Escolar Documentos
Profissional Documentos
Cultura Documentos
9. On information and belief, Defendants import, manufacture, distribute, offer for sale
and/or sell bags which infringe design patents and trade dress owned by Robin Ruth in
connection with its City-State Products (hereinafter Infringing Products). On information and
belief, Defendants sell Infringing Products within the State of New York and within this J udicial
District.
NATURE OF CLAIMS, JURISDICTION AND VENUE
10. This action arises under the Patent laws of the United States (35 U.S.C. 1 et. seq.),
the Trademark and Unfair Competition laws of the United States (15 U.S.C. 1051 et seq.), and
under the statutory law of the State of New York (N.Y. Gen. Bus. Law 349 et seq.) and the
common law of the State of New York.
11. J urisdiction of this Court is founded upon 28 U.S.C. 1331, 1338(a) and (b), 15
U.S.C. 1121, and the pendent jurisdiction of this Court.
12. Venue is proper within this J udicial District under 28 U.S.C. 1391(b) and (c), and
1400 (b).
13. On information and belief, Defendant BH Fashion and Arkash have committed and
continue to commit acts of patent and trade dress infringement and unfair competition in this
J udicial District.
14. On information and belief, Defendants Mourdi and Albert Faks, individually and
through their active control of BH Fashion and Arkash, have committed and continue to commit
acts of patent and trade dress infringement and unfair competition in this J udicial District.
15. On information and belief, Defendants BH Fashion, Arkash, Mourdi Faks, and Albert
Faks are subject to personal jurisdiction in this District because they reside in this J udicial
District, and purposefully engaged in, and continue to engage in, activities giving rise to claims
4
for patent and trade dress infringement and unfair competition in this J udicial District which are
directed at the residents of New York in this J udicial District.
FACTS COMMON TO ALL CLAIMS FOR RELIEF
Robin Ruths City-State Products
16. At all times relevant herein, Robin Ruth has been engaged in the business of
designing, manufacturing, marketing, distributing and selling a line of bags and accessories of
varying styles, with each bag and accessory item characterized, in part, by a unique and
distinctive repeating pattern containing the name of a particular geographic area or city, where
the repeating pattern may appear in a unique and distinct font of a single color, except for one
instance where the name of the area or city appears in a different and contrasting color (Classic
Robin Ruth Trade Dress). Robin Ruth distributes and sells goods bearing the Classic Robin
Ruth Trade Dress worldwide, throughout the United States, and including within this J udicial
District, principally through retail stores, souvenir shops, airports, and on the Internet.
17. The Classic Robin Ruth Trade Dress has been applied to numerous styles of bags and
accessories, including a Tote Bag, a Neck Wallet and a Hobo Bag. Images of these bags bearing
the Classic Robin Ruth Trade Dress are attached hereto as Exhibit A1-A3. Images of the Neck
Wallet bearing the Classic Robin Ruth Trade Dress are attached hereto as Exhibit A4. Images of
the Hobo Bag bearing the Classic Robin Ruth Trade Dress are attached hereto as Exhibit A5.
18. The Classic Robin Ruth Trade Dress is non-functional, fanciful, distinctive, well-
recognized, and represents the source of Robin Ruths products sold in association therewith and
the substantial goodwill of Robin Ruth throughout the United States, including in this J udicial
District. The Classic Robin Ruth Trade Dress constitutes valid trade dress and Robin Ruth owns
exclusive rights to it.
5
19. Robin Ruths new, non-obvious, and ornamental design for the Tote Bag is the
subject of U.S. Design Patent No. D586,118 for a Handbag, which issued on February 10,
2009 (the 118 Patent). A true and correct copy of the 118 Patent is attached hereto as Exhibit
B. Robin Ruth is the owner by assignment of all right, title, and interest in the 118 Patent.
20. Robin Ruths new, non-obvious, and ornamental design for the Neck Wallet is the
subject of U.S. Design Patent No. D597,304 for Neck Wallets, which issued on August 4,
2009 (the 304 Patent). A true and correct copy of the 304 Patent is attached hereto as Exhibit
C. Robin Ruth is the owner by assignment of all right, title, and interest in the 304 Patent.
21. Robin Ruth has also designed and is manufacturing, marketing, distributing and
selling a bag known as the City Bag, characterized, in part, by a unique and distinctive repeating
pattern containing the name of a particular geographic area or city where the individual lines of
text share the same unique and distinctive font but vary in size, orientation, and related hue
(City Bag Trade Dress).
22. Robin Ruth distributes and sells goods bearing the City Bag Trade Dress worldwide,
throughout the United States, and including within this J udicial District. Images of the City Bag
bearing the City Bag Trade Dress are attached hereto as Exhibits A6-A7.
23. The City Bag Trade Dress is non-functional, fanciful, distinctive, well-recognized,
and represents the source of Robin Ruths products sold in association therewith and the
substantial goodwill of Robin Ruth throughout the United States, including in this J udicial
District. The City Bag Trade Dress constitutes valid trade dress and Robin Ruth owns exclusive
rights to it.
24. Robin Ruths new, non-obvious, and ornamental design for the City Bag is the
subject of U.S. Design Patent No. D612,597 for a Handbag, which issued on March 30, 2010
6
(the 597 Patent). A true and correct copy of the 597 Patent is attached hereto as Exhibit D.
Robin Ruth is the owner by assignment of all right, title, and interest in the 597 Patent.
25. Robin Ruth has also designed and is manufacturing, marketing, distributing and
selling bags known as the Repeat Color Hobo Bag, characterized, in part, by a unique and
distinctive repeating pattern containing the name of a particular geographic area or city, where
each line of the repeating pattern shares the same unique and distinctive font and appears in one
of several repeating colors (Repeat Color Hobo Bag Trade Dress).
26. Robin Ruth distributes and sells goods bearing the Repeat Color Hobo Bag Trade
Dress worldwide, throughout the United States, and including within this J udicial District.
Images of the Repeat Color Hobo Bag bearing the Repeat Color Hobo Bag Trade Dress are
attached hereto as Exhibit A8-A9.
27. The Repeat Color Hobo Bag Trade Dress is non-functional, fanciful, distinctive, well-
recognized, and represents the source of Robin Ruths products sold in association therewith and
the substantial goodwill of Robin Ruth throughout the United States, including in this J udicial
District. The Repeat Color Hobo Bag Trade Dress constitutes valid trade dress and Robin Ruth
owns exclusive rights to it.
28. Robin Ruth products bear distinctive hang tags containing original, unique, and
distinctive design elements including a black and white bisected rectangle displaying a logo on
one side and a bar code on the other side, and a black and white circular medallion bearing a
logo. Defendants Infringing Products bear hang tags with the same elements. Photographs of the
Robin Ruth hang tag as compared to the BH Fashion Design hang tag are attached as Exhibit E.
The unique design features of Robin Ruths hang tags have become well-known to the
7
purchasing public as an indication of a quality Robin Ruth product, to which BH Fashion Design
has misappropriated for use in their hang tags on the Infringing Products.
29. Robin Ruth has expended substantial sums of money in advertising and promoting its
line of bags and accessories bearing its distinctive trade dress styles. As a result, the product line
has become a cultural phenomenon and has enjoyed substantial recognition by consumers,
becoming well and favorably known to the purchasing public and widely recognized as
indicating the source or origin of Robin Ruths products. The London Tote Bag was featured
on CBS News as a part of a gift set celebrating President Obamas visit to the Queen of England.
Reality television personalities Kate Gosselin and Nicole Snooki Polizzi were photographed
carrying the New York Tote Bag, and the Dalai Lama was photographed wearing a Robin
Ruth cap bearing the Amsterdam Classic Robin Ruth Trade Dress.
DEFENDANTS ACTS OF INFRINGEMENT
30. On information and belief, Defendants market and sell within this J udicial District
Infringing Products which copy Robin Ruths line of bags and embody Robin Ruths trade dress
and patented inventions, including for the Tote Bags, Neck Wallets, Hobo Bags, City Bags and
Gradated Color Hobo Bags, without authorization from Robin Ruth. Photographs of Infringing
Products of BH Fashion are attached hereto as Exhibit F. A copy of an Arkash catalog showing
Infringing Products are attached hereto as Exhibits G1-G9, and photographs of Infringing
Products of Arkash are attached hereto as Exhibits G10-G11.
31. Robin Ruth maintains a website for advertising, promoting and selling its products.
Excerpts from Robin Ruths website are attached as Exhibit H. Arkash has maintained a website
for advertising, promoting and selling its products which is identical to, and directly competitive
with, Robin Ruths website. Excerpts from Arkashs website are attached as Exhibit I. On
8
information and belief, Arkash directly copied Robin Ruths website and such copying forms a
part of Arkashs infringement as alleged herein.
32. Defendants Infringing Products are competitive with Robin Ruths products and, on
information and belief, are offered for sale and sold to consumers through the same channels of
trade.
33. By trading on Robin Ruths valuable goodwill, Defendants have caused and are likely
to cause confusion, mistake, and deception of purchasers and potential purchasers as to the
source or origin of the Defendants products and as to the existence of an association,
connection, or relationship between Robin Ruth and Defendants.
34. On information and belief, Defendants infringement has been willful and deliberate,
with full knowledge of Robin Ruths rights, and designed specifically to trade upon the
enormous goodwill associated with Robin Ruths trade dress and to capitalize on Robin Ruths
initiative.
35. Defendants actions have damaged and are likely to damage the superior reputation
and goodwill of Robin Ruth.
36. Robin Ruth is being irreparably injured and monetarily damaged by Defendants acts.
Robin Ruth has no adequate remedy at law.
COUNT 1 PATENT INFRINGEMENT OF U.S. D586,118, D597,304 AND D612,597
37. Robin Ruth repeats and realleges the allegations set forth in paragraphs 1-36 above,
as though fully set forth herein.
38. This cause of action arises under the United States Patent Act, 35 U.S.C. 1, et seq.
39. The 118 Patent, the 304 Patent, and the 597 Patent are valid and enforceable.
9
40. By the acts alleged herein, BH Fashion and the individual defendants have infringed
at least one claim of the 118 Patent, the 304 Patent, and the 597 Patent, without Robin Ruths
authorization or consent.
41. By the acts alleged herein, Arkash and the individual defendants have infringed at
least one claim of the 597 Patent, without Robin Ruths authorization or consent.
42. On information and belief, Defendants infringement has been intentional and willful,
making this an exceptional case.
43. Defendants will, on information and belief, continue to commit patent infringe as
alleged unless and until they are enjoined by this Court. Robin Ruth has been and is likely to
continue to be irreparably injured unless Defendants are enjoined. Robin Ruth has no adequate
remedy at law and is thus damaged in an amount that is yet to be determined.
COUNT 2 TRADE DRESS INFRINGEMENT IN VIOLATION OF SECTION 43(a) OF
THE LANHAM ACT, 15 U.S.C. 1125(a)
44. Robin Ruth repeats and realleges the allegations set forth in paragraphs 1-36 above,
as though fully set forth herein.
45. This cause of action arises under Section 43(a) of the Lanham Act, 15 U.S.C.
1125(a).
46. Defendants acts as alleged herein are likely to cause confusion, mistake, or deception
of purchasers and potential purchasers as to the origin, sponsorship, approval, or association of
Defendants products by Robin Ruth in violation of Section 43(a) of the Lanham Act, 15 U.S.C.
1125(a).
47. By the acts alleged herein, Defendants have used false designations of origin and
false and misleading descriptions and representations, which misrepresent the nature,
characteristics, and qualities of the Infringing Products and falsely describe the origin,
10
60. Defendants acts as alleged herein are likely to deceive or to confuse the trade and the
general public as to the source or origin of Defendants Infringing Products and as to the
existence of a relationship between Robin Ruth and Defendants.
61. On information and belief, Defendants are acting in a manner such as to deceptively
and/or fraudulently pass off its goods as those of Robin Ruth and to capitalize on the initiative
and goodwill of Robin Ruth.
62. Because of Defendants use of Robin Ruths distinctive trade dress and website
design, ordinary persons acting with reasonable care are likely to mistake Defendants goods for
those of Robin Ruth.
63. Defendants, through their unfair competition and false designations of origin, have
unfairly competed with Robin Ruth by use of unfair and improper business practices, in violation
of the common law of the state of New York.
64. Robin Ruth has and is being irreparably damaged by such acts, and damage will
continue unless Defendants acts are enjoined. Robin Ruth has no adequate remedy at law and is
thus damaged in an amount that is yet to be determined.
COUNT 5 DECEPTIVE ACTS AND PRACTICES IN VIOLATION OF N.Y. GEN. BUS.
LAW 349 ET SEQ.
65. Robin Ruth repeats and realleges the allegations set forth in paragraphs 1-36 above,
as though fully set forth herein.
66. This cause of action arises under Section 349 et seq. of the New York Consolidated
Laws.
67. Because of Defendants acts alleged herein, ordinary persons acting with reasonable
care are likely to mistake Defendants Infringing Products for the genuine goods of Robin Ruth.
13
68. Defendants unauthorized acts alleged herein constitute unlawful, unfair and
fraudulent business practices.
69. Defendants unauthorized acts as alleged herein include deceptive, untrue, and
misleading advertisements, confusing the public into believing that Robin Ruth is responsible
for, endorses, or sponsors Defendants Infringing Products.
70. Robin Ruth has and is being irreparably damaged by such acts, and damage will
continue unless Defendants acts are enjoined. Robin Ruth has no adequate remedy at law and is
thus damaged in an amount that is yet to be determined.
WHEREFORE, Robin Ruth demands judgment:
A. Adjudging and decreeing that Defendants have unlawfully infringed the 118 Patent,
the 304 Patent, and the 597 Patent and have misappropriated Robin Ruths trade dress rights;
B. Preliminarily and permanently enjoining Defendants, their officers, agents, servants,
employees and attorneys and all those in active concert or participation with any of them:
1. from importing, distributing, advertising, promoting, selling, and/or offering to
sell any product which infringes any claim of the 118 Patent, the 304 Patent, or
the 597 Patent, or which embodies a design that imitates the Classic Robin Ruth
Trade Dress, the City Bag Trade Dress, or the Repeat Color Hobo Bag Trade
Dress, or any colorable variation thereof, unless the product emanates from or is
authorized by Robin Ruth; and
2. from falsely representing or suggesting that Defendants products are affiliated
with, related to, or sponsored by Robin Ruth or suggesting any connection with it;
14
C. Requiring Defendants to pay their profits to Robin Ruth, any damages sustained by
Robin Ruth as a result of Defendants acts, and Robin Ruths costs for the action, and attorneys
fees, pursuant to 35 U.S.C. 284, 289, and 15 U.S.C. 1117(a);
D. Requiring that all product labels, signs, prints, packages, wrappers, receptacles, and
advertisements of Defendants bearing the Classic Robin Ruth Trade Dress, the City Bag Trade
Dress, the Repeat Color Hobo Bag Trade Dress, and any reproduction, counterfeit, copy, or
colorable imitation thereof, and all plates, molds, matrices and other means of making the same,
be delivered up to Plaintiff for destruction, pursuant to 15 U.S.C. 1118;
E. Requiring Defendants to pay to Robin Ruth three times the amount of actual
damages, and reasonable attorneys fees and costs, because of the exceptional nature of this case,
pursuant to 35 U.S.C. 285, 15 U.S.C. 1117(a), and/or N.Y. Gen. Bus. Law 349 et seq.; and
F. Granting such other and further relief as this Court deems just and proper.
JURY DEMAND
Robin Ruth requests a trial by jury in this matter.
Dated: J une 13, 2013 Respectfully submitted,
s/ Wendy E. Miller _
Wendy E. Miller (WM-1982)
COOPER & DUNHAM LLP
30 Rockefeller Plaza, 20
th
Fl.
New York, NY 10112
Tel: (212) 278-0400
Fax: (212) 371-0525
wmiller@cooperdunham.com
C a s e 0 : 1 0 - c v - 6 0 2 1 5 - D L G D o c u m e n t 2 1 - 1 E n t e r e d o n F L S D D o c k e t 0 4 / 0 9 / 2 0 1 0 P a g e 2 6 o f
2 8
Exhibit A-3
~
<.J
c:
a
...-
X
a
...-
CJ)
0)
ro
co
C/)
ttl
>
c
ttl
u
G:l'
Exhibit A-1
C
a
s
e
0
:
1
0
-
c
v
-
6
0
2
1
5
-
D
L
G
D
o
c
u
m
e
n
t
2
1
-
1
E
n
t
e
r
e
d
o
n
F
L
S
D
D
o
c
k
e
t
0
4
/
0
9
/
2
0
1
0
P
a
g
e
2
7
o
f
2
8
E
x
h
i
b
i
t
A
-
4
Canvas Bags 11 .2X 16 nch
(j
vrll( <JEW '{X}'
il w {m <Jf',\ Q'./k
", )r.tk Jrw "' 'J(.ft<.. 'lflot.
Y. <'( ' "" t.JfW o( )(..X
-:_'()'1 ,,; ' ... _;;;. lJt-
BNYOOI A
(J
_, ,.,v
1
.':"\'4 .nQK tJf\li
.:.._ .cQ}( I{
;' , ,_;.. t.,lty.
. .. < ,;.. . -:..0(
" . .::"
BNYOOI J
n
c
. ...
. .r""
BNYOOI-B
.... ' (.'.r , .... .... \
":_\ .. \. IJfl',
" ..-: ..:.., ' "\. '
,.;;.: JI A;
BNYOOI 1:.
{j
0<1'< JB>. ,()(11(
I -00( >JEW .QQ\<
' '<N. 0<'1< >J;;..
"' ()I.'!( {)til(
C0: N
BNYOOI C
A
>'(Y I<J(vJ 1 )t/'l.' .. tY
x, Jrv., o.:.. ,
C 1(. \J(VJ C".'l( ,_,;- 'I
11/j{ I ' 1.'\o:
>01 IHII
BNYOOI N
BNYOOI E
A
\ ' 1,1, I ( ' . v.-
; '"' .r ... 1
.,.( 'J ., L, ..
-.::, . ' )( ,. ,..
:.)
-
BNYOOI -X
{)
',..,.,.
... .,._ , f:.'l,
It ' ./. ''o r
: ' . t ..... '\. '. '
1 r.;. C )
.: ..
BNY'OO 1-f
A
. r .. ,. .. .. ,. 4
.._.:..._.,:-,: ._ ... , (' ..
. ''I'll 1.,.., -a ..,
., ., - ;o ''"'
. A '..I..
BNYOOI Q
8NY00 l G
(J
-
-
8NY00 1 Z
[!:=!:!
BNYOO I I
(J
11111 tttw vollll fttlo
tint YOI\11 NBW 1'1
NUW YURII Nl'-1'
' Nt W''fCIAI\ l'l&fi
.. . r.t:
Bt-! Y002A
m
...... ' .. ..
www.robl nruth.com
E
x
h
i
b
i
t
A
-
2
C a s e 0 : 1 0 - c v - 6 0 2 1 5 - D L G D o c u m e n t 2 1 - 1 E n t e r e d o n F L S D D o c k e t 0 4 / 0 9 / 2 0 1 0 P a g e 2 8 o f
2 8
Exhibit A-5
"'
ro
>
c
m
u
"'
Q)
E
...._
9 '
1.0
..--
Exhibit A-3
Exhibit A-2
+-'
Q)
co
s
u
Q)
z
c
0
Q)
u:... ' -
. .
'!''
. ';:
re- -- (. "-
<1
<1
<j
LL.
,.!.
0
......
>-
z
co
w
I
"'
0
"'
>-
z
co
0
I
"'
0
......
>-
z
co
u
I
"'
0
......
>-
z
co
Exhibit A-4
Roun eo Bag
6t ' I I
,, !:
,. ".. .
~ l
f:,OI I
~
Exhibit A-5
1ty ags-819
04Y!t01 A ou ~ c
,,
n ....
s"'r' I
IY51JI 11
Exhibit A-6
Exhibit A-7
Exhibit A-8
Exhibit A-9
Exhibit B-1
111111 1111111111111111111111111111111111111111111111111111111111111
c12) United States Design Patent
Shabi
(54) HANDBAG
(75) Inventor: Yaniv Shabi, Forest Hills, NY (US)
(73) Assignee: Tomgal LLC, Delray Beach, FL (US)
(**) Term: 14 Years
(21) Appl. No.: 29/278,270
(22) Filed: Mar. 23, 2007
(51) LOC (9) Cl. .................................................. 03-01
(52) U.S. Cl. ....................................................... D3/234
(58) Field of Classification Search . ... ... ... ... .. ... D3/230,
D3/232-234, 238, 240-246, 318, 324; 150/100,
150/103-104, 107-110, 118-119
See application file for complete search history.
(56) References Cited
U.S. PATENT DOCUMENTS
D244,914 S * 7/1977 Nicol .......................... D9/704
D453,070 S * 112002 Jacobs ......................... D3/234
OTHER PUBLICATIONS
4 imprint tote bags item E (sarasota beach club), p. 64 [online].
4imprint, Summer 2006 [retrieved Jul. 16, 2008]. Retrieved from the
Internet: http:/
These are pictures of handbags offered for sale by Robin Ruth in a
Robin Ruth Catalog with dates underneath each handbag when they
were first offered for sale-Jun. 30, 2006 thru Nov. 29, 2006.
* cited by examiner
USOOD586118S
(10) Patent No.: US D586,118 S
** Feb. 10, 2009 (45) Date of Patent:
Primary Examiner-Holly H Baynham
(74) Attorney, Agent, or Firm-Jon A. Gibbons; Fleit
Gibbons Gutman Bongini & Bianco P.L.
(57) CLAIM
The ornamental design for a handbag, as shown and
described.
DESCRIPTION
FIG. 1 is a top plan view of a first embodiment of a handbag
with the city ORLANDO, showing our new design;
FIG. 2 is a top plan view of a second embodiment of a
handbag with the city NEW YORK, showing our new design;
FIG. 3 is a top plan view of a third embodiment of a handbag
with the city LAS VEGAS, showing our new design;
FIG. 4 is a top plan view of a fourth embodiment of a handbag
with the city CHICAGO, showing our new design;
FIG. 5 is a top plan view of a fifth embodiment of a handbag
with the city LOS ANGLES, showing our new design; and,
FIG. 6 is a top plan view of a sixth embodiment of a handbag
with the city SAN FRANCISCO, showing our new design.
The broken lines in FIGS. 1-6 are included for the purpose of
illustrating a portion of the handbag that forms no part of the
claimed design.
1 Claim, 6 Drawing Sheets
Exhibit B-2
U.S. Patent Feb.10,2009 Sheet 1 of 6 US D586,118 S
...
, .......
,::::::::.
Exhibit B-3
U.S. Patent Feb.10,2009 Sheet 2 of 6 US D586,118 S
Exhibit B-4
U.S. Patent Feb.10,2009 Sheet 3 of 6
,:::::::::
:::Y{:
..... ., ,-. ...
.=:.:_::.._. :, : :, :, ,: - ._ .. -_...___ ....._ ..
US D586,118 S
:::::::})
Exhibit B-5
U.S. Patent Feb.10,2009 Sheet 4 of 6 US D586,118 S
Exhibit B-6
U.S. Patent Feb.10,2009 Sheet 5 of 6
u ....
,, , ....
..............
--.........
(f:-!.?-J)
::c::}
:::::::1)
(f:.f,?j)
,.. ...
:::::::'})
U .. j}:::U
US D586,118 S
:\
Vl::::-
LU
-
-l
LU
CJ)
z
<
w
3f
Exhibit B-7
U.S. Patent Feb.10,2009 Sheet 6 of 6 US D586,118 S
Exhibit C-1
I IIIII 1111111111111111111111111111111111111111111 11111111111
USOOD597304S
c12) United States Design Patent (10) Patent No.: US D597 ,304 S
** Aug. 4, 2009
Avrahami
(54) NECK WALLETS
(75) Inventor: BoazAvrahami, LJ Badhoevedorp (NL)
(73) Assignee: Tomgal, LLC., Pompano Beach, FL
(US)
(**) Term: 14 Years
(21) Appl. No.: 29/326,702
(22) Filed: Oct. 23, 2008
(51) LOC (9) Cl. .................................................. 03-01
(52) U.S. Cl. ....................................................... D3/234
(58) Field of Classification Search .......... D3/232-233,
(56)
D3/240-252, 318, 324; 150/100, 103-104,
150/106-110, 113-114, 118-119, 130--132
See application file for complete search history.
References Cited
U.S. PATENT DOCUMENTS
D244,914 S * 7/1977 Nicol .......................... D9/704
D453,070 S * 112002 Jacobs ......................... D3/234
* cited by examiner
Primary Examiner-Holly H Baynham
(74) Attorney, Agent, or Firm-Jon A. Gibbons; Fleit
Gibbons Gutman Bongini & Bianco P.L.
(45) Date of Patent:
(57) CLAIM
The ornamental design for a neck wallet, as shown and
described.
DESCRIPTION
FIG.1 is a top plan view of a first embodiment of a neck wallet
with the city San Francisco, showing our new design;
FIG. 2 is a top plan view of a second embodiment of a neck
wallet with the city Las Vegas, showing our new design;
FIG. 3 is a top plan view of a third embodiment of a neck
wallet with the city Chicago, showing our new design;
FIG. 4 is a top plan view of a fourth embodiment of a neck
wallet with the city Miami, showing our new design;
FIG. 5 is a top plan view of a fifth embodiment of a neck
wallet with the city New York, showing our new design; and,
FIG. 6 is a top plan view of a sixth embodiment of a neck
wallet with the city Los Angles, showing our new design.
The broken lines in FIGS. 1-6 are included for the purpose of
illustrating a portion of the neck wallets that forms no part of
the claimed design.
1 Claim, 6 Drawing Sheets
Exhibit C-2
U.S. Patent Aug. 4, 2009 Sheet 1 of 6 US D597 ,304 S
F I G ~ 1
Exhibit C-3
U.S. Patent Aug. 4, 2009 Sheet 2 of 6 US D597 ,304 S
Exhibit C-4
U.S. Patent Aug. 4, 2009 Sheet 3 of 6 US D597 ,304 S
Exhibit C-5
U.S. Patent Aug. 4, 2009 Sheet 4 of 6 US D597 ,304 S
..
: : .. -... :
" , ,_ . : r , __ -'-..
.. , 1 : '-
,_,--' 'i. '.\ l :V S< !
. __ .. '
.., '. __ v :
.. \ ........
\..:- ! :1 :
t-;::(&' '( :..:.."'
n ;J.ci :,
. ..._.-/'.,. : ...................""" ......... \ !
., ' -! \. t ol'
.... ..... .t ". f- !I
... .., ........... ........................ .,...,.. ........... .,.,...,..,._ ................. ..,. .. 'lijl'llji .................... .,..,..,. ........................... ... .................................. .,. ....... R-.. ..
< ;:cor._--._--._"""
I( -" !! {
:1: t
il'/'::.\ .. t ......... ........,:..: ' '
'\. ' ' ' '
j --:
'( :
j "" ,11----
< ' ' '( .. ,
>i' r
>
H
>' '
}.I
.,. '
'
"' t
.... :
'oi "\'
n\ {: .... , \ !'\ . ..-? (i
-'>"[ : u
i-
\{
. t fb:i}. _ f';. . -,< i __: . -_.:!.: ,:'_,_., .. ,-.":-:s,-., . ... __ : .. __ -__ .. ::... .._:-
[ ; u _ --::-_: ..
_,.-
FIG.4
Exhibit C-6
U.S. Patent Aug. 4, 2009 Sheet 5 of 6 US D597 ,304 S
Exhibit C-7
U.S. Patent Aug. 4, 2009 Sheet 6 of 6 US D597 ,304 S
Exhibit D-1
I IIIII 1111111111111111111111111111111111111111111 11111111111
c12) United States Design Patent
Avrahami
(54) HANDBAG
(75) Inventor: BoazAvrahami, Badhoevedorp (NL)
(73) Assignee: Tomgal, LLC, Pompano Beach, FL (US)
(**) Term: 14 Years
(21) Appl. No.: 29/320,308
(22) Filed: Jun.25,2008
(51) LOC (9) Cl. .................................................. 03-01
(52) U.S. Cl. ....................................................... D3/234
(58) Field of Classification Search .......... D3/232-234,
(56)
D3/238, 240-246, 318, 324; 150/100, 103-104,
150/106-110, 113-114, 118-119
See application file for complete search history.
References Cited
U.S. PATENT DOCUMENTS
D244,914 s
D453,070 S *
D535,472 S *
D576,793 S *
7/1977 Nicol
112002 Jacobs ......................... D3/234
112007 Fendi .......................... D3/234
9/2008 Norsa .......................... D3/234
OTHER PUBLICATIONS
These are pictures of handbags offered for sale by Robin Ruth in a
Robin Ruth Catalog with dates underneath each handbag when they
were first offered for sale-Jun. 30, 2006 thru Nov. 29, 2006.
4 imprint tote bags item E (sarasota beach club), p. 64 [online].
4imprint, Summer 2006 [retrieved Jul. 16, 2008]. Retrieved from the
Internet: http:/
USOOD612597S
(10) Patent No.:
(45) Date of Patent:
US D612,597 S
** Mar. 30, 2010
These are pictures of handbags offered for sale by Robin Ruth in a
Robin Ruth Catalog with dates underneath each handbag when they
were first offered for sale-Jun. 30, 2006 thru Nov. 29, 2006.
* cited by examiner
Primary Examiner-Holly H Baynham
(74) Attorney, Agent, or Firm-Jon A. Gibbons; Fleit
Gibbons Gutman Bongini & Bianco P.L.
(57) CLAIM
The ornamental design for a handbag, as shown and
described.
DESCRIPTION
FIG. 1 is a top plan view of a first embodiment of a handbag;
FIG. 2 is a top plan view of a second embodiment of a
handbag;
FIG. 3 is a top plan view of a third embodiment of a handbag;
FIG. 4 is a top plan view of a fourth embodiment of a handbag;
FIG. 5 is a top plan view of a fifth embodiment of a handbag;
FIG. 6 is a top plan view of a sixth embodiment of a handbag;
and,
FIG. 7 is a top plan view of a seventh embodiment of a
handbag.
Portions of the design shown in broken or dashed lines in the
drawings are for illustrative purposes only, and forms no part
of the claim design.
1 Claim, 7 Drawing Sheets
Exhibit D-2
U.S. Patent Mar. 30, 2010 Sheet 1 of 7 US D612,597 S
Exhibit D-3
U.S. Patent Mar. 30, 2010 Sheet 2 of 7 US D612,597 S
FIG.2
Exhibit D-4
U.S. Patent Mar. 30, 2010 Sheet 3 of 7 US D612,597 S
FIG.3
Exhibit D-5
U.S. Patent Mar. 30,2010 Sheet 4 of7 US D612,597 S
Exhibit D-6
U.S. Patent Mar. 30, 2010 Sheet 5 of 7 US D612,597 S
FIG.5
Exhibit D-7
U.S. Patent Mar. 30, 2010 Sheet 6 of 7 US D612,597 S
FIG.6
Exhibit D-8
U.S. Patent Mar.30,2010 Sheet 7 of7 US D612,597 S
FIG.7
A
c 0
E
Exhibit G-3 F
Exhibit F-1
A
c
E
DNY0003 (10"X10") SM
DNY0004 (1 O"X15") MED
DNY0006 ( lS" X 21 ") LG
B
D
F
Exhibit F-2
Exhibit F-3
DNY0001
A B
c
E F
Exhibit F-4
DNYOOOS
A
c D
E
Exhibit F-5
Exhibit F-6
Exhibit I-2
Exhibit F-7
Exhibit G-1
Exhibit G-1
Exhibit G-2
Exhibit G-3
Exhibit G-4
Exhibit G-5
Exhibit G-6
Exhibit G-7
Exhibit G-8
Exhibit G-9
Exhibit G-10
Exhibit G-11
E
x
h
i
b
i
t
H
-
1
NEWS
01.12.2012
Christmas is near!
Robin Ruth Germany is taking
part at the famous BRAVO .de
advent calendar. You can w1n
5 different city bundles. For
more information visit our ...
05.11.2012
MBYC 2012 Kids Fishing
Tournament
MBYC 2012 K1ds F1sh1ng
Tournament and charity event
of Robin Ruth in Jamaica. Our
friend Lennox Lewis was
VIDEO NEW COLLECTION
E
x
h
i
b
i
t
H
-
2
NEWS
01..12.2012
Christmas is near!
Robin Ruth Germany IS tak1ng
part at the famous BRAVO .de
advent calendar. You can w1n
5 different city bundles. For
more information visit our ...
05.1.1.2012
MBYC 2012 Kids Fishing
Tournament
MBYC 2012 Kids F1sh1ng
Tournament and chanty event
of Robin Ruth in Jamaica. Our
friend Lennox Lewis was
VIDEO NEW COLLECTION
E
x
h
i
b
i
t
H
-
3
there too!
21.09.2012
Robin Ruth is licensed to
sale NBA accessories
Robrn Ruth team is proud to
say that we are licensed to
sale NBA accessones. Hold on
NBA Fans we are coming :_)
Let us show you what we.
31.08.2012
Spotted
Graffiti piece spotted nearby
the Amsterdam soccerteam
AJAX stad1on of a man
wearing a Robin Ruth
cap .. WE ARE EVERYWHERE I
06.08.2012
Gifts 2012" in Moscow
Our Robin Ruth office in
Russia participated in a great
salon .. Business gifts,
souvenirs, elite stationery"
which took place in Moscow
March ..
c .. . TII=C .
Company Contact
STREET
. .. . " .4
{ .. I - ' <. 't
v -;g . . '. n . .$.
.
"'-C:. :"' ... ' ' " ... . .. '
r: ., - . ) ' . ' \,._ .-:-:;-. .
1 .' . " .... . !'\] . ::.::ii
' ,... t .- -
. (\fi' . 0: " .1 r."\ ;'_.'
... ) ... 1W
.... _...;...: ; -... . ,., .. .:;:.'I
. ._ . ., fl:
... . .. _... . . . \ . .., .
, n \1.\(\ -""'! ' . ..
;-;;rp'- ' '" .
.\ l ,..__.,
. .,.
< ; ... ....... ::'
ROBIN RUTH on Facebook
Find us on Facebook
Robin-Ruth
6,606
6,606 people like Robin-Ruth.
Dorescar Al.,tn Tor.
IJ F acebt-ok plu9in
KamiUa Etiro
IJt.r..e 138 0 &::.:!_ 1
Press Newsletter FAQ Career Terms and Conditions
E
x
h
i
b
i
t
I
-
1
I
Suppon (186}334-9965
:* f b
search site Q.
HOME ABOUT US SHOP OUR CATALOG FAQ'S CONTACT US
Welcome To Arkash Fashion, Your Number 1 Source For All
Gifts & Souvenirs.
I I
e
WATCH COLLECTION
Our Collection of Affordable Fashion
Watches
learn More
8
ARKASH FASHION BAGS
COLLECTION
Our Collection of Affordable Fashton Bags
learn More
0
WHOLESALE ACCOUNTS
Arkash fashton IS always lookmg to grow
with new merchants.
learn More
E
x
h
i
b
i
t
I
-
2
Support Hoiline: ,785}334-8965
AllllllfaUiaCIII
~ f
YCU
ern
search s1te
Welcome To Arkash Fashion, Your Number 1 Source For All
Gifts & Souvenirs.
e
ARKASH FASHION BAGS
COUECTION
Collecuon of Affordable Fash1on Bags
0
WHOLESALE ACCOUNTS
Arkash fash1on 1s always looking to grow
with new merchants.
~
E
x
h
i
b
i
t
I
-
3
meswith
fined skin
a color
ge switcher. a
ngs and
Jptions
GIFTS UNDER S20
YoLI can now setup a
word press installation that
looks like this demo with just a
single dick of your moL1se.
Amazing to get started and
accustomed to the theme
The theme comes with a built in font and color selectors in case you
want co change rhe tone of your website by changing the font and wlors.
You can also use choose between a ton of predefined skins as a start1ng
point for your custornization and with the help of color selectors for li nks.
image and color create a uni que layout in a t11atter of seconds
ts as easy as can be!
ACCESSORI ES
To get your content
displayed p1 operly the
theme uses wordpress
shortcodes. Visual previews help
you while creating those
shortcodes so you don't need to
men1orize t he codes.
120%
effon for every customer we
get. Thats how we roll!