jat wheels v. jnc wheel - am. compl

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Multiple Documents Part Description 1 16 pages 2 Exhibit A-C JAT Wheels Inc v. JNC Wheel Collection et al, Docket No. 2:14-cv-04898 (C.D. Cal. Jun 24, 2014), Court Docket © 2014 The Bureau of National Affairs, Inc. All Rights Reserved. Terms of Service // PAGE 1

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JAT Wheels v. JNC Wheel - Am. Compl.

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Page 1: JAT Wheels v. JNC Wheel - Am. Compl

Multiple DocumentsPart Description1 16 pages2 Exhibit A-C

JAT Wheels Inc v. JNC Wheel Collection et al, Docket No. 2:14-cv-04898 (C.D. Cal. Jun 24, 2014), Court Docket

© 2014 The Bureau of National Affairs, Inc. All Rights Reserved. Terms of Service // PAGE 1

Page 2: JAT Wheels v. JNC Wheel - Am. Compl

JAT WHEELS INC.’S FIRST AMENDED COMPLAINT

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Yang & Wang, P.C. Tommy SF Wang SBN: 272409 Andrew J. Wei SBN: 293787 355 S. Grand Ave., Ste. #2450 Los Angeles, CA 90071 Telephone: (888) 827-8880 Fax: (888) 827-8880 Email: [email protected]; [email protected] Attorneys for Plaintiff JAT Wheels, Inc.

UNITED STATES DISTRICT COURT

CENTRAL DISTRICT OF CALIFORNIA JAT Wheels, Inc., a California Corporation d/b/a/ STR Racing,

Plaintiff, vs. JNC Wheel Collection; and DOES 1-10, collectively, Defendant.

) ) ) ) ) ) ) ) ) ) ) ) ) ) )) ) ) ) ) ) ) ) ) ) ) ) ) ) )

Case No.: CV 14-04898 JVS (MRWx) FIRST AMENDED COMPLAINT FOR:

1. FALSE DESIGNATION OF

ORIGIN [15 U.S.C. §1125(a)/Lanham Act §43(a)];

2. FEDERAL TRADEMARK DILUTION [15 U.S.C. §1125(c)];

3. FEDERAL COPYRIGHT INFRINGEMENT [17 U.S.C. 106];

4. FEDERAL UNFAIR COMPETITION [15 U.S.C. §1125(a)];

5. CALIFORNIA COMMON LAW UNFAIR COMPETITION; and

6. CALIFORNIA UNFAIR COMPETITION (CALIFORNIA BUSINESS & PROFESSIONS CODES §17200, et. seq.]

DEMAND FOR JURY TRIAL

Case 2:14-cv-04898-JVS-MRW Document 24 Filed 09/22/14 Page 1 of 16 Page ID #:437

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JAT WHEELS INC.’S FIRST AMENDED COMPLAINT

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Plaintiff, JAT WHEELS, Inc. a California Corporation, d/b/a/ STR Racing

(hereinafter “Plaintiff”), hereby files this Complaint against Defendant JNC

WHEEL COLLECTION (hereinafter “Defendant”), and DOES 1 to 10, and alleges

as follows:

INTRODUCTION

1. Plaintiff files this action to combat the willful sale of unlicensed and

counterfeit products (hereinafter “Infringing Products”) bearing the

Plaintiff‘s exclusive Trademark, and unauthorized use of Plaintiff’s

copyrighted photographs. The Defendant is a corporation specializing in

the research, manufacture and sales of aftermarket automobile wheels.

2. Plaintiff seeks a Permanent Injunction, damages, costs, and attorneys’ fees

as authorized by the Lanham Act, California’s common law, and

California Business & Professions Code.

JURISDICTION AND VENUE

3. This Court has subject matter jurisdiction under 28 U.S.C. § 1331 (federal

question) and 28 U.S.C. § 1338(a) (action arising under an Act of

Congress relating to trademarks).

4. The Court has personal jurisdiction over Defendant since Defendant has

committed acts of trademark infringement and unfair competition in this

district and/or Defendant has sufficient minimum contacts with this

district to such that the exercise of jurisdiction over Defendant by this

Court does not offend traditional notions of fair play and substantial

justice. Among other things, Defendant has advertised, offered to sell and

sold products that infringe Plaintiff’s Trademark rights to consumers

within this judicial district, knowing or having reason to know that

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JAT WHEELS INC.’S FIRST AMENDED COMPLAINT

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consumers, including those within this judicial district, would purchase

said goods from Defendant, believing that they were authentic goods

produced by and/or associated with Plaintiff or its authorized licensees.

5. Further, this Court has jurisdiction over Plaintiff’s California state

statutory and common law claims pursuant to 28 U.S.C. § 1367.

6. Supplemental jurisdiction exists over Defendant because on information

and belief, Defendant conducts business in California and in this judicial

district, has purposefully availed itself to California and in this judicial

district, or has otherwise availed itself of the privileges and protections of

the law of the State of California, such that this Court’s assertion of

jurisdiction over Defendant does not offend traditional notions of fair play

and due process.

7. Venue is proper within the Central District of California pursuant to 28

U.S.C. §§ 1391(b) and 1400(a) because on information and belief, a

substantial part of the events or omissions giving rise to the claim

occurred in this judicial district, and has caused damages to Plaintiff in

this district.

THE PARTIES

8. Plaintiff, JAT WHEELS, INC., d/b/a/ STR Racing, is a California

corporation duly organized and existing under the laws of the State of

California, and whose office is located at address 2107-D W.

Commonwealth Ave. #392, Alhambra, California 91803.

9. Upon information and belief, Defendant, JNC WHEELS COLLECTION,

is, and at all times mentioned herein was, a corporation organized and

Case 2:14-cv-04898-JVS-MRW Document 24 Filed 09/22/14 Page 3 of 16 Page ID #:439

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existing under the laws of the State of California, having its principal

place of business at 4525 Whittier Blvd, Los Angeles CA 90022.

10. The true names and capacities, whether individual, corporate, associate or

otherwise, of Defendants herein named DOES 1-10, inclusive are

unknown to Plaintiff. Plaintiff therefore sues said Defendants by such

fictitious names. When the true names and capacities of said Defendants

have been ascertained, Plaintiff will amend this pleading accordingly.

11. Plaintiff further alleges that Defendant and DOES 1-10, inclusive sued

herein by fictitious names are jointly, severally and concurrently liable

and responsible with the named Defendant upon the causes of action

hereinafter set forth.

12. Plaintiff is informed and believes and thereon alleges that at all times

mentioned herein Defendant, and DOES 1-10, inclusive, and each of

them, were the agents, servants, and employees of every other Defendant

and the acts of each Defendant, as alleged herein, were performed within

the course and scope of that agency, service or employment.

FACTS

13. Plaintiff is an automobile wheel designer, manufacturer and distributor.

Plaintiff has been distributing its wheels under the name STR Racing

since its formation in 2012.

14. Upon information and belief, Defendant is an automobile wheel

distributor.

15. Plaintiff owns and holds the exclusive rights, title, and interest to market

and sell merchandise bearing the STR Trademark (the “STR Trademark”

or “Trademark”). Plaintiff applied for a trademark registration on April

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JAT WHEELS INC.’S FIRST AMENDED COMPLAINT

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18, 2014 with the United States Patent and Trademark Office. The STR

Trademark Serial Number is 86256705. (Exhibit A). One of Plaintiff’s

most popular and best selling wheels is the STR 513.

16. In or around May 2014, Plaintiff discovered that Defendant was selling

automobile wheels on the Internet that bore a remarkable similarity to

products that Plaintiff designed, manufactured and sold. Some of these

wheels also bore Plaintiff’s STR Trademark, or were promoted and sold

using Plaintiff’s STR Trademark.

17. Without Plaintiff’s consent, Defendant used the STR Trademark in

connection with its aftermarket automobile parts that are in direct

competition with Plaintiff’s aftermarket automobile parts. Defendant has

used Plaintiff’s trademark in its advertising for such products and

services, thereby competing unfairly with Plaintiff, infringing upon

Plaintiff’s trademark rights, and improperly trading on the goodwill

established by Plaintiff. (Exhibit B).

18. In or around April 2014, Plaintiff published photographs to its website

displaying its aftermarket automobile parts. (Exhibit C). Plaintiff owns

the copyrights and ownership rights to these photographs, and has filed for

a copyright registration for these photographs. The Copyright

Registration Service request number is 1-1766525611.

19. Without Plaintiff’s consent, Defendant sporadically, but consistently,

used Plaintiff’s copyrighted images to promote and sell the Infringing

Products on Defendant’s website.

20. Defendant’s infringing activities have caused damages to Plaintiff by

causing customer confusion as to the source of the STR Trademark. In

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addition, Defendant’s use of the aforementioned STR Trademark has and

continues to dilute Plaintiff’s goodwill in its products and business that it

has invested significant time and resources.

21. On information and belief, Defendant’s use of Plaintiff’s trademark is

willful and deliberate, therefore entitling Plaintiff to enhanced damages

and reasonable attorney fees and costs.

22. On information and belief, Defendant intends to continue their unlawful

activity, and Plaintiff continues to and will continue to suffer irreparable

harm—for which there is no adequate remedy at law—unless Defendant is

enjoined by this Court.

COUNT I- FALSE DESIGNATION OF ORIGIN [15 U.S.C.

§ 1125(a)/Lanham Act §43(a)]

23. Plaintiff repeats and re-alleges, as set forth herein, the allegations

contained in paragraphs 1 through 22 and brings the following claim for

false designation of origin pursuant to 15 U.S.C. § 1125(a) and the

Lanham Act § 43(a) against the Defendant.

24. Defendant has used Plaintiff’s STR Trademark in commerce in

connection with its own goods, where use is likely to cause confusion, or

to cause mistake, or to deceive as to the origin, sponsorship, association or

approval of such goods.

25. By utilizing the Plaintiff’s Trademark in its advertising for, and in

connection with its products, Defendant has misrepresented and falsely

described to the general public the origin and the source of the products

offered for sale. Further, it creates a likelihood of confusion, mistake or

deception to the ultimate purchaser as to the source of the products.

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26. For example, Defendant markets, conducts business, and publicly

represents that the STR Trademark is associated or connected to the

Defendant’s business thereby creating a false designation of origin of

Plaintiff’s brand of goods and services. (Exhibit B).

27. The confusion, mistake, or deception referred to herein arises out of the

aforementioned acts of Defendant and the acts of the Defendant constitute

false designation of origin and unfair competition in violation of 15

U.S.C. § 1125(a) and Section 43(a) of the Lanham Act.

28. Upon information and belief, the aforementioned acts of the Defendant

were undertaken willfully with the intention of causing confusion, mistake

or deception. Plaintiff is entitled, pursuant to 15 U.S.C. § 1117, to

recovery of: (1) Defendant’s profits; (2) Plaintiff’s damages, including

lost profits; and (3) costs of the action. Plaintiff is further entitled to treble

damages above the amount of actual damages in a sum not more than

three times the amount of actual damages. Defendant’s intentional and

deceitful actions make this a case in which the Plaintiff is entitled to an

award of attorneys’ fees.

29. By reason of the aforementioned acts by Defendant, Plaintiff has suffered

and will continue to suffer irreparable damage, in an amount to be

determined, which damage will continue unless and until enjoined by

Order of this Court.

COUNT II- FEDERAL TRADEMARK DILUTION [15 U.S.C. §1125(c)]

30. Plaintiff repeats and re-alleges, as if set forth herein, the allegations

contained in paragraphs 1 through 29 and brings the following claim for

trademark dilution pursuant to 15 U.S.C. § 1125(c) against the Defendant.

Case 2:14-cv-04898-JVS-MRW Document 24 Filed 09/22/14 Page 7 of 16 Page ID #:443

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31. Plaintiff’s STR Trademark is distinctive, well known and famous.

32. Defendant is diluting the distinctiveness of Plaintiff’s STR Trademark by

marketing and selling inferior goods bearing marks virtually identical or

confusingly similar to Plaintiff’s STR Trademark. Upon information and

belief, Defendant has engaged in the conduct alleged in these claims,

willfully intending to trade on Plaintiff’s reputation and/or to cause

dilution of the reputable and distinctive Trademark owned by Plaintiff.

33. Defendant markets, conducts business, and publicly represents that the

Trademark is associated or connected to the Defendant’s business thereby

creating a false designation of origin of Plaintiff’s’ brand of goods and

services. Thus, Defendant’s acts violate 15 U.S.C. §1125(c).

34. As a direct and proximate result of Defendant’s trademark dilution,

Plaintiff has and will continue to suffer damages to its business, reputation

and good will, and the loss of royalties and profits that Plaintiff would

have made but for Defendant’s acts. Upon information and belief,

Defendant’s acts of infringement have also resulted in substantial profits

for the Defendant. The amount of these damages will be proven at trial.

COUNT III-FEDERAL COPYRIGHT INFRINGEMENT

35. Plaintiff repeats and re-alleges, as set forth herein, the allegations

contained in paragraphs 1 through 34.

36. Plaintiffs were and are the exclusive holder of all rights, title and interest

in their photographs, as separate and distinct works.

37. Defendant has infringed and is infringing the copyrighted photographs by

unlawfully reproducing and using such photographs in violation of the

United States Copyright Act, 17 U.S.C. 106.

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38. Defendant’s infringement was and is willful, in bad faith, and executed

with full knowledge of Plaintiff’s copyright, and in conscious disregard

for Plaintiff’s exclusive rights in the protected work.

39. Defendant’s deliberate infringement of Plaintiff’s copyrights has greatly

and irreparably damaged Plaintiff.

40. Defendant’s production of infringing products and copyrighted material,

and Defendant’s wrongful conduct, have deprived and continue to deprive

the Plaintiff of their opportunity of expanding their goodwill. Plaintiff is

entitled to an injunction restraining Defendant, its officers, agents, and

employees, and all persons acting in concert with it, from engaging in any

further acts in violation of the copyright laws.

41. Plaintiff is further entitled to recover the damages, including attorneys’

fees, they have sustained and will sustain, and any gains, profits, and

advantages obtained by Defendant as a result of Defendant’s acts of

infringement alleged above. At present, the amount of such damages,

gains, profits, are in an amount to be determined.

COUNT IV-FEDERAL UNFAIR COMPETITION [15 U.S.C. §1125(a)]

42. Plaintiff repeats and re-alleges, as set forth herein, the allegations

contained in paragraphs 1 through 41 and brings the following claim for

unfair competition pursuant to 15 U.S.C. § 1125(a) against the Defendant.

43. As a direct result of the Plaintiff’s longstanding use, sales, advertising,

and marketing, Plaintiff’s STR Trademark has acquired a secondary and

distinctive meaning among the public who have come to identify

Plaintiff’s STR Trademark with the Plaintiff and its respective products.

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44. Plaintiff is informed and believes that thereon alleges that as early as May

of 2014, Defendant has infringed Plaintiff’s Trademark rights by

marketing and selling goods bearing marks virtually identical or

confusingly similar to the recognized and distinctive STR Trademark,

owned by Plaintiff.

45. The Infringing Products and related merchandise that the Defendant has

sold and distributed duplicates and appropriates Plaintiff’s Trademark and

deludes and confuses the public into believing that the Plaintiff approved,

authorized, or sponsored the products and related merchandise sold,

offered for sale, or distributed by the Defendant.

46. Defendant, by misappropriating and using the likenesses of Plaintiff’s

Trademark in connection with the sale of products and related

merchandise, is misrepresenting and will continue to misrepresent and

falsely describe to the general public the origin and sponsorship of their

products. Defendant has caused such products to enter into interstate

commerce willfully with full knowledge of the falsity of the designation

of their origin and description and representation in an effort to mislead

the purchasing public into believing that their products are authorized or

emanate from the Plaintiff.

47. Defendant’s actions, as alleged herein, were and are likely to deceive the

consuming public and therefore constitute unfair and fraudulent business

practices in violation of 15 U.S.C. §1125(a).

48. Defendant’s unlawful, unfair, and fraudulent business practices described

above present a continuing threat to members of the public in that they are

likely to be deceived by the origin and quality of Plaintiff’s products.

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49. Upon information and belief, Defendant’s acts of unfair competition have

resulted in substantial profits for the Defendant in an amount to be

determined. Defendant’s acts of unfair competition have also resulted in

damages to Plaintiff by causing a diversion of sales from Plaintiff to

Defendant, lost royalties and other damages resulting from irreparable

harm to Plaintiff’s goodwill. The exact amount of Plaintiff’s damages is to

be determined.

50. Plaintiff has also incurred costs and attorneys’ fees to bring this action.

51. Defendant’s conduct has caused and will continue to cause irreparable

injury to Plaintiff unless permanently enjoined.

COUNT V- CALIFORNIA COMMON LAW UNFAIR COMPETITION

52. Plaintiff repeats and re-alleges, as set forth herein, the allegations

contained in paragraphs 1 through 51 and brings the following claim for

unfair competition pursuant to California’s common law against the

Defendant.

53. The Court has jurisdiction over this Cause pursuant to 28 U.S.C. § 1367.

54. By Defendant’s acts alleged herein, the Defendant has engaged in unfair

competition under the common law of the State of California.

55. Defendant has distributed and sold Infringing Products displaying the

Trademark of the Plaintiff in California, thereby creating a false

designation of origin of Plaintiff’s brand of goods and unfairly competing

with Plaintiff’s business.

56. Upon information and belief, Defendant has knowingly and willfully

misappropriated Plaintiff’s Trademark in an effort to create the impression

that the Defendant’s counterfeit products are sanctioned by the Plaintiff

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and to misappropriate the goodwill associated with Plaintiff’s Trademark,

entitling Plaintiff to an award of exemplary damages and attorneys’ fees.

57. The aforesaid acts of the Defendant have caused damage to Plaintiff, in

an amount to be determined.

58. By reason of the acts of the Defendants alleged herein, Plaintiff has

suffered, is suffering and will continue to suffer irreparable damage,

which damage will continue unless enjoined by Order of this Court.

COUNT VI- UNFAIR COMPETITION UNDER CALIFORNIA

BUSINESS & PROFESSIONS CODE §17200, et. seq.

59. Plaintiff repeats and re-alleges, as set forth herein, the allegations

contained in paragraphs 1 through 58 and brings the following claim for

unfair competition pursuant to California Business and Professions Code

§17200.

60. The Court has jurisdiction over this Cause pursuant to 26 U.S.C. § 1367.

61. By acts complained of herein, Defendant has engaged in unfair

competition under Section 17200 of the Business and Professions Code of

the State of California.

62. Defendant’s use of the infringing mark complained of herein constitutes

deceptive and misleading advertising and is likely to, and is intended to,

cause confusion to the purchasers and potential purchasers of the

products.

63. Defendant markets, conducts business, and publicly represents that the

Plaintiff’s STR Trademark is associated or connected to the Defendant’s

business and thus creates a false designation of origin of Plaintiff’s brand

of goods and services.

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64. Upon information and belief, the aforesaid acts of Defendant was

undertaken willfully and with the intention of causing confusion, mistake

and deception, entitling the Plaintiff to an award of exemplary damages

and attorneys’ fees.

65. The aforesaid acts of Defendant have caused damage to Plaintiff in an

amount to be determined.

66. By reason of the acts of the Defendant alleged herein, Plaintiff has

suffered injury in fact and has lost money or property as a result of

Defendant’s acts of unfair business practices alleged herein, is suffering

and will continue to suffer irreparable damage, which irreparable damage

will continue unless enjoined by Order of this Court.

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PRAYER FOR RELIEF

WHEREFORE, Plaintiff demands entry of a judgment against the Defendant as

follows:

1. The Defendant, its officers, agents, servants, employees, attorneys, and

all those in active concert or participation with them be enjoined and

restrained:

a. From further using Plaintiff’s STR Trademark or any other

confusingly similar mark, in connection with the manufacture,

sale, advertisement or promotion of any product or any other

similar infringement of Plaintiff’s Trademark rights, for products

not originating from Plaintiff or authorized by Plaintiff;

b. From diluting any of Plaintiff’s Trademark or any other

confusingly similar mark;

c. From using Plaintiff’s copyrighted works of art;

d. From engaging in unfair competition by making and selling its

products or otherwise using confusingly similar marks and designs,

in such a way as to misrepresent the origin of any of the

Defendant’s products;

2. For an order requiring Defendant to deliver and be impounded during the

pendency of this action all material in Defendant’s possession, custody or

control that include or incorporate products that infringe Plaintiff’s STR

Trademark rights, including but not limited to, any containers, packages,

labels and advertisements in their possession or under their control

bearing any of Plaintiff’s STR Trademark, or any simulation,

reproduction, counterfeit, copy, or colorable imitation thereof;

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3. Directing that the Defendant report to this Court within thirty (30) days

after a Permanent Injunction is entered to show its compliance with

paragraphs 1 and 2 above;

4. For compensatory damages in an amount to be proven at trial;

5. For all gains, profits and advantages derived by Defendant by its

infringement of Plaintiff’s trademark rights;

6. For punitive damages in an amount sufficient to punish Defendant for its

wrongful conduct and to deter others from engaging in similar conduct in

the future;

7. For statutory damages as provided by law;

8. For permanent injunction against Defendant, preventing Defendant from

any future usage of any identical or similarly confusing marks related to

Plaintiff’s Trademark;

9. Directing such other relief as the Court may deem appropriate to prevent

the trade and public, or individual members thereof, from gaining the

erroneous impression that the Plaintiff authorized or approved any

products manufactured, sold, or otherwise circulated or promoted by the

Defendant or that such products are in any way related to the Plaintiff;

10. For a judgment declaring that this case is exceptional and awarding to

the Plaintiff from the Defendant, as a result of the Defendant’s sale of

Infringing Products bearing the Plaintiff’s STR Trademark, three times

the Plaintiff’s damages and three times the Defendant’s profits, after an

accounting, or statutory damages, should the Plaintiff opt for such relief,

consisting of Five Hundred Thousand Dollars ($500,000.00) for each of

the Plaintiff’s Trademarks infringed upon by the Defendant, and to the

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extent this Court concludes such infringement was willful, Five Million

Dollars ($5,000,000.00) for the Plaintiff’s STR Trademark infringed

upon by the Defendant pursuant to 15 U.S.C. § 1114 and § 1117;

11. Awarding to the Plaintiff its reasonable attorneys’ fees and investigative

fees pursuant to 15 U.S.C. § 1117;

12. Awarding to the Plaintiff its costs in bringing this action; and

13. Awarding other such relief to the Plaintiff as this Court deems just.

DATE: September 22, 2014 BY:

________________________/S/ Tommy SF Wang Yang & Wang P.C.

Attorney for Plaintiff JAT Wheels, Inc.

Case 2:14-cv-04898-JVS-MRW Document 24 Filed 09/22/14 Page 16 of 16 Page ID #:452

Page 18: JAT Wheels v. JNC Wheel - Am. Compl

EXHIBIT A

Case 2:14-cv-04898-JVS-MRW Document 24-1 Filed 09/22/14 Page 1 of 21 Page ID #:453

Page 19: JAT Wheels v. JNC Wheel - Am. Compl

United States Patent and Trademark Office

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Word Mark STR RACINGGoods andServices

IC 012. US 019 021 023 031 035 044. G & S: Vehicle wheels;; Wheel rims;; Wheel rims. FIRST USE:20120101. FIRST USE IN COMMERCE: 20120101

StandardCharactersClaimedMark DrawingCode (4) STANDARD CHARACTER MARK

Serial Number 86256705Filing Date April 18, 2014Current Basis 1AOriginal FilingBasis 1A

Owner (APPLICANT) JAT Wheels, Inc. CORPORATION CALIFORNIA 11323 Shoemaker Ave. Santa FeSprings CALIFORNIA 90670

Attorney of Record Tommy SF WangType of Mark TRADEMARKRegister PRINCIPALLive/DeadIndicator LIVE

Case 2:14-cv-04898-JVS-MRW Document 24-1 Filed 09/22/14 Page 2 of 21 Page ID #:454

Page 20: JAT Wheels v. JNC Wheel - Am. Compl

EXHIBIT B

Case 2:14-cv-04898-JVS-MRW Document 24-1 Filed 09/22/14 Page 3 of 21 Page ID #:455

Page 21: JAT Wheels v. JNC Wheel - Am. Compl

Feedback as a seller Feedback as a buyer All Feedback Feedback left for others

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ccwreps ( 111 )

Positive Feedback (last 12 months): 99.1% [How is Feedback percentage calculated?]Member since: Sep-05-13 in United States

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Recent Feedback ratings (last 12 months)

1 month 6 months 12 months

Positive 13 73 113

Neutral 0 1 3

Negative 0 1 1

Detailed seller ratings (last 12 months)

Criteria Average rating Number ofratings

Item as described 109

Communication 108

Shipping time 109

Shipping and handling charges 116

117 Feedback received (viewing 26-50) Revised Feedback: 3

Period: All

Feedback From During

Good Buyer: l***r ( 130 ) Past 6 months

16X9 JNC031 SL 4X100 +15 WHEEL AV.18 GOLD MACHINE LIP EM1 EK9 EG6 EF DA(#181427314505)

US $749.99Best Offer Price was Accepted

View Item

It's awesome! Love it! Buyer: 2***2 ( 388 ) Past 6 months

17X8.5 JNC004 4X100 4X108 +30 WHEEL RS SILVER AV.05 ESM002R FOCUS EM1 EM2(#181397052515)

US $569.99 View Item

Thanks Buyer: y***k ( 157 ) Past 6 months

18X9 +32 JNC 027 5X100 HYPER BLACK RIM FIT STI TC FRS BRZ COROLLA MBBATTLE (#181476323731)

US $539.99 View Item

great look Buyer: d***- ( 61 ) Past 6 months

15X9 JNC003 4X100 4x114.3 +0 WHEEL FLAT BRONZE 240SX 510 280Z 5" HUGE LIPMIATA (#181430158004)

US $489.99 View Item

Loce it! Fast Shipping, Great Seller Buyer: r***t ( 133 ) Past 6 months

17X8 JNC 030 5X114.3 +32 HYPERBLACK WHEEL MITSUBISHI LANCER ECLIPSE TC XBSTI SI (#171358689857)

US $589.99Best Offer Price was Accepted

View Item

Excellent seller , very caring of customer, good communication. Thanks A+++ Buyer: d***u ( 906 ) Past 6 months

JNC001 C-CW 18X8.5 +30 5X114.3 PLATINUM AV.12 531 EVO WRX 8 9 X 10 350Z 370Z(#181422126516)

US $779.99 View Item

Awesome product fast ship Buyer: s***s ( 496 ) Past 6 months

18X8.5 JNC016 RO-TIFORM BLQ 5X100 HYPER BLACK JETTA GOLF GTI WRS STI AUDI US $699.99 View Item

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SellHi Andrew (Sign in) My eBay

Case 2:14-cv-04898-JVS-MRW Document 24-1 Filed 09/22/14 Page 4 of 21 Page ID #:456

Page 22: JAT Wheels v. JNC Wheel - Am. Compl

A4 A5 (#171357647647)

Thanks alot guys very very quick! Buyer: u***0 ( 36 ) Past 6 months

16X8 JNC031 SL 4X100 +20 WHEEL AV.18 GOLD MACHINE LIP EM1 EK9 EG6 EF DA(#181458871843)

US $549.99 View Item

Good services Buyer: s***7 ( 15 ) Past 6 months

16X9 JNC010 RO-TIF-ORM ROC 4X114.3 4X100 +15 WHEEL FULL MACHINE MIATA 280Z510 (#171342461776)

US $569.99 View Item

Money was refund due to my mistake. This seller cares about its costumers. Buyer: o***7 ( 651 ) Past 6 months

17x9 CCW JNC001 Wheel Full Machined +25 5x100 5X114.3 av-12 531 ES-M007 FA CIVIC(#171344100772)

US $589.99 View Item

Fast shipping. Great description! Thank you! ! Great help and seller!! Buyer: c***v ( 152 ) Past 6 months

16x9 CONCAVE JNC014 4X100 +20 FULL MACHINED WHEEL GRID AV.05 RS5 DA EK(#171362772893)

US $529.99 View Item

Great product, fast shipping, good seller. Buyer: a***s ( 155 ) Past 6 months

18" CCW JNC001 18X8.5 +30 5x114.3 FITS WRX STI EVO 8 9 X FULL MACHINE TSX TLFA (#171365586062)

US $649.99Best Offer Price was Accepted

View Item

Article super, expédition rapide, vendeur sérieux Buyer: 9***9 ( 42 ) Past 6 months

18X9.5 JNC014 5X100 +30 WHITE WHEEL GRID TE37 SUBARU WRX STI FRS TC(#181423139162)

US $699.99 View Item

Great product. .. lightning fast shipping! Buyer: b***b ( 147 ) Past 6 months

17X8 JNC006 CE28 CONCAVE 5X100 5X114.3 +28 FLAT BLACK RSX TC COROLLA FRSCIVIC (#171357935435)

US $569.99 View Item

Fast shipping Buyer: c***c ( 48 ) Past 6 months

16X8 JNC031 SL 4X100 +20 WHEEL AV.18 GOLD MACHINE LIP EM1 EK9 EG6 EF DA(#171346848407)

US $549.99 View Item

A++++too seller Buyer: c***u ( 60 ) Past 6 months

17X8.5 JNC005 5X114.3 +30 LM STYLE BLACK W/ GOLD RIVETS RSX ACCORD ACURALANCER (#181422336897)

US $599.99 View Item

Wheels are junk.One rim had a tiny hole in it. Gold rivets were striped off Buyer: 1***1 ( 60 ) Past 6 months

Reply by ccwreps (Jun-23-14 16:44):SHOW ME THE PICTURE JNC WHEELS LIKES TO SEE IT!!!

18X8 JNC005 5X114.3 +34 LM STYLE BLACK W/ GOLD RIVETS TL TSX ACCORD CIVICFG FA (#171343349363)

US $599.99 View Item

Detailed item information is not available for the following items because the Feedback is over 90 days old.

Great customer service Buyer: _***u ( 41 ) Past 6 months

18X9 JNC005 5X114.3 +34 LM STYLE BLACK W/ GOLD RIVETS TL TSX ACCORD CIVICFG FA (#171342439560)

US $599.99

Love my item!!!! Buyer: e***y ( 43 ) Past 6 months

17X9 JNC010 R-OTIFORM ROC 5X114.3 +25 WHEEL FULL HYPER BLACK RSX FA5 TLTSX EP3 (#171342409378)

US $699.99

It's great I love it Buyer: f***a ( 5 ) Past 6 months JNC001 CCW V.2 17X8 +25 5x100 5X114.3 BRONZE MACHINED LIP 531 AV.12 RSX FA5

(#171310617394)US $619.99

Wheels are awesome! Buyer: e***o ( 101 ) Past 6 months

JNC019 18X9 +25 BLACK CHROME 5X114.3 5X100 C.-CW WORK HUGE 4" LIP! XD9OUTCAST (#181426782127)

US $849.99

Case 2:14-cv-04898-JVS-MRW Document 24-1 Filed 09/22/14 Page 5 of 21 Page ID #:457

Andrew Wei
Page 23: JAT Wheels v. JNC Wheel - Am. Compl

Fast send aaaa++ Buyer: w***i ( 60 ) Past 6 months

18x9.5 JNC016 ROTI-FORM BLQ 5X114.3 GOLD MACHINE LIP STAGGERRED ACCORDTL TSX (#171347405805)

US $759.99

A+ Buyer: e***v ( 204 ) Past 6 months

15x8 15X9 JNC003 4X100 4x114.3 +0 WHEEL FLAT BRONZE 240SX 510 280ZSTAGGERED (#181402372194)

US $469.99

very good! Buyer: e***p ( 96 ) Past 6 months

18X9 JNC005 5X114.3 +34 LM STYLE BLACK W/ GOLD RIVETS TL TSX ACCORD CIVICFG FA (#171345152684)

US $599.99

Good quality Buyer: u***3 ( 112 ) Past 6 months

15X8 15X9 JNC010 ROTIFORM ROC 4X114.3 4X100 +20 WHEEL SILVER STAGGERREDDC2 EK (#171314257269)

US $529.99

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Case 2:14-cv-04898-JVS-MRW Document 24-1 Filed 09/22/14 Page 6 of 21 Page ID #:458

Page 24: JAT Wheels v. JNC Wheel - Am. Compl

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ccwreps ( 111 )

Positive Feedback (last 12 months): 99.1% [How is Feedback percentage calculated?]Member since: Sep-05-13 in United States

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Recent Feedback ratings (last 12 months)

1 month 6 months 12 months

Positive 13 73 113

Neutral 0 1 3

Negative 0 1 1

Detailed seller ratings (last 12 months)

Criteria Average rating Number ofratings

Item as described 109

Communication 108

Shipping time 109

Shipping and handling charges 116

117 Feedback received (viewing 51-75) Revised Feedback: 3

Period: All

Feedback From During

... Buyer: y***y ( 163 ) Past 6 months

JNC001 CCW V.2 17X9 +20 5x100 5X114.3 BRONZE MACHINED LIP XXR531 AV.12 RSXFA5 (#181363608737)

US $639.99

Ok Buyer: i***n ( 47 ) Past 6 months

18x9 JNC005 5X112 +34 OFFSET LM STYLE WHITE AUDI A4 S4 GOLF GTI A3 A5(#171314900693)

US $669.99

Buyer: a***y ( 81 ) Past 6 months

16x8 JNC004 4X114.3 4X100 +25 WHEEL RS STYLE 606 STR GOLD MACHINED LIP AV05(#181395795972)

US $479.99

Pretty fast shipping wheels look good Buyer: s***e ( 48 ) Past 6 months

JNC001 CCW V.2 17X9 +20 5x100 5X114.3 PLATINUM AV.12 RSX FA5 531 EP3 WRX TSXTL (#171308047867)

US $749.99

Thank you Buyer: v***e ( 321 ) Past 6 months

18X8.5 JNC014 5X114.3 +30 WHITE WHEEL GRID TE37 EVO X VIII 350Z G35 LANCERIS350 (#181391806358)

US $659.99Best Offer Price was Accepted

A++++ love it. Makes driving this auto so much easier to bare lol Buyer: r***r ( 103 ) Past 6 months

17X8 JNC010 ROTIFORM ROC 5X114.3 +30 WHEEL GOLD MACHINE LIP IS250 TSXIS300 RSX (#171322200901)

US $629.99

Awesome seller and great product ! Buyer: n***2 ( 142 ) Past 6 months

18X8.5 18x9.5 JNC004 5X114.3 5X100 +30 +25 STAGGERED SILVER MACHINED TSX US $659.99

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SellHi Andrew (Sign in) My eBay

Case 2:14-cv-04898-JVS-MRW Document 24-1 Filed 09/22/14 Page 7 of 21 Page ID #:459

Andrew Wei
Page 25: JAT Wheels v. JNC Wheel - Am. Compl

MK4 (#181315148607)

Fast shipping Buyer: t***p ( 89 ) Past 6 months

16x8 JNC004 4X114.3 4X100 +25 WHEEL RS STYLE 606 STR GOLD MACHINED LIP AV05(#171308048347)

US $479.99

A+ Buyer: _***e ( 13 ) Past 6 months

16X9 JNC004 4X114.3 4X100 +15 WHEEL RS SILVER ACCORD CB7 240SX AV.05ESM002R (#181341321862)

US $569.99

Great seller. Products arrived very quickly. Buyer: d***b ( 29 ) Past 6 months

JNC026 CV3 18X9 +32 5X114.3 WHITE CONCAVE FITS RSX TSX TL FA5 ACCORD WRXTC (#171296099193)

US $679.99

Great product, quick shipping, A+ Seller! Buyer: i***d ( 335 ) Past 6 months

18x8.5 JNC004 5X100 5X114.3 +30 RS WHITE MACHINED LIP TSX TL FRS TC COROLLA(#181322690977)

US $649.99

Great seller love the wheels they are perfect A++++ Buyer: h***h ( 104 ) Past 6 months

18" CCW JNC001 18X9.5 +25 5x114.3 FITS MUSTANG G35 350Z EVO 8 9 X FULLMACHINE (#181363363179)

US $699.99Best Offer Price was Accepted

Bon Buyer: r***e ( 63 ) Past 6 months

18" CCW JNC001 18X9.5 +25 5x114.3 FITS MUSTANG G35 350Z EVO 8 9 X FULLMACHINE (#181363363179)

US $699.99

A+++++++ Fast Shipping , Great seller Buyer: a***l ( 80 ) Past 6 months

16X8.5 JNC004 4X114.3 4X100 +25 WHEEL RS FLAT BRONZE CIVIC INTEGRA DC2AV.05 EK (#181354231754)

US $479.99

Great service Buyer: 1***o ( 68 ) Past 6 months

16X9 JNC010 ROTIFORM ROC 4X114.3 4X100 +20 WHEEL SILVER MACHINED LIP CB7240SX (#181376704449)

US $579.99

Great service Buyer: 1***o ( 68 ) Past 6 months

16X9 JNC010 ROTIFORM ROC 4X114.3 4X100 +20 WHEEL SILVER MACHINED LIP CB7240SX (#171296066149)

US $579.99

Buyer: s***b ( 138 ) Past 6 months

17X9.5 JNC021 5X114.3 5X100 +15 WHEEL RPF1 STYLE 240SX S13 S14 S15 SBC(#181330143409)

US $700.00

good all around Buyer: m***c ( 282 ) Past 6 months

18x8 JNC005 5X112 +34 OFFSET LM STYLE WHITE AUDI A4 S4 GOLF GTI A3 A5(#181330144597)

US $599.99

Great service! And great product! Hope to work with the seller soon! Buyer: d***s ( 18 ) Past 6 months

18" CCW STYLE 18X9.5 +25 5x114.3 FITS MUSTANG G35 350Z WHITE MACHINED LIP(#181337500803)

US $699.99

Fits perfect , fast ship A+ Buyer: l***n ( 257 ) Past 6 months

18" CCW JNC001 18X9.5 +25 5x114.3 FITS MUSTANG G35 350Z EVO 8 9 X FULLMACHINE (#181353011753)

US $699.99Best Offer Price was Accepted

So pumped to put these on my car Buyer: l***8 ( 143 ) Past 6 months

18" CCW JNC001 18X8.5 +30 5x114.3 FITS WRX STI EVO 8 9 X FULL MACHINE TSX TLFA (#181353013304)

US $649.99Best Offer Price was Accepted

Perfect Buyer: c***r ( 29 ) Past 6 months

16X9 JNC004 4X114.3 4X100 +15 WHEEL RS GOLD MACHINED LIP ACCORD CB7 240SXAV.05 (#181324893206)

US $569.99

Case 2:14-cv-04898-JVS-MRW Document 24-1 Filed 09/22/14 Page 8 of 21 Page ID #:460

Andrew Wei
Page 26: JAT Wheels v. JNC Wheel - Am. Compl

awesome wheels and lug nuts! Buyer: s***u ( 87 ) Past 6 months

18" CCW STYLE 18X9.5 +25 5X100 5x114.3 FITS 350Z G35 MUSTANG VELOSTER JETTAAUDI (#181307557022)

US $699.99Best Offer Price was Accepted

Great seller Buyer: n***a ( 231 ) Past 6 months

17X9 JNC014 5X114.3 +25 WHITE WHEEL RSX FA TSX TL ACCORD EP3 GRIDCONCAVE XXR (#181337473817)

US $639.99

Good work Buyer: 3***3 ( 32 ) Past 6 months

JNC001 CCW V.2 17X9 +20 5x100 5X114.3 WHITE MACHINED LIP XXR531 AV.12 RSXFRS (#181342377945)

US $639.99

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Case 2:14-cv-04898-JVS-MRW Document 24-1 Filed 09/22/14 Page 9 of 21 Page ID #:461

Page 27: JAT Wheels v. JNC Wheel - Am. Compl

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ccwreps ( 111 )

Positive Feedback (last 12 months): 99.1% [How is Feedback percentage calculated?]Member since: Sep-05-13 in United States

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Recent Feedback ratings (last 12 months)

1 month 6 months 12 months

Positive 13 73 113

Neutral 0 1 3

Negative 0 1 1

Detailed seller ratings (last 12 months)

Criteria Average rating Number ofratings

Item as described 109

Communication 108

Shipping time 109

Shipping and handling charges 116

117 Feedback received (viewing 76-100) Revised Feedback: 3

Period: All

Feedback From During

Blown away with my new wheels....awesome fast shipping seller Buyer: n***s ( 41 ) Past 12 months

JNC001 CCW V.2 15X8 +0 4x100 GOLD MACHINED LIP XXR531 AV.12 EK EG MIATA 3"LIP! (#181351682686)

US $439.99

Small issue with tracking info but overall great service and description of item Buyer: a***0 ( 1 ) Past 12 months JNC001 CCW V.2 17X9 +20 5x100 5X114.3 WHITE MACHINED LIP XXR531 AV.12 RSX

FRS (#181343715569)US $639.99

Love my wheels! Buyer: e***r ( 66 ) Past 12 months

16x8 CCW JNC001 Wheel +25 4x100 4X114.3 av-12 XXR531 ESM007 WHITE MACHINEDFACE (#181337500309)

US $500.00

Great buy fast shipping Buyer: g***m ( 113 ) Past 12 months

JNC019 18X8 et25 HYPERBLACK MACHINE LIP 5X114.3 STYLE CCW WORK HUGE 4"LIP!! (#181328062927)

US $679.99

Very sporty rims. Highly recommended. Fast shipping and good customer care Buyer: a***a ( 127 ) Past 12 months

JNC008 19X8.5 19X10.5 5X100 5X114.3 +15 +25 HYPER BLACK WHEELS RIMSTAGGERED (#181330753696)

US $739.99

Good stuff... Buyer: b***m ( 82 ) Past 12 months

16x8 JNC004 4X114.3 4X100 +15 WHEEL RS STYLE 606 STR GOLD MACHINED LIP AV05(#181341348499)

US $479.99

Perfect seller. Thanks Buyer: z***z ( 154 ) Past 12 months

16X9 JNC004 4X114.3 4X100 +15 WHEEL RS GOLD MACHINED LIP ACCORD CB7 240SX US $569.99

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SellHi Andrew (Sign in) My eBay

Case 2:14-cv-04898-JVS-MRW Document 24-1 Filed 09/22/14 Page 10 of 21 Page ID #:462

Andrew Wei
Page 28: JAT Wheels v. JNC Wheel - Am. Compl

AV.05 (#181320361030)

Nice wheels lots of white over spray had to have them buffed out Buyer: o***h ( 29 ) Past 12 months

18" CCW STYLE 18X9.5 +25 5x112 FITS AUDI A4 S4 S6 VW WHITE MACHINED FACEJETTA (#181316875635)

US $699.99

Super fast shipping, good quality, and GREAT PRICE Buyer: l***o ( 181 ) Past 12 months

16X9 JNC004 4X114.3 4X100 +15 WHEEL RS WHITE MACHINED LIP ACCORD CB7240SX AV.05 (#181327653211)

US $569.99

Good communication Buyer: p***l ( 21 ) Past 12 months

Feedback was revised on Mar-04-14 13:16

16" 16x9 CCW JNC001 Wheel +10 4x100 4X114.3 av-12 XXR531 ESM007 EK EM1 EM2(#181323749225)

US $525.00

Fast fast shipping. Great product. Awesome price. Buyer: 4***4 ( 247 ) Past 12 months

18x9 JNC005 5X114.3 +34 OFFSET LM STYLE GOLD MACHINED LIP TSX TL CL RLSTAGGERED (#181323001910)

US $629.99

Description says "TL" in it. Did not fit my 07 TL type s. No returns. Not cool. Buyer: a***s ( 113 ) Past 12 months

Reply by ccwreps (Feb-27-14 13:51):says TL not TL types EBAY FITMENT GUIDE said it fits not my prob ebay's mistake

18x9 JNC005 5X114.3 +34 OFFSET LM STYLE GOLD MACHINED LIP TSX TL CL RLSTAGGERED (#181318435514)

US $629.99

Recieved the product on time very fast shipping will order from them again. Buyer: s***6 ( 29 ) Past 12 months

17" 17x9 CCW JNC001 Wheel Gold Machined Lip +25 4x100 4X114.3 av12 XXR531ESM007 (#181314560142)

US $569.99

great service Buyer: n***8 ( 51 ) Past 12 months

18x9 JNC005 5X114.3 +34 OFFSET LM STYLE WHITE TL TSX IS300 GS300 IS250 IS350FA (#181307530511)

US $629.99

Great service Buyer: j***r ( 60 ) Past 12 months

19X8.5 19X 9.5 JNC005 5X114.3 +30 +25 LM STYLE HYPER BLACK 350Z G35 370Z 300ZX(#181307546017)

US $645.99

Fast shipping exact description AAA++ Buyer: -***o ( 30 ) Past 12 months

JNC019 18X8 et25 HYPERBLACK MACHINE LIP 5X114.3 STYLE CCW WORK HUGE 4"LIP!! (#181312138759)

US $679.99

Great looking wheels Buyer: 9***s ( 74 ) Past 12 months

15x8 15X9 JNC003 4X100 4x114.3 +0 WHEEL FLAT BRONZE 240SX 510 280ZSTAGGERED (#181320381478)

US $469.99

Excelent! Fast shipping! Buyer: n***n ( 185 ) Past 12 months

16" 16x9 CCW JNC001 Wheel +10 4x100 4X114.3 av-12 XXR531 ESM007 EK EM1 EM2(#181309094023)

US $525.00

Awesome fast shipping Buyer: j***m ( 65 ) Past 12 months

16" 16x8 CCW JNC001 Wheel Full Machined +25 5x100 5X114.3 av-12 XXR531 ESM007(#181320271239)

US $500.00

Excellent service.. Fast response Buyer: x***i ( 37 ) Past 12 months

17" 17x9 CCW JNC001 Wheel Gold Machined Lip +25 5x100 5X114.3 av12 XXR531ESM007 (#181323001159)

US $569.99

GREAT RIMS, GREAT SELLER :) Buyer: 9***4 ( 220 ) Past 12 months

15X8 JNC002 DR20 AV07 4X100 +25 WHEEL FULL MACHINED EG6 SA RACING EKMIATA (#181312437662)

US $429.99

Case 2:14-cv-04898-JVS-MRW Document 24-1 Filed 09/22/14 Page 11 of 21 Page ID #:463

Page 29: JAT Wheels v. JNC Wheel - Am. Compl

Great seller Buyer: 3***3 ( 12 )

No longer a registered userPast 12 months

16X9 JNC004 4X114.3 4X100 +15 WHEEL RS WHITE MACHINED LIP ACCORD CB7240SX AV.05 (#181320363228)

US $569.99

A+ Buyer: i***y ( 55 ) Past 12 months

17" 17x9 CCW JNC001 Wheel Gold Machined Lip +25 5x100 5X114.3 av12 XXR531ESM007 (#181307548837)

US $569.99

AWESOME PRODUCT!!! SUPER FAST SHIPPING!! WILL BUY FROM AGAIN! Buyer: o***g ( 200 ) Past 12 months

18x9.5 JNC014 5X100 +25 HYPERBLACK SUBARU WRX LEGACY OUTBACK JETTA GRIDTE37 (#181293080360)

US $699.99

fast shipping, good product! Buyer: p***d ( 41 ) Past 12 months

17X9 JNC010 ROTIFORM ROC 5X114.3 +25 WHEEL WHITE MACHINED LIP DC5 TSX TLFA FG (#181298113858)

US $749.99

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Case 2:14-cv-04898-JVS-MRW Document 24-1 Filed 09/22/14 Page 12 of 21 Page ID #:464

Page 30: JAT Wheels v. JNC Wheel - Am. Compl

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ccwreps ( 111 )

Positive Feedback (last 12 months): 99.1% [How is Feedback percentage calculated?]Member since: Sep-05-13 in United States

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Recent Feedback ratings (last 12 months)

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Positive 13 73 113

Neutral 0 1 3

Negative 0 1 1

Detailed seller ratings (last 12 months)

Criteria Average rating Number ofratings

Item as described 109

Communication 108

Shipping time 109

Shipping and handling charges 116

117 Feedback received (viewing 101-117) Revised Feedback: 3

Period: All

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thanks!! Buyer: s***s ( 50 ) Past 12 months

17" 17x9 CCW JNC001 Wheel Full Machined +25 4x100 4X114.3 av-12 XXR531 ESM007(#181280750901)

US $599.99Best Offer Price was Accepted

Love the design and hope to get it soon Buyer: v***s ( 11 ) Past 12 months

16X9 JNC010 ROTIFORM ROC 4X114.3 4X100 +20 WHEEL SILVER MACHINED LIP CB7240SX (#181318994171)

US $569.99

A++ Buyer: a***a ( 311 ) Past 12 months

18X8.5 18X9.5 JNC004 5X114.3 5X100 BBS RS HYPERBLACK STAGGERED TL TSXJETTA MK4 (#181296735233)

US $619.99

fast service and nice products Buyer: c***d ( 39 ) Past 12 months

16X9 JNC010 ROTIFORM ROC 4X114.3 4X100 +20 WHEEL SILVER MACHINED LIP CB7240SX (#181296893419)

US $569.99

recommend seller hope to do business again Buyer: l***j ( 129 ) Past 12 months

M12X1.5MM WHEEL RIM RACING LUG NUTS 20 PIECES FLASHY VIP LUXRY JDM REDALUMINUM (#181292312302)

US $29.99

Amazing Quality - Awesome Seller - I will buy more in the future from them A++++ Buyer: n***t ( 27 ) Past 12 months

18x8 JNC005 5X100 +34 OFFSET BBS LM STYLE HYPER SILVER TC WRX SUBARUJETTA (#181290218845)

US $559.99

Excellent seller great communication hope to do business in the future Buyer: 8***8 ( 112 ) Past 12 months

16X9 JNC010 ROTIFORM ROC 4X114.3 4X100 +20 WHEEL WHITE MACHINED LIP 240SX US $569.99

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SellHi Andrew (Sign in) My eBay

Case 2:14-cv-04898-JVS-MRW Document 24-1 Filed 09/22/14 Page 13 of 21 Page ID #:465

Page 31: JAT Wheels v. JNC Wheel - Am. Compl

CB7 EG (#181294474036)

Fast shipping. Good seller and prices Buyer: w***g ( 105 ) Past 12 months

16X8.25 JNC014 HYPER SILVER 4X100 +25 WHEEL ROTA GRID TE37 CONCAVE EGMIATA EK (#181290200841)

US $479.99

Awesome sellers! I received exactly what I wanted! Beautiful wheels! Perfect! Buyer: e***_ ( 8 ) Past 12 months 17X8.5 JNC 004 4X114.3 4X100 +15 WHEEL RS STYLE 606 STR GOLD MACHINED LIP

FA FG (#181246184886)US $569.99

look real good and great price Buyer: 9***9 ( 187 ) Past 12 months

15X8 JNC003 4X114.3 4X100 +0 SILVER WHEEL HOLESHOT 513 CE28 LOW OFFSET EGEK EF (#181246171758)

US $415.00

Looks better in person =) Buyer: e***l ( 84 ) Past 12 months

16" 16x8 CCW Style JNC Wheel low offset Full Machined +25 4x100 4X114.3 Miata EG(#181260543836)

US $395.00

Great deal thanks.. Fast shipping Buyer: c***n ( 126 ) Past 12 months

16" 16x8 CCW Style JNC Wheel low offset Full Machined +25 4x100 4X114.3 Miata EG(#181250586621)

US $395.00

super fast shipping thanks Buyer: a***y ( 96 ) Past 12 months

M12X1.5MM WHEEL RIM RACING LUG NUTS 20 PCS FLASHY VIP LUXRY JDM PURPLEALUMINUM (#181243681085)

US $29.99

Fast shipping Buyer: n***5 ( 28 ) Past 12 months

15" 15x9 CCW Style JNC Wheel low offset Full Machined +10 4x100 4X114.3 Miata EG(#181224371708)

US $389.99

great item, fast shipping!! A++ Buyer: r***n ( 1359 ) Past 12 months

M12X1.5MM WHEEL RIM RACING LUG NUTS 20 PIECES FLASHY VIP LUXRY JDM BLUEALUMINUM (#181236979379)

US $29.99

had a shipping mistake but got it resolved and im happy with the product. thanks Buyer: d***8 ( 35 ) Past 12 months

Feedback was revised on Oct-18-13 17:24

M12X1.5MM WHEEL RIM RACING LUG NUTS 20 PIECES FLASHY VIP LUXRY JDM BLUEALUMINUM (#181236979379)

US $29.99

Great Package with Fast Delivery! Highly Recommended! Buyer: j***a ( 51 ) Past 12 months

M12X1.5MM WHEEL RIM RACING LUG NUTS 20 PIECES FLASHY VIP LUXRY JDM REDALUMINUM (#181225312256)

US $27.99

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Case 2:14-cv-04898-JVS-MRW Document 24-1 Filed 09/22/14 Page 14 of 21 Page ID #:466

Andrew Wei
Andrew Wei
Page 32: JAT Wheels v. JNC Wheel - Am. Compl

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Home > for sale > auto parts > JNC 275 WHEEL STR 513,TRAKLITE HOLESHOT STYLE WHITE BRONZE FLAT BLACK - $325 (East LA O% Financing)

JNC 275 WHEEL STR 513,TRAKLITE HOLESHOT STYLE WHITE BRONZE FLATBLACK - $325 (East LA O% Financing)

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Ad id: 2112130923545731 | Views: 25

Price: 325 USDDate listed: 9 months agoJNC 275 WHEEL (TRAKLITE HOLESHOT OR STR 513 STYLE 15X8+04X100/4X1143. FLAT BLACK , WHITE,FLAT BRONZE OR SILVER $325 OR $550 WITH BRAND NEW TIRES 4525 whittier blvdlos angeles ca90022Tel(323)262-1818Mon-Sat 9Am-8PmSundays 11am-5pm

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Case 2:14-cv-04898-JVS-MRW Document 24-1 Filed 09/22/14 Page 15 of 21 Page ID #:467

Andrew Wei
Page 33: JAT Wheels v. JNC Wheel - Am. Compl

EXHIBIT C

Case 2:14-cv-04898-JVS-MRW Document 24-1 Filed 09/22/14 Page 16 of 21 Page ID #:468

Page 34: JAT Wheels v. JNC Wheel - Am. Compl

Case 2:14-cv-04898-JVS-MRW Document 24-1 Filed 09/22/14 Page 17 of 21 Page ID #:469

Page 35: JAT Wheels v. JNC Wheel - Am. Compl

Case 2:14-cv-04898-JVS-MRW Document 24-1 Filed 09/22/14 Page 18 of 21 Page ID #:470

Page 36: JAT Wheels v. JNC Wheel - Am. Compl

Case 2:14-cv-04898-JVS-MRW Document 24-1 Filed 09/22/14 Page 19 of 21 Page ID #:471

Page 37: JAT Wheels v. JNC Wheel - Am. Compl

Case 2:14-cv-04898-JVS-MRW Document 24-1 Filed 09/22/14 Page 20 of 21 Page ID #:472

Page 38: JAT Wheels v. JNC Wheel - Am. Compl

Case 2:14-cv-04898-JVS-MRW Document 24-1 Filed 09/22/14 Page 21 of 21 Page ID #:473