SGR/12191978.

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FRIEDLAND VINING, P.A. 1500 San Remo Avenue Suite 200 Coral Gables, Florida 33146
(305) 777-1720 (305) 456-4922 telecopier

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF FLORIDA

Case No: __________


LITTLE LEAGUE BASEBALL,
INCORPORATED, a Federally
Chartered Corporation,

Plaintiff,

v.

A LITTLE LEAGUE LLC,
DR. RUBEN BRAVO, and
ANNMARIE BRAVO,

Defendants.
_____________________________/

COMPLAINT
Plaintiff, Little League Baseball, Incorporated (Little League), by and through
undersigned counsel, hereby brings this action against Defendants A Little League LLC (A
Little League), Dr. Ruben Bravo (Dr. Bravo), and Annmarie Bravo (Ms. Bravo) (collectively
Defendants), and alleges as follows:
NATURE OF THE ACTION
1. This is an action for preliminary and permanent injunctive relief, profits,
damages, and attorneys fees in connection with Defendants infringement of Little Leagues
federally registered marks in violation of 15 U.S.C. 1114(1); for Defendants unfair
competition in violation of 15 U.S.C. 1125(a); for Defendants dilution of Little Leagues
famous and distinctive marks in violation of 15 U.S.C. 1125(c) and Fla. Stat. 495.151; for
Defendants infringement and unfair competition in violation of the common law of Florida; and
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for Defendants interference with Little Leagues sole and exclusive right to use and authorize
the use of the term LITTLE LEAGUE in violation of 36 U.S.C. 130506.
PARTIES
2. Little League is a United States Federal Membership Corporation with its
principal place of business in Williamsport, Pennsylvania.
3. A Little League is a Florida limited liability company whose principal address is
1810 Northwest 7
th
Street, Miami, Florida 33125. A Little League can be personally served by
service on its Registered Agent, Maria E. Carrera at its registered address, 4238 SW 147
th
Court,
Miami, Florida 33185.
4. Dr. Bravo is a citizen of the State of Florida, resides at 4238 SW 147
th
Court,
Miami, Florida 33185, and can be personally served at his residence address.
5. Ms. Bravo is a citizen of the State of Florida, resides at 905 Brickell Drive, No.
1725, Miami, Florida 33185, and can be personally served at her residence address.
JURISDICTION
6. This Court has jurisdiction over the subject matter of the instant action pursuant to
the provisions of 15 U.S.C. 1121 and 28 U.S.C. 1331, 1338, and 1367.
7. This Court has personal jurisdiction over Defendants because A Little League
LLC is a Florida limited liability with its registered office and principal place of business in
Florida, individual defendants are residents of Florida, and a substantial part of the events giving
rise to the claims asserted herein occurred in this Florida.
VENUE
8. Venue is proper as to Defendants in this Court pursuant to the provisions of 28
U.S.C. 1391(b) and (c) because A Little League LLC is a Florida limited liability with its
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registered office and principal place of business in this District, individual defendants reside in
this District, and a substantial part of the events giving rise to the claims asserted herein occurred
in this District.
FACTS COMMON TO ALL COUNTS
9. Little League is the owner of various trademarks and service marks including, but
not limited to, LITTLE LEAGUE, LITTLE LEAGUE BASEBALL, and LITTLE LEAGUE
BASEBALL & Design (collectively the Little League Marks).
10. Little League is the owner of the following United States Federal Registrations for
the Little League Marks:
a. LITTLE LEAGUE BASEBALL, Reg. No. 642,433, in respect of
services in connection with the development of sportsmanship, clean play and athletic
ability of young boys through the medium of a planned program of baseball in
International Class 42;
b. LITTLE LEAGUE BASEBALL and Design, Reg. No. 1,028,942, in
respect of promoting and developing sportsmanship, team play, and athletic ability
through the medium of a planned program of baseball in International Class 41;
c. LITTLE LEAGUE BASEBALL and Design, Reg. No. 1,028,752, in
respect of t-shirts and sweatshirts in International Class 25;
d. LITTLE LEAGUE, Reg. No. 1,049,641, in respect of baseball uniforms
and baseball shoes in International Class 25 and baseballs, baseball bats, chest
protectors, baseball gloves, and batting and catching helmets in International Class 28;
and
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e. CHARACTER COURAGE LOYALTY LITTLE LEAGUE
BASEBALL, Reg. No. 1,464,669, in respect of baseball uniforms, caps, t-shirts and
sweatshirts in International Class 25, and conducting baseball programs for youth in
International Class 41 (collectively the Registrations).
True and correct copies of the Registrations are attached as Exhibit A.
11. Little Leagues Registrations have become incontestable under 15 U.S.C. 1065,
and thus constitute conclusive evidence of the validity of the registered marks, of Little Leagues
ownership of such marks, and of Little Leagues exclusive right to use such marks in commerce.
12. Exclusively since at least as early as 1939, Little League has continuously offered
services in connection with the development of sportsmanship, clean play, and athletic ability in
young boys through the medium of a planned program of baseball under the mark LITTLE
LEAGUE BASEBALL. The rights supported by such use of the LITTLE LEAGUE
BASEBALL mark and the goodwill associated therewith inure to Little League.
13. Exclusively since at least as early as 1950, Little League has continuously
licensed the sale of baseball uniforms, baseball shoes, baseballs, baseball bats, chest protectors,
baseball gloves, and batting and catching helmets under the mark LITTLE LEAGUE. The
rights supported by such use of the LITTLE LEAGUE mark and the goodwill associated
therewith inure to Little League.
14. Little League licenses the use of the Little League Marks to identify various
goods and services, which goods are sold and services are rendered by its licensees throughout
the United States, including metropolitan Miami, Florida.
15. Little League is a federally chartered corporation to which Congress has granted
the exclusive right to use and authorize the use of the designations LITTLE LEAGUE
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BASEBALL, LITTLE LEAGUE, and the like under 36 U.S.C. 130506. A true and correct
copy of 36 U.S.C. 130506 is attached as Exhibit B.
16. Defendants, with at least constructive knowledge of Little Leagues rights in and
to the Little League Marks, have adopted and used the designations A LITTLE LEAGUE
LEARNING CENTER and LITTLE LEAGUE LEARNING and the domains
www.littleleaguelearning.com and www.alittleleaguelearningcenter.com to identify their child
care center and child care and educational services in Miami, Florida. True and correct copies of
materials taken from Defendants www.littleleaguelearning.com and
www.alittleleaguelearningcenter.com websites showing use of A LITTLE LEAGUE
LEARNING CENTER and LITTLE LEAGUE LEARNING are attached as Exhibit C.
17. Defendants have no affiliation with Little League.
18. As a result of Defendants adoption and use of the designation A LITTLE
LEAGUE LEARNING CENTER and LITTLE LEAGUE LEARNING and the domains
www.littleleaguelearning.com and www.alittleleaguelearningcenter.com to identify their child
care center and child care and educational services, Defendants are: 1) trading on the goodwill
and reputation of Little League; 2) capitalizing on the many hundreds of thousands of dollars
spent annually by Little League in advertising and promoting its services; and 3) misleading the
purchasing public into believing that their child care center and child care and educational
services are legitimately connected or affiliated with, or sponsored or approved by, Little
League.
19. The public is likely to be confused or deceived by the false impression arising
from Defendants use of names and marks confusingly similar to the Little League Marks.
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20. On January 23, 2014 and again on February 13, 2014, Little League notified
Defendants of its exclusive rights in the Little League Marks and its exclusive rights to use and
authorize the use of Little League, and requested that Defendants discontinue and refrain from
their infringing, unfair, and improper conduct. Little League did not receive a response to either
notification. True and correct copies of the notifications are attached as Exhibit D.
21. On April 11, 2014, counsel for Little League notified Ms. Bravo of the exclusive
rights of Little League in the Little League Marks and the exclusive rights of Little League to use
and authorize the use of Little League, and requested that Defendants cease and desist from
their infringing, unfair, and improper conduct. On April 18, 2014, Dr. Bravo called counsel for
Little League and left a voice mail message to which counsel for Little League responded by
telephone and e-mail the same day. On April 20, 2014, Dr. Bravo spoke with counsel for Little
League by telephone and in an e-mail of the same date to counsel for Little League stated that the
matter would be resolved [by ceasing and desisting from use of Little League within 10
business days by May 5, 2014. True and correct copies of such correspondence are attached as
Exhibit E.
22. On May 6, 2014, counsel for Little League ascertained that the website
www.littleleaguelearning.com was no longer available. A true and correct copy of counsels
search results is attached as Exhibit F.
23. On May 15, 2014, counsel for Little League received a letter from counsel for A
Little League which challenged the exclusive rights of Little League to use and authorize the use
of Little League. Counsel for Little League responded to such letter on May 30, 2014, but did
not receive a reply. Counsel for Little League has repeatedly sent correspondence to and
attempted to contact counsel for A Little League by e-mail and telephone, but has not received a
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response to any such communications. True and correct copies of such correspondence are
attached as Exhibit G.
24. Despite Dr. Bravos assurances of April 20, 2014, Defendants continue to use the
designation A LITTLE LEAGUE LEARNING CENTER and the domain
www.alittleleaguelearningcenter.com to identify, advertise, and promote their child care center
and child care and educational services. True and correct copies of Defendants exterior signage
at their child care center showing use of A LITTLE LEAGUE LEARNING CENTER and
LITTLE LEAGUE LEARNING are attached as Exhibit H.
25. Defendants infringement and misuse of the Little League Marks demonstrates a
willful and bad faith intent to create confusion, deception, and mistake in the minds of Little
Leagues customers and potential customers, and to trade on Little Leagues goodwill by
implying an affiliation, connection, or association of their child care center and child care and
educational services with Little League or an approval of by their child care center and child care
and educational services by Little League, as a result of which Defendants have been and will be
unjustly enriched.
COUNT I
FEDERAL TRADEMARK INFRINGEMENT (15 U.S.C. 1114)

26. Little League incorporates by reference Paragraphs 1 through 25 of the Complaint
as though fully set forth herein.
27. Defendants use of the Little League Marks in connection with their child care
center and child care and educational services is likely to cause confusion, to cause mistake, or to
deceive persons into the erroneous belief that Defendants services are authorized, sponsored by
or in some way connected with Little League.
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28. Defendants aforesaid acts constitute infringement of Little Leagues federally
registered Little League Marks in violation of Section 32(1) of the Lanham Act, as amended, 15
U.S.C. 1114.
29. Upon information and belief, Dr. Bravo and Ms. Bravo directed and controlled
the acts of A Little League, personally participated therein, and/or had full and complete
knowledge thereof.
30. By reason of the acts of Defendants herein alleged, Little League has suffered
and, unless Defendants are restrained from continuing their unlawful acts, will continue to suffer
serious and irreparable harm for which it has no adequate remedy at law.
COUNT II
FEDERAL UNFAIR COMPETITION (15 U.S.C. 1125(a))

31. Little League incorporates by reference Paragraphs 1 through 25 of the Complaint
as though fully set forth herein.
32. Defendants unauthorized use of the Little League Marks constitutes a false
designation of origin and false description, and falsely represents to the public an affiliation,
connection, or association of their child care center and child care and educational services with
Little League or an approval of their child care center and child care and educational services by
Little League.
33. By engaging in the aforesaid acts, Defendants falsely represent to the public that
their child care center and child care and educational services are legitimately affiliated or
connected with Little League, falsely describe that their child care center and child care and
educational services are sponsored or approved by Little League, and falsely designate that their
child care center and child care and educational services originate from Little League.
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34. Defendants acts constitute violations of Section 43(a) of the Lanham Act, as
amended, 15 U.S.C. 1125(a).
35. Upon information and belief, Dr. Bravo and Ms. Bravo directed and controlled
the acts of A Little League, personally participated therein, and/or had full and complete
knowledge thereof.
36. By reason of the acts of Defendants herein alleged, Little League has suffered
and, unless Defendants are restrained from continuing their unlawful acts, will continue to suffer
serious and irreparable harm for which it has no adequate remedy at law.
COUNT III
FEDERAL TRADEMARK DILUTION (15 U.S.C. 1125(c))

37. Little League incorporates by reference Paragraphs 1 through 25 of the Complaint
as though fully set forth herein.
38. The Little League Marks are well-known, famous, and distinctive marks.
39. Defendants acts complained of herein constitute trademark dilution under
Section 43(c) of the Lanham Act, 15 U.S.C. 1125(c) because Defendants use of the Little
League Marks in connection with the advertising, sale, and promotion of Defendants child care
center and child care and educational services has diluted the distinctive quality of the Little
League Marks.
40. Upon information and belief, Dr. Bravo and Ms. Bravo directed and controlled
the acts of A Little League, personally participated therein, and/or had full and complete
knowledge thereof.
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41. By reason of the acts of Defendants herein alleged, Little League has suffered
and, unless Defendants are restrained from continuing their unlawful acts, will continue to suffer
serious and irreparable harm for which it has no adequate remedy at law.
COUNT IV
VIOLATION OF STATE OF FLORIDA ANTI-DILUTION STATUTE
(Fla. Stat. 495.151)

42. Little League incorporates by reference Paragraphs 1 through 25 of the Complaint
as though fully set forth herein.
43. The Little League Marks are well-known, famous, and distinctive marks.
44. Defendants acts complained of herein constitute trademark dilution in violation
of Fl. Stat. 495.151 because Defendants use of the Little League Marks in the state of Florida
in connection with the advertising, sale, and promotion of Defendants child care center and
child care and educational services has diluted the distinctive quality of the Little League Marks.
45. Upon information and belief, Dr. Bravo and Ms. Bravo directed and controlled
the acts of A Little League, personally participated therein, and/or had full and complete
knowledge thereof.
46. By reason of the acts of Defendants herein alleged, Little League has suffered
and, unless Defendants are restrained from continuing their unlawful acts, will continue to suffer
serious and irreparable harm for which it has no adequate remedy at law.
COUNT V
COMMON LAW TRADEMARK INFRINGEMENT AND UNFAIR COMPEITION

47. Little League incorporates by reference Paragraphs 1 through 25 of the Complaint
as though fully set forth herein.
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48. Defendants have violated and infringed Little Leagues common law rights in the
distinctive Little League Marks and have otherwise unfairly competed with Little League in
violation of the common law of the State of Florida.
49. Defendants use of the Little League Marks has caused and will continue to cause
a likelihood of confusion among the public that Defendants child care center and child care and
educational services are affiliated with, associated with, or otherwise approved by Little League.
50. As a result of Defendants infringing activities, Defendants have been and are
currently being unjustly enriched by its wrongful misappropriation of the Little League Marks.
51. Defendants acts complained of herein constitute trademark infringement and
unfair competition under the common law of Florida.
52. Upon information and belief, Dr. Bravo and Ms. Bravo directed and controlled
the acts of A Little League, personally participated therein, and/or had full and complete
knowledge thereof.
53. By reason of the acts of Defendants herein alleged, Little League has suffered
and, unless Defendants are restrained from continuing their unlawful acts, will continue to suffer
serious and irreparable harm for which it has no adequate remedy at law.
COUNT VI
INTERFERENCE WITH EXCLUSIVE RIGHT TO LITTLE LEAGUE MARKS

54. Little League incorporates by reference Paragraphs 1 through 25 of the Complaint
as though fully set forth herein.
55. Defendants acts complained of herein interfere with and violate the sole and
exclusive right to use and authorize the use of the LITTLE LEAGUE mark that has been
granted by Congress to Little League under 36 U.S.C. 130506.
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56. Upon information and belief, Dr. Bravo and Ms. Bravo directed and controlled
the acts of A Little League and had full and complete knowledge thereof.
57. By reason of the acts of Defendants herein alleged, Little League has suffered
and, unless Defendants are restrained from continuing their unlawful acts, will continue to suffer
serious and irreparable harm for which it has no adequate remedy at law.
PRAYER FOR RELIEF
WHEREFORE, Little League respectfully requests that the Court enter judgment against
Defendants as follows:
(a) Preliminarily and permanently enjoining and restraining Defendants, their
servants, agents, employees and successors, and all other persons in active concert or
participation with them, or any of them, from the following acts:
(1) Using, in the advertisement or promotion of their child care center and
child care and educational services, the designations A LITTLE LEAGUE
LEARNING CENTER and LITTLE LEAGUE LEARNING and the domains
www.littleleaguelearning.com and www.alittleleaguelearningcenter.com, or any
other colorable imitation of the Little League Marks;
(2) Expressly or impliedly representing to customers, potential customers, or
the public that their child care center and child care and educational services are
affiliated in any way with Little League;
(3) Representing by words or conduct that their child care center and child
care and educational services are authorized, sponsored, endorsed by, or
otherwise connected with Little League; and
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(4) Doing any other acts calculated or likely to cause confusion or mistake in
the mind of the public or to lead consumers into the belief that Defendants child
care center and child care and educational services are authorized, sponsored,
licensed, endorsed, or promoted by Little League, or are otherwise affiliated with
or connected to Little League.
(b) Adjudging Defendants to have infringed the Little League Marks;
(c) Requiring Defendants to account for and pay over to Little League all damages
suffered by Little League and all profits wrongfully derived by Defendants as a result of
their infringement, dilution, and unfair competition;
(c) Requiring Defendants to pay over to Little League three times the actual damages
sustained by Little League, together with the reasonable attorneys fees and costs
incurred by Little League in the prosecution of this action;
(d) Ordering Defendants to deliver up for destruction all labels, signs, prints, insignia,
brochures, and any other written or recorded material or advertisements in their
possession or control containing the Little League Marks or any other colorable imitation
of the Little League Marks;
(e) Ordering Defendants to cancel their registrations of the domain names
littleleaguelearning.com and a alittleleaguelearningcenter.com;
(f) Ordering Defendants to change the corporate name A Little League LLC to a
name that does not contain the term Little League;
(g) Requiring Defendants, in accordance with 15 U.S.C. 1116, to file with this
Court and serve on Little League within thirty (30) days from the date of entry of any
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injunction a report in writing, under oath, setting forth in detail the manner and form in
which Defendants have complied with the terms of the injunction; and
(h) Awarding Little League such other and further relief as the Court finds just.
This 28th day of July, 2014.
Respectfully submitted,


_/s/Jaime Rich Vining________________
FRIEDLAND VINING, P.A.
David K. Friedland
Florida Bar No. 833429
Jaime Rich Vining
Florida Bar No. 30932
1500 San Remo Avenue
Suite 200
Coral Gables, Florida 33146
(305) 777-1720 telephone
(305) 456-4922 facsimile
e-mail: dkf@friedlandandvining.com
e-mail: jrv@ friedlandandvining.com


J. Rodgers Lunsford III (pro hac vice to be
filed)
Georgia Bar No. 461200
Elizabeth Borland III (pro hac vice to be
filed)
Georgia Bar No. 460313
Smith, Gambrell & Russell LLP
Suite 3100 Promenade
1230 Peachtree Street, N.E.
Atlanta, Georgia 30309-3592
(404) 815-3500 (phone)
(404) 815-3509 (fax)
e-mail: rlunsford@sgrlaw.com
e-mail: egborland@sgrlaw.com

Attorneys for Little League Baseball,
Incorporated
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