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1
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COMPLAINT
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EXTRACTED KEY WORDS
KMART MISLEADING TARGET MISLEADING REPRESENTATIONS ADVERTISING COMPARE MINN MERCHANDISE STAT CONSUMERS MINNESOTA DARE PLAINTIFF BUSINESS COMMERCE DISPLAY MISREPRESENTATION TARGET DAMAGE ACT STORES PURCHASING SUBD QUALITIES PROMOTION COURT DEFENDANT KMART CONTEXT GOODS IRREPARABLE HARM |
UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA
1
Target Corporation, 1 Civil Action No.
1
Plaintiff, >1 COMPLAINT
vs. 1)
Kmart Corporation,
; JURY TRIAL DEMANDED
Defendant. 111
Plaintiff Target Corporation, for its Complaint against defendant Kmart
Corporation, states as follows:
1. Plaintiff Target Corporation (hereinafter `Target") is a Minnesota
corporation having its principal place of business in Minneapolis, Minnesota.
2. Defendant Kmart Corporation (hereinafter `Kmart") is a Michigan
corporation having its principal place of business in Troy, Michigan.
ON AND VENU&
3. The claims alleged herein arise under the Lanham Act, 15 U.S.C.
5 1125(a) and under Minn. Stat. §$ 8.3 1,325D. 13 (the Minnesota Unfair Trade Practices
Act), 325D.44 (the Minnesota Uniform Deceptive Trade Practices Act), 325F.67 (the
Minnesota False Advertising Act), and 325F.69 (the Minnesota Consumer Fraud Act).
4. This Court has subject matter jurisdiction of these claims based on 15
U.S.C. $1121,28 USC. 55 1331 and 1367, and the doctrine of pendent jurisdiction.
5. Venue is proper in this Judicial District under 28 U.S.C. 0 1391(b) and
(c)*
6. This Court has personal jurisdiction over defendant Kmart in that
Kmart may be found within the State of Minnesota and the claims for relief alleged herein
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