Plaintiff goes to great lengths....to create distance between its products, which it confusingly classifies as "high quality" and Defendant's products which it classifies as "not Italian" and "fast food." Plaintiff cannot have its cannoli and eat it too. Either the products are similar or they are not.5) A little ribbing of his own clients, before setting the record straight on who they are:
Plaintiff is correct that Catherine Daake is "highly sophisticated," though her siblings are believed to be possessed of some rather unsophisticated stories relating to Catherine's awkward teenage years. Sophistication issue aside, the sibling owners of Mangia Mobile had never heard of Plaintiff's restaurant prior to receiving the cease and desist letter issued by Plaintiff's prior counsel of record. Moreover, and relevance issue aside, neither Catherine nor her brothers live in a "gated community."Here's the pleading in its entirety: Mangia Mobile Response Memo
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