Escolar Documentos
Profissional Documentos
Cultura Documentos
REV. 4/2012
417 o
The JS-44 civil cover sheet and the information contained herein neither replace norOTPplement tfieTilin? and servii
pleadings or other papers as required by law, except as provided by local rules of court. This form, approved t?
Judicial Conference of the United States in September 1974, is required for use of the Clerk of Court for the purpose of
initiating the civil docket sheet.
PLAINTIFFS
DEFENDANTS
FEB 18201*
CAUSEOF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE ABRIEF STATEMENT OFCAUSE)
Claimsfor copyrightinfringemenfunder tiecbon 108 ofthe UnitedStates CopyngntAct of 1976, as amended (the "Copyright Act"), 17 U.S.C. 106; unfaircompetitionunder Section
43(a) of the United States TrademarkActof 1946, as amended (the "Lanham Act"), 15 U.S.C. 1125(a);trademark infringement under Section 32(1)ofthe LanhamAct, 15 U.S.C.
1114(1);false advertising under Section 43(a)(1)(B)of the Lanham Act, 15 U.S.C. 1125(a)(1)(B); and related claims under New York's statutory and common law.
Has thisor a similar case been previously filed inSDNY at any time? No
|x] Yes
If yes,give date
Yes D
No
NATURE OF SUIT
TORTS
CONTRACT
[
[
[
[
1110
1120
M30
]140
[ ]150
INSURANCE
MARINE
PERSONAL INJURY
PERSONAL INJURY
FORFEITURE/PENALTY
BANKRUPTCY
OTHER STATUTES
[ ]362
[ ]610
[ ]620
AGRICULTURE
OTHER FOOD &
[ ]422 APPEAL
[ J400
STATE
DRUG
DRUG RELATED
SEIZURE OF
[ ]423 WITHDRAWAL
[ ]625
[
[
[
[
I
]410
]430
]450
]460
I 470
ANTITRUST
BANKS & BANKING
COMMERCE
DEPORTATION
[
[
[
[
]480
]490
]810
]850
LIABILITY
SLANDER
[ ]330
[ ]368
ASBESTOS PERSONAL
FEDERAL
INJURY PRODUCT
EMPLOYERS'
LIABILITY
ENFORCEMENT
LIABILITY
MEDICARE ACT
[ ]340 MARINE
[ ]345 MARINE PRODUCT
RECOVERY OF
DEFAULTED
STUDENT LOANS
LIABILITY
(EXCL VETERANS)
[ ]153
[ ]365
OVERPAYMENT &
OF JUDGMENT
[]151
[ ]152
U310 AIRPLANE
[]315 AIRPLANE PRODUCT
MILLER ACT
NEGOTIABLE
INSTRUMENT
RECOVERY OF
RECOVERY OF
PERSONAL PROPERTY
I ]370
t 1371
[ J380
PRODUCT LIABILITY
[ ]360
OVERPAYMENT
OTHER PERSONAL
[ J 385
INJURY
OTHER FRAUD
TRUTH IN LENDING
OTHER PERSONAL
PROPERTY DAMAGE
PROPERTY DAMAGE
PRODUCT LIABILITY
[ ]190
BENEFITS
STOCKHOLDERS
SUITS
OTHER
)630
I 640
]650
]660
[ ]690
21 USC 881
LIQUOR LAWS
PROPERTY RIGHTS
RR & TRUCK
AIRLINE REGS
P<]820 COPYRIGHTS
OCCUPATIONAL
SAFETY/HEALTH
PRODUCT
LIABILITY
[ ]196
FRANCHISE
REAL PROPERTY
[ ]441 VOTING
[ ]442 EMPLOYMENT
[ ]443 HOUSING/
[ ]530
[ ]535
[ ]540
HABEAS CORPUS
LAND
CONDEMNATION
[ ]444 WELFARE
( ]445 AMERICANS WITH
[ ]220
[ ]230
FORECLOSURE
RENT LEASE &
[ ]240
[ ]245
TORTS TO LAND
DISABILITIES -OTHER
TORT PRODUCT
[ ]290
ALL OTHER
EJECTMENT
LIABILITY
FAIR LABOR
t ]720
STANDARDS ACT
LABOR/MGMT
DISABILITIES EMPLOYMENT
[ ]446
[ ]740
[]790
DEATH PENALTY
MANDAMUS & OTHER
RELATIONS
LABOR/MGMT
REPORTING &
DISCLOSURE ACT
RAILWAY LABOR ACT
OTHER LABOR
LITIGATION
[]791
EMPLRETINC
SECURITY ACT
[
[
I
[
[
] 861
] 862
] 863
] 864
J 865
HIA(1395ff)
BLACK LUNG (923)
DIWC/DIWW (405(g))
SSID TITLE XVI
RSI (405(g))
REAPPORTIONMENT
RACKETEER INFLU
ENCED & CORRUPT
ORGANIZATION ACT
(RICO)
CONSUMER CREDIT
CABLE/SATELLITE TV
SELECTIVE SERVICE
SECURITIES/
COMMODITIES/
EXCHANGE
[ ]875 CUSTOMER
CHALLENGE
12 USC 3410
[ ]893
ENVIRONMENTAL
[ ]894
ENERGY
MATTERS
26 USC 7609
ALLOCATION ACT
[ ]895 FREEDOM OF
INFORMATION ACT
ACCOMMODATIONS
[ ]210
[ ]710
MOTIONS TO
VACATE SENTENCE
20 USC 2255
CIVIL RIGHTS
[ ] 830 PATENT
[ J 840 TRADEMARK
OTHER
LABOR
[J 730
[]510
CONTRACT
28 USC 157
SOCIAL SECURITY
PRISONER PETITIONS
CONTRACT
1 ]195
28 USC 158
PROPERTY
[
[
[
[
OF VETERAN'S
[ ]160
IMMIGRATION
DETERMINATION
[ ]462
[ ]550
[ ]555
CIVIL RIGHTS
PRISON CONDITION
NATURALIZATION
UNDER EQUAL
APPLICATION
[ ]463
AMERICANS WITH
I ]465
ACCESS TO JUSTICE
[ ]950 CONSTITUTIONALITY
OF STATE STATUTES
REAL PROPERTY
DO YOU CLAIM THIS CASE IS RELATED TO A CIVIL CASE NOW PENDING IN S.DNY'
IF SO, STATE:
judge
DOCKET NUMBER
NOTE: Please submit at the time of filing an explanation of why cases are deemed related.
H 1 Original
ORIGIN
2 Removed from
Proceeding
state Court
from
Reopened
II 7 Appeal toDistrict
Litigation
Judge from
Magistrate Judge
Judgment
Appellate
Court
| I b. At least one
party is pro se.
(PLACEAN x IN ONEBOXONLY)
1 U.S. PLAINTIFF
BASIS OF JURISDICTION
Q2 U.S. DEFENDANT
M 3 FEDERAL QUESTION
IF DIVERSITY, INDICATE
Q4 DIVERSITY
CITIZENSHIP BELOW.
PTF
DEF
CITIZEN OR SUBJECT OF A
FOREIGN COUNTRY
PTF
DEF
13
PTF
DEF
FOREIGN NATION
9 Skyline Drive
Hawthorne, New York 10532
Westchester County
DEFENDANT(S) ADDRESS(ES) AND COUNTY(IES)
Trophy Depot, Inc.
171 Rodeo Drive
James O'Boyle
Trophy Depot, Inc.
Howard Becker
Checkone:
WHITE PLAINS
[X] MANHATTAN
(DO NOT check either box ifthis a PRISONER PETITION/PRISONER CIVIL RIGHTS COMPLAINT.)
Richard Z. Lehv
"' l. kl
is so Designated.
Deputy Clerk, DATED
y, ^
15
'">
1178
Plaintiff,
v.
Plaintiff, Crown Awards, Inc., by its attorneys, Fross Zelnick Lehrman & Zissu, P.C, for
its Complaint against Defendants, Trophy Depot, Inc., James O'Boyle, and Howard Becker,
alleges as follows:
1. This is an action for blatant and willful copyright infringement and unfair
competition on a massive scale.
2. Plaintiff designs, manufactures, and sells trophies, medals, and other awards for
sports competitions and other activities and events. Founded in 1978, Plaintiff started as a single
storefront in Brooklyn, and grew into the largest retailer of awards in the country. Plaintiff has its
own staff of designers, who create original designs for an enormous variety of medals, trophies,
and other awards for sporting events and other competitions and occasions.
{F1617946.9 1
3. Defendants, unable or unwilling to design their own trophies, medals, and awards,
have adopted a predatory and unlawful business model, consisting of intentional and wholesale
copying of Plaintiff s products and business. Indeed, whenever Plaintiff releases a new design or
adds a new feature to its website, no matter how idiosyncratic or unusual, Defendants shortly
thereafter do the exact same thing. For example, just last month Plaintiff introduced its new
prices, and several weeks later Defendants' website started to show the exact same pricing.
4. Defendants know that their conduct is unlawful, having been enjoined by a federal
court in 2005 from infringing the copyright in Plaintiffs catalog and ordered to pay Plaintiff
nearly half a million dollars. Despite these penalties and the court's description of Defendants'
conduct as "disturbing," Defendants were undeterred, and they have expanded their infringing
activities to include:
{F1617946.9 )
J3L
-^
{F1617946.9}
Copying the component parts of awards, such as Mylar inserts and neck ribbons,
which can be combined with thousands of medals and other awards. The following
are several examples of inserts copied by Defendants that can be placed on trophies,
medals, and plaques, thereby making the finished trophy or award an infringing work:
Plaintiff's Copyrighted Designs
{F1617946.9 |
TY*
{F1617946.9 }
The following are four examples of ribbons copied by Defendants that can be
(F1617946.9 (
Copying the exact look and feel of Plaintiffs "Trophy Builder" for custom design of
trophies and other awards:
Plaintiff's Copyrighted Design
GrMntfMmnls kssksh
-- *
I
'
_ Mr T*.y*ur Tiepjhyt
*>
B#
(F1617946.9)
Copying the exact look and feel of Plaintiff s "Engraving Engine" for custom
engraving of awards:
Plaintiffs Copyrighted Design
/\
* >ll 5^r.Q jj
CwteMPhrMi
Si
)
_*<
www
CfMMMl
tg,J
' WJ.SLK
2333SS33
(F1617946.9|
Copying the overall look and feel of Plaintiffs homepage, as shown below, and many
other pages within the site:
Plaintiffs Copyrighted Homepage
filaSftBr^
If* h^
kMf
^m
mmm
"^
J?
s^ "LT^
mmm
<r *t *i_
Jf 9
A4 #
IB
^SI-IO;
<#. H_ fiU <k^
M ?f_ .4 1
s**
sot-
ws- ux..
i w ia
- w saa*..;
d89
h
Hk. T
JL_
V~ 4k
* 119 Is
'L
&J%
MM
MM
MM
M3T KJHt;
VSt t,
1* iif A
VI" S I t i
*_.._ 6
V^K 0
=~---
,_
(F1617946.9)
yJKiM.0 '
"~zz. ******
Mmmv
'*"*
~^V r~"*
** r*r*
*BS" r*"T
i- i
Copying other key elements of Plaintiff s website, namely the look and feel of
Plaintiffs display of trophies and awards, as shown below:
Plaintiffs Copyrighted Page
Cmntfhnrfs
HtKSMtMNG
WoSuD
^"Wi
Elf
or
I*-.
a:
fe 'i
ELEL-
Is*
III
' H4
fTTTf''^
*Mm* LiLfi2Ji
\sf* LlZIBtJ
y
" TTWi*
*"&**
rrrr-.
ll
*-,'&*
1'.;iwa
% Ji
{F1617946.9}
10
jSr.,*~+
Engaging in false advertising, such as claiming that they offer "Same-Day Shipping,"
when they do not.
5. Despite having full knowledge that their actions are unlawful, Defendants persist in
running a business that is based on copying Plaintiffs protected works and, indeed, Plaintiffs
entire business. Plaintiff has had no choice than to file this action to stop these recidivist
Defendants from copying its products, components, and website, by asking this court to shut
down the infringing website as it is currently designed, to permanently enjoin further sale of all
the infringing products, and to order Defendants to turn over their ill-gotten gains.
6. Plaintiff therefore brings claims for copyright infringement under Section 106 ofthe
United States Copyright Act of 1976, as amended (the "Copyright Act"), 17 U.S.C. 106; unfair
competition under Section 43(a) ofthe United States Trademark Act of 1946, as amended (the
"Lanham Act"), 15 U.S.C. 1125(a); trademark infringement under Section 32(1) ofthe
Lanham Act, 15 U.S.C. 1114(1); false advertising under Section 43(a)(1)(B) ofthe Lanham
{F1617946.9 |
, ,
Act, 15 U.S.C. 1125(a)(1)(B); and related claims under New York's statutory and common
law. Plaintiff seeks injunctive and monetary relief.
JURISDICTION AND VENUE
7. This Court has jurisdiction under Section 501 ofthe Copyright Act, 17 U.S.C. 501,
under Section 39 ofthe Lanham Act, 15U.S.C. 1121, under Sections 1331 and 1338(a) and (b)
ofthe Judicial Code, 28 U.S.C. 1331, 1338(a) & (b), and under principles of pendent
jurisdiction. Supplemental jurisdiction exists over Plaintiffs state law claims pursuant to 28
U.S.C. 1367.
8. This Court has personal jurisdiction over Defendants because, on information and
belief, (a) Defendant Trophy Depot, Inc.'s place of incorporation and principal place of business
is New York, (b) Defendants James O'Boyle's and Howard Becker are both domiciles of New
York, and (c) Defendants sell their infringing products to customers in this District.
9. Venue is proper in this District under Section 1391(b) ofthe Judicial Code, 28 U.S.C.
1391(b), because a substantial part ofthe events giving rise to the claims occurred in this
District, and because Defendants are deemed to reside in this District by virtue of being subject
to personal jurisdiction here.
THE PARTIES
10. Plaintiff, Crown Awards, Inc., is a corporation organized and existing under the laws
ofthe State of New York, having its principal place of business at 9 Skyline Drive, Hawthorne,
New York 10532.
11. On information and belief, Defendant Trophy Depot, Inc. is a corporation organized
and existing under the laws ofthe State of New York, having its principal place of business at
171 Rodeo Drive, Edgewood, New York 11717. On information and belief, Trophy Depot, Inc.
is the registrant ofthe domain name trophydepot.com.
12. On information and belief, Defendant James O'Boyle is resident and citizen ofthe
State of New York. On information and belief, Mr. O'Boyle is the sole shareholder and chief
{F1617946.9}
12
executive officer of Trophy Depot, Inc., directs and controls its infringing activities, and profits
from them.
I.
14. Founded in 1978, Plaintiff today is the largest awards supplier in the United States.
Plaintiff supplies awards for myriad activities and occasions, from sporting events to educational
16. Plaintiff offers its products for sale primarily through its website,
www.crownawards.com, its annual catalogs, and Crown Trophy retail stores in over forty states.
Plaintiffs annual catalog, which contains the entire line of products offered by Plaintiff at the
time the catalog is published, is distributed to thousands of consumers and corporate customers
across the United States. Plaintiff advertises through its website, catalogs, promotional emails,
and social media, such as Facebook, Instagram, and Twitter.
A.
17. Plaintiff, through its design team, has independently created thousands of awards
and other products. Plaintiff, as the employer-for-hire, is the author under the Copyright Act of
{F1617946.9 j
13
these original works of authorship. As such, Plaintiff is the owner of all right, title, and interest
in and to the copyright in its awards and other products. Attached as Exhibit A hereto are
c.
d.
U.S. Copyright Registration No. VAu 676-949 for double action medals
for various sports, which registered on September 19, 2005;
g.
h.
j.
U.S. Copyright Registration No. VAu 676-956 for 2" 3D diecast medals,
which registered on September 19, 2005;
{F1617946.9 }
14
1.
m.
n.
U.S. Copyright Registration No. VA 1-902-804 for a large hip hop dog
tag, which registered on February 18, 2014;
o.
p.
U.S. Copyright Registration No. VA 1-851-810 for a pop out star acrylic,
which registered on February 1, 2013;
q.
r.
s.
t.
u.
U.S. Copyright Registration No. VA 1-811-025 for black and gold trophy
columns, which registered on February 17, 2012;
v.
w.
x.
{F1617946.9 }
15
y.
19. Plaintiff also owns numerous copyright registrations for its annual catalogs, which
cover the awards and other original works shown therein, such as Plaintiffs "price breaks" (as
explained below). Plaintiffs copyright registrations for its catalogs include the following:
a.
c.
d.
e.
f.
has a pending application to register the copyright in its 2014 catalog, which was filed on April
11, 2014. Copies ofthe 2012 and 2013 catalogs are attached as Exhibit D.
B.
20. Formerly, awards and medals were shipped in generic packaging, such as cardboard
boxes. Plaintiff was the first supplier in its industry to offer elegant presentation packaging,
namely satin-lined boxes, an image of which is attached as Exhibit E. Plaintiff is the owner of
all right, title, and interest in and to the trade dress of such packaging. Plaintiffs packaging
{F1617946.9)
16
incorporates several distinct elements that make up the trade dress, including the packaging's
royal blue color, a rectangular box with a satin interior, and Plaintiffs logo printed in gold
(collectively, the "Packaging Trade Dress").
21. By virtue of extensive sales, advertising and promotion, the Packaging Trade Dress
has become instantly recognizable to the public as exclusively denoting Plaintiff. As such, the
Packaging Trade Dress has obtained secondary meaning and is a valuable asset of Plaintiff.
C.
22. Plaintiffs products are grouped into product lines. Attached as Exhibit F hereto are
before been represented on medals, such as a 5-kilometer run and a mud run. Once the activity
or occasion is selected, Plaintiff independently designs the artwork on each medal. As a result,
all of these 3D medals are original works created by Plaintiff.
24. Other product lines within the medals category include "double action" medals and
"perimeter" medals, on which the year is repeated around the rim (e.g., 2014 or 2015). There are
also product lines within the other award categories. For example, within the sculptures category
there are numerous product lines, such as a line of cup sculptures, and within the crystal awards
category there are several product lines, such as a line of 3D laser-printed crystal blocks.
25. Plaintiff also creates lines of components that can be added to its products. For
example, it has designed hundreds of Mylar inserts that can be added to the front of medals,
placed on top of trophies, and placed on plaques. It is often the insert that gives an award its
meaning and makes the award unique, differentiating it from other awards. For example, if a
(F1617946.9)
17
child plays sports every year and receives a medal at the end of each season, most likely the key
differentiating component of his or her medal will be the insert, as the insert will show the sport
(soccer, basketball, baseball, etc.) or other activity for which this particular medal was awarded.
Thus, the insert is often the reason for the consumer's purchase ofthe entire medal or award.
26. Plaintiffs collection of inserts is unique in the industry. Plaintiff began designing its
own line of inserts over twenty years ago. The line began with about thirty inserts, and today
includes over 500 styles. Plaintiff decides which activities and occasions to represent on the
inserts, selecting from thousands of possibilities. Plaintiffs design team independently creates
the artwork for the inserts, often researching an activity to determine a design that would appeal
to participants of that activity. For some sports, Plaintiff offers dozens of designs. Plaintiffs
design team also has designed inserts with rhinestones, glitter, or embossing, which no other
awards company had done before Plaintiff.
27. Neck ribbons are another component that Plaintiff designs. Plaintiffs neck ribbons
also can be used with virtually all of its medals. Plaintiffs design team has independently
created numerous original neck ribbon designs, some displaying the year and others showing the
activity.
28. Individual items in all of Plaintiffs product lines are designed for hundreds of
specific activities or occasions, including sports such as baseball, soccer, football, and
gymnastics, non-sports competitions such as baking and chili cooking, academic achievement,
music and dance, and countless others, including such new competitions as mud runs. Plaintiff
even offers an award for an ugly Christmas sweater party. Other items, such as crystal awards,
are initially blank, and are engraved with the achievement intended to be recognized and perhaps
the name ofthe recipient.
29. To create all of these product lines, components, and individual products, Plaintiff
independently selected, coordinated, and arranged a vast number of elements, including
activities, occasions, and competitions, and also selected, coordinated, and arranged the images
or designs used to represent visually each activity, occasion, or competition to be shown on each
(F1617946.9}
li
product or component. For example, there are countless ways to represent a judo competition.
Plaintiff chose to represent judo on its two-inch 3D medal by showing one wrestler flipping the
other over his hip, with both wrestlers surrounded by a fan-like pattern, within a circle of stars.
(See illustration in Paragraph 3, above.) Plaintiff is the owner of all right, title, and interest in
and to the copyright in such original selection, coordination, and arrangement of products,
components, and product lines.
30. The selection, coordination, and arrangement in Plaintiffs products, components,
and product lines are covered by the copyright registrations for Plaintiffs catalogs and website,
among others. See Ex. C infra, Ex. H supra.
D.
Plaintiffs Website
31. Plaintiff has independently created the content and design of each iteration of its
website. Plaintiff independently created the look and feel of its website, which is an original
work of authorship. Plaintiff is the owner of all right, title, and interest in and to the copyright in
its website. Attached as Exhibit G hereto are screenshots of several representative pages of
Plaintiffs website, including the homepage and several individual product pages.
32. Plaintiff owns the following copyright registrations for its website:
a.
b.
Copies ofthe Certificates of Registration listed above are attached hereto as Exhibit H. Plaintiff
also has an additional application pending to register the copyright in its website, which was filed
on June 27, 2013.
33. In addition, Plaintiff is the owner of all right, title, and interest in and to the trade
dress of its website. Plaintiffs website incorporates several distinct elements that make up the
trade dress, including:
(F1617946.9)
19
a.
a homepage with a header at the top that features Plaintiffs logo and the
categories of products sold by Plaintiff, two keyword search bars (one at
the upper right and one in the left margin), featured products arranged in
four columns, and information about Plaintiff underneath the featured
products;
b.
product lines within the category and beneath that the full set of product
lines within the category, which are displayed in four columns, and a
vertical frame on the left side containing links to subcategories within the
category; and
c.
individual product pages with the header at the top, a picture ofthe
product, and the price breaks to the right ofthe product.
Such elements collectively create a particular trade dress that is characteristic of Plaintiff s
website (the "Website Trade Dress").
34. For over a decade and continuing through today, Plaintiff has made widespread and
exclusive use of its Website Trade Dress. Plaintiff has enjoyed enormous success selling
products through its website.
35. As a result of Plaintiff s efforts, the Website Trade Dress has become instantly
recognizable to the public as exclusively denoting Plaintiff. As such, the Website Trade Dress
has obtained secondary meaning and is an enormously valuable asset of Plaintiff. Except for
Defendants' infringing design, Plaintiffs competitors do not use this trade dress. Except for
Defendants' unlawful copy, the Website Trade Dress is unique to Plaintiff.
E.
36. Plaintiff offers customers various options to customize their awards. For example, a
customer can build his or her own trophy, choosing the preferred base, column, and figurine or
(F1617946.9 )
20
insert to top the trophy. Customers also can engrave their awards with personalized text (e.g.,
with the name ofthe award's recipient or the name and year of an event). When such
customization is done on Plaintiffs website, it is done through two unique web-based programs
developed by Plaintiff: the Trophy Builder and the Engraving Engine.
37. The Trophy Builder assists customers with selecting the component parts of awards.
Although the name implies that it is meant for customizing trophies, the Trophy Builder works
for all types of awards. As the customer selects the different parts ofthe award, an onscreen
image ofthe award updates to show the customer's choices. Thus, a customer can see what his
or her customized award will look like before it is assembled by Plaintiff, a feature that is unique
to Plaintiff. Attached as Exhibit I hereto are screenshots from Plaintiffs website demonstrating
how the Trophy Builder program works for several types of awards.
38. As shown in Exhibit I, the Trophy Builder involves several steps. For example,
when using the Trophy Builder to create a customized trophy, the customer first picks a trophy
style, which brings the customer to the product page for that trophy style. Then the customer
selects the size ofthe trophy, which causes several drop-down boxes to appear. The first drop
down box requires the customer to select an activity or occasion, such as a sport, hobby, or
holiday. The activity or occasion chosen will determine the contents ofthe next drop-down box,
which the customer uses to pick a figurine or insert to top the trophy. So, if a customer chooses
soccer as the activity, the next drop-down box will contain a number of soccer-related figurines
or inserts, such as a soccer ball or a man or woman kicking a soccer ball, among others. But if a
customer selects track and field as the activity, he or she will be presented with figurines or
inserts that relate to track and field. Once the figurine or insert is selected, it is shown in the
product's image. Next the customer picks the column color, which also appears in the product's
image. Finally, the customer selects the base color. Once these steps are completed, the final
product is shown in the product's image.
39. Plaintiff has independently created the overall look and feel ofthe Trophy Builder,
which is an original work of authorship, involving the selection, coordination and arrangement of
{F1617946.9 }
21
numerous elements. As such, Plaintiff is the owner of all right, title, and interest in and to the
copyright in the Trophy Builder.
40. The Trophy Builder is the subject of U.S. Copyright Registration No. TX 6-415-744,
owned by Plaintiff and which registered on December 13, 2005. A copy ofthe Certificate of
Registration is attached hereto as Exhibit J. Plaintiff has an additional application pending to
register the copyright in its Trophy Builder, which was filed on December 30, 2014. The Trophy
Builder is also subject to Plaintiffs copyright registrations for its website. See Ex. H.
41. The Engraving Engine facilitates the customization of text on awards. Like the
Trophy Builder, the Engraving Engine lets the customer see how the engraved text will appear
on the product before it is actually engraved by Plaintiff. Attached as Exhibit K are screenshots
from Plaintiffs website showing the various steps ofthe Engraving Engine for several types of
awards.
42. Before entering the Engraving Engine, the customer indicates whether each award
should have the same text or different text (e.g., engrave each award with a different recipient's
name). Then the customer clicks the blue Engraving Engine button on the product page, which
causes the Engraving Engine to appear in a pop-up screen.
43. The customer then types in his or her desired text. If the customer chose to have
different text on each award, he or she will indicate for each line whether it should appear on all
ofthe awards or just that particular one. For example, the customer might want to put "State
Championship" and "New York" on the first two lines of each award, but engrave different text
on the third line of each award, such as "First Place," "Second Place," and "Third Place." The
Engraving Engine does not require a customer to separately type the repeating lines for each
award. Further, for some products, the Engraving Engine allows the customer to select the size
ofthe text (small, medium, or large) and elect whether to insert an ornament instead of text on a
specific line.
44. Plaintiff has independently created the look and feel ofthe Engraving Engine, which
(F1617946.9}
22
numerous elements. As such, Plaintiff is the owner of all right, title, and interest in and to the
copyright in the Engraving Engine.
45. The Engraving Engine is the subject of U.S. Copyright Registration No. TX 6-415-
745, owned by Plaintiff and which registered on December 13, 2005. A copy ofthe Certificate of
Registration is attached hereto as Exhibit L. Plaintiff has an additional application pending to
register the copyright in its Engraving Engine, which was filed on December 30, 2014. The
Engraving Engine is also subject to Plaintiffs copyright registrations for its website. See Ex. H.
46. The look and feel ofthe Trophy Builder and Engraving Engine are unique to
Plaintiff. There are many ways for companies to present their customization options to
consumers. Thus, while many of Plaintiff s competitors offer customized awards, none - except
for Defendant's unlawful copies - use designs that are the same as or substantially similar to
Plaintiffs designs.
F.
47. The price of Plaintiff s awards depends on how many units the consumer purchases;
the unit price decreases if more awards are purchased. The number of units at which the price
decreases is referred to as a "price break." Plaintiff has different price breaks for different types
of awards. For example, Plaintiffs 2014 catalog offered eight prices breaks for medals (at 1, 10,
50, 100, 300, 500, 750, and 1,000 units), five price breaks for trophies (at 1,10, 50, 100, and 250
units), and four price breaks for crystal awards (at 1,10, 50, and 100 units). For each of these
awards, the price per unit is lower if the consumer buys 60 units instead of 40 units, and even
lower if the customer buys 120 units instead of 60. Plaintiff invested much time and effort in
determining suitable price breaks and how to present such price breaks to customers.
48. Plaintiffs pricing structure has other characteristics as well. It offers certain features
at no cost, such as a free logo on crystal and acrylic awards if the customer orders more than
twenty-five units and free engraving of forty characters on trophies and plaques, with additional
characters costing 10 cents per character on trophies and 25 cents per character on plaques. But
(F1617946.9)
23
the first forty characters are not free on all types of awards. For example, it costs 50 cents per
medal to engrave the same text on each medal, and 75 cents per medal to engrave different text
on each medal.
49. To create its pricing structure, Plaintiff has independently selected, coordinated, and
arranged its price breaks with the per unit prices. Moreover, Plaintiff has independently created
the look and feel of those portions of its catalogues and website that present Plaintiffs price
breaks and other pricing policies. As such, Plaintiff is the owner of all right, title, and interest in
and to the copyright in the design of its price break presentations. Attached as Exhibit M are
examples of how Plaintiff compiles and presents its price breaks to consumers.
50. The selection, coordination, and arrangement in Plaintiffs price breaks, as well as
the overall look and feel of its presentation of its pricing information, are covered by the
copyright registrations for Plaintiffs catalogs and website. See Exs. C, H, infra.
G.
51. Plaintiff has been using the CROWN AWARDS name and mark since its founding
in 1978.
52. Plaintiff extensively advertises and promotes its CROWN AWARDS mark. Plaintiff
has achieved great commercial success under the CROWN AWARD mark over the last several
decades.
53. In addition to Plaintiffs extensive and strong common law rights in the CROWN
AWARDS trademark that have resulted from this use, Plaintiff owns the following U.S.
trademark registrations for the mark CROWN AWARDS: U.S. Registration No. 2,663,903 for
use in connection with "custom design and printing of trophies, medals, plaques, ribbons, awards
and desk sets for others" in International Class 42, which issued on December 17, 2002, and is
based on a first use in commerce on January 1, 2001; and U.S. Registration No. 2,586,186 for
"mail order retailing services and electronic retailing services via computer featuring trophies,
(F1617946.9)
24
medals, plaques, ribbons, awards and personalized desk sets" in International Class 35, which
issued on June 25, 2002, and is based on a first use in commerce on January 1, 2001.
54. Printouts detailing the registration information for the above marks are attached
hereto as Exhibit N. These registrations are all valid, subsisting, and in full force and effect.
Moreover, the above registrations have become incontestable under Section 15 ofthe Lanham
Act, 15 U.S.C. 1065, and serve as conclusive evidence ofthe validity ofthe registered marks,
ofthe registration ofthe marks, and of Plaintiff s exclusive right to use the marks in commerce
on or in connection with the products for which the marks are registered, as provided by Section
33(b) ofthe Lanham Act, 15 U.S.C. 1115(b).
II.
A.
55. Defendants own and operate Trophy Depot, which supplies awards for various
activities and occasions. Like Plaintiff, Defendants offer their awards for sale through their
website, located at www.trophydepot.com, and their print catalog.
56. On information and belief, Trophy Depot does not have a design department.
Instead, Defendants copy Plaintiffs product designs and product lines to create awards and
product lines that are substantially similar to Plaintiffs original works. Further, Defendants have
modeled their website, including their designs for building customized awards and engraving
personalized text, on Plaintiffs website. As a result, Defendants' website has the same overall
57. That Defendants do not design their own awards is confirmed by Defendant Becker,
who is Trophy Depot's "Creative Director." Mr. Becker states on his resume that he manages
"product additions or removal using competitive research." See Howard Becker's resume on
www.indeed.com, attached hereto as Exhibit O.
58. Defendants are not ignorant ofthe unlawfulness of their conduct. Plaintiff
(F1617946.9)
25
Plaintiffs catalogs, and earlier versions of its website and advertising materials. Crown Awards
Inc. v. James Engravers, Ltd., Civil Action No. 03-2448 (E.D.N.Y 2005). In addition to granting
59. Defendants' infringing conduct is far more pervasive than that at issue in the prior
lawsuit. This time, Defendants are infringing Plaintiffs copyrights in the designs in Plaintiffs
awards, the selection, arrangement, and coordination in Plaintiffs product lines, the overall look
and feel of Plaintiff s Trophy Builder and Engraving Engine as well as the overall website,
Plaintiffs price breaks, and Plaintiffs Packaging Trade Dress. In addition, they are falsely
advertising that they offer "Same-day Shipping," and are using Plaintiffs trademark as a paid
keyword.
1.
awards that are substantially similar, if not identical, to Plaintiffs copyrighted awards. In
addition, Defendants have copied many of Plaintiff s inserts and neck ribbons as well. Thus,
even when Defendants sell a trophy that is not copied from one of Plaintiff s trophies, they will
likely combine it with an infringing insert or neck ribbon, making the entire product an
infringing copy. Defendants have intentionally engaged in such copying of Plaintiff s protected
designs in its awards, inserts, and neck ribbons.
61. Defendants' copying has become so common that nearly every time Plaintiff
introduces a new award, Defendants start selling a substantially similar award shortly thereafter.
Defendants appear to be constantly monitoring Plaintiffs website for new products to copy. For
example, Plaintiff was the first company to offer medals that print the words "GOLD,"
{F1617946.9 |
26
"SILVER," and "BRONZE" on medals of those colors. No sooner had Plaintiff added those
62. As another example, the design on Plaintiffs mud run medal is a muddy footprint,
with brown paint used for the mud. This is the first medal in Plaintiffs Two-Inch 3D medal
product line with added color. Defendants immediately followed suit, also using brown paint in
a product line that otherwise has no color. Further, there are countless ways to represent a mud
run; that Defendants also use a muddy footprint is telling.
Plaintiffs Copyrighted Design
63. Finally, no sooner had Plaintiff added a medal for an "Ugly Christmas Sweater
party" than Defendant's added a product for an "Ugly Christmas Sweater," as follows:
(F16I7946.9 1
27
ortfrSSJ
64. Defendant's copying is not limited to these medals and inserts. As shown below and
in the attached exhibits, Defendant' copying extends to all types of awards, inserts, and neck
ribbons. For example, Plaintiff has long offered Two-Inch 3D medals for a wide variety of
activities and occasions, and just recently Defendants began offering nearly identical Two-Inch
3D medals for the same activities and occasions. Below are several examples of Plaintiff s TwoInch 3D medals next to Defendants' infringing medals:
Plaintiffs Copyrighted Designs
j mm A
28
(F1617946.9)
29
{F1617946.9 }
30
(F1617946.9)
31
^IHSmmmT'
'fytB/****
{F1617946.9)
32
65. As is apparent from these images, Defendants' medals are substantially similar to
Plaintiffs medals. For example, both ofthe 5-kilometer race medals consist of a shoe with
wings and the text "5K," which are encircled by a decorative rim. Moreover, on both 5-
kilometer race medals certain parts ofthe design extend beyond the medals' borders. The judo
medals are also disconcertingly similar. Both show two men in the same judo pose on top of a
fan-shaped background, surrounded by stars. In fact, Defendant's image ofthe men is identical
to Plaintiffs image; the only difference is that Defendant's image has been reversed. And the
twirling medals are virtually identicalboth have the term "Twirling" across the bottom ofthe
medal and batons radiating from a central point in the medal.
66. All of Plaintiff s Two-Inch 3D medals were offered for sale before Defendants
began offering their copies for sale. In addition, Defendants' entire line of Two-Inch 3D medals
consists of copies. In other words, Defendants do not offer for sale a single Two-Inch 3D medal
that is not a copy of one of Plaintiff s medals. This is remarkable evidence of Defendants'
intentional copying.
67. Other medals offered by Defendants also are substantially similar to those offered by
Plaintiff. For example, the perimeter and double action medals, as shown below:
(F1617946.9 }
33
A* Pr>
Pioi:
(F1617946.9 1
34
68. As further example of Defendants' willful and blatant copying, shown below are
trophy cups offered by both Plaintiff and Defendants:
69. The cups on both Plaintiffs and Defendant's trophies are identical: parallel grooves
encircle the cup underneath a wavy rim, with S-shaped handles that have similar design details.
The bases also are the same. In addition, each sport is represented by the same sculptureboth
soccer cups are adorned with a cleated shoe resting against a soccer ball, and both basketball
cups are adorned with a basketball next to a hoop.
(F1617946.9)
35
70. Another example is Defendants' 3D laser crystal blocks, which are nearly identical
to the 3D laser crystal blocks offered by Plaintiff:
Plaintiffs Copyrighted Designs
'mine**msm
|i:
{F1617946.9)
'**
36
I .
71. The similarities between Plaintiffs and Defendants' awards do not end there. Like
Plaintiff, Defendants offer inserts for use in connection with many different types of awards,
such as trophies, medals, and plaques. Many of Defendants' inserts are substantially similar to
Plaintiffs inserts, as shown below:
{F1617946.9 )
37
T^m
(F1617946.9)
38
>^%^i ph
(F16I7946.9 }
39
SKII
{F1617946.9 |
40
{F1617946.9|
41
72. Finally, many of Defendants' medal neck ribbons are substantially similar to those
designed, created, and copyrighted by Plaintiff. Each of Defendants' neck ribbons can be
attached to any of its medals. Thus, Defendants' infringing neck ribbons can be paired with any
ofthe medals that Defendants offer for sale. One example of Defendants' blatant copying of
Plaintiffs neck ribbon is their year neck ribbon. In 2014, Plaintiff released a new neck ribbon,
which displayed the year vertically, as shown below. Prior to 2014, Plaintiff, like every other
awards retailer, including Defendants, displayed the year horizontally on its neck ribbons. This
year, however, Defendants released a new neck ribbon with the year displayed vertically, as
shown below. Defendants immediately copied Plaintiffs protected neck ribbon.
{F1617946.9 )
42
{F1617946.9 1
43
RIBBON CLOSE UP
{F1617946.9}
44
&
V
%
{F1617946.9 [
45
74. The above are just several examples of Defendants' practice of intentionally copying
Plaintiffs protected awards, inserts, and ribbons, and manufacturing and offering for sale such
copies in violation of Plaintiff s exclusive rights under the copyright law. Attached as Exhibit Q
are more examples of Plaintiff s awards, inserts, and ribbons shown side-by-side with
Defendants' infringing awards, inserts, and neck ribbons.
2.
Defendants have offered for sale and sold product lines that reflect a selection,
{F1617946.9I
46
VH
sAti'
u,4fSk
1
%
"i*
77. Defendants have selected the same activities for their 3D laser crystal product line as
Plaintiff. Moreover, Defendants use an image for each activity that is substantially similar to the
image used by Plaintiff for the same activity. Thus, this copying represents the exact same
selection, coordination and arrangement as on Plaintiffs website and is conclusive evidence of
willful infringement.
78. Defendants also have copied Plaintiffs crystal awards. Plaintiffs crystal awards
come in various shapes, all of which were selected, coordinated, and arranged by Plaintiff to
(F1617946.9!
47
create the crystal product line. As shown below, ofthe thousands of shapes available,
Defendants offer for sale a crystal product line that uses the same shapes as Plaintiffs line:
Plaintiffs Copyrighted Line
^^^
'"HI
(FI6I7946.9)
48
<&.
*%
/L
ifii
{F16I7946.9 }
49
79. These are just some examples ofthe substantial similarity resulting from
Defendants' willful copying of Plaintiff s selection, coordination, and arrangement in its product
lines. Attached as Exhibit R are more examples of Plaintiff s protected product lines shown
side-by-side with Defendants' infringing product lines.
3.
80. The overall look and feel of Defendants' website is substantially similar to that of
Plaintiffs website. Moreover, Defendants' website incorporates the elements that make up
Plaintiffs Website Trade Dress, thereby making consumer confusion likely. Attached as Exhibit
S hereto are several pages from Plaintiffs website side-by-side with the equivalent pages from
Defendants' website.
81. As shown in Exhibit S, the similarities between the websites can been seen on many
pages, including the homepages, the pages showing a category of awards (such as trophies or
medals), the individual product pages, the "About Us" pages, the catalog order form pages, the
policy pages, and the pages showing the various activities and occasions for which awards can be
purchased. For example, just as Plaintiff uses two search boxes in on its website (one at the top
right and the other below the first at the left margin), Defendants use two search boxes on their
website (one at the top right and the other below the first on the left.) There is no need for a
website to have two search boxes on the home page and few other websites have two.
Defendants appear to have used two search boxes simply because they slavishly copy whatever
Plaintiff does.
82. Similarly, Defendants' home page shows its main categories of products in four
columns, just like Plaintiffs home page. And when the customer clicks on one of those product
categories on either website, the customer is taken to a page that shows the individual products in
the category in a nearly identical four-column array, and both websites have links to product
subcategories in the left margin. The similarities are so close that, if the customer has both web
{F1617946.9 |
50
pages open at the same time, it is hard to tell which one the customer is looking at any given
moment.
83. There are numerous other similarities in the text on the website. For example,
Plaintiffs history on its website has a photograph of its facility and says, "Crown Awards is
America's leading supplier of awards for corporate businesses and youth sports. Founded by
Chuck Weisenfeld in 1978, Crown started as from a single store front operation in Brooklyn,
New York and blossomed into the largest retailer of awards in the country... . Crown started its
business as a small trophy shop and has grown to our current 250,000 square foot facility in
Hawthorne, New York." Copying that, Defendants include a photograph of their facility and the
following statements, "From our humble beginnings as a small trophy shop in Queens, NY to
one ofthe largest trophy & award suppliers in the world.... 2011: Trophy Depot expands and
Moves again to Edgewood, NY to a beautiful 51,000 sq. ft. facility, with a staff of over 120
people."
84. These similarities between the parties' respective websites are the result of
Defendants' intentional copying of Plaintiff s website.
4.
85. Plaintiffs Trophy Builder and Engraving Engine are unique to Plaintiff. While
many of Plaintiffs competitors also offer customization options, none, except Defendants,
present and display their customization programs using the same visual design for the user
interface. The unique look and feel ofthe Trophy Builder and Engraving Engine is the result of
Plaintiffs investment of time and resources into their development. A team of employees with
knowledge of website and database development determined what type of user interfaces would
provide the customer with an easy and positive experience customizing awards on Plaintiffs
website, and then that team set out to create such designs.
86. Defendants, like Plaintiff, provide customers the option of building their own awards
and engraving personalized text onto awards. The overall look and feel of Defendants' awards
51
builder and engraving programs is substantially similar to that of Plaintiff s Trophy Builder and
Engraving Engine, respectively. Attached as Exhibit T are pages showing Plaintiffs Trophy
Builder and Engraving Engine side-by-side with Defendants' infringing customization user
interface. As shown in this exhibit, a customer who uses Defendants' customization program
encounters the same user interface as a customer who uses Plaintiffs Trophy Builder and
Engraving Engine.
87. Defendants intentionally copied Plaintiffs Trophy Builder and Engraving Engine.
Such copying allowed Defendants to freeload off of Plaintiff by saving time, money, and effort
compared with Defendants' 2014 and 2015 price breaks. As shown in this exhibit, Defendants
display price breaks and prices per unit within each break that are virtually identical to the
designs created by Plaintiff. Thus, Defendants' selection, coordination, and arrangement of its
price breaks and prices, as well as the overall look and feel of their presentation, are substantially
similar to the look and feel of Plaintiff s displays.
Plaintiffs price breaks and the overall look and feel of Plaintiff s presentation of its pricing
information. As evidence of such intentional copying, on January 15, 2015, Plaintiff updated its
price breaks, and shortly thereafter, Defendants came out with the same revised price breaks.
See Ex. U (2015 price breaks).
6.
V are images showing Plaintiffs presentation packaging and Defendants' presentation packaging
side-by-side. As shown in these images, Defendants' packaging incorporates all ofthe elements
{F1617946.9 |
52
of Plaintiffs Packaging Trade Dressboth rectangular boxes are royal blue with a satin interior,
and the companies' logos are printed in gold on both.
91. Such similarities are the result of a deliberate attempt by Defendants to attract
Shipping" on engraved trophies and medals if such awards are ordered before 4:00 P.M. on
fine-print text that states that same-day shipping is not available in April, May, June, or October.
See screenshot of Defendants' website showing shipping policies, attached hereto as Exhibit X.
Defendants do not remove the same-day shipping advertisement from their website during those
months. Attached as Exhibit Y hereto is a screenshot from Defendants' website showing the
same-day shipping advertisement prominently featured on their website in June, one ofthe
months in which same-day shipping is not offered. Thus, the "Same-Day Shipping" claim is
blatantly false.
93. Plaintiff has an interest in making sure that consumers are not deceived as to
94. Plaintiff has invested heavily in being able to offer same-day shipping to its
customers. Efforts taken by Plaintiff include building a large warehouse, carrying massive
inventories, and hiring many employees to fulfill orders, all of which have required exerting
significant time and resources.
95. The only reason that Defendants claim to offer same-day shipping is that Plaintiff
offers it. Defendants added the same-day shipping advertisement to their site immediately after
{FI617946.9)
53
attempt to misrepresent their ability to provide same-day shipping to compete unfairly with
Plaintiff.
to their site on the promise of same-day shipping when they know that they are not able to
deliver on such a promise. In fact, Defendants even allow customers to place orders for
thousands of pieces of obscure items, promising same-day shipping on such obscure items,
despite having knowledge that they could not possibly provide same-day shipping on these
products because they do not have them in stock. On information and belief, Defendants call
such customers the next day informing them that the promised same-day shipping cannot be
honored. Such bait-and-switch tactics are misleading to consumers.
8.
keyword on Google's search engine. As a result, a Google search for "Crown Awards" yields a
paid advertisement for Trophy Depot. See Exhibit Z attached hereto, showing paid
advertisement for Trophy Depot resulting from Google search for "Crown Awards."
98. On information and belief, Defendants have purchased the "Crown Awards"
keyword to confuse and deceive consumers about the affiliation, connection, or association
99. The conduct described in the Complaint amounts to copying of every aspect of
Plaintiffs business. Defendants have copied entire lines of products, individual product and
component designs, the selection, coordination, and arrangement of products on the website, the
display of pricing ofthe products, and the look and feel ofthe website pages that allow the
products to be designed (Trophy Builder) and customized (Engraving Engine). Indeed, a
(F1617946.9)
54
customer cannot order an award from Defendants without encountering an infringing aspect of
Defendants' business. As a result, the only way for these recidivist Defendants to stop their
infringing conduct is to redesign their entire business, including their website, from scratch, and
stop selling all their infringing products.
FIRST CLAIM FOR RELIEF
100. Plaintiff repeats and incorporates herein by reference each ofthe foregoing
allegations.
101. Plaintiffs awards, product lines, catalog, website, and Trophy Builder and
Engraving Engine programs (collectively, the "Copyrighted Works") are original and creative
works of Plaintiff. Plaintiff is the owner of all right, title, and interest in and to the copyright in
the Copyrighted Works and own the copyrights registrations for the same.
Plaintiffs website, and reflects the same selection, coordination and arrangement of elements as
Plaintiffs website, including the Trophy Builder and Engraving Engine.
(FI617946.9 1
55
105. Defendants thereby have violated and, on information and belief, continue to
violate, Plaintiffs exclusive rights in the Copyrighted Works under Section 106 ofthe Copyright
Act, 17 U.S.C. 106, in violation of Section 501 ofthe Copyright Act, 17 U.S.C. 501.
106. On information and belief, Defendants' aforesaid conduct has been undertaken
108. Defendants' copyright infringement has caused, and unless enjoined by this Court,
will continue to cause, Plaintiff to sustain irreparable damage, loss, and injury, for which
Plaintiff has no adequate remedy at law.
SECOND CLAIM FOR RELIEF:
TRADE DRESS INFRINGEMENT
109. Plaintiff repeats and incorporates herein by reference each ofthe foregoing
allegations.
110. Plaintiffs Website Trade Dress is used in commerce, is non-functional, and is
inherently distinctive or has acquired secondary meaning as the indicator of Plaintiff as the
exclusive source of products containing or incorporating such design.
111. Defendants have adopted the Website Trade Dress and have, without Plaintiffs
authorization or consent, used the Website Trade Dress or designs that are confusingly similar
thereto on Defendants' own website.
inherently distinctive or has acquired secondary meaning as the indicator of Plaintiff as the
exclusive source of products containing or incorporating such design.
113. Defendants have adopted the Packaging Trade Dress and have, without Plaintiffs
authorization or consent, used the Packaging Trade Dress or designs that are confusingly similar
thereto on Defendants' own packaging.
{F1617946.9)
56
114. Defendants' conduct is likely to cause confusion, cause mistake, or deceive as to the
affiliation, connection, or association between Defendants and Plaintiff, or as to Plaintiffs
continue to cause, Plaintiff to sustain irreparable damage, loss, and injury, for which Plaintiff has
no adequate remedy at law.
THIRD CLAIM FOR RELIEF:
118. Plaintiff repeats and incorporates herein by reference each ofthe foregoing
allegations.
119. Over many years of extensive use in connection with the sale of awards, Plaintiffs
federally registered CROWN AWARDS mark has become well-known in the industry
nationwide. Plaintiff has established a strong reputation and substantial goodwill by reason of its
success and reputation.
120. Defendants' actions described above, including its use of CROWN AWARDS as a
Google keyword, are likely to cause confusion and mistake and to deceive consumers into
believing that Defendants' goods and services are provided, authorized, endorsed, or sponsored
by Plaintiff, thereby damaging Plaintiffs reputation, goodwill, and sales.
121. Defendants' conduct described herein is willful and violates Section 32(1) ofthe
Lanham Act, 15 U.S.C. 1114(1).
122. Defendants' aforesaid conduct has caused, and unless enjoined by this Court, will
continue to cause, Plaintiff to sustain irreparable damage, loss, and injury, for which Plaintiff has
no adequate remedy at law.
(F1617946.9)
57
123. Plaintiff repeats and incorporates herein by reference each ofthe foregoing
allegations.
124. Defendants advertise on their website that they offer "Same-day Shipping," but they
in fact do not offer same-day shipping at least four months out ofthe year.
125. Defendants' representation all year round that they offer "Same-day Shipping" is a
false and misleading description of fact and a false and misleading representation of facts in
commercial advertising or promotion that misrepresents the nature, characteristics, or qualities of
Defendants' products, services, and commercial activities.
126. On information and belief, Defendants made this false and misleading
sold as a result of such deceptive advertising in interstate commerce and into this district.
128. Defendants' conduct described herein is willful and violates Section 43(a)(1)(B) of
the Lanham Act, 15 U.S.C. 1125(a)(1)(B).
129. Defendants' aforesaid conduct has caused, and unless enjoined by this Court, will
continue to cause, Plaintiff to sustain irreparable damage, loss, and injury, for which Plaintiff has
no adequate remedy at law.
130. Defendants' conduct as described herein is also harming the public.
FIFTH CLAIM FOR RELIEF:
COMMON LAW TRADE DRESS INFRINGEMENT
131. Plaintiff repeats and incorporates herein by reference each ofthe foregoing
allegations.
132. Defendants' aforesaid conduct constitutes common law trade dress infringement
under the common law ofthe State of New York.
{F1617946.9J
58
133. Defendants' aforesaid conduct of common law trade dress infringement has caused,
and unless enjoined by this Court, will continue to cause, Plaintiff to sustain irreparable damage,
loss, and injury, for which Plaintiff has no adequate remedy at law.
SIXTH CLAIM FOR RELIEF:
COMMON LAW UNFAIR COMPETITION
134. Plaintiff repeats and incorporates herein by reference each ofthe foregoing
allegations.
135. Defendants' aforesaid conduct constitutes common law unfair competition with
Plaintiff under the common law ofthe State of New York.
136. Defendants' aforesaid conduct of common law unfair competition has caused, and
unless enjoined by this Court, will continue to cause, Plaintiff to sustain irreparable damage, loss,
and injury, for which Plaintiff has no adequate remedy at law.
SEVENTH CLAIM FOR RELIEF:
DECEPTIVE TRADE PRACTICES
137. Plaintiff repeats and incorporates herein by reference each ofthe foregoing
allegations.
138. By reason ofthe acts set forth above, Defendants have been and are engaged in
deceptive acts or practices in the conduct of a business, trade, or commerce, in violation of
Section 349 ofthe New York General Business Law.
139. On information and belief, through such deceptive acts, Defendants have engaged
in consumer-oriented conduct that has affected the public interest of New York and has resulted
in injury to consumers and harm to the public in the state of New York.
140. On information and belief, Defendants' conduct is willful and in knowing disregard
of Plaintiff s rights.
(F1617946.9)
59
141. Defendants' aforesaid conduct has caused, and unless enjoined by this Court, will
continue to cause, Plaintiff to sustain irreparable damage, loss, and injury, for which Plaintiff has
no adequate remedy at law.
(a)
website and customization programs of Plaintiff or that copy Plaintiffs selection, arrangement,
and coordination of products, displays and other elements;
(b)
imitating, copying, or making unauthorized use ofthe Website Trade Dress and
Packaging Trade Dress, respectively, or any other design that is confusingly similar to the
Website Trade Dress or Packaging Trade Dress;
(c)
using any false designation of origin or false description or performing any act
that can or is likely to lead members ofthe trade or public to believe that Defendants are
associated with Plaintiff or that any product manufactured, distributed, advertised, displayed,
promoted, offered for sale, sold, imported, or exported by Defendants is in any manner
associated or connected with Plaintiff, or is authorized, licensed, sponsored, or otherwise
approved by Plaintiff;
(F1617946.9 )
60
(d)
infringing the CROWN AWARDS mark, including but not limited to use as a
(e)
thereof, or any name or mark that is confusingly similar to the CROWN AWARDS mark, on or
in connection with Defendants' goods or services;
(f)
using any false or misleading representations of fact, or performing any act, which
can, or is likely to, lead members ofthe trade or public to hold false beliefs concerning the
nature, qualities, or characteristics of Defendants' goods or services;
(g)
performing any ofthe activities referred to in subparagraphs (a) through (g) above or taking any
action that contributes to any ofthe activities referred to in subparagraphs (a) through (g) above.
2. Directing that Defendants turn over to Plaintiff for impoundment and eventual
destruction or other disposition, without compensation to Defendants, all materials in their
possession or control that violate the provisions of paragraphs l(a)-(h) above, along with all
4. Directing that Defendants, pursuant to 15 U.S.C. 1116(a), file with the Court and
serve upon Plaintiff, within thirty (30) days ofthe entry of injunction prayed for herein, a written
report under oath or affirmed under penalty of perjury setting forth in detail the form and manner
in which it has complied with the permanent injunction.
IF1617946.9 )
61
9. That Plaintiff be awarded such other and further relief as the Court may deem just and
proper.
AjttLA^iUL,JUL.
By_
Lichard Lehv
Emily Weiss
866 United Nations Plaza
eweiss@frosszelnick.com
Attorneysfor Plaintiff
{F1617946.9)
62
EXHIBIT A
5K 2" 3D MEDALS
SPORTSMANSHIP
*
SPORTSiViMSHIP
jf+*%i
ERFORME
f
t
RIBBON CLOSE UP
RIBBON CLOSE UP
RIBBON CLOSE UP
RIBBON CLOSE UP
LJBLJ
l t'.n
'!11
n'.iid
*y-Y
STAR PERFORMER
3D LASER CRYSTAL
P & \ %l "W W% JH I
ill! 1 HIIS 1
CLEAR TROPHIES
HOLDS 2" INSERT
W,1!
MtAi
ft.-/
EXHIBIT B
Certificate ofRegistraUon
sS*.
VA 1-850-985
/^Io^uLJk. f-^fajj-
Effective date of
registration:
February 4,20J3
Completion/Publication
Author
An"rCre"e* PhMW<*T=ch^dfawlng
Work made for hire: Yes
Domiciled in: United States
Copyright claimant
Certification
Y']^,umedStatcs
Correspondence: Yes
Page 1of 1
Elyse Weisenfeld
FORM CA
FORM CA RECEIVED
EXAMINED BY
FOR
COPYRIGHT
OFFICE
USE
ONLY
CORRESPONDENCE
BASIC REGISTRATION
YES Q NO
DO NOTWRITE ABOVE THIS LINE. IFYOU NEED MORE SPACE, USE A SEPARATE CONTINUATION SHEET.
Continuation of: Q Part B or Q Part C
Em
coM
Deposit Account: Ifthe registration fee is to be charged to a Deposit Account established in the Copyright Office, give name and numberof Account.
Name
Account Number _
Certification* I, the undersigned, hereby certify that 1 am the: (Check only one)
author
Downer of exclusive right(s)
other copyright claimant Qauly authorized agent of
of the work identified in this applicationand that the statements made by me in this applicationare conect to the best of my knowledge.
Typed or printed name
g(z.\to
AtopR-gyv^
DateV
jp\2.\ JEfrfe.
Handwritten signature
Certificate
will be
mailed in
window
eu-v|4e
\ajvs6*vjf&ue>
Number/Street/Apt
1. Application form
envelope
to this
address:
City/SlaleCIP T
Library ot Congress
Copyright OMice
=fc
*17 L/SC506(e): Any parsonwhoknowingly makesatalse representational a material (aclinthe applicalion lorcopyrighl registralion provided forbysection409,or in anywritten statementtiledinconnection
withthe application, shall be lined not more than $2,500
Form CA-Full
Rev 07/2006
Print: 07/2006,000
/,
Certificate of Registration
This Certificate issued under the seal ofthe Copyright
ri>-l?*
/TicuuL A- i^jtt*
1870
***jL
Registration Number
VA 1-815-363
Effective date of
registration:
February 17,2012
Title
Title of Work: Insert Medals
Previous or Alternative Title: Diamond Cut, Gold Shooting Star, Black Shooting Star, Galaxy Star, 2012
double action
Completion/Publication
Year of Completion: 2011
Author
Yes
United States
Copyright claimant
Copyright Claimant: Crown Awards, Inc.
9 Skyline Drive, Hawthorne, NY, 10532, United States
Certification
Name: Elyse Weisenfeld
Correspondence:
Yes
Page 1 of 1
Registration #: VA0001815363
Service Request #: 1-726768699
Elyse Weisenfeld
9 Skyline Drive
Hawthorne, NY 10532 United States
Certificate of Registration
This Certificate issued under the seal ofthe Copyright
i**.
^(Sfeo
1870
Registration Number:
VA 1-639-384
Effective date of
registration:
March 18.2008
Title
Title of Work: Insert Medals
Previous or Alternative Title: 2-1/2" star insert knock out, 2-1/2" Venetian insert, 3" star insert knock out
2008 insert
Natu re of Work:
'
Medals
Completion/Publication
Yearof Completion: 2007
Author
Domiciled in:
Yes
United States
Copyright claimant
CopyrightClaimant: Crown Awards, Inc.
Certification
Name: Elyse Weisenfeld
Date: March 14,2008
Correspondence: Yes
Page 1of I
IPN#:
Registration*:
VA0001639384
j
I
i
|
I
Certificate of Registration
This Certificate issued under theseal ofthe Copyright
t>-*.
Registration Number
VA 1-849-588
TlLuL A *hk
Effective date of
A*JGt
registration:
February 4,2013
Title
Title of Work: 3" Double Action Medals
Completion/Publication
Year of Completion:
Date of 1st Publication:
2012
January 30, 2013
Author
Author:
Author Created:
Work made for hire:
Domiciled in:
sculpture
Yes
United States
Copyright claimant
Copyright Claimant:
Certification
Name:
Elyse Weisenfeld
Page 1 of 1
Certificate of Registration
O-STAT^
f^.FormVA
c- - iifcwk~r*t.if:M..i *.*.
VA 1 329789
"
rflNIIIHiHII
^dSfeo
Month
Pay
tui
DO NOT WRITE ABOVE WIS LINE IF YOU NEED MORE! SPACE, USE ASEPARATE CONTINUATION SHEET.
TMeofThBWortt*
NAT0REOFTHtSWORKTSfthMto
Double Action Medals
Medals
baseball, dance, gym, usa hockey, usa back/field, soccer, winged foot, karate, wrestling, winner, 2005
SXlaS.^^
IfpubhibedmapezdicolaracnilgLve VolumeY
Nanbcf
NAME OF AUTHOR
Crown Awards,Inc.
Wat U>ueoatnbullo010 the work a
"mrknultforluren
0Yea
NOTE
Under tha taw,
the'author* at
"wort made
for hire" It
generally tha
employer, not
lOomaMtB
D 2-DimoTOonalBttwD*
D Reproduction ofwork ofart
onfQnieaof .
USA
ilia employee
wortthatwas
"made lorhire"
*2<&!*!tate*htt
orDomicile
Nameof Country
ONo
(H* Instruc
DPhotograph
DJewelry design
Q Y
DNo
*Ye$,-eaedatatod
D technical drawing
D Architectural work
_______
.. 77^
Dates of Birth and Death
Year Bom T
(or other
pereon tor
WailhaojitribaUofllolhewofta
aa 'Author* ol
Pseudonymous?
D Text
A~flNar*
wnieeofo
the span
I<%
provfdaa, gin \J
the employer
waa prepared)
OnPBgoT
Issue Date Y
Nemo 01Country
Anoayrnous?
Qg/Qluno*
OYes
DNo
Pseudonymous*
I Domiciled 10
-______
leave me
Year Died T
D Yea
,
DYh
ONo
_i.~
V..t?.*mm<.?*!*'
otthosequoaaorala
*Voa,"aaesataaKl
ONo
tftSBwoorts
D 3-Dirnenstona] sculpture
Q Map
O Technical drawing
D 2-Dimensional artwork
D Photograph
D Jewelry design
O Architectural work
3
4
Seehattierone
OafomeomrJetino
thrseptoa
C"*M1WK.
2004
TNaWOrmetlen
rnuetbeghnm
Vaar InaOeaaaa.
QText
USA
Crown Awards,Ire
9 Skytine Drive
Hawthorne, NY 10532
Transfer If tha clamantta)named hen mspace 4.(ore) duTerent from tbc authors) rumed mspace 2. n>v. a
erafslateraenUfrOTtUdaiau,lMobuB^
Vaai
__L
mm
rmrtm
TWO DEPOSITS RECEIVED
. *
FUNDS RECEIVED
-Sepitherennet line S
PBtot_i_^rjaBas
FOR
COPYRIGHT
OFFICE
USE
ONLY
DO NOT WRITE ABOVE THIS LINE. IF YOU NEED MORE SPACE, USE ASEPAHATE CONTJNUATON SHEET.
PREVIOUS REGISTRATION Has registration for dm work, or lot anenlier version ofriiswrA already beeaoiadeu
OYea QNo If your answeru"Yes," why uanother registration being sought? (Check apuiopimle box )
a. O This isthe firtt published edition ofawork pevic^y register^ in unpublisr^ term
b. O This u Ike first appucahoo aubmtned byuna author as copyn|>t dainuaL
c O Tresis achanted version ofdie work, asshown byspate* ontins appbcaima
Year ofRegistration T
a, Preedstsag Material Irkatilyanypreejuiiiig work or works that this work ubased oner incorporates T
SeehstrucDons
before cornptetrng
this a
DEPOSIT ACCOUNT Ifthe regislrabon fee isto be charged lo aDeposit Accountotabtahed in it* &HmeJOffii^
WtmtAccount Number
NaiiitfAddresa/AptrTJiyia__'T
ElyseWeisenfeld
9 SkylineDrive
Hawthorne,NY 10532
Fax number
(914)347-7700x121
Email elyse@crownawards.com
CERTIFICATION* I,Aeiiridersigiied,iuMetryoerrifythaIamthe
O author
checkonly one
O othercopyright claimant
O ownerof exduaivenghtfs)
rf
_
. , 'Crown
Awards, Inc.
B euthonxed agent of
m __-
Mnol*Anforee*weopyrtgMcsrners.or
envelops
tothlB
address:
08730/05
(X)T
Hand
Certificate
will be
mailed In
window
Date
Namef
ElyseWeisenfeld
Crown Awards, Inc.
Number/SftBsl/AptT
9 Skyline Drive
QffiD__B_BSQEBg_g_g_L_
H[!^^Xt_QL^QLraQj|^^_tnBB
^fcejT
^^
iNcwaamdabletilrotaelnchartormorBy __"__!_
a malarial
mggm.
ssgw
Otv/BlalaSDPY
Hawthorne, NY 10532
rtance Avenue, 8
,OC200
US QorarrmwtPrintingOlta. 20o3-*9fr6OS/60,029
Certificate of Registration
Form VA
ItrjraWeAeJdMVtaalArti
uwrrtp mm romictrrofhci
UK-
VAU676-949
Ld^QM^>
870-
~f v
NATOMOfTHBWORKY
TWeofTldiWorkV
Medals
OaPssj-T
bee* Dats Y
HoDbUaaedUapertodlcalceMrUlgWe: Val
NAMK OF AUTHOR
Year Ben
Year Died
NOTE
Under the at*,
JDo-fclledtn J__
the'eutrior" ol
a*ewrka<eate
Aaoarjnaeenj?
On|ctti*ef
fi Yea
far Mrs'Is
Generally the
employer, not
the asaplejee
(seehvalruo-
D Reprodietsooorwodtorarl
tlona). Porany
Dleweliydealjii
DYee OHo
oftuawejanelonsai
D Yea
"*>'***
D He
DTrxhnscaldrawlnj
OTstt
O Ardiuscturelwork
partof this
went ttial was
made tor hirecheek
Yea" in
eaTsa-ini
the
apace
DsttirfHrbs-lDBita
Yew Bora
'NssMOf Asflwr T
|"%
Year Died
rtded. etve 1/
Ma 1
(or other
ae'Author" of
that part, and
lasrbJre-T
DYee
NamecfQouney
QfjfOtbtaaof
iDooscsMia
OHo
Have the
3
4
WasTbaaAaater^CcaMbirrJrjaastliaWorlr.
0 Ike work a
person tor
where the work
Yes
U No
tUBtyam*
DYea
DHo
"Weeed "
NsfcntfAattllMrslsIp Q_sevcpriaabc(eiXSelnsrtnrCi10faB
D J-DtaiiaJotjalanilptara
2-Difrawrlonal artwork
DMap
D Photograph
DTedmtealdrjrwmf
D Tent
O Bspradirstmofworkctfait
D Jewelry design
D Architectural wo*
2l
tmSSP""*
200s
M^gkk
u*^^^^^*^ __
SSSSSr D otwisW
'eer aaaSeeaSh
SaoeaMpel
COPYeUGOTOAIMANT(S)ftanandaddMesit^
__o_ar
aptacrgrreailnaaaeelT
Grown Awards, Inc.
9 Skyline Drive
Hawthorne. NY 10532
Transfer If da cbfaaaaa(s) aaned basefaapace 4 la(are) differe torn theaafeafe}
brkfataierjSBoJerto-BMdainaaa^dcMa^
fctepacelgivea
FUNDS RECEIVED
yj
EXAMINED BY
CHECKED
FORMVA
FOR
COPYRIGHT
OFFICE
USE
ONLY
lESPOrtoENCE
CORRESI
Yes
YaartfittakSmlloaY
DKRTVATrVKWOREORCOMrTIATIONCrOTrJotebcA
a.Flreeils(ss(ablcrasi losnrlfyastypnetlstiiigworkcTwr^lbjiiliU
tea apace.
DEHMITACCOUNT ITtaeieajUrataieeiitoblcsse^taarjop^
NaaaaT
COHUanVONDENCBOtreaaisB^adita
...
BysBWeiatnfeld
9 SkylineDrive
Hawthorne, MY 10532
fceaeodsandde^taloiimnwibcr
E-aii
(914)347-7700x121
Faxnumber
dyK@aownawanb.com
D author
checkonly one^
J Downer ofexduarnrie^(a)
1 rfatihSnrteod atentof,
Awardi,lDc.
ByseWt
_. 08730705
CsrUflcsto
win be
r^rwWebenfeld J
maDsdln
Otwn Awards, 1
snvslops
tenia
eddraaa:
bajiyweprSas^Secoo
IB
\A
9 Skyline Drive
OWy|r^fWi#jDH^^aWTyrsB^F"
s WrPOM WasaaaWB
aattlsMati
VbVPMIHbW
ObaVHaOPv
Hawthorne, NY 10532
*f7UJeUa.|*H(e^a%ypitVnsin
WlBl ttf aVtAtaatfOn, leefl bf l%at4 letl HIObV tMH sP,800.
lMaeth|1>l|ttstl^tellWlW|^
ywlOHiariartHTwiaaaMlrioontcloii
Certificate of Registration
,**_^to
FormVA
Pore Work*/theVassalArte
UNITEOSTAriSCOrYRICrlTOfnCf
__..
"
VA 1-349-852
OjlM &juL&
Month
* Day
v-^ /
Medals
rrsnSs^
BpeiiUabediaaiieticdlealceaerlalgrfe: VeknaeT
Maaebce-T
OaPaeseT
NAMEOF AUTHOR
NOTE
WuTbJaiAsriicir'iCoobtntlMtotlieWoTk
ORfat_a<iof
OYaa
iDnrictledia
ONo
the 'author ol
a "work made
tor hire-la
USA
Anoejiaoei?
Pscudonyniouir
DYse
ONo
'Yei.'eeeaecUed
InelnaiSane.
generally the
employer, not
the employe*
(eeekiMnn-
tlona). Perany
G) 3-Wmeajiotial sculpture
QMap
OTeeArical drawing
D MJitrawioMl artwork
D Reduction ofwork ofart
OPhotograph
DJewelry design
OText
Q Architectural work
paitetthia
work thai was
in* apace
Nanxof Asthor T
provided, phre I
Year Died
the employer
(or other
person lor
Hreckaaaatalba-ainrr
O Yea
waa prepared)
ae Author* of
WasT1aUAerti>or'Coau>fl-tl<mtotrMWcrt
Qtafcitizenof
I. Domiciled in
ONo
Arjino_r
PanodoeyraouiT
Q Yea
ONo
^sVmdoMod
leave the
i.
O 3-Dimerulonal acniptnre
2-Din_r_ic_d artwork
Q Map
Q Photograph
O Technical drawing
DJewelry design
O ArcMtectaral work
2005
OText
{bstesadrtatkaellfatMalcM^
-2Q_ y__Q6_
, Year an fan* t^ss^rsfe
MA IMbM aMaHWlaVL
CO*YRI^CLAlMAlTO<S)r<sji^
API
authorgivenia apace 2.
Orown Award*,Inc.
!i!_g__l
I TVW) DEPOSITS RECEIVED
9 Skyline Drive
Hswthoroe, NY 10532
Tirn*ferlfizicWniai*e)r*ir*
bri*fueMar**iofrjewe*cfcuiieii<s)
MORE ON BACK
'Crt^aliw>aab>epaeftjrtfw
>8eeoelaMlMtMeena.
8i to tornattaw*.
II
FUNDS RECEIVED
oowrrtMrritaBhi
Page tot-
FORMVA
CHECKED BY
FOR
CORRESPONDENCE
COPYRIGHT
OFFICE
USE
ONLY
Yes
DO NOT WRITE ABOVE THIS LINE. IF YOU NEED MORE SPACE, USE ASEPARATE CONTINUATION SHEET.
PREVIOUS REGISTRATION Hal ttjUirsrioa for this wir*iforanearrtaveniontflhbwoifc
EoYes OW tfyoiireiiswri*"Yea,"wkybaer*JkBrten^^
a. 8f ThisuWru*pubbjhlrfdonrf*workrrow
b. D Thisis theBra ^ptiotfaKmbnltted bythis eatoras copyright claimant.
c. DThisfeadnangedver4oeoftlttwonXusr>ownbysp*ee6catt^
Ifyourar*wis-YeCejve:rrevliiMRee*r^
Year ofRegistration T
SeelnstrueSons
baron eHnpkrfrg
Una
b. Material Added toTali Work ffive abrief, general slaterrentofuwsnaterial that r been added to this wcrk and in which c^
Nmme
Account Number
.a
CORRESPONDENCE Give name and address to which correrpondence about this applicalion should be sent. Naoe/Addnss/ADtX^/SolrVZIP
"b
ElyseWeisenfeld
9 Skyline Drive
Hawthorne, NY 10532
Aeodeerldaye>iieteler^ore)iiurnr)et
(914)347-7700x121
Fax number
Email elyse@crownawards.com
CERTIFICATION* I,tlvtiinaripied,hefetryce<tirybSotIaiiithe
author
{!
O othercopyrightclaimant
O owner of exduniverightfa)
^.uhSorieedag^ofNansolante
^^AWa_^l
orotteroopyrtuhl darmanL ororo otc*jslifat(*)A
Byse Weisenfeld
CsrlHicata
willba
mailsdln
window
snvalopa
to this
Data
01/30/06
rilysVweisenfeld
Crown Awards, Inc.
NimberStreeMptT
a.
ralnch*c*oimorwy
orfepgaHejo
9 SkylineDrive
fCbp)stjf*
SSgrese
CItyfSuia/ZrPT
HavYthoroe,NY 10532
DtoKni1n0y*fMKM
smss"
SSmT
flSJrepreeenWofflHaneTO
Certificate of Registration
STAT^
17[
J870
VA 1-850-398
I A- hjiojtx
Effective date of
(XUc^,
registration:
February 4, 2013
Title
Title of Work: 2" 3D PiepastMedals
Previous or Alternative Title: Rugby, grand piano, gold, silver, bronze, mud racing
Completion/Publication
Year of Completion:
2012
Author
Yes
United Slates
Copyright claimant
Copyright Claimant: Crown Awards, Inc.
Certification
Name: Elyse Weisenfeld
Correspondence:
Yes
Page 1 of 1
Registration #: VA0001850398
Service Requests 1-887252365
Elyse Weisenfeld
9 Skyline Drive
Hawthorne, NY 10532 United States
Certificate ofRegistration
This Certificate issued under the seal ofthe Copyright
vJIlZ**.
7homc^A-
1870
Registration Number
VA 1-892-651
t^Mo^Jx
Effective date of
registration:
Title
Title of Work: 2" 3D Diecast Medals
Previous or Alternative Title: Microphone, 4th Place, Skiing, Hip Hop, Road Bike, Bookworm, T-Ball and
Tennis 2" 3D Diecast Medals
Completion/Publication
Year of Completion: 2013
Author
Yes
United States
Domiciled in:
United States
Copyright claimant
Copyright Claimant: CrownAwards, Inc.
9 Skyline Drive, Hawthorne
Certification
Name:
Erin Andrews
Page 1 of 1
Registration#: VAOOOl892651
Service Request #: 1-1236737501
Elyse Weisenfeld
9 Skyline Drive
Hawthorne, NY 10532
Certificate of Registration
This Certificate issued under the seal ofthe Copyright
Office in accordance with title 17, United States Code,
attests that registration has been made for the work
identified below. The information on this certificate has
1%>mL a ^
Registration Number
VA 1-815-364
Ljfe
Effective date of
registration:
February 17,2012
Title
Title of Work: 2" 3D Diecast Medals
Previous or Alternative Title: cheerpyramid, large mouth bass, starperformer, together we can, 5k,You're
a star, 1 year and 5 year
Completion/Publication
Year of Completion:
Date of 1st Publication:
2011
January 28, 2012
Author
Author:
Author Created:
Work made for hire:
Domiciled in:
sculpture
Yes
United States
Copyright claimant
Copyright Claimant:
Certification
Name: Elyse Weisenfeld
Correspondence:
Yes
Page 1 of 1
Certificate of Registration
JX2&<u
FormVA
IWaWorerftaeVisual Arte
VAU676-956 "
LM^Mo
( P 2flg
rUTOTIOFTHBWOtUn
Medals
a^rarloaBt sWAJtCflallhvUtaat
tfp*U*bedieaperiodiedorBtaI|r* VetaaaeT
NAMKOFAOTHOB T
Year Born T
tee Mm* la
generally me
eraptoyef.not
Itia amploree
(eamalnjcWone). for any
NeatnsaTAlUaWi^ Oa>*apjiep^
a 3-Dinw_iot_Iecolptt-e
2-Dimeruikmal artwork
BMattme
era Diet aria
iter Mm*
oftece *Yer in-
heodorarranus?
USA.
No
Year Died T
Qgjatheeof
OYas
tf|Mtf trtWaVVt
BWeudWol
a"a-rkaaade
Andior'aNidoiiBjiij wDonddto
rSKotOourey
later Mr*"T
NOTE
OaFefsiT
lew Date
OYaa DNo
lteiaraerletter
Yes
Vac'seedseaasd
D No
Ireanassone.
DMap
DTechnicaldxiwte|
D Photograph
Text
D Jewelry design
D Architectural week
OttotffiMfc tad DMtt
NswaeerAnther
Year Born T
YeerDiedT
Ml
let otter
a mark a
Was Ikes
aeeaonre*
at Isr hirer
ULDoasiefledia
DNo
OBJOteaof
DYea
ee'Autnof of
A^vgNa^rBaJitjreTi^saaicile
AraarytrausT
Ye.
dno xzxzzs:
heeskser-oaaT
DYea
D No
^aa,-aaar>taalid
leave the
Text
D RerjroductJouofworkofert
Jewelrydesign
D ArdiltertaaJ work
2i
D Tednrical drtwin*
2-Dimeraionalartwork
Ilesaaoalrseaaaa
TraaManeadlea 1% OoaaeMaMBiM
e-atbeK-ai \J ONLtlMasart
2005
Year
kiaeeeaS.
Day
onnnsuXT OAianUNixn
gg SEP 19 2005
9 SkylineDrive
1*
Hawthorne, NY 10532
if TWodeP>oiTsreo
RECEIVED
IKMBONBACK^ Ocrraa|eaiaBBjfe*eeBrtiiiri^
' naaiaealel>eliii
6tontraamaterg.
FUNDS RECEIVED
. MMsTMnnlH
aaalcy^2-a
f.a
i i t fiiitiieieiiiiajeaaeii
uw
aaenaweeta fin
PORMVA
EXAMINED BY
CHECKED BY
ylhi
FOR
CORRESPONDENCE
COPYRIGHT
OFFICE
Yee
USE
ONLY
POiKffWBrfEABOWTHBUNsUFY^
sBBOSaf
HUWtOU8SIMBTaUT10Hastae>e*icfa
DYea QNe Uyoerar*wrb"Ya*"i*ykaoollirree>ratioerx^
a. DTtneiaAeflralpiiblbMeAtlonof^
b. DTnilUttetn^BBptotaeabBdltrt^
c D 11aberkaa|ednraVnrJ'r_a*ork,aaaaDrabrsp
rFyo-ar^ta>-Ycs,-,|>t:PrerlotiiIUlsinta
YcerofteeJatrattoaT
owk{OMiiilceBceu7 fttbreceenjMM&Mi.
MRrfRaXntpMLnQ
tee apace.
b
DlKWTTACCOIJrn'irtoiaisatraticar-biota
AeeeuaiNaeaberV
FJyseWeuenfcld
9 Skyline Drive
Hawuwrne,NY 10532
(914) 347-7700x121
Fax nutter
dyK@cKrwnawBids.com
CaWnFICAtlON* Itbettno^rala^rres^cerbtylhalleinthe
{ D author
Or^a^tdtfeunl
DowtiertfeeriunraerJsitfe)
Dow
***'"*""
kf.t
ByaeWdaV-tMd
nriuA
08/30/05
oreianywraeweajBjriawaaadlrie
iimjL,p^j,uUrj,..!i.l^alj.llieJULil..s)i 1.1. uijiaajjxcuuuraagw
turjaMaan
IJA(<owtiri-<PiiieigOrsoa-2003-o>^otvao,ca
Certificate of Registration
STAT^y
tft* FormVA
\m/ braWckoftbeVataalAria
UNITtDSTmC0mrGHT0W
VA 1-349-556
^(SSfeo
two
Homt'
torn
v*vee/
NATUraOFTHBWOKKTseerreenjr*-,
Medals
eTtatrjoawAlttTBatlTeTtlJtiT
uajUgitkiesr5ieerid.TltteofO>nedTaWorfcV
NuabcrT
NAMB OF AUTHOR
YearBomT
Asd^jNgtaulity or DonicBe
Weethkrxeurttratsaatetkeworka
^rcetaaadelorUrt^
0 Yes
IrferacUedia
a "work made
USA
GS MMmer-tontJsculpture
DMap
D 2-Dirrrenional artwork
Q rUproductlonofworkofert
D Photograph
a Jewelry design
...^^^^^^^^
..
ae'Author of
QYea
D No
. _.
D Arcbitcctural work
-,
Date* of Birth and Death
YearBomT
Year Died
____________
Waa tab ecettrctatlea to the work a
AelhortN^nalltyorDcenlcile
WTl_Ao11t^iCootribetktotl>eWork
qo J Quia of _________
DYea
iDomkliedln
DNo
Anoevoaoeat
pModonyrootti?
DYea
DNo
3
4
Dm tHftuCelum
hejlfrig m|Tl_|lr__|
^ee'eeedetaled
Iret/ucoone.
leave the
ol With and
death want.
Hfeyeeedetaeed
D Technical drawing
provided, give KJ
was prepared)
Pswrfooyinoui?
Tew
AnonyaooaT
work thatwaa
the employ
Year Died
WMTbiaAouWiCordruatii-tottsiWorfc
Ottzcaof
OR
0 Ho
roihlre'le
oenerely the
employer, net
the employee
dee hainteno). For my
part ol this
NOTE
Oa Pages Y
Isaac Date*
fet*tc*Aetbcrfehip Oiodrapprora>Mboi<).Se*ilsetruc(lorie
D3-Dimenaionl sculpture
DMap
DTechnical dmwing
2-DitneneJeaaj artwork
DTteproductionofworkofart
D Photograph
Jewelry design
DText
D Architectural work
to*riN^lnMTMtmtoTkUrmTlUtoyrk
_2Q_
3006
Veer
heetimaukeehid.
Nation
COPTMsOTCIAiMANlXSjNarre^add^
aurhorghin apace 2. T
Tf-terKeelaie_an;e>aaBiedr^
MrfereaaeteflaeJ(ctakeaat{s)otoa^
MOREON BACK ^
'
&xnrJeteeIopplrj_aapaoeeCnurrtr^
See derated Inattiolenc.
Page10___ pages
V
EXAMINED BY
CHECKED BY
FOR
CORRESPONDENCE
COPYRIQHT
OFFICE
USE
ONLY
Yes
DO NOT WRITE ABOVE THIS LINE. IF YOU NEED MORE SPACE, USE ASEPARATE CONTINUATION SHEET.
PREVIOUS REGBTRATION His registration for Ibis worlr, - fa aaeartlerveroOT oftrmworfc already tra
c DTiihbacbarigedveraV>eoflhawori;ushowal>yvac6ont^
[fyeuramwerU"YeCpve:PrevreRee>lreUoBN^^
VcarorKegUU-atloai-
DERIVATIVE WORK ORCOMPILATION Cornplete both space 6a sad 6b for aderivative work; compku only 6b tor acornpilatioa.
a. rreexhtteg Material Ideality ariy preexisting work or works that e^oiUr>uedcorir*orporalet.-
SeelreerocrJona
baloraoomplanng
We apnea.
Naat
Account Number
CORRESPONDENCE Give name and address to which con-ponienct about tKi appHcalioi should be sent. NemeMddieea/AiriratySiite/ZIP
Elyse Weisenfeld
9 Skyline Drive
Hawthonie,NY 10532
Areaooc*errfday1rriatereriK>r*raaricr
(914) 347-7700x121
Fajcnumber
>
Email elyse@crownawards.com
CERTIFICATION* loNeurdenigiMhesebyoettifytriatlainrhe
O author
D othercopyright claimant
Downer of exdueive rightfe)
^ L _, a agent. of
< Crown
Awards,' Inc...
tfauthorUed
_____
Typed or printed nameand date YIf this application gives adate ofpublicaamtaepece3,donrjteignandeuljmltitDeforethatdate.
ByseWeisenfeld ^
- M3W*
Data
Handwritten slgwruiepC)^^
(A i
CertHlcetd
will be
mailed In
window
envelope
Eryse Weisenfeld
_-_.
>sTfln^uTapr^lcolt(space g
to this
9 Skyline Drive
addreaa:
CtyrStatafziPT
Hawthorne, NY 10532
.r^Sundaeleejn^leelncreKkornior __?___
c*ceyeeleflec^
fiSSeT* "-~iaMana>
teau
?__?__
,-_y Avenue.8*.
)"
i. Oj& 20es*4000
'l7.JM|iW:JWp^^I^Hllyr^
wnnt aMieetlon.analbe tned not morattianS2J0Q.
Bav.uauaia9-3C# Web flev: June SOtB *JPrWed on recycled paper
Certificate of Registration
This Certificate issued under the seal oftheCopyright
o ___&.
*I870-^
<XUfr~
Registration Number
VA 1-902-773
A^hfy.
v\_X_L
Effective date of
registration:
February 18,2014
Title
Title of Work: Prestige Plaques
Contents Titles: Basketball, Baseball, Football, and Soccer 6" Prestige Plaques
Completion/Publication
February 10,2014
Author
Author: Crown Awards, Inc.
Yes
United States
Domiciled in:
United States
Copyright claimant
Copyright Claimant: Crown Awards, Inc.
9 Skyline Drive, Hawthorne
Certification
Name:
Erin Andrews
Correspondence: Yes
Page 1 of 1
Registration #: VA0001902773
Service Request #: 1-1228992221
Elyse Weisenfeld
9 Skyline Drive
Hawthorne, NY 10532
Certificate of Registration
ThisCertificate issued under the seal ofthe Copyrighl
o___l*\
Registration Number
VA 1-767-936
In
1870
Effective date of
registration:
February 3,2011
Title
Title of Work: Icicle Series Lucites
Completion/Publication
Year of Completion:
2010
Author
Author:
Author Created:
Work made for hire:
Domiciled in:
sculpture/3-D artwork
Yes
United States
Copyright claimant
Copyright Claimant:
Certification
Name:
Correspondence:
Yes
Page 1 of 1
Registration #: VAOOOl767936
Service Request #: 1-559062236
Elyse Weisenfeld
9 Skyline Drive
Hawthorne, NY 10532 United States
Certificate of Registration
This Certificate issued under theseal oftheCopyright
.*-i___**
Registration Number
VA 1-811-025
S^ TTLuLA'rtkUfe
Effective date of
registration:
February 17,2012
Title
Title of Work: trophy columns
Previous orAlternativeTitle: patriot, 2012, silver swirl, black and goldbaseball, black andgoldbasketball,
black and gold football, black and gold soccer
Completion/Publication
Year of Completion:
2011
Author
Yes
United States
Copyright claimant
Copyright Claimant:
Certification
Name:
Elyse Weisenfeld
Page 1 of 1
Elyse Weisenfeld
9 Skyline Drive
Hawthorne, NY 10532 United States
Certificate of Registration
This Certificate issued under the seal ofthe Copyright
*pj*L*
OMx*~
Registration Number
VA 1-849-589
A'kk
Effective date of
<wX-fl.
registration:
February 4, 2013
Title
Title of Work: Sport Cup Sculptures
Previous or Alternative Title: baseball, basketball/bowling, soccer, wrestling
Completion/ Publication
Year of Completion:
Date of 1st Publication:
2012
January 30, 2013
Author
Author:
Author Created:
Work made for hire:
Domiciled in:
sculpture
Yes
United States
Copyright claimant
Copyright Claimant: CrownAwards, Inc.
Certification
Name:
Elyse Weisenfeld
Date:
February 4, 2013
Page 1 of 1
1-887204753
Elyse Weisenfeld
9 Skyline Drive
Hawthorne, NY 10532 United States
Certificate of Registration
This Certificate issued under the seal ofthe Copyright
*!__?*.
FormVA
VA 1-329-787
'
llIIBliiW
V va y
>^ ($&<_
J8?0-
vkj
--3b- ^5
l.f??.N0T WRITE Afl0VE THIS UNE-IF Y0U WEED M0RE SPACE. USE ASEPARATE CONTINUATION SHEET.
TIBe oTThis Work
Mylars
Mylars
Preitti-orAlteiimilveTifleiT 2005.1st pi, 2nd pi, 3rd pi, victory male and femde,tmh,achieveinent.parncipant. happybirUidaT
archery, art, basketball, baseball, tball, badminton, billiards, beauty, bmx, uphill, boHng,bowung, cheer, dnl), cbef, chess, team mom, etc.
!eaSl^!_^^
ff|Mislicduiapenadicol(xsetulgiva Volume
I Domiciled ia JUSA.
employer, not
His employee
(aaa Instruc
tions) Forany
DJewelry design
On Pages
qjj I Citaeobf
DNo
the author- ol
a "work made
lor Mra* l>
genarally tho
bsocDaleT
Name ol Gountty
NOTE
Number*
Atee~-*>
DY DNo *_*
Pseudonymous'
D Yes
DNo
"VaVsea rJatalsd
bissuowors
D Technical drawing
DText
D Architectural work
part of Ma
arork that was
Name of Anther
check *Yaa" In -*
the spies
I
pmvtdsd, give I
YearBomT
Year Died
Kit employer
(oretrwr
parson lor
whom tha work
Aoubor's Nationality<>rDomJdle
rauiwoTCeunlry
wsa prepared)
aa'Author* of
thai pan. arte
laavsBio
specs tor dales
l Domiciled in
DNo
of birth and
daath blank
3
4
Sm instructions
a *kfc--_n.
2004
behws compistina
this space
Qp I Quzegof
ThraWsrrealkin
reuatbaeh-a
Year tor"
D Jewelry design
DNo
^Waae debuted
D Technical drawing
D Text
O Architectural work
bWKIW
Comptata
--tNsurrormarJoe
-. H BUs work
rtaabeeni
beenpublehod
Month January
D,y
J__ Yuar
2003
JJSA_
Nation
I APPa_Hft^
flraWlJ
ONEDERM
MW
tnsrnjclkiro
COPYRIGHT
CtAIMANT<S)Nsiae
sad address roM begivcotrveau-^clmmiuit uthesa~a.tr*
slidgiven
u space
2
-=_!.
Anonymous*
Pseudonymous?
fl FUNDS RECEIVED
(waiters M) onthe reverse akfct olMspage
Slcnmelorniatsnee
DOMOTW7UTEHE
fajo 1otQ-jmos
FOR
COPYRIGHT
OFFICE
USE
ONLY
DO NOT WRITE ABOVETHIS UNE. IF YOU NEED MORE SPACE, USE ASEPARATE CONTINUATION SHEET.^
SkviousregSation^^^"^^T*^!ll^^"^^^>ti*-*-*"*"^w*1oaal
DYes DNo Ifjoures'We,-WByuaniiuBaiepsBn*
a. DT^s"lbefir*blisnededinrjncifawcrtpnrnom
Ifyoursniweris-Yra.'ii.el'refloaalUg^
YenrofKegJstratkmT
Je-ew
^ll.shMd
s.Pretilsllii| Material MMhrvsnvticeeiiisunewotk-worlcsta
fcseabrysaypreesisungworkor
SMkiamialona
before oornpleBrio
------^^
.sclsuned. T
^ORRESTONDnTCEZrTan^^^
Elyse Weisenfeld
9 Skyline Drive
rIawmorne,NY 10532
Arsar^arddaytlrrtaleriiorisiar
(914)347-7700x121
Fat number
Email elyse@crownawards.com
CERTIFICATION* I the iinderaigned, hereby certify that lamthe
D author
dieckonlyoneb>
I ^I
^
othercopyright claimant
r/
Is^H.u*oneMas^___^
;} , ... TOrown Awards,Inc.
cfthe work iditrJinedmthia.ppa-t^
^dprailrfr~aiaal.Ttfrlu..pplr^
Certificate
will be
mailed In
Elyse Weisenfeld
Crown Awards. Inc.
window
Numbor/Straet/Aotv
envelope
9 Skyline Drive
to this
address:
08730/05
OtyfStHa/ZIP f
Hawthorne, NY 10532
mil
m .W+l-U.-^
with trapplh*IW tball baltnad not moraianS2*
i f V v m *,~l siy a> it #
Sa^S
inosKAirams_SE
DCS05SMOM
L
US Gowri^Prier*0o 2prjW8S/60i
Certificate of Registration
Office in accordance with title17, United States Code,
atteststhat registration has been made for the work
identified below. The information on this certificatehas
taamrkeftaaVbealArti
lmiiiHiiin
FormVA
av>:51_**
^62feL_
11
ttat
Ttflee/ThlsWorky
NATURE OFTHISWORK*
2006 Mylars
Mylan
PeAUcateaiaCMllrsMlM tfAsworkra*rabUe*desacoatiux^
eeabiwalloe appeared. TMs of CaawttfreWork V
tfpaba^badtaapestaoa^erseaUtrw: V.
NamDerT
iDeeiT
NAM 07 AUTHOR T
NOTE
BYes
Oa Fae~
AjBltee^httfeeew^w
OT/cilb-of
Aaoaynoust
iDowaciUb
DNo
USA
DNo
"'"
lor Mra" la
paeerelly the
osipjsyar. net
stsaeeiBloyee
(eeektweBene). Foreny
part el bus
work diet was
maaalormracheck Yes'In-,
nteeeeee
O J-Kmeisilotialacalr<Bre
DMap
QTecbnicsJdrswinj
El 2-WrrasnrrionaJ artwork
D Rerductionofvrjrkofeit
D Photograph
DJewelry deal
OTexl
DArchitecturalwork
NaaMe/Aiitbor T
the eHipteyer
(or other
as Oewarka
ifor
wea prepared)
Yea
M'AaihereT
A-.rjr.eeat
onjcbb-or
ONo
Year Died
Irjor-dledbi
OHo
nfce.'eiestaled
leeve Die
D tWmenalonel artwork
D rUproo^ictiOTofworlofert
3
4
31
D Photograph
0 Jewelry design
OTrxhnlcaldrawing
OText
D Architectural work
iew
2005
Day
Year
"SEFrmm
9 Skyline Drive
Hawthorne, NY 10932
tfewekfceeaeMaisaadeereiaejeeseis
hriefa
oltiwe
eejtelb~B-cbjBwjraeetas>ri
MORE ON BACK
api*rt^svq-taremekisofMperje.
Ss-taa1 at anal
if
FUNDS RECEIVED
do mot wniyi h
EXAMINED BY
CHECKED BY
CORRESPONDENCE
FOSMVA
HZ
_Vj
FOR
COPYRIQHT
OFFICE
Yes
USE
ONLY
DOHOTWrOTBAsfOVETHI8LJNtllFYOUrit"^
HVWatE01IlTl^
c. D'ThbisaebaaiJdvttahair/lsaiwonXesilt^
Kyou,^wctWu,"frt:Prt*uKt&nl*Hu*M'*
YearaffcejstratkmT
a rn<-saiHeeM Wssuu>se7prosiJs*worJt-io^
Seelnstftore
__,
belerBeeBs]
tratapeei.
_e_Cepyri|alOflV*f>eTiar-s_iiiina
.a
Hyse Weisenfeld
9 Skyline Drive
Hawtbxmw.NT 10532
A~codanddiytmttkJ~nurri-
Fa* number
EmsU dyse@crownawards.corn
CKRTIFICATION* Lflieundeadpir^herehja^rJ-Iamthe
| Dauthor
rferkofuVoneav J
Oelhareei^teudmeol
s^ktfaurbodarfae^.^BoWnAw*'-^
Nw-rtaui-oiotwuu^lSceaTisrtorew
ByseWdscQfdd
Cevtillcato
wBlbe
I In
r^Vdsedfeld
Crown AwarrJa.Inc.
reeneerratrsetfApt
to Ma
_*"""V
__
08/30/05
Date
9
**J_tf'^yWOMfJf 5aSa*a^aSfCS_eeil
9 SkylineDrive
______M_i_
OreWa-aPV
Hawthorne, NY 10532
waitwaprAVetbaslaatoeeadMraoree^
UAOe^rnrr-raPr^Orac.aetX*^
Certificate of Registration
o5>^_^*
FormVA
PereWoA of tbeVlsealArU
UNITlD STATSS COPYSICHT OfflCS
VA 1-349-554
y^QM^
rsto-
Monti
IDey
*er
2006 Mylars
Mylars
Previotss as*AMariiaslveTitles
Na_berT
NAME OF AUTHOR
the-author-ol
e "work nude
torture"*
Aathor'sNadoBuu^orDc-Ocfle
Neeofcounay
WMlaeiceeuifarlJowwtacworka
note -*r
Under lbs law.
QRfc--of
I fcxradledin __A_
DNo
Aaoayitwu?
DYea DN ^tSyrfrrM
tmeatpaml
DYes DNo
D 3-Dlna~sknalsctdr^are
DMap
D Technicaldrawing
ereployar. not
the employee
0 2-Kmorakmal artwork
OTexi
(ee Instruc
D Photograph
D Jewelrydesign
D Architectural work
Name of Aetbor T
theepeoe
I
provided, give I
Bisamptoyar
(or other
parson tor
where the went
waa prepared)
as'Author of
leave'the
space rordeiae
deaftblank.
3
4
Yee.'eseoWaSed
panereJfy the
OePse
iDeteT
Ats^^NatonaWyor Domicile
AeoeysioBsf
onfofii-of
DYee
NatereofAetboratdp Chsckappiopt-ebo{ei).Sae>InatntCtterie
3-Wmeealoaalseolptore
DMap
D Photograph
DText
D Jewelry design
D Architectural work
saeotbeabssn
2005
Veer Iaeleeeae7
I I osTLYetMawork
**
"J-
"^mrm
is
Weepae*
MORE ON BACK
DNo JJ_J_J_**,<'
O Technicaldrawing
D 2-Dlrmrisionol artwork
DYee DN *$*
PseodoeyiBoiisT DYes
I Domiciled ki
_
DNo
Year Died T
FUNDS RECEIVED
*CefflelalaalappeaisaeeeoteO<um
Sk/i tie sa a) Sne a.
00 w t ewe-liea
aoalolZlpaeas
;'-.. I
FOR
CORRESPONDENCE
COPYRIGHT
OFFICE
Yes
USE
ONLY
DO NOT WRITE ABOVE THIS LINE. IF YOU NEED MORE SPACE. USE A SEPARATE CONTINUATION SHEET.
PREVIOUS REGISTRATION Has registration for Ihhwort, orIcr soean^ version ofe_
c DTliiiuscrjjMvenioeofttawoik,usticiwobyspce6ocu^p{iUcirio(L
Year ofSeghlratlon
e.Preeeblbi|Material IdentifysayptecditingworkorworkstbsllUsmiiskisbisedrjeorineotiiorsles.T
SeelnsuuoSons
before come
Satapace.
DEPOSIT ACCOUNT Ifthe registration fee islobe charged to sDeposit Aeeouat established iaIbe Copyright Office, give name and numberofAecoimL
NaeteT
AeeeualNueaberT
_a
ElyseWeisenfeld
9 Skyline Drive
Hawthorne, NY 10532
Areaeefcarrfdayttrotelepnone number
Email
914) 347-7700x121
Faxmimber
dyse@crownawards.com
D author
D othercopyrightclaimant
Downer ofexclusiveright's)
oftha workidentified inthU application and that theatatementa o_ie remainthis ar^csdon are corract totha beet ofmyta
Typed or printed name and data Y Ifthis application gives adate ofpublication fat ace3, do not sign and submit itbefore that date.
ElyseWeisenfeld
veisenieia
H_6Svril<jeySrinshj^tX)Y
j^"7
Date
01/30/06
//
Certificate
will b
Elyse Weisenfeld j
mailed In
Crown Awards, 1
window
Nunber/StrseVApt*
tl*rflifgn(*r^telncr*ormon~ _;__
9 Skyline Drive
e>papoaa rnaamM
envelope
to this
addreaa:
oapeaioaw
CtVStslaWY
Hawthorne, NY 10532
M7T!l!Sfeoe(sTAnypSraon^
ctTreabaaaWlnWeBsoae^^
EXHIBIT C
Certificate of Registration
GFormTX
For aNondrainatic LiteraryWork
e^_2^-
TX 6-116-209
iniHii
TxnesueaM
EFFECt|VEJ)r<fEOF REGISTRATION
^^tT**5
oa, QA Yesef/ /
SHEET
PUBLICATION ASA CONTRIBUTION If this work was published as acontribution to aperiodical, serial, or collertorv give information about the
ailleAveworkmwtaAtbecetioibutioeBppiiated
NAME OF AUTHOR
On Psges
Issue Date
Number
Anonymous?
DYee Or No u* delated
raaadonyinoiat
ONo
_^
_l(.
NAME OF AUTHOR
NOTE
lorhire le
For any
Name ol Country
THE WORK
qh/ Citizen of _
>
Anonymous?
lltheenswertoerher
mu
n li
Yes O No
olthesequestions b
.y _, art,^
(. Domiciled infe_
Pseudonymous? DYes Q No '""-~
DNo
NATURE OFAUTHORSHIP Bnpfly dessibp noteire ofmsial crlei by this author u. wludicjpynglii isdamned
pan of this
work that wee
mode to? ff
check Yes In
the epaco
LI
c4those (juestons is
NAME OF AUTHOR T
(or ether
4^
person lor
2
4
See instructions
colore compledng
this space
Name of Country
qjjf Ghxen of
DYea
Anonymous?
ONo
____
* ssi-Sr
MtajeSL
Oayt> 20
t
!
9 Skyline Drive
Hawthorne New York 10532
space i. give ebriefatarement ofhow the daimant(s) obtained ownership ofthe copynght
^ Melon
^TOwzoSF
MORE ON BACK
,,> 2005
|| FUNDS RECEIVED
POreQTWfVTeHfgfr'
Page I of
pages
EXAMINED BY
FORMTX
CHECKED BY
FOR
COPYRIGHT
OFFICE
USE
ONLY
CORRESPONDENCE
Yea
DO NOT WHITE ABOVE THIS UNE IF YOU NEED MORE SPACE USE A SEPARATE CONTINUATION SHEET
PREVIOUS REGISTRATION Hasregistration forthiswork,or foranearlier version ol thiswork,already beenmadem theCopyright Office?
DYea sfNo Ifyour answer is Yes why isanother registration bong sought? (Qieck appropriate box )T
a D Thisis the first published editionof a work previously registered in unpublished form
Year of Registration
This work incorporates some illustrations photography andcompilations fromCrown Awards2004Catalog (Reg # TX 5 914 114) Crown Awards2003
Catalog (Reg # TX 5 746 317) Crown Awards2002Catalog (Reg # TX 5 704-497) Crown Awards200) Catalog (Reg # TX 5 704 498) CrownAwards
2000 Catalog (Reg TX 5 907 758) end prior Crown Awards catalogs
Gee Instructions
before corripleUng
this space
Material AddedtoThisWork Give obrief general statement ofthematerial thathasbeenadded tothisworkand in whichcopynght is claimed T
DEPOSITACCOUNT Iftheregistration fee istobecharged toa Deposit Account established in theCopynght Office givename andnumber of Account
NuneT
Account Number
N/A
CORRESPONDENCE Give name and address towhich correspondence about thuapplication should besent
Samuel Goldfarb Esq
Neme/Address/Apt/Oty/Sfate/ZIP T
Email k-
sgoldfarb@agry!aw com
l^eKJrlFICATiOi^ i, me undesigned herebyici-iiiy that1ia*. 'd&
Check only one
claimant
of exclusivenghtfe)
of the work idenbhed in this application and that the statementsmade
by me inthisappbcabon arecorrect to thebestof my knowledge
Typed orpunted name and date Ifthisappbcabon gives edare ofpublication inspace 3 donotsign andsubmit itbefore that date
m
-
D,te^ 1/21/05
window
envelope
to this
orderpayabletoAejaWo/Csoymhts
3 Oeeoslmetenel
audit
SL5J *
S_t"UL
address
"JHCi!??** p**"*^!^^'*"'*"^**'*^!*<l<raffceriMrwrpyrjMl^^
Certificate of Registration
This Certificate issued under theseal ofthe Copyright
o-STAT-frv
l^&bteu>
"*-77T0
VA 1-677-366
Effective dale of
registration:
February 9,2009
Title
Author
Domiciled in:
2-D artwork
Yes
United States
Copyright claimant
Copyright Claimant: Crown Awards, Inc.
9 Skyline Drive, Hawthorne, NY, 10532, United States
Certification
Name: Elyse Weisenfeld
Correspondence: Yes
Page 1 of 1
Registration it:
Service Request*:
VAOOOl 677366
1-159012527
Elyse Weisenfeld
9 SkylineDrive
Hawthorne, NY 10532 United States
Certificate ofRegistration
.*___*,.
Registration Number
VA 1-701-983
QjCH) 6trSfel_
Effective date of
registration:
February3,2010
Title
Completion/Publication
Author
Yes
United States
Copyright claimant
CopyrightClaimant: Crown Awards, Inc.
Certification
Name: Elyse Weisenfeld
Correspondence: Yes
Page 1 of 1
Registration*:
VA0001701983
Elyse Weisenfeld
9 Skyline Drive
Hawthorne,NY 10532 United States
Certificate of Registration
This Certificate issued under the seal ofthe Copyright
Office in accordance with title 17, United States Code,
attests thatregistration hasbeen made for the work
n%
J870
Registrarion Number
VA 1-759-294
Effective date of
registration:
February 3, 2011
Title
Completion/Publication
Year of Completion: 2010
Author
Domiciled in:
2-D artwork
Yes
United States
Copyright claimant
Copyright Claimant: Crown Awards, Inc.
Certification
Page 1 of 1
Registration #: VA0001759294
ServiceRequest*: 1-559062372
Elyse Weisenfeld
9 Skyline Drive
Hawthorne, NY 10532 United States
fzOC* <j\r9!o\\t>
Copyright Office fees are subject to change.
For currenl fees, check the Copyright Office
website al www.copyright.gov. write the Copy
Form CA
ForSupplementary Registration
UNITED STATES tOPVUIGHT OFFICE
REGISTRATION NUMBER
Month
Day
Year
00 NOT WRITE ABOVE THIS LINE. IFYOU NEED MORE SPACE, USE A SEPARATE CONTINUATION SHEET.
Title oWork
lOW
lo\o
Name(s) of AuthoHs)
Line Number
Corrected Information T
Explanation of Correction T
Line Number
Z2
CHEcv-^D &&*<&
MORE ON BACK
vNi^R-e
Aecvt^NiT/YULN C7(V\1TT^D
Page 1 ot
pages
Certificate ofRegistration
This Certificate issued under the seal ofthe Copyright
Office in accordance with title 17, United States Code,
attests that registration has been made for the work
identified below. The information on this certificate has
Registration Number
VA 1-811-016
AIAomLA Tzfy.L Xz
Effective date of
registration:
February 17,2012
Title
Completion/Publication
Year of Completion:
2012
Author
Author Created:
Work made for hire:
Domiciled in:
sculpture
Yes
United States
Copyright claimant
Copyright Claimant:
Certification
Name: Elyse Weisenfeld
Page 1 of 1
Elyse Weisenfeld
9 Skyline Drive
Hawthorne, NY 10532 United States
Form CA
For Supplementary Registration
UNITED STATES COPYRIGHT OFFICE
REGISTRATION NUMBER
Month
Day
Year
DO NOT WRITE ABOVE THIS LINE. IF YOU NEED MORE SPACE, USE A SEPARATE CONTINUATION SHEET.
*V*w, 4t-A> >* i^r."*^#&.%*&.
Title of Work Y
2)|2_
V.
VA-\-<_Al -otV_>
2>\rL.
Name(s) of Copyright Claimant(s)
Name(rj) of Authoris) T
Corrected Information T
Explanation of Correction T
Line Number
MORE ON BACK
Page 1 ol
pages
Certificate of Registration
This Certificate issued under the sealofthe Copyright
.o_2_I_t.
TtIculL A- k
Registerof Copyrights,United Statesof America
Registration Number
VA .1-849-715
Effective date of
registration:
February 1,2013
Title
Title ofWork: 2013 Crown Awards Catalog
Previous or Alternative Title:
Completion/Publication
Year of Completion:
Date of 1st Publication:
2012
January 30, 2013
Author
Author:
Domiciled in:
Yes
United States
Copyright claimant
Copyright Claimant: Crown Awards, Inc.
9 Skyline Drive, Hawthorne, NY, 10532, United States
Certification
Name:
Elyse Weisenfeld
Page 1 of 1
Registration #: VA0001849715