IN THE UNITED STATES DISTRICT COURi
FOR THE MIDDLE DISTRICT OF NORTH CAROLINA
DURHAM DIVISION
_- . .
F,lLE NO, ;..j.
4 $I 5
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_,..,
UNIVERSIM OF NORTH CAROLINA and 1
THE UNIVERSITY OF NORTH CAROLINA j
at CHAPEL HILL, 1
I
Plaintiffs,
V.
(I) JACK R. ERICKSON, individually and ) VERIFIED
d&/a VALUABLE ASSETS LEAVE ) COMPLAINT AND
UNRIVALED ESTATES HOLDINGS INC., ) PRELIMINARY
VALUABLE ASSETS LEAVE UNRIVALED ) (Fed. R. Civ. P.
ESTATES LEASING INC., VALUABLE
ASSETS LEAVE UNRIVALED ESTATES
INVESTMENTS INC., VALUE WEB DESIGN, )
and THE VALUE COMPANIES ; 1
(2) APRIL M. ERICKSON, individually and )
dlbla VALUABLE ASSETS LEAVE
UNRIVALED ESTATES HOLDINGS INC.,
VALUABLE ASSETS LEAVE UNRIVALED )
ESTATES LEASING INC., VALUABLE
ASSETS LEAVE UNRIVALED ESTATES
INVESTMENTS, INC., VALUE WEB DESIGN, )
and THE VALUE COMPANIES ;
(3) VALUABLE ASSETS LEAVE UNRIVALED;
ESTATES HOLDINGS INC.;
(4) VALUABLE ASSETS LEAVE UNRIVALED))
ESTATES LEASING INC.; and
(5) VALUABLE ASSETS LEAVE UNRIVALED;
ESTATES INVESTMENTS INC. 1
Defendants. i
Plaintifis, The Board of Governors of The University of North Carolina (the
`Board"), and The University of North Carolina at Chapel Hill ("UNC-CH"), by arld
SNIPPETS:
ESTATES LEASING INC., VALUABLE
`Board"), and The University of North Carolina at Chapel Hill, by arld
Erickson"); Valuable Assets l&ve Unrivaled Estates Holdings Inc.
Investments") (collectively, `Defendants") allege as follows:
registered by UNC-CH and that seeks to use the reputation and good will of UNC-CH to
consumers, and constitutes unfair competition and unfair and deceptive or deceptive
trade practices in violation of the law of the North Carolina.
the State of North Carolina with its principal office in Chapel Hill, Orange County, North
and is and/or was the President and registered agent for VALUE Investments.
Nevada corporation and has and/or had its principal place of business in SC&dale,
VALUE Investments and VALUE Web Design.
Erickson have failed to comply with corporate formalities with respect to each of the
Plaintiffs, Defendants J. Erickson and A. Erickson are personally liable for, among other
has sought to promote a tradition of and reputation for excellence since first admitting
the verbiage "UNC;" the verbiage "Ilniversity of
The UNC mark has achieved inconte$tible
The "unogirls.com" Web site is and/or was accessible from Defendants'
which incorporates the UNC mark - is also dilutive of the UNC mark.
time and, unless restrained, will cause further irreparable injury, leaving Plaintiffs with I
Unfair and Decaotive Trade Practices
Plaintifis have been damaged and are entitled to a judgment setting aside
identical or similar to the UNC mark or any other trademarks belonging to Plaintiffs;
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