauthorized use that are attributable to the use
25 and are not taken into account in computing the actual damages;
26 4. For punitive damages;
27 5. For attorney’s fees and costs.
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1 ON THE THIRD CAUSE OF ACTION

2 1. For general and special damages according to proof at trial;
3 2. For injunctive relief;
4 3. For punitive damages.
5 ON THE FIFTH CAUSE OF ACTION
6 1. Preliminary and permanent injunctive relief ordering Defendants to cease
7 their unfair competition.
8 2. Disgorgement of any and all of Defendants’ profits associated with this
9 unfair competition.
10 3. Such other and further relief as the Court may deem just and proper.
11
12 Respectfully submitted,
13
14 Date: February 27, 2018 NOVIAN & NOVIAN, LLP

15
By: /s/ Farhad Novian
16 Attorney for Plaintiff
17 CHAN-SUNG JUNG
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1 JURY DEMAND
2
3 Plaintiff hereby demands a jury trial of all issues so triable.
4
5 Respectfully submitted,
6
7 Date: February 27, 2018 NOVIAN & NOVIAN, LLP

8
9 By: /s/ Farhad Novian
Attorney for Plaintiff
10 CHAN-SUNG JUNG
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