Jarratt v. Amazon - Complaint

Case 5:16-cv-05302-PKH Document 1
Filed 10/25/16 Page 1 of 17 PageID #: 1
IN THE UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF ARKANSAS
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By
HUGH JARRATT,
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Dep,.,
an Arkansas resident
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JARRATT INDUSTRIES, LLC,

PLAINTIFFS
an Arkansas Limited Liability Company

vs.
CASE NO.
\ Lo-5308 Pk. H
DEFENDANTS
AMAZON.COM, INC.
A Delaware Corporation
CT DISCOUNT STORE, INC.
A New York Corporation
JURY TRIAL REQUESTED

COMPLAINT
Comes now the Plaintiffs, Hugh Jarratt and Jarratt Industries, LLC, by and through their
attorney, Schrantz Law Firm, PLLC, for their Complaint against Amazon.com, Inc. and CT
Discount Store, Inc. state as follows:
1.
Plaintiff Hugh Jarratt (hereinafter referred to as "Jarratt") is an Arkansas resident residing
in Fayetteville, Arkansas.
2.
Plaintiff Jarratt Industries, LLC (hereinafter referred to as "Jarratt Ind.") is an Arkansas
limited liability company with its principal place of business in Fayetteville, Arkansas.
3.
Defendant Amazon.com, Inc. (hereinafter referred to as "Amazon") is, upon information
and belief, a Delaware corporation with its principal place of business located in Seattle,
Washington.
4.
Defendant CT Discount Store, Inc. (hereinafter referred to as "CT Discount") is, upon
information and belief, a New York corporation with is principal place of business located in
Floral Park, New York.
/
Jurisdiction
5.
This is a complaint for patent infringement arising under the patent laws of the United
States,, Title 35 of the United States Code, 35 U.S.C. 271, 282, 283, 284, 285.
6.
This Court has jurisdiction under 28 U.S.C. 1338 and 1400 and venue is proper under
28 U.S.C. 139l(b).
7.
Furthermore, Defendants intentionally and maliciously pirated and infringed upon a
patent and trademark belonging to the Jarratts located in Fayetteville, Arkansas.

8.
This Court has subject matter jurisdiction over the Jarratts' federal claims pursuant to 35
U.S.C. 271, 35 U.S.C. 289, 15 U.S.C. 1121, and 28 U.S.C. 1331 and 1338.
9.
This Court has supplemental jurisdiction over the Jarratts' pendent state law claims
pursuant to 28 U.S.C. 1367 in that the state law claims are integrally interrelated with the
Jarratts' federal claims and arise from a common nucleus of operative facts such that
administration of the Jarratts' state law claims with their federal claims furthers the interest of
judicial economy.
10.
The Court has personal jurisdiction over Defendants because upon information and
belief, Defendants have transacted business within the state of Arkansas; promoted themselves
via the Internet, which is available to Internet users throughout the world, including those in
Arkansas and in this district; committed acts, or caused consequences to occur that resulted in an
action for the torts alleged in this complaint, including patent infringement and trademark
infringement.
11.
Venue is proper in this district under 28 U.S.C. 1391(b) because a substantial part of the
acts giving rise to the claim occurred in this district and because Defendants are subject to
personal jurisdiction in this district.
Factual Background
12.
For many years, Jarratt has been engaged in the development, manufacture, and sell of
taco plates and other kitchen utensils and cooking products.

13.
Jarratt has taken steps to protect his innovative designs, including his taco plates. In
particular, Jarratt owns U.S. Patent No. D574,187 entitled "Divided Plate for Separating Food"
(hereinafter referred to as "the'187 patent") relating to Jarratt's taco plate. Relevant to this
dispute, Jarratt is and has been the owner of all right, title, and interest to the'187 patent.
14.
On August 5, 2008, the'187 patent was duly and lawfully issued to inventor Hugh
Jarratt. A true and correct copy of the '187 patent is attached as Exhibit 1.
15.
Jarratt owns rights in the '187 patent sufficient to bring this action.
16.
Jarratt has achieved success and nationwide notoriety with his patented Taco Plate.
Jarratt's Taco Plate has been featured on the NBC's Today Show in the segment entitled "What's
Hot in the Kitchen" which aired on or around July 5, 2012. Jarratt's patented taco plate has also
been featured in the NBC Nightly News, ABC's Dateline, the Seattle Times, the Arkansas
Business Journal, the Arkansas Democrat Gazette, and the Fayetteville Flyer. See Exhibits 2 and
3.
I 7.
Jarratt's patented plates have been and are currently sold through Amazon through both
Natural State Mercantile and Wire Whisk.
18.
Upon information and belief, Amazon sells, offers for sale, and exposes for sale
Defendants' infringing plates by CT Discount Store, Inc.

19.
Upon information and belief, CT Discount Store, Inc. sells and offers for sell infringing
plates on Amazon's website located at Amazon.com.

20.
Upon information and belief, Amazon profits from the sale of the infringing plates.
21.
Defendants currently sell, offer for sell, and expose for sale infringing taco plates that
were not acquired from Jarratt. Offers for sale and exposures for sale of Defendants' infringing
taco plates are attached as Exhibits 4 and 5.
22.
Upon information and belief, Defendants transact or have transacted business within this
judicial district for Defendants' individual gain and benefit and are subject to the jurisdiction of
this Court.
23.
Upon information and belief, without Jarratt's authorization, Defendants have offered for
sale, sold, and exposed for sale and continue to offer for sale, sell, and expose for sale in the
United States and Arkansas imitation taco plates having designs that are covered by the '187
patent (hereinafter referred to as "Defendants' Infringing Plates").
24.
Upon information and belief, Defendants knowingly and intentionally sold, offered for
sale, and exposed for sale and continue to sell, offer for sale, and expose for sale Defendants'
Infringing Plates as simulations of Jarratt's taco plates. See Exhibits 4 and 5.
25.
Amazon directs potential customers to purchase from CT Discount Store, instead of
Jarratts' licensed products. See Exhibits 4 and 5 (bottom portion of page 2).
26.
Amazon provides links to infringing plates offered at lower prices than the prices at
which Jarratt's licensed products are offered. See Exhibits 4 and 5 (bottom portion of page 2).
27.
Amazon encourages users to compare the prices of the infringing products to the licensed
products in a table that compares similar items. See Exhibits 4 and 5 (bottom portion of page 2).
28.
Amazon also provides an Amazon Selling Coach that provides pricing information
concerning competing products.

29.
The Amazon Selling Coach recommends matching the lowest price for the competing
products.
30.
Amazon, through its Amazon Selling Coach, recommends that Jarratt's licensees match
the prices of the lower priced infringing products to compete with the infringing products. See
Exhibit 6.
31.
Chart 1 below demonstrates Defendants' infringement by comparing figures of the '187
patent with the Infringing plates sold by Defendants.

Chart 1: Comparison of the '187 patent to Defendants' Infringing Plate
FIG. I
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FIG. 7
32.
Based on information and belief, Defendants have infringed and continue to infringe the
'187 patent within the meaning of35 U.S.C.271(a), 289 at least by selling, offering to sell,
and exposing for sale Defendants' Infringing Plates without Jarratt's authorization or license.
33.
Jarratt has sold and is currently selling its Taco Plate bearing the design claimed in the
'187 patent. As contemplated by the Patent Act, 35 U.S.C. 287, Jarratt has provided notice of
the '187 patent by marking the '187 patent number on Jarratt's Taco Plates models bearing those
patented designs since approximately the time the United States Patent and Trademark Office
I
issued the '187 patent.
34.
On information and belief, Defendants' infringement of the '187 patent has been and
continues to be intentional and willful.

Defendants offer two variations of infringing plates in a four (4) pack and six (6) pack
35.
variations. See Exhibits 4 and 5.

The Jarratts offer taco plates that were made in the USA that were manufactured in
36.
Arkansas. See Exhibits 2 and 3.

The Jarratts provide such taco plates to Wal-Mart through Wal-Mart's Made in America
37.
campaign. See Exhibits 2 and 3.

38.
Defendants falsely advertise that the infringing plates were made in the USA. See
Exhibits 4 and 5.
39.
The infringing plates sold by Defendants were actually made in China despite being
r
advertised as Made in the USA. See Exhibits 7 and 8, showing pictures of the bottom of the
infringing taco plate and packaging showing that the plates are made in China.
40.
Consumers and the public purchase the infringing taco plates under the belief that the
infringing taco plates are made in the USA due to the Defendants' false marketing. See Exhibits
2-3 (showing the Jarratts' American made products) and 4-5 (Defendants' false marketing).
41.
Consumers and the public are not made aware that the infringing taco plates are made in
China until after the consumers receive the infringing plates from the Defendants.
42.
Defendants' bait and switch of offering American made products and then providing
Chinese made products irreparably harms the Jarratts and the Jarratts' reputation.
43.
Infringing on both the Jarratts' patent and trademarks, Defendants harm Jarratt Industries'
reputation as a company that provides products Made in the USA.

COUNT 1
Patent Infringement
44.
The Jarratts incorporate the preceding Paragraphs of their Complaint as if fully rewritten
here.
45.
Defendants have made, used, offered to sell, sold, and/ot imported into the United States,
and continues making, using, offering to sell, selling, and/or importing into the United States,
taco plates having designs that infringe the '187 patent without Jarratt's authorization.
46.
Defendants have also sold and exposed for sale and continue to sell and expose for sale
Jarratt's patented design or colorable imitation thereof.

47.
Defendants sell and expose for sell an infringing plate that is a sufficiently similar design
to Jarratt's patented design.

48.
The infringing plate and Jarratt's patented design share sufficient similarities such that
the infringing plate and Jarratt's patented plate stack upon each other.
49.
On information and belief, Defendants' infringement has been intentional and willful,
making this an exceptional case.

50.
Jarratt has been and will continue to be irreparably harmed by Defendants' infringement
of the '187 patent.
COUNT 2- Unfair Trade Practices (15 U.S.C.1125(a))
51.
here.
52.
Defendants' sell and offer of sale of the imitation plates creates unfair competition
against Jarratts.
53.
Defendants' use of Jarratt Indusries and Jarratt Industries (with Industries misspelled), for
goods that are identical, related, and/or substantially similar to those produced by the Jarratts
constitute a false designation of origin and a false representation as to the origin of Defendants'
infringing plates is likely to cause confusion, mistcike, or deception as to the source of
Defendants' goods and is likely to create the false impression that the goods are authorized,
sponsored, endorsed, licensed by, or affiliated with the Jarratts. Defendants' actions constitute
unfair competition in violation of Section 43(a)(l)(A) of the Lanham Act, 15 U.S.C.
1125(a)(l)(A).
54.
Defendants deceived and continue to deceive potential customers by misrepresenting the
Defendants' goods as the Jarratts' own goods.

55.
Defendants' conduct is willful, intended to reap the benefit of the goodwill of the Jarratts
and violates Section 43(a)(l)(A) of the Lanham Act, 15 U.S.C.

56.
1125(a)(l)(A).
Defendants' conduct has caused and is causing immediate and irreparable injury to the
Jarratts and will continue both to damage the Jarratts and deceive the public unless enjoined by
this Court.
COUNT 3
Common Law Trademark Infringement, Unfair Competition, and

False Designation of Origin or Description
57.
here.
58.
Defendants' use of Jarratt Indusries and Jarratt Industries is likely to cause confusion,
mistake, or deception as to the source or sponsorship of the Jarratts.

59.
Defendants' sale of infringing plates under the trademark Jarratt Indusries and Jarratt
Industries, constitutes commercial use of a trademark, or a false designation of origin, or. a false
or misleading description or representation of fact which is likely to cause confusion, mistake or
deception as to the affiliation, connection or association of Defendants with the Jarratts, or as to
10
the origin, quality, sponsorship or approval of Defendants' goods or associated activities thereby
causing damage to the reputation of the Jarratts' products and trademarks.
60.
Defendants' goods as the Jarratts' own goods.

61.
Defendants' goods as Made in the USA.

62.
Defendants' misconduct alleged herein constitutes commercial use of a trademark, or a
false designation of origin, or a false or misleading description or representation of fact which in

commercial
advertising
or
promotion
misrepresents
the
characteristics
or
qualities
of
Defendants' products or commercial activities.

63.
By engaging in the misconduct alleged herein, Defendants have infringed the Jarratt
Industries mark and the Jarratt Industries' rights in the Jarratt Industries mark.
64.
Defendants' knowledge of the Jarratt Industries' prior use of the Jarratt Industries mark
demonstrates such activities were, and remain, willful and intentional.

65.
Defendants' willful and intentional acts of infringement have caused and are causing
great injuries to the Jarratts' business, the value of the Jarratt Industries mark, and the Jarratts'
goodwill and reputation, in an amount that cannot yet be ascertained. The Jarratts are entitled to
an award of damages compensatory of these injuries caused by Defendants, the continuation of
which unless restrained, will cause further irreparable injury and damage, leaving the Jarratts
with no adequate remedy at law.
66.
Defendants' continued unauthorized use of the Jarratt Industries mark constitutes
common law trademark infringement and unfair competition.
11
67.
By reason of Defendants' misconduct, the Jarratts are entitled to preliminary and
permanent injunctive relief against Defendants,_ and anyone acting in concert with Defendants,
enjoining further acts of infringement, unfair competition, false advertising and false designation
of origin.
68.
As a direct and proximate result of the intentional misconduct of Defendants alleged
herein, the Jarratts are entitled to recover Defendants' profits in an amount to be determined at
trial, plus enhanced damages based on Defendants' willful, intentional, and/or grossly negligent
acts, plus attorneys' fees.
COUNT 4 - Violation of the Arkansas Law under Deceptive Trade Practices Act
(Ark. Code Ann. 4-88-101, et seq.)
69.
here.
70.
Defendants' acts constitute unfair trade practices in violation of the Arkansas law and
specifically the Arkansas Deceptive Trade Practices Act, Ark. Code Ann.
4-88-101, et seq., for
at least the following reason:

a.
Defendants are using the Jarratt Industries mark knowingly to make false
representations as to the characteristics, uses, benefits, source, quality sponsorship or approval of
Defendants' infringing products; and

b.
Defendants, by causing confusion as to origin of their services and products, are
engaging in unconscionable, false or deceptive acts or practices in business, commerce or trade.

71.
Defendants' goods as Jarratts' own goods.
12
72.
Defendants' goods as Made in the USA.

73.
Defendants' willful and intentional acts have caused and are causing great injuries to the
Jarratts' business, the value of the Jarratt Industries mark, and the goodwill and reputation, in an
amount that cannot yet be ascertained.
74.
By reason of Defendants' misconduct, the continuation of which, the Jarratts are entitled
to preliminary and permanent injunctive relief against Defendants, and anyone acting in concert
with Defendants, enjoining further acts of infringement, unfair competition, false advertising and
false designation of origin.
7 5.
Furthermore, in view of Defendants' knowledge of the Jarratt Industries' prior use of the
Jarratt Industries mark, such activities were, and remain, willful and intentional.
76.
As a direct and proximate result of the intentional misconduct of Defendants alleged
herein, the Jarratts are entitled to recover Defendants' profits in an amount to be determined at
trial, plus enhanced damages based on Defendants' willful, intentional, and/or grossly negligent
acts, plus attorneys' fees.
COUNT 5-Tortious Interference with Prospective Business Relations
77.
here.
78.
At all times material hereto, the Jarratts' have had prospective business relations and
expectancies with customers of the Jarratts' products sold under the Jarratt Industries mark and
company name and the '187 patent.
79.
Defendants were aware of, or should have been aware of, said prospective business
relations.
13
80.
The misconduct of Defendants alleged herein tortiously interfered with said business
relations, and with said prospective customers and expectancies; such misconduct includes,
among other things redirecting customers searching for the Jarratts' goods to Defendants'
competing infringing goods that infringe the Jarratts' patent and trademark and goods that are
deceptively marketed to the public as Made in the USA.
81.
Defendants' continued unauthorized use of the Jarratt Industries mark has interfered with
and impaired the Jarratts' ability to advertise and serve its customers.
82.
Defendants have employed improper means by using the Jarratts' mark without the
Jarratts' consent.
83.
Defendants' goods as Jarratts' own goods.

84.
Defendants have an improper motive to profit from and exploit the Jarratt Industries mark
on confusingly similar goods without the Jarratts' permission and without compensation.
85.
In view of Defendants' kllowledge of the Jarratts' competing business and goods, such
deceptive activities were, and remain, willful and intentional. The Jarratts and the public have
been injured by such activities.
86.
As a direct and proximate result of the misconduct of Defendants alleged herein, the
Jarratts are entitled to recover Defendants' profits in an amount to be determined at trial, plus
enhanced damages based on Defendants' willful, intentional, and/or grossly negligent acts, plus
attorneys' fees.
87.
Some of the misconduct of Defendants alleged herein has been committed with malice, or
with reckless disregard for the injury that such misconduct would cause to the Jarratts, entitling
the Jarratts to punitive or exemplary damages.
14
WHEREFORE, the Jarratts request a jury trial on any issues so triable, and the Jarratts
respectfully pray for the following relief:

A.
Judgment that Defendants willfully infringed the '187 patent in violation of 35 U.S.C.
271(a);
B.
An award of damages adequate to compensate Jarratt for the patent infringement that has
occurred pursuant to 35 U.S.C.
284, which shall be trebled as a result of Defendant's willful
patent infringement, or an award of Defendant's profits from its infringement pursuant to 35

U.S.C.
289, whichever is greater, together with prejudgment interest and costs;
C.
A preliminary and permanent injunction against further infringement of the '187 patent
by Defendants, their agents, servants, employees, officers, and all others controlled by them;
D.
An award to Jarratt of attorney's fees, costs, and expenses in this action pursuant to 35
U.S.C.
285, with prejudgment interest; and
E.
A preliminary and permanent injunction enjoining Defendants, their employees,
agents, officers, directors, attorneys, representatives, successors, affiliates, subsidiaries and

assigns, and all those in concert or participation with any of them from:
(a)
imitating, copying, using, reproducing, registering, attempting to register and/or

displaying any mark so resembling any of the Jarratt Industries' marks as to be
likely to cause confusion, mistake or deception therewith;
(b)
using any false description or representation or any other thing calculated or likely
to cause consumer confusion, deception or mistake in the marketplace with regard
to the Jarratt Industries' marks or products sold thereunder;
(c)
An order for corrective advertising in a form, manner and frequency that is

acceptable to the Jarratts and the Court;
15
F.
An order directing that Defendants file with the Court and serve upon counsel for
the Jarratts within thirty (30) days after the entry of such order or judgment, a report in writing
and under oath setting forth in detail the manner and form in which it has complied with this
Court's orders;
G.
Judgment against Defendants, awarding the Jarratts such damages which have
been sustained or will sustain by reason of Defendants' acts of patent infringement, trademark
infringement, and unfair competition and that such sums be trebled pursuant to 15 U.S.C.
1117;
H.
Judgment against Defendants, awarding the Jarratts all profits of Defendants
resulting from its misconduct alleged herein, in an amount to be proven at trial;

I.
Judgment against Defendants, awarding the Jarratts enhanced damages based
upon Defendants' profits after an accounting thereof, including all statutory enhancements and
other enhancements on account of the willful nature of Defendants' misconduct;
J.
An award of prejudgment and post judgment interest;
K.
An award of the Jarratts' costs iand expenses, including, without limitation, the
Jarratts' attorney's fees incurred herein pursuant to 15 U.S.C. 1l17(a); and

L.
All other relief, in law or in equity, to which the Jarratts may be entitled, or which
the Court deems just and proper.
Respectfully submitted,
Hugh Jarratt, and
Jarratt Indus
lo-\- \l,
Date
s, LLC, Plaintiffs
Stephen D. Schrantz
Arkansas Bar No. 2006215
16
Schrantz Law Firm, PLLC

1000 East Matthews, Suite C
Jonesboro, AR 72401
(870) 275-7838 - Telephone
schrantzlaw@gmail.com
17
Case 5:16-cv-05302-PKH Document 1-1
I lllll l llllll Ill llll llll l llll lll l lllll lllll l lll lll l lllllll II llll llll
USOOD574187S
02)
(54)
(76)
United States Design Patent
(10)
Patent No.:
Jarratt
(45)
Date of Patent:
S * 6/2004
S * 8/2004
D545,127 S *
6/2007
D563,166 S "'
3/2008
2004/0222228 Al * I 1/2004
DIVIDED PLATE FOR SEPARATING FOOD

Invento:
Hugh Jarratt, 1649 N. Viewpoint Dr.,

Fayetteville, AR (US) 72701
(**)
Term:
(21)
Appl. No.: 29/292,196
(22)
Filed:
(51)
LOC (8) Cl.
(52)
U.S. CI.
(58)
Field of Classification Search
14 Years
..................................................
............... .........................
07-01
07/504; D7/555
. ... .. .... . .... ...
D7/500,
220/574, 575, 500

See application file for complete search history.
D363,413
D374,15 l
D428,809
D487,860
Wiedmeyer et al. .... ...... D7/543

Fife ..... ............. .... ...... D7/504
D7/554.2
Woolfolk et al. .. . .......... D7/504

Price ............. ..... ...... .. 220/574
cited by examiner
(7 4) Attorney, Agent, or Firm-Keisling Pieper & Scott PLC;
991426; 211/126.1; 206/557, 561, 521.15;
DJ99,J94
Levien
Stephen D. Schrantz; Trent C. Keisling
D9/426; D28/61, 73; D30/130; 108/25;
DI 15,876
.. .. .... .. .... ..... ..
D490,656
D494,816
Assistant Examiner-Cynthia Underwood
D7/504, 555, 357, 541, 553.1, 553.6, 554.2;
2,677,350
Aug. 5, 2008
Primary Examiner-Philip Hyder
Oct. I, 2007
(56)
US D574,187 S
**
CLAIM
(57)
The ornamental design for a divided plate for separating food,

as shown and described.
. DESCRIPTION
FIG. 1 is a perspective view of a divided plate for separating
food showing my new design;
References Cited
FIG. 2 is a front elevational view of the design ofFIG. l;
U.S. PATENT DOCUMENTS
FIG. 3 is a rear elevational view of the design of FIG. I;
S
A
S
S
S
S
S
*
*
7/1939 Deynzer .. .. ... ...... ........ . D7/541
FIG. 4 is a left side elevational view of the design ofFIG.1;
511954 Prestidge et
FIG. 5 is a r ight side elevational view of the design ofFIG.1;
"
911964
"
10/1995
10/1996 Malvasio
*
*
8/2000
Patton,
Smith
al . ......... 119/61.53
Jr. .................... D7/555
.. ....... ..... ........ . .. .
D7/504
... .... .......... ... .
D7/504
............. ... ..... ... .
D7/504
FIG. 6 is a top plan view of the design ofFIG. 1; and,

FIG. 7 is a bottom plan view of the design ofFIG. 1.
Adair ........ ............ .. ... . D7/555
3/2004 Turner
1 Claim, 3 Drawing Sheets
Exhibit 1
U.S. Patent
Aug. 5, 2008
Sheet 1of3
FIG.1
FIG.2
FIG.3
US D574,187 S
U.S. Patent
Sheet 2 of 3
Aug. s, 2008
"\.\ti!;-;:
r---*>:-:-u
FIG.4
r i--fi',<---- '>':2:r
FIG.5
FIG. 6
US D574,187 S
U.S. Patent
Aug. 5, 2008
Sheet 3 of 3
FIG_ 7
US D574,187 S
Walmart Orders One Million Taco Plates From

Local Inventor
POSTED 7:16 PM, JULY 9, 2014, BY ELLEN THALLS
This is an archived article and the information in the article may be outdated. Please look at the time stamp on
the story to see when it was last updated.
A Fayetteville man had an idea to invent a plastic taco-holder when he was a student at the
University of Arkansas, and on Tuesday, Hugh Jarratt had the biggest sale of his life--
Walmart bought one million taco plates.
"I ate way too many tacos in college," He said, "And I got tired of them falling over."
Exhibit 2
Walmart had their first ever "open-call" for U.S. inventors as part of a new initiative to get
more American products on their shelves. Jarratt was one of 800 inventors to go before
Walmart buyers to pitch their inventions to secure a sale.
Jarratt's wife and business partner Nicole said reality hadn't sunk in as of Wednesday
afternoon.
"Last night for a second, we were like so we now have to produce a million taco plates," His
wife said, "Where do we start? Where do we go from here?"
The couple said they first started selling their taco plates five years ago at the War Eagle
Craft fair. After selling most of his inventory, Jarratt said he realized he needed to look for a
local manufacturer.
"I Googled injection molding in Arkansas, and the first one that comes up in Poly Tech
Molding Inc.," He said.
The couple said they immediately felt welcomed by the Prairie Grove company, which was
only a 30 minute drive from their home.
"It just feels good to be able to work with people, and give them more business that are
really kind of like our neighbors," Jarratt said.
Poly Tech plant manager Gaylene Deere said the million plate sale will bring in huge
production numbers for their company. Right now the company employees 50 people, but
the massive sale will give the local business an opportunity to employ up to 10 more.
"We are ecstatic," Deere said, "We are really happy for Hugh, and for Poly Tech
Molding...that's going to give us the opportunity to create more jobs in the area and just
grow with him."
Both Jarratt and Deere are proud that the taco plate is a local product. Jarratt is a
Fayetteville native, the manufacturer is in Northwest Arkansas and many of the raw
materials including packaging and dyes come from Fort Smith.
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28 customer reviews
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by JARAATTINDUSRIES LLC
***** ..
12.l 11 "JI
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(Set/4) Taco Divider Plates Set Keep Shells Upright Dish W/ Side
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I ncludes separate sections for rice, bean s or other
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High-<iensity reusable plastic is grease and stain
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This item: (Set/4) Taco Divider

Plates Set - Keep Shells
Upright
Fiesta Taco Pl ates SP.t of 4

by Wa!terDrake
of Six Muit1 Colored Plates
/orange/yellow
Fiesta Taco
Hol der Plates
Set
Taco Plate Set of 4 Greenfblue
Dis h WI Side Se<:tions
Customer Rat ing
*1.:ritrtrtr
*-(((115)
f(54)
****ir (35)
Pnce
$14.95
$14.49
$22.49
$17.99
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Sold By
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Wire Whisk
Color
Red
Red, biue. orange and green,
Assorted
green, orange, yellow, blue
each plate is
color
n nc --.. -"" ...
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..
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Product Description
Taco Divider Plates Set
Handy plates with dividers
keep hard or soft taco shells upright while you prepare AND eat them! Includes separate sections for rice, beans
is grease and stain resistant. Set of 4. Microwave/dishwasher safe. US made. 13'x 8. 75'.
or other sides. High-density reusable plasbc
Product Information
9
13 x
ltemWeight
15.2 ounces
Feedback
2 inches
Product Dimensicms
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15.2 ounces (View shipping
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Manufacturer
JARRATT INDUSRIES LLC
ASIN
BOOL3H82DQ
Customer Reviews
trJ:rk'trtl
28 customer
reviews
4.8 out of 5 stars

Best Sel!ers Rank
#30,972 in Home
& Kitchen (See
Top 100 in Home
& Kitchen)
#44 1n Kitchen & Dining > Tabl et op

> Plates > Accent Plates
Date first available
at
June
1 a. 2014
Amazon.com
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Customer Reviews
4.8 out of 5 stars T

5 s tar
4
star
star
?. 51ar
,..------....._,
86%
Share your thoughts with other customers
11%
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------._,
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customer re,iews
Top Customer Reviews
Ad feedback 0
*1rtrt:l* Terrific Taco Plate!

By
Pierrot o n
September 19 2016
Most Recent Customer Reviews
Verifie<l Purchase
We do
Taco Tuesdays,
and I
have been looking for a gift for my daughter "The
No only do we have the upright holders for her tacos,
but now
Cook".
These are just perfect!
we have separate places for beans, salad, rice.
olives or sour cream. The tacos stay crisper now!
*****
Fun plates
Love these plates. TI1ey are fun and colorful Easily
holds your tac os and sides. Also dishwasher safe for

easy clean up.
Comment
Was this revi ew helpful to you?
TJJ."ti:'trtr<tl:
Great product for the price!
r-y;-j
Published 1 month ago by Oa'hn
Report abuse
***** Five Stars

It
By Lou G on February 22, 2015

Verified Purch3.se
Great product for the price. The photo shown looks almost what my
tacos I made when
I first
tried it. So
handy to keep taco shells upright, whether solid shells, m fried soft shells, or plain flour tortillas. I bought a
set for my Dad in NM also, and he likes them!
One
Comment
per son found this
1f"k1f"t?<{;rLove
Perfect for Taco Tuesday!
Publishe'14
helpful. Was this r eview helpful to you?
Report abuse
months ago b; Doug
***** I
love to use these plates.
These plate help keep you taco filling in the taco
i'<*'n'.'n:r Great!
By Patric e
was exactly as pictured.
Published 3 months ago by Amazon Customer
shell.
Salinas on May
16, 2015
Published 5 months ago by scubadiver
Veritied Purchase
At first I
didn't think the holders were deep enough. But I was wrong. These were so ni for serving tacos and
some sides.
I wanted them for dominoe night,
they were perfect. And such colors! My friends loved them. I
would definitely recommend.
***** Five Stars

These are great for taco night! Love that they're
microwaveable and dishwasher safe.
Published 7 months ago by Ji!!
Comment
Was this review helpful to you?
1411r***
Absolutely LOVE these plates
Report abuse
****'* Five
Stars
Finally able to keep our tacos upright'

Published B months
By Deana Gascoigne on August 24, 2016
ago by debra a porwoll
Venf:ied Purchase
Absolutely LOVE these plates . I use them in our camper. We love hard shell tacos and these make dishing
up for a meal very easy. They aren't very big if you want large servings of sides (beans, rice. etc ... )
can always go back for seconds. The important thing is that making your tacos is a
but you
breeze! When camping
***tI-* Very Good
Seller
Taco plates arrived
shape just as advertised
surgeries
easy to hold onto.
Publishe'1 8
Was this re,ew helpfJI to you?
":d4<{;r"(J.r(J(
L.....:".....
25, 2015
*"**** Nice deal, good size.
My husband and I love tacos and always fight to keep them upright when filling them up. These plates
'OU to fill three tacos and keep them from tipping over and spilling the goods. LOL
TI1e two areas at the front are great for rice and beans. We love taco night at home even more now.
Comment
Was this
t::r1rtrlir1:
These plates work great for taco night
By
Linda
Five Stars
Publishe'1 8 months ago by Carrie Kennedy
'.k:rified Purchase
reV1ew helpful
to you?
Report abuse
allow
Nice deal. good size.

Published 1 year ago by
****\')
Taajer
fun to use
does the job wish it was stiffer. but they sure are fun
to use.
Published 1 year ago by 4birds
F Elliott
on April
21. 2015
of illness &
LOVE this!!!!! These are great!l!
Fun and functional
By Renata P on July
Product!
months ago tr1 Mikey Faulds
*****
Report abuse
&
Sorry Fm so late with review, because
we don't always have a "table" to sit at so we are sitti ng in chairs to eat. These plates are light weight and
Comment
in good
Search Customer Reviews

L
J lif@I
These plates work great for taco night. It's so ni ce to have the tacos keep falling over on the plate. My
granddaughters love them and enJOY picking out the color tha want for that meal. Anyone who eats tacos will
enjoy th e convenience of use.
pful
One person found th15 helpfui Was this reV1ew hel
Comment
*****
By Shirley
Report abuse
to you?
Five Stars
E on May 15, 2015
Verified Purchase
tto
Love them and they e en work with the flat bo

Comment
2 people found this he l
1;(1;('f:l-tr*
Perfect!
By
______ ________
pful.
m taco's.
pfu
i to you?
im y- l c 14 1 Report abuse
Was hi s review helpfui to 'ou?
Report abuse
Was this Te\lleW hel
A. Ellis on January 7. 2015
Verified Purchase
Perfect plates for tac
Comment
night[
people found this helpful
See all 28 customer reviews (newest first)
Write a customer review
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6 Double Dipper Bowl
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POCAHONTAS, AR 72455
6 Taco Plates
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!
0 This item: Fi es ta Taco

0 IMUSA.
Holder Plates Set of Six
t>.dd both to U.1
Mul ti
Colored Plates
MEXl-1000-TORTW. TorU!ia Warmer. Brick Color. 8 5-inches
$22.49
$5.99
l'fi&MI@
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l.... . . . ...J
>
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Ser,ing Taco's
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IMUSA, MEXl-1000-
Perfoct for
'f:rtrl"t;'. 302
TORTW. Tortilla Warmer,
$7 01
Brick Color. 8 5-inches
./Prime
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Exhibit 5
Page
1 of6
Case
Document
1-5
Perlli
i5:16-cv-05302-PKH
l d Condiment
Sunselia Buddy Boxes
Ch l e
Ser;er en ice with
Removable Containers
Filed 10/25/16
Page
PageID
#: -33
Wo.,,i
y
Bowl
Safe, Heavy
Duty 2 of 6
Pistachio
Modern Innovations
o.,,n
3 Compartment
Stainless
Stainless Steel Bakin g
Contamers (4 Pack)
Wine Glasses,
Steel Stemless
Set of 4,
SeMng lray
Reusable Bento Lunch ...
18 Oz Made of
i'{60
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$13 89 ./Prime
**frlrl:! 97
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Rack & Cooling Rack, 12

x 17 inches Fits Half.
Bowl
with Prsiachios Shell
Double D;sh Nut
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Green
*****372
***** 49
$16.99 .;p,,,,,.,
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Product Description
Perfect
for parties
Prodm::t Information
Size:6 Taco
Plates
Warranty & Support
Product Oimensmns
14.4 x 8.5 x 2-2 inches
ltemW.,.ight
1.6 pounds
Product Warranty:
1.6 pounds (View sh;ppmg rates and
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Manufacturer
Jarratt lndustnes
ASIN
B009YKH3MO
Customeir
reviews
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#37,993 in Home and Kitchen (See Top
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This item: Fresta Taco Holder
Plates Set
of Six Multi Colored
Plates Set
Shells Upright Orsh W/ Side
(Set/4) Taco Divider
Taco Plate
WalterOrake
Keep
iorange.lyellow
Plates
Sections
Customer Rating
f!ltttrtJ (54i
***14>':?
Price
S22.49
Shipping
Sold By
Color
(115)
***** (28)
'llf!it1ri? (35)
$14.49
$14.95
$17.99
FREE Shipping
FREE Shipping
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CT DISCOUNT STORE
Natural S t ate Mercantr!e
CT DISCOUNT STORE
Wire Whisk
As so rt ed
Red. blue, orange and green. each
Red
green. orange, yellow. blue
0.85 pounds
0.95 pounds
1.1 pounds
Plastic
Plastic
Plastic
plate is a sol.id diflement color

Item Package Weight
Material
Set of<! Green/blue
Fresta Taco Plates, Set of 4 by
1.6 pounds
Plastic
Case 5:16-cv-05302-PKH
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'
Premium
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Customer Questions & Answers

0,.,
HzrJt- a qu(:stlor(>
A.
0
vot es
Sr::-:i.rch fur answar..;

What material is used?
Question:
Plastic .
Answer:
By
"'
A.
0
votes
Patricia A Smith on
Question:
Are these BPA free?
Answer:
Yes they are BFA free
March 21
By Boen Sales on December
"'
2015
24 2015
SELLER
"' See more answers (2)
A.
What's th size of th e plates?
Question:
13" x
Answer.
votes
9"
8' Patnc1a A.
..,..
Smith on May 4 2015
Customer Reviews
4.4 mit of S
5
f!tars "'
star
74%
4 star
-----: 17%
3 star
3%
2 sta1
2%
1 star
i'"----...
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Share y o ur thought s with other customers
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fil"41.Prlii? 113
$18.04 vPtlme
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Top Customer Reviews

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***><t.rtl:
Awesome Plates
By Libby Cherry on A.prii
SlZe 6 Tato
iiJ. 2013
Most Recent Customer Reviews
Venfied Purchase
Plates
frequently. I just bought these several weeks ago and they are great! Well made, holds
can load them up. and wash up nicely in the dishwasher
We love tacos and have them pretty

our tacos well so we
***'(:rC:l Looking forward to double dip of

pleasure!!
They are very cute
Comment
1"****
Great!
people found this helpiui Was this m;ew helpful to you?
and rm
sure
I will en1oy them.
Had a
specific plan m mind and then plans changed so havenl
Report abuse
actually used them yet!
By Earl Chandler on
Size
6 Taco Plates
Published 11
January 17. 2014

Veri!ietl Purchase
Gave these as a gtfl and did they go over big!! Will order some for myself. Like that there are
6 and not the normal 4 in
pkg
Comment
*'****
da1s ago by Eitee-n
***** Five Stars

plates are larger than we thought which 1s
The
great and
they are perfect !
f'ublished 20 da1s ago by Lyon Milne

6 people found this helpful Was this re,iew helpful to you?
Taco Eatin Essentials
By Jeff on Febmary
14. :'.015
I Y [ - N; -J Report abuse
1
*****
Fun and Festive!!
These dishes are really nice and work great for seo.ing
tacos. They are sturdy
fun!
and
roomy
and very colorful.
Lots of
all of the co nt ents on th e table. Now, you
can put that off until you
bite into th e taco

Puonsnea 21 oays ago oy Luzuma
These plates are great on "Taco N ight... No more v.ill you perfectly construct your t aco s only to
have them fall over and spill

and the bottom cr ac ks and spills the
cont ents down your shirt ffont.
'llr**'kw Nice set

Great set of bowls for company, easier to serve salsa and
ch ips or dip and veggies.
One person found this heipful
Comm ent
Was thi s re'llew helptV to you?
Pub!Jshed 1 month ago
irtrizw Ta co night just got more fun and less messy

By M. Aziz on September 23 2014
Size 6 Taco Plates
****'* So convenient!
pl atesf The colors are fun.
Microwaveable and dishwasher safe
salsa and its great the re is
people found tl11s
hel pfu L
Was tl11s
. .] Report abuse
re;iew he lpful to you?
just one
them for chips and
dish to clean.
Published 1 nw11h ago by Amanda J
Q uality Made in the USA enough said!
Comment
by b1ue eyes
These bowls are amaz ing! I u sually use
Vemied Purchase
Taco night just got more fun and less messy. LO''e these
Nice array of colors. Great for
summer time outdoors, no worry about gl as s breaking.
Report abuse
***** Five Stars

Cute
Publishe<l 1 monn1 ago by AHson
'A''iill"** These plates are such a great idea. They have space for three to four ...
By MySnow on March 11!, 2016
Size: 6 Taco Plate s
1'r'k1l-** Great for parties
Venlied Purcllue
Purchased the set of six
taco
plates for use
by our family
I purchased these to use at a large gathering so that each

chips and dips. Worked great .
Oh, and they wash beautifully in the top shett of the
of ffequent taco makers and eaters. Yay! No more taco ho lders
table would haw ifs own
that slide all over your plate. These plates are such a g reat idea They have space for three to four tac os : we make the
regular hard shell tacos. Two sections al one end can hold extras such as refried beans, toppings. The length of the
i nternal space of the
plate is 11
inches; this is not including the external lip of
the plate ,
dishwasher.
so a \'l!fY good size. S turd y and
Published 1 month
easy to hold .
Comment
One person found this helpful.
Was thi s re'/lew helpfui to you?
1'1fr11l** Taco night is so much better with these

plates
[ 'f.i:!] [.J Report abuse

__
of you tacos falling over as

plates'!! LOVE
scientific mom on October 28 2()14
Size
6 Taco
Published 1 month a90 bt A.mazon Customer
Plates
We love these, the kids especially. And ii
with these plates! tt your tired

you make them you need these
Taco night is so much better
** great for parties, and kids!

By
a go by Oleta Mcgregor
makes fil ling tacos
much easier! The smallest taco slot definitely onty fits what
would cal l a "regular" size taco shell. The bigger ones they ha\'1! in stores l ately fit in the other two slots. The sta n d n stu1f'
flat bot toms donl fit. however. these stand them for you anyway! For people who want both hard and soft
shell, I put the soft shell m th e middle bet.veen two hard shells and they hold the soft shell up.
The two side spots fit rice and beans well. or guacamole, sour cream, pico de gallo, etc. We\.., put them in the micr owave
and dishwasher (top rack) may times, and they hawnl warped or anything. Ordering more as a gilt!
shells with the
"'1fi1rf11r(:r(; Three Stars

what I expected
Published 3 months ago !>'!Kenneth R. McMil!an
not
"'1f'1rir1rCr Otherwise a very good buy.

Wish the dish itself was a little deepe r . Tacos want to bend
Comment
'{;rk
Taco Ptates
By
Magda on
Size
6 Taco
people found this hel pfu l \Nas !his rei.ew helpful to you?
f..-..i:J i. _!_:>_J Report abuse

_
in assorted colors
Verified Purchase
,<>-
TACO PLATES:
At last. NO
Published 4 months ago by Barbara H
Search Customer Reviews
December 28. 2013
Plates
over and not sta nd upright. Otherwise a very good buy.
J ''d'
more spilled tacos. These work great and makes it easier to make tacos and have them stand up!
Like the color asst. too
Comment
J p eopl e found this helpfui. Was this re-.irn helpful to you?
L!_e.::_ _ j
Report abuse
1'Ji''lf:r*tt THE BEST

By JK Brad y on J anu ary 7. 2014
Size: 6 Taco Pl ates 111'rilied Purd>aR
These are so fun and fuclionablell We love them! an d all the children want them also ...( will give them the website:)
Comment
See all
2 peo ple found this
customer
hel pful .
Was this re-,,ew helpful to you?
reviews (newest first)
Report abuse
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This item: Fiesta Taco Holder Plates Set of Six Multi Colored Plates
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ti:i pn.t't!. :t t'.i pncc tn.'3.i;:mtc tee .ts ,m tte $!!'QC o:mcitnn.
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Jarratt v. Amazon - Complaint

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Jarratt v. Amazon - Complaint

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Case 5:16-cv-05302-PKH Document 1

Filed 10/25/16 Page 1 of 17 PageID #: 1

IN THE UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF ARKANSAS

JARRATT INDUSTRIES, LLC,

an Arkansas Limited Liability Company

JURY TRIAL REQUESTED

Plaintiff Hugh Jarratt (hereinafter referred to as "Jarratt") is an Arkansas resident residing

Plaintiff Jarratt Industries, LLC (hereinafter referred to as "Jarratt Ind.") is an Arkansas

Defendant Amazon.com, Inc. (hereinafter referred to as "Amazon") is, upon information

Case 5:16-cv-05302-PKH Document 1

Filed 10/25/16 Page 2 of 17 PageID #: 2

Furthermore, Defendants intentionally and maliciously pirated and infringed upon a

patent and trademark belonging to the Jarratts located in Fayetteville, Arkansas.

Case 5:16-cv-05302-PKH Document 1

Filed 10/25/16 Page 3 of 17 PageID #: 3

taco plates and other kitchen utensils and cooking products.

Natural State Mercantile and Wire Whisk.

Case 5:16-cv-05302-PKH Document 1

Filed 10/25/16 Page 4 of 17 PageID #: 4

Defendants' infringing plates by CT Discount Store, Inc.

plates on Amazon's website located at Amazon.com.

Amazon directs potential customers to purchase from CT Discount Store, instead of

Case 5:16-cv-05302-PKH Document 1

Filed 10/25/16 Page 5 of 17 PageID #: 5

concerning competing products.

Chart 1 below demonstrates Defendants' infringement by comparing figures of the '187

patent with the Infringing plates sold by Defendants.

Case 5:16-cv-05302-PKH Document 1

Filed 10/25/16 Page 6 of 17 PageID #: 6

Case 5:16-cv-05302-PKH Document 1

Filed 10/25/16 Page 7 of 17 PageID #: 7

issued the '187 patent.

Case 5:16-cv-05302-PKH Document 1

Filed 10/25/16 Page 8 of 17 PageID #: 8

continues to be intentional and willful.

variations. See Exhibits 4 and 5.

Arkansas. See Exhibits 2 and 3.

campaign. See Exhibits 2 and 3.

reputation as a company that provides products Made in the USA.

Case 5:16-cv-05302-PKH Document 1

Filed 10/25/16 Page 9 of 17 PageID #: 9

Jarratt's patented design or colorable imitation thereof.

to Jarratt's patented design.

making this an exceptional case.

of the '187 patent.

COUNT 2- Unfair Trade Practices (15 U.S.C.1125(a))

Case 5:16-cv-05302-PKH Document 1

Filed 10/25/16 Page 10 of 17 PageID #: 10

Defendants deceived and continue to deceive potential customers by misrepresenting the

Defendants' goods as the Jarratts' own goods.

and violates Section 43(a)(l)(A) of the Lanham Act, 15 U.S.C.

Common Law Trademark Infringement, Unfair Competition, and

mistake, or deception as to the source or sponsorship of the Jarratts.

Case 5:16-cv-05302-PKH Document 1

Filed 10/25/16 Page 11 of 17 PageID #: 11

Defendants deceived and continue to deceive potential customers by misrepresenting the

Defendants' goods as the Jarratts' own goods.

Defendants deceived and continue to deceive potential customers by misrepresenting the

Defendants' goods as Made in the USA.

Defendants' misconduct alleged herein constitutes commercial use of a trademark, or a

false designation of origin, or a false or misleading description or representation of fact which in

Defendants' products or commercial activities.

demonstrates such activities were, and remain, willful and intentional.