I'M Still Me v. Quintessential Tots Et. Al.
I'M Still Me v. Quintessential Tots Et. Al.
I'M Still Me v. Quintessential Tots Et. Al.
JON FALLON, ESQ. (JF2851) MANDELBAUM SALSBURG P.C. ATTORNEYS FOR PLAINTIFF
155 PROSPECT AVENUE WEST ORANGE, NEW JERSEY 07052 973.736.4600 (MAIN OFFICE) 732.637.9733 (DIRECT) [email protected] (EMAIL)
UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY -------------------------------------------------------------X IM STILL ME, LLC; Plaintiff, v. QUINTESSENTIAL TOTS, LLC d/b/a ITZY RITZY; ALL AROUND THE HOUSE; BABY BROWNS; BABY HALF OFF; GEOFFREY, LLC d/b/a BABIES R US; BUY BUY BABY, INC. COMFY BUMMY; COTTON BABIES, INC.; FEBRUARY WON, INC. d/b/a ECOMOM.COM; GRUNTY BABY BOUTIQUE; HEALTHY COTTAGE; I LOVE NATURAL BABY; KOHLS ILLINOIS, INC.; MY NATURAL BABY BOUTIQUE; NESSALEE BABY; TINYDIPITY.COM; WAYFAIR, LLC; WILD CHILD; WRAPABLES.COM; JOHN SMITH, an individual; and ABC COMPANIES; Defendants. -------------------------------------------------------------X Civil Action No.: ________________ COMPLAINT AND DEMAND FOR JURY TRIAL
COMPLAINT AND DEMAND FOR JURY TRIAL Plaintiff Im Still Me, LLC (hereinafter Plaintiff), by and through its counsel, Jon Fallon, Esq., of Mandelbaum Salsburg, P.C., complain against Quintessential Tots, LLC d/b/a Itzy Ritzy, and a number of its vendors, customers and/or distributors (collectively hereinafter Defendants), John Smith and ABC Companies, and alleges upon knowledge as to itself and otherwise upon information and belief as follows: NATURE OF THE ACTION 1. This is an action for (1) Patent Infringement under 35 U.S.C. 271(a), (2) Trade Dress Infringement under 15 U.S.C. 1125 (a), (3) Unfair Competition under 15 U.S.C. 1125 (a), and(4) Unfair Competition under New Jersey Common Law. JURISDICTION AND VENUE 2. This Court has subject matter jurisdiction over all causes of actions set forth herein based upon 15 U.S.C. 1121, 28 U.S.C. 1331, 1338(a) and 1338(b), and pursuant to the supplemental jurisdiction of this Court for all non-federal causes of action under 28 U.S.C. 1367. 3. This Court has personal jurisdiction over Defendants by virtue of, inter alia, (a) each Defendant having numerous business relations within the state of New Jersey and conducting regular and continuous business transactions therewith, giving it the requisite minimum contacts with the state required to be subject to jurisdiction therein; (b) commission of tortious acts by all Defendants within the State of New Jersey and within this Judicial District;
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and (c) regular and continuous transaction of business, including the tortious acts complained of herein, within and/or directed at the State of New Jersey and this Judicial District. 4. Venue is proper in this judicial district and division pursuant to 28 U.S.C. 1391(b) and (c). THE PARTIES TO THE COMPLAINT 5. Plaintiff Im Still Me, LLC is a Connecticut Limited Liability Company with its principal place of business at 85 Hill Road, Redding, CT 06896 6. Defendant Quintessential Tots, LLC d/b/a Itzy Ritzy (hereinafter Itzy Ritzy) is believed to be an Illinois Corporation, having a principal place of business at 1665 Quincy Avenue, Unit 179, Naperville, IL 60540. 7. Defendant All Around the House is company having a principal place of business at 70264 Hwy. 99, Summerfield, KS 66541. 8. Defendant Baby Browns is company having a principal place of business at 7111 W 151st St, Suite 33, Overland Park, KS 66223. 9. Defendant Baby Half Off is a company having a principal place of business at 1743 S. Horne, #200, Mesa, AZ 85204. 10. Defendant Geoffrey, LLC is a Delaware limited liability company having a principal place of business at 1 Geoffrey Way, Wayne, NJ 07470. 11. Defendant Buy Buy Baby, Inc. is a New York corporation having a principal place of business at 895 East Gate Boulevard, Garden City, NY 11530.
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12.
Defendant Comfy Bummy is a company having a principal place of business at 231 S. Washington Street, Naperville, IL 60540.
13.
Defendant Cotton Babies, Inc., is a Missouri corporation having a principal place of business at 6116 Baumgartner, St. Louis, MO 63129.
14.
Defendant February Won, Inc. d/b/a ecomom.com is a California corporation having a principal place of business at 8737 Venice Boulevard, Suite 101, Los Angeles, CA 90034.
15.
Defendant Grunty Baby Boutique is a company having a principal place of business at 3331 California Road; Seaside, CA 93955.
16.
Defendant Healthy Cottage is a Massachusetts company having a principal place of business at 22 Stratton Road, Grafton, MA 01519.
17.
Defendant I Love Natural Baby is a company having a principal place of business at 11 College Street, Greenville, SC 29601.
18.
Defendant Kohls Illinois, Inc. is a Delaware Corporation having a principal place of business at N56 W17000 Ridgewood Drive, Menomonee Falls, WI, 53051.
19.
Defendant My Natural Baby Boutique is a company having a principal place of business at 120 Somerset Drive, Suffern, NC 10901.
20.
Defendant Nessalee Baby is a New Jersey company having a principal place of business at 346 Mounts Corner Drive, Freehold, NJ 07728.
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21.
Defendant TinyDipity.com is a company having an unknown address, whose information is available through its website administrator having an address at 11400 W. Olympic Blvd. Suite 200, Los Angeles, CA 90064.
22.
Defendant Wayfair, LLC is a Massachusetts limited liability company, having a principal place of business at 177 Huntington Avenue, Suite 6000, Boston, MA 02115.
23.
Defendant Wild Child is a Massachusetts company having a principal place of business at 5 Medford Street, Arlington, MA 02474.
24.
Defendant Wrappables.com is a company having a principal place of business at 5696 Stewart Avenue, Fremont, CA 94538.
25.
Defendant John Smith is a fictitious person whose present identity and address is unknown who has also violated Plaintiffs rights as set forth herein, or who assisted, conspired, or otherwise cooperated with the other Defendants in the acts complained of herein.
26.
Defendants ABC Companies are fictitious entities whose present identity and address is unknown, who have also violated Plaintiffs rights as set forth herein, or who assisted, conspired, or otherwise cooperated with the other Defendants in the acts complained of herein.
BACKGROUND 27. On November 10, 2008, Design Patent Application Serial No. 29/327,649 (the 649 Application) was filed at the United States Patent and Trademark
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Office (USPTO) by inventors Sandra Wright and Mackenzie WrightSullivan, under the title Protective Garment. Less than one year later, on November 3, 2009, the 649 Application issued as United States Design Patent No. D603,142 (the 142 Patent), a copy of which is attached hereto as Exhibit A. 28. Plaintiff is the exclusive owner, by assignment, of the 142 Patent and has the right to sue and recover damages for infringement thereof. 29. Plaintiff properly marks all patented products in accordance with 35 U.S.C. 287, where appropriate. 30. At least as early as November 2009, Plaintiff has been advertising and disclosing its novel design for a protective garment, more commonly identified as a combination bib, burp cloth and bath cloth for babies. 31. Defendant Itzy Ritzy is a manufacturer, distributer and retailer of baby products. Itzy Ritzy claims to offer a stylish and modern collection of baby, toddler and lifestyle accessories. One of Itzy Ritzys products, sold under the name Bitzy, is identified as a bib, burp and bath cloth, and embodies the novel aesthetic design of Plaintiffs patented protective garment (hereinafter Infringing Products.) Upon information and belief, the Infringing Products were introduced to market sometime in 2011. 32. Each of the other Defendants named herein have made, used, imported, offered for sale or sold the Infringing Products made by Defendant Itzy Ritzy. Evidence exhibiting each of the Defendants respective websites offering the
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Infringing Products for sale, is attached hereto as Exhibit B. Note: in light of Plaintiffs demand notices to Defendant Itzy Ritzy, some of the Defendants websites currently show the Infringing Products as unavailable or backordered; however, Plaintiff had previously confirmed such products were actually offered for sale and sold by each of such named Defendants. 33. Plaintiff reached out to Defendant Itzy Ritzy in early 2012 in efforts to resolve this dispute. After numerous back and forth email exchanges, in or around June 2012, Defendant Itzy Ritzy agreed to cease all sales of the Infringing Products, but refused to compensate Plaintiff for any past infringement, and refused to instruct its customers and retail partners to cease selling the Infringing Products. Accordingly, Plaintiff has filed this Complaint to obtain the necessary remedies to protect its valuable intellectual property assets.
FIRST CAUSE OF ACTION PATENT INFRINGEMENT UNDER 35 U.S.C. 271(a) 34. 35. Paragraphs 1 through 33 are realleged and incorporated herein by reference. The claim of the 142 Patent is presumed valid pursuant to 35 U.S.C. 282, and is valid. 36. Defendants in violation of 35 U.S.C. 271(a), have infringed and are currently infringing, contributorily infringing and/or inducing a third party to infringe, the claim of the 142 Patent, either literally or under the Doctrine of Equivalents, by causing to be made, using, offering to sell, selling and/or
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importing into the United States, without license or authority, within this Judicial District and elsewhere, the Infringing Products, which are covered by the 142 Patent, and/or contributing towards and/or inducing a third party to do the same. 37. Defendants intentionally caused to be made, used, offered to sell, sold and/or imported into the United States the Infringing Products, with actual knowledge, and/or knowledge imputed to it, that such products embody the claim of the 142 Patent. 38. Defendants have infringed, and upon information and belief, will continue to infringe, the claims of the 142 Patent by the use, manufacture, offer for sale, sale, and/or importation of the Infringing Products. 39. As a result of the Defendants actions, Plaintiff has suffered injury, including irreparable injury, and damages, including lost profits, reasonable royalties, and other damages as set forth herein.
SECOND CAUSE OF ACTION TRADE DRESS INFRINGEMENT UNDER 15 U.S.C. 1125 40. 41. Paragraphs 1 through 39 are realleged and incorporated herein by reference. Plaintiff has expended significant resources promoting its products covered by its 142 Patent, sold under the brand OopC!,and the exclusive rights to the such aesthetic appearance covered by the claims therein. In view of the associated niche market, most persons and businesses in the baby garment
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protection industry are aware of Plaintiffs patented aesthetic appearance and its rights under the 142 Patent. Accordingly, the aesthetic appearance of Plaintiffs patented products have an inherently distinctive trade dress, or in the alternative, an acquired distinctive trade dress, in the relevant marketplace. 42. The Defendants use of the Infringing Products, through sale, offering for sale, and the like, is likely to deceive relevant consumers in the stair retreading industry as to the Defendants affiliation with Plaintiff, or as to a sponsorship or an approval of the Infringing Products by Plaintiff. 43. The Defendants will, if not preliminary and permanently enjoined by the Court, continue its acts of trade dress infringement as set forth in the Lanham Act, thereby deceiving the public, trading on the exclusive rights granted to Plaintiff by virtue of its trade dress rights. 44. As a result of the Defendants collective actions, Plaintiff has suffered injury, including irreparable injury, and damages, including lost profits, reasonable royalties, and other damages as set forth herein.
THIRD CAUSE OF ACTION UNFAIR COMPETITION UNDER 15 U.S.C. 1125(a) 45. 46. Paragraphs 1 through 44 are realleged and incorporated herein by reference. Plaintiff has expended significant resources promoting its products covered by its 142 Patent, and the exclusive rights to such aesthetic appearance
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covered by the claims therein. In view of the associated niche market, most persons and businesses in the baby garment protection industry are aware of Plaintiffs patented aesthetic appearance and its rights under the 142 Patent. 47. The Defendants collective actions regarding the Infringing Products, as described herein, are likely to have misled, and will continue to mislead many persons in the stair retreading industry to believe the Defendants have received permission, license, or other consent from Plaintiff to make, use, sell, offer for sale, or import into the United States, the Infringing Products. 48. The Defendants use of the Infringing Products, through sale, offering for sale, and the like, is likely to deceive relevant consumers in the stair retreading industry as to the Defendants affiliation with Plaintiff, or as to a sponsorship or an approval of the Infringing Products by Plaintiff. 49. The Defendants will, if not preliminary and permanently enjoined by the Court, continue its acts of unfair competition as set forth in the Lanham Act, thereby deceiving the public, trading on the exclusive rights granted to Plaintiff in the form of the 142 Patent, and causing Plaintiff immediate and irreparable harm, damage and injury. 50. As a result of the Defendants collective actions, Plaintiff has suffered injury, including irreparable injury, and damages, including lost profits, reasonable royalties, and other damages as set forth herein.
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FOURTH CAUSE OF ACTION UNFAIR COMPETITION UNDER NEW JERSEY COMMON LAW 51. 52. Paragraphs 1 through 50 are realleged and incorporated herein by reference. The aforementioned collective acts of the Defendants constitute unfair competition and unfair business practices contrary to the common laws of New Jersey. 53. The Defendants will, if not preliminary and permanently enjoined by the Court, continue its acts of unfair competition as defined by the common laws of New Jersey, thereby deceiving the public, trading on the exclusive rights granted to Plaintiff in the form of the 142 Patent, and causing Plaintiff immediate and irreparable harm, damage and injury. 54. As a result of the Defendants collective actions, Plaintiff has suffered injury, including irreparable injury, and damages, including lost profits, reasonable royalties, and other damages as set forth herein.
PRAYER FOR RELIEF WHEREFORE, Plaintiff demands judgment against each of the defendants as follows: A. a permanent injunction restraining Defendants, their respective officers, agents, servants, employees, attorneys, and those in active concert or participation with them, or any of them who receive actual notice of the order by personal service or otherwise, from:
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1.
making, using, selling, offering for sale, or importing into the United States, the Infringing Products; and
2.
assisting or inducing others to make, use, sell, offer for sale, or import into the United States, the Infringing Products;
B.
an award of damages for Defendants acts of liability under 35 U.S.C. 271, in accordance 35 U.S.C. 284, and in particular, an award of damages adequate to compensate for the infringement but in no event less than a reasonable royalty for the use made of the Infringing Products, together with interest and costs as fixed by the Court;
C.
an award of increased damages under 35 U.S.C. 284, including three times the amount found or assessed in paragraph (B) above;
D.
an award of damages inclusive of any actual damages suffered by Plaintiff as a result of Defendants liability stated hereinabove, including arising out of Defendants liability arising out of Counts I IV, and other Counts that may be added at a later date once additional information is obtained;
E.
an award of damages from Defendants for their liability under 43(a) of the Lanham Act, including any profits made by Defendants in connection with its unlawful activity, any damages sustained by Plaintiff as a result of Defendants unlawful activity, and any costs incurred with pursuing this Action, including Court costs, attorneys fees, and additional costs related thereto, pursuant to 15 U.S.C. 1117(a);
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F.
an award of all damages incurred, directly or indirectly, as a result of Defendants unlawful acts set forth herein, said damages to be trebled at the discretion of the Court pursuant to N.J.S.A. 56:4-2;
G.
a determination by the Court that Defendants unlawful actions set forth herein are exceptional, warranting an award of damages to Plaintiffs for all reasonable attorneys fees incurred by Plaintiffs, pursuant to 35 U.S.C. 285 and 15 U.S.C. 1117(a);
H. I.
an award of prejudgment and post-judgment interest and costs of suit; an award of punitive damages in an amount to be determined by the Court, but not less than $500,000.00, for Defendants deliberate and willful acts;
J.
an award of actual and compensatory damages in an amount not presently known, but to be computed during the pendency of this action; and
K.
an award of any such other and further relief as this Court deems just and equitable.
Respectfully submitted,
JON FALLON, ESQ. (JF2851) MANDELBAUM SALSBURG P.C. ATTORNEYS FOR PLAINTIFF
155 PROSPECT AVENUE WEST ORANGE, NEW JERSEY 07052 973.736.4600 (MAIN OFFICE) 732.637.9733 (DIRECT) [email protected] (EMAIL)
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CERTIFICATION PURSUANT TO LOCAL CIVIL RULE 11.2 The undersigned hereby certifies, pursuant to Local Civil Rule 11.2, that with respect to the matter in controversy herein, neither plaintiff nor plaintiffs attorney is aware of any other action pending in any court, or any pending arbitration or administrative proceeding, to which this matter is subject.
Respectfully submitted,
JON FALLON, ESQ. (JF2851) MANDELBAUM SALSBURG P.C. ATTORNEYS FOR PLAINTIFF
155 PROSPECT AVENUE WEST ORANGE, NEW JERSEY 07052 973.736.4600 (MAIN OFFICE) 732.637.9733 (DIRECT) [email protected] (EMAIL)
CERTIFICATION PURSUANT TO FEDERAL RULE OF CIVIL PROCEDURE 7.1 The undersigned hereby certifies, pursuant to Federal Rule of Civil Procedure 7.1, that with respect to the matter in controversy herein, Plaintiff does not have any parent corporation, nor have any publicly held corporation owning 10% or more of its stock.
Respectfully submitted,
JON FALLON, ESQ. (JF2851) MANDELBAUM SALSBURG P.C. ATTORNEYS FOR PLAINTIFF
155 PROSPECT AVENUE WEST ORANGE, NEW JERSEY 07052 973.736.4600 (MAIN OFFICE) 732.637.9733 (DIRECT) [email protected] (EMAIL)
EXHIBIT A
EXHIBIT B
Bitzy by Itzy Ritzy Bib, Burp and Bath Cloth 3 uses in 1 Fresh Bloom Page 1 of 1 Case 2:33-av-00001 Document 16756 Filed 12/10/12 Page 22 of 66 PageID: 375670
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Bitzy by Itzy Ritzy Bib, Burp and Bath Cloth 3 uses in 1 Fresh Bloom Price: $12.99 This item is in stock Quantity: 1
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Bitzy by Itzy Ritzy... Bib, Burp and Bath Cloth... Fresh Bloom... The Itzy Ritzy BC8024 Bitzy 3-in-1 bib, burp and wash cloth is eco-friendly and grows with your baby. This versatile, multi-use cloth was designed to meet every busy mom's needs. Generously sized at over 20... E-mail a friend about this item. Return to Catalog
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11/23/2012
Itzy Ritzy | Bib and Burp Cloth in Modern Floral | BabyBrowns Page 1 of 2 Case 2:33-av-00001 Document 16756 Filed 12/10/12 Page 23 of 66 PageID: 375671
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Bitzy Bib, Burp and Bath Cloth Designed for busy moms, the versatile Bitzy multi-tasks with style. Featuring super-soft layers of eco-friendly bamboo rayon and absorbent cotton, this ingenious product can be used as a bib, burp cloth or washcloth. The adaptable Bitzy saves space in your diaper bag, and it saves you precious time spent with your baby rather than searching through multiple items for just the one that you need. At 20 inches in length, with a tapered and contoured shape, the Bitzy makes a great burp cloth. The cloth grows with your baby, and when shes ready for a bib, simply snaps around her neck, providing a stylish bib with full coverage. Its soft, absorbent fabric also works wonders at bath time. Beautiful custom designed, trademark Itzy Ritzy fabrics and its inventive design make the Bitzy a designer original. Perhaps thats why it is a favorite of modern mothers throughout not only the United States but also Canada, Asia, Europe, Australia and the Mideast. Even celebrities love the Bitzy. Angelina Jolie, Nicole Richie and Pink are just a few of the famous moms who are fans of Itzy Ritzys innovative products. Featured on Good Morning America, the Today show and in Parents magazine, the company has also won multiple awards from Cribsie, Red Tricycle and Baby and Childrens Product News. Comfortable and absorbent layers of eco-friendly bamboo rayon and cotton May be utilized as a bib, burp cloth or washcloth Machine washable Line dry recommended 9 inches wide by 20.5 inches long Durable, rust-free plastic snaps
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Baby Half Off - Itzy Ritzy Nursing Pads And Bib Burp And Bath Cloths Page 1 of 5 Case 2:33-av-00001 Document 16756 Filed 12/10/12 Page 25 of 66 PageID: 375673
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Bitzy Bib, Burp & Bath Cloth Multiple uses to grow with your baby, transforming between a burp cloth, bib and wash cloth! Bamboo Rayon trimmed in 100% designer cotton fabric Bamboo Rayon is soft, absorbent, & comfortable Generous 9" x 20.5" size Tapered contoured shape for perfect coverage Rust-free plastic snaps ensure bib stays in place Machine washable
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Glitzy Gals Washable Nursing Pads are reusable, comfortable and luxurious! Designer 100% cotton top layer lined with interior and bottom layers of absorbent, eco-friendly bamboo rayon. 4 in diameter - perfect size to do their job without adding bulk. Say goodbye to itchy, expensive disposable nursing and breastfeeding pads! Double up for heavy letdown or nighttime wear. Six-piece/3 Pair box set The perfect chic and eco-friendly gift for expecting moms, baby showers, or as a little treat for yourself! Done nursing? Suds up in the tub...Glitzy Gals are perfect for small hands & baby's tender skin...kids get a kick out of the funky fabrics too!
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Itzy Ritzy Bib, Burp and Bath Cloth - Rodeo Drive - Itzy Ritzy - Babies "R" Us Page 1 of 4 Case 2:33-av-00001 Document 16756 Filed 12/10/12 Page 30 of 66 PageID: 375678
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11/23/2012
Itzy Ritzy Bib, Burp and Bath Cloth - Rodeo Drive - Itzy Ritzy - Babies "R" Us Page 3 of 4 Case 2:33-av-00001 Document 16756 Filed 12/10/12 Page 32 of 66 PageID: 375680
Product Description The Bitzy, 3 in 1 bib, burp and wash cloth by Itzy Ritzy is eco-friendly and grows with your baby! This versatile, multi-use cloth was designed to meet every busy mom's needs! Generously sized at over 20 inches in length, the Bitzy features a tapered contoured shape that provides perfect coverage for burping, feeding or washing baby. Use the versatile Bitzy as a bib by snapping the ends together or use in the bath as a washcloth. Made with baby's comfort in mind, this handy accessory has layers of soft absorbent bamboo rayon and cotton. Itzy Ritzy products are made with the highest quality workmanship using 100% machine washable cotton and are CPSIA certified safe for baby. The Bitzy is trimmed with custom designed fabrics exclusive to Itzy Ritzy. Product Washing Instructions: Machine wash in cold water with like colors, no bleach. Line dry recommended. Product Dimensions: 9-inches length x 20.5-inches wide. At Itzy Ritzy, we believe that parenting in style is possible. Our collection is designed to provide families with smart and stylish solutions to everyday parenting challenges. From multi-purpose designs that empower and chic prints that inspire, to eco-friendly solutions that raise consciousness, we've reinvented practical luxury for modern families around the world while remaining true to our core vision of keeping things simple. Itzy Ritzy has been featured on The Today Show and Good Morning America and is the winner of the 2011 Red Tricycle Totally Awesome Awards and back-to-back winner of the Best New Product by Baby & Children's Product News.
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itzy ritzy Itzy Ritzy Bitzy Bib, Burp & Bath Cloth - Licorice Swirl & Baby Bamboo
The Bitzy has multiple uses to grow with your baby, transforming between a burp cloth, bib and a wash cloth! The cloth is made from Bamboo Rayon trimmed in 100% designer cotton. The Bamboo Rayon is soft, absorbent and comfortable. It features a tapered contoured shape for perfect coverage and measures 9" x 20 1/2". It also has rust-free plastic snaps to ensure cloth stays in place. Machine washable.
Customer Reviews for Itzy Ritzy Bitzy Bib, Burp & Bath Cloth - Licorice Swirl & Baby Bamboo
Best Bib
May 29, 2012
BabyK from Glenview, IL Parental Status: Parent Number of Children: 2 Would you recommend? Yes This is my favorite bib and I feel it's better than the Aiden and Anais (who has great swaddle blankets). I love that it has bamboo in there and it's super soft for my kids' sensitive skin. Both of my kids have thick necks and this bib fits just right. I like how it can be converted from a bib to a burp cloth or even a security blanket. I have these bibs in other designs and always give 'em as gifts. It is pricey but so worth it! I've washed 'em way too many times but they still look great! Share this review:
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11/23/2012
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Multiple uses to grow with your baby, transforming between a burp cloth, bib and wash cloth! Bamboo Rayon trimmed in 100% designer cotton fabric Generous 9" x 20.5" size Tapered contour shape for perfect coverage Rust-free plastic snaps ensure bib stays in place
This innovative bib has multiple uses to grow with your baby, transforming between a burp cloth, bib and wash cloth! Made from bamboo rayon and trimmed in 100% designer cotton fabric, it is soft, absorbent and comfortable. The tapered, contoured shape is the perfect coverage and the rust-free plastic snaps ensure the bib stays in place.
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11/23/2012
Itzy Ritzy Bitzy Bib, Burp & Bath Cloth - Natural Body Care - Cotton Babies Cloth Diap... Page 1 of 3 Case 2:33-av-00001 Document 16756 Filed 12/10/12 Page 39 of 66 PageID: 375687
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The Itzy Ritzy Bitzy has multiple uses to grow with your baby transforming from a burp cloth to a bib and to wash cloth. Made from Bamboo Rayon and trimmed in 100% designer cotton you and your baby can by stylish and functional. Bamboo rayon is soft, comfortable & absorbent. The tapered contoured shape and generous 9" x 20.5" sizing allow for perfect coverage, no matter how you use it, and the rust free snaps ensure bib stays in place. The Itzy Ritzy Bitzy is simple to use and machine washable.
http://www.cottonbabies.com/product_info.php?products_id=3263
11/23/2012
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Itzy Ritzy Bitzy Bib, Burp & Bath Cloth Reviews (2) Write a review of this product! Rating: [5 of 5 Stars!]
Reviewed by Kate on Monday 02 April, 2012
I absolutely love these bibs. My son spits up a lot and most of the bibs we tried were just too small and not absorbant enough. These cover a lot of area and can be used as an over the shoulder burb cloth or bib. They are a must have.
http://www.cottonbabies.com/product_info.php?products_id=3263
11/23/2012
Itzy Ritzy Bitzy Bib, Burp & Bath Cloth - Natural Body Care - Cotton Babies Cloth Diap... Page 3 of 3 Case 2:33-av-00001 Document 16756 Filed 12/10/12 Page 41 of 66 PageID: 375689
Rating: [4 of 5 Stars!]
This product was great for my child with reflux, I could use it as a burp cloth and then if he didn't spit up I could stick it on him as a bib in his exersauser and it would protect his clothes when he did spit up...I knew it was coming so he might as well look cute doing it :) View all 2 reviews
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11/23/2012
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Itzy Ritzy Bitzy Bib, Burp & Bath Cloth - Rodeo Drive
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Soft, absorbent and comfortable bamboo rayon trimmed in 100% cotton fabric. 9 x 20.5 Generous size with tapered contoured shape for perfect coverage 3-in-1 Multiple uses to grow with child: burp cloth, bib and wash cloth Rust-free snaps Machine washable
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11/23/2012
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11/23/2012
Itzy Ritzy Bitzy - Bid, Burp & Bath Cloth - Grunty Baby Page 1 of 2 Case 2:33-av-00001 Document 16756 Filed 12/10/12 Page 44 of 66 PageID: 375692
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Multiple uses to grow with your baby, transforming between a burp cloth, bib and wash cloth! Bamboo Rayon trimmed in 100% designer cotton fabric Bamboo Rayon is soft, absorbent, & comfortable Generous 9" x 20.5" size Tapered contoured shape for perfect coverage Rust-free plastic snaps ensure bib stays in place Machine washable
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11/23/2012
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Itzy Ritzy Bitzy Bib, Burp and Bath Cloth, BC8066 (Modern Floral)
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Product Features
3-uses-in-1-diaper bag must have-absorbent-contoured shape-hidden rust-free snaps Grows with your baby, transforming between a burp cloth, bib and wash cloth Cloth is made from Bamboo Rayon, trimmed in 100% designer cotton Measures:9" x 20 1/2" Machine washable
Product Specifications
Part Number Item Package Quantity BC8066 1
Product Description
The Itzy Ritzy BC8024 Bitzy 3-in-1 bib, burp and wash cloth is eco-friendly and grows with your baby. This versatile, multi-use cloth was designed to meet every busy mom's needs. Generously sized at over 20-inches in length, the Bitzy features a tapered contoured shape that provides perfect coverage for burping, feeding or washing baby. Use the versatile Bitzy as a bib by snapping the ends together or use in the bath as a washcloth. Made with baby's comfort in mind, this handy accessory has layers of soft absorbent bamboo rayon and cotton. The Bitzy is trimmed with custom designed fabrics exclusive to Itzy Ritzy. Avocado Damask is a stylish unisex print in green and white. Product Washing Instructions: Machine wash in cold water with like colors, no bleach. Line dry recommended. Product Dimensions: 9-inches by 20.5-inches.
Product Details
Shipping Weight: 6.4 ounces (View shipping rates and policies) ASIN: B008BIMNX0 Item model number: BC8066 Average Customer Review: Be the first to review this item Did we miss any relevant features for this product? Tell us what we missed. Would you like to update product info, give feedback on images, or tell us about a lower price?
http://www.amazon.com/Itzy-Ritzy-BC8066-Modern-Floral/dp/B008BIMNX0
11/23/2012
Amazon.com: Itzy Ritzy Bitzy Bib, Burp and Bath Cloth, BC8066 (Modern Floral): Hom... Page 2 of 3 Case 2:33-av-00001 Document 16756 Filed 12/10/12 Page 47 of 66 PageID: 375695
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Bamboo Rayon trimmed in 100% designer cotton fabric Bamboo Rayon is soft, absorbent, & comfortable Generous 9" x 20.5" size Tapered contoured shape for perfect coverage Rust-free plastic snaps ensure bib stays in place Machine washable
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Bitzy
Bib, Burp & Bath Cloth
Multiple uses to grow with your baby, transforming between a burp cloth, bib and wash cloth! Bamboo Rayon trimmed in 100% designer cotton fabric Bamboo Rayon is soft, absorbent, & comfortable Generous 9" x 20.5" size Tapered contoured shape for perfect coverage Rust-free plastic snaps ensure bib stays in place Machine washable
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Itzy Ritzy Avocado Damask Bib, Burp and Bath Cloth Page 1 of 2 Case 2:33-av-00001 Document 16756 Filed 12/10/12 Page 51 of 66 PageID: 375699
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Natural Bitzy Bib, Burp & Bath Cloth Page 1 of 2 Case 2:33-av-00001 Document 16756 Filed 12/10/12 Page 53 of 66 PageID: 375701
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Bamboo Rayon trimmed in 100% designer cotton fabric Bamboo Rayon is soft, absorbent, & comfortable Generous 9" x 20.5" size Tapered contoured shape for perfect coverage Rust-free plastic snaps ensure bib stays in place Machine washable Coordinates perfectly with our wet bags
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Go Green with Baby Bamboo: Baby bamboo is an eco-friendly fabric, as bamboo is sustainable and grown without pesticides and fungicides. The soft, smooth texture is exceptional for babies' tender skin Naturally anti-bacterial, anti-microbial, and deodorizing. Bamboo needs no harsh chemicals that can irritate tender skin; its own natural ingredient, BAMBOO KUN prevents bacteria growth. Bamboo fabric even has an inherent UV protection factor Our baby bamboo fabric looks and feels like Silk, but it is much more practical as it is machine washable! Bitzy Burpers utilize remnant fabric that would otherwise go to waste yet another way to reduce, reuse, recycle & go green! Itzy Ritzy is all the rage in Hollywood! Celebrities like you love Itzy Ritzy, including these Celebrity Moms and Dads: Rebecca Romijn, Jerry O'Connell, Halle Berry, Nicole Kidman, Angelina Jolie, Brad Pitt, Melissa Joan Hart, Marissa Jaret Winokur, Sean Diddy Combs, Gwen Stefani & Nicole Richie!
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Natural Bitzy Bib, Burp & Bath Cloth Page 2 of 2 Case 2:33-av-00001 Document 16756 Filed 12/10/12 Page 54 of 66 PageID: 375702
Everything Organic & Natural For Your Baby 100% Certified Cotton or 100% Natural Bamboo Baby Clothes & Accessories, Non Toxic Teething Jewelry, Safe for your Baby or a PBA-Free Baby Bottle with Anti-Colic Nipple, You Will Find it in My Natural Baby Boutique. The varieties of our Organic Products make it easy to create an Eco Friendly gift basket for someone special in your life. We offer gift registry and gift certificates. Home | Gift Certificates | Gift Registry | Order Tracking | Testimonials | Why Buy Organic | Good Read | Our Friends | Causes We Believe In | Customer Service | Contact Us | Privacy Policy Copyright 2011 My Natural Baby Boutique. All Rights Reserved. Site design by MyDreamWeb Design
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11/23/2012
Itzy Ritzy - Bitzy - Burp and Wash Cloths | NessaLeeBaby.com Page 1 of 1 Case 2:33-av-00001 Document 16756 Filed 12/10/12 Page 55 of 66 PageID: 375703
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11/23/2012
Itzy Ritzy Bitzy Bib, Burp & Bath Cloth in Social Circle Pink Page 1 of 4 Case 2:33-av-00001 Document 16756 Filed 12/10/12 Page 56 of 66 PageID: 375704
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Itzy Ritzy Bitzy Bib, Burp & Bath Cloth in Social Circle Pink Page 2 of 4 Case 2:33-av-00001 Document 16756 Filed 12/10/12 Page 57 of 66 PageID: 375705
Itzy Ritzy Bitzy Bib, Burp & Bath Cloth in Social Circle Pink
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SKU: BC8057. Category: Bib, Bath & Burp Cloths, Brands, Cool Finds, Itzy Ritzy, Mealtime. Tags: burpy bib pink baby.
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Itzy Ritzy Bitzy Bib, Burp & Bath Cloth in Social Circle Pink Every new parent needs burp cloths and bibs, and this bamboo rayon burpy bib trimmed in 100% designer cotton fabric does triple duty as a 3-in-1. Its unique design provides maximum coverage for both you and your baby. Drape it around babys neck or fasten with a simple snap in the back.
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11/23/2012
Itzy Ritzy Bitzy Bib, Burp & Bath Cloth in Social Circle Pink Page 3 of 4 Case 2:33-av-00001 Document 16756 Filed 12/10/12 Page 58 of 66 PageID: 375706
Why its a Tinydipity pick: Tapered contoured shape for perfect coverage. Rust-free plastic snaps ensure bib stays in place. We love the versatility and durability of these burp cloth/bib hybrids and they come in lovely, modern patterns to boot!
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Itzy Ritzy Bitzy Bib, Burp & Bath Cloth in Social Circle Pink Page 4 of 4 Case 2:33-av-00001 Document 16756 Filed 12/10/12 Page 59 of 66 PageID: 375707
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11/23/2012
Itzy Ritzy Bitzy Bib, Burp and Bath Cloth in Social Circle Blue | Wayfair Page 1 of 3 Case 2:33-av-00001 Document 16756 Filed 12/10/12 Page 60 of 66 PageID: 375708
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Itzy Ritzy Bitzy Bib, Burp and Bath Cloth in Social Circle Blue - BC8058 (View all from Itzy Ritzy)
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Itzy Ritzy Bitzy Bib, Burp and Bath Cloth in Social Circle Blue | Wayfair Page 2 of 3 Case 2:33-av-00001 Document 16756 Filed 12/10/12 Page 61 of 66 PageID: 375709
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Itzy Ritzy Bitzy Bib, Burp and Bath Cloth in Social Circle Blue | Wayfair Page 3 of 3 Case 2:33-av-00001 Document 16756 Filed 12/10/12 Page 62 of 66 PageID: 375710
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Wild Child : Itzy Ritzy Bitzy Bib, Burp & Bath Cloth - ItzyRitzyBibBurp&BathCloth Page 2 of 3 Case 2:33-av-00001 Document 16756 Filed 12/10/12 Page 63 of 66 PageID: 375711
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- 3-in-1 bib, burp and wash cloth is eco-friendly and gro your baby. - Features a tapered contoured shape that provides pe coverage for burping, feeding or washing baby. - Measured 9-inches by 20.5-inches. - Machine wash in cold water with like colors, no bleach recommended.
http://wildchildgear.com/ItzyRitzyBibBurp%26BathCloth.html
11/23/2012
Itzy Ritzy Bitzy Bib, Burp and Bath Cloth, BC8026 (Licorice Swirl) - Amazon.com Page 1 of 3 Case 2:33-av-00001 Document 16756 Filed 12/10/12 Page 64 of 66 PageID: 375712
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Itzy Ritzy Bitzy Bib, Burp and Bath Cloth, BC8026 (Licorice Swirl)
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Product Features
Dimensions: 9"L x 20.5"W. Material: Bamboo Rayon, 100% Cotton. Washing Instructions: Machine wash in cold water with like colors, no bleach. Line dry recommended.
Product Specifications
Part Number BC8026
Product Description
The Itzy Ritzy BC8024 Bitzy 3-in-1 bib, burp and wash cloth is eco-friendly and grows with your baby. This versatile, multi-use cloth was designed to meet every busy mom's needs. Generously sized at over 20-inches in length, the Bitzy features a tapered contoured shape that provides perfect coverage for burping, feeding or washing baby. Use the versatile Bitzy as a bib by snapping the ends together or use in the bath as a washcloth. Made with baby's comfort in mind, this handy accessory has layers of soft absorbent bamboo rayon and cotton. The Bitzy is trimmed with custom designed fabrics exclusive to Itzy Ritzy. Avocado Damask is a stylish unisex print in green and white. Product Washing Instructions: Machine wash in cold water with like colors, no bleach. Line dry recommended. Product Dimensions: 9-inches by 20.5-inches.
Product Details
Shipping Weight: 6.4 ounces (View shipping rates and policies) ASIN: B007JW499A Average Customer Review: Be the first to review this item Amazon Best Sellers Rank: #244,159 in Home Improvement (See Top 100 in Home Improvement) Did we miss any relevant features for this product? Tell us what we missed. Would you like to update product info, give feedback on images, or tell us about a lower price?
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11/23/2012
Itzy Ritzy Bitzy Bib, Burp and Bath Cloth, BC8026 (Licorice Swirl) - Amazon.com Page 2 of 3 Case 2:33-av-00001 Document 16756 Filed 12/10/12 Page 65 of 66 PageID: 375713
Itzy Ritzy Bib, Burp and Bath Cloth, Social Circle Blue
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Itzy Ritzy Bitzy Bib, Burp and Bath Cloth, BC8067 (Fresh Bloom)
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11/23/2012
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