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1
.
COMPLAINT
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EXTRACTED KEY WORDS
DEFENDANTS MARK ACT UUA DAMAGES COMMON LAW LANHAM ACT COURT INJUNCTIVE RELIEF DAVID PERMANENT WEB SITE NEWLY FORMED AUA PLAINTIFF FISHER CONGREGATIONS MASSACHUSETTS UNFAIR COMPETITION LEGAL SUCCESSOR VIRGINIA COMMON LAW HISTORIC AMERICAN UNITARIAN COMPLAINT VIOLATION FALSE DESIGNATION ATTORNEYS FEES ANTICYBERSQUATTING CONSUMER PROTECTION CONTROVERSY EXCEEDS JURISDICTION JUDICIAL DISTRICT |
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF VIRGINIA
ALEXANDRIA DIVISION
UNITARIAN UNIVERSALIST )
ASSOCIATION,
)
) Case
No.
01-431-A
Plaintiff, )
)
vs. ) )
AMERICAN UNITARIAN )
ASSOCIATION,
)
DEAN C. FISHER AND DAVID R. )
BURTON, ) )
Defendants.
)
COMPLAINT AND JURY DEMAND
Introductory Statement
1. Plaintiff, the Unitarian Universalist Association ("UUA"), brings this civil
action for preliminary and permanent injunctive relief, damages and attorneys fees
against defendants. This action arises out of defendants' unlawful use of the name and
mark AMERICAN UNITARIAN ASSOCIATION.
Jurisdiction
2. This is an action arising under Section 43(a) and (c) of the Lanham Act,
15 U.S.C.§§ 1051 et seq., the Anticybersquatting Consumer Protection Act, Section 43(d)
of the Lanham Act, 15 U.S.C. § 1125(d) and common law.
3. The amount in controversy exceeds $75,000 and the controversy is
between citizens of different states.
4. This Court has jurisdiction under 15 U.S.C. § 1121 and 28 U.S.C.
1331, 1332, 1338 and 1367.
Venue
5. Venue is proper under 28 U.S.C. § 1391(b) as a substantial part of the
events or omissions giving rise to the claim occurred in this judicial district and the
defendants are subject to personal jurisdiction in this district.
Parties
SNIPPETS:
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