Tory Burch v. Top Fashion - Trade Dress Complaint PDF

JUDGE ARRAMi
FEB 04 2015
CIVIL COVER SHEET
JS 44C/SDNY
REV. 4/2014
<*
Mfcjr
The JS-44 civil cover sheet andthe information contains hegmneither
pleadings or other papers as required by law, except asMroviaecay local
Judicial Conference of the United States in SeptembcW?4,^j
:~~J'
initiatingthe civil docket sheet.

PLAINTIFFS
DEFENDANTS
River LightV, LP. and Tory Burch LLC
Top Fashion Inc. d/b/a Top Handbag and Cai Yan Chen
ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER
ATTORNEYS (IF KNOWN)
R. David Hosp, Fish & Richardson P.C.
601 Lexington Avenue, 52nd Floor, New York, NY 10022

Tel.: (212)765-5070
CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE ABRIEF STATEMENT OF CAUSE"
(DO NOT CITE JURISDICTIONAL STATUTES UNLESS DIVERSITY)
Trademark infringement under 15 U.S.C. 1051 et seq. and copyright infringement under 17 U.S.C 101, et seq.
Has this action, case, or proceeding, or one essentially the same been previously filed in SDNY at any time? NoSresQudge Previously Assigned
If yes, was this case Vol. Invol.
Dismissed. No
Is THIS AN INTERNATIONAL ARBITRATION CASE7
No 0
Yes
If yes, give date.
Yes
NATURE OF SUIT
(PLACE AN[x] INONEBOXONLY)
ACTIONS UNDER STATUTES
TORTS
PERSONAL INJURY
CONTRACT
[
I
[
[
1110
] 120
1130
]1"0
[ ]150
INSURANCE
MARINE
[ ] 310 AIRPLANE
[ ] 315 AIRPLANE PRODUCT
LIABILITY
MILLER ACT
NEGOTIABLE
INSTRUMENT
RECOVERY OF
OVERPAYMENT &
[ ] 320 ASSAULT, LIBELS,

SLANDER
[ J 330 FEDERAL
EMPLOYERS'
MEDICARE ACT
[ J 340 MARINE
[ ) 345 MARINE PRODUCT
RECOVERY OF
LIABILITY
OF JUDGMENT
[ ] 151
[ 1152
DEFAULTED
STUDENT LOANS
[ ) 350 MOTOR VEHICLE

[ ] 355 MOTOR VEHICLE
RECOVERY OF
INJURY
[ ] 362 PERSONAL INJURY -
OF VETERAN'S
BENEFITS
STOCKHOLDERS
[ 1190
SUITS
OTHER
1 1195
CONTRACT
CONTRACT
PRODUCT
MED MALPRACTICE
[ J365 PERSONALINJURY
PRODUCT LIABILITY
21 USC 881
, , 6g0 OTHER
LAND
CONDEMNATION
[ )220
[ 1230
ACCOMMODATIONS
FORECLOSURE
RENT LEASE &
EJECTMENT
[ ]445 AMERICANS WITH
[ ]240
[ ]245
TORTS TO LAND
TORT PRODUCT
[ 1446 AMERICANS WITH
( ]290
LIABILITY
ALL OTHER
REAL PROPERTY
DISABILITIES EMPLOYMENT
28 USC 157
1 ) 830 PATENT
fc) 840 TRADEMARK
[ ] 370 OTHER FRAUD

[ ] 371 TRUTH IN LENDING
SOCIAL SECURITY
REAPPORTIONMENT
[
[
[
[
[
] 410 ANTITRUST
J430 BANKS & BANKING
] 450 COMMERCE
1460 DEPORTATION
1470 RACKETEER INFLU
ENCED & CORRUPT
ORGANIZATION ACT
(RICO)
[ 1480 CONSUMER CREDIT

[ ] 490 CABLE/SATELLITE TV
[ 1850 SECURITIES/
COMMODITIES/
[ 1380 OTHER PERSONAL
LABOR
PROPERTY DAMAGE
[ 1385 PROPERTY DAMAGE
[ ] 710 FAIR LABOR

STANDARDS ACT
VACATE SENTENCE
28 USC 2255
[ ] 530 HABEAS CORPUS

[ ] 535 DEATH PENALTY
[ J540 MANDAMUS &OTHER
] 861
] 862
J 863
1864
1865
HIA(1395ff)
BLACK LUNG (923)
DIWC/DIWW (405(g))
SSID TITLE XVI
RSI (405(g))
EXCHANGE
[ ]890 OTHER STATUTORY

ACTIONS
[ ]891 AGRICULTURAL ACTS
[ ] 740 RAILWAY LABOR ACT

[ ] 751 FAMILY MEDICAL
LEAVE ACT (FMLA)
[ J790 OTHER LABOR

LITIGATION
[ I 791 EMPL RET INC

SECURITY ACT
IMMIGRATION
PRISONER CIVIL RIGHTS
[ ) 462 NATURALIZATION
[ ] 550 CIVIL RIGHTS
( 1555 PRISON CONDITION
(
(
(
[
[
RELATIONS
(Non-Prisoner)
[ 1210
[ J423 WITHDRAWAL
PROPERTY RIGHTS
REAL PROPERTY
[ ] 441 VOTING
[ 1442 EMPLOYMENT
[ 1443 HOUSING/
I 1 375 FALSE CLAIMS
[ ] 820 COPYRIGHTS
PERSONAL PROPERTY
[ J463 ALIEN DETAINEE

[ ] 510 MOTIONS TO
[ ]440 OTHER CIVIL RIGHTS
[ J400 STATE
28 USC 158
INJURY PRODUCT
LIABILITY
[ ) 720 LABOR/MGMT
CIVIL RIGHTS
OTHER STATUTES
[ ] 422 APPEAL
[ ]368 ASBESTOS PERSONAL l '
PRODUCT LIABILITY
ACTIONS UNDER STATUTES
BANKRUPTCY
SE|ZURe 0F PROPERTY
PRISONER PETITIONS
LIABILITY
[ ] 196 FRANCHISE
INJURY/PRODUCT LIABILITY
[ ]360 OTHER PERSONAL
OVERPAYMENT
[ ]160
FORFEITURE/PENALTY
PRODUCT LIABILITY
(EXCL VETERANS)
[ 1153
PERSONAL INJURY
[ 1367 HEALTHCARE/
PHARMACEUTICAL PERSONAL , , 625 DRUG RELATED
LIABILITY
ENFORCEMENT
& Case No.
APPLICATION
[ J465 OTHER IMMIGRATION
( j560 CIVIL DETAINEE
FEDERAL TAX SUITS
[ 1870 TAXES (U.S. Plaintiff or
[ ] 893 ENVIRONMENTAL
Defendant)
[ ] 871 IRS-THIRD PARTY
MATTERS
[ ] 895 FREEDOM OF
INFORMATION ACT
26 USC 7609
[ ] 896 ARBITRATION
[ ] 899 ADMINISTRATIVE
PROCEDURE ACT/REVIEW OR
APPEAL OF AGENCY DECISION
[ 1950 CONSTITUTIONALITY OF
STATE STATUTES
ACTIONS
CONDITIONS OF CONFINEMENT
DISABILITIES -OTHER
[ ] 448 EDUCATION
Checkif demanded in complaint:
CHECK IF THIS IS ACLASS ACTION
p_0 YOU CLAIM THIS CASE IS RELATED TO ACIVIL CASE NOW PENDING IN S.D.N.Y.?
UNDER F.R.C.P. 23
IF SO, STATE:
DEMAND STBD at trial
OTHER lnJunction. etc JUDGE
DOCKET NUMBER
Check YES only ifdemanded in complaint
JURY DEMAND: EYES LKlO
NOTE: You must also submit at the time of filing the Statement of Relatedness form (Form IH-32).
(PLACE AN x INONE BOX ONLY)
H 1 Original
ORIGIN
LH 2 Removed from
Proceeding
II 3 Remanded D 4 Reinstated or
StateCourt
from
a. ,11 parties represented
Q 5 Transferred from 6 Multidistrict
Reopened
(Specify District)
7 Appeal to District
Litigation
Judge from
ADDellate
Magistrate Judge
Court
Judgment
I I b. At leastone
party is pro se.
(PLACEANxINONEBOXONLY)
1 U.S. PLAINTIFF
BASIS OF JURISDICTION
2 U.S. DEFENDANT \x\ 3 FEDERAL QUESTION
IFDIVERSITY, INDICATE
Q4 DIVERSITY
CITIZENSHIP BELOW.
(U.S. NOT A PARTY)
CITIZENSHIP OF PRINCIPAL PARTIES (FOR DIVERSITY CASES ONLY)

(Place an [X] in one box for Plaintiff and one box for Defendant)
PTF
DEF
CITIZEN OF THIS STATE
[ ]1
[ ]1
CITIZEN OR SUBJECT OF A
PTF DEF
CITIZEN OF ANOTHER STATE
[ ]2
[ ]2
INCORPORATED or PRINCIPAL PLACE
[ ]3 [ ]3
FOREIGN COUNTRY
INCORPORATED and PRINCIPAL PLACE
PTF
DEF
( )5
[ ]5
[ ]6
[ ]6
OF BUSINESS IN ANOTHER STATE
[ ]4 [ ]4
FOREIGN NATION
OF BUSINESS IN THIS STATE
PLAINTIFF(S) ADDRESS(ES) AND COUNTY(IES)
Tory Burch LLC, 11 West 19th Street, 7th Floor, New York, NY 10011, New York County;
River Light V, L.P., 11 West 19th Street, 7th Floor, New York, NY 10011, New York County.
DEFENDANT(S) ADDRESS(ES) AND COUNTY(IES)
Top Fashion Inc. d/b/a Top Handbag, 145 West 30th Street, Unit B, New York, NY 10001, New York
County; Cai Yan Chen, 251-23 57 Avenue, Little Neck, New York 11362, Queens County.
DEFENDANT(S) ADDRESS UNKNOWN

REPRESENTATION IS HEREBY MADE THAT, AT THIS TIME, I HAVE BEEN UNABLE, WITH REASONABLE DILIGENCE, TO ASCERTAIN
RESlbENCE ADDRESSES OF THE FOLLOWING DEFENDANTS:
Check one:
THIS ACTION SHOULD BE ASSIGNED TO:
WHITE PLAINS
[x] MANHATTAN
(DO NOT check either box if this a PRISONER PETITION/PRISONER CIVIL RIGHTS
, COMPLAINT.)
DATE AiljUC}
RECEIPT #
SIGNATWREdF, ATTORNEY OF REGQBD

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ADMITTED TO PRACTICE IN THIS DISTRICT

N NO
W YES (DATE ADMITTED Mo. _2
Attorney Bar Code # RH3344
Magistrate Judge is to be designated by the Clerk of the Court. MAG. JUDGE C0TT
Magistrate Judge
Ruby J. Krajick, Clerk of Court by
is so Designated.
Deputy Clerk, DATED
UNITED STATES DISTRICT COURT (NEW YORK SOUTHERN)
Yr. 2007
15 CV 00821
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
RIVER LIGHT V, L.P. and

TORY BURCH LLC,
GO
Plaintiffs,
C.A. No.
JURY TRIAL DEMANDED
TOP FASHION INC. d/b/a TOP HANDBAG
and CAI YAN CHEN,

Defendants.
COMPLAINT
Plaintiffs River Light V, L.P. and Tory Burch LLC ("TB LLC") (together, "Tory Burch")
file this Complaint for trademark infringement, trademark counterfeiting, trademark dilution, and
trademark cancellation, as well as copyright infringement, unfair competition, and other related
claims against defendants Top Fashion Inc. d/b/a Top Handbag ("Top Fashion") and Cai Yan Chen
(together, "Defendants"), and in support thereof allege as follows.
NATURE OF THE ACTION
1.
This case concerns Defendants' sale of a line of infringing and counterfeit Tory Burch
products and blatant copying and unlawful use of Tory Burch's intellectual property, including a
confusingly similar and/or substantially indistinguishable version of Tory Burch's iconic "TT
Logo" trademark depicted below, which dilutes Tory Burch's registered and common law rights
in several respects.
UH
2.
For over a decade, Tory Burch, together with its authorized licensees, has used the
distinctive and famous TT Logo as its core branding element in connection with the sale of its
distinctive style of handbags, clothing, footwear, jewelry, and a variety of other products through
TORY BURCH retail boutiques, select high-end specialty stores and department stores, and online
at toryburch.com. Tory Burch owns many federal trademark registrations (some of which are
incontestable) for the TT Logo, and similar variations thereof, in connection with such products.
In addition, Tory Burch owns a federal copyright registration for the TT Logo.
3.
Tory Burch also uses and owns copyright registrations for the below-depicted "4T
Design" and "Lux T Jacquard Design."
J Li
4T Design
4.
Lux T Jacquard Design
Tory Burch has invested significant time, energy, and hundreds of millions of dollars
in the advertising, promotion, and offering of its goods and services under the TT Logo, 4T Design,
Lux T Jacquard Design, and other variations thereof (collectively, Tory Burch's TT Logo and its
variations are referred to herein as the "Tory Burch Trademarks," and the copyrighted designs of
the TT Logo, the 4T Design, and the Lux T Jacquard Design are referred to herein as the "Tory
Burch Copyrighted Designs").
5.
The TT Logo and/or other of the Tory Burch Trademarks and Copyrighted Designs
appear on virtually all of Tory Burch's products. The Tory Burch Trademarks and Tory Burch
Copyrighted Designs are closely and uniquely associated with the TORY BURCH brand and have
come to symbolize the high quality that consumers expect from Tory Burch as the source of such
products. Accordingly, Tory Burch enjoys strong consumer loyalty, recognition, and goodwill in
the Tory Burch Trademarks and Copyrighted Designs.
6.
The TT Logo in particular is famous, and embodies an enormous amount of goodwill,
which is a valuable asset of the company.
7.
Reflecting its popularity and iconic status, the TT Logo and other Tory Burch
Trademarks are often infringed and counterfeited, and Tory Burch enforces its rights through legal
actions. Tory Burch has spent significant resources protecting its trademarks and copyrighted
designs from infringers unlawfully and unfairly attempting to capitalize on Tory Burch's goodwill.
8.
Defendants are one such group, trading unfairly off of Tory Burch's goodwill and
pirating Tory Burch's intellectual property. In spite of Tory Burch's clear and longstanding rights
in the Tory Burch Trademarks in connection with handbags, footwear, clothing, jewelry, and other
products, Defendants have adopted confusingly similar designsthe "Infringing TT Logo" and
the "Infringing T Design" depicted belowand use them in connection with the unauthorized
manufacture, production, distribution, advertisement, offering for sale, and/or sale of counterfeit
products, including handbags, footwear, clothing, and jewelry (the "Infringing Products").
tkti PR mmmt H
tmrnt
4H4tHl
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4$$!
I
Infringing TTLogo
(as compared to the TTLogo and 4T Design)
mm til mm tit mm
Infringing T Design
(as compared to the Lux T Jacquard Design)
9.
As shown below, Defendants position the Infringing TT Logo and Infringing T Design
on their Infringing Productsproducts which themselves mimic the distinctive style of the Tory
Burch productsin the same size and manner as Tory Burch positions the Tory Burch Trademarks
and Copyrighted Designs on its products, including with the Infringing TT Logo in the same gold
tone used by Tory Burch, thereby conveying to consumers a product that has the same overall
commercial impression as Tory Burch products. To further the deliberate deception, Defendants
also use merchandise hangtags that feature an orange hue suspiciously similar to the distinctive
orange hue that is used by, and has come to be associated with, Tory Burch. Thus, the overall
manner in which Defendants design, market, and sell their Infringing Products replicates the Tory
Burch merchandising aesthetic and makes clear that Defendants' adoption and use ofthe Infringing
TT Logo and Infringing T Design is not merely a coincidence.
Genuine Tory Burch Clutch
Defendants' Infringing Clutch
Genuine Tory Burch Tote
Defendants' Infringing Tote
Genuine Tory Burch Tote
10.
Defendants' Infringing Tote
Defendants are not connected or affiliated with Tory Burch, nor do they have
permission from Tory Burch to use any ofthe Tory Burch Trademarks or Tory Burch Copyrighted
Designs or any other intellectual property belonging to Tory Burch. Rather, Defendants are
blatantly exploiting the Tory Burch Trademarks and Copyrighted Designs for Defendants' own
commercial gain, intending to confuse and deceive the public by drawing on Tory Burch's
goodwill in the marketplace. By using the Infringing TT Logo and Infringing T Design to sell the
Infringing Products that deliberately copy the style of the Tory Burch products, Defendants intend
to, and are likely to, cause confusion and deceive consumers and the public regarding the source
of Defendants' products, and to dilute the value of Tory Burch's intellectual property, all to the
detriment of Tory Burch.
11.
Defendants' infringement and dilution of the Tory Burch Trademarks, and
infringement of the Tory Burch Copyrighted Designs, has and will continue to irreparably harm
Tory Burch and the substantial goodwill it has developed in its brand. It also has and will continue
to cause monetary harm in an amount to be determined at trial.
PARTIES
12.
TB LLC is a Delaware limited liability corporation having its principal place of
business at 11 West 19th Street, 7th Floor, New York, New York 10011.
13.
River Light V, L.P. is a subsidiary of TB LLC, and is a Delaware limited partnership
having its principal placeof business at 11 West 19th Street, 7th Floor, New York, New York 10011.
River Light V, L.P. is the record owner of the intellectual property, including the Tory Burch
Trademarks and Tory Burch Copyrighted Designs at issue in the instant action, and licenses such
intellectual property exclusively to its affiliate TB LLC in the United States for use and sub
licensing in connection with TB LLC's business.
14.
Upon information and belief, defendant Top Fashion is a domestic entity located at 145
West 30th Street, Unit B, New York, New York 10001 and at 143 W 30th New York, New York
10001. Top Fashion may be served through its owner, operator, and co-managing agent, Cai Yan
Chen at 143 W 30th New York, New York 10001, or at 145 West 30th Street, Unit B, New York,
New York 10001 or at 251-23 57 Avenue, Little Neck, New York 11362, or through Top Fashion's
CEO and co-managing agent, Xing Hua Lin, at 143 W 30th New York, New York 10001, or at
145 West 30th Street, Unit B, New York, New York 10001.
15.
Upon information and belief, defendant Cai Yan Chen is an individual residing in New
York at 251-23 57 Avenue, Little Neck, New York 11362. Upon information and belief, Cai Yen
Chen is the owner, operator, and co-managing agent of defendant Top Fashion. Cai Yan Chen
may be served at 251-23 57 Avenue, Little Neck, New York 11362, or at 143 W 30th New York,
New York 10001, or at 145 West 30th Street, Unit B, New York, New York 10001.
JURISDICTION AND VENUE
16.
Tory Burch files this action against Defendants for trademark infringement,
counterfeiting, dilution, and cancellation under the Lanham Trademark Act of 1946, 15 U.S.C.
1051 et seq. (the "Lanham Act"), as well as for copyright infringement under 17 U.S.C. 101,
et seq., unfair competition and for related claims under the statutory and common law of the State
ofNew York. This Court has subject matter jurisdiction over the federal trademark infringement,
dilution, and cancellation claims, as well as the federal copyright infringement claims, under 28
U.S.C. 1331, 1338(a).
17.
This Court has supplemental jurisdiction over the state law claims in this action, which
arise under state statutory and common law pursuant to 28 U.S.C. 1367(a), since the state law
claims are so related to the federal claims that they form part of the same case or controversy and
derive from a common nucleus of operative facts.
18.
This Court has personal jurisdiction over Defendants because they are incorporated in,
regularly solicit and conduct business in, reside in, and/or are domiciled in this judicial district.
19.
Venue is proper in this district pursuant to 28 U.S.C. 1391(b) and (c) because this is
the judicial district where (i) a substantial part of the events or omissions giving rise to the claims
occurred; and (ii) where Defendants are subject to personal jurisdiction.
FACTS
The Famous TORY BURCH Brand
20.
Tory Burch launched in 2004 out of a small boutique in Manhattan's NoLita
neighborhood. In ten years, it has grown into a billion dollar fashion powerhouse with more than
2,000 employees and more than 100 Tory Burch stores worldwide. In addition, Tory Burch
operates a multi-channel business platform in more than fifty countries across four continents, and
the fashion line is carried at over 1,000 department and specialty stores worldwide, including such
well-known retailers as Saks Fifth Avenue, Bergdorf Goodman, Neiman Marcus, Nordstrom, and
Bloomingdale's.
21.
Bright and bold colors, including orange in particular, are an integral part ofthe overall
aesthetic of the TORY BURCH brand.
For example, Tory Burch boutiques are instantly
recognizable by their oversized orange lacquered doors. And Tory Burch's packaging, tags, and
other point-of-sale materials incorporate bright and bold colors and designs, including the color
orange and the 4T Design.
The TT Logo
22.
Tory Burch's distinctive TT Logo is the heart of the TORY BURCH brand. It is used
in connection with handbags, including totes, cross-body bags, clutches, shoulder bags, evening
bags, and coordinating wallets and wristlets, as well as a variety of other products, including
clothing, footwear, jewelry, and housewares. The Tory Burch products represent a distinctive style
aesthetic that has been described as "preppy-bohemian." Exh. 1. The following are examples of
the TT Logo depicted on Tory Burch handbags, footwear, jewelry, and accessories.
f "^
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23.
Tory Burch filed its first federal trademark application to register the TT Logo on
September 23, 2003, and began using the TT Logo in connection with handbags, clothing, and
footwear, among other items, in February of 2004. Tory Burch owns common law rights in and
incontestable federal trademark registrations for the TT Logo in connection with such goods and
related services (see trademark registration summary chart below).
Tory Burch also owns a
copyright registration for the TT Logo (U.S. Reg. No. VA 1-768-387), with a year of creation of
2003 and a date of first publication of February 1, 2004). Exh. 2.
24.
Tory Burch also owns numerous other trademark registrations for the TT Logo and
variations thereof (collectively, the "Tory Burch Registered Trademarks") in connection with a
variety of goods and services, including handbags, clothing, footwear, and jewelry. The following
chart contains the details of many of the registrations for the Tory Burch Registered Trademarks.
\ Mark
Status
Goods/Services
04: Candles
tSm\
Kg)
Registration
Reg. No. 3029795
First Use 2/1/04
Reg. Date 12/13/05
14: Jewelry
18: Accessories, namely, handbags, umbrellas and
cosmetic bags sold empty
24: Housewares, namely, towels
25: Clothing, namely, shirts, tops, sweaters, pants,
skirts, shorts, dresses, bathing suits, bikinis, sarongs,
shoes, socks, belts, robes and headwear; outerwear,
namely, scarves, jackets, vests, and coats
Mark
Status
Registration
Reg. No. 3024142
First Use 2/8/04
Goods/Services
35: Retail clothing apparel and accessories stores
Reg. Date 12/6/05

Registration
Reg. No. 3563326
First Use 2/1/04
18: A full line of handbags

25: A full line of women's clothing and footwear
Reg. Date 1/20/09

Registration
Reg. No. 4029068
First Use 1/1/08
25: Socks, robes
Reg. Date 9/20/11

Registration
Reg. No. 4129090
First Use 10/31/08
06: Metal key chains
Reg. Date 4/17/12

Registration
Reg. No. 4150523
First Use 10/31/08
18: Leather key chains
Reg. Date 5/29/12

Registration
Reg. No. 4276065
First Use 9/30/08
16: Calendars, note cards, passport covers, pen and

pencil cases, pencils, stationery
Reg. Date 1/15/13

Registration
Reg. No. 4432775
First Use 9/6/13
Reg. Date 11/12/13

Registration
Reg. No. 4045568
First Use 10/21/09
03: Cologne; cosmetic preparations for body care;

cosmetics; fragrances for personal use; nonmedicated skin care preparations; perfumes
09: Eyewear; eyewear cases
Reg. Date 10/25/11

Registration
Reg. No. 4213404
First Use 10/31/08
Reg. Date 9/25/12
18: Backpacks; Beach bags; Business card cases;

Coin purses; Dog collars; Dog leashes; Overnight
bags; Pet clothing; Wallets; Wristlet bags
10
Mark
Registration
Reg. No. 4213405
Kg)
-It*
"3P
Goods/Services
Status
First Use 10/31/09
Reg. Date 9/25/12

Registration
Reg. No. 4459720
First Use 6/30/12
09: Cell phone cases; Leather protective covers

specially adapted for personal electronic devices;
Protective covers and cases for cell phones, laptops
and portable media players
18: Backpacks; Cosmetic cases sold empty;
Handbags; Leather pouches; Tote bags
Reg. Date 12/31/13

Registration
Reg. No. 4365683
"3E"
First Use 3/31/13
25: Belts; footwear
Reg. Date 7/9/13
n3G.
"31?
Registration
Reg. No. 4242007
First Use 11/30/09
09: Eyewear
Reg. Date 11/13/12
hXh
T
hXh
Registration
Reg. No. 4382707
First Use 1/31/11
Reg. Date 8/13/13

Registration
Reg. No. 4363739
First Use 1/31/11
hXi.
"X"
-JC,
"X"
Reg. Date 7/9/13

Registration
Reg. No. 4317165
First Use 8/31/07
Reg. Date 4/9/13

Registration
Reg. No. 4345875
First Use 8/31/07
Reg. Date 6/4/13
09: Cell phone cases; Eyewear; Leather protective

covers specially adapted for personal electronic
devices; Protective covers and cases for cell phones,
laptops and portable media players; Sunglasses
14: Jewelry
18: Business card cases; Cosmetic cases sold empty;

Handbags; Leather pouches; Luggage; Purses; Tote
bags; Umbrellas; Wallets; Wristlet bags
25: Belts; Dresses; Footwear; Hats; Jackets;
Pajamas; Pants; Scarves; Shirts; Skirts; Sweaters;
Swimwear
The above-identified registrations are valid, subsisting, and in full force and effect. Exh. 3.
The 4T and Lux T Jacquard Designs
25.
Since 2004, Tory Burch also has used the following 4T Design, which conforms to the
Tory Burch design style aesthetic, in connection with a variety of goods and services, including
handbags, clothing, and footwear.
11
26.
Below is an example of a Tory Burch shopping bag bearing the 4T Design.
27.
Tory Burch owns copyright registrations for the 4T Design (Reg. Nos. VA 1-812-667,
with a year of completion of 2003 and a date of first publication of February 27, 2004, and VA 1655-281, with a year of completion of 2003 and a date of publication of February 29, 2004). Exh.
4.
28.
Since at least as early as 2008, Tory Burch has also used the following Lux T Jacquard
Design in connection with handbags, clothing, and footwear, and has obtained a copyright
registration for that design (Reg. No. VA 1-655-228, with a year of completion of 2006 and a date
of first publication of November 30, 2007). Exh. 5. Among other uses, Tory Burch has also
12
featured the Lux T Jacquard Design as a repeating pattern on the exterior and/or interior of its
handbags.
Brand Significance
29.
Over the past decade, the Tory Burch Trademarks, the Tory Burch Copyrighted
Designs, and the TORY BURCH brand have seen a meteoric rise in recognition and popularity.
See River Light V, L.P. v. Lin&JInt'l, Mr., No. 13-Civ-3669,2014 WL 6850966, at *1 (S.D.N.Y.
Dec. 4, 2014) (granting Tory Burch's motion for summary judgment as to defendant's liability for
trademark infringement and noting that TORY BURCH is a "well-known fashion brand"). In
2013 alone, Tory Burch earned sales revenues in excess of $900 million. Moreover, Tory Burch
has invested hundreds of millions of dollars in marketing and advertising its goods, marks, and
designs.
30.
The TORY BURCH brand has a strong media presence, and is frequently covered by
fashion blogs, magazines, newspapers, and talk shows. One of the earliest defining moments for
Tory Burch was in 2005 when Oprah Winfrey endorsed the brand on her talk show; immediately
after Oprah's endorsement, the Tory Burch website received over eight million hits. Exh. 6. The
popular television series Gossip Girl frequently features Tory Burch products (and Ms. Tory Burch
herself made a cameo appearance in an episode in 2009). Exh. 7.
31.
Social media platforms are constantly active with buzz about the TORY BURCH
brand, with fans posting photos ofrecent purchases, commenting on current and future collections,
and "pinning" photos of desired products on Pinterest. The TORY BURCH brand has over
13
1,300,000 likes on Facebook and Ms. Tory Burch has over 670,000 followers on Instagram and
over 341,000 followers on Twitter. Exh. 8.
32.
TORY BURCH brand products are particularly popular among the fashion conscious
and celebrity trend-setters. Celebrities frequently seen wearing TORY BURCH products include
Blake Lively, Oprah Winfrey, Jennifer Lopez, Rashida Jones, Jessica Alba, Hilary Swank, Sarah
Jessica Parker, Reese Witherspoon, Pippa Middleton, and Anne Hathaway. Exh. 9. Recently,
Kate Middleton was photographed wearing a graphic print TORY BURCH dress during a "play
date" with Prince George in New Zealand, and the dress sold out almost immediately on Tory
Burch's website and every other online retailer, including Nordstrom.com, Bloomingdales.com,
and Net-a-Porter. Exh. 10. On another occasion, Michelle Obama wore an aqua blue tie-dye
TORY BURCH dress to an event in Watertown, Wisconsin; within days, the dress sold out on the
Tory Burch website and other online retailers such as Shopbop. Exh. 11.
33.
Not surprisingly, Tory Burch has received many awards and accolades, including
(i) the 2008 Accessories Designer of the Year award from the Council of Fashion Designers of
America; (ii) the 2007 Accessory Brand Launch of the Year award from the Accessories Council
of Excellence; and (iii) the 2005 Rising Star Award for Best New Retail Concept from Fashion
Group International. Exh. 12.
34.
The TT Logo in particular is frequently the subject of unsolicited media coverage and
has been repeatedly recognized for its popularity and iconic status:
"iconic double-T medallion" ("Pretty Smart," Fast Company, September 2014);
"now instantly recognizable double T logo" (Rubenstein, Hal, "The Tory Effect,"
Delta Sky, May 2014);
"It's the double T medallion that has women screaming..." (NBC Today Show,
September 26, 2013);
"distinctive double-T logo" (Forbes, Moira, "Tory Burch's Seven Lessons for
Entrepreneurs," Forbes, May 22, 2013);
14
"a stacked-T logo as instantly recognizable as those of brands established
generations prior" (Gaffney, Adrienne, "Tory Burch," The Wall Street Journal,
October 26, 2012);
"the iconic Tory Burch logo" ("Madder Men," Forbes, May 7, 2012);
"bold prints and the double-T logo medallion are hallmarks of the affordable
luxury Tory Burch brand" (Amato-McCoy, Deena M., "Tory Burch," Apparel,
May 1,2012);
"[The Tory Burch] line, with its distinctive double T logo, is now in hundreds of
department stores" (CBS News Sunday Morning, January 29, 2012);
"But the foundation of Burch's brand is her logo, two graphically styled T's.
The logo has shaped Burch's concept from the beginning and is one of the most
recognizable fashion icons."

November 10,2011);
("Designer Tory Burch Resonates with Us,"
the "signature double-T medallion" (Sapienza, Terri, "Clothes to Home with Tory
Burch," The Denver Post, October 24, 2011);
"the near-ubiquitous double-T logo" (Cardwell, Diane, "Where Fashion Types

Talk of Summer Travel," New York Times, June 25, 2011); and
"The famous double T LOGO ... is Tory Burch's most famous . . ." (Urban
Dictionary, "Tory Burch").
Exh. 13.
35.
As a result of Tory Burch's extensive use and promotion of its brand for over a decade,
the Tory Burch Trademarks and Copyrighted Designs, including the famous TT Logo, have
acquired considerable value and recognition; are symbols of Tory Burch's quality, reputation, and
goodwill; and serve as instant source-identifiers for Tory Burch's products and services. See Lin
& J, 2014 WL 6850966, at *1 (noting Tory Burch's continuous use and extensive promotion of
the TT Logo as a source identifier for many of its products since 2004).
Quality Control and Brand Protection
36.
Tory Burch's products are distributed through a carefully controlled network of
authorized retailers, including high-end department stores, select quality boutiques, more than 100
TORY BURCH retail boutiques, and Tory Burch's website. See Lin & J, 2014 WL 6850966, at
15
*2 (noting that sales of TORY BURCH brand products are limited to a network of authorized
retailers).
37.
Tory Burchmaintains strict quality control standards for all of its products. SeeLin &
J, 2014 WL 6850966, at *2 (notingTory Burch's strict quality control standards). Such control is
necessary, as the TORYBURCH brand, similar to otherhigh-end brands with recognizable logos,
is the subject of counterfeiting and trademark infringement. Since its inception, Tory Burch has
spent significant resources to protect its rights in the Tory Burch Trademarks and Tory Burch
Copyrighted Designs, including but not limited to legal actions and seizures of counterfeit goods.
Defendants and Their Infringing Conduct
38.
Defendant Top Fashion is a handbag, clothing, footwear, and accessory wholesale
outlet located in midtown Manhattan. Defendant Cai Yan Chen licenses the Infringing TT Logo
and Infringing T Design to Defendant Top Fashion for use in connection with its infringing
products.
39.
Defendant Cai Yan Chen has a history of capitalizing on the renown of famous brands.
For example, Cai Yan Chen applied to federally register a check design trademark highly similar
to Burberry's famous checkdesign(Ser. No. 85/374,777). Exh. 14. After Burberry filed a Notice
of Opposition against Cai Yan Chen's application through the TTAB (No. 91204544), Cai Yan
Chen abandoned the application. Exh. 15. Defendant Cai Yan Chen also owns two trademark
registrations (Reg. Nos. 4,320,008 and 4,320,009) for design marks arguably confusingly similar
to Louis Vuitton's famous "quatrefoil" design. Exh. 16.
40.
In late 2012, Tory Burch learned that Top Fashion was selling handbags mimicking the
distinctive design and style of Tory Burch's handbags, and bearing the Infringing TT Logo and
Infringing T Design that are substantially indistinguishable from and confusingly similar to the
16
Tory Burch Trademarks and Tory Burch Copyrighted Designs, including the TT Logo, 4T Design,
and Lux T Jacquard Design (see product comparison chart below).
41.
Over the course of multiple visits to Top Fashion's store since that time, Tory Burch's
agents have observed and identified hundreds of handbags, wallets, makeup bags and belts
containing the Infringing TT Logo and/or Infringing T Design on display. Defendants sell as both
on a retail and wholesale basis. Upon information and belief, Defendants distribute the Infringing
Products wholesale to dozens of retailers throughout the country. The chart below demonstrates
Defendants' unlawful activity by comparing examples of genuine Tory Burch handbags to
Defendants' unauthorized reproductions of the Infringing TT Logo and Infringing T Designs on
infringing handbags.
Genuine Tory Burch Handbags
Defendants' Infringing Handbags
*~mmmmm%WmmMmmmmmmmmWmmWI*t
17
Genuine Tory Burch Handbags
Defendants' Infringing Handbags
18
2012-2013 Correspondence
42.
Tory Burch sent a cease-and-desist letter to Top Fashion on October 12, 2012,
(i) explaining Tory Burch's intellectual property rights in its TT Logo, 4T Design, and Lux T
Jacquard Design; (ii) identifying Defendants' infringing conduct (use of the Infringing TT Logo
and Infringing T Design in their sale of infringing products); and (iii) demanding, among other
things, that Defendants immediately and permanently cease and desist their unlawful conduct.
Exh. 17.
43.
On October 15,2012, Tory Burch receiveda response letter from Top Fashion,via Lin
Xing Hua (President of Top Fashion), refusing to comply with thedemands made in Tory Burch's
letter. Exh. 18. Top Fashion asserted that it was not unlawfully using Tory Burch's intellectual
property. Id. Top Fashion indicated further that the Infringing TT Logo was licensed to Top
Fashion by an individual named Cai Yan Chen, who owns a federal trademark registration for the
Infringing TT Logo. Id.
44.
Cai Yan Chen's federal trademark application for the Infringing TT Logo in connection
with "handbags, shoulderbags, backpacks, purses, tote bags, luggage,clutch purses, garmentbags
for travel, evening bags, and wallets" in Class 18 was filed on July 8, 2011 and claimed a first use
date of June 1, 2011; it matured to registration on February 21, 2012 (Reg. No. 4,102,185). Exh.
19.
45.
Cai Yan Chen also applied to register the Infringing T Design as a trademark in
connection with leather for use in the manufacture ofproducts including handbags, claiming a first
use date of June 1, 2011; however, the USPTO ultimately refused to register Cai Yan Chen's
application on the basis of a likelihood of confusion with Tory Burch's TT Logo. Exh. 20. Top
19
Handbag did not respond to the USPTO's refusal, and the application therefore became abandoned.
Id.
46.
On November 20,2012, Tory Burch responded to Top Fashion's letter, explaining that
Top Fashion's conduct is infringing and unlawful, regardless of whether Cai Yan Chen had
obtained a federal trademark registration. Exh. 21. Tory Burch reiterated its demands from its
October 12, 2012 letter, and noted further that Top Fashion's letter failed to address how its
infringement of Tory Burch's copyright in the Lux T Jacquard Design. Id.

M.
The parties exchanged correspondence throughout the remainder of 2012 and into
2013, and based on that correspondence, Tory Burch believed that Top Fashion stopped selling
the Infringing Products. However, as explained in more detail below, Tory Burch recently learned
that Defendants continue to sell the Infringing Products in blatant disregard of Tory Burch's
intellectual property.
Top Fashion's Recent and Current Activities
48.
In the first half of 2014, third parties, including agents from U.S. Customs and Border
Protection, began sending Tory Burch inquiries regarding the legitimacy of Top Fashion's
products.
Tory Burch then conducted an investigation and discovered that, contrary to its prior
understanding, Top Fashion was in fact continuing to sell the Infringing Products.
49.
First, on June 17,2014, an investigator for Tory Burch entered defendant Top Fashion's
location at 143 West 30th Street, New York, New York 10001 and purchased a handbag bearing
the Infringing TT Logo for $30.00. The investigator paid cash and was given a business card that
read, among other things "TOP FASHION, INC. Handbag Wholesale."
50.
On August 28, 2014, an investigator for Tory Burch visited the same Top Fashion
location and observed several handbags bearing the Infringing TT Logo openly displayed for
20
purchase. The investigator purchased two handbags and two wallets for a total price of$90.00
and paid cash.
51.
On January 9,2015, Tory Burch's investigator visited Top Fashion and observed over
seven hundred (700) Infringing Products openly displayed and available for purchase, including
handbags, wallets, makeup bags, and belts bearing the Infringing TT Logo. The investigator
purchased eleven Infringing Products, including seven handbags, two wallets, one makeup bag,
and one beltall of which bear the Infringing TT Logo.
52.
Further, notwithstanding its knowledge of Tory Burch's clear prior rights, Defendants
have apparently expanded their product line to include clothing, shoes, jewelry, and other
accessories. Indeed, on July 18,2014, Cai Yan Chen filed twonew federal trademark applications
for theInfringing TTLogo in connection with "Dresses, skirts, tunics, sweaters, tops, shorts, pants,
jackets, denim, outwear, belts, hats, scarves, gloves, swimwear and shoes, namely, heels, flats,
wedges, slippers, loafers, sneakers, sandals, flip-flops, boots and espadrilles" in Class 25 (Ser. No.
86/341,327) and "jewelry and watches" in Class 14 (Ser. No. 86/341,253), with both applications
claiming a first use date of August 1, 2011. Exh. 22. The Trademark Office recently approved
the '253 application for publication. Id. The following photographs illustrate Defendants' use of
the Infringing TT Logo in several expanded categories of goods:
Defendants' Infringing Footwear
Genuine Tory Burch Footwear
21
Defendants' Infringing Jewelry
Genuine Tory Burch Jewelry
Genuine Tory Burch Belt
53.
Defendants'Infringing Belt
Because Cai Yan Chen's application for the Infringing TT Logo in connection with
handbags wrongly matured to registration, and its application for the Infringing TT Logo in
connection with jewelry and watches was wrongly approved for publication, in light of Tory
Burch's longstanding and incontestable rights for nearly identical trademarks for identical goods
and services, Tory Burch (i) filed a Petition to Cancel the registration with the Trademark Trial
and Appeal Board; (ii) filed aNotice ofOpposition against the application for jewelry and watches;
(iii) intends to file a Notice of Opposition against theapplication for clothing and footwear, if and
when it is approved for publication; and (iv) intends to file a Motion to Stay the Trademark Trial
and Appeal Boardproceedings during the pendency of this action.
22
54.
As shown above, Defendants use a combination of elements so reminiscent of the
TORY BURCH brand and Tory Burch products that it is clear they are willfully executing a
calculated scheme to unlawfully trade off the goodwill of the famous TORY BURCH brand. In
addition to their adoption and use of the Infringing TT Logo and Infringing T Design, Defendants:
Position the Infringing TT Logo on their Infringing Products in the same size and manner
as Tory Burch positions the TT Logo on its products, and use the Infringing TT Logo in
the same gold tone Tory Burch is famous for:
Genuine Tory Burch Clutch
Defendants' Infringing Clutch
Position the Infringing T Design on their Infringing Products in the same size and manner
as Tory Burch positions the Lux T Jacquard Design on its products:
Genuine Tory Burch Tote Defendants' Infringing Tote
Sell products that are substantially similar to Tory Burch's most popular products (e.g., the
popular "Reva flat" depicted below):
^^tf|P
Genuine Tory Burch Reva Flat
Defendants' Infringing Reva Flat
23
Use an orange hue on their merchandise hangtags that is suspiciously similar to the
distinctive orange hue used by Tory Burch:
Defendants' Use of Orange
Distinctive Tory Burch Orange
55.
"I" " """'ix '
Defendants are not authorized and have never been authorized by Tory Burch to
produce, manufacture, distribute, advertise, offer for sale, and/or sell products bearing the TT
Logo, 4T Design, Lux T Jacquard Design, or any variation thereof.
56.
Upon information and belief, Defendants' Infringing Products are of a quality inferior
to Tory Burch's genuine products.
57.
Upon information and belief, Defendants are aware of the extraordinary fame and
strength ofthe TORY BURCH brand and the Tory Burch Trademarks and Copyrighted Designs,
including the iconic TT Logo, and the goodwill associated therewith. Upon information and belief,
Defendants had access to the Tory Burch Trademarks and Copyrighted Designs prior to
Defendants' creation and sale of the Infringing Products.
24
58.
Upon information and belief, Defendants are actively using, promoting, and otherwise
advertising, distributing, selling, and/or offering for sale substantial quantities of Infringing
Products with theknowledge that such goods will be mistaken for genuine Tory Burch products.
59.
Upon information and belief, at all relevant times, Defendant Cai Yan Chen, who has
been doing business in his individual capacity, and as the owner of the Infringing TT Logo and
Infringing TDesign, contributed directly tothese infringing acts by knowingly allowing Defendant
Top Fashion to display and offer the Infringing Products. Upon information and belief, Defendant
Cai Yan Chen personally participated in, directed, and/or had the ability and right to supervise,
direct, and control the infringing activities alleged in this Complaint. Defendant Cai Yan Chen
had an obligation and ability to control and stop these infringements, but failed to do so. Upon
information and belief, Defendant Cai Yan Chen has received, and continues to receive, direct
financial benefits from these acts of infringement. These acts and omissions to act by Defendant
Cai Yan Chen materially contributed to and proximately caused the infringement alleged herein.
60.
Upon information and belief, Defendants are conducting their counterfeiting and
infringing activities within thisjudicial district and elsewhere throughout New York.
61.
Defendants' use of unauthorized reproductions of the Tory Burch Trademarks and
Copyrighted Designs in connection with the manufacturing, advertising, promoting, distributing,

offering for sale, and/or selling of the Infringing Products is likely to cause confusion, deception,
and mistake in the minds of consumers, the public, and the trade. Defendants' wrongful conduct
is likely to create a false impression anddeceive consumers, thepublic, andthetrade into believing
there is a connection or association between genuine Tory Burch products and Defendants'
Infringing Products.
25
62.
Defendants are engaging in the above-described illegal counterfeiting knowingly and
intentionally, or with reckless disregard or willful blindness to Tory Burch's rights for the purpose
of trading on the goodwill and reputation of Tory Burch. If Defendants' intentional counterfeiting
and infringing activities are not permanently enjoined by this Court, Tory Burch and the
consuming public will continue to be damaged.
63.
Tory Burch is suffering irreparable injury and has suffered substantial damage as a
result of Defendants' counterfeiting and infringing activities.

64.
Tory Burch has no adequate remedy at law.

FIRST CLAIM FOR RELIEF
(Trademark Infringement - 15 U.S.C. 1114)
65.
Tory Burch incorporates herein by reference the averments ofthe preceding paragraphs
as though fully set forth herein.
66.
The Tory Burch Registered Trademarks are nationally recognized, including within
this judicial district, as being affixed to goods originating with Tory Burch.
67.
As described above, Tory Burch owns the distinctive Tory Burch Registered
Trademarks, including the TT Logo, all in connection with a variety of goods and services
including clothing, footwear, handbags, and jewelry.
68.
The registrations embodying the Tory Burch Registered Trademarks, several of which
are incontestable, are in full force and effect, and are entitled to protection under both federal law
and common law.
69.
Tory Burch's ownership and exclusive use in commerce of the TT Logo and other Tory
Burch Registered Trademarks predates the use by Defendants of their Infringing TT Logo and
Infringing T Design.
26
70.
Defendants use the Infringing TT Logo and Infringing T Design in interstate commerce
in connection with the sale, offering for sale, distribution, and/or advertising of their Infringing
Products.
71.
Defendants' use of the Infringing TT Logo and Infringing T Design is without Tory
Burch's permission or authority and is in total and willful disregard of Tory Burch's rights to
control its trademarks.
72.
Defendants' unauthorized use in commerce of the Infringing TT Logo and Infringing
T Design, as described above, constitutes trademark infringement in violation of 15 U.S.C. 1114

in that it is without Tory Burch's consent and is likely to cause confusion, mistake, and/or
deception among consumers.
73.
Upon information and belief, Defendants are and were at all relevant times both
actually and constructively aware of Tory Burch's prior use, ownership, and registration, and
Defendants' conduct is therefore willful and intentional and intended to confuse the public as to
the source of Defendants' products, and to injure Tory Burch and reap the benefit of Tory Burch's
goodwill associated with the Tory Burch Registered Trademarks.
74.
As a direct and proximate result of Defendants' willful and unlawful conduct in
violation of 15 U.S.C. 1114, Tory Burch has been damaged and will continue to be damaged.
75.
Upon information and belief, Defendants have realized, and continue to realize,
substantial revenues, profits, and other benefits rightfully belonging to Tory Burch as a result of
their wrongful conduct.
76.
Defendants' conduct has caused, is causing, and will continue to cause Tory Burch to
suffer irreparable harm and, unless Defendants are restrained, Tory Burch will continue to be so
damaged, because it has no adequate remedy at law.
27
77.
In light of the foregoing, Tory Burch is entitled to injunctive relief prohibiting
Defendants from using the Tory Burch Registered Trademarks or any marks identical and/or
confusingly similar thereto for any purpose, and to recover from Defendants all damages, including
attorneys' fees, that Tory Burch has sustained and will continue to sustain as a result of such
infringing acts, and all gains, profits and advantages obtained by Defendants as a result thereof, in
an amount not yet known, as well as the costs of this action pursuant to 15 U.S.C. 1117(a),
attorneys' fees and treble damages pursuant to 15 U.S.C. 1117(b), and/or statutory damages
pursuant to 15 U.S.C 1117(c).
SECOND CLAIM FOR RELIEF
(Trademark Counterfeiting - 15 U.S.C. 1114)
78.

79.
As described above, Tory Burch owns the distinctive Tory Burch Registered
Trademarks, including the TT Logo, all in connection with a variety of goods and services
including clothing, footwear, handbags, and jewelry.
80.
The registrations embodying the Tory Burch Registered Trademarks, several of which
are incontestable, are in full force and effect, and are entitled to protection under both federal law
and common law.
81.
Tory Burch's ownership and exclusive use in commerce ofthe TT Logo and other Tory
Burch Registered Trademarks predates the use by Defendants of their Infringing TT Logo.
82.
Defendants, without authorization from Tory Burch, have used and are continuing to
use spurious designations that are identical to, or substantially indistinguishable from, the Tory
Burch Registered Trademarks, including the TT Logo, in interstate commerce.
28
83.
Defendants' unauthorized use of the Infringing TT Logo and Infringing T Design is
without Tory Burch's permission or authority and is in total and willful disregard of Tory Burch's
rights to control its trademarks.
84.
The foregoing acts of Defendants are intended to cause, have caused, and are likely to
continue to cause confusion or mistake, or to deceive consumers, the public, and the trade into
believing that Defendants' Infringing Products are genuine or authorized by Tory Burch.
85.
Defendants' acts constitute trademark counterfeiting in violation of 15 U.S.C. 1114.
86.
goodwill associated with the Tory Burch Registered Trademarks.
THIRD CLAIM FOR RELIEF
(False Designation of Origin & False Description - 15 U.S.C. 1125(a))
87.
88.
As described above, Tory Burch owns the distinctive Tory Burch Trademarks, all in
connection with a variety of goods and services, including clothing, footwear, handbags, and
jewelry.
89.
Tory Burch's ownership and exclusive use in commerce ofthe Tory Burch Trademarks
predates the use by Defendants of their Infringing TT Logo and Infringing T Design.
29
90.
Products.
91.
92.
T Design, and advertising of the same, as described above, constitutes false designation of origin
in violation of 15 U.S.C. 1125(a)(1)(A) in that it is likely to cause confusion, to cause mistake,
or to deceive as to the affiliation, connection, or association of Defendants with Tory Burch and/or
as to the origin, sponsorship, or approval by Tory Burch of Defendants' goods, services, or
commercial activity.
93.
goodwill associated with the TT Logo.
94.
As a direct and proximate result of Defendants' willful and unlawful conduct in
violation of 15 U.S.C. 1125, Tory Burch has been damaged and will continue to be damaged.
95.
30
96.
97.
Defendants from using the Tory Burch Trademarks, or any marks confusingly similar thereto, and
to recover all damages, including attorneys' fees, that Tory Burch has sustained and will sustain,
and all gains, profits and advantages obtained by Defendants as a result of their infringing acts
alleged above in an amount not yet known, as well as the costs of this action.
FOURTH CLAIM FOR RELIEF
(Trademark Dilution -15 U.S.C. 1125(c))
98.
99.
As described above, Tory Burch owns the distinctive and federally registered TT Logo
in connection with a variety of goods and services, including clothing, footwear, handbags, and
jewelry.
100.
Tory Burch's ownership and exclusive use in commerce of the TT Logo predates the
use by Defendants of their Infringing TT Logo and Infringing T Design.
101.
Through consistent and continued use, product promotion, and consumer and industry
recognition, Tory Burch has developed the TT Logo to the point it is "famous" within the meaning
ofthe Lanham Act. Defendants did not begin using the Infringing TT Logo or Infringing T Design
in commerce until after Tory Burch's TT Logo became famous.
31
102.
Products.
103.
104.
Defendants' unauthorized use of the Infringing TT Logo and Infringing T Design in
the context of counterfeit products identical to Tory Burch's products is likely to cause dilution
(by blurring and tarnishment) of the distinctive qualities of the TT Logo in violation of 15 U.S.C.
1125(c).
105.
goodwill associated with the TT Logo and other Tory Burch Trademarks.
106.
As a direct and proximate result of Defendants' violations of 15 U.S.C. 1125, Tory
Burch has been and will continue to be damaged.

107.
108.
32
109.
Defendants from using the TT Logo, and to recover all damages, including attorneys' fees, that
Tory Burch has sustained and will sustain, and all gains, profits and advantages obtained by
Defendants as a result of their infringing acts alleged above in an amount not yet known, as well
as the costs of this action.
FIFTH CLAIM FOR RELIEF
(Copyright Infringement - 17 U.S.C. 101, etseq.)
110.
ToryBurchincorporates hereinby reference the averments of the preceding paragraphs
111.
Tory Burchowns valid copyrightregistrations in the Tory Burch Copyrighted Designs.
112.
Tory Burchhas compliedin all respects with the CopyrightAct and with all other laws
governing copyright in connection with its registered works. Tory Burch is the proprietor of all
rights, title, and interest to the Tory Burch Copyrighted Designs.
113.
As the owner of the Tory Burch Copyrighted Designs, Tory Burch is entitled to
exclusive use of these designs without unauthorized use of the Tory Burch Copyrighted Designs
by third parties.
114.
Given the widespread popularity of the Tory Burch products bearing the Tory Burch
Copyrighted Designs, Defendants had access to saidcopyrighted worksand, upon information and
belief, Defendants have knowingly infringed upon said designs by manufacturing, distributing,
advertising, and selling identical and/or substantially similar copies of the designs to the public in
violation of 17 U.S.C. 501.
115.
Upon information and belief, Defendants have intentionally, knowingly, and willfully
copied the Tory Burch Copyrighted Designs in order to personally benefit from the widespread
33
customer recognition and acceptance of said designs, and to capitalize upon the market created by
said designs.
116.
Upon information and belief, the aforesaid infringements by Defendants of the Tory
Burch Copyrighted Designs occurred and continue to occur with Defendants' knowledge that such
designs are copyrighted, and Defendants, in committing the acts complained of herein, have
willfully infringed upon Tory Burch's rights under the Copyright Laws of the United States, Title
17 U.S.C. 101, etseq.
117.
118.
119.
Defendants from using Tory Burch's copyrighted works, including the Tory Burch Copyrighted
Designs, and to recover from Defendants all damages, including attorneys' fees, that Tory Burch
has sustained and will sustain as a result of such infringing acts, and all gains, profits and
advantages obtained by Defendants as a result thereof, in an amount not yet known, as well as the
costs of this action pursuant to 17 U.S.C. 504(b) or statutory damages pursuant to 17 U.S.C.
504(b), and attorneys' fees and treble damages pursuant to 17 U.S.C. 505(b).
34
SIXTH CLAIM FOR RELIEF
(Dilution and Injury to Business Reputation - NY General Business Law 360-1)
120.
Tory Burch incorporates herein by reference the averments of the preceding paragraphs

121.
As described above, Tory Burch owns the distinctive TT Logo in connection with a
variety of goods and services, including clothing, footwear, handbags, and jewelry.
122.
Through consistent and continued use, product promotion (including in New York),
and consumer and industry recognition, Tory Burch has developed the TT Logo to the point it is
"famous" within the meaning of the Lanham Act. Defendants did not begin using the Infringing
TT Logo or Infringing T Design in commerce until after Tory Burch's TT Logo became famous.
123.
Tory Burch's ownership and exclusive use in commerce of the TT Logo predates the
use by Defendants of their Infringing TT Logo and Infringing T Design.

124.
Products.
125.
126.
Defendants' unauthorized use of the Infringing TT Logo and Infringing T Design in
the context of counterfeit products identical to Tory Burch's products is likely to cause dilution
(by blurring and tarnishment) of the distinctive qualities of the TT Logo in violation of New York,
General Business Law 360-1.
35
127.
the source of Defendants' products, and to injure Tory Burch and reap the benefitof Tory Burch's
goodwill associated with the TT Logo and other Tory Burch Trademarks.
128.
By the acts described above, Defendants have caused and will continue to cause
irreparable injury to Tory Burch's goodwill and business reputation, in violation of New York,
General Business Law 360-1.
129.
As a direct and proximate result of Defendants' violations of New York, General
Business Law 360-1, Tory Burch has been and will continue to be damaged.
130.
131.
damaged because it has no adequate remedy at law.
132.
Defendants from using the TT Logo and variations thereof, and to recover all damages, including
attorneys' fees, that Tory Burch has sustained and will sustain, and all gains, profits and advantages
obtained by Defendants as a result of their infringing acts alleged above in an amount not yet
known, and the costs of this action.
36
SEVENTH CLAIM FOR RELIEF
(New York Statutory and Common Law Trademark Infringement N.Y. Gen. Bus. L. Sec. 360-o)
133.
Tory Burch incorporates herein by reference theaverments of thepreceding paragraphs
134.
As described above, Tory Burch owns the Tory Burch Trademarks in connection with
a variety of goods and services, including clothing, footwear, handbags, and jewelry.
135.
Tory Burch's ownership andexclusive use in commerce of the Tory Burch Trademarks
136.
Defendantsuse the InfringingTT Logo and Infringing T Design in interstate commerce
Products.
137.
Defendants' use of the Infringing TT Logo & Infringing T Design is without Tory
138.
T Design, as described above, is likely to cause confusion among relevant consumers.

139.
Defendants' acts constitute trademark infringement in violation of the law of the State
of New York.
140.
goodwill associated with the Tory Burch Trademarks.
37
141.
As a direct and proximate result of Defendants' trademark infringement in violation of
the law of the State of New York, Tory Burch has been and will continue to be damaged.
142.
143.
EIGHTH CLAIM FOR RELIEF
(New York Common Law Unfair Competition

and Misappropriation of Intellectual Property Rights)
144.
145.
As described above, Tory Burch owns the distinctive Tory Burch Trademarks in
connection with a variety of goods and services, including clothing, footwear, handbags, and
jewelry.
146.
Tory Burch's ownership and exclusive use in commerce of the Tory Burch Trademarks
147.
The above-described acts, including Defendants' adoption and use of the confusingly
similar Infringing TT Logo and Infringing T Design, constitute common law unfair competition
and misappropriation of Tory Burch's intellectual property rights.
148.
Defendants misappropriated the labors and expenditures of Tory Burch in bad faith.
149.
As
a direct and
proximate result of Defendants'
unfair competition and
misappropriation, Tory Burch has been and will continue to be damaged.
38
150.
151.
NINTH CLAIM FOR RELIEF
(Unjust Enrichment)
152.
ToryBurch incorporates hereinby reference the averments of the preceding paragraphs
153.
Through the conduct described above, Defendants were enriched at Tory Burch's
expense and it is against good equity and conscience to permit Defendants to retain any profits or
other rewards from its conduct.
154.
Defendants' conduct was with a deceptive intent.
155.
TENTH CLAIM FOR RELIEF
(Cancellation of Cai Yan Chen's Federal Trademark Registration)
156.

157.
This is an action for cancellation of Cai Yan Chen's trademark registration for the
Infringing TT Logo, pursuant to 15 U.S.C. 1064 and 1119.
39
158.
In view of Tory Burch's prior trademark rights in the distinctive TT Logo and other of
the Tory Burch Trademarks, Cai Yan Chen is not entitled to the exclusive right to use the Infringing
TT Logo and U.S. Reg. No. 4,102,185 should be cancelled.
159.
Registration of the Infringing TT Logo is causing, and will continue to cause, damage
to Tory Burch, because it unfairly provides Cai Yan Chen with prima facie evidence of the
exclusive right to use the Infringing TT Logo in connection with its Infringing Products.
160.
Based on the foregoing, Tory Burch is entitled to an order pursuant to 15 U.S.C.
1119, directing the Director of the Trademark Office to cancel U.S. Reg. No. 4,102,185.
PRAYER FOR RELIEF
WHEREFORE, Tory Burch respectfully prays that this Court enter judgment in its favor
and against Defendants as follows:
A.
Defendants, their agents, servants, employees, officers, associates, attorneys, and
all persons acting by, through, or in concert with any of them, are hereby temporarily,
preliminarily, and permanently enjoined from using the Tory Burch Trademarks, or any marks,
designs or designations confusingly similar thereto and the Tory Burch Copyrighted Designs,
including, but not limited to:
(1)
manufacturing, importing, advertising, marketing, promoting, supplying,
distributing, offering for sale, or selling any products which bear the Tory Burch Trademarks
and/or the Tory Burch Copyrighted Designs, or any marks/designs identical, substantially
indistinguishable, substantially similar, and/or confusingly similar thereto;
(2)
engaging in any other activity constituting unfair competition with Tory
Burch, or acts and practices that deceive consumers, the public, and/or trade, including without
limitation, the use of designations and design elements associated with Tory Burch;
40
(3)
engaging in any other activity that would dilute the distinctiveness of the
Tory Burch Trademarks; and
(4)
committing anyotheract which falsely represents or which hasthe effect of
falsely representing that the goods and services of Defendants are licensed by, authorized by,
offered by, produced by, sponsored by, or in any other way associated with Tory Burch;
B.
Ordering Defendants to recall from any distributors and retailers and to deliver to
Tory Burch for destruction or other disposition all remaining inventory of Infringing Products, or
other products bearing the Tory Burch Trademarks, Tory Burch Copyrighted Designs, or any
marks confusingly similar or substantially similar thereto, including all advertisements,
promotional and marketing materials therefore, as well as means of making same;

C.
Ordering Defendants to file with this Court and serve on Tory Burchwithinten (10)
days after entry of the injunction a report in writing, under oath setting forth in detail the manner
and form in which Defendants have complied with the injunction;
D.
Declaring that the Infringing TT Logo is not entitled to federal registration based
on its likelihood of confusion with the Tory Burch Trademarks;
E.
Ordering that U.S. Reg. No. 4,102,185 be cancelled and directing the Clerk of the
Court to transmit notice of the Order to the Director of the Trademark Office of the United States
Patent and Trademark Office;
F.
Ordering an accounting by Defendants of all gains, profits, and advantages derived
from their wrongful acts;
G.
Awarding Tory Burch all of Defendants' profits and all damages sustained by Tory
Burch as a result of Defendants' wrongful acts, and such other compensatory damages as the Court
determines to be fair and appropriate pursuant to 15 U.S.C. 1117(a) and 17 U.S.C. 504(b);
41
H.
Awarding treble damages in the amount of Defendants' profits or Tory Burch's
damages, whichever is greater, for willful infringement pursuant to 15 U.S.C. 1117(b);

I.
Awarding applicable interest, costs, disbursements and attorneys' fees, pursuant to
15 U.S.C. 1117(b) and 17 U.S.C. 505;
J.
Awarding Tory Burch statutory damages pursuant to 15 U.S.C. 1117(c) and 17
U.S.C. 504(c);
K.
Awarding Tory Burch punitive damages inconnection with its state law claims, on
account of Defendants' willful misconduct and fraud and deceit upon the public; and
L.
Such other relief as may be just and proper.

DEMAND FOR JURY TRIAL
Tory Burch demands a trial byjury of all claims so triable.
42
Dated: February 4, 2015
Respectfully submitted,
FISH & RICHARDSON P.C.
R. David Hosp (RH3344)

Elizabeth E. Brenckman (EB1378)
601 Lexington Avenue, 52nd Floor

New York, New York 10022
Tel: (212) 765-5070
Fax:(212)258-2291
hosp@fr.com
brenckman@fr.com
Natalie L. Arbaugh (pro hac vice forthcoming)
1717 Main Street, Suite 5000
Dallas, TX 75201
Tel: (214) 478-3302

Fax: (214) 747-2091
arbaugh@fr.com
Attorneysfor Plaintiffs River Light V, L.P. and

Tory Burch LLC
43
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Clare O'Connor Forbes Staff
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The consumer economy: retail, and the people reinventing it.
1/03/2013 4:40PM
124,015 views
Fashion Tycoon Tory Burch

Becomes A Billionaire (Thanks,
In Part, To $200 Ballet Flats)
+ Comment Now
+ Follow Comments
Five years ago this month,

fledgling womenswear
designer Tory Burch
landed on the cover of
Town & Country

magazine. The
accompanying profile
tried to explain the

growing popularity of her
fashion line, launched
from her kitchen in 2004.
The designer Tory Burch, center,

poses with models. Clickfor
more photos. (Credit: AP
Photo/Diane Bondareff)
The seven big mistakes and how

NOT to train your sales team
+
Improve your sales
Learn
by Selling in English
More
"Her tunics became the uniform for everyone from

the Upper East Side lady who lunches," it read, "to women across America
who wanted to look like an Upper East Side lady who lunches."
I That uniform preppy-bohemian, you could call it, orWASP chic has
IJJurned ToryBurch into a household name, and nowa billionaire.
Tory is set to join the 2013 Forbes World's Billionaires list in March as one of a
handful of women who made their fortunes rather than inherited them,
including Oprah Winfrey and Meg Whitman. The 46-year-old Penn graduate
and former fashion PR is now the second youngest self-made female
billionaire in America; Spanx inventor Sara Blakely. who joined the rich list in
_2Q1Z, is the youngest at 41.
Paradoxically, Tory's newfound billionaire status comes as a result of her exhusband's latest business move. One-time company co-chair Chris Burch sold
part of his 28.3% stake in the brand to two new investors this week, putting to
rest months of lawsuits and counterclaims that threatened to derail a future
TPO.
Chris' deal values the company at $3.25 billion, according to private company
analysts PrivCo. Representatives for the fashion house would not comment on
that figure, but Forbes' own calculations using price-to-revenue ratios for
similar public companies suggest Tory Burch LLC is worth at least $3.5
billion. This makes Tory's own 28.3% stake in her eponymous firm worth $1
billion.
Our valuation could well prove conservative should

Tory and her board decide to take the company
public in coming months. Tory Burch LLC brought
in close to $800 million in revenues in 2012. By way
of comparison, fellow American-luxe womenswear
designer Michael Kors' company brought in $800
million in revenues in 2011, went public that year,
and now boasts a market cap of over $10 billion.
Tory hit the big time in 2006, with the launch of her
best-known product, a $195 pair of leather ballet
flats in every conceivable color with her signature
'double T' medallion logo on the top. She named the
shoes "the Reva" after her mother.
In 2008, she cemented her status in the fashion firmament by winning the
industry's version of the Oscar, the Accessory Designer of the Year award
from the Council of Fashion Designers of America. In 2010, queenmaker
Oprah Winfrey included Tory's Reva flats in her final Favorite Things episode,
elevating them to wardrobe must-haves. That year, the company opened its
first standalone stores in Europe and Asia.
Then came the bump in the road that put a long-rumored IPO on hold
indefinitely. The trouble between exes Tory and Chris began in 2011 when
Chris launched C. Wonder, a preppy clothing chain bearing a striking
resemblance to Tory's multi-billion dollar brand but at a far cheaper price.

Since then, Chris has been forced off the board of Tory Burch LLC,but
retained a 28.3% stake in his ex-wife's company.
In October, Chris sued Tory and the majority of her company's board, alleging
they were trying to hinder his relations with suppliers and hamper his attempt
to sell some of his stake. Tory Burch LLC countersued in November, claiming
C. Wonder "is a knockoff brand...with mass-market versions of the top-selling
Tory Burch items." (You can judge for yourself: scroll through the images in
this counterclaim.!
On January 1st, the board at Tory Burch LLC and

Chris announced they'd settled "all pending legal
claims!!, putting an end to what the presiding judge
had called a "drunken WASP test". That same day,
Chris announced the sale of most of his 28.3% stake
to two new high-profile investors, philanthropist

Chuck Feeney's General Atlantic and Warren
Buffett banker Byron Trott's BDT Capital Partners.
None of the parties involved disclosed exactly how
much of his 28.3% Chris sold, nor the price paid by
these new minority shareholders. PrivCo got their
hands on the offering memorandum and value the
sale at $812.5 million, although a representative for Tory Burch LLC wouldn't
corroborate that figure. (Calls and emails to Burch Creative Capital, Chris'
holding company, were not returned.)
PrivCo's number-crunchers say Chris, as well as Tory, is now a billionaire
thanks to dividends and other assets. The 59-year-old retail veteran has
indeed made some canny investments over the years, including stakes in
phone gadget manufacturer Aliph, which owns popular Bluetooth handset
Jawbone; pricey Norwegian artesian bottled water brand Voss and wireless
charging outfit Powermat. Watch this space: Chris may well join his ex-wife in
the Forbes billionaires' club.
Read More:
Why Tory Burch Should Be Fashion's Next Billionaire (And How Her Ex Could
Stop Her!
Is Billionaire Blavatnik Playing Both Sides In Tory Burch Battle?
Fashion Mogul Tory Burch Settles With Her Ex (And

Gets A New High Profile Investor)
Undercover Billionaire: Sara Blakely Joins The Rich
List Thanks To Spanx
Follow me on Twitter and Facebook.
EXHIBIT 2
Type of Work:
Visual Material
Registration Number / Date:

VA0001768387
/ 2011-03-16
Application Title:
TT & Design.
Title:
TT & Design.
Description:
Electronic file
(eService)
Copyright Claimant:
River Light V, L.P.,

Date
of
Creation:
Date
of
Publication:
2004-02-01
Nation
of
First
Transfer:
By written agreement.
2003
Publication:
United States
Authorship on Application:
MODco Creative, Inc., employer for hire;
States. Authorship: 2-D artwork.
Rights and Permissions:

Mary L. Grieco,
Domicile:
Olshan Grundman Frome Rosenzweig & Wolosky
LLP, 65 East 55th Street, New York, NY, 10022,

States, (212) 451-2300, mgrieco@olshanlaw.com
Names:
United
MODco Creative, Inc.

River Light V, L.P.
United
EXHIBIT 3
United States Patent and Trademark Office

Home Site Index Search FAQ Glossary Guides Contacts eBusiness eBiz alerts News Help
Trademarks > Trademark Electronic Search System (TESS)

TESS was last updated on Wed Aug 20 02:21:02 EDT 2014
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Record 1 out of 1
TSDR
I ASSIGN Status I TTAB Status
I( Use the "Back" button of the Internet Browser to return to TESS)
Word Mark
TT
Goods and
IC 004. US 001 006 015. G & S: Candles. FIRST USE: 20040201. FIRST USE IN COMMERCE: 20040201
Services
IC 014. US 002 027 028 050. G & S: Jewelry. FIRST USE: 20040201. FIRST USE IN COMMERCE: 20040201
IC 018. US 001 002 003 022 041. G & S: Accessories, namely, handbags, umbrellas and cosmetic bags sold empty.
FIRST USE: 20040201. FIRST USE IN COMMERCE: 20040201
(CANCELLED) IC 020. US 002 013 022 025 032 050. G & S: [ Housewares, namely, wood boxes and furniture ].
IC 024. US 042 050. G & S: Housewares, namely, [ bed sheets, table linens and ] towels. FIRST USE: 20040201.
FIRST USE IN COMMERCE: 20040201
IC 025. US 022 039. G & S: Clothing, namely, shirts, tops, sweaters, pants, skirts, shorts, dresses, bathing suits,
bikinis, sarongs, shoes, socks, belts, [ undergarments, ] robes and headwear; Outerwear, namely, scarves, jackets,
vests and coats. FIRST USE: 20040201. FIRST USE IN COMMERCE: 20040201
Mark
Drawing
(3) DESIGN PLUS WORDS, LETTERS, AND/OR NUMBERS
Code
Design
Search Code
Serial
Number
Filing Date
Current
Basis
Original
Filing Basis
09.01.02 - Embroidery; Labels, clothing; Stitching, not on clothing pockets

26.01.21 - Circles that are totally or partially shaded.
76546289
September 23, 2003

1A
1B
Published
for
Opposition
February 22, 2005
Change In
Registration
CHANGE |N REGISTRATION HAS OCCURRED
Registration 3Q2979S
Number
International
Registration 0854054
Number
Registration December 13, 2005

Date
Owner
(REGISTRANT) River Light V, LLC LIMITED LIABILITY COMPANY DELAWARE 685 Kromer Avenue Berwyn
PENNSYLVANIA 19312
(LAST LISTED OWNER) RIVER LIGHT V, L.P. LIMITED PARTNERSHIP DELAWARE 11 West 19th Street, 7th
Floor New York NEW YORK 10011
Assignment
Recorded
Attorney of
Record
Description
of Mark
Type of
Mark
Register
Affidavit
Text
Live/Dead
Indicator
ASSIGNMENT RECORDED
Steven R. Gursky, Mary L. Grieco, Safia A. Anand

Color is not claimed as a feature of the mark.
TRADEMARK
PRINCIPAL
PARTIAL SECT 8 (6-YR).
LIVE
uSaHll
ISEARCH OG
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Int. Cls.: 4, 14, 18, 20, 24 and 25

Prior U.S. Cls.: 1, 2, 3, 6, 13, 15, 22, 25, 27,
28, 32, 39, 41, 42 and 50
Reg. No. 3,029,795
Registered Dec. 13, 2005
Corrected
OG Date Dec. 15, 2009
TRADEMARK
PRINCIPAL REGISTER
RIVER LIGHT V, L.P. (DELAWARE LIM

ITED PARTNERSHIP)
FOR: HOUSEWARES, NAMELY,

WOOD BOXES AND FURNITURE, IN
7TH FLOOR
CLASS 20 (U.S. CLS.

AND 50).
11 WEST 19TH STREET
NEW YORK, NY 10011
2, 13, 22, 25, 32
FIRST USE 2-1-2004; IN COMMERCE

2-1-2004.
FOR: CANDLES, IN CLASS 4 (U.S.

CLS. 1, 6 AND 15).
FOR: HOUSEWARES, NAMELY, BED

SHEETS, TABLE LINENS AND TOWELS,
IN CLASS 24 (U.S. CLS. 42 AND 50).

2-1-2004.
2-1-2004.
FOR:
JEWELRY, IN CLASS 14 (U.S.
CLS. 2, 27, 28 AND 50).

2-1-2004.
FOR: ACCESSORIES, NAMELY,

HANDBAGS, UMBRELLAS AND COS
METIC BAGS SOLD EMPTY, IN CLASS
18 (U.S. CLS. 1, 2, 3, 22 AND 41).
2-1-2004.
FOR: CLOTHING, NAMELY, SHIRTS,

TOPS, SWEATERS, PANTS, SKIRTS,
SHORTS, DRESSES, BATHING SUITS,
BIKINIS, SARONGS, SHOES, SOCKS,
BELTS, UNDERGARMENTS, ROBES
AND HEADWEAR; OUTERWEAR,
NAMELY, SCARVES, JACKETS, VESTS
AND COATS , IN CLASS 25 (U.S. CLS.

22 AND 39).
2-1-2004.
SER. NO. 76-546,289, FILED 9-23-2003.
In testimony whereof I have hereunto set my hand

and caused the seal of The Patent and Trademark
Office to be affixed on Dec. 15, 2009.


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Record 1 out of 1
TSDR
Word Mark
Goods and Services
( Use the "Back" button of the Internet Browser to return to TESS)
TT
IC 035. US 100 101 102. G & S: Retail clothing apparel and accessories stores. FIRST USE:
20040208. FIRST USE IN COMMERCE: 20040208
Mark Drawing Code
Design Search Code
Serial Number
76546288
Filing Date
September 23, 2003
Current Basis
1A
Original Filing Basis
1B
Published for
Opposition
Registration Number
International
Registration Number
January 18, 2005

3024142
0850292
Registration Date
December 6, 2005
Owner
(REGISTRANT) River Light V, LLC LIMITED LIABILITY COMPANY DELAWARE 685 Kromer Avenue
Berwyn PENNSYLVANIA 19312
(LAST LISTED OWNER) RIVER LIGHT V, L.P. LIMITED PARTNERSHIP NEW YORK 11 West 19th
Street, 7th Floor NEW YORK NEW YORK 10011
Assignment Recorded
ASSIGNMENT RECORDED
Attorney of Record
Description of Mark
Color is not claimed as a feature of the mark.
Type of Mark
SERVICE MARK
Register
PRINCIPAL
Affidavit Text
SECT 15. SECT 8 (6-YR).
Live/Dead Indicator
LIVE
Int. CI.: 35
Reg. No. 3,024,142
Prior U.S. Cls.: 100, 101 and 102

Registered Dec. 6, 2005
New Cert.
OG Date Dec. 22, 2009
SERVICE MARK
PRINCIPAL REGISTER
REGISTRATION ASSIGNED
RIVER LIGHT V, L.P. (DELAWARE LIM

ITED PARTNERSHIP)
99 MADISON AVENUE
NEW YORK, NY 10016
FOR:
RETAIL CLOTHING APPAREL
AND ACCESSORIES STORES, IN CLASS

35 (U.S. CLS. 100, 101 AND 102).
2-8-2004.
SER. NO. 76-546,288, FILED 9-23-2003.
In testimony whereof I have hereunto set my hand

and caused the seal of The Patent and Trademark
Office to be affixed on Dec. 22, 2009.
^J ~
K^^^^J


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ASSIGN Status I TTAB Status
( Use the "Back" button of the Internet Browser to return to TESS) f
Word Mark
TT
Goods and
IC 018. US 001 002 003 022 041. G & S: A full line of handbags. FIRST USE: 20040201. FIRST USE IN
Services
COMMERCE: 20040201
IC 025. US 022 039. G & S: A full line of women's clothing and footwear. FIRST USE: 20040201. FIRST USE IN
COMMERCE: 20040201
Mark Drawing
Code
Design Search
Code
Trademark
Search Facility
Classification
Code

26.01.01 - Circles as carriers or as single line borders
LETS-1 TT A single letter, multiples of a single letter or in combination with a design

SHAPES-CIRCLE Circle figures or designs including semi-circles and incomplete circles
SHAPES-MISC Miscellaneous shaped designs
Serial Number
77345778
Filing Date
December 6, 2007
Current Basis
1A
Original Filing
Basis
Published for
Opposition
Registration
Number
Registration
Date
Owner
1A
November 4, 2008
3563326
January 20, 2009
(REGISTRANT) River Light V, L.P. LIMITED PARTNERSHIP DELAWARE 11 West 19th Street, 7th Floor New
York NEW YORK 10011
Attorney of
Record
Prior

. 4 ..
Registrations
3024142;3029795
Description of
Color is not claimed as a feature of the mark. The mark consists of a circle with a "T" and an upside down "T"
Mark
in the middle.
Type of Mark
Register
TRADEMARK
PRINCIPAL
Affidavit Text
SECT 15. SECT 8 (6-YR).
Live/Dead
Indicator
LIVE
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Int. Cls.: 18 and 25
Prior U.S. Cls.: 1, 2, 3, 22, 39 and 41
Reg. No. 3,563,326

Registered Jan. 20,2009
TRADEMARK
PRINCIPAL REGISTER
RIVER LIGHT V, L.P. (DELAWARE LIMITED

PARTNERSHIP)
99 MADISON AVENUE NEW
NEW YORK, NY 10016
FIRST USE 2-1-2004; IN COMMERCE 2-1-2004.
OWNER OF U.S. REG. NOS. 3,024,142 AND

3,029,795.
FOR: A FULL LINE OF HANDBAGS, IN CLASS 18
(U.S. CLS. 1,2, 3,22 AND 41).
THE MARK CONSISTS OF A CIRCLE WITH A "T"

AND AN UPSIDE DOWN "T" IN THE MIDDLE.

FOR: A FULL LINE OF WOMEN'S CLOTHING
AND FOOTWEAR, IN CLASS 25 (U.S. CLS. 22 AND

39).
SER. NO. 77-345,778, FILED 12-6-2007.
JOHN GARTNER, EXAMINING ATTORNEY

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Record 1 out of 1
TSDR
Word Mark
Goods and
Services
IC 025. US 022 039. G & S: Socks; Robes. FIRST USE: 20080101. FIRST USE IN COMMERCE: 20080101
Mark Drawing
DES|Gn PLUS WORDS, LETTERS, AND/OR NUMBERS
Code
Design Search
Code
Serial Number
77345862
Filing Date
December 6, 2007
Current Basis
1A
Original Filing
Basis
Published for
Opposition
Registration
Number
Registration
Date
Owner
1B
May 13, 2008

4029068
September 20, 2011
(REGISTRANT) River Light V, L.P. CRB, LLC, a Delaware limited liability company LIMITED PARTNERSHIP
DELAWARE 11 West 19th St, 7th Floor New York NEW YORK 10011
Attorney of
Record
Prior
Registrations

3024142;3029795;AND OTHERS
Description of
Color is not claimed as a feature of the mark. The mark consists of A circle with a "T" and an upside down "T" in
Mark
the middle.
Type of Mark
TRADEMARK
Register
PRINCIPAL
Live/Dead
~J ~
Indicator
v- ,
LIVE
ISBD3IL11BOI
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states; of &m
W*
Mmtefc &tatetf patent mh T&ra&etnarfc 0Uitt

Wnit
Reg. No. 4,029,068
er%
river light v,l.p. (Delawarelimited partnership)

11 WEST 19TH ST, 7TH FLOOR
Registered Sep. 20,2011 newyork,ny 10011

Int. CL: 25
FOR: SOCKS; ROBES, IN CLASS 25 (U.S. CLS. 22 AND 39).

TRADEMARK
OWNER OF U.S. REG. NOS. 3,024,142,3,029,795, AND OTHERS.
PRINCIPAL REGISTER
THE MARK CONSISTS OF A CIRCLE WITH A "T" AND AN UPSIDE DOWN "T" IN THE
MIDDLE.
SN 77-345,862, FILED 12-6-2007.
JOHN GARTNER, EXAMINING ATTORNEY
Director of the United States Patent and Trademark Office
~J
-,


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Word Mark
T T
Goods and
IC 006. US 002 012 013 014 023 025 050. G & S: Metal key chains. FIRST USE: 20081031. FIRST USE IN
Services
COMMERCE: 20081031
Mark Drawing
Code
Design Search
Code

Serial Number
77801962
Filing Date
August 11, 2009
Current Basis
1A
Original Filing
Basis
Published for
Opposition
Registration
Number
Registration
Date
Owner
1B
November 17, 2009

4129090
April 17, 2012
DELAWARE 11 West 19th Street, 7th Floor New York NEW YORK 10011
Attorney of
Record
Prior
Registrations
Steven R. Gursky
3024142;3029795;3563326
Description of Color is not claimed as a feature of the mark. The mark consists of an upright "T" underneath an upside down
Mark
inside a circle.
Type of Mark
TRADEMARK
Register
PRINCIPAL
Live/Dead
T"
Indicator
LIVE
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SHtuteb &tate* patent atrti ^raoemarfe Office
Reg. No. 4,129,090
v*f
river light v,l.p.(Delaware limited partnership)

11 WEST 19TH STREET, 7TH FLOOR
Registered Apr. 17,2012 newyork,nyiooii

Int. CI.: 6
FOR: METAL KEY CHAINS, IN CLASS 6 (U.S. CLS. 2,12,13,14,23,25 AND 50).
TRADEMARK
OWNER OF U.S. REG. NOS. 3,024,142,3,029,795, AND 3,563,326.
PRINCIPAL REGISTER
THE MARK CONSISTS OF AN UPRIGHT "T" UNDERNEATHAN UPSIDE DOWN "T" INSIDE
A CIRCLE.
SN 77-801,962, FILED 8-11-2009.
TARAH HARDY, EXAMINING ATTORNEY
Director ofthe United States Patent and Trademark Office
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TSDR
Word Mark
IC 018. US 001 002 003 022 041. G & S: Leather key chains. FIRST USE: 20081031. FIRST USE IN
Services
COMMERCE: 20081031
Mark Drawing
Design Search
Code

Serial Number
77801996
Filing Date
August 11, 2009
Current Basis
1A
Original Filing
Basis
Published for
Opposition
T T
Goods and
Code
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Registration
Number
Registration
Date
Owner
1B
November 17, 2009

4150523
May 29, 2012
Attorney of
Record
Prior
Registrations
Steven R. Gursky
3024142:3029795:3563326
Description of Color is not claimed as a feature of the mark. The mark consists of an upright "T" underneath an upside down "T"
Mark
inside a circle.
Type of Mark
TRADEMARK
Register
PRINCIPAL
Live/Dead
~J . . . v .
Indicator
~~~,
LIVE
Han
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Mi*
QJmteb States: patent anb tErabernarfc (Pfftcc
Reg. No. 4,150,523
^H
river light v,l.p. (Delaware limited partnership)

Registered May 29,2012 new york,ny iooh

Int. CL: 18
FOR: LEATHER KEY CHAINS, IN CLASS 18 (U.S. CLS. 1,2,3,22 AND 41).
TRADEMARK
PRINCIPAL REGISTER
THE MARK CONSISTS OF AN UPRIGHT "T" UNDERNEATHANUPSIDE DOWN "T" INSIDE
A CIRCLE.
SN 77-801,996, FILED 8-11-2009.

TARAH HARDY, EXAMINING ATTORNEY
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Word Mark
Goods and
Services
IC 016. US 002 005 022 023 029 037 038 050. G & S: Calendars; Note cards; Passport covers; Pen and pencil
cases; Pencils; Stationery. FIRST USE: 20080930. FIRST USE IN COMMERCE: 20080930
Mark
Drawing
Code
Design
Search Code
Serial
Number
Filing Date

77803663
August 13, 2009
Current Basis 1A
Original
Filing Basis
Published for
Opposition
Registration
Number
Registration
Date
Owner
1B
January 19, 2010

4276065
January 15, 2013
Attorney of
Record
Prior
Registrations

3024142;3029795;3563326
Description
Color is not claimed as a feature of the mark. The mark consists of an upright "T" directly below an inverted "T" all
of Mark
surrounded by a circle.
Type of Mark
TRADEMARK
^j
Register
Live/Dead
Indicator
... y^^^^j
PRINCIPAL
LIVE
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Vli^
Wnittit States? patent anfc t&rabemarfc Office
Reg. No. 4,276,065
^K
river light v,l.p.(Delaware limited partnership)

Registered Jan. 15,2013 newyork,nyiooh

Int. CL: 16
FOR: CALENDARS; NOTE CARDS; PASSPORT COVERS; PEN AND PENCIL CASES; PEN
CILS; STATIONERY, IN CLASS 16 (U.S. CLS. 2,5,22,23,29,37,38 AND 50).
TRADEMARK
PRINCIPAL REGISTER

THE MARK CONSISTS OF AN UPRIGHT "T" DIRECTLY BELOW AN INVERTED "T" ALL
SURROUNDED BY A CIRCLE.
SN 77-803,663, FILED 8-13-2009.

NICHOLAS COLEMAN, EXAMINING ATTORNEY

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Word Mark
Goods and
IC 003. US 001 004 006 050 051 052. G & S: Cologne; Cosmetic preparations for body care; Cosmetics;
Services
Fragrances for personal use; Non-medicated skin care preparations; Perfumes. FIRST USE: 20130906. FIRST
USE IN COMMERCE: 20130906
Mark Drawing
Code
Design Search
Code
Serial Number

77948341
Filing Date
March 2, 2010
Current Basis
1A
Original Filing
Basis
Published for
Opposition
Registration
Number
1B
July 27, 2010

4432775
International
Registration
1043796
Number
Registration
Date
Owner
November 12, 2013
Attorney of
Record
Prior
Registrations
Description of
Mary L. Grieco
3024142;3029795;3563326
Color is not claimed as a feature of the mark. The mark consists of an upright "T" directly below an inverted "T"
Mark
all surrounded by a circle.
Type of Mark
TRADEMARK
Register
PRINCIPAL
Live/Dead
Indicator
LIVE
mi ISEARCH OG
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îte* states of 3W*

V*V*
WlniUto States? patent mb flfrabemarfc #fftce
Reg. No. 4,432,775
*-lf
river light v, l.p. (Delaware limited partnership)

Registered Nov. 12,2013 newyork,ny iooh

Int. CI.: 3
FOR: COLOGNE; COSMETIC PREPARATIONS FOR BODY CARE; COSMETICS; FRA

GRANCES FOR PERSONAL USE; NON-MEDICATED SKIN CARE PREPARATIONS; PER
FUMES , IN CLASS 3 (U.S. CLS. 1,4,6,50,51 AND 52).
TRADEMARK
PRINCIPAL REGISTER

SN 77-948,341, FILED 3-2-2010.

KEVIN CORWIN, EXAMINING ATTORNEY
Deputy Director of the United States Patent and Trademark Office

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Word Mark
Goods and Services
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TT
IC 009. US 021 023 026 036 038. G & S: Eyewear; Eyewear cases. FIRST USE: 20091021. FIRST USE IN
COMMERCE: 20091021
Mark Drawing Code (3) DESIGN PLUS WORDS, LETTERS, AND/OR NUMBERS
Design Search Code 26.01.01 - Circles as carriers or as single line borders
26.01.02 - Circles, plain single line; Plain single line circles
Serial Number
85325963
Filing Date
May 20, 2011
Current Basis
1A
Original Filing Basis
1A
Published for
Opposition
Date Amended to
Current Register
Registration
Number
August 9, 2011
May 27, 2011

4045568
Registration Date
October 25, 2011
Owner
(REGISTRANT) River Light V, L.P. CRB, LLC, a Delaware limited liability company LIMITED
PARTNERSHIP DELAWARE 11 West 19th Street, 7th Floor New York NEW YORK 10011
Attorney of Record
Prior Registrations
3024142;3029795;3563326
Description of Mark Color is not claimed as a feature of the mark. The mark consists of an upright "T" directly below an inverted
"T" all surrounded by a circle.
Type of Mark
TRADEMARK
Register
PRINCIPAL
Live/Dead Indicator
LIVE
ISEARCH OG
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V2>*
SHmteb &tatetf patent antr tlrabemarfe #tce
Reg. No. 4,045,568
^H
river light v,l.p. (Delaware limited partnership)

Registered Oct. 25,2011 newyork,nyiooh

Int. CI.: 9
FOR: EYEWEAR; EYEWEAR CASES, FN CLASS 9 (U.S. CLS. 21,23,26,36 AND 38).
TRADEMARK
PRINCIPAL REGISTER
SER. NO. 85-325,963, FILED S.R. 5-20-2011 AM. PR. 5-27-2011.

KATHLEEN M. VANSTON, EXAMINING ATTORNEY

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Word Mark
Goods and
Services
IC 018. US 001 002 003 022 041. G & S: Backpacks; Beach bags; Business card cases; Coin purses; Dog
collars; Dog leashes; Overnight bags; Pet clothing; Wallets; Wristlet bags. FIRST USE: 20081031. FIRST USE IN
COMMERCE: 20081031
Mark Drawing
Code
Design Search
Code

Serial Number
85530802
Filing Date
February 1, 2012
Current Basis
1A
Original Filing
Basis
Published for
Opposition
Registration
Number
1A
July 10, 2012

4213404
International
Registration
1141379
Number
Registration
Date
Owner
September 25, 2012
Attorney of
Record
Prior
Registrations
Description of

3024142;3029795;3563326;AND OTHERS
Mark
all surrounded by a circle.
Type of Mark
TRADEMARK
Register
PRINCIPAL
Live/Dead
Indicator
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îteU states of 3mer(c

V2V*
?Kmteb States: patent anb tKrabemarfc #fftce
Reg. No. 4,213,404
*-Cf

Registered Sep. 25,2012 newyork,nyiooii

Int. CI.: 18
FOR: BACKPACKS; BEACH BAGS; BUSINESS CARD CASES; COIN PURSES; DOG COL
LARS; DOG LEASHES; OVERNIGHT BAGS; PET CLOTHING; WALLETS; WRISTLET BAGS
, IN CLASS 18 (U.S. CLS. 1,2,3,22 AND 41).
TRADEMARK
PRINCIPAL REGISTER
OWNER OF U.S. REG. NOS. 3,024,142,3,563326 AND OTHERS.
SER. NO. 85-530,802, FILED 2-1-2012.

SUE LAWRENCE, EXAMINING ATTORNEY

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Word Mark
Goods and
Services
IC 009. US 021 023 026 036 038. G & S: Cell phone cases; Leather protective covers specially adapted for
personal electronic devices; Protective covers and cases for cell phones, laptops and portable media players.
Mark Drawing
Code
Design
Search Code
Serial
Number
Filing Date

85530803
February 1, 2012
Current Basis 1A
Original Filing
Basis
Published for
Opposition
Registration
Number
1A
July 10, 2012

4213405
International
Registration
1141379
Number
Registration
Date
Owner
September 25, 2012
Attorney of
Record
Prior
Registrations

3024142;3029795;3563326;AND OTHERS
Description
of Mark
Color is not claimed as a feature of the mark. The mark consists of an upright "T" directly below an inverted "T" all
surrounded by a circle.
Type of Mark TRADEMARK

Register
Live/Dead
Indicator
PRINCIPAL
LIVE
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îteU states of Sttteti^

VIV*
SBntteu &tate* patent anb tobemarfe Office
Reg. No. 4,213,405
*-**

Registered Sep. 25,2012 newyork,nyiooii

Int. CI.: 9
FOR: CELL PHONE CASES; LEATHER PROTECTIVE COVERS SPECIALLY ADAPTED

FOR PERSONAL ELECTRONIC DEVICES; PROTECTIVE COVERS AND CASES FOR CELL
PHONES, LAPTOPSAND PORTABLE MEDIA PLAYERS,IN CLASS 9 (U.S. CLS. 21,23,26,

TRADEMARK
36 AND 38).
PRINCIPAL REGISTER
OWNER OF U.S. REG. NOS. 3,024,142,3,563,326 AND OTHERS.

SER. NO. 85-530,803, FILED 2-1-2012.
Director ofthe United States Patent and Trademark. Office

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Word Mark
Goods and
IC 018. US 001 002 003 022 041. G & S: Backpacks; Cosmetic cases sold empty; Handbags; Leather pouches;
Services
Tote bags. FIRST USE: 20120630. FIRST USE IN COMMERCE: 20120630
Mark Drawing
Code
Design Search 26.09.21 - Squares that are completely or partially shaded

Code
26.09.28 - Miscellaneous designs with overall square shape; Square shapes (miscellaneous overall shape)
27.03.01 - Geometric figures forming letters, numerals or punctuation
Serial Number 85591301
Filing Date
April 6, 2012
Current Basis
1A
Original Filing
Basis
Published for
Opposition
Registration
Number
Registration
Date
Owner
1B
July 3, 2012
4459720
December 31, 2013
Attorney of
Record
Prior
Registrations
Steven R. Gursky
3024142;3029795;3563326;AND OTHERS
Description of Color is not claimed as a feature of the mark. The mark consists of design of four equal parts created from two
Mark
stylized split "T"s.
Type of Mark
TRADEMARK
Register
PRINCIPAL
Live/Dead
Indicator
LIVE
mimWmwLSmliSw
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states
of
OmwfA
V2i^
Wnitih &tate* patent attfr t&rabemarfc Office
^H
JG.
"3.7
Reg. No. 4,459,720

Registered Dec. 31,2013 newyork,ny iooh

Int. CI.: 18
FOR: BACKPACKS;COSMETIC CASES SOLD EMPTY; HANDBAGS; LEATHERPOUCHES;

TOTE BAGS, IN CLASS 18 (U.S. CLS. 1,2,3,22 AND 41).
TRADEMARK
PRINCIPAL REGISTER

THE MARK CONSISTS OF DESIGN OF FOUR EQUAL PARTS CREATED FROM TWO
STYLIZED SPLIT "T"S.
SN 85-591,301, FILED 4-6-2012.

/(Lu^j.j.du^
Commissioner for Trademarks of the

j
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"3C"
Word Mark
Goods and
Services
Mark Drawing
Code
Design Search
Code
IC 025. US 022 039. G & S: Belts; Footwear. FIRST USE: 20130331. FIRST USE IN COMMERCE: 20130331
Serial Number
85591319
Filing Date
April 6, 2012
Current Basis
1A
Original Filing
Basis
Published for
Opposition
Registration
Number
Registration
Date
Owner
1B
August 28, 2012

4365683
July 9, 2013
Attorney of
Record
Prior
Registrations

3024142;3029795;3563326;AND OTHERS
Mark
Type of Mark
TRADEMARK
Register
PRINCIPAL
Live/Dead
^J ~ . ~ . . . v .. ~ ~ ~ ,
Indicator
LIVE
uaaisuul
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îtefc states of g)W.

V*^
SHntteb &tate* patent an* t&ra&etnarfc ttitz
^Cf
JG.
Reg. No. 4,365,683

Registered July 9, 2013 newyork, ny iooi i

Int. CI.: 25
FOR: BELTS; FOOTWEAR, IN CLASS 25 (U.S. CLS. 22 AND 39).

TRADEMARK

PRINCIPAL REGISTER
SN 85-591,319, FILED 4-6-2012.
WILLIAM VERHOSEK, EXAMINING ATTORNEY
Acttaf Director of the United State* Patent and Ttaideiiiwfc Offlee

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TSDR
"DC"
Word Mark
TT
Goods and
IC 009. US 021 023 026 036 038. G & S: Eyewear. FIRST USE: 20091130. FIRST USE IN COMMERCE:
Services
20091130
Mark Drawing
Code
Design Search
Code
Serial Number
85591453
Filing Date
April 6, 2012
Current Basis
1A
Original Filing
Basis
Published for
Opposition
Registration
Number
Registration
Date
Owner
1A
August 28, 2012

4242007
November 13, 2012
Attorney of
Record
Prior
Registrations

3024142;3029795;3563326;AND OTHERS
Mark
Type of Mark
TRADEMARK
Register
PRINCIPAL
Live/Dead
^J ~ . . .
Indicator
v - ~~~f
LIVE
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states
of
nter,rj>
Vll^
mteb &mzi patent anb ^rabemarfe Office
^K
iJCh
"IP
Reg. No. 4,242,007

Registered Nov. 13,2012 newyork,ny iooii

Int. CI.: 9
FOR: EYEWEAR, IN CLASS 9 (U.S. CLS. 21,23,26,36 AND 38).

TRADEMARK
PRINCIPAL REGISTER
SER. NO. 85-591,453, FILED 4-6-2012.

WILLIAM VERHOSEK, EXAMINING ATTORNEY
^J ~ . . y ^ ^ J

^gjB Ktaaa-^ RM1T1BB35SB3 ^^1B i^j^LiJ EgffiM B33J

Record 1 out of 1
TSDR
I ASSIGN Status TTAB Status
Word Mark
TT
Goods and
IC 009. US 021 023 026 036 038. G & S: Cell phone cases; Eyewear; Leather protective covers specially adapted
for personal electronic devices; Protective covers and cases for cell phones, laptops and portable media players;
Services
Sunglasses. FIRST USE: 20110131. FIRST USE IN COMMERCE: 20110131

Mark
Drawing
(5) WORDS, LETTERS, AND/OR NUMBERS IN STYLIZED FORM
Code
Serial
Number
Filing Date
Current
Basis
Original
Filing Basis
Published for
Opposition
Registration
Number
Registration
Date
Owner
85716917
August 30, 2012

1A
1A
May 28, 2013

4382707
August 13, 2013
(REGISTRANT) River Light V, L.P. CRB, LLC, a limited liability company of Delaware. LIMITED PARTNERSHIP
Attorney of
Record
Prior
Registrations
Description
of Mark
Type of Mark

3029795;3563326;4029068;AND OTHERS
Color is not claimed as a feature of the mark. The mark consists of an upright "T" directly below an inverted "T".
TRADEMARK
Register
Live/Dead
Indicator
PRINCIPAL
LIVE
wasmm
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V^
Wniteb States: patent anb ^rabemarE #fftce
Reg. No. 4,382,707
^*

Registered Aug. 13,2013 newyork,nyiooii

Int. CI.: 9
FOR: CELL PHONE CASES; EYEWEAR; LEATHER PROTECTIVE COVERS SPECIALLY

ADAPTED FOR PERSONAL ELECTRONIC DEVICES; PROTECTIVE COVERS AND CASES
TRADEMARK
CLASS 9 (U.S. CLS. 21,23,26,36 AND 38).
PRINCIPAL REGISTER
FIRST USE 1-31 -2011; IN COMMERCE 1-31-2011.
FOR CELL PHONES, LAPTOPS AND PORTABLE MEDIA PLAYERS; SUNGLASSES, IN

THE MARK CONSISTS OF AN UPRIGHT "T" DIRECTLY BELOW AN INVERTED "T".
SER. NO. 85-716,917, FILED 8-30-2012.

BARBARA BROWN, EXAMINING ATTORNEY
Acting Director of the United States Patent and Trademark OfBce
... ^J v ^ ^ ^ ,

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I ASSIGN Status | TTAB Status
Word Mark
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TT
Goods and
Services
14- US 002 027 028 50' G &S: Jewelry. FIRST USE: 20110131. FIRST USE IN COMMERCE: 20110131
Code DraWm9 (5) WORDS, LETTERS, AND/OR NUMBERS IN STYLIZED FORM

Serial Number
85716924
Filing Date
August 30, 2012
Current Basis
1A
Original Filing
Basis
Published for
Opposition
Registration
Number
Registration
Date
Owner
1A
April 23, 2013

4363739
July 9, 2013
Attorney of
Record
Prior
Registrations
Description of
STEVEN R. GURSKY
3029795;3563326;4029068;AND OTHERS
Mark
Type of Mark
TRADEMARK
Register
PRINCIPAL
Live/Dead
Indicator
LIVE
^tiitefc states of 8*^

V2i^
Wnitsto State* patent anb t&rabemarfe Office
Reg. No. 4,363,739
*-l?

Registered July 9, 2013 newyork,ny iooii

Int. CI.: 14
FOR: JEWELRY,IN CLASS 14 (U.S. CLS. 2,27,28 AND 50).

TRADEMARK
PRINCIPAL REGISTER
THE MARK CONSISTS OF AN UPRIGHT "T" DIRECTLY BELOW AN INVERTED "T"
SER. NO. 85-716,924, FILED 8-30-2012.

Acting Director ofthe United Statei Patent and Trademark Office
^J
.. v^^^y

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TSDR
Word Mark
Goods and
IC 018. US 001 002 003 022 041. G &S: Business card cases; Cosmetic cases sold empty; Handbags; Leather
Services
pouches; Luggage; Purses; Tote bags; Umbrellas; Wallets; Wristlet bags. FIRST USE: 20070831. FIRST USE IN
COMMERCE: 20070831
Mark
Drawing
Code
Serial
Number
Filing Date
Current
Basis
Original
Filing Basis
Published for
Opposition
Registration
Number
Registration
Date
Owner
85716927
August 30, 2012

1A
1A
January 22, 2013

4317165
April 9, 2013
Attorney of
Record
Prior
Registrations
Description
of Mark
Type of Mark

3029795;3563326;4029068;AND OTHERS
TRADEMARK
^ j ^ v . . . v - ^.^^.J
Register
Live/Dead
Indicator
PRINCIPAL
LIVE
msmwwmmBsmMSLMmi
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VZi^
WniUto &mz* patent anb ^rabetnarfe Office
Reg. No. 4,317,165
^*#

Registered Ap r. 9,2013 newyork, ny iooii

Int. CL: 18
FOR: BUSINESSCARD CASES; COSMETICCASES SOLDEMPTY;HANDBAGS; LEATHER

POUCHES;LUGGAGE;PURSES; TOTEBAGS;UMBRELLAS;WALLETS; WRISTLETBAGS
TRADEMARK
PRINCIPAL REGISTER
SER. NO. 85-716,927, FILED 8-30-2012.
Acting EMrcctarof the United States Patent and Tfrdemait Office

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JC
Word Mark
Goods and
IC 025. US 022 039. G & S: Belts; Dresses; Footwear; Hats; Jackets; Pajamas; Pants; Scarves; Shirts; Skirts;
Services
Sweaters; Swimwear. FIRST USE: 20070831. FIRST USE IN COMMERCE: 20070831
Mark Drawing
Code
Serial
Number
Filing Date

85717008
August 30, 2012
Current Basis 1A
Original Filing
Basis
Published for
Opposition
Registration
Number
Registration
Date
Owner
1A
March 19, 2013

4345875
June 4, 2013
Attorney of
Record
Prior
Registrations
Description of

3029795;3563326;4029068;AND OTHERS
Mark
Type of Mark
TRADEMARK
Register
PRINCIPAL
Live/Dead
Indicator
LIVE
^ttttet> states of aw*

W*
Wniteb States? patent an* t&ratemarfc Office
Reg. No. 4,345,875

.
*-Cg

Registered June 4, 2013 newyork,ny iooii

Int. CL: 25
FOR: BELTS; DRESSES; FOOTWEAR; HATS; JACKETS; PAJAMAS; PANTS; SCARVES;

SHIRTS; SKIRTS; SWEATERS; SWIMWEAR, IN CLASS25 (U.S. CLS.22 AND 39).
TRADEMARK
PRINCIPAL REGISTER

SER. NO. 85-717,008, FILED 8-30-2012.
DAWN HAN, EXAMINING ATTORNEY
Acting Director ofthe United Statca Patent and Trademark Offlc
Type of Work:
Visual Material

VA0001655281
/ 2008-12-22
Application Title:
4T.
Title:
4T.
Description:
Electronic file
(eService)
Copyright Claimant:
Tory Burch LLC, Transfer: By written agreement.

Date
of Creation:
Date
of
2003
Publication:
2004-02-29
Nation of
First
Publication:
United States
MODCo Creative,
Inc, employer for hire; Domicile: United

States; Citizenship: United States. Authorship: 2-D
artwork.
Names:
MODCo Creative,
Tory Burch LLC
Inc
EXHIBIT 4
Type of Work:
Visual Material

VA0001812667
/ 2012-03-12
Application Title:
4T Design (no color)
Title:
4T Design (no color)
Description:
Electronic file
(eService)
Copyright Claimant:
Tory Burch LLC.
Date
of
Creation:
Date
of
Publication:
2004-02-27
Nation of
First
2003
Publication:
United States
Tory Burch LLC,
employer for hire;
Domicile:
United States;
Citizenship: United States. Authorship: 2-D artwork.

Rights and Permissions:
tiffany walden, Tory Burch LLC, 11 W 19th Street, 7th

Floor, New York, NY, 10011, United States, (646)
745-1279, (646) 745-1279, twalden@toryburch.com
Names:
Tory Burch LLC
Type of Work:
Visual Material

VA0001655281
/ 2008-12-22
Application Title:
4T.
Title:
4T.
Description:
Electronic file
(eService)
Copyright Claimant:
Tory Burch LLC, Transfer:

Date
of Creation:
Date
of
By written agreement.
2003
Publication:
2004-02-29
Nation of
First
Publication:
United
States
MODCo Creative,
Inc, employer for hire; Domicile: United

States; Citizenship: United States. Authorship: 2-D
artwork.
Names:
MODCo Creative,
Tory Burch LLC
Inc
EXHIBIT 5
Type of Work:
Visual Material

VA0001655228
/ 2008-12-22
Application Title: LUX T JACQUARD.

Title:
LUX T JACQUARD.
Description:
Electronic file.
Copyright Claimant:
Tory Burch LLC.
Date
of
Creation:
Date
of
Publication:
2007-11-30
Nation of
First
2006
Publication:
United States
Tory Burch LLC, employer for hire; Domicile: United States;
Citizenship: United States. Authorship: 2-D artwork.
Names:
Tory Burch LLC
Certificate of Registration
This Certificate issued under theseal oftheCopyright
*vi>.
Office in accordance with title 17, United States Code,

atteststhat registration has been made for the work
identified below. The information on this certificate has
beenmade a part of the CopyrightOffice records.
^62feu)
*-7ô-*J
Registration Number:
Registerof Copyrights,United Statesof America
VA 1-655-228
Effective date of
registration:
December22,2008
Title
TMeofWork: LUXTJACQUARD
Completion/ Publication _ _ _
YearofCompletion: 2006
Date of 1st Publication: November 30,2007
Nation of 1st Publication: United States
Author
Author ToryBurchLLC
Author Created:
2-D artwork
Work made for hire: Yes

Citizen of:
United States
Domiciled in:
United States
Copyright claimant
Copyright Claimant: Tory Burch LLC
11West 19th Slreel;7th Fl()or, New York,NY, 10011,United States
Certification
Name:
SethRKertzer
Date: December 22,2008
Page 1of 1
IPN#:
Registration#:
VAOOOl 655228
Service Request #: 1-145124842
Greenberg Traurig, LLP

G. RoxanneElings
200 Park Ave.
34th Floor
New York,NY 10166 United States
TITLE OF PRINT: LUXT JACQUARD

YEAR CREATED: 6.23.06
DATE OF INITIAL USE:
FALL 07
CREATED BY: IN-HOUSE, SUKI WONG

USAGE: ACCESSORIES-EMBOSSED PATENT LEATHER, FALL 2007
EXHIBIT 6
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Tory Burch
Founder and Creative Director, Tory Burch
Featured Lady Tory Burch launched her namesake company in

February 2004 to fill a void in the fashion industry. By offering
an affordable, accessible, luxury lifestyle brand, Tory innovated
the marketplace. Today, her collections are available at Tory
Burch boutiques, and in 450 select department and specialty
stores worldwide. Celebrity fans include Oprah Winfrey,
Jennifer Lopez, Cameron Diaz, Uma Thurman and Hilary
Swank. As a nod to her innovative brand, in 2008 Tory was
honored by the Council of Fashion Designers of America with
what is considered the Academy Award of fashion - Accessory
Designer of the Year.
Tory's retail days began when she was a sophomore in high

school and worked at Benetton folding sweaters. Later, her
first job in fashion was as an assistant for the designer Zoran
doing everything from sales to press relations. "It was an
incredible experience," she says. "And I learned so much."
After years working in the fashion industry and as a customer, Tory noticed there was a gap in
the market for clothes that were not only beautifully made, but also accessibly priced. She
wanted to create classic American sportswear that was luxurious and sophisticated at a more
attainable price point. So, in 2004 Tory started Tory Burch out of her apartment and opened her
flagship boutique in New York City's Nolita neighborhood.
Tory also wanted customers to feel like they walked into her living room rather than a store, so
she bucked the popular minimalist retail decorating trend by adorning her boutique with bright
orange walls, green carpet, vintage chandeliers and white couches to give the location a unique
and luxurious feel.
The next year was big for Tory Burch. Brand recognition for her company
changed overnight after Tory appeared on Oprah as "the next big thing in
fashion." That day, toryburch.com received eight million hits. Oprah also wore Tory's tunics on
the cover of O, The Oprah Magazine, in June 2005 and July 2006. Tory was also acknowledged
for her store's design aesthetic when Fashion Group International awarded Tory Burch the 2005
Best New Retail Concept for going against the minimalist retail design concept.
Over the next several years, Tory added stores in major United States cities, began international
distribution with prominent retailer Harvey Nichols in London and Dubai, and established her
retail presence in Milan, Tokyo and Manila.
The Tory Burch collection is influenced by many forces including Tory's childhood on a farm near
Philadelphia and her mother and father's unique sense of personal style. "My parents Buddy and
Reva are my greatest inspirations," she says. "They were such an effortlessly chic couple and so
gracious and welcoming to everyone they met."
Photography, art, films, travel and the work of interior designer David Hicks drive Tory's designs,
as well.
Inspiration at Tory Burch also comes from

team members. "Many people on our
team have been with the company since
Dream it
Launch it
Lrveit&
we started it out of my apartment six

years ago," she says. "We keep each
other motivated by coming up with new
ideas and finding inspiration everywhere
It's very collaborative, and people feel
like theyare an integral partof something|

special."
"We have an extraordinary group of
people who all have different opinions
and experiences. This diversity makes us
stronger, more collaborative and pushes
us to come up with great ideas,
business-wise and design-wise."
The goal at Tory Burch has always been to build a lifestyle brand that customers return to
season after season, year after year. "Every season we think about the collection as a lifestyle what do women need and what do they want?" she says. "We think about that across all our
categories." Within her collections, Tory strives to offer special, versatile pieces that women can
make their own.
After six years in business, Tory Burch is poised for more expansion. "We have managed our
growth, making sure that everything was done at the right time and for the right reasons," says
Tory. "We want to grow worldwide slowly and strategically, while always maintaining our quality,
prices and relationship with the customer."
When Tory started her company in 2004, she wanted to create a foundation to help other women
achieve their dreams. "Last year, we started the Tory Burch Foundation with our partner Accion
USA to financially empower women," Tory says. "Through microfinance, we enable women to
start, sustain and grow their own businesses. They in turn can help their communities, revitalize
local economies and support others."
Assorted Terra Apothecary Jars, Se.

..
One Kings Lane
<
Shop now!
What we learned from Tory: "Have confidence in your unique idea and be tenacious."
Will to Win
"My parents and family instilled in me a strong work-ethic, the confidence to do anything and a
desire to follow-through."
Customer Commitment
"We work hard to maintain a high level of design at a price that is attainable."
Good Times
"One of the most exciting moments was the first time I saw a woman wearing something from
our Tory Burch collection, I was so excited and flattered."
This Featured Lady was profiled by Megan L. Reese, WORDrobe Stylist for Her Write Image in
West Grove, PA.
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EXHIBIT 7
Latest Fashion Shoot
Kendall and Kylie's
<*-' PEOPLE PREMIUM
VIDEO
ROYALS
COUNTRY
TV
Emmy Moments Worth

Reliving
messing up my line. Blake
I was a little nervous about
have never acted before, so
and the rest of the cast. "I
to work with Blake Lively
dish about what it was like
the plot, she was ready to
she was hush-hush about
debut as well. And while
Hilary Duff won't be the only

famous guest stars on
tonight's episode of Gossip
Girl- designer Tory Burch
will be making her acting
Banks and
9in
made me laugh and put me at ease though, and the crew

was so gracious," Tory tells PEOPLE exclusively. Though
CW/GIOVAMMI RUHNO.'LANDOV
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10/05/2009 at 09:30 AM ET
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EXCLUSIVE: Tory Burch

Dishes on Filming Gossip Girl
with Blake Lively
Mi
PEOPLE.COM
Sarah Jessica Parker:
The Burger that

Changed Our Lives
to Expos
Prejudice
Man witt
Wears h
COURTESY OF TORY BURCH
SERENA AND BLAIR
Get style extras and howto's on the latest celebrity

fashion trends bx
subscribing to PEOPLE.
CLICK HERE TO SEE TORY BURCH'S LOOKS FOR
for Serena and Blair?
that would be cool enough even for college." We can't wait to

see Tory Burch on Gossip Girl tonight! Love her picks for
Serena and Blair? Shop them here. Read more on Gossip
Girl at cwTV.comTell us: What do you think of Tory's picks
this feminine look. I would add a custom-made headband
leather driving gloves add just the right amount of edge to
in contrasting colors, prints and textures. The booties and
fall collection (click through to see them). "Serena's style is

sophisticated yet rebellious," says Tory. "I think she'd live in
these leather leggings, and pair them with an embellished
top and oversized vest. It's a cool, sexy look that Serena
could wear uptown, downtown, and everywhere in between."
As for Blair: "[She] has a quirky ladylike style and looks great
and Leighton Meester's Blair Waldorf wear from her real-life
what she would like to see Blake's Serena van der Woodsen
Tory's scenes weren't filmed in her actual office, the designer

tells us that the set was a dead ringer. "They did an
incredible job recreating my office, down to the books I have
on my Lucite shelves and framed photos of my boys!" This
time around Tory didn't get a chance to dress Gossip's
leading ladies, but the designer definitely has some ideas on
Last Night's Look: Love It or Leave
family - this "Babycat" bag
Meet the newest member of the star's
I Really Love My ...
sxm
. Demi Lovato's 10 best looks
natural exfoliant
. Shop this video: Heal your soles with a
. Here's what the Emmy nominees should

wear on their big night
Stylelist
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. How Sin City Star Jessica Alba Channele
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5 Best & Worst Looks of the Week:
It?
w^jswsraweiiwgtf!
EXHIBIT 10
10/11/2014
Tory Burch: Great Choice for Kate Middleton's Mass Playdate - Princess Diaries - Racked National
RACKED
Get the latest from Racked National

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Tory Burch: Great Choice for Kate Middleton's Mass Playdate

Wednesday, April 9, 2014, by Kenzie Bryant
KATE MIDDLETON
NEW ZEALAND
PRINCE GEORGE
PRINCESS DIARIES
RACHELRILEY
ROYAL NEW ZEALAND PLUNKET
SOCIETY
TORY BURCH
Kate at Plunkett's Parent's Group at Government House, via Getty
Kate Middleton photos have surfaced from her tour Down Under (still in New
Zealand <http://racked.com/archives/2014/04/07/kate-middletorts-nz-look-istaken-straight-from-dianas-playbook.php> ) in which she's wearing the "Paulina"
dress from Tory Burch's Resort 2014 collection to a ten-baby playdate. The
dress is currently sold out <http://www.toryburch.com/paulinadress/52132424.html> on the site, at Nordstrom.com
<http://shop.nordstrom.eom/s/tory-burch-paulina-fringe-a-line-dress/3640559?
amp;country=US&currency=USD&cm_cat=datafeed&cm_ite=tory_burch_'paulin
a'_fringe_aline_dress:989402&cmjDla=dresses:women:dress&cm_ven=Google_Product_A
ds&mr:referrallD=3784a92b-bfe7-11e3-87fe-001b2166c2c0&origin=pla>and
Net-a-Porter.com <http://www.net-a-porter.com/us/en/product/403397?
cm_mmc=ProductSearch-_-us-_-Dresses-_Paulina&gclid=CJjbtra7070CFcx9OgodfGkAVg> , but seemed perfect for

chatting with the other parents and romping with the children on the floor.
http://racked.com/archives/2014/04/09/of-course-kate-middleton-wears-tory-burch-to-mass-play-date.php
1/3
Tory Burch: Great Choice for Kate Middleton's Mass Playdate - Princess Diaries - Racked National
10/11/2014
The baby hangout was organized by the Royal New Zealand Plunket Society,
which is a real thing, and the barrier to entry for was birthday: The little ones had
to be born within a two weeks of his July 22 birthday last year. Speaking of
George, he was wearing dungarees from British children's brand Rachel Riley
<http://www.rachelriley.com/> with a sailboat embroidered on it. And that's not
even the cutest thing. The cutest thing is the picture of mother and son below.
The cutest picture of George yet, via Getty
Kate Middleton's Red Look Is Straight from Diana's Playbook

<http://racked.com/archives/2014/04/07/kate-middletons-nz-look-is-taken-
straight-from-dianas-playbook.php> [Racked]
Kate Middleton Nearly Has Another Marilyn Moment in NZ
<http://racked.com/archives/2014/04/06/kate-middleton-has-second-marilynmonroe-moment-in-australia.php> [Racked]
Recommended
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http://racked.com/archives/2014/04/09/of-course-kate-middleton-wears-tory-burch-to-mass-play-date.php
2/3
EXHIBIT 11
SEARCH THIS BLOG
TUESDAY, SEPTEMBER 17, 2013
Michelle Obama Sells Out Tory Burch Tie-Dye Dress

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The first lady ofthe United States, Michelle Obama, can sell out a dress just as quickly as Kate
Middleton. She proved that this week when her blue Tory Burch tie-dye dress that she wore to a
Drink-Up function with Eva Longoria, sold out in a few hours across all the sites.
OTHER LOCAL FASHION BLOGS I

READ
iFashion
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Miss Milli B
We Are Awesome
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Zalebs
TeeTeeisWithMe
Elle Magazine
PopYaCollar
Miss Molly Fashions

Desmarais
Man of the Cloth

Miss Moss
Hurricane Vanessa
Of course the dress is doing a great job as I was definitely encouraged by it to drink more water.
A Fashion Friend
Actually I need much more encouragement. Every day. The dress itself would be a good idea.
BLOG ARCHIVE
June 2014 (20)

jftrjf / jf **"\"^"^j*
May 2014 (2)
April 2014 (14)

*
&
March 2014 (85)
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December 2013 (80)
November 2013 (124)
October 2013 (137)
September 2013 (115)
August 2013 (109)
July 2013(118)
June 2013 (95)
May 2013(109)
Sadly, the dress was dropped in price from $695 down to $347.50 before the FLOTUS wore it, and
then, just like that, it was gone. Grrrr.
April 2013 (99)

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For the record, Eva Longoria is wearing a Camilla and Marc dress. I like that one too.
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Stars Come Out for
Tory Burch Store
Opening in LA
Dame Helen Mirren

in Tory Burch at
Red 2 Premier,
Pippa Middleton on
Date Night in Cute
Tory Burch Sandals
New York
May 2010(20)
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m:qi
jb:@i
Recommend this on Google
December 2009 (22)

November 2009 (28)
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September 2009 (33)
1
COMMENT:
Anonymous said...
Oh what a dress! Surprised about the designer though, at first glance I thought it must be a
August 2009 (43)

July 2009(41)
June 2009 (87)
EXHIBIT 12
COUNCIL of FASHION DESIGNERS of

AMERICA
01 ABOUT
CFDA
Members
02 MEMBERS
03 PROGRAMS
04 AWARDS
05 NEWS
06 RESOURCES
The CFDA membership consists ofmore than 450 leadingfashion

womenswear, menswear, jewelry, and accessory designers.
Membership is by invitation only, and is open to Americans
designing in the United States or abroad or international designers

whose businesses are based in the United States.
TORYBURCH
Tory Burch is CEO and designer of the luxury lifestyle brand Tory Burch. She grew up in
Valley Forge, Pennsylvania and graduated from the University of Pennsylvania with a degree in
art history. Tory then moved to New York to pursue a career in fashion and worked for some of
the most influential American designers including Ralph Lauren, Vera Wang and Narciso
Rodriguez at Loewe.
After years of working in fashion, Tory noticed a void in the market for a collection with a
designer aesthetic at a more attainable price point. In 2004 she launched Tory Burch, a lifestyle
brand rooted in classic American sportswear with multiple categories, including ready-to-wear,
handbags, shoes, jewelry and accessories. The collection is available at 65 boutiques across
the U.S., Europe, Middle East and Asia, www.toryburch.com and over 1000 select department
and specialty stores worldwide.
Tory Burch has received recognition from the fashion industry, including the 2005 Rising Star
award from Fashion Group International; 2007 Accessory Brand Launch of the Year from the
Accessories Council of Excellence; the 2008 CFDA for Accessory Designer of the Year; and
Glamour's 2011 Woman of the Year award. In 2010, Tory was named one of Forbes' Most
Powerful Women in the World, and in 2011 she was chosen as one of New York's 50 Most
Powerful Women by Crain's New York Business.
An avid philanthropist, Toryworks with several charitable organizations and holds positions on
the board of the CFDA, the Society of Memorial Sloan-Kettering Cancer Center and the Startup
America Partnership. In 2009 Tory launched the Tory Burch Foundation to empower women
and families, initially through microfinance and mentoring in the United States. For more
information please visit www.toryburchfoundation.org.
EXHIBIT 13
FAST COMPANY
HOW TORY BURCH MEASURES UP

AGAINST HER COMPETITORS
THE AFFORDABLE-LUXURY CATEGORY, FASHION'S
FASTEST-GROWING, IS DOMINATED BY AMBITIOUS,

MARKET-SAVVY BRANDS.
BY JEFF CHU
I.TORY BURCH
Founder's current
role: CEO, creative
director/designer
CEO: Burch
Founded: 2004
Headquarters:
New York
Revenue in 2013:
$800 million
Employees (in
2013): 2,000
Stores in the U.S.:
62
Notable
collaborations:
Illustrations by Ollanski
Estee Lauder,
Fossil, Luxottica
Namesake's net worth: $1 billion
Signature: Ballet flats with the iconic double

medallion
-T
Namesake's net worth: $100 million
Signature: Tote bags with a comedic repetition of the

Marc Jacobs name on them
Innovations in retail: At pop-up store, accepted

pavment for fraqrance samples in social media posts
Founder's current role: Chief designer
CEO: Mark Weber (LVMH group)

Founded:1984
Headquarters: New York

Revenue in 2013: N/A
Employees (in 2013): 1,300

Stores in the U.S.: 64
Notable collaborations: BaubleBar, Estee Lauder
Namesake's net worth: $400 million
Signature: All-black palette
Innovations in retail: Testing a mobile app that works

with clothing-embedded sensors to direct customers to
items in stores
Some figures courtesy of Fashion Business Intelligence.

*An exact number could not be verified.
RELATED ARTICLES
Pretty Smart
The Secret To Tory Burch's Success: Storytelling

How Did Tory Burch Build a $1 Billion Brand So Quickly?
Patience.
[Photos by Erik Madigan Heck, Hairby Jessica Cillin, Makeup

by Berta Carnal]
A version of this article appeared in the September 2014 issue of
Fast Company magazine.
JEFFCHU
Jeff Chu writes on international affairs, social issues,
and design for Fast Company.
CONTINUE
August 18, 2014 | 6:00

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The Tory Effect
Like {2D SHRRE

Global style icon, consummate New Yorker and ailAmerican girl. Tory Burch is all that and more, wrapped
into one lovely, talented and very savvy package.
The average American

doesn't speak a second language.
NKWfORK
,;:", /.'".v'"'' . ;l!.,;v;:':'ii::,: ,;.. ,,,
For those who won't settle,

there's Rosetta Stone.
HAL RUBENSTEIN, MAY 2014
LEARN MORE
I'm sure she has her moments, but have you ever seen a picture of Tory Burch where she doesn't seem
enveloped in the essence of serenity? In fact, it's hard to imagine her ever trucking after a taxi, racing outfromspin
class with wet hair, eating on the run or ever losing her cooljust a few of the frantic, normal behavioral traits
common to many New Yorkers. But don't be misled by the low-decibel tones, the beckoning half-smile or ever-
placid demeanorthatbetray her Philadelphia mainline breeding (think Grace Kellyor Katharine Hepburn as Tracy
Lord in The Philadelphia Story).Tory Burch commands ownership of the two key traits all New Yorkers must have
to succeed: She trusts her gut, and she is fearless.
Against popular wisdom, Burch opened her first freestanding store in 2004, the same year she launched her
business on Manhattan's Elizabeth Street, in the very-now-but-so-not-then flocked-to neighborhood of Nolita.east
ofSoho. Few would have bet on this location as a game/set/match for a fledgling clothing line getting press for its
beaded cardigans, Nantucket-friendly boho tunics and citrus-hued flats sporting her now instantly recognizable
double T logo. But at the close of its opening day, the new shop had been nearly stripped clean. "Myinitial fiveyear plan was to have three freestanding stores," Burch says. "Maybe a few more, just as long as we grew
organically."
Itturns out the lady has a Kelly green thumb. Ten years later, Burch's affordable, aspirational and often adorable
approach to contemporary luxury spans a network of more than 120 stores across North America, Latin America,
Europe, Asia and the Middle East, with plans for further global expansion, and annual sales approaching $1
billion.
"It's going well," Burch says with the same satisfied reserve that other women might acknowledge a well-attended
lawn party. But like the sawiest of New Yorkers, Burch exhibits another enviable trait: She never shows her hand
or her sweat. Around this town, that's the mark of a winner.
HAL RUBENSTEIN: Your

success was almost
instantaneous. Did you know it

would take off so quickly?
TORY BURCH: Yes, it was a
rapid trajectory, and I admit we

did begin with high hopes, if
http://deltaskymag.delta.com/Sky-Extras/Favorites/Tory-Burch.aspx
1/3
1/7/2015
Tory Burch, Favorites, Extras| Traveldestinations, blogs, contests and offers from DeltaSky Magazine + deltaskymag.com
because Iwas so eager to make
money to create our foundation
[which supports female
entrepreneurs]. But it was a
tremendous amount of work to
find that one opening, that niche

where we knew we would fit. We
specifically targeted that

particular customer who wanted
fine crafted things that didn't
cost a fortune. We knew that
woman was out there, but didn't

want to wait for her to come to
us. We decided we'd have to
reach out directly to her.
What attracted you to this

particular customer?
Photo by Sean Davies.
Like minds, perhaps. As a

woman, it's natural to want to
design the clothes that I personally want to wear, because they suit my work, they suit my life,they suit my age. And
in doing so, you want to celebrate and incorporate the inspirations that excite and inspire you.
What are those inspirations?
New York City plays such an important part because of its intense energy and the constant diversity of people you
find everywhere you go. Also, music, culture and fashion are so seamlessly interwoven in life in Manhattan. You
are surrounded by art and innovation. They are not saved for special occasions.
But you are not a native New Yorker?
No, I'm from outside Philadelphia, which is another city I will always love because it's home, and it's a city that has
a more casual way of doing things. Lifethere is also about being outside. Withthree boys, it's impossible to
imagine not spending lots of time outdoors. Surround yourself with nature and you can't help but think about colors
and prints and fabrics with an easy flow.
What's the bestfworst of living in New York?
The best is the convenience of being in the middle of the most exciting city in the world. The worst is having been
brought up on a farm in Pennsylvania, so I know my three boys need to be outside more often.
Do other cities play a factor in design?
Yes, but in a more imaginary way. I remember as a child hearing my mom and dad talk about their travels, and I
would run to books to see pictures of these exotic places. Ido love to travelon my last vacation I was enchanted
by Myanmar, and my sons were thrilled to be at Machu Picchubut you don't have to run around the globe to get
excited by the colors, fabrics and textures of other cultures. Ifell in love with the style of Deauville in the '60s for our
spring 2014 collection, but I've never been there. Then again, Deauville today is very different than it was in the
What is a key element in
becoming a success in an
industry as idiosyncratic and
volatile as fashion?
The clearer the vision you have

as a designer and as a
company, the more focused a
collection you and your team
can produce. The easier it is for
a customer to understand your
message. Not only is it
counterproductive and
exhausting trying to be
everything to everyone, it
doesn'tworkin business.That
doesn't mean we only appeal to

one kind of woman. Instead, we
Burch preps a model for the fall 2013 runway show.
have a responsibility to show
women how they canadaptour
clothes to their ages and lifestylehow to mix it with elements of their own wardrobe to create a personal style,
how they can wear what you love making and look special and unique. You can't expect your collection to do all
the work. You have to adapt, instruct and evolve. Your customer becomes your partner. And as they change, so do
you. You can never sit back.
Do you have a uniform when you travel? Are there essentials you always pack?
Travel is always foremost in my mind when lam both shopping and designing. I travel so much, and so do most of
the women I know. It makes you seek out clothes that are versatile, hold their shape and don't require a lot of
maintenance. For the plane, I usually favor a trench coat, a favorite pair of comfortable jeans and great flats. I
always travel with great sweaters, crisp shirtings, cotton jersey knit shirts, boots that can go from day to evening. I
always have a few of our signature tunics, which we have been making from the very beginning. One in cotton and
one in cashmere. Accessories to dress up and down or just wear because you think they are fun and will make you
happy. You're stuck ifyou don't choose clothes you can wear and repurpose throughout the trip. Not surprisingly,
these are but a few of the things we love to make.
What are the four things you always take on a plane with you?
A Porthault baby pillow, a Loro Piana cashmere wrap, pictures of my boys and a red ribbon for good luck. Iam very
superstitious, like my stepdaughters. I also always walk on a plane with my right foot and, yes, I knock on wood.
Do you turn off when you travel or are you constantly looking?
Relaxing is something Ido easily, but Iam always taking notes and posting pictures. The beauty of traveling is not
2/3
1/7/2015
Tory Burch, Favorites, Extras | Travel destinations, blogs, contests andoffers from Delta SkyMagazine + deltaskymag.com
merelyabout getting away from what you know but about findinggreat new things, imagining how you can put your
own spin on them. Ialso use travel to give our Web readers incredible tips on travel, clothes, food and shopping
that they probably won't find anywhere else.
Your website, TorvBurch.com. is one of the best-designed and most-visited websites in the industry [4.3
million visits and 1.8 million visitors per month]. It has been justly praised because it's more than an ecommerce siteit's about a way to live, to dress, to look at and explore life that appears to be in perfect
harmony with your brand.
The site is ever-involving. Naturally,we were so interested in an online component when we launched the brand
that we had an e-commerce site up two months after opening our first store. But as soon as we did that, we realized
the site had to do more to keep our customer engaged and to learn more about them. Our customer is inquisitive,
she has an active life, she wants to know what else is new and exciting and she wants ideas about more than just
what to wear, because ifyou divorce fashion from reality you can't stay relevant. Byoffering her fresh and focused
information, and incorporating other designers, musicians, artists, chefs and tastemakers and showing what we
love in terms of food, home, decor, gifts, itopened up new lines of communication so we can learn more about the
woman who wears Tory and how we can serve her better. And by letting them communicate what they like and
want to know more about, they help us build a better site.
What's next?
Nowwe are going to go global in a way Ididn't originally dream about. We just opened a flagship in Munich. We
are opening on the rue St. Honore in Paris, which is so very exciting. We already have shops in the U.K..Rome
and Tokyo. We are about to introduce watches: We have partnered with Fossil to come up with a line of watches
that are so beautiful but not expensive. We don't do a lot of licensees, but these Swiss-made watches will be very
special and Ican't wait for people to see them. We are also working on a seriously functional sports line, clothes
you can wear at work and at the gym. And we are building beauty very slowly, organically. We started with one lip
color and one bronzer. Now we are up to 12. We are going to do activewear, because I want clothes that Ican
wear to class as well as to the office. And we have plans to start menswear. My boys are growing up and Iguess I
still want to dress them. I'm hoping they willthink the clothes we do are cool, but I never take anything for granted.
Ever.
4 PREVIOUS
SPILL IT: TELL US WHAT YOU THINK! //

JEAN K WITTER
Cannot find links on website to Tory Burch's must-visit spots in Paris & Shanghai, as listed in Sky magazine. How
can I do so?
5/20/2014 6:51:30 AM
Sky Magazine
Hi Jean, that piece is part of the exclusive content now featured in our digital edition. You can find it at
http://deltaskymag.com/may.
5/20/2014 9:30:50 AM
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TODAY | September 26, 2013
Designer Tory Burch: 1 learned on the job'

Fashion designer Tory Burch tells TODAY'S Savannah Guthriethat she didn't let
inexperience keep her from starting her company, which has grown into a mult-billion
dollar enterprise in less than a decade.
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Transcript of this video
his content comes from Closed Captioning that was broadcast along with this program.
public. first, an entrepreneur with global clothings and accessories, first a look at how she has spun fashion goals.
[it's the double t medallion that has women screaming, whether it's the clothing the jewelry or those iconic ballet flats you love, tory burch has more affordable prices, a
multi-billion dollar brand cooked up ten years ago in the kitchen burch shared with her then husband chrisburch. it opened and ten months later on an episode of oprah hit
the big time with the midas touch there new york style center tory burch is hailed as the next ting in fashion.
the next day, she had 8 million hits online, travel hit at home, burch and her husband divorced, maintaining respectful relationship for the three sons and the company
they shared together.
that is until 2011 when chris launched his own brand with a similar aesthetics, it sparked lawsuits, tory's company calls it a knockoff, chris claims claimed the two didn't
compete, giving significantly lower prices, the two eventually settled out of course, since then, there has only been good news for burch, making world's billionaire's list,
launching a line this month to rave reviews, now a staple of any successful designer brand, her very own fragrance and tory burch is with us now. good morning to you.
good morning.
let's let that soak in a moment, self-made billionaire, can you believe that?
no, i really can't, you know what, we have worked so hard, our company will be ten years in february. we have a great brand.
you had a billion dar company in less than ten years, are you the first to say you didn't start out with design experience, this was inspiration, a lot of women are
watching this, they want to know how you did it?
i definitely learned on the job. i would say. if have you an idea, a unique idea, it's a lot of work, but you can do it.
you have expanded left and right, do you ever look at it and think, okay, what is too big? you don't want it to get out of your control, are you so much a part of what
makes the prand special.
we think of it every time, every store we open, it's a lot of thought we're strategic, we've had so much rapid growth, it's been measured.
there have been highs and lows, we mentioned you had a legal battle with your ex-husband over his, really, did you hear about that? i guess the question is, i know
you've settled it now. have you really moved on from it? are you two in a place where you are back to getting along and being respectful and this is behind you?
we really have, i never wanted a legal battle, so from the beginning, i always wanted to settle, we have six kids that we love and it's really behind us. it really is. we talk,
we talk about the. he has his own businesses now.
so there is no hard feelings, you don't look at the success of c wonder and say gosh, that's a knockoff or a ripoff.
i always wanted chris to be a success, that was never a part of the conversation.
you had an unconventional path for a designer, i have to show a picture of you as a littlegirl, you kind of had the tory burch being then, you had a hand bag, let's show
the picture of you coming up. i thought to myself, you never had one of those gotm phases, did you?
maybe number i never had the goth fachltz i wore a lot of grateful dead tee-shirt, it was preppy, i always had a different kind of style.
tell me about the from gravenlts it is a rite of passage, you know you are big when you have a fragrance, was it fun?
estee was fun. it was a five-year conversation with them, learn d.c. science of what goes into a fragrance.
can i try it?
i hope you do.
what did you use in it?
we started with bessey bear a big fragrance my father wore, then we put sandalwood, man da rir - mandarine.
in your spring runway, there can be no greater ambition to bring back the fannie pack.
we dont call it that.
when you think of, this is a new passion, it's time has come what is old is new again.
as soon as my mother saw it, we said the belt bag.
it sounds much better.
tory, thank you for your success, it's great to have you here.
thank you very much.
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Billionaire Tory Burch's Seven

Lessons For Entrepreneurs
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I Walk down any sidewalk from New York to Shanghai and you'll see women
I wearing ballet flats with Tory Burch's distinctive double-T logo. They're also
I wearing her patterned tunics, handbags, clutches, and bold country club-chic
iTJants, skirts, dresses, and tops. Tory Burch hasn't just made preppy clothes
hip and modern, she's built a multi-billion dollar fashion empire in less than a
decade. And she's leveraging her experience and influence for the greater
good with the Tory Burch Foundation, an organization dedicated to
empowering female entrepreneurs.
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Recentlynamed to Forbes' list of the World's 100 Most Powerful Women.

Burchhas helped change the world's notion of what being a female
entrepreneur meansthe fashion mogul has proven that it doesn't have to be
hawking cupcakesor launching a Mommyblog. At just 46 years old, she's part
of a growinggroup of women who are newlyminted, self-made billionaires,
like fellow power woman &Spanx founder. Sara Blakely. Including Burch and
Blakely, 16 of this year's Forbes Power Women founded their own businesses.
I recently sat down with Burch at the inaugural Forbes Women's Summit
where she opened up about her dazzling journey to the top of the fashion
worldand offered some entrepreneurial advice and leadership lessons she's
learned the hard way on her journey to incredible success.
1. "Follow your passion." Although Burch grew up as a self-described
tomboy, she became interested in art history and fashion in college at the
University of Pennsylvania and went on to work for influential designers like
Ralph Lauren and Vera Wang. And when she decided to launch her company,
she dreamed bigshewanted a global brand. "I never designed before this
company," Burch says. "[Youhave to] take a risk and put yourself out there.".
2. "Thicken your skin." Burch went through 10 names (including Tory by
TRB) for her company before reluctantly settling on using her own. And while
she's proved wrong all of the naysayers who thought she'd fizzle out in a flash,
having her own name on the brand makes her acutely sensitive to criticism.
Which is why she relies so much on the advice of her parents to thicken her
skin. "Being a sensitive, thoughtful person opens you up for criticism and
being affected by it," Burch says. "I heard and tried not to listen to a lot of
negativity. The noise and negativity were just the sidebar."
3. "Put the right people in the right positions." Burch describes herself
as a very loyal person, and one of the toughest business lessons she learned
was that loyaltya strength in most circumstancescan also be a weakness
for her. Loyalty made her reluctant to make staff personnel changes. "When
you have the wrong people in the wrong position it affects the entire
company," she says. "It's a hard lesson to learn. It has a ripple effect." Be
aware of the potential for your strength to become an Achilles Heel.
4. "Create relationships." As part of the programming for her Tory Burch
Foundation, there are 10 mentoring events a year. That's because Burch
believes that networking, collaborating with, and rooting for other women
helps you make lasting relationships that organically further your career and
set you up for success. "Every job that you have might not be the perfect job,
but you really take away different things, and you create relationships," says
Burch, who counts Saks' Ron Frasch. Google's, Eric Schmidt, as well as her
older brother and company's co-president, as major mentors in her life.
5. "Go big." On the one hand, Burch had a five-year plan of opening just
three stores. (She has launched dozens around the country and world,
including stores in Portland, Oregon and Duabi.) On the other hand, from the
beginning, she knew she wanted to build a global brand. Just as she's had to
roll with setbacks, she's also embraced the happy boosts that come along the
way, like the Oprah Winfrey show "Next BigThing" shout-out that gave her 8
million website hits, and media coverage from her editor friends in the
magazine world.
Luck is important, but the power of networking and collaboration helps you
make your luck.
6. "Be authentic." While talking about her personal life and her children are
off-limits, she is an open book when it comes to her business, her foundation,
and the Tory Burch brand in general. One for instance? When her company
changed operating systems, they endured a glitch-y six-month period where
they couldn't track shipments. But rather than hiding the snafu, Burch
decided to embrace social media and be transparent with customers about
what was happening. The result? Her customers became her advocates.
7. "Buckle up." When you see someone as successful as Burch, it's easy to
view that success as a destination she's reached, instead of an ongoing journey
that takes hard work, creative solutions, handling setbacks, and constant
innovation. Burch admits that being an entrepreneur isn't for everyone: She
works long hours and remembers the early days when her business was
launching when she would put all of her children to bed and then be on the
phone until 4am with her Hong Kong office. "Buckle up, and know that it's
going to be a tremendous amount of work, but embrace it," says Burch.
Setbacks are always going to be theresome of them even bigger than the
challenge of launching a business in the first placeand it's crucial to think of
them as learning opportunities.
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MAGAZINE - TRACKED
Tory Burch
The designer turneda tinylinethat startedin her kitchen into a powerhouse. Now shetakes on Fashion Week, homework
crises and a sprawling emp ^j|2ffi|<QJ faltering smile
m
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1 Comment
By ADRIENNE GAFFNEY
VIEWFINDERS
Updated Oct. 26, 2012 9:23 p.m. ET
Pw.e* tv The all now 2015 C Class
join our journey: We're taking a freshlook

at America's cultural landscape through the
'ens of photographer and social influence!
Ryan Plett chronicled as he travels
cross-country .behindthe wheel of a 2015
Mercedes-Benz C-C.ass
Burch holds one of a string of daily staff meetings in her vibrant orange office. Photography by Kevin
Tachman
LESS THAN 10 YEARS AGO, Tory Burch was a star on the New York social scene,
with an army of six gorgeous children and step-children, a Main Line pedigree and an
Mclftf Wfil
RECOMMENDED STORIES
countless vanity projects of the rich and famous have been born with fanfare only to
Pade into oblivion thereafter. Burch is the exception. With a stacked-T logo as instantly
I recognizable asthose of brands established generations prior, the 46-year-old has
I created an international retail empire, now reportedly worth $2 billion, and has earned
I the respect of her peers.
A Day With Tory Burch
The success of her line has made clear
that sometimes all it really takes to make

it are simple, chic clothes. Burch, CEO
and designer, has never bought into the
notion that great fashion has to be raw
or edgy, instead proving that classic
sportswear can be just as influential
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6
5;40p
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OltiM*
and develop a devoted following. A rare

hiccup occurred this year when her exhusband and former business partner,
4:45 pm
6
56
74
View Graphics
Chris Burch, opened C. Wonder, a rival

emporium in Manhattan, raising the
possibility of a legal skirmish. Tory, who
now dates music mogul Lyor Cohen,
has been handling the matter quietly,
with typical reserve.
A veteran of Ralph Lauren's press department, Burch functions as a walking

advertisement for her line. Instantly recognizable by her golden hair, trim figure and
impeccable style, she is a source of fascination to the women who wear her clothes
to buy a Burch is to buy a bit of the woman herself. Her iconic ballet flats are named
after her much-adored mother, Reva. The signature caftans, which reached cult
status after being adopted by Oprah, convey a kind of blue- blood ease that feels
genuine rather than hackneyedand, more importantly, they happen to flatter a wide
range of sizes and ages.
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In addition to designing, Burch travels around the globe to promote her brand; leads
the Tory Burch Foundation, which helps mentor female entrepreneurs; and oversees
a brand Web site that rivals the best lifestyle blogs. Following Burch for a day
provides an almost maddening lesson in maintaining the perfect deportment while
balancing late-night fittings, lost homework and an endless stream of meetings.
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Madder Men
Leonardo Premutico // Johannes Jacobs
Uofounders, Johannes Leonardo
Bacardi, Google, Coca-Cola, and Anheuser-Busch InBev mark an

impressive client roster for five-year-old Johannes Leonardo,
started by former Saatchi & Saatchi New York executive creative
Tweet
directors Jan Jacobs and Leo Premutico. The duo s work has
been lauded by major awards shows such as the Clios and Cannes
Lions, and their 2008 Super Bowl spot for Tide featuring the
talking stain was named among the top 20 Super Bowl ads of
all time by Advertising Age. More recently, the team s talent has
been evident in Google s Re:Brief project. Jacobs s personal
style? I do love a great suit even though I rarely put one on I m
really a beach bum at heart. Premutico defines his simply: jeans,
T-shirt, and a jacket. We need stuff we can be loose in and think
creatively in. Not clothes that we re just wearing for meetings.
RH Shan
{^Jreddlt
Lori Senecal
Chairman and CEO, Kirshenbaum Bond Senecal+
Qj Submit
ôri Senecal oversees an ad agency that can boast of many iconic
campaigns, from the Snapple Lady to Target s Bullseye.
Since joining in 2009, she has helped client BMW reintroduce The Ultimate
Driving Machine. Previously, she served as president of the New York office
of McCann Erickson, where she worked on major brands, including Xbox and
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Coca-Cola. The Montreal native speaks fluent French and wears all black, all
the time. Great advertising is not that different from great style both have
more impact when they are unique, distinctive, and leading edge, she says.
Her style is inspired by Apple, because she loves its clean modern edge,
monochromatic sleekness, and consistency. That goes for her food, too: The
Tribeca resident can be found every Friday evening eating dinner at the bar at
Nobu.
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Before joining the advertising world, Jerome Austria worked the night shift as
a security guard, drove a gas truck and fueled planes at an airport, and
collected carts in a Costco parking lot. He has since directed an interactive
Nike commercial featuring Rihanna; spearheaded Volkswagen s online
Super Bowl teaser, The Bark Side ; and amassed more than 50
+ show more
international awards for his work. Earlier in his career, Austria spent nearly
three years at Wieden & Kennedy New York, where clients included Cocaôla, Nike, and ESPN. He enjoys checking out the latest curated craziness
by Humberto Leon and Carol Lim at Opening Ceremony in Los Angeles. And
how does he characterize his style? Teenage grown-up.
Emmanuel Andre
ÔO, TBWA Worldwide
When Emmanuel Andre grew bored with finance as a business school

student, he sought a more creative career: advertising. Andre served as
TBWA Worldwide chief of staff for three years before becoming regional
director of TBWAAsia Pacific in Hong Kong. He returned to New York in
2008 and assumed the role of COO for TBWA Worldwide; clients include
Apple, McDonald s, and Visa. I lead a double life, he says. When he s

not attending to his duties at the ad agency, he s engaged in portrait
photography. His work has been showcased globally and published in various
books and magazines. Behind the lens, you 11 find him in a T-shirt and jeans;
at the office, he almost always sports a black suit, white or blue shirt, and a
skinny black tie. I like to sophisticate the unsophisticated, he explains.
The very best pieces are often the simplest ones that stand the test of
time.
David Eastman
EO, JWT North America and Worldwide Digital Director
David Eastman (left) was an actor before he got into advertising. Post-drama
school in the U.K., he landed a gig in Glengarry Glen Ross. That was as
good as it got, he says. Transitioning to the ad world came through an early
role at Agency.com, a briefly public company that eventually became part of
TBWA. He s now CEO, JWT North America and worldwide digital director,
and has worked with brands such as Johnson & Johnson, British Airways, TVtobile, Mercedes, and Nestle. On Mad Men, he says, everybody wore suits,
even the creatives. There must have been a moment in time when the account
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people were the only ones who wore suits. To this day, they re called
suits.
His style? A mix of casual and formal. If I try to emulate anyone
it is probably my father. His influences were people like Cary Grant.
Mark Beeching
Worldwide Chief Creative and Strategy Officer, Digitas
Vlark Beeching s (right) career began in children s theater as a writer and

actor. He later worked as a radio journalist in Munich but left to pursue a
doctorate in linguistics. He eventually abandoned that to set up a London ad
agency with his brother. I knew more or less nothing [about advertising]
but was happy to learn, he says. Today, Beeching is worldwide chief creative
and strategy officer at Digitas, an integrated digital agency where he s
worked with big brands like American Express, Samsung, Delta, Kraft, and
Procter & Gamble. The best ideas always come from identifying with people
as people, not as advertising targets, he says. Beeching s style is influenced
by his father, who wore secondhand suits from thrift stores and white canvas
sneakers. It embarrassed me at the time, but looking back, he always looked
like a rock star. Beeching, the father of two daughters, is a lifelong
nondrinker and has never smoked a cigarette. Not very Mad Men, he
says. But it s my own form of rebellion.
Sara Rotman
Founder, CEO, and Chief Creative Officer, MODCo Creative

Sara Rotman is founder, CEO, and chief creative officer of creative branding
agency MODCo Creative short for My Own Damn Company. Rotman s
shop sits behind Nina Ricci, Theory, Jack Rogers, and Carolina Herrera,
among others but she s most proud of her work with Vera Wang and Tory
Burch. She worked directly with Burch to create all brand materials,
including the iconic Tory Burch logo, package design, and original store
design. MODCo also created brand images for all of Vera Wang s licensed
brands, including those for David s Bridal, Zales, and Kohl s. MODCo s
tattooed Boss Lady, as dubbed on her business card, who doubles as a
competitive polo player and owns eight horses, also founded scarves and
accessories line Loquita. When it comes to fashion, Rotman values beautiful
construction and fit. She describes her style as punk rock with a couture
edge, and a little vintage thrown in here and there.
Steve Stoute
Founder and CEO, Translation
last summer at the U.K. s Glastonbury music festival, Beyonce s set

included a rendition of Happy Birthday. It was directed at neither Jay-Z
nor the Queen of England, but Steve Stoute, who has scored her deals with
the likes of Samsung and Tommy Hilfiger. Since launching Translation in
2004, he has also paired Jay-Z with Reebok, LeBron James with State Farm,
and Justin Timberlake with McDonald s. His proudest recent achievement:
winning the coveted Bud Light account. It said a lot about how fast the
company has grown. Stoute sees a resurgence of the old model, in which
agencies are in charge but this time, he thinks it will be small, agile players
making waves. When you watch [MadMen], clients let the big agencies
lead them, he explains. With the smaller companies now, clients are
saying, We want some independent thought.
\jaz Ahmed pays little heed to clothes; he hasn t got time. Efficiencycomes
through a uniform of J.Crew slacks, black cashmere sweater, and Nike SB
line skateboarding shoes. My style is more Silicon Valleythan it is old>chool Madison Avenue, says the cofounder and chairman of digital shop
AKQA. Indeed, style shortcuts are a consequence of industry success. Ahmed
was 21 when he founded AKQA in 1995. Today his global agency counts Nike,
Volkswagen, Google, and Heineken as clients. Early heroes Sir Richard
Branson and Sir Alex Ferguson (manager of football club Manchester United,
rival to Ahmed s beloved Arsenal club) have provided the author of Velocity
(with Nike s Stefan Olander) a blueprint for winning. Ahmed s proudest
wins? When the people you hire achieve success for your clients, he says.
The other ecstatic part of my career is when the ideas that we produce are
of real interest and use to audiences.
Jimmy Smith
3EO and Chief Creative Officer, Amusement Park Entertainment
!fhe couldn t be a professional basketball player, his childhood dream, then

Jimmy Smith at least wanted to dress the part. I m a Jordan guy. Brand
Jordan, Smith says. All the retro sneakers, all the original Air Jordan. If
I m getting dressed up, then I 11 actually put on a Jordan tracksuit.
Otherwise, it s shorts, T-shirt, and gym shoes. The author of Soul ofthe
Game and The Truth and the writer behind the MTV documentary
Battlegrounds for Nike now runs Amusement Park Entertainment, a co/enture with IPG. That s after a career that included stints at Wieden &
Kennedy, where he created Book of Dimes,
an ad starring LeBron James
and Bernie Mac for Nike; BBDO, where he served as executive creative
director for Motorola; and TBWA/Chiat/Day L.A., where he was group
creative director on Gatorade. Smith drove the transformation of Gatorade to
simply G, a decision that helped evolve the product line. Influences:

Jesus Christ. My parents. Family. The guy who raised me creatively was
Bootsy Collins. Before our shoot, Smith had never worn a suit, not even to
his mother s funeral. I wore a jersey suit. A white one. I knew she d be
like, Now, Jimmy, you know you don t wear suits.
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Tory Burch Modernizes Assortment

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By Deena M. Amato-McCoy
Bold prints and the double-T logo medallion are hallmarks of the affordable luxury Tory
Burch brand, which appeals to women ranging from working professionals to soccer moms.
As the brand expands its merchandise categories, it continues to gain more attention from
consumers, putting pressure on Tory Burch to guarantee it can meet this demand.
Already planning its chain's assortments according to consumer shopping patterns and
inventory data, the company is working to gain more visibility across its other business
divisions, wholesale and international. By adopting a point-of-sale-based reporting solution
that provides timely visibility into customer demand, Tory Burch is primed to deliver more
precise, tailored product allocations across its enterprise.
Tory Burch set out in 2004 to create a lifestyle concept including ready-to-wear, handbags,
shoes and jewelry. Inspired by her love for art, music, culture and travel, her brand is
synonymous with graphic prints, bold colors and unique, signature detail.
Fast-forward eight years, and Tory Burch is now a brand sold across a 67-store chain, as well
as in 1,000 department and specialty stores, including Bloomingdales, Holt Renfrew,
Nordstrom, Bergdorf Goodman, Shopbop, Lane Crawford and Saks Fifth Avenue, globally.
Managing relationships with these retailers is the job of the company's wholesale division
and is a crucial component of the brand's growth. However, without insight into POS and
transaction data from retail partners, "we're not able to tell how well our products are selling
across their locations," said Mike Giresi, CIO, Tory Burch.
Historically, department and specialty retail partners provided Tory Burch with merchandise
reports, created in Excel, illustrating sales on the size- and color-level, but this data didn't
delve into specific sales across specific stores or regions. Also, sales representatives would
spend four hours weekly, manually combining Excel reports and applying dedicated formulas
just to understand how certain unit colors and styles sold for a specific week across the chain.
These data sources had to be quickly integrated into a central merchandising analysis tool
that users could easily access and use to analyze the selling performance so as to determine
merchandising actions for the coming week.
"It was a time consuming process, and once it was complete in one category, such as readyto-wear, we had to apply the same process two more times once for shoes, and another for
jewelry and accessories," he explained. "Even with this information, we still could not get the
granular data we needed to streamline our assortments."
Tory Burch realized it needed clean and complete retail selling and inventory information, and
that UPC detail was required to competitively plan, adapt and move goods through the chain
faster than ever before. The company required data collection from many types of data
sources and formats that at the time were not available in a timely manner, including retailer
portals, merchant
spreadsheets and PDFs.
To resolve this issue, Tory Burch partnered with Sky IT Group, a New York City-based
company that provides a POS-based reporting program, giving each manager in the
wholesale channel timely visibility into the customer demand and inventory data needed to
drive precise in-season management, synchronized production and delivery cycles, tailored
product allocations and enhanced retailer-vendor collaboration. The SKYPAD platform allows
Tory Burch to drill down to specific information, including particular style, color or size and
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understand how this item is selling at individual stores.
The wholesale division is live with the solution, and the new process has improved assortment
planning and eliminated the need for a dedicated associate to manage and compile this data.
Tory Burch is currently adding its international operations onto the system.
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The next step is to take the same measures to bring its retail division onto the solution, so
that it can streamline the sales information by category. By having all three operating groups
on the system, the brand will be able to more easily compare sales across its major product
categories week-over-week. Tory Burch went live on all three divisions last summer.
Deena M. Amato-McCoy
Read up on all of the 2012 Top Innovators here, and click here to submit a nomination for
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JANUARY 29, 2012, 12:19 AM | Tory Burch, known for her
,.' ';,.,,
classic tunics and popular Reva ballet flats, has taken the fashion
world by storm. Launched only in 2004, she now owns 65
boutiques all over the world. Rita Braver sat down with the fashion
mogul to discuss her family, her career, and got a sneak preview at
an upcoming collection for New York Fashion Week.
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Tory Burch resonates with us

By Joy Sewing November 9, 2011 Updated: November 10, 2011 12:25pm
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Photo By Nick de la Torre
1 of 16
Fashion designer Tory burch makes a specail appearance to show her fall line Neiman Marcus, Thursday,
Nov. 3, 2011, in the Galleria in Houston. ( Nick de la Torre / Houston Chronicle )
HJIB1
mm
Tory Burch is curled up on the floor in a dressing room at Neiman Marcus in Houston, looking fresh despite
having just arrived on an early-morning flight.
"I never imagined this," Burch, 45, said, as she tucked her legs underneath her body. "I had a five-year plan of
M0revideos:
three stores. I had a concept, but I didn't realize it would resonate with a lot of women."
hibii^Pb
Tory Burch is one of the fashion industry's fastest-growing companies. The company has about 1,000
employees and revenues expected to top $500 million this year, according to the Wall Street Journal. She's
expanded from her signature elegant tunics and ballet flats to a complete ready-to-wear collection with
accessories, eyewear and a new fragrance deal with Estee Lauder. She hopes one day to design a sportswear
inn
line for yoga, tennis and golf enthusiasts.
Burch casually mentionsthe upcoming opening of her 61st boutique, in Honolulu's Waikiki. There are 44 Tory
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Burch stores in the U.S., including one in the Galleria, and outlet stores in Cypress and San Marcos. There are
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She smiles bashfully, as if humbled by her own popularity.
(She Budgets)
Burch thinks women support her brand because she's one of them. A working mother to three boys and three
stepdaughters, she juggles the demands of running a growing company, designing collections and attending
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rasn't a good mom, I wouldn't be a good businessperson," Burch said. "You have to have boundaries. My
ren come first no matter what. I take them to school every morning, and I'm home by 6:30 regardless of
(Bankrate)
what's happening."
Bom and raised on a farm in Valley Forge, Pa., Burch grew up a self-described tomboy who liked sports and
hanging out with three brothers. She had little interest in fashion, though her parents were dapper dressers and
Stay Connected
her father designed his own clothing.
She graduated from the Universityof Pennsylvania with a degree in art history, then moved to New York and
worked in pubic relations and advertising for designers, including Ralph Lauren and Vera Wang. She never
took a design class but drew on her art-history background to launch her company in 2004, with a goal of
delivering beautiful but more moderately priced designer clothing. A Tory Burch dress averages $500, nearly
half the cost of many designer dresses.
"I was such a tomboy, and I still am. Most people don't think of me that way. Ifyou look at the collections, it
comes through. I'm always interested in the feminine-meets-masculine. It's easy wear that's not fussy but
Lifestyle
classic."
In 2005, Burch appeared on The Oprah Winfrey Show as one of Winfrey's "next big things" in fashion.
It was the golden touch and generated nearly 8 million hits on Burch's website the next day.
Ken Downlg, fashion director for Neiman Marcus, described Burch's collections asa "nod to the past while
redefininglhe future."
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this weekend
Lord Fancy Pants

launched at Tootsies
"She loves her mother as much as I love my mother, and we use our mothers for inspiration," Downing said.
Burch's hugely popular ballet flats, which retail for $195-$235, are named for her mother, Reva.
But the foundation of Burch's brand is her logo, two graphically styled T's. The logo has shaped Burch's concept
from the beginning and is one of most recognizable fashion icons.

It's also one of the most copied.
In June, Tory Burch won $164 million in a lawsuit against 232 websites (including ToryBurchOutletShop.com,
LouboutinTime.com, and JimmyBoots.com) selling counterfeit Tory Burch flats, handbags and accessories. The
award is thought to be the largest sum of damages ever issued to a fashion company in the ongoing battle
against online counterfeiters, according to Women's Wear Daily.
O
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Houston
"At the beginning, the knockoffs were a form of flattery," Burchsaid. "Butat the end of the day, they hurt our
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Halloween proves
business. You shut one website down, and another pops up. They do their own Tory blogs. We even caught
someone in Times Square making our logos with a machine and putting it on bags. It's an ongoing fight, but this
suit is an exciting first step."
Burch's fall collection features a mix of English-country looks with glamorous bow-tie blouses and fur trimmings.
She mixes navy and black and does a sleek three-piece suit, which incorporates a vest into the jacket's design.
Bright colorcontinues to be an integral part of her aesthetic, from store interiors to the collections. Her tunics
and caftans have a relaxed feel for vacation or everyday wear.
"I live in color. My apartment has color, and itjust elevates your mood. I'm happy women love color as well."
Her passion extends well beyond the runway. In 2009, she started the Tory Burch Foundation to offer micro
loans and mentoring to women across the country.
Ifthe spirit of philanthropy carries over to her children, Burch would be proud.
"I have three boys, and I want to teach them about women's issues and everything women have endured and
continue to endure," she said. "To have men support those issues is a great thing."
joy. sewing@chron. com
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B3Q
UPDATED:
3YEARSAGO
Forthe past sevenyears, fashion-conscious women

ofallages have beensporting shoes, sunglasses,
handbags and clothing by New York designer Tory
Even if you don't recognize her name, you've

probably seen her work.
POSTED: 10/24/2011 01:00:00AM MDT
The Washington Post
By Terri Sapienza
In May, Burch opened her first boutique in the

Washington area, one of 6o Burch boutiques
worldwide. A grand-opening party will take place
I^Burch bearing her signature double-T medallion.
I
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of the CYNTHIA SHIRT to celebrate the HBO documentary
Romualdez to design her shops. (He's also

helped with her homes.) The two design most of
the furniture, fabrics and rugs used throughout
Burch works with New York designer Daniel
blue.
that has just recently been painted high-gloss
room with faux-tortoise trim and a kitchen floor
surprising given that Burch's New York

apartment, which has been featured in Vogue,
has a circular entry with hand-painted
chinoiserie wallpaper, an orange painted dining
Such attention to decorating details is not
Burch's boutiques aren't just about glamour; they're surprisingly homey, too.
her stores.
for your own home.
orange lacquered double doors opens to reveal a

The Education of Dee Dee Ricks and Benefit The Susan G.
Komen Cynthia Fund at Tory Burch Flagship on October 19,
magnetic mix of graphic patterns, reflective
2011. (Getty Images for HBO)
surfaces, mirrored walls and a bold palette of plum
brown, orange, green and gold. Sumptuous white
sofas with plump ikat cushions create a cozy lounge
area for shoppers (or their mates) to take a breather or try on shoes. In the dressing rooms, when
you pull back the heavily lined, purple-patterned curtain panels and spot more plum cushions
sitting atop velvet x-benches, don't be surprised if you start coveting a similar luxe dressing space
inspirational as the clothing.
to population increase
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Designer Tory Burch attends the Tory Burch and HBO launch
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admire the interior design, which is just as
If you're not a fan of, or can't afford, her fashion

line, it's still worth stopping by her boutique to
attend.
Thursday, with Burch flying in from New York to
A: I would love to do home at some point, but it's a tough business. I'm looking into it. We'd have
tabletop, linens, sheets, picture frames, wastebaskets and fabric.
Q: Is there a Tory Burch home collection in the future? If so, what would it include?
less.
I like auctions as well, smaller boutique auctions around the country, which are more accessible
than the bigger, well-known auction houses. You can find beautiful things and the prices are often
A: I live on 1st Dibs late at night, after I put my boys to bed. It's an addiction. You can find
everything and anything there.
Q: Where do you like to shop for your own homes?
It's energizing.
A: Since I was a little girl it's been my favorite color. It's just a happy, powerful color.
Q: Orange is your signature color. Why do you find it so appealing?
And I love color. It makes me happy.
using elements from all different places.
A: So many different things. From interior designers like Madeleine Castaing and David Hicks to
traveling. I love traveling and taking my boys with me. I love mixing texture and color and fabrics
and cultural elements. I think it's interesting to not have one distinct style but an evolving style
Q: When decorating your own home, what inspires you?
A: It's organic, and it's always evolving. Daniel and I are great friends. We worked on my
apartment and my Southampton (N.Y.) home. We know each other quite well. With each store we
open, we want it known that it's ours, but we also take each location into consideration. The stores
have a common vein, but from a design standpoint each has its own unique feel. I want customers
to visit stores around the world and have a different feeling when they walk in.
each shop?
which are similar but not identical. How do you guys come up with the concept for
Q: You collaborate with designer Daniel Romualdez when designing your boutiques,
company.
A: I love interiors and home and architecture and design. Interior design has been a big part of the
brand from the beginning. I was working on my apartment when I was conceptualizing the
Q: How does interior design figure into the vision of your brand?
influences and her obsession with 1st Dibs.
"We wanted a place that wasn't intimidating and where people would feel comfortable," says
Burch, 45, who grew up in Valley Forge, Pa. "To me, there's nothing worse than walking into a
store and feeling like it's too precious. We think it's a big compliment when people just want to
hang out." We spoke to Burch by phone from her office in New York to discuss her interior design
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V]Si:|OHVS
vjy r\ivL-Ksn i
AT THE TABLE |THE LAMBS CLUB
Where Fashion Types Talk of Summer Travel
V^SQ'^PinDaflon;81!10
Mylan Cannon/The New York Times
LUNCH Mark Holgate and Tony Burch, foreground.

By DIANECARDWELL
Published: June 25, 2011
Open less than a year, the Lambs Club in the lobby oftheChatwal
Hotel has become a go-to lunch spot for the fashion set and the news
media that cover them. Nestled along 44th Street east of Broadway
and not far from the Royalton, where the chef Geoffrey Zakarian fed a
similar crowd back in the late 1980s, the stylish black-and-red Art
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Deco room is named for the theatrical club once housed in the
building. It draws a chatty, buzzy scene of executives from labels as

diverse as American Apparel and Nina Ricci along with a variety of
editors and writers. On Wednesday, a designer and an editor
discussed plans for a store opening, vacations and what to do on
BIRDMAN
Fashion's Night Out. DIANE CARDWELL
MOST EMAILED
IN THE SEATS Tory Burch, the designer behind the near-ubiquitous double-T logo ballet
flats, wearing a graphic black-and-cream blouse from her collection; and Mark Holgate,
the fashion news director of Vogue.
1.
2.
Small Plates
ART REVIEW
Wisps From an Old Man's Dreams
ON THE PLATES Chicken paillard with farro and walnut salad ($24), declared by both
to be possibly the best they had ever had, and a Diet Coke ($4) for Ms. Burch. "No vodka
3.
PAUL KRUGMAN
Secret Deficit Lovers
martini," she said, laughing.

WHY THEY CAME Mr. Holgate visits the restaurant, which Ms. Burch had not tried
before, every few weeks and thought it would be a good setting for their discussion.
"There's basically not a place in the world where she's not opening a store right now, so I
was interested to hear about the empire expansion," he said.
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WHAT THEY TALKED ABOUT One of these stores, which is to be her "global
flagship," Ms. Burch said, and the third in New York City, set to open in August at Madison
Avenue and 68th Street; plans for an event there on Sept. 8 for Fashion's Night Out, a
celebrity-studded shopping extravaganza organized by Vogue, the Council of Fashion
Designers of America and NYC & Company, which is the city's tourism arm; and summer
6.
OP-ED CONTRIBUTOR
Bill Maher Isn't the Only One Who

Misunderstands Religion
7- At Florida State, Football Clouds Justice
plans, described witha touchofmodesty. Mr.Holgate, whois puttingtogethera European

tour to London, Edinburgh wherehe is from and either Viennaor Stockholm, said
Ms. Burch had the more interesting plans, to visit Venicefor the Biennale and to go to
Capri, Italy, withher family. Laughing, shesaid,"They're not that interesting."
8.
GRAY MATTER
Are We Really Conscious?
A version of thisarticle appeared in print on June 26,2011, on page MB2 ofthe New Yorkedition with the headline: Where
9- An Easy Choice? Dream On
Fashion Types Talk of Summer Travel.
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random A B C D E F G H I J K L MNO P Q R S||u V WXY Z # new
1- tory burch
The famous double T LOGO a ballet shoes is Tory Burch's most famous products. It appearance
is in the United States show "Gossip Girl". Founded in February 2004, so far, the Tory Burch
products in the U.S. has, Europe, and Asia home independent boutiques, 50 stores toryburch
websites, and global selection of the more than 500 stores and stores sold them.
tory burch, tory burch flats, tory burch outlet,tory burch boots, tory burch sandals
by angela flower June 11, 2011
14
Merch
Random Word
SHOP NOW
Authentic Modern Design
for Your Home
EXHIBIT 17
VK^
mnitsto States; patent anb ttfrabemarit Office
Reg. No. 4,213,404

Registered Sep. 25,2012 newyork,ny iooh

Int. CI.: 18
FOR: BACKPACKS; BEACH BAGS; BUSINESS CARD CASES; COIN PURSES; DOG COL
LARS; DOG LEASHES;OVERNIGHTBAGS;PET CLOTHING;WALLETS; WRISTLETBAGS
TRADEMARK
PRINCIPAL REGISTER
SER. NO. 85-530,802, FILED 2-1-2012.

Certificate of Registration
ThisCertificate issued under the sealofthe Copyright
t>-J2*2**.
Officein accordance with title 17, UnitedStatesCode,
atteststhat registration has been made for the work

identified below. The information on this certificate has
been made a part of the Copyright Office records.
Ldi^M^
1870'
RegistrationNumber:
RegistertifCopyrights,United Statesof America
VA 1-655-228
Effective date of
registration:
December 22,2008
Title
TMeofWork: LUX T JACQUARD
Completion/ Publication
Year of Completion: 2006
Date of 1st Publication: November30,2007
Nation of 1st Publication: United States
Author
Author ToryBurch LLC

Author Created:
Work made for hire:

Citizen of:
2-D artwork
Yes
United States
Domiciled in:
United States
Copyright claimant
CopyrightClaimant: Tory BurchLLC
11West 19th Street, 7th Floor,New York, NY, 10011, United States
Certification
Name:
SethRKertzer
Date: December 22,2008
Page 1 of 1
IPN#:
Registration #:
VAOOOl 655228
Service Request #: 1-145124842
Greenberg Traurig,LLP
G. Roxanne Elings
200 Park Ave.
34th Floor
New York,NY 10166 United States
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YEAR CREATED: 6.23.06
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CREATED BY:
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USAGE: ACCESSORIES-EMBOSSED PATENT LEATHER, FALL 2007
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JUDGE ARRAMi

CIVIL COVER SHEET

The JS-44 civil cover sheet andthe information contains hegmneither

pleadings or other papers as required by law, except asMroviaecay local

Judicial Conference of the United States in SeptembcW?4,^j

initiatingthe civil docket sheet.

River LightV, LP. and Tory Burch LLC

ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER

ATTORNEYS (IF KNOWN)

R. David Hosp, Fish & Richardson P.C.

601 Lexington Avenue, 52nd Floor, New York, NY 10022

Is THIS AN INTERNATIONAL ARBITRATION CASE7

If yes, give date.

(PLACE AN[x] INONEBOXONLY)

ACTIONS UNDER STATUTES

[ ] 320 ASSAULT, LIBELS,

[ ) 350 MOTOR VEHICLE

[ ] 362 PERSONAL INJURY -

[ ]445 AMERICANS WITH

[ 1446 AMERICANS WITH

[ ] 370 OTHER FRAUD

[ 1480 CONSUMER CREDIT

[ 1380 OTHER PERSONAL

[ 1385 PROPERTY DAMAGE

[ ] 710 FAIR LABOR

[ ] 530 HABEAS CORPUS

[ ]890 OTHER STATUTORY

[ ]891 AGRICULTURAL ACTS

[ ] 740 RAILWAY LABOR ACT

[ J790 OTHER LABOR

[ I 791 EMPL RET INC

PRISONER CIVIL RIGHTS

I 1 375 FALSE CLAIMS

[ J463 ALIEN DETAINEE

[ ]440 OTHER CIVIL RIGHTS

[ ]368 ASBESTOS PERSONAL l '

ACTIONS UNDER STATUTES

[ ]360 OTHER PERSONAL

& Case No.

[ J465 OTHER IMMIGRATION

( j560 CIVIL DETAINEE

FEDERAL TAX SUITS

[ 1870 TAXES (U.S. Plaintiff or

[ ] 871 IRS-THIRD PARTY

Checkif demanded in complaint:

CHECK IF THIS IS ACLASS ACTION

DEMAND STBD at trial

OTHER lnJunction. etc JUDGE

Check YES only ifdemanded in complaint

JURY DEMAND: EYES LKlO

(PLACE AN x INONE BOX ONLY)

a. ,11 parties represented

Q 5 Transferred from 6 Multidistrict

2 U.S. DEFENDANT \x\ 3 FEDERAL QUESTION

(U.S. NOT A PARTY)

CITIZENSHIP OF PRINCIPAL PARTIES (FOR DIVERSITY CASES ONLY)

CITIZEN OF THIS STATE

CITIZEN OF ANOTHER STATE

INCORPORATED or PRINCIPAL PLACE

INCORPORATED and PRINCIPAL PLACE

OF BUSINESS IN ANOTHER STATE

OF BUSINESS IN THIS STATE

PLAINTIFF(S) ADDRESS(ES) AND COUNTY(IES)