La Luz Roja de San Marcos Trademark PDF

Case 8:14-cv-01789 Document 1 Filed 11/07/14 Page 1 of 14 Page ID #:1
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STEVEN J. EYRE, CB# 119714

3550 WILSHIRE BOULEVARD, SUITE 1440
LOS ANGELES, CALIFORNIA 90010
(213) 385-6926
fax (213) 385-3313
stevenjeyre@gmail.com
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Attorney for Plaintiffs
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UNITED STATES DISTRICT COURT
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CENTRAL DISTRICT OF CALIFORNIA
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COMPLAINT FOR
Plaintiff,
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No.
SINFORIANO SILVA,
-vs.-
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ALBERTO CAMPILLO, SILVIA

PATATAN JUSTO, RAFAEL
SANTIAGO, PABLO ARTEAGA,
JULIO BARRIOS, JUAN MANUEL
CORTEZ dba LA HACIENDA NIGHT
CLUB, DAVID MARTINEZ dba EL
NUEVO MONTERREY NIGHT CLUB,
DOES 1-10,
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Defendants.
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1. FEDERAL TRADEMARK
INFRINGEMENT;
2. UNFAIR COMPETITION;
3. COMMERCIAL
DISPARAGEMENT;
4. STATE LAW COMMON LAW
AND STATUTORY TRADE
NAME INFRINGEMENT;
5. INTERFERENCE WITH
PROSPECTIVE BUSINESS
ADVANTAGE;
6. ACCOUNTING;
7. TEMPORARY, PRELIMINARY
AND PERMANENT INJUNCTIVE
RELIEF
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JURY TRIAL DEMANDED
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-1Silva vs. Campillo
COMPLAINT
Plaintiffs allege:
JURISDICTION AND VENUE
1.
These claims arise under the laws of the United States, particularly
under the federal Lanham Act (15 U.S.C. 1501 et seq.), and under the laws of the
State of California, including California common law. Jurisdiction is proper under 28
U.S.C. 1331 and 1138(a). Jurisdiction is also proper pursuant to the Court's
supplemental jurisdiction as provided in 28 U.S.C. 1367 in that the state law claims
alleged herein are so related to the federal claims that they form part of the same case
or controversy under Article III of the United States Constitution.

2.
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Venue is proper in this District under 28 U.S. C. 1391(b) and
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1391(c) in that some defendants reside in this District, transact affairs in this District
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and that a substantial part of the events or omissions giving rise to the claims herein
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occurred within this District.

THE PARTIES
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3.
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California.
4.
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5.
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Defendant Silvia Patatan Justo is a resident of Ventura County,
California.
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Defendant Alberto Campillo is a resident of Ventura County,
California. 2005 for one year
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Plaintiff Sinforiano Silva is a resident of Los Angeles County,
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Defendant Rafael Santiago is a resident of Los Angeles, California.
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Plaintiff is informed and believes that defendant Pablo Arteaga is a
2006.
resident of Orange County, California.
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Plaintiff is informed and believes that defendant Julio Barrios is a
resident of Orange County, California.
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COMPLAINT
9.
Defendant Juan Manuel Cortez is a resident of Orange County and
does business in Orange County under the fictitious business name of La Hacienda
Night Club, which business is also located in Orange County.
10.
Defendant David Martinez is a resident of Orange County and does
business in Orange County under the fictitious business name of El Nuevo Monterrey
Night Club, which business is located in Orange County.
11.
The DOE defendants are individuals or entities whose identity is
unknown at the time of filing of this Complaint, and who will be identified as soon as
their identities are ascertained. Plaintiff is informed and believes, and based upon
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such information and belief alleges, that each of the defendants, including the DOE
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defendants, are responsible for the actions complained of herein and that in so acting,
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the defendants were acting as the agents of the remaining defendants.

PLAINTIFFS MARK
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12.
Plaintiff is the owner of the musical group La Luz Roja de San
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Marcos (The Red Light of San Marcos) and is owner of the federally registered
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service mark LA LUZ ROJA DE SAN MARCOS, Reg. No. 3,440,398 in
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International Class 41 for entertainment in the nature of live performances by a
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musical group. Plaintiffs registration was issued on June 3, 2008 and continues in
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full force and effect, and is incontestable under the provisions of 15 U.S.C. 1065.
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13.
Plaintiff has used the mark LA LUZ ROJA DE SAN MARCOS
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(plaintiffs Mark) in commerce in connection with the live performances of his
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musical group since at least as early as 1997.
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14.
Plaintiff has controlled and owned his musical group La Luz Roja de
San Marcos since at least as early as 1997.

15.
Plaintiffs musical group is an exponent of the tropical style of music,
a subcategory of the Regional Mexican musical genre.

16.
Plaintiffs musical group has performed throughout the United States
in venues such as night clubs, and on radio and television.
COMPLAINT
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The salient term in plaintiffs mark is La Luz Roja (The Red
Light). Plaintiffs musical group is often advertised with the salient term La Luz
Roja in bold letters above the phrase de San Marcos.
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La Luz Roja.
Plaintiffs musical group is sometimes advertised and referred to as

DEFENDANTS ACTIONS
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19.
The individual defendants Alberto Campillo, Rafael Santiago and
Julio Barrios are former members of plaintiffs musical group who left the group
some ten years ago. None of the three defendants mentioned in this paragraph were
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owners of the group or the group name. Each was paid a fixed amount for each gig
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in which they participated.
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Defendant Alberto Campillo performed with plaintiffs musical group
in or about the year 2005, and left the group after approximately one years time.
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Defendant Rafael Santiago performed with plaintiffs musical group
in or about the year 2006, and left the group after approximately two years time.
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Defendant Julio Barrios performed with plaintiffs musical group in
or about the year 2005, and left the group after approximately one years time.
23.
Defendant Pablo Arteaga never performed with plaintiffs musical
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group. Plaintiff alleges on information and belief that defendant Pablo Arteaga is a
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former protg of Julio Barrios.
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Plaintiff is informed and believe that defendant Silvia Patatan Justo is
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the wife of Alberto Campillo and has sought to register the mark LA BRILLANTE
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LUZ ROJA DE BETO CAMPILLO in her own name as the owner of the mark in an
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intent to use application filed with the United States Patent and Trademark Office
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(USPTO) in March 2014.
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25.
Defendants and each of them are using plaintiffs Mark, or
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confusingly similar variations of plaintiffs Mark, in connection with the selling,
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booking and advertising of the performances of their respective musical groups.
COMPLAINT
Although defendants may claim that the names they use to market their groups are
different than plaintiffs Mark, on multiple occasions the performances of defendants
have been advertised using the salient term La Luz Roja in bold letters and more
often than not the phrase La Luz Roja de San Marcos in the advertising of
defendants groups.
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Defendant Juan Manuel Cortez has on more than occasion advertised
a performance of one or more of an individual defendants musical group using
plaintiffs Mark or confusingly similar variations of plaintiffs Mark in connection
with events at Juan Manuel Cortez venue, La Hacienda Night Club.
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Plaintiff has advised defendant Juan Manuel Cortez that plaintiff is
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the owner of the La Luz Roja de San Marcos mark and that the use of plaintiffs
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Mark or confusingly similar variations of plaintiffs Mark in the advertising of one or
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more of defendants groups is unauthorized.
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Plaintiff and informed and believes that defendant Juan Manuel
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Cortez has ignored plaintiffs advisements and has booked one or more of
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defendants groups and advertised them using the La Luz Roja salient term if not
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the full name, La Luz Roja de San Marcos, in the advertising of such
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performances.
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29.
Defendant David Martinez has on more than occasion advertised a
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performance of one or more of an individual defendants musical group using
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plaintiffs Mark or confusingly similar variations of plaintiffs Mark in connection
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with events at David Martinez venue, El Nuevo Monterrey Night Club.
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30.
Plaintiff has advised defendant David Martinez that plaintiff is the
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owner of the La Luz Roja de San Marcos mark and that the use of plaintiffs Mark
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or confusingly similar variations of plaintiffs Mark in the advertising of one or more
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of defendants groups is unauthorized.
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31.
Plaintiff and informed and believes that defendant David Martinez
has ignored plaintiffs advisements and has booked one or more of defendants
COMPLAINT
groups and advertised them using the La Luz Roja salient term if not the full name,
La Luz Roja de San Marcos, in the advertising of such performances.
32.
The infringements by defendants, and each of them, can be expected
to continue unless and until this Court issues and injunction enjoining defendants
conduct.
33.
Plaintiff will suffer irreparable harm as a result of the conduct of
defendants and each of them unless enjoined, including loss of reputation (customers
tricked into buying a ticket for a performance by a pirate group are less likely to
believe ads for the actual group in the future), loss of income (venue operators pay
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less for a pirate group, forcing the actual group to compete against itself on price
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for its services), consumer confusion and market saturation, to name a few of the
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deleterious effects of defendants wrongful conduct. The damage to plaintiffs
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reputation, earning ability and bottom line is incalculable; the harm is irreparable.
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FIRST CLAIM FOR RELIEF
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(INFRINGEMENT OF A FEDERALLY REGISTERED TRADEMARK,
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AGAINST ALL DEFENDANTS)
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34.
Plaintiff realleges and incorporates in this cause of action all previous
paragraphs of this complaint.
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35.
This claim for relief arises under 15 U.S.C. 1114(1)(a).
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36.
As mentioned above, plaintiff is the owner of the federally registered
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mark LUZ ROJA DE SAN MARCOS, Reg. No. 3,440,398 for entertainment services
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of a musical group.
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As between plaintiff and defendants, plaintiff is the senior user of the
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mark LA LUZ ROJA DE SAN MARCOS in connection with the entertainment
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services of a musical group.
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38.
Plaintiffs mark LA LUZ ROJA DE SAN MARCOS is arbitrary
mark, and thus constitutes a strong mark.
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COMPLAINT
39.
The marks used by defendants in connection with their groups and/or
advertising are similar to plaintiffs mark in that as used by defendants they either are
identical to plaintiffs mark or contain additional terms that do not alter the salient
term of the mark, i.e. La Luz Roja.
40.
The services provided by defendants groups are the similar to those
provided by plaintiffs musical group, i.e. live performances of a musical group,
particularly of tropical music.
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41.
The relevant marketplace for the services of plaintiffs musical group
and that of defendants is identical, i.e. the Regional Mexican music market in the
United States.
42.
There have been instances of actual confusion caused by defendants
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and each of them wherein one or more of defendants musical groups is advertised
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using the mark of plaintiffs musical group, i.e. LA LUZ ROJA DE SAN MARCOS.
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Plaintiff is informed and believes that the intent of defendants and
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each of them in using plaintiffs mark, or at a minimum the salient term La Luz
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Roja of plaintiffs mark, in connection with the advertising of the services of
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defendants musical groups is to confuse the public into believing that the musical
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group being advertised is that of plaintiff.
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44.
There is a strong likelihood of confusion arising from the activities of
defendants and each of them, as described herein.

45.
Plaintiff is entitled to injunctive relief to prevent the violation of his
rights as registrant of the above-referenced marks. 15 U.S.C. 1116(a).

46.
For the violations detailed above, and any others shown hereafter,
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plaintiff is entitled to recover defendants profits, any damages sustained by plaintiff
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and plaintiffs costs, and reasonable attorneys fees. 15 U.S.C. 1117(a). In
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addition, plaintiff is entitled to recover treble damages and attorneys fees against
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defendants and each of them for defendants use of a counterfeit mark. 15 U.S.C.
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1117(b). In the alternative, plaintiff is entitled to elect statutory damages against
COMPLAINT
each of the defendants for the violations described herein in an amount not less than
$1,000 or more than $200,000 per type of goods or services sold, offered for sale or
distributed. 15 U.S.C. 1117(c).
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Plaintiff is informed and believes that the actions of defendants were
and are willful. Plaintiff is entitled to recover statutory damages for willful violations
in an amount not exceeding $2,000,000 (two million dollars) pursuant to 15 U.S.C.
1117(c).
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Plaintiffs allege on information and belief that unless restrained by
this Court, defendants will continue to infringe plaintiffs service mark and trade
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name, thus engendering a multiplicity of judicial proceedings, and pecuniary
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compensation will not afford plaintiffs adequate relief for the damage to their trade
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name and mark in the public perception.
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SECOND CLAIM FOR RELIEF
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(FEDERAL UNFAIR COMPETITION AGAINST ALL DEFENDANTS)
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This claim for relief arises under 15 U.S.C. 1125(a)(1)(A) and is
alleged against all defendants.

51.
The actions of defendants and each of them in using plaintiffs mark
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LA LUZ ROJA DE SAN MARCOS as described above constitute false designation
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of origin, false description of fact and false representation likely to cause confusion,
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mistake or deceive as to the affiliation of the defendants groups and/or
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establishments with plaintiffs musical group La Luz Roja de San Marcos.
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52.
rights in the above-referenced marks. 15 U.S.C. 1116(a).

53.
For the violations detailed above, plaintiff is entitled to recover
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defendants profits, any damages sustained by plaintiff and plaintiffs costs, and
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reasonable attorneys fees. 15 U.S.C. 1117(a).
COMPLAINT
THIRD CLAIM FOR RELIEF
(COMMERCIAL DISPARAGEMENT AGAINST ALL DEFENDANTS)
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55.
This claim for relief arises under 15 U.S.C. 1125(a)(1)(B) and is
alleged against all defendants.

56.
The actions of defendants and each of them in using plaintiffs mark
LA LUZ ROJA DE SAN MARCOS as described above constitute false advertising,
false promotion and misrepresentation of the nature, characteristic and qualities of the
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services of the defendants musical groups.

57.
rights in the above-referenced marks. 15 U.S.C. 1116(a).

58.
For the violations detailed above, plaintiff is entitled to recover
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defendants profits, any damages sustained by plaintiff and plaintiffs costs, and
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reasonable attorneys fees. 15 U.S.C. 1117(a).
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FOURTH CLAIM FOR RELIEF
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(STATE LAW COMMON LAW AND STATUTORY
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TRADE NAME INFRINGEMENT)
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59.
Plaintiff realleges and incorporate in this cause of action all previous

60.
This claim for relief arises under the laws of the State of California
and is alleged against all defendants.

61.
By their acts alleged herein, defendants have engaged in trade name
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infringement and dilution, California Bus. & Prof. Code 14330 et seq., and
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14402 et seq.
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62.
Defendants have intentionally deceived the public by misrepresenting
that their services are connected with plaintiffs musical group.
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COMPLAINT
63.
Plaintiff is informed and believes that the acts of defendants
described herein were undertaken willfully and with the intention of causing
confusion, mistake or deception.
64.
Monetary relief alone is not adequate to address fully the irreparable
injury that defendants illegal actions have caused and will continue to cause plaintiff
if defendants conduct is not enjoined. Plaintiff therefore is also entitled to
preliminary and permanent injunctive relief to stop defendants ongoing acts of unfair
competition.
FIFTH CLAIM FOR RELIEF
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(INTERFERENCE WITH PROSPECTIVE BUSINESS ADVANTAGE
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AGAINST ALL DEFENDANTS)
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66.
This claim for relief arises under the common law of the State of
California and is alleged against all defendants.

67.
Defendants and each of them, through their actions, have interfered
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with the prospective business advantage of plaintiff by interfering with the right of
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plaintiffs to exploit and benefit commercially from his LA LUZ ROJA DE SAN
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MARCOS mark and the good will arising from his musical group La Luz Roja de
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San Marcos.
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68.
Plaintiff has been damaged by the tortious interference by defendants
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and each of them with plaintiffs economic relations in an amount to be alleged by
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amendment to this complaint.
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69.
The aforementioned acts of defendants were and are willful,
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oppressive and malicious. Plaintiff therefore should be awarded punitive damages in
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the amount to be alleged by amendment to this complaint.
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COMPLAINT
SIXTH CLAIM FOR RELIEF
(ACCOUNTING AGAINST ALL DEFENDANTS)
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71.
This claim for relief arises under the common law of the State of
California and is alleged against all defendants.

72.
Defendants are in possession of information relating to monies paid
to defendants from their misleading and deceptive practices described herein, which
represents a misappropriation of monies from plaintiff. The books, accounts, records,
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ledgers, etc. which will provide this information are in the possession of defendants
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and each of them. The amount of damages, profits and interest owing to plaintiff
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from defendants cannot be ascertained without an accounting by defendants and each
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of them.
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73.
Defendants and each of them have also benefited economically from
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the usurpation of plaintiffs trade name and service mark without accounting to
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plaintiff for the income and profits realized by defendants and each of them as a
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result of such activities.
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74.
Plaintiff hereby demands, and is entitled to, an accounting of all
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monies received by defendants and each of them from their use of the mark and trade
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name of plaintiff's licensor and any other confusingly similar terms.
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SEVENTH CLAIM FOR RELIEF
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(TEMPORARY, PRELIMINARY AND PERMANENT INJUNCTIVE RELIEF-
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-AGAINST ALL DEFENDANTS)
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75.

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The continuing wrongful acts of defendants herein have harmed and
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continue to harm the interests of plaintiff in his trade name La Luz Roja de San
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Marcos and his federally registered trademark LA LUZ ROJA DE SAN MARCOS.
COMPLAINT
If this court does not issue a temporary, preliminary and permanent injunction against
defendants and each of them prohibiting the use of the LA LUZ ROJA DE SAN
MARCOS mark and trade name in connection with the goods and services of
defendants musical group, plaintiff will suffer irreparable harm for which there is no
adequate remedy at law.

PRAYER
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WHEREFORE, plaintiff prays for relief as follows:
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For an order requiring defendants to show cause, if they have any, why
they should not be enjoined as set forth below, during the pendency of this action.
2.
For a temporary restraining order, a preliminary injunction, and a
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permanent injunction, all enjoining defendants and each of them and their agents,
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servants, employees and co-venturers, and all persons in active concert or
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participation with them who receive actual notice of the order by personal service
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or otherwise, from engaging in or performing any of the following acts:
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(a) Using the name La Luz Roja de San Marcos or any confusingly
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similar or colorable imitation of the name, including without limitation the phrase
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La Luz Roja, in connection with advertising in any form, or in connection with
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the goods or services of defendants or any of them;
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(b) Using the name La Luz Roja de San Marcos or any confusingly
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similar or colorable imitation of the name, including without limitation the phrase
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La Luz Roja, in any manner for the purpose of enhancing the commercial value
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of the goods or services of defendants;
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(c) Otherwise infringing or diluting the distinctive quality of

plaintiffs service mark and trade name La Luz Roja de San Marcos;
(d) Causing a likelihood of confusion, deception or mistake as to the
makeup, source, nature or quality of plaintiffs or defendants services;
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COMPLAINT
(e) Contacting promoters, advertisers or other businesses for the
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purpose of offering the services of defendants as La Luz Roja de San Marcos or
any confusingly similar or colorable imitation of the name.
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For an order requiring defendants to deliver up and destroy all
promotional literature, advertising, tickets, goods and other material bearing the
infringing, diluting or injurious designations.
4.
For defendants profits in an amount according to proof.
5.
For actual damages in an amount not less than $100,000.
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For three times the amount of plaintiffs actual damages suffered by
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reason of defendants infringement of plaintiffs mark and trade name.

7.
For three times the amount of defendants profits derived from
infringement of plaintiffs mark and trade name.

8.
For statutory damages in an mount not less than $1,000 nor greater than
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$200,000 per type of goods or services sold, with respect to the infringement of
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plaintiffs registered mark.
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9.
If the Court finds that the infringements of plaintiffs registered mark is
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willful, for statutory damages in an amount not less than $1,000 nor greater than
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$2,000,000 per type of goods or services sold.
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10. For punitive damages in an amount to be proved at trial.
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11. For prejudgment interest.
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12. For an accounting of all monies received by defendants from their
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activities in connection with the use of the name La Luz Roja de San Marcos.
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13. For costs of suit.
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14. For reasonable attorneys fees.
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15. For such other relief as the court may deem appropriate.
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Dated: November 7, 2014

/stevenjeyre/
Steven J. Eyre
Attorney for plaintiff
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COMPLAINT
DEMAND FOR JURY TRIAL
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Plaintiff demands a trial of this action by a jury.

Dated: November 7, 2014
/stevenjeyre/
Steven J. Eyre
Attorney for plaintiff
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COMPLAINT

La Luz Roja de San Marcos Trademark PDF

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Case 8:14-cv-01789 Document 1 Filed 11/07/14 Page 1 of 14 Page ID #:1

STEVEN J. EYRE, CB# 119714

Attorney for Plaintiffs

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA

ALBERTO CAMPILLO, SILVIA

JURY TRIAL DEMANDED

-1Silva vs. Campillo

Case 8:14-cv-01789 Document 1 Filed 11/07/14 Page 2 of 14 Page ID #:2

JURISDICTION AND VENUE

State of California, including California common law. Jurisdiction is proper under 28

or controversy under Article III of the United States Constitution.

Venue is proper in this District under 28 U.S. C. 1391(b) and

occurred within this District.

Defendant Silvia Patatan Justo is a resident of Ventura County,

Defendant Alberto Campillo is a resident of Ventura County,

California. 2005 for one year

Plaintiff Sinforiano Silva is a resident of Los Angeles County,

Defendant Rafael Santiago is a resident of Los Angeles, California.

Plaintiff is informed and believes that defendant Pablo Arteaga is a

Plaintiff is informed and believes that defendant Julio Barrios is a

resident of Orange County, California.

-2Silva vs. Campillo

Case 8:14-cv-01789 Document 1 Filed 11/07/14 Page 3 of 14 Page ID #:3

Defendant Juan Manuel Cortez is a resident of Orange County and

Night Club, which business is also located in Orange County.

Defendant David Martinez is a resident of Orange County and does

Night Club, which business is located in Orange County.

The DOE defendants are individuals or entities whose identity is

the defendants were acting as the agents of the remaining defendants.

Plaintiff is the owner of the musical group La Luz Roja de San

service mark LA LUZ ROJA DE SAN MARCOS, Reg. No. 3,440,398 in

International Class 41 for entertainment in the nature of live performances by a

Plaintiff has used the mark LA LUZ ROJA DE SAN MARCOS

(plaintiffs Mark) in commerce in connection with the live performances of his

musical group since at least as early as 1997.

San Marcos since at least as early as 1997.

Plaintiffs musical group is an exponent of the tropical style of music,

a subcategory of the Regional Mexican musical genre.

Plaintiffs musical group has performed throughout the United States

in venues such as night clubs, and on radio and television.

-3Silva vs. Campillo

Case 8:14-cv-01789 Document 1 Filed 11/07/14 Page 4 of 14 Page ID #:4

The salient term in plaintiffs mark is La Luz Roja (The Red

Roja in bold letters above the phrase de San Marcos.

Plaintiffs musical group is sometimes advertised and referred to as

The individual defendants Alberto Campillo, Rafael Santiago and

in which they participated.

Defendant Alberto Campillo performed with plaintiffs musical group

Defendant Rafael Santiago performed with plaintiffs musical group

Defendant Julio Barrios performed with plaintiffs musical group in

Defendant Pablo Arteaga never performed with plaintiffs musical

former protg of Julio Barrios.

Plaintiff is informed and believe that defendant Silvia Patatan Justo is

(USPTO) in March 2014.

Defendants and each of them are using plaintiffs Mark, or

confusingly similar variations of plaintiffs Mark, in connection with the selling,

booking and advertising of the performances of their respective musical groups.

-4Silva vs. Campillo

Case 8:14-cv-01789 Document 1 Filed 11/07/14 Page 5 of 14 Page ID #:5

different than plaintiffs Mark, on multiple occasions the performances of defendants

Defendant Juan Manuel Cortez has on more than occasion advertised