Lebewohl et al v. Heart Attack Grill LLC et al

Filing 77

DECLARATION of William W. Chuang in Support re: 62 MOTION for Summary Judgment Of Non-Infringement.. Document filed by Jack Lebewohl, Jeremy Lebewohl, Uncle Abies Deli Inc., Uncle Abies Deli Sandwich Trademarks LLC, Uncle Abies Deli on First, Inc.. (Chuang, Willliam)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
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JACK LEBEWOHL, JEREMY LEBEWOHL,
UNCLE ABIES DELI INC. d/b/a 2ND AVE DELI,
UNCLE ABIES DELI ON FIRST INC. d/b/a 2ND AVE DELI,
AND UNCLE ABIES DELI SANDWICH TRADEMARKS LLC,
Plaintiffs,
-against-

Index No. 11-cv-3153 (PAE)

HEART ATTACK GRILL LLC, HAG LLC,
JON BASSO, DIET CENTER LLC (TEXAS) AND
DIET CENTER LLC (DELAWARE)
Defendants.
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DECLARATION OF WILLIAM W. CHUANG IN FURTHER SUPPORT OF
PLAINTIFFS’ MOTION FOR SUMMARY JUDGMENT
1.

My name is William W. Chuang. I am counsel for Plaintiffs in this action. As such, I
am fully familiar with the facts and circumstances of the within proceeding, except
as to those matters that I allege to be based upon information and belief, and as to
those matters, I believe them to be true. I hereby affirm the statements in this
declaration under the penalties of perjury.

2.

Exhibits B, C, D, M, N, and O to the Statement of Uncontested Facts are true and
correct copies of printouts from the websites listed on each document, which I
printed out on the dates shown on each document.

3.

Exhibit B is a true and correct copy of an article from Chowhound.com that I printed
out on September 28, 2010.

4.

Exhibit C is a true and correct copy of an article from gailharrington.net that I
printed out on February 15, 2012.
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5.

Exhibit D is a true and correct copy of an article from Chowhound.com that I printed
out on February 15, 2012.

6.

Exhibit M is a true and correct copy of an article from Yelp.com that I printed out on
February 15, 2012.

7.

Exhibit N is a true and correct copy of an article from nytimes.com that I printed out
on February 9, 2012.

8.

Exhibit O is a true and correct copy of an article from Bloomberg.com that I printed
out on February 9, 2012.

Dated: May 7, 2012
New York, NY

Affirmed.
/s
William W. Chuang

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