Escolar Documentos
Profissional Documentos
Cultura Documentos
Document 4
Filed 06/22/11
Page 1 of 14
Page ID#: 36
CV No. 11-592-AC
Plaintiff,
v.
FIRST AMENDED COMPLAINT (Trademark Infringement, Unfair Competition, Trademark Dilution, Unfair and Deceptive Trade Practices, Declaratory Judgment Regarding Registration)
Plaintiff Pendleton Woolen Mils, Inc. ("plaintiff' or "Pendleton") files this Complaint
and states as follows:
1. This is an action for trademark infringement, unfair competition and dilution,
unfair and deceptive trade practices, and declaratory judgment arising out of the Trademark Act
of 1946, 15 U.S.C. 1051 et seq. (2002) ("the Lanham Act"); the Declaratory Judgment Act,
2201-2202; the Oregon Unlawfl Trade Practices Act, ORS 646.605-646.656 (2009); the
Oregon anti-dilution statute, ORS 647.107 (2009); and the common law.
005436.0664/50995721
Case 3:11-cv-00592-AC
Document 4
Filed 06/22/11
Page 2 of 14
Page ID#: 37
2. Defendant is marketing and selling apparel, fragrances, and related products under
Defendant's use of the trademark is likely to cause confusion, mistake, or deception as to the
Pendleton's trademarks.
THE
PARTIES
under the laws of the state of Oregon, with a principal place of business at 220 NW Broadway,
Portland, Oregon, 97209.
under the laws of the state of Oregon, with a principal place of business at 1205 SW Cour,
Pendleton, Oregon, 97801.
5. This Cour has original subject matter jurisdiction over this action under the
Lanham Act pursuant to 15 U.S.C. 1116 and 1121 and 28 U.S.C. 1331 and 1338. This
Court has supplemental jurisdiction over Pendleton's state and common law claims pursuant to
28 U.S.C. 1367.
6. This Cour has personal jurisdiction over Defendant under 28 U.S.C. 1331
because Defendant has distributed, sold, or offered for sale merchandise under the infringing
trademark within this state, has engaged in acts or omissions within this state causing injur, has
manufactured, distributed, sold, or offered for sale products used or consumed within this state in
the ordinary course of trade, resides in this state, or otherwise has made or established contacts
within this state suffcient to permit the exercise of personal jurisdiction.
resides in this District and/or is subject to personal jurisdiction in this District. Moreover, a
PAGE 2 - FIRST AMENDED COMPLAINT
LANE POWELL PC
005436.0664/50995721
Case 3:11-cv-00592-AC
Document 4
Filed 06/22/11
Page 3 of 14
Page ID#: 38
substantial par of the events or omissions giving rise to the claims herein occurred in this
District and, upon information and belief, important and relevant records are located in this
District.
8. Pursuant to Local Rule 3-2(b), venue is proper in this Division because a
substantial part of the events or omissions giving rise to the claims occurred in this Division and
the intellectual property at issue is owned by Pendleton and thus resides in this Division.
FACTUAL BACKGROUND
9. Pendleton owns numerous federal registrations issued by the U.S. Patent and
Trademark Offce ("USPTO") for the trademark PENDLETON for use on a variety of goods. See Certificates of Registration Nos. 3,574,742, 3,555,536, 3,574,743, 3,568,773, 3,718,175,
3,297,528, 3,049,323, 2,951,453, 1,980,970, 2,059,665, 1,218,445, 913,742, and 514,710
attached as Exhibits 1-13, incorporated herein and made a part hereof. Pendleton also owns
numerous federal registrations for marks containing the term PENDLETON, including
PENDLETON COLORPLA Y, Reg. No. 3,680,928; PENDLETON ESTATE VINEYARDS &
WINERY, Reg. No. 3,662,604; PENDLETON ECO-WISE WOOL, Reg. No.
3,638,636;
No.
2,053,150; WARRNTED TO BE A
49'ER, Reg. No. 666,627. Collectively, the PENDLETON trademarks are referred to herein as
the "PENDLETON Marks." PAGE 3 - FIRST AMENDED COMPLAINT
LANE POWELL PC 601 SW SECOND AVENU, SUITE 2100
PORTLAND, OREGON 97204.3158 503.778.2100 FAX: 503.778.2200
005436.0664/50995721
Case 3:11-cv-00592-AC
Document 4
Filed 06/22/11
Page 4 of 14
Page ID#: 39
Pendleton has been using PENDLETON on blankets and throws since at least as early as 1895
and on apparel since at least as early as 1912.
11. In addition to sales of products and services pursuant to the registrations listed in
paragraph 9 above, Pendleton has sold numerous additional products under the mark
PENDLETON and marks including "PENDLETON" together with other words. For example,
Pendleton has used the mark PENDLETON in connection with scented lotions, soaps, and other
scented bath products since at least 2006.
12. As a result of Pendleton's promotion and sale of products under the
PENDLETON Marks, the PENDLETON Marks have gained significant recognition and
goodwil among the purchasing public.
13. The PENDLETON Marks have acquired distinctiveness with respect to the
products and services sold under them.
14. Since at least as early as 1997, Defendant has been a licensee of Pendleton and
thus acknowledged Pendleton's ownership and rights in the PENDLETON Marks via a license
agreement between the parties related to sales of appareL.
15. In addition, since at least as early as 2003, Defendant has either expressly or
constructively acknowledged Pendleton's ownership and rights in the PENDLETON Marks via a
trademark licensing arrangement that has existed since about 2003 between Pendleton and a third
party and likewise between Defendant and the same third pary. The products produced via the
aforementioned arangement are co-branded with Pendleton's PENDLETON mark and marks
owned by Defendant and acknowledge Pendleton's ownership ofthe PENDLETON mark.
16. The 1997 license agreement allowed Defendant to use the words "PENDLETON
ROUND-UP" on apparel in a limited manner occurring on the grounds of Defendant's event and
in stores located in Pendleton approved by Pendleton.
17. The parties operated under the 1997 agreement until May 16, 2011.
005436.0664/50995721
Case 3:11-cv-00592-AC
Document 4
Filed 06/22/11
Page 5 of 14
Page ID#: 40
18. On May 16, 2011, Pendleton terminated and revoked the license which formerly
allowed Defendant to sell apparel using Pendleton's PENDLETON mark and described the
limited circumstances under which Defendant was authorized to sell apparel and related products
19. After May 16,2011, Defendant continued, and currently continues, to sell apparel
and related goods bearing Pendleton's PENDLETON mark and/or marks confusingly similar to
the PENDLETON Marks, including PENDLETON ROUND-UP (the "Infringing Mark"). The
Infringing Mark is confusingly similar to the PENDLETON Marks when used on goods similar
or related to the various goods and services offered by Pendleton. Defendant's products sold
under the Infringing Mark compete with Pendleton's products sold under the PENDLETON
Marks.
20. Defendant is also currently selling or in the past has sold personal products,
including fragrances, under the Infringing Mark.
21. Defendant's use of the Infringing Mark includes, but is not limited to, using a
form, format, or design that emphasizes solely the PENDLETON portion of
22. On information and belief, Defendant has encouraged and/or allowed the
manufacturer and/or distributor of its fragrance products to use and apply to register the mark
PENDLETON FRAGRANCES for use on fragrance products, which is nearly identical and
confusingly similar to the PENDLETON Marks.
23. Defendant's activities are likely to cause confusion, mistake, and deception as to
the affiiation, connection, or association of Defendant with Pendleton, and as to the origin,
sponsorship, or approval of
005436.0664/5099572.1
Case 3:11-cv-00592-AC
Document 4
Filed 06/22/11
Page 6 of 14
Page ID#: 41
25. Pendleton repeats and realleges each of the allegations set forth in paragraphs i
through 24 above as if fully set forth herein.
26. The PENDLETON Marks and the goodwil of the business associated with it are
of great value, are highly distinctive, and have become associated in the public mind with
Pendleton's high quality products.
27. Defendant's use of the Infringing Mark is likely to cause confusion, deception,
and mistake by creating the false and misleading impression that Defendant's goods are
activities have caused and, unless enjoined by this Cour, wil continue to cause a likelihood of
confusion and deception of members of the trade and public and, additionally, irreparable har
and injur to Pendleton's goodwil and reputation as symbolized by the federally registered
PENDLETON Marks, for which Pendleton has no adequate remedy at law.
Pendleton's great and irreparable injur and are in knowing and wilful violation of Pendleton's
rights under 15 U.S.C. 1114(a).
30. As a direct and proximate result of Defendant's conduct, Pendleton has suffered
damages to its valuable PENDLETON Marks and other damages in an amount to be proven at
triaL.
31. Defendant has caused and is likely to continue causing substantial injury to the
public and to Pendleton, and Pendleton is entitled to injunctive relief and to recover Defendant's
PAGE 6 - FIRST AMENDED COMPLAINT
LANE POWELL PC 601 SW SECOND A VENU, SUITE 2100
PORTLAND, OREGON 97204-3158 503.778.2100 FAX 503.7782200
005436.0664/50995721
Case 3:11-cv-00592-AC
Document 4
Filed 06/22/11
Page 7 of 14
Page ID#: 42
profits, actual damages, enhanced profits and damages, costs, and reasonable attorneys' fees
under 15 U.S.C. 1114, 1116, and 1117.
32. Pendleton repeats and realleges each of the allegations set forth in paragraphs 1
through 31 above as if fully set forth herein.
34. Upon information and belief, Defendant has intentionally and wilfully used the
Infringing Mark in disregard of
Pendleton's rights.
35. As a direct and proximate result of Defendant's conduct, Pendleton has suffered
damages to its valuable PENDLETON Marks and other damages in an amount to be proven at
triaL.
36. Pendleton has no adequate remedy at law, and if Defendant's activities are not
enjoined, Pendleton wil continue to suffer irreparable harm and injur to its goodwil and
reputation.
38. Pendleton has extensively and continuously promoted, advertised, and used the
PENDLETON Marks in the U.S. for more than a century and the marks have thereby acquired
distinctiveness and become famous and well-known symbols of
005436.0664/50995721
Case 3:11-cv-00592-AC
Document 4
Filed 06/22/11
Page 8 of 14
Page ID#: 43
39. Defendant's use of the Infringing Mark began after the PENDLETON Marks
became famous.
40. Defendant is making commercial use of the Infringing Mark that dilutes and is
likely to dilute the distinctiveness of Pendleton's PENDLETON Marks by eroding the public's
exclusive identification of these famous marks with Pendleton, tarishing and degrading the
positive associations and prestigious connotations of the marks, and otherwise lessening the
capacity of the marks to identify and distinguish goods and services.
trade on the goodwil associated with Pendleton's PENDLETON Marks to the great and
irreparable injur of Pendleton.
42. Defendant's conduct has caused, and is likely to continue causing, substantial
injur to Pendleton's goodwil and business reputation, and dilution of the distinctiveness and
43. Pendleton repeats and realleges each of the allegations set forth in paragraphs 1
through 42 above as if fully set forth herein.
44. Defendant's acts set forth above violate Oregon laws, and paricularly
ORS 647.107, in that Defendant has diluted the distinctive quality of
causing irreparable harm to Pendleton's goodwil and business reputation. Pendleton is entitled
to injunctive relief and to recover damages, costs, and reasonable attorneys' fees.
45. Pendleton repeats and realleges each of the allegations set forth in paragraphs 1
through 44 above as if fully set forth herein.
005436.0664/50995721
Case 3:11-cv-00592-AC
Document 4
Filed 06/22/11
Page 9 of 14
Page ID#: 44
46. Defendant's acts constitute common law trademark infringement and unfair
competition, and have created and wil continue to create a likelihood of confusion to the
irreparable injur of Pendleton and its PENDLETON Marks unless restrained by this Cour, as
Pendleton has no adequate remedy at law for this injur.
47. On information and belief, Defendant acted with full knowledge of Pendleton's
use of, and statutory and common law rights to, the PENDLETON Marks and without regard to
the likelihood of confusion of the public created by Defendant's activities.
of Pendleton.
49. As a result of Defendant's acts, Pendleton has been damaged in an amount not as
relief, an accounting of Defendant's profits, damages, and costs. Further, in light of the
deliberately fraudulent and malicious use of confusingly similar imitations of the PENDLETON
Marks, and the need to deter Defendant from similar conduct in the future, Pendleton
additionally is entitled to punitive damages.
50. Pendleton repeats and realleges each of the allegations set forth in paragraphs 1
through 49 above as if fully set forth herein.
51. Defendant's unauthorized use of the PENDLETON Marks have caused and are
52. Defendant has been and is intentionally and wilfully passing off its goods as
005436.0664/5099572.1
Case 3:11-cv-00592-AC
Document 4
Filed 06/22/11
Page 10 of 14
Page ID#: 45
Pendleton, and Pendleton is entitled to injunctive relief and to recover damages, costs, and
reasonable attorneys' fees.
54. Pendleton repeats and realleges each of the allegations set forth in paragraphs 1
through 53 above as if fully set forth herein.
55. On July 15, 2010, Defendant fied an intent-to-use application in the USPTO to
register the mark PENDLETON ROUND-UP for "Fragrances" in International Class 3, and was
assigned application serial number 85/085,903.
56. Pendleton's registrations for the PENDLETON Marks have earlier fiing dates
than Defendant's application for PENDLETON ROUND-UP for use on fragrances, hence
Pendleton's registrations have priority over Defendant's application.
57. Pendleton's use of the mark PENDLETON in connection with scented lotions,
soaps, and other scented bath products, which are categorized in the same International
been using the mark PENDLETON in interstate commerce in connection with candles, scented
lotions, scented soaps, and other scented bath products for several years. These goods are similar
or related to, and in the same International Classification as, fragrances. Hence, Pendleton's use
has priority over Defendant's application.
005436.0664/50995721
Case 3:11-cv-00592-AC
Document 4
Filed 06/22/11
Page 11 of 14
Page ID#: 46
59. The goods on which Defendant intends to use and is using its PENDLETON
ROUND-UP mark, as evidenced by Defendant's application, are similar and/or related to the
the USPTO denied Defendant's claim of acquired distinctiveness based on prior registrations.
The USPTO indicated that Defendant could "submit evidence that the relevant purchasing
community would be likely to see the proposed mark, and more importantly the term
"PENDLETON", as (aJ trademark when used in connection with fragrances."
International Class that includes fragrances; (c) Defendant's mark has not acquired
distinctiveness for the goods identified in Defendant's application because Defendant's use has
not been substantially exclusive or continuous; (d) the goods in Defendant's application are not
the same or related to the goods or services in its prior registrations on which it bases its claim of
acquired distinctiveness; and (e) any evidence submitted by Defendant showing consumers'
recognition of PENDLETON as a trademark for fragrances should be discounted or disregarded
based on Pendleton's various PENDLETON marks, which have priority and acquired
distinctiveness prior to Defendant's application filing date.
005436.0664/5099572 I
Case 3:11-cv-00592-AC
Document 4
Filed 06/22/11
Page 12 of 14
Page ID#: 47
64. Pendleton wil be damaged by the registration Defendant seeks because the
registration wil assist and support Defendant in the confusing and misleading use of the mark
PENDLETON ROUND-UP and wil give color of exclusive statutory rights to Defendant in
violation and derogation of
65. Accordingly, Defendant has no right to register the mark PENDLETON ROUND-
follows:
designation of any kind on or in connection with Defendant's goods that is a copy, reproduction,
colorable imitation, simulation of, confusing similar to, or in any way similar to the trademarks,
service marks, names, or logos of Pendleton;
c. using any trademark, service mark, name, logo, design, or source
designation of any kind on or in connection with Defendant's goods or services that is likely to
cause confusion, mistake, deception, or public misunderstanding that such goods or services are
005436.0664/50995721
Case 3:11-cv-00592-AC
Document 4
Filed 06/22/11
Page 13 of 14
Page ID#: 48
designation of any kind on or in connection with Defendant's goods that dilutes or is likely to
dilute the distinctiveness of the trademarks, service marks, names, or logos of Pendleton; and
e. passing off, palming off, or assisting in passing off or palming off,
Defendant's goods as those of Pendleton, or otherwise continuing any and all acts of unfair
competition as alleged in this Complaint.
2. That Defendant account for and pay over to Pendleton profits realized by
Defendant by reason of its unlawfl acts herein alleged and that the amount of damages for
trademark infringement of the PENDLETON Marks be increased by a sum not exceeding three
times the amount thereof as provided by law.
3. That Pendleton be awarded actual damages in an amount to be proven at trial and
punitive damages, and that such damages be increased by a sum not exceeding three times the
amount thereof as provided by law by reason of Defendant's wilful and intentional conduct.
4. That the Court declare that Defendant has no right to register the PENDLETON
ROUND-UP mark for use on "Fragrances," or on any goods similar or related to the goods and
services offered by Pendleton.
5. That the Court order Defendant to abandon the U.S. trademark application for
incurred herein.
7. That Pendleton be awarded prejudgment interest.
005436.0664/5099572.1
Case 3:11-cv-00592-AC
Document 4
Filed 06/22/11
Page 14 of 14
Page ID#: 49
8. That Pendleton be awarded such other and further relief as the Cour deems just
and equitable.
DATED: JuneZl,2011
By
005436.0664/50995721
Case 3:11-cv-00592-AC
Document 4-1
Filed 06/22/11
Page 1 of 13
Page ID#: 50
Int. Cl.: 33
Prior U.S. as.: 47 and 49
TREMAK
PRICIAL REGISTER
PENDLETON
PENDLETON WOOLEN MILLS, INC (OREGON
CORPORATION)
220 NW BROADWAY
THE MARK CONSISTS OF STANDARD CHARACTERS WITHOUT CLAI TO ANY PARTICULAR FONT, STYLE, SIZE, OR COLOR.
OWNER OF U.S. REG. NO. 2,953,861.
PORTLAND, OR 97209
SEC.2(F.
FOR: DISTILLED SPIRITS, IN CLAS 33 (U.S. CLS.
47 AND
49).
EXHIBIT I
PAGE =i
Case 3:11-cv-00592-AC
Document 4-1
Filed 06/22/11
Page 2 of 13
Page ID#: 51
Int. Cl.: 20
Prior U.S. as.: 2, 13, 22, 25, 32, and 50
TRADEMA
SUPPLEMENTAL REGISTER
PENDLETON
PENDLETON WOOLEN MILLS, INC. (OREGON
CORPORATION) 220 NW BROADWAY PORTLAND, OR 97209
FOR: SOFAS; CHAIRS; TABLES; BEDS; OTTO-
MANS; DRESSERS; CHESTS; NIGHTSTANDS; MIRRORS, IN CLASS 20 (U.S. CLS. 2, 13, 22, 25, 32 AND
50).
S.R. 11.17.2008.
EXHIBIT d.
PAGE 1
Case 3:11-cv-00592-AC
Document 4-1
Filed 06/22/11
Page 3 of 13
Page ID#: 52
Int. Cl.: 21
PENDLETON
PENDLETON WOOLEN MILLS, INC. (OREGON CORPORATION)
220 NW BROADWAY PORTLAND, OR 97209
THE MARK CONSISTS OF STANDARD CHARACTRS WITHOUT CLAI TO ANY PARTICULAR FONT, STYLE, SIZE, OR COLOR.
OWNER OF U.S. REG. NOS. 2,713,136, 3,049,323
AND
OTHERS. .
SEC.2(.
SER. NO.. 77336,531, FILED 11-26-2007.
EXHIBIT J
PAGE I
Case 3:11-cv-00592-AC
Document 4-1
Filed 06/22/11
Page 4 of 13
Page ID#: 53
Int. Cl.: 25
Pror U.S. as.: 22 and 39
Reg. No. 3,568,773
PENDLETON
PENDLETON WOOLEN MILLS, INC. (OREGON CORPORATION)
220 NW BROADWAY
PORTLAND, OR 97209
FOR: FOOTWEAR, IN CLASS 25 (U.S. CLS. 22 AND
39).
OTHERS.
PAGE -r
EXHIBIT 4
Case 3:11-cv-00592-AC
Document 4-1
Filed 06/22/11
Page 5 of 13
Page ID#: 54
PENDLETON
Reg. No.3, 718,175 PENDLETON WOOLEN MILLS, INC. (OREGON CORPORATION)
Registered Dec. 1,2009 220 NW BROADWAY
PORTLAN, OR 97209
In t. CI.: 33 FOR: WINE, TN CLASS 33 (US. CLS 47 AND 49).
TO ANY PAR-
1),Yt-~
Dira.111T oftht! I.l1ilt!d Stiile~ l'lto:nt and I"radeinilrk om".:
EXHIBIT .~
PAGE --
Case 3:11-cv-00592-AC
Document 4-1
Filed 06/22/11
Page 6 of 13
Page ID#: 55
Int. Cl.: 30
Prior U.S. a.: 46
PENDLETON
PENDLETON WOOLEN MILLS, INC. (OREGON CORPORATION)
220 NW BROADWAY PORTLAND, OR 97209
EXHIBIT (0
PAGE I
Case 3:11-cv-00592-AC
Document 4-1
Filed 06/22/11
Page 7 of 13
Page ID#: 56
TRDEMA
PENDLETON
AS CLOTHING, FOOTWEAR, HEADGEAR, AND ACCESSORIES THEREFOR, JEWELRY, BLANKETS, BEDDING, LINENS, PILLOWS, FABRIC, FURNITURE, RUGS, HOME FURNISHINGS AND
PORTLAN, OR 972083030
FOR: TOTE BAGS, OVERNIGHT BAGS, BACKPACKS, DUFFEL BAGS, SATCHELS, SADDLE
ACCESSORIES FOR BATH, KITCHEN, OFFICE, AND HOUSEHOLD, HOUSEWARES AND KICHEN UTENSIL, LUGGAGE, BAGS, AND ACCES-
BAGS, COSMETC CASES SOLD EMPT, TOILETRY CASES SOLD EMPT, SHAVING,BAGS SOLD
EMP, LEATHER BLANKT CARRIRS, CANVAS WOOD CARRIERS, LEATHER KEY CHAINS, AND DOG APPAREL, IN CLASS 18 (U.S. CLS. 1,2,3,
22 AND
SORIES THEREFOR, TRAVEL ITEMS, BOOKS, PAPER GOODS, PRIED MATTER, ARTWORK, TOYS, HOUSEHOLD AND HOLIDAY DECORATIONS, COLLECTmLES, COMPACT DISCS AND DISC CASES, COMPUTER ACCESSORIES, AND PET PRODUCTS, IN CLASS 35 (U.s. CLS. 100, 101
AND 102).
FIRST USE 0-0-1995; IN COMMERCE 0-0-1995.
41).
THE MARK CONSISTS OF STANDARD CHARACTERS WIHOUT CLAI TO ANY PARTICULAR FONT, STYLE, SIZE, OR COLOR.
OWNER . OTHERS. OF U.S. REG. NOS. 514,710, 2,717,244
INGS, CLOTH COASTERS, TABLE RUNNERS, OVEN MITS, AND FIREPLACE MITT, IN CLASS 24 (U.S. CLS. 42 AN 50).
FIRST USE 0--1895; IN COMMERt?E 0-0-1895.
AND
SEC.2().
SER. NO. 78452,195, FILED 7-16-2004.
EXHIBIT l
PAGE I
Case 3:11-cv-00592-AC
Document 4-1
Filed 06/22/11
Page 8 of 13
Page ID#: 57
Int. cl.: 14
PENDLETON
SEC.2(F.
SER. NO. 78-310,260, FILED 10-7-2003.
FOR: JEWELRY AND WATCHES, IN CLASS 14 (U.S. CLS. 2,27,28 AND 50).
FIRST USE 7-13-2001; IN COMMERCE 7-13-2001.
EXHIBIT
PAGE I
Case 3:11-cv-00592-AC
Document 4-1
Filed 06/22/11
Page 9 of 13
Page ID#: 58
Int. CI.: 25
TRADEMARK
PRINCIPAL REGISTER
PENDLETON
SEC.2(F).
SER. NO. 74-684,919, FILED 6-5-1995.
EXHIBIT g
PAGE I
Case 3:11-cv-00592-AC
Document 4-1
Filed 06/22/11
Page 10 of 13
Page ID#: 59
Int. CI.: 25
.p~.
PENDLETON WOOLEN MILLS (OREGON
CORPORATION) 220 N.W. BROADWAY PORTLAND, OR 97209
THE LINING IN THE DRAWING is A FEATURE OF THE MARK AND is NOT INTEND.
ED TO INDICATE COLOR.
AND 777,908.
SEC.2(F).
SN 74-568,276, FILED 8-31-1994.
PAGE I
EXHIBIT IQ
Case 3:11-cv-00592-AC
Document 4-1
Filed 06/22/11
Page 11 of 13
Page ID#: 60
~L .."f
--I
Int. Cl.: 24
Pror U.S. Q.: 42
Reg. No. 1,218,445 Registered Nov. 30, 1982
TRADEMA
Pricipal Regster
For: BLANKS, in CLASS 24 (U.S. Cl. 42). Firt us 1963; in commer 1963.
Owner of U.S.
EXHIBIT-L PAGE \
Case 3:11-cv-00592-AC
Document 4-1
Filed 06/22/11
Page 12 of 13
Page ID#: 61
lnt. CI.: 25
Prior U.S. C1.: 39
Reg. No. 913,742
PENDLETON
PENDLETON WOOLEN
(OREGON CORPORATION) 220 N.W. BROADWAY PORTLAND, OR 97209
MILLS
EXHIBIT
PAGE
JI
Case 3:11-cv-00592-AC
Document 4-1
Filed 06/22/11
Page 13 of 13
Page ID#: 62
Iit. a.: i4
Pror u.s. a.: 42
im
Re Se. 6, 19
OG Da Se. ill. 1m
PRCIAL REIST
TREM
PENDLETON
PEDLEIN WOOLEN MIlJ
218 S.W. JERSN ST
PORTLND, OR 971
OWNER OF U.S. RE. NO. 184,711. SEC 2(.
~:.
"
EXHIBIT \~
PAGE \