Bombas v. Maison Impeccable - Complaint
Bombas v. Maison Impeccable - Complaint
Bombas v. Maison Impeccable - Complaint
____________________________________
)
BOMBAS LLC, )
)
Plaintiff, ) Civil Action No. 1:18-cv-4412
)
)
v. ) COMPLAINT FOR TRADEMARK
) INFRINGEMENT; TRADE DRESS
) INFRINGEMENT; UNFAIR
MAISON IMPECCABLE, ) COMPETITION AND FALSE
) DESIGNATION OF ORIGIN; DESIGN
) PATENT INFRINGEMENT
Defendant. )
)
) JURY TRIAL DEMANDED
)
)
this Complaint against Defendant, Maison Impeccable (“MI” or “Defendant”) and alleges as
follows:
and unfair competition under Section 43(a) of the Lanham Act, 15 U.S.C. § 1125(a), common law
trademark infringement, common law trade dress infringement, patent infringement of Plaintiff’s
Design Patent No. D723,261 (the “D261 patent”) in violation of the Patent Act of the United States,
and for substantial and related claims of unfair competition under the statutory and common laws of
the State of New York, all arising from Defendant’s unauthorized use of Plaintiff’s trademark and
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patented design in connection with the manufacture, advertising, promotion, and/or sale of
Plaintiff seeks injunctive and monetary relief to retain control over the substantial
goodwill associated with its trademarks, trade dress, and patented design, which are being
Plaintiff’s claims arise under 15 U.S.C. § 1051, et seq. (the Lanham Act),
particularly 15 U.S.C. § 1125(a), and the Patent Laws of the United States, 35 U.S.C. § 271 et seq.,
and for injunctive relief and damages under 15 U.S.C. §§ 1116 and 1117 and 35 U.S.C §§ 283 –
285. This Court has subject matter jurisdiction over the claims pursuant to the provisions of 28
U.S.C. §§ 1331 (federal question jurisdiction) and 1338 (any Act of Congress relating to patents or
trademarks), 15 U.S.C. § 1121 (action arising under the Lanham Act), and 35 U.S.C. §§ 271 and
281.
This Court has supplemental jurisdiction pursuant to 28 U.S.C. § 1367 over the
claims arising under New York statutory and common law because these claims are so related to the
federal claims as to form part of the same case or controversy and arise out of a common nucleus of
This action arises from Defendant’s use of, making, selling, offering to sell, and/or
importing, marketing, and promoting the Infringing Socks, and conduct of activities, that infringe
This Court has personal jurisdiction over Defendant because, inter alia, Defendant:
(1) transacts business within this district; (2) contracts to supply goods to or services in this District;
(3) has committed a tortious act within this District; (4) has committed a tortious act causing injury
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to Plaintiff within this District; (5) regularly solicits business, or engages in other persistent course
of conduct, or derives substantial revenue from goods used or consumed or services rendered, in this
District; (6) expects or should reasonably expect its acts to have consequences in this District and
derives substantial revenue from interstate or international commerce; (7) has systematic and
continuous contacts with this District; (8) continues to transact and do business in this District; and
(9) has websites and social media accounts that are accessible in this District, and through which
Defendant transacts business. Defendant’s acts form a substantial part of the events or omissions
giving rise to Plaintiff’s claims. For example, Defendant offers to sell and/or sells infringing
Upon information and belief, Defendant sells its goods to consumers in New York
marketed and offered for sale, and through which consumers can contact Defendant to purchase
sales to consumers in New York are not isolated occurrences. Rather, Defendant’s sales to New
York customers are means for establishing regular business in New York, to operate commercial
business in New York, and to sell substantial goods to New York consumers.
including this District, and has delivered Infringing Socks into the stream of commerce with the
expectation that they will be used and/or purchased by consumers in the State of New York,
1400(b) because a substantial part of the events giving rise to this action took place in this District,
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Plaintiff’s claims arise from the same nucleus of operative facts, and Plaintiff has suffered harm in
this District and the Lanham Act provides that venue lies in the place of harm.
Parties
Plaintiff is a corporation duly organized and existing under the laws of the State of
New York, having a principal place of business at 37 East 18th Street, 4th Floor, New York, NY
10003. Plaintiff is the owner of the intellectual property that is the subject of this Complaint.
Upon information and belief, Defendant is a corporation duly organized and existing
under the laws of the State of California, having a principal place of business at 1120 Granville
Ave., #102, Los Angeles, CA 90049. Upon information and belief, Defendant, without Plaintiff’s
authorization, is manufacturing, distributing, marketing, offering for sale and selling socks that
Plaintiff was created to help those in need through the manufacture, distribution, and
sale of high-quality socks. Plaintiff discovered that socks are one of the most requested clothing
items at homeless shelters after hearing a statement from Major George Hood, Chief Officer for the
Salvation Army: “Through our work with those in need, we know that socks are oftentimes the most
requested clothing item in homeless shelters.” From that day on, Plaintiff dedicated itself to
building a business that donates one pair of socks to those in need for every pair of socks purchased.
2013. Plaintiff’s initial fundraising goal was to raise $15,000 between April and September 2013.
Plaintiff surpassed its goal by approximately $127,500 (850%). Over 2,700 purchasers backed
Plaintiff’s initial campaign. (See Exhibit A, a website screenshot from Plaintiff’s Indiegogo
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Plaintiff grew rapidly after its Indiegogo campaign. Plaintiff soon found itself on the
widely popular ABC television series Shark Tank negotiating a deal with Daymond John – an
American entrepreneur best known as the founder and CEO of the “FUBU” fashion brand.
(See also Exhibit B, a website printout referencing Plaintiff’s Shark Tank appearance, which is
Plaintiff also caught the eye of large, famous retailers, such as The Gap as a result of
its constant growth and increasing sock donations (through partnerships with hundreds of charitable
organizations, such as Hannah’s Socks and the Bowery Mission). Retailers not only wanted to
support Plaintiff’s altruistic mission, but also knew Plaintiff’s goods are high in quality. To this
end, The Gap in 2015 entered a co-branding deal with Plaintiff through which Plaintiff’s socks were
sold at The Gap retail stores for the 2015 holiday season. The Gap honored Plaintiff’s ONE PAIR
PURCHASED = ONE PAIR DONATED®1 policy. This venture was widely popular and
1
Registration No. 4,945,652.
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increased Plaintiff’s recognition in the market. (See Exhibits C & D, webpage screenshots or press
releases related to Plaintiff’s partnership with The Gap, which are incorporated herein by reference.)
As a result of Plaintiff’s success, to date Plaintiff has donated over 8.5 million pairs
Plaintiff is the registered owner of the BOMBAS® trademark. The term “bombas”
is derived from the Latin word “bombus” meaning “bumblebee.” The term “bombas” is particularly
meaningful to Plaintiff because bees work together to make the hive a better place, which is
precisely what Plaintiff aims to do with its business. Plaintiff’s business is inspired by and
Besides the use and ownership of the trademarks BOMBAS® (Reg. No. 4,492,577),
® (Reg. No. 4,492,579), BEE BETTER® (Reg. No. 5,323,994), and ® (Reg.
No. 5,359,406), Plaintiff has also extensively and excusively used, and is thus the owner of common
(“Plaintiff’s Mark”.)
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Plaintiff’s Mark: Application Ser. No. 87921290, filed May 15, 2018.
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Plaintiff first used Plaintiff’s Mark at least as early as July 24, 2013 and has
continuously, extensively, and exclusively used Plaintiff’s Mark in commerce in the U.S. since that
time.
marketing and promotion (discussed in more detail below), Plaintiff’s Mark has become a
Plaintiff has rights to the trade dress of its marketing, goods, and packaging.
Plaintiff’s trade dress includes an individual honeycomb used alone or in combination with other
individual honeycomb pieces (“Plaintiff’s Trade Dress” (Plaintiff’s Mark and Plaintiff’s Trade
Dress are collectively referred to as “Plaintiff’s Mark and Trade Dress”), which emphasize
Plaintiff’s bumblebee/hive theme. Examples of Plaintiff’s Trade Dress have appeared on Plaintiff’s
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Plaintiff was the first to introduce the features comprising Plaintiff’s Trade Dress for
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meaning.
Plaintiff’s Trade Dress has acquired distinctiveness as demonstrated by, inter alia:
Plaintiff’s expenditure of millions of dollars promoting and popularizing Plaintiff’s Trade Dress
through advertising and product donations to those in need—to date Plaintiff has donated over 8.5
million pairs of socks to those in need; Plaintiff’s participation on Shark Tank; unsolicited media
coverage of Plaintiff’s products and donation program; Plaintiff’s sales success, having generated
millions of dollars of revenue; having partnered with The Gap during the 2015 holiday shopping
season; Plaintiff’s extensive, exclusive use of Plaintiff’s Trade Dress; the recognition of Plaintiff’s
Trade Dress and the good will associated therewith in the industry; and Defendant’s plagiarism
(described in more detail below), which trades off Plaintiff’s Trade Dress and the goodwill and
Plaintiff’s Trade Dress provides a unique ornamental and aesthetic appearance that
Plaintiff’s Trade Dress is not essential to the use of the purpose of Plaintiff’s socks.
There are numerous alternative means to perform the function of promoting and
Since well before Plaintiff’s official launch, Plaintiff has been devoted to bringing
high-quality sock designs to the consuming public. Plaintiff has expended significant resources in
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Plaintiff’s Mark and Trade Dress are inherently distinctive and strong when used in
relation to socks.
and Trade Dress, and in light of the unsolicited media coverage and notoriety pertaining to
Plaintiff’s goods and Plaintiff’s Mark and Trade Dress, the same have become distinctive of
Plaintiff, indicate a single source of origin of Plaintiff’s goods, and have acquired secondary
meaning.
Plaintiff has used Plaintiff’s Mark and Trade Dress continuously, exclusively, and
Plaintiff has used Plaintiff’s Mark and Trade Dress extensively since its first use
Plaintiff has advertised and otherwise promoted Plaintiff’s Mark and Trade Dress
extensively since its first use thereof, through the internet, social media outlets and by other means.
Plaintiff’s products bearing Plaintiff’s Mark and Trade Dress have been the subject
of unsolicited media coverage. Major publications like the New York Times have written about
Plaintiff. (See, e.g., Exhibit E (New York Times Article, March 16, 2016, “Selling High-End Socks
by Giving Them Away,” incorporated herein by reference), Exhibit F (online Forbes article, Feb. 6,
2017 “Meet Bombas, The Social Impact Company That Gave 2 Million Pairs of Socks To The
Homeless,” incorporated herein by reference) Exhibit G (online CNBC article, August 22, 2017,
“How Daymond John faced failure and ended up winning big,” incorporated herein by reference),
and Exhibit H (online Fast Company article, May 11, 2018, “Getting Startups Fired Up About
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recognition of and love for Plaintiff’s Mark and Trade Dress. Consumers even travel the world and
take photographs of their feet while wearing Plaintiff’s socks and post those photographs to social
media.
Plaintiff’s products bearing Plaintiff’s Mark and Trade Dress have been sold
extensively.
Plaintiff’s Mark and Trade Dress, and the unsolicited media coverage featuring the same, Plaintiff’s
Plaintiff has earned valuable and residual goodwill and reputation in the minds of
consumers in the United States for being the sole of source goods bearing Plaintiff’s Mark and
Trade Dress.
Plaintiff has protected its sock designs by a design patent. On March 3, 2015, the
United States Patent and Trademark Office duly and lawfully issued United States Design Patent
No. D723,261 titled, “Sock” (“the D261 Patent” (Plaintiff’s Mark and Trade Dress and the D261
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D261 patent
Plaintiff is the owner of all right, title, and interest in the D261 Patent. A true and correct copy of
the D261 Patent is attached hereto as Exhibit I, which is incorporated herein by reference.
imports into the United States socks that infringe Plaintiff’s Intellectual Property, including the
D261 Patent.
Long after Plaintiff’s adoption and first use of Plaintiff’s Intellectual Property in
connection with Plaintiff’s socks, Defendant, without Plaintiff’s authorization, began copying and
using Plaintiff’s Intellectual Property, or marks, trade dress, and designs substantially similar
and offering the Infringing Socks for sale. A screenshot from the Kickstarter campaign is attached
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On April 11, 2016, Plaintiff’s attorneys sent a cease and desist letter to Defendant,
which placed Defendant on notice of Plaintiff’s Intellectual Property and requested that Defendant
immediately cease all sales of the Infringing Socks and shut down its Kickstarter campaign.
Defendant, which stated that Defendant disagreed with Plaintiff and would continue offering to sell
As of April 2016, Defendant’s website was very simple and merely directed
potential customers to its Kickstarter campaign. Upon recent investigation, however, Plaintiff has
discovered that, after the Kickstarter campaign, Defendant altered its website to not only
prominently display the Infringing Socks, but also mimic Plaintiff’s Intellectual Property throughout
Plaintiff has also discovered that Defendant’s business is growing despite being put
Below are images from Defendant’s current website and Kickstarter website, which
provide non-limiting examples of Infringing Socks, infringing marks and trade dress that are
confusingly similar to Plaintiff’s Intellectual Property, and evidence showing the substantial
similarities between the parties’ websites and how Defendant has copied the look and feel of
Plaintiff’s Intellectual Property (screenshots of Defendant’s current website are attached hereto as
2
Notably, Exhibits K and L display a pop-up which respectively provide that “[s]omeone from Rochester, New
York” and “Bedford Corners, New York” just “purchased The Stealth Sock.”
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As displayed above, to date, the Infringing Socks are still being promoted and
Though Defendant has many patterns, shapes and arrangements to choose from, it
copied and/or used marks, trade dress, and/or designs that are confusingly similar to Plaintiff’s
Intellectual Property and used the confusingly similar marks, trade dress, and/or designs in a way
Defendant has also copied Plaintiff’s Trade Dress by copying the look and feel of
Plaintiff’s website.
Defendant’s products, marketing, and trade dress are likely to confuse and mislead
customers into believing that Defendant’s goods originate from, are sponsored by, or are affiliated
with Plaintiff.
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During the term of the D261 Patent, Defendant has manufactured or had
manufactured for it, and has offered for sale, sold, used, and/or imported articles embodying the
patented design of the D261 Patent, and engaged in activities that infringe the D261 Patent.
Defendant’s Infringing Socks infringe the single claim of the D261 Patent.
gives, the design on the Infringing Socks and Plaintiff’s patented design are substantially the same.
An ordinary observer would see the design on the Infringing Socks as making the
same design impression, or as being the same design, as the patented design of the D261 Patent.
An ordinary observer would likewise consider the design on the Infringing Socks, in
the context of any prior art, and giving such attention as a purchaser usually gives, to be the same as
In the eye of the ordinary observer, giving such attention as a purchaser usually
gives, the design on the Infringing Socks and Plaintiff’s patented designs are substantially the same,
with the resemblance being such as to deceive such an observer, inducing him to purchase one
In fact, the design on the Infringing Socks is virtually identically, if not identical, to
Defendant’s bad-faith activities have caused and will continue to cause a likelihood
of deception and confusion in the marketplace among consumers, and extensive damage to
Property.
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Upon information and belief, Defendant deliberately set out to use Plaintiff’s
Intellectual Property to benefit from the recognition and substantial goodwill that Plaintiff has
D261 Patent.
notice of Plaintiff’s rights therein, demonstrates Defendant’s willful infringement and bad faith.
Defendant has no right to use Plaintiff’s Intellectual Property. Defendant has no right
tends to and does create confusion and the erroneous impression that Defendant’s products emanate
or originate from Plaintiff and/or that said products are authorized, sponsored, or approved by
Plaintiff, even though they are not. This confusion causes irreparable and incalculable harm to not
only Plaintiff, but those in need who receive Plaintiff’s sock donations.
For every instance of confusion and each mistaken sale that goes to Defendant, a
Plaintiff’s Intellectual Property for its own financial gain. Furthermore, Defendant has unfairly
benefited and profited from Plaintiff’s outstanding reputation for high-quality socks, its mission to
help those in need, and its significant advertising and promotion of Plaintiff’s goods and Intellectual
Property.
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lost sales, Defendant’s manufacture, distribution, and sale of Infringing Socks will irreparably injure
Plaintiff’s reputation as Plaintiff is unable to control the quality of Defendant’s goods and/or the
Defendant’s acts and ongoing activities, as set forth herein, are willful. Therefore,
this case constitutes an exceptional case under 15 U.S.C. § 1117(a) and 35 U.S.C. § 285.
Upon information and belief, Defendant’s conduct is continuing and will continue
COUNT I
Federal Unfair Competition and False Designation of Origin
15 U.S.C. § 1125(a)
Plaintiff repeats and re-alleges each and every allegation in the foregoing paragraphs
injunctive relief to prevent or restrain infringement of its well-known mark and may petition the
Court to award damages, disgorgement of profits, and attorneys’ fees as a result of the trademark
infringement.
Defendant’s acts described above, including its use in commerce of marks and trade
dress highly similar or identical to Plaintiff’s Mark and Trade Dress, have caused or are likely to
affiliation, or approval of Defendant’s goods, and constitutes infringement of Plaintiff’s Mark and
Trade Dress and unfair competition in violation of the Lanham Act, and common law trademark
and unfair competition laws. Further, Defendant’s acts described above constitute materially false
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representations of fact that are likely to cause confusion, mistake, or deception as to the source,
1125(a).
As stated above, Plaintiff’s Mark and Trade Dress have become extremely well-
After Plaintiff’s Mark and Trade Dress became well-known, Defendant started to
use and continues to use Plaintiff’s Mark and Trade Dress, or marks and trade dress identical or
substantially similar to thereto, for commercial purposes and without Plaintiff’s permission.
Even after being placed on notice of Plaintiff’s rights in April 2016, Defendant
Upon information and belief, Defendant is willfully offering for sale and selling
socks that infringe Plaintiff’s Mark and Trade Dress in order to benefit from Plaintiff’s goodwill and
Defendant’s actions have damaged Plaintiff’s business, reputation, and goodwill and
have interfered with Plaintiff’s own use of Plaintiff’s Mark and Trade Dress.
Unless restrained and enjoined by this Court, Defendant will persist in its activities,
causing irreparable harm and injury not only to Plaintiff, but to those in need who receive socks
donated by Plaintiff.
from using Plaintiff’s Mark and Trade Dress, pursuant to 15 U.S.C. § 1116.
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Defendant’s profits in providing its goods using Plaintiff’s Mark and Trade Dress; (ii) damages
sustained by Plaintiff due to Defendant’s providing its goods using marks and trade dress identical
or confusingly similar to Plaintiff’s Mark and Trade Dress; and (iii) the costs of this action.
Plaintiff is also entitled, under 15 U.S.C. § 1117(a), to recover: (i) exceptional damages for
intentional infringement, bad faith, and willful conduct equal to three times profits or damages,
COUNT II
Common Law Trademark and Trade Dress Infringement
Plaintiff repeats and re-alleges each and every allegation in the foregoing paragraphs
Plaintiff is the owner of common-law trademark rights in Plaintiff’s Mark and Trade
Dress in New York and throughout the United States. These rights are senior and superior to any
Defendant has used in commerce, without Plaintiff’s consent, marks and trade dress
that are identical or confusingly similar to Plaintiff’s Mark and Trade Dress.
Defendant’s use of Plaintiff’s Mark and Trade Dress is likely to cause consumer
confusion, deception, or mistake among consumers as to the origin, source, sponsorship, affiliation,
or approval by Plaintiff of Defendant’s goods, in violation of New York common law as preserved
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malicious, and intended to injure Plaintiff, in clear disregard of Plaintiff’s legal rights.
Plaintiff has no adequate remedy at law inasmuch as money damages alone would
not adequately compensate Plaintiff for the harm to its rights, goodwill, and business reputation, not
to mention the extreme harm experienced by the public due to the fact that, for every lost sale of
Defendant’s acts described above greatly and irreparably damage Plaintiff and will
COUNT III
Common Law Unfair Competition
Plaintiff repeats and re-alleges each and every allegation in the foregoing paragraphs
Plaintiff is the owner of common law rights in Plaintiff’s Mark and Trade Dress.
Plaintiff has invested substantial time, labor, skill, and money in the development of
Through its conduct described above, including the unauthorized use of Plaintiff’s
Mark and Trade Dress and making false or misleading representations of fact in connection with the
sale of products confusingly similar to Plaintiff’s, Defendant has passed off their products as those
of Plaintiff or being in connection or affiliation with Plaintiff, and has intentionally misappropriated
Plaintiff’s labors, investments, and expenditures and intentionally exploited Plaintiff’s Mark and
among consumers as to the source, origin, sponsorship, affiliation, or approval of Defendant’s goods
by Plaintiff.
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Defendant has used marks and trade dress that are confusingly similar to Plaintiff, in
relation to identical or highly similar goods as Plaintiff’s and in competition with Plaintiff, all of
which provided and continues to provide Defendant an unfair advantage, because Defendant bore
Defendant’s conduct was made in bad faith, with full knowledge of Plaintiff’s
ownership of and/or exclusive right to use and license Plaintiff’s Mark and Trade Dress.
By knowingly competing against Plaintiff using confusingly similar marks and trade
dress for identical or highly similar goods, Defendant has misappropriated a commercial advantage
belonging to Plaintiff.
Defendant’s conduct is illegal and actionable under the common laws of the State of
New York.
New York common law as preserved by New York General Business Law § 360-o.
malicious, and intended to injure Plaintiff, in clear disregard of Plaintiff’s legal rights.
Plaintiff has no adequate remedy at law inasmuch as money damages alone would
not adequately compensate Plaintiff for the harm to its rights, goodwill, and business reputation, not
to mention the extreme harm experienced by the public due to the fact that, for every lost sale,
Defendant’s acts described above greatly and irreparably damage Plaintiff and will
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COUNT IV
Patent Infringement
Plaintiff repeats and re-alleges each and every allegation in the foregoing paragraphs
affirmative act to encourage a manufacturer(s) of the Infringing Socks to manufacture the same and
Upon information and belief, Defendant has and has had actual knowledge that the
induced acts constitute patent infringement, or, has and has had willful blindness thereto.
Upon information and belief, Defendant has and has had specific intent to induce
Plaintiff provided actual notice to Defendant of its infringement of the D261 Patent
demonstrating: Defendant’s awareness of the D261 Patent, the objectively high likelihood that
Defendant’s actions constitute infringement of the D261 Patent, that the D261 Patent is valid and
enforceable, and that Defendant knew or should have known the risk of using Plaintiff’s patented
design.
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Defendant has infringed and continues to infringe the D261 Patent by making, using,
promoting, marketing, offering to sell, and/or selling in the United States, including the state of New
York and within this District, products that are substantially similar to the D261 Patent in violation
Given the widespread popularity and recognition of Plaintiff’s patented design and
the patent notice provided by Plaintiff, Defendant had pre-suit knowledge of Plaintiff’s rights in the
D261 patent and has intentionally copied said design on Defendant’s own products in an effort to
pass them off as if they originated, are associated with, are affiliated with, are sponsored by, are
authority, permission, or license from Plaintiff. As such, Defendant’s infringing activities violate 35
U.S.C. § 271.
has suffered and continues to suffer substantial damages as a result of Defendant’s bad faith
activities. Plaintiff has also suffered actual damages, including lost profits, and has been forced to
retain legal counsel and pay costs of court to bring this action.
The injury to Plaintiff will continue unless and until Defendant is enjoined from
further infringement.
Defendant from the unlawful conduct alleged herein, including without limitation, Defendant’s
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infringement of the D261 Patent, Defendant’s willful and deliberate infringement justifies an
increase of three times the damages to be assessed pursuant to 35 U.S.C. § 284 and further qualifies
this action as an exceptional case supporting an award of attorneys’ fees pursuant to 35 U.S.C. §
285.
A. Grant of a permanent injunction enjoining and restraining Defendant and its officers,
agents, servants, employees, owners, representatives, and attorneys, and all those in active concert
a. Selling any products bearing and offering any services utilizing Plaintiff’s
Intellectual Property, or any variations thereof in or as part of any business, service or commercial
activity;
trade dress or design in relation to any products or services related to socks and t-shirts, or in any
Property as a trademark, service mark, trade dress or patented design in any jurisdiction in the U.S.;
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e. Offering for sale, selling or marketing merchandise that tends in any way to
deceive, mislead or confuse the public into believing that Defendant’s merchandise in any way
Plaintiff’s goods;
h. Engaging in further acts infringing Plaintiff’s rights under New York law;
advertisers, and other persons involved in Defendant’s offer of, or attempt to offer, goods under
Plaintiff’s Intellectual Property, that Plaintiff’s Intellectual Property is owned and controlled
bearing and/or utilizing Plaintiff’s Intellectual Property (or any other name, or other designation,
c. Within ten (10) days of judgment, take all steps necessary to remove from
Defendant’s place(s) of business and website(s), all references to Plaintiff’s Intellectual Property,
including but not limited to the offering for sale of products that infringe the same.
C. Ordering an accounting by Defendant of all revenues and profits derived from the
D. Ordering Defendant to account for and pay over to Plaintiff any and all revenues and
profits derived by it and all damages sustained by Plaintiff by reason of the acts complained of in
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this Complaint, including an assessment of interest on the damages so computed, and that the
damages be trebled pursuant Section 35 of the Lanham Act, 15 U.S.C. §1117, as well as 35 U.S.C.
Plaintiff’s actual damages, and awarding Plaintiff the costs of this action along with Plaintiff’s
F. That each such award of damages be enhanced to the maximum available for each
G. That Plaintiff be awarded punitive or exemplary damages under New York law
because of the egregious, malicious, and tortious conduct of Defendant complained of herein;
H. That Plaintiff recover the costs of this action including its expenses and reasonable
attorneys’ fees pursuant to 15 U.S.C. §1117, 35 U.S.C. § 285 and all further applicable law, because
of the deliberate and willful nature of the infringing activities of Defendant sought to be enjoined
J. Enter an order for Judgment in favor of Plaintiff and against Defendant on each and
every Claim of this Complaint, including by granting the following relief against Defendant:
and trademark infringement under Section 43 of the Lanham Act, 15 U.S.C. § 1125 and unfair
competition and trademark infringement under the common law and statutory laws of the State of
New York;
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Plaintiff’s rights under the D261 Patent, under 35 U.S.C. § 101 et seq.;
d. That the D261 Patent was duly and legally issued by the U.S. Patent Office,
e. Requiring that Defendant, within thirty (30) days after service of notice of
the entry of judgment, or an injunction pursuant thereto, file with the Court and serve on Plaintiff’s
counsel a written report under oath setting forth in detail the manner in which Defendant has
f. Awarding to Plaintiff such other and further relief as the Court may deem
JURY DEMAND
Respectfully submitted,
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EXHIBIT A
Title: BOMBAS : Better Socks. Better World . Bee Better. I Indiegogo Case 1:18-cv-04412 Document 1-1 Filed 05/17/18 Page 2 of 6
Link: https ://www. i ndiegogo .com/ projects/ born bas-better-socks-better-world-bee-better# /
CLOSED
PROJECT OWNER
David Heath
New York, United States
2 Campaigns I More
look better, feel better, and perform better. Free shipping in the U.S.
Estimated delivery
One pair purchased = One pair donated. November 2013
SO claimed
HI THERE .
Ships Worldwide
Thanks for checking out Bombas. We've received a ton of support getting this far and we're really
excited to finally share all of our hard work with everyone. Our project started two years ago when
we came across a quote that changed everything. We learned that socks are the #1 most $49 USD
requested clothing item in homeless shelters. Since then, the idea blossomed, designs were A Week's Worth of Bombas
designed , charity partners were secured, socks were tested , and here we are, launching Bombas Your choice of any seven (7) pairs of
exclusively on lndiegogo. Bombas socks. one for each day of the
week+ Seven (7) pairs of Bombas socks will
We'd love to hear from you , so reach out with any questions, comments or digital high fives. be donated to those in need + Free shipping
in the U.S.
- David and Randy
Estimated delivery
November 2013
739claimed
Ships Worldwide
Estimated delivery
November 2013
334claimed
Ships Worldwide
$99 USO
Estimated delivery
November 2013
327claimed
Through our work with those Ships Worldwide
in need, we know that socks GET THIS PERK
are the most requested clothing
item at homeless shelters.
$198 USO
- MAJOR GEORGE HOOD. His and Hers
CHIEF COMMUNICATIONS OFFICER FOR THE SALVATION ARMY
You get 2 full sets of Bombas! That includes
32 pairs of socks total, and 32 pairs
donated to charity. Each set includes eight
(8) pairs of calf-length Bombas + Eight (8)
We came across this quote two years ago and it really stuck with us . We started to think ... If
pairs of ankle Bombas. BONUS: One (1) pair
TOMS donates a pair of shoes for every pair purchased ... and Warby Parker donates a pair of of our limited edition, multi-colored
eyeglasses ... then why couldn't Bombas donate a pair of socks? Bombas for him and one (1) pair for her,
only available through lndiegogo!
Estimated delivery
November 2013
34claimed
Ships Worldwide
$225 USO
Estimated delivery
November 2013
-
these days. These are the is cool in the summer, warm in the
·-·
••·••····
•·,·.... .
antidot e to drab. w inter, and wicks moisture better
-
than traditional cotton.
·.. $4000 USO
COLOR. Athletic socks shouldn't have
STAY UP TECHNOLOGY. to be boring and white. Bombas come
We tested hundreds of in Jet Black and Heather Gray, accented Fully Custom Bombas
tension levels In the calf to by one of four neon colors: Blaze
make sure Bombas stay up, Orange, Lightning Yellow, Electric Blue, Work with us to create a unique set of
but aren't too tight. and our signature Hot Pink. Bombas exclusively for you - Includes eight
• hundred (800) pairs of your custom
INVISITOE: Most socks have an Bombas socks ( For personal use or
irritating seam that constantly rubs
• Y·STITCHEO HEEL the top of your toes. We hate that promotional purposes only. Not for re-sale .
Instead of a straight stit ch. seam. So we got rid of it by sewing Great for gifts!) + eight hundred (800) pairs
we use a Y-shaped stitch.
' ' all Bombas together by hand. will be donated to the charity of your choice
which creates a natural cup
'
' ' '
'
' • (Note: Your custom Bombas is limited to
•
'
around your heel. ' '' ' one style, calf or ankle, but will include both
'
male and fema le sizes)
Estimated delivery
November 2013
1 out of 10 claimed
Ships Worldwide
$6000 USO
Estimated delivery
November 2013
0 out of 10 claimed
Ships Worldwide
$10000 USO
AND WHAT 'S WITH ALL THE BEE S? The Sock Drop
Select the first organizations to receive our
first sock drop. a bulk delivery of socks to
an organization in need, + Full travel and
The word Bombas is derived from the Latin word for bumblebee. Bees work together to make the
accommodations for you and a guest to
hive a better place. We like that. So much so that it inspired our slogan that's written on the inside meet us to participate in the delivery first
of every pair of Bombas: bee better. hand. We will design a sock with you in
honor of the occasion which we will make
available for sale on our website with your
name or company listed in recognition of
your generous support.
Estimated delivery
February 2014
0 out of 5 claimed
Ships Worldwide
$350000 USO
Estimated delivery
December 2013
0 out of 1 claimed
Allowing for 20 days to receive the funds we raised we can expect to have Bambas delivered to
you within 3 months after the end of the campaign. And we will do everything within our control to
expedite the process to get them to you as soon as possible.
It is important to note that while Bambas are produced for these standard size ranges, Bambas
have more stretch and recoil than your traditional pair of socks. As such, we have had athletes
with shoes sizes up to a 15 wear Bambas comfortably with no compromise in performance or
durability.
Since Bambas have a unisex design, our Teen sizing can be worn by both girls and boys with the
corresponding shoe sizes . If buying these as a gift for a youngster, sizes 5-9 range on average
from 12-18 years in age.
If you've worn your Bambas, our only request is that you wash them prior to send ing them back.
We want to make sure you're happy but don't want to handle your funked up Bambas in the
process. And so you don't feel bad , your Bambas will be donated to someone in need.
As such , Bambas are equally at home with a pair of jeans, a button down , and Red Wings as they
are with shorts, at-sh irt and some Nike AirMax 95's. We've even worn the black ones with a tux
before . The black and heather grey base colors are neutral enough to go with any color fabric and
any shoe, while the neon accents are subtle enough to provide enough contrast to get noticed , but
not too much to stand out.
The only solution here is to make sure these people have their own . Bambas are inexpensive and
cool enough to make for pretty excellent gifts. Remember, they're cheaper and last a whole lot
longer than flowers. And hey, you'll be helping someone less fortunate in the process, so win/win
all around .
Will the founder of Bombas really get a Bombas tattoo if you raise $200,000?
David is 30 years old and has zero tattoos. He's never really thought about getting one. But he
has given his word that he will get a Bambas tattoo if we raise $200 ,000 in fund raising. It's his way
of committing to something he truly believes in and will be a permanent reminder of your support.
His mother is not happy about this. We like David's mother, but a promise is a promise. If you
pledge, and encourage your friends to pledge, the ink will flow freely. And permanently. And we
Case 1:18-cv-04412 Document 1-1 Filed 05/17/18 Page 6 of 6
promise to post video and pictures right on this page as proof.
Let us know if you t hink t his campaign contains prohi bited cont ent.
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CRAFT MEAD
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Help us get Boneflower Craft Mead Pleistocene Park is flying bison from Shared P2P Hosting Time.
into your glasses ! Alaska to Siberia to fight climate Next-Gen Internet: Where we host the A food cart bringing tasty on-the-go
change peer-to-peer web on mini-servers. breakfast to Northwestern, in the
morning and late at night.
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EXHIBIT B
Title: Shark Tank: Season 6 Premiere: Sleeping Baby, Hamme r & Na ils, Amber,Case and1:18-cv-04412
Bombas - Watch Season 6 Episode
05/17/1801Page 2 of 2
e
Document 1-2 Filed
Link: http: // a be.go .com/shows/shark-tan k/ep isode-guide/season-06/ 1-sea son-6-p rem i ere-s leeping-baby-hammer-nails-a mber-and-bo mbas# recap
p gbaby
S6 EOl Season 6 Premiere: Sleeping Baby, Hammer & Nails, Amber, and Bambas
09/26/14 I TV-PG I cc
Sleeping Baby Inc. is the home of the fabulous Zipadee-Zip(r) 1 The Zipadee-Z ip(r) is a mom-invented product that is restori ng
sleep and san ity to babies and pa rents all over the world in a way that no other baby sleep product has before The Texas 1
couple, Brett and Stephanie Parker, created this business in an effort to provide their daughter with the cozy, womb-like sleeping
environment she loved, but the freedom to rol l around safely and freely. Not only did it drastically improve their daughter's sleep,
but parents started flocking to their website in search of a sleep solution for their little ones. Sleeping Baby Inc. has grown
drastically by word of mouth marketing a lone Now babies everywhere are having sweeter dreams because of the Zipadee -Zip !
1
At Hammer & Na ils - The Nail Shop for Guys, hand and foot care is a completely masculine experience. With our low-lighting,
oversized leather chai rs, personal flat-screen TVs with personal remotes, premium sports channels, high-end headphones and
complimenta ry beverages; Hammer & Nails - The Nail Shop for Guys is man cave nirvana.
PITCH: Amber
Wedding Wagon is a revolutionary mobile officiant franch ise that brings the ceremony to the customer. It's like pizza delivery for
weddings No more "going to the chapel" ... with the Wedding Wagon, ou r couples get to choose that special location that means
1
the most to them. We simply meet them there for a fun and unforgettable ceremony. Best o f all, as a low-overhead franchise you
never have to worry about the usual headaches t hat a traditional wedding brings like food & catering, elaborate set-ups or
employees to manage. Instead, we keep thi ngs simple by provid ing "Happily Ever After... Delivered!"
PITCH: Bambas
BOMBAS is a line of purpose-built and thoughtfully designed athletic-leisure socks, re-e ngineered witl1 seven substantial updates
to look better, feel better, and with a mission to help those in need. With the knowledge that socks are the #1 most req uested
cloth ing item at homeless shelters, BOMBAS donates a pair for every pair purchased, and to date has donated more than 70,000
pairs. For more information, check out Bambas.com.
Shark Tank > Episodes > Season 06 > l Season 6 Premiere· SleP.p1ng Baby. Hammer&. Nails, Ar<1ber, and Bambas
your califomia privacy rights children's online privacy policy closed captioning
EXHIBIT C
Title: Gap and Bombas Partner to Raise Awareness for Homeless Need Case 1:18-cv-04412 Document 1-3 Filed 05/17/18 Page 2 of 3
Lin k: https: //www.prnewswlre.com/news-releases/ gap-and-bo mbas-partner-to-ra ise-awa reness-for-ho meless-need-300178021 .htm I
C
PR Newswire
News Products Contact Search Q
News in Focus Business & Money Science & Tech Lifestyle & Hea lth Po li cy & Pub lic Interest People & Cu lture Adva n ced Sea rch
NEWS PROVIDED BY
Gap Inc. -+
Nov 76, 2075, 06:50 ET
NEW YORK, Nov. 16, 2015 /PRNewswi re/ -- This holiday season, Gap is joini ng forces with Bambas, t he at hletic -leisure
sock company w ith a philanthropic mission, to bring awareness to the most requested cloth ing item in homeless
shelters: socks. The exclusive Gap x Bambas col lection w ill be available in se lect Gap stores around the world and on
Gap.com. For every pair sold in partic ipat ing countries, Gap w i ll give a pair of specially-designed Bambas donation socks
to som eone in need.
•
global audience, and together the two brands share a goa l to
donate one m ill io n pairs of socks to homeless shelters in
pa rti cipat ing Gap m.arkets.
Gap x Bombas Socks for Men
"Bambas was fou nded because we wanted to he lp so lve a problem that many peop le didn't know existed ," said Ra ndy
Goldberg, co-fo unde r and c hief brand officer of Born bas. "With t he suppo rt of Gap, we are able to b ring an international
spotlight to the iss ue that drives us year-round," added David Heath, co -founder and chief execut ive officer of Bambas.
The Bambas donation socks are purpose-bu ilt to he lp meet t h e needs of those w ho have inspired the Bambas mission.
Each pair has reinforced seams for greater durability, an anti-m icrobial treatment t o deter t h e growth of odor and
fungus and darker co lors to minimize visible wear. These attributes make a big differe nce in the lives of t hose who don't
have the luxury of having a clea n pa ir of socks eve ry day.
In store and on line (i n the U.S. and Canada), Gap w ill carry the exc lusive line of Gap x Bombas ca lf socks fo r adults and
children. Wit h in each category, there are four d ifferent color combinations exclusive to the pa rtners h ip. The Gap x
Bombas socks wi ll be ava il able at select Gap stores in the U.S., Canada and Japan. Working w ith charitable partners,
Good360 and t he National Coal it ion for the Home less, all Gap x Bambas and Gap brand socks purchased in these
countries as we ll as Gap brand socks purchased in the EU wi ll cont ribute to the goal of one mil lion donated.
To extend that campa ign furthe r, Gap is ra isi ng awareness for t he issue through socia l media w it h the use of the
hasht ag #socksforal l.
AboutGap
Gap is one of the world 's most iconic apparel and accessories brands and t he authority on American casua l style.
Founded in San Franc isco in 1969, Gap's collections are designed to bu ild the foundat ion of modern wardrobes - all
th ings denim, classic w h ite sh irts, khakis and must-have trends. Beginning w ith the first internationa l store in London in
1987, Gap cont in ues to connect w ith customers on line and across the b rand 's about 1,700 company-operated and
franchise retail locations around the world. Gap indudes Women's and Men 's appare l and accessories, GapKids,
babyGap, GapMatern ity, GapBody and GapFit col lections. The brand also serves value-conscious customers wrth
excl usive ly-designed collections for Gap Outlet and Gap Factory Stores. Gap is the namesake brand for leading globa l
Case 1:18-cv-04412 Document 1-3 Filed 05/17/18 Page 3 of 3
specia lty retailer, Gap Inc. (NYSE: GPS) which includes Gap, Banana Republic, Old Navy, Athleta and Intermix. For more
information, p lease visit www.gapinc.com.
About Bombas
Founded in 2013, Bombas is a col lection of high ly functional and fashionab le athletic-leisure socks with a philanthrop ic
mission. After d iscovering socks are the #1 most requested cloth ing item in homeless shelters, founders Randy Goldberg
and David Heath established the brand's mission to donate a pa fr of socks for every pair sold . Each sock is constructed
using Bombas Sock Tech, comprised of seven substantia l ways to improve the comfort, pe rformance and design of the
athletic sock. The collection is currently avai lable on www.Bombas.com in a variety of bold colors and neutral solid for
men, women and kids.
Media Contacts:
Challn Tulyathan
Gap
212 886 7445
cha Iin_tu lyatha [email protected]
Emi ly Hofstetter
Bombas
845 641 5099
[email protected]
Al icia Storey
Edelman
+44 (0)20 3047 2640
a [email protected]
Related Links
https://www.prnewswire.com/news-releases/gap-and-bombas-partner-to-raise-awareness-for-homeless-need-300l7E
•
Contact PR Newswire Products About My Services
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EXHIBIT D
Title: Gap and Bambas Pa·r tner to Ra ise Awareness for Homeless Need Case 1:18-cv-04412 Document 1-4 Filed 05/17/18 Page 2 of 2
Link: http://www.gapinc.com/content/gapinc/html/media/pressrelease/2015/med_pr_gap_bombas_ 1115.htm1
Gap I C. • Jl·ittii• 0
ATtl Li A IN E1MIX Search Ga p Inc.
:. -- ·•:. .., _- .~
PRESS RELEASE CONTACT US
-·· ., - .... , .... ..... ,. __._,, We're happy to hear from you .
Brands : GaR. Gag, Inc. Cat egori es: B rand Camgaigns Social Resg,onsibility_
_
:COMPANY:
. I ,,. •
Choose a Departme nt
11/16/2015
- _,._, --- -' ·- _, ·- '. .- _ _.. :
,DESIGN
RAISE AWARENESS fO,R Meet ug with us on Facebook
'. ).ipRE's's;ifELEAS°Es; The exclusive partnership sets goal to donate 1 million socks to
View us on YouTube
NEW YORK - November 1i6, 2015 - This holiday season , Gap is joining forces with
EMAI L AL ERTS
Bombas, the ath[etic-leisure sock company with a philanthropic mission, to bri ng Get breaking news 0 11 Gap Inc.
awareness to the most requested clothing item in homeless shelters: socks. The and our brands.
exclusive Gap x Bambas collection will be available in select Gap stores around the
world and on Gap.corn. For every pair sold in participattng countries, Gap w ill give a pai r
of specially-designed Bambas donation socks to someone in need.
The partnership is part of Gap's ongoing commitment to support local communities and
to give back this holiday season Since its founding in 201 3, Bambas has been
committed to donating a pair of socks for every pair so ld and, to date, has donated more
than 500,000 pairs of socks in the United States. Inspired by that accomplishment, Gap
has committed to bringing awareness of the Bambas mission to a global audience, and
together the two brands share a goal to donate one million pairs of socks to homeless
shel1ers in participating Gap markets.
" G;i[) h ;is ;;ilw;iys hf'Pr1 <:omm ittf'rl to i nr.orrinr;;ifina ;i rnsitivf' sor.i ;;il i m p ;;ir.l in to 0 11 r
everyday business," said Steven Sare, senior vice president of Merchandising for Gap.
"We saw a natural partner in Bambas because their giveback component resonates so
strongly with our values an.ct those of our customers who are excited about giving back .
We were also impressed by the inn ovative design of the socks 1hat Bambas donates, as
they're specifically crafted to meet the particular needs of the people recei ving them."
"Bambas was founded because we wanted to help sol;ve a problem th at many people
didn 't know existed," said Randy Gotdberg, co-founder and chief brand officer of
Bambas. "With the support of Gap , we are able to bring an international spotlight to the
issue that drives us year-round," added David Heath, co-founder and chief executive
officer of Bombas.
The Bambas donation socks are purpose-built to help meet the needs of those who
have inspired the Bombas mission. Each pair has reinforced seams for greater
durability, an anti-microbial treatment to deter the growth of odor and fungus and darker
colors to minimize visible wear. These attributes make a big difference in the lives of
those who don't have the luxury of having a clean pair of socks every day.
In store and onl ine (in the u_s_and Canada), Gap w ill carry the exclusive line of Gap x
Bambas calf socks for adults and children. Wrthin each category, there are four different
color combinati ons exclusive to the partnership. The Gap x Bambas socks will be
available at seJect Gap stores in the U.S. , Canada and Japan. Working wrt.h charitable
partners, Good360 and 1he Nati onal Coa lition for the Homeless, all Gap x Bambas and
Gap brand socks purchased in these countries as well as Gap brand socks purchased in
the EU will contribute to the goal of one million donated .
To extend that campaign further, Gap is raising awareness for the issue throug h social
media with the use of the hashtag #socksforal l.
About Gap
Gap is one of the world's most iconic apparel and accessories brands an d the auth ority
on Ameri can casual style_ Founded in San Francisco in 1969, Gap's collections are
designed to build the fou ndati on of modern wardrobes - all things denim, classic whrte
shirts, khakis and must-have trends. Beginning with the first intern ational store in
London in 1987 , Gap continues to connect with customers online and across the brand's
about 1,700 company-operated and franchise retail locations around the world_ Gap
includes Women's and Men's apparel and accessories , GapKids , babyGap ,
GapMatem ity, GapBody and GapFit collections. The brand aJso serves value-conscious
customers with exclusively-designed collections for Gap Outlet and Gap Factory Stores.
Gap is !he namesake brand for leading globat specialty retailer, Gap Inc. (NYSE: ,GPS)
which includes Gap, Banana Republi c, Old Navy, Athleta and Intermix. For more
information, please visit www.gai:iinc.com .
About Bombas
EXHIBIT E
5/11/2018 Selling High-End
Case 1:18-cv-04412 DocumentSocks by GivingFiled
1-5 Them Away - The New Page
05/17/18 York Times
2 of 5
REVALUED
David Heath, a 32-year-old entrepreneur wearing customized black and pink Nikes, hovered near
the lunch line at the Bowery Mission, one of New York’s oldest homeless shelters.
“Want a pair of socks?” he asked an aging man in a tattered black coat who had come indoors on
a cold, rainy afternoon.
“I would love a pair of socks,” the man said. “Just what I need.”
Mr. Heath handed the man a pair of new high-end cotton socks and turned his attention to the
next person in line.
Along with his pal Randy Goldberg, Mr. Heath is a co-founder of Bombas, a start-up based in New
York that makes what it calls “the most innovative sock in the last 20 years.”
Pricing its socks, which feature neon colors with a bee logo, at up to $18 a pair, Bombas has been
developing a reputation for design and for its business model. For every pair that the company
sells, it gives a pair to someone in need.
While it may be tempting to write off Mr. Goldberg and Mr. Heath as millennial do-gooders
piggybacking on poverty to make a quick buck, the Bombas co-founders say they are addressing
a real need. Socks, it turns out, are the most requested item at homeless shelters. (Shelters won’t
accept used socks, not many socks are donated, and people living on the street wear through
pairs quickly.)
It was this sobering fact that inspired the Bombas founders to start their company in 2013. A few
years on, they have donated more than 900,000 pairs of socks.
https://www.nytimes.com/2016/03/20/business/selling-high-end-socks-by-giving-them-away.html
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Case 1:18-cv-04412 DocumentSocks by GivingFiled
1-5 Them Away - The New Page
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3 of 5
By building altruism into its business model, Bombas joins a growing list of so-called buy-one-
give-one companies. Toms, a shoemaker based in Los Angeles, pioneered the idea. It gives away
a pair of shoes to children in the developing world for each pair it sells. In recent years, the
approach has expanded to companies making eyeglasses, snack bars, soap, toothbrushes and
even pet food.
But as the buy-one-give-one companies have proliferated, so have questions about the model’s
efficacy, and even its ethics. Impoverished children don’t need shoes as much as education and
clean drinking water, goes one line of criticism. Others pointed out that by flooding a community
with free shoes, a company like Toms was effectively putting local shoe stores out of business.
“As larger companies adopt these models to take advantage of the business opportunity,
consumers may become suspicious about the authenticity of the overall concept,” Christopher
Marquis and Andrew Park wrote in the Stanford Social Innovation Review. And as more
entrepreneurs seek to capitalize on this form of cause marketing, companies are devising all
manner of promises to entice new customers. United By Blue, an apparel maker in Philadelphia
that sells $600 jackets, pledges to clean up one pound of trash from waterways for every item it
sells.
That may be a worthwhile venture, but at some point, the connection between profit and
benevolence becomes strained. “Opportunities exist for smoke and mirrors, sleights of hand and
confusion on the part of the consumer,” said Katherine Klein, head of the Social Impact Initiative
at the Wharton School at the University of Pennsylvania.
Writing in The Journal of Consumer Psychology last year, a group of professors referred to the
practice as “guilt laundering.” And yet despite these critiques, buy-one-give-one companies are
not only doing good, but also thriving.
Mr. Heath and Mr. Goldberg were colleagues at a lifestyle website when they learned — via a
Facebook post — that socks were the most requested items in homeless shelters. Keen to start
their own company and solve that problem, they spent the next couple of years researching the
sock business and developing prototypes.
It didn’t take long for the men to arrive at a conclusion: “Most socks aren’t very comfortable,” Mr.
Heath said. The sock business was ripe for disruption, they decided.
After dozens of iterations, the Bombas founders developed a sock with several new features: a
seamless toe, a cushioned foot bed, an arch support system, elastic that keeps long socks up and
blister tabs on the backs of ankle socks.
https://www.nytimes.com/2016/03/20/business/selling-high-end-socks-by-giving-them-away.html
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1-5 Them Away - The New Page
05/17/18 York Times
4 of 5
The socks that Bombas donates to homeless people have reinforced seams and an antimicrobial
treatment. Kevin Hagen for The New York Times
“If we build a better pair of socks, we can sell more socks,” Mr. Heath said. “And if we sell more
socks, we can donate more socks.”
In October 2013, Bombas raised $145,000 through Indiegogo, a crowdfunding site. A year later, the
company raised a $1 million seed round from friends and family. To date, Bombas has sold more
than 900,000 pairs of socks.
As Mr. Heath and Mr. Goldberg have developed their business, they have learned from the
stumbles of their buy-one-give-one peers. Instead of trying to solve problems in distant lands, the
founders have focused on giving their socks to homeless shelters in the United States.
“If other companies can do this for developing world countries, why can’t we do this to solve a
problem that people don’t even know is right here in our backyard?” Mr. Heath said.
And rather than lead their pitch with the social mission, they try to keep the focus on what they
say are the most comfortable socks on the market.
“It’s a fine line between exploiting the people you’re trying to help and helping those people,” Mr.
Heath said.
https://www.nytimes.com/2016/03/20/business/selling-high-end-socks-by-giving-them-away.html
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1-5 Them Away - The New Page
05/17/18 York Times
5 of 5
Homeless advocates say their help is welcome, however it arrives. “Socks are one of the most
needed but often the least donated items at shelters,” said Megan Hustings, interim director of
the National Coalition for the Homeless. “Anything that works to get those socks to people is
good.”
The socks that Bombas gives away differ slightly from those that it sells. The donated socks
feature reinforced seams for added durability, dark colors that show less wear and an
antimicrobial treatment that prevents odors and germs.
While Bombas employees distribute some socks personally, they send most of the donations to
charity partners like Hannah’s Socks, a group in Ohio that has distributed 100,000 pairs to local
shelters.
Giving away so many socks comes at a cost. In 2014, when Mr. Heath and Mr. Goldberg appeared
on “Shark Tank,” the reality television show where entrepreneurs pitch investors, their buy-one-
give-one model came under fire.
“You have to double your sales to give me the equivalent returns I get from a company that’s not
doing the same thing,” said Kevin O’Leary, one of the hosts, declining to invest.
Another host, Mark Cuban, the billionaire owner of the Dallas Mavericks basketball team, said
the price point for socks was too low to justify the $4 million valuation the Bombas founders were
seeking.
Finally, Daymond John, founder of the Fubu clothing line, agreed to invest $200,000 for 17.5
percent of the company, or a valuation slightly over $1 million. (After the show, the terms of his
investment were renegotiated.) It was a humbling outing for the founders, who are now seeking
more funding.
Yet even without a heady valuation, Bombas is enjoying a growth spurt. Sales reached $4.6
million last year, and are expected to hit $7.4 million this year. The average pair sells for about $11.
During their recent visit to the Bowery Mission, while Mr. Heath and Mr. Goldberg handed out
socks, Bombas employees served stewed chicken, quinoa and tomatoes to more than 200 people
who had turned up at the shelter in the rain.
As Mr. Heath engaged in charity, he addressed a thorny issue. Was Bombas exploiting people’s
sympathy in order to make a buck? And if it was, did that even matter?
“As far as people washing away their guilt, that’s fine,” Mr. Heath said. “We’re doing something
good with the purchases they’re making. If they feel good about themselves, great.”
A version of this article appears in print on March 20, 2016, on Page BU3 of the New York edition with the headline: Selling High-End Socks by Giving Them Away
https://www.nytimes.com/2016/03/20/business/selling-high-end-socks-by-giving-them-away.html
Case 1:18-cv-04412 Document 1-6 Filed 05/17/18 Page 1 of 5
EXHIBIT F
5/17/2018 Meet Bombas, The Social
Case 1:18-cv-04412 Impact Company
Document 1-6ThatFiled
Gave 205/17/18
Million Pairs OfPage
Socks To
2 The
of 5Homeless
/ Under 30 / #ChangeTheWorld
FEB 6, 2017 @ 05:36 PM 14,405
There has never been a more explosive time in the world of social impact. Social
entrepreneurs have emerged from almost every industry, solving problems to
improve the lives of others while employing business strategies to do so. A popular
strategy has been the “one-for-one” business model, a model that’s easily tangible
for consumers to understand and connect with social impact – I buy one, they give
one.
https://www.forbes.com/sites/toriutley/2017/02/06/meet-bombas-the-social-impact-company-that-gave-2-million-pairs-of-socks-to-the-homeless/#140f0e15288b
5/17/2018 Meet Bombas, The Social
Case 1:18-cv-04412 Impact Company
Document 1-6ThatFiled
Gave 205/17/18
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Socks To
3 The
of 5Homeless
Meet Bombas, another player in the one-for-one business. The social impact sock
company has a twofold goal: first, design the best sock in the history of feet, and
second, give a pair of socks to someone in need with every purchase.
For cofounders Randy Goldberg and David Heath, the dream started when they
learned that the No. 1 most requested item in homeless shelters was socks. “I didn’t
grow up dreaming of being in the sock business,” Goldberg states, claiming he’d
never really thought about the importance of the sock before he learned about the
need. The need comes from the fact that donating socks comes down to hygienic
issues – socks need to be new, and unfortunately, there aren’t enough donations
coming in to meet demand.
After learning about the need, Heath and Goldberg realized that socks are largely the
same – the sock industry hadn’t been innovating, and not much had changed about
the everyday sock in decades. “We decided to start there – have a customer-focused
approach to innovate and create a great sock – the best socks in the history of feet,”
Goldberg states.
After investing over a year in R&D with factory partners, the team finally landed on
a great product. In August 2013, they launched an Indiegogo campaign that reached
over $140,000 in presales, and in 2014, the duo aired on Shark Tank where they
landed a deal with Daymond John. From there, things really started to grow.
That growth led to the achievement of the team’s initial mission – to give away as
many socks as they could to those in need in homeless shelters around the country.
When Bombas first got started, they hoped to give away 1 million socks to those in
need by 2025. But because of incredible reception by their consumers across the
globe, they hit that lofty goal in just two and a half years, announcing the
accomplishment in November 2016. They had been giving away more than 1,000
pairs per day.
But, something even more remarkable just happened for the Bombas team. Just six
months after reaching their initial 2025 goal of giving away 1 million socks, they
reached 2 million socks given to those in need.
https://www.forbes.com/sites/toriutley/2017/02/06/meet-bombas-the-social-impact-company-that-gave-2-million-pairs-of-socks-to-the-homeless/#140f0e15288b
5/17/2018 Meet Bombas, The Social
Case 1:18-cv-04412 Impact Company
Document 1-6ThatFiled
Gave 205/17/18
Million Pairs OfPage
Socks To
4 The
of 5Homeless
/ Under 30 / #ChangeTheWorld
FEB 6, 2017 @ 05:36 PM 14,489
“We had been running fast, so the moment we realized we had given away this many
socks was really just a moment to pause. A moment to realize that we appreciated
coming to work every day and why we’re building the company we’re building. It
was a moment to celebrate the team and remind ourselves why we started. More
than anything, it was affirming that other people felt the same way we did – that our
products were something worth purchasing and the cause was something to spend
time on,” Goldberg shares.
Goldberg shares the generous culture at Bombas, now employing nearly 30 people,
is another contributor to the team’s success. Goldberg states that when a new hire is
brought on the team, they’re given 10 pairs of socks to donate in the community to
those in need – a practice, Goldberg states, that helps root their employees directly
with the company’s mission. Beyond that, Bombas has created a culture of
volunteering and giving back – “We go and volunteer and are there to listen and
learn – to hear people’s stories and connect.” According to Goldberg, the Bombas
team now has more than 600 donation partners across the U.S.
For Bombas, this is just the beginning. After making an impact through 2 million
pairs of socks and touching numerous lives along the way, the company is looking
forward to another year of growth and impact, with potential partnerships on the
horizon with Veterans Affairs (VA) and Special Olympics.
For other social entrepreneurs, Goldberg has a word of advice: “Make sure you know
why you’re doing what you’re doing, and make sure you know who you’re supporting
https://www.forbes.com/sites/toriutley/2017/02/06/meet-bombas-the-social-impact-company-that-gave-2-million-pairs-of-socks-to-the-homeless/2/
5/17/2018 Meet Bombas, The Social
Case 1:18-cv-04412 Impact Company
Document 1-6ThatFiled
Gave 205/17/18
Million Pairs OfPage
Socks To
5 The
of 5Homeless
and what they really need. No matter what happens in your business, don’t sacrifice
the impact you’re making – it has to stay the primary driver.”
By designing the best socks in the history of feet and staying committed to their
customers, Bombas hopes to continue putting socks on those in need through
generosity, great design and a steadfast commitment to giving back.
https://www.forbes.com/sites/toriutley/2017/02/06/meet-bombas-the-social-impact-company-that-gave-2-million-pairs-of-socks-to-the-homeless/2/
Case 1:18-cv-04412 Document 1-7 Filed 05/17/18 Page 1 of 4
EXHIBIT G
5/11/2018 Case 1:18-cv-04412'Shark Tank' investor1-7
Document Daymond John05/17/18
Filed won big with Bombas
Page 2 of 4
Daymond John speaking at the Iconic Conference in New York on June 7th, 2017.
When people fail, they often feel like they want to give up. But for the PRIMETIME SHOWS ›
most successful, like Daymond John, failure is just an opportunity to
learn.
"I have a warehouse full of FUBU socks," John admits on the "The James
Altucher Show" podcast.
https://www.cnbc.com/2017/08/21/shark-tank-investor-daymond-john-won-big-with-bombas.html
5/11/2018 Case 1:18-cv-04412'Shark Tank' investor1-7
Document Daymond John05/17/18
Filed won big with Bombas
Page 3 of 4
"Socks are the hardest things to sell," he says. "First of all, if you're
wearing them, I don't know what brand they are. They're in buckets and
barrels over at Burlington Coat Factory, right?"
Bombas sells re-engineered athletic socks. And, for every pair they sell,
they donate another pair to charity. Their name comes from the Latin
word for bumblebee, and their motto "bee better" is stitched into every
sock as a reminder of the business' philanthropic mission.
"If other companies can do this for developing world countries, why
can't we do this to solve a problem that people don't even know is right
here in our backyard?" Heath says in the Times.
When Heath and Goldberg pitched the sharks in 2014, they had
$450,000 in sales. Although no other judges were interested in the
business — fearing the give-away aspect would be too expensive —
John was willing to make a deal to invest $200,000 for 17.5 percent
equity.
John says the company's online-only model was a new way to think
about socks, and a reason he was interested in the deal.
"They were selling socks, but they weren't selling in traditional retail
stores," he says. "They were selling them direct to the customer."
In fact, Heath says that was some of John's best advice — to stay out of
brick and mortar.
"We had early ambitions of and thoughts of going into retail," Heath
says. "[John] actually convinced us that really, e-commerce and direct-
to-consumer is kind of the future."
For John, the other reasons why Bombas' business works are simple but
powerful.
"Number one the socks are amazing, they have no seams on the front so
your toe doesn't get jammed up," he says. "Number two is they donate
https://www.cnbc.com/2017/08/21/shark-tank-investor-daymond-john-won-big-with-bombas.html
5/11/2018 Case 1:18-cv-04412'Shark Tank' investor1-7
Document Daymond John05/17/18
Filed won big with Bombas
Page 4 of 4
a pair to the homeless shelter, because the homeless, one of their
biggest challenges are the care for their feet."
"I started to learn that I can't sell the crap of socks that I have in a
warehouse in Secaucus now, but these guys are selling it in a whole new
way," John says on the podcast. "So I started to educate myself on new
ways to do business."
In the two months after the Bombas "Shark Tank" episode aired, the
company did $1.2 million in sales and completely sold out of inventory,
Heath tells CNBC Make It.
Now, the company is on track to do $50 million in sales for 2017. The
success has also allowed them to increase their donations, from 70,000
pairs before "Shark Tank," to now over 4 million.
Though they taught John a thing or two, he's also helped them with
their success. "He's really open minded," says Heath of their shark, "and
just generally a smart business guy."
Don't miss: Daymond John broke his 'Red Lobster' rule to do these
'Shark Tank' deals—now they're his top 2 companies, making millions
0
How Daymond John went from waiting
tables at Red Lobster to creating a $6
billion urban clothing brand
Ali Montag
News Associate
https://www.cnbc.com/2017/08/21/shark-tank-investor-daymond-john-won-big-with-bombas.html
Case 1:18-cv-04412 Document 1-8 Filed 05/17/18 Page 1 of 8
EXHIBIT H
Case 1:18-cv-04412 Document 1-8 Filed 05/17/18 Page 2 of 8
5/11/2018
0 7 . 2 9 . 1 7 M OV I N G T H E N E E D L E
BY ELIZABETH SEGRAN
6 MINUTE READ
When you think of the immediate needs of the homeless, clean socks may not be the first thing that come to mind. But
they’re essential, says Ira Gooch, a program coordinator at Bridge Over Troubled Water, a shelter for homeless youth in
downtown Boston. “We’re dealing with a real sock shortage,” he notes. “We’re not allowed to accept used socks. And when
you’re homeless, socks are a really big deal.”
Socks are an afterthought to most people, but they are the most requested item at homeless shelters. Gooch explains that
when you’re homeless, your socks wear out easily, since you’re walking a lot. It’s hard to keep your socks clean because
you don’t have easy access to a washing machine. As a result, many people on the street develop foot problems. “We see
cases of frostbite in the winter,” he says. “Kids come in with blisters and bleeding feet, athlete’s foot, and other infections.
It’s not pretty.”
https://www.fastcompany.com/40445016/how-one-sock-brand-is-helping-startups-step-up-their-social-good-game
5/11/2018 Case 1:18-cv-04412 Document 1-8 Filed 05/17/18 Page 3 of 8
In 2013, entrepreneurs Randy Goldberg and David Heath stumbled across a Facebook post that mentioned a serious need
for socks at homeless shelters around the country. They decided to launch a sock company called Bombas that would
follow the one-for-one model pioneered by the shoe brand Toms and adopted by brands like Warby Parker. Bombas has
worked hard to develop a line of premium, high-tech, fashionable socks, between $12 and $18, that customers would want
to buy. Some of Bombas’s best-selling socks are dapper polka-dot dress socks for men and pastel color-block crew socks
for women. Four years later, they have sold–and donated–nearly four million pairs.
Last week, when I visited Bridge Over Troubled Water, three employees from the Bombas headquarters in New York had
come to donate socks. While the brand sends thousands of socks to 750 organizations around the country, they
https://www.fastcompany.com/40445016/how-one-sock-brand-is-helping-startups-step-up-their-social-good-game
5/11/2018 Case 1:18-cv-04412 Document 1-8 Filed 05/17/18 Page 4 of 8
occasionally drop them off in person. “It’s a great way for us to bond as a team,” says Emily Hofstetter, who was employee
number three at Bombas and is now the brand’s head of communications. “We also think it’s really important to connect
with the people we are serving as a company, because it reminds us about our mission.”
The Bombas team has come with a big bag of socks, but they’ve also come with a picnic. Fifty young people are expected
to show up for a special lunch prepared by Bombas, so the team spends two hours cutting up watermelon, laying out lunch
meats, and cutting up tomatoes and lettuce leaves. Kelly Cobb, Bombas’s VP of community and giving, has spent the
weekend baking cupcakes with her mother for this event.
At noon, young people begin streaming into the shelter’s games room. The Bombas employees form a line to serve them
deli-style, making individual sandwiches to their specifications. “Dijon or honey mustard?” Cobb asks one young man. They
spend a minute discussing the merits of each and he settles on the Dijon. “Good choice,” she says.
Hofstetter says that these interactions have helped Bombas better serve the homeless. It was through the feedback they
received from the community that they decided to reengineer the socks they would donate to the homeless. “At first, we
firmly believed that those experiencing homelessness deserved the same exact socks that we sell to our customers,”
Hofstetter says. “But then it became clear that the homeless community have different needs, so our regular collection
wasn’t serving them well.”
https://www.fastcompany.com/40445016/how-one-sock-brand-is-helping-startups-step-up-their-social-good-game
5/11/2018 Case 1:18-cv-04412 Document 1-8 Filed 05/17/18 Page 5 of 8
While regular Bombas socks have a special seam that eliminates the bump at the toe, for added comfort, the donation
socks have a reinforced seam to make them more durable. The socks are treated with anti-microbial technology, so they
don’t need to be washed as frequently and deter fungus. Also, these donation socks only come in black, which is more
stain resistant. “We know we’re not solving the problem of homelessness with what we do,” says Cobb says. “But our goal
is to solve an immediate need. And right now, that need is socks.”
But Hofstetter points out that these visits are also reinvigorating to employees, since it puts a face to the people they are
trying to help with their business. It also gives meaning to their everyday tasks–like making spreadsheets and calling
suppliers–when they return to the office.
Now, Bombas is trying to pave the way for other companies to have in-person giving experiences. Bombas is uniquely
equipped to do this, since it has built relationships with homeless shelters and the nonprofit sector. Many companies have
time and funds set aside for employees to contribute to charitable causes, but it can be hard to know exactly
how. “Whenever we talk to other companies, they always say they want to increase their social good initiatives, they just
don’t know where to start,” Hofstetter says.
https://www.fastcompany.com/40445016/how-one-sock-brand-is-helping-startups-step-up-their-social-good-game
5/11/2018 Case 1:18-cv-04412 Document 1-8 Filed 05/17/18 Page 6 of 8
01:32
This year, Bombas has been creating ways for other brands to dip their toe into the world of social good. In February, they
created an event called “60K day,” which was based on the concept than on any given night, 60,000 people in New York
end up at a homeless shelter. The plan was to bring individuals from 60 of New York’s hottest companies to visit a shelter
and hand out 60,000 socks. Among the brands that showed up were startups like Birchbox, Thinx, Kind, Casper,
Classpass, Harry’s, Maple, and Spring, among more established brands like Gap, LinkedIn, Shake Shack, and Kenneth
Cole.
For people who haven’t interacted with vulnerable communities before, the process can seem daunting. Bombas helped
bridge this gap by offering some guidelines about how to chat with people experiencing homelessness. For instance, it is
https://www.fastcompany.com/40445016/how-one-sock-brand-is-helping-startups-step-up-their-social-good-game
5/11/2018 Case 1:18-cv-04412 Document 1-8 Filed 05/17/18 Page 7 of 8
important to be warm and friendly in conversations, but it is best not to ask where someone is from, since this might be a
painful issue for them to talk about.
“The goal was to make it really easy for them to participate in the sock donations,” Hofstetter explained. “But it was
also about starting a broader conversation about homelessness, and providing a model for these companies to replicate
about how to get involved with their communities.”
The event was a big success. Employees from the various brands mingled and felt a sense of community, but it
also spurred conversations about how each company can use their own particular areas of strength to contribute in their
own unique ways. Birchbox, for instance, has been donating boxes of beauty products–from shampoo to nail polish–to
homeless women. Harry’s has been donating razors to people in need and funding charities that serve veterans. Shake
Shack has been enlisting its staff to donate food to the hungry after work. These discussions spurred other, less socially
involved brands to consider how they can help.
.r:rn:I .r m
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......
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This summer, Bombas launched another program called “Skip Day,” where it invites New York-based companies to take
advantage of Summer Fridays and flexible summer hours to volunteer to serve the homeless community. Bombas makes it
easy for individuals at companies to jump right into the work. Employees from different companies can gather and
assemble bags of products that the homeless need to get through the hot summer months, such as cold bottles of water,
ice pops, and wipes. They then go out into the streets to hand these out.
Right now, all of these programs are taking place in New York, where Bombas is based. But soon, Bombas wants to bring
this model to other cities around the country.
“We don’t want Skip Day to be a one-off chance for people to help,” Hofstetter says. “We’re trying to lay a foundation so
that they feel comfortable continuing to do this work on their own. There is so much need, we need all hands on deck.”
https://www.fastcompany.com/40445016/how-one-sock-brand-is-helping-startups-step-up-their-social-good-game
5/11/2018 Case 1:18-cv-04412 Document 1-8 Filed 05/17/18 Page 8 of 8
ABOUT THE AUTHOR
Elizabeth Segran, Ph.D., is a staff writer at Fast Company. She lives in Cambridge, Massachusetts. More
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EXHIBIT J
Title : Stea lth Socks : Covertly Fresh, Impeccably Sty led by Maison ImpeccableCase - Kickstarter
1:18-cv-04412 Document 1-10 Filed 05/17/18 Page 2 of 14
Link: https ://www. kicksta rter.com/ proj ects/ 708442929/ stea lth-socks-covertl y-fresh-i mpecca bly-styled
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l x Covert Travel Kit
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Retail value: $32
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world
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Case 1:18-cv-04412 Document 1-10 Filed 05/17/18 Page 3 of 14
THE Retail value: $46
BOSSROYAl
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EST IMATED DELIV ERY SHI PS TO
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Aug 2016 Anywhere in t he
- Business Insider
" A soc k t hat co u Id k eep eve n Ja m es Bo n d's f eet Aug 2016 Anywhere in t he
c ool and sweat-f ree under pre ss ure" world
THE PROBLEM
Pledge $48 or more
Rough day at work. The Agent
3x pairs of Stealth Socks
Scramble for a loomi ng dead line. Presentation to a surly manager. Gunfi re from villainous Pattern (s) of your choice
l x pair of Deodorizers
henchmen. One of t hose days.
Retail value: $81
The Pathfinder
Limited
3 17 backers
l x pair of Deodorizers
l x Covert Travel Kit
Retail value: $ 152
Inspired by the archetypa l super-spy, we 've created t he perfect sock to keep you looking
EST IMATED DELIV ERY SHI PS TO
and feel ing effort lessly cool, whether stress mea ns spreadsheets or shootouts. Throug h the
Aug 2016 Anywhere in t he
design process, we've tested every product on the market and made dozens of prototypes world
to reach t he perfect blend of features and capabilit ies. Like an ejection- seat-equipped
Limited
sports car, the Stea lt h Sock's stylishly unassum ing exterior conceals t he incred ible 216 backers
The Operator
10x pairs of Stealth Socks
Pattern (s) of your choice
Retail value: $ 230
Limited
101 backers
Pledge $149 or mo re
T h,::, 1-1!:lnrll<=>r
Case 1:18-cv-04412 Document 1-10 Filed 05/17/18 Page 4 of 14 l 0x pairs of Stealth Socks
Pattern(s) of your choice
l x pair of Deodorizers
l x Covert Travel Kit
Retail value: $267
Socks aren't the first item in our wardrobe we give EST IMATED DE LIV ERY SHI PS TO
thought to; however, they are an important part of a Aug 2016 Anywhere in t he
world
man 's clothing. Like a weak link in a chain, poor quality
socks matched with a high quality su it and shoes ri sks Limited
162 backers
weaken ing the strength of your entire presentation .
STEALTH TECH 1 D1
2x pairs of Deodorizers
2x Covert Travel Kit
Anti-Odor
•••••••
Moisture Wicking
e
Breathable Comfortable
@
Durable
Like the agents it 's designed for, the Stea lth Sock can go anywhere and do anyth ing. Sleek
and svelte, it's thin enough to fit perfectly under a handcrafted leather dress shoe, yet its
ample cushioning and performance features make it equa lly at home under boots on the trail
or sneakers and jeans off-duty.
New to the Stealth Sock fami ly are the Recon & Zero. Just in time for the campaign's end ,
these unlocked stretch goals provide the technolog ical punch of the Stealth Sock in more
casual or beach-appropriate cuts.
R E C 0 N
AVAILABLE IN BL ACK AND LIGHT GREY
z E R 0
AVAILABLE IN BLACK ANO LIGII T GIEY
Case 1:18-cv-04412 Document 1-10 Filed 05/17/18 Page 5 of 14
SMELL YA LATER
True to its na me, the Stealth Sock feat ures an unmatched abil ity to remain undetectably
fresh, even after mu ltiple wea rs and heavy use. How is t hat possible? Well:
0 0 0 0 0
0 0 0 0
0 0
ODOR PARTICLES
Sweat itself doesn't smell, but the microbes on our skin do.
r,,
lUH~ RESULT
,
A unique, dual-;.threat approach to odor management
that resi~Js bacteria up to 5X better than normal socks
Stealth Sock silver fabric works by keeping bacteria, t he real odor culprits, in chec k at
healthy skin levels; w ithout it, t hey grow uncontrollably lead ing to that locker-room smell.
Untreated fabric
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0 2 3 5
Elapsed Time (hr)
•1so 20743 Test Method
so go ahead, wear ·em again if the situation ca lls for it. Pack a little lighter for that trip. w e
won't tell - and nobody else can.
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Stealth SOCKS wfck moist! : 2x faster than merino wool
'["T T , -
-.s_ocks and 4x faster than regular cotton/poly socks
thanksJo carbon - infused fi6ers and terry loop~ack fabric
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To prove the Stealth Sock's performance, we had samples tested at a 3rd party laboratory
certified by the American Association of Textile Chem ists and Colorists.
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HEXAGONAL CUSHIONING
Targeted cushioning softens each step you take
while channeling cooling air in between
ANKLE CUSHIONING
Added cushioning offers 180° protection to
prevent rubbing and chafing at high friction
areas on the back of the ankle.
Y-STITCHED HEEL
An extended heel pocket made using a Y-stitch
method cups your foot for an ergonomic fit.
Case 1:18-cv-04412 Document 1-10 Filed 05/17/18 Page 7 of 14
The Stea lth Sock's unique fi ber blend give it a higher degree of stretch and adaptab ility t han
most other products. As a resu lt, it fits comfortably on feet from US Men's 5/ Women's 6 to
Men's 14/ Women 's 15.
Lengthwise stretch
STAY SHARP
Some brands have caught crit icism for allowing silver to leach out of t heir clothes and onto
t heir wearers. Unli ke cheaper, coated t hreads, the Stea lth Sock utilizes a po lymeric matri x
design to encapsu late t he silver in its fibers. This means t he odor-fighting ability is proven
to stay in t he sock and off your skin, all wh ile ensuring antim icrob ial effectiveness even after
100-t- washes.
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• 50 b330Test Method
When we were testing other socks on t he ma rket, nothing irritated us more t han spending
$30 on a pair with some cool technology, only for it to pill to shreds and disintegrate after
on ly a few wears. We vowed never to make t hat mistake. Besides using a naturally more
wear-resista nt fabric, we added :
POLYMER REINFORCEMENT
Polymer strengthens high-wear zones and reduces
pilling for improved longevity.
001 - NIGHTFALL
Blue and grey fibers combine in a luxurious microstripe, creating a
unique look and texture that fits in any occasion.
002 - REDACT
Our most formal and inconspicuous pattern, this rich charcoal smartly
conceals the tech in your shoes - perfect for black tie or black ops.
003 - WRAITH
This simple yet elegant light grey choice is the perfect all- season
pairing for the lighter pieces in your wardrobe.
004 - MARINER
With its rich navy hue, the Mariner is the quintessential sock - subtly
suitable with any shade of casual, business casual, or formal attire.
005 - RUGGER
Bold crimson and navy stripes bring a tastefully fun flair with this
classically preppy collegiate staple.
006 - TERRA
Stay grounded with wonderfully wide block stripes in navy and green
that are equally at home on land or sea.
007 - ROYALE
Keep your cool at the Monte Carlo or your weekly poker game with
this stylish playing card motif set against a clean grey body.
008 - NOCTURNE
This celestial pattern features deep midnight blue studded with intense
Aquamarine - a versatile look at the office or half a world away.
009 - TEMPEST
Amethyst dots provide vivid contrast against a dark grey backdrop like
the calm before a coming storm.
010 - HIGHLAND
Pack some punch with this navy argyle - descended from Scottish
tartans to become one of the most iconic patterns in the world.
Designed with versatil ity in mind, the Covert Travel Kit's zippered pockets and elastic straps
make it the perfect case for carrying and organizing your gear in any situation . Built out of
heavy-duty nylon, toss it into you r suitcase for you r next trip or use the integrated webbi ng
system to strap it into a bag or pack.
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The Deodorizer
Bu ilt with the same charcoa l carbon technology, the Deodorizer is a natura l companion to
our Stealth Socks. Coming in a two pack, the Deodorizer captures odor with a sli m and
convenient form factor, perfect for sli pping into shoes, gym bags, suitcases, or anywhere
else odors or hu mid ity aren't welcome.
Case 1:18-cv-04412 Document 1-10 Filed 05/17/18 Page 10 of 14
GET REWARDED
$25
THE QUARTERMASTER lX
1x Covert Travel Kit
Retail value: $32
$32
THE ROOKIE 2X
2x pairs of Stealth Socks
Pattem(s) of your choice
Retail value: $46
$48
THE AGENT
3x pairs of Stealth Socks
lX 3X
Pattern(s) of your choice
1x pair of Deodorizers
Retail value: $81
$74
THE PATHFINDER 5X
5x pairs of Stealth Socks
Pattern(s) of your choice
Retail value: $115
$95
THE WORK WEEK WARRIOR
5x pairs of Stealth Socks
Pattern(s) of your choice
lX lX
1x pair of Deodorizers
1x Covert Travel Kit
Retail value : $152
$135
THE OPERATOR 1Ox
1Ox pairs of Stealth Socks
Pattern(s) of your choice
0,...'"";1 u..._f, , ..... ¢?"ln
Case 1:18-cv-04412 Document 1-10 Filed 05/17/18 Page 11 of 14
$149
THE HANDLER
1Ox pairs of Stealth Socks
Pattern(s) of your choice 1X 1X
1x pair of Deodorizers
1x Covert Travel Kit
Retail value: $26 7
$249
THE DOUBLE AGENT
20x pairs of Stealth Socks 2X 2X
Pattern(s) of your choice
2x pairs of Deodorizers
2x Covert Travel Kit
Retail value: $534
Additiona l deodorizers, t ravel kits, and Stealt h Socks available as add-ons via backer survey
at t he end of t he campaign.
+ + + + +~
STRETCH GOALS
$30,000 - UNLOCKED
TEMPEST
Amethyst dots provide vivid contrast against a dark grey backdrop like
the calm before a coming storm.
$50,000 - UNLOCKED
HIGHLAND
Pack some punch with this navy argyle - descended from Scottish
tartans to become one of the most iconic patterns in the world.
$70,000 - UNLOCKED
THE STEALTH SOCK - RECON
This ankle -cut variant of the Stealth Sock packs the fiber technology
and features of the full-size version while keeping a lower profile.
$100,000- UNLOCKED
THE STEALTH SOCK - ZERO
This no-show variant of the Stealth Sock runs completely under the radar
and are perfect for loafers and boat shoes.
OUR STORY
Case 1:18-cv-04412 Document 1-10 Filed 05/17/18 Page 12 of 14
Maison Impeccable was founded in early 2015 by a few high school friends from Michigan
reu niting from coast to coast throug h a shared passion for style and a love of action flicks.
Our team spans a dive rse range of industries and experiences: business, medicine, retail,
tech, and even fi nance - all of which help to give us unique insights and perspectives into
the clothes we wear and how we can improve them.
Despite diffe ri ng backgrou nds, we all independently ended up at the same conclusion :
today's clothes sim ply aren 't as good as they should be, always forcing us to sacrifice on
one aspect or another. We' re not the first to come up with th is idea either - a ha ndfu l of
other bra nds are paving the way and doing great work. That said , when we tried what was
on the market, something always wasn't quite right. Sure, A was great, but B was all w rong .
Why didn't t hey do C and had t hey even considered D? Rather than wait for compan ies to
magica lly figure out and produce what we wanted, we decided stri ke out on our own. We
were already reading and lea rning about t his stuff obsessively in our free time, why not
make something of it?
As much work as we·ve put in over the past year and change, we wouldn 't be whe re we are
today w ithout all t he people who've helped us along t he way. Among othe rs, we'd li ke to
tha nk:
THE MISSION
Maison Impeccable is a startup ded icated to evolving garments and how we interact w ith
them. By ana lyzing clothing equally through the lenses of util ity and aesthetics, we seek to
engineer pieces that offer uncompromising pe rforma nce across all use cases. Building upon
the belief t hat each individual is the hero of their ow n life, our goal is to keep wearers
outfitted for the day's missions, wherever they may lead .
WHY KICKSTARTER
As t he common Kickstarter story goes, the t raditional model of buy-fi rst-sel l-later
manufact uring is too expensive for new brands just getting sta rted.
All orders wil l be shi pped from our fulfi ll ment warehouse in Georgia. We evaluated dozens of
companies for reputation , reliability, and experience before choosing t his critical
partner. We're proud to offer free shipping w ith in t he Un ited States for all Kickstarter
backers.
For operatives outside of t he US, shi pping will add a small fee to cover added costs. Taxes,
VAT and/ or duties aren 't included in t he prices and may be added in accordance wit h you r
local regulations.
Because pol icies around customs and duties can vary by cou nt ry, please check yours in
advance to avoid any complications down the line!
Tl MELINE
2015
JANUARY
Ml team founded
APRIL
Visited and sourced manufacturers
MAY
First Stea lth Socks desi gned
2016
FEBRUARY
Finalized prototypes
MARCH
Campaign launches
APRIL
Campaign ends
MAY
Funding received, surveys go out
JUNE
Product ion comp l ete
AUGUST
Product arr ives at fulfil lment center
SEPTEMBER
Sh ipp ing to backers comp l ete
SHARING
IN PARTNERSHIP W ITH
COM AN PARTNERS
TOP CROWDFUNDING MARKETING AGENCY
The most li kely risks have to do with timing: machine time for production , logistics time
across t he ocean, and fu lfi llment time to get into you r ha nds. We' re keeping our partners in
those fields ready and w ill continue to do so throughout t he campaign so we should be
ready to go .
Beyond that, we don't see any direct risks or challenges, but the path to get here frequently
rem inded us t hat life always has a few su rprises in store. Our diverse backgrounds and
experiences will help us ma nage whatever might pop up , and counter to our otherwise
clandestine ways, we promise to run this campaign with clear communication and fu ll
transparency.
Arts Comics & Illustration Design & Tech Film Food & Craft Games Music Publishing
EXHIBIT K
Title: Ma,is.on Impeccable I Effortles.s., Eng inee red. Case 1:18-cv-04412 Document 1-11 Filed 05/17/18 Page 2 of 4
e
Link : https.://www. impeccab le.mais.an/
MISSION
Maison Impeccable is dedicated to evolving garments and how we interact with them. By analyzing clothing through
the lenses of utility and aesthetics, we engineer pieces that offer uncompromising performance -
keeping users outfitted for life's journeys, wherever they may lead.
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Case 1:18-cv-04412 Document 1-11 Filed 05/17/18 Page 3 of 4
S_HOP NOW
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"Stealth Socks .. These socks are ... These socks make A sock that cou ld keep
ach ieve the impossible; a step or t en above whatever you have on even James Bond's
[it] fits wel l and won't everyt hing else in now look sad in feet cool and sweat-
develop a fou l odor'' your top drawer comparison free under pressure
BUSINESS
INS IDER GEAR PATROL !!!CONSUMPTION
#STAYIMPECCABLE
BUSINESS
INSIDER
!!!CONSUMPTION GEAR PATROL EVERYDAY CARRY THE MANUAL
© MAISON IMPECCABLE 2017. ENGINEERED IN LOS ANGELES. CALlf=ORNIA. PRIVACY PO L ICY TERMS OF SERV I CE
Case 1:18-cv-04412 Document 1-11 Filed 05/17/18 Page 4 of 4
EXHIBIT L
Title: Products - Maison Impeccable Case 1:18-cv-04412 Document 1-12 Filed 05/17/18 Page 2 of 4
Link: https://www.impeccable.maison/co llections/all
PR 0DUCTS
1
...
COV ER T T RA V EL K IT - ONE SIZE DEODORIZERS - ONE SI ZE T HE ST EA LTH SOCK - NIGHTFA LL
•
$21 .00 $8 .00 $16.00
T HE STEA LTH SOCK - W RA IT H T H E ST EALTH SOCK - ROY ALE TH E STEA LT H SOCK - T EM PEST
•• ••
$16.00 $16.00 $16.00
16 reviews 16 rev iews
** 16 reviews
TH E ST EALTH SOCK - H IGHLA ND T HE STEA LTH SOCK PRO T OTYP E - ONE SIZ E T H E ST EALT H SOCK RECON - L/ Xl
•• •
$16.00 $10.00 $14.00
16 rev iews 8 reviews
Case 1:18-cv-04412 Document 1-12 Filed 05/17/18 Page 3 of 4
..
THE STEALT H SOCK RECON - L/ XL TH E STEA LT H SOCK RECON - L/ XL T HE STEA LT H SOCK RECON - L/ XL
•
$14.00 $14.00 $14.00
T HE STEALT H SOCK RECON - L/ XL THE ST EALT H SOCK RECON - L/ XL T HE STE ALTH SOCK RECON - S/ M
•
$14.00 $7 4.00 $7 4.00
* 8 rev iews
* 8 reviews 8 reviews
THE STEALTH SOCK RECON - S/M T HE ST EALTH SOCK RECON - S/ M THE ST EALTH SOCK RECON - S/ M
•
$14.00 $14.00 $14.00
*
8 rev iews
* 8 reviews 8 reviews
THE STEALTH SOCK RECON - S/ M T HE ST EALTH SOCK RECON - S/ M T HE STEALTH SOCK ZERO - J ET BLACK
• •
$14 ..QO $7 4.00 $12.00
8 reviews
* 8 reviews 2 reviews
THE STEALT H SOCK ZERO - PHAN TOM GREY THE STE ALTH SOCK ZERO - SAHARA KHAK I
•
$12.00 $12.00
2 rev iews 2 rev iews
Case 1:18-cv-04412 Document 1-12 Filed 05/17/18 Page 4 of 4
~, MAISON IMPECCABLE ;,_017. ENGINEERED IN LOS ANG!:LES, CALIFORNI.<'>. "illV~.,:v <'0'..IC'i •ERM5 OF Se:R\'lr_:E
- PayPal