deadline - wordpress.com · 22 23. in july 2011, universal began distributing a poster for the...

Case 2:12-cv-03454-R-PJW Document 1 Filed 04/20/12 of 54 Page ID #:5

DEADLINE.co

m


DEADLINE.co

m

1 20. The Film was released theatrically in the United Kingdom on April

2 13, 2012, and is scheduled for theatrical release in the United States on May 18,

3 2012. In anticipation of Battleship's theatrical release, Universal has invested

4 extensive amounts of money, time and effort in promoting and marketing the Film

5 in the United States and around the world.

6 21. Universal began its worldwide advertising and promotional campaign

7 for the Film more than nine months ago. As a result of these efforts, the movie-

8 going public has come to associate the title Battleship, as well as the Film's

9 distinctive and widely-disseminated title design and artwork, with Universal as the

10 source of the Film.

11 22. Since at least July 2011, Universal has continuously used a distinctive

12 title design (the "Battleship Title Design") in promoting and advertising the Film.

13 The Battleship Title Design is shown below and includes the all-capital-letters title

14 "BATTLESHIP" in a beveled, stencil-like font, characterized by a steely-gray

15 color and the use of a gradient (also known as a color ramp or color progression)

16 across the steely-gray color scheme:

17

18

19

20

21

22 23. In July 2011, Universal began distributing a poster for the Film, the

23 Battleship One-Sheet Teaser, for display in theater lobbies throughout the United

24 States. The Battleship One-Sheet Teaser showed the title of the Film using the

25 Battleship Title Design. A copy of the Battleship One-Sheet Teaser is shown

26 below and also is attached as Exhibit A.

~ ~ --~ nn-=l(l-, " --, -,' 1-1 '-, -I / " :~' ,. i' - '1 i i, ! ,', ,'~ , L L - L Imi ~í!YI;L f I~ I;~~ IJ l.~. ~nJ t! ¡~ ',~I _.::" ~.,/ l1~ ~

27

28

-6-COMPLAINT


DEADLINE.co

m


DEADLINE.co

m

deadline - wordpress.com · 22 23. in july 2011, universal began distributing a poster for the...

Documents