Moguldom Media Group, LLC v. Okasi

Filing 1

COMPLAINT with Jury Demand filed by Moguldom Media Group, LLC.. Consent form to proceed before U.S. Magistrate and pretrial instructions provided. ( Filing fee $ 350.00 receipt number 42159.) (Attachments: # 1 Civil Cover Sheet)(eop) Please visit our website at http://www.gand.uscourts.gov to obtain Pretrial Instructions. [Transferred from Georgia Northern on 5/1/2012.]

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JAN 00 2012
IN THE UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF GEORGIA, ATLANTA DIVISION
MOGULDOM MEDIA GROUP, LLC

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Plaintiff
v.
CHINAZOR OKASI
Defendant.

Civil Action File No.

1:

047

COMPLAINT

Plaintiff, Moguldom Media Group, LLC ("MMG"), by counsel, for its
Complaint against Defendant, Chinazor Okasi ("Okasi"), complains and alleges as
follows:
INTRODUCTION
1.

This is an action for (a) false advertising and dilution, pursuant to the

Lanham Act § 43(a), 15 U.S.C. § 1125(a) and (c); (b) deceptive trade practices
pursuant to the Georgia Uniform Deceptive Trade Practices Act, Ga. Code Ann. §
10-1-370 et seq.; (c) unfair competition under the Georgia common law; and (d)
willful violations of the Lanham Act and common law claims of unfair
competition. MMG seeks permanent injunctive relief; damages sustained by

1

MMG as a result ofOkasi's deceptive practices and treble damages and/or punitive
damages resulting from Okasi's foregoing behavior; and all costs and fees,
including reasonable attorneys' fees, incurred by MMG in this action.

THE PARTIES
2.

Plaintiff, MMG, is a corporation organized and existing under the

laws of the State of New York, having its principal place of business at 171
Madison Ave, Penthouse, New York, NY 10016.
3.

Defendant, Okasi, is an individual having residence at 151 Sip

Avenue, Jersey City, NJ 07306.
JURISDICTION AND VENUE

4.

This action arises under the federal Lanham Act, 15 U.S.C. § 1051 et

seq., and is between citizens of different states. Jurisdiction is proper under 28

U.S.C. §§ 1331 and 1338. This action further comprises claims arising under state
law wherein jurisdiction is proper under 28 U.S.C. § 1367.
5.

Okasi has purposefully directed false and misleading statements

regarding MMG's brand Madame Noire to residents of the State of Georgia
through the use of her personal website and through a twitter account. Through
these actions, a substantial part of the events giving rise to this claim occurred in
Georgia.

2

6.

Venue properly resides in the United States District Court for the

Northern District of Georgia pursuant to 28 U.S.C. §§ 1391.

FACTUAL BACKGROUND
7.

MMG is a network of owned and operated digital brands focusing on

African Americans.
8.

The brands owned by MMG capture the pulse of diverse segments of

African Americans and provide rich, compelling experiences across multiple
medial channels including online video, mobile and social media platforms.
9.

MMG owns such famous and distinctive brands as Bossip, The

Atlanta Post, 24Wired.TV, HipHopWired, StyleBlazer and Madame Noire.
10.

In early 2009, MMG had an idea for a women's lifestyle website to be

primarily directed to African American women.
11.

The idea was that the website was to provide, among other things, on­

line reviews of African American celebrity gossip and entertainment news, current
events, lifestyles and personal relationships.
12.

The initial idea for the website was the creation of MMG owner and

CEO Jamarlin Martin ("Martin") and the initial development was through a design
team ofMMG employees and managers.

3

13.

The website was tentatively to be called "Clever Today," a suggestion

by Martin. Immediately, MMG began investing resources in web design, research
and hiring for the launch of the website.
14.

The idea for the website was circulated to MMG's brand editors for

input and contribution.
15.

The editor of The Atlanta Post, a MMG brand, contacted Martin and

recommended Okasi as a potential candidate for advancement within MMG.
16.

At the time, Okasi was with MMG as an assistant editor of The

Atlanta Post working in excess of 20 hours per week on her projects. Okasi had
been under contract with MMG since December, 2009.
17.

After the recommendation, Martin interviewed Okasi and offered her

a promotion from contractor to fulltime employee with MMG. The position
offered to Okasi was as the Assistant Director of Editorial Strategy to be based in
the Company's office in New York, NY. Her duties were to include working
across various MMG brands, including the development of the newest concept
"Clever Today." Okasi's immediate supervisor was Martin.
18.

Okasi was presented with an employment contract on March 15, 2010.

Okasi signed the employment contract with MMG on April 12, 2010. In addition,

4

the employment agreement included an Employee Non-Disclosure and Intellectual
Property Rights Agreement which was executed by Okasi on April 14, 20 I O.
19.

During this time, Okasi began attending meetings related to the

development and design of the new "Clever Today" website. These meetings were
attended by numerous individuals, including Martin, Okasi, Marve Frazier, Elaine
Flores and Rashaun Hall. During the development meetings, Okasi requested that
the name of the website be reexamined and new alternatives be explored.
20.

Martin directed Okasi to research alternative names for the concept

and website and their potential availability via an eventual internet website.
Among the alternative names suggested by Okasi were "Polish" and "Madame
Noire." Okasi's preferred alternative was the name "Polish."
21.

Martin rejected the "Polish" name and idea concepts proposed by

Okasi related to the same. However, the development team liked "Madame Noire"
and agreed to change the website and online magazine name of "Clever Today" to
"Madame Noire."
22.

In March, 2010, MMG applied for a trademark of the name "Madame

Noire" with an intent to use in commerce.
23.

The first use of the name "Madame Noire" in commerce was May 6,

2010.

5

24.

The website was launched in early June, 20 IO.

25.

The United States Patent and Trademark Office issued a registration

number of3,932,5656 to MMG as the owner of the mark "Madame Noire" on
March 15,2011.
26.

Over several months, MMG hired additional assistant editors for the

website Madame Noire. The editorial team included Elaine Flores, Danielle
Kwateng and Kweli Wright.
27.

All three of the assistant editors voluntarily quit their positions citing

difficulties with their working relationships with Okasi and her inability to
communicate and manage effectively.
28.

An additional assistant editor, Demetria Irwin, was hired and worked

closely with Okasi. Ms. Irwin also asked to be transferred to a different
department ofMMG. Ms. Irwin also cited difficulties working with Okasi as the
reason for the request to transfer.
29.

MMG became concerned with the management style ofOkasi in her

role as Assistant Director of Editorial Strategy and attempted interventional
meetings to address the issues.
30.

The difficulties surrounding Okasi's inability to effectively

communicate and manage employees continued and MMG management made the

6

decision to reduce Okasi's role back to one of contractor as of January, 20 lOin an
attempt to keep continuity and harmony among the rest ofMMG's employees.
MMG was concerned that Okasi's increasingly toxic personality and continued
unprofessional behavior was detrimental to the overall good of the company.
31.

Unfortunately, Okasi's disruptions continued and, after additional

problems were reported, Okasi's contract was terminated in March, 2010.
32.

MMG has invested substantial time, resources and money in the

development and branding of Madame Noire and the associated website since its
conceptual beginning.
33.

Since Okasi's termination, the website has increased its traffic over

34.

Once terminated from her employment with MMG, Okasi filed for

400%.

and obtained unemployment benefits against MMG.
35.

When Okasi's unemployment benefits were exhausted, Okasi began

making unfounded claims that she owned the name Madame Noire and she began
threatening Martin that she was going to sue MMG unless she was compensated
for the same. MMG declined to negotiate with Okasi over her baseless claims.

7

36.

Okasi currently maintains a personal website at www.chinaokasi.com.

The website is interactive and is commercial in nature as Okasi advertises and
promotes her books and personal media appearances.
37.

Okasi's website is accessible through the internet and is directed to

residents of Georgia through the direct references to content written by her while
an assistant editor of AtlantaPost.com, a publication that was directed to the
residents of Atlanta, Georgia.
38.

On her personal website, Okasi falsely claims that she is the creator

and founder of "MadameNoire.com." See Exhibit "A," attached hereto.
39.

Okasi also maintains a twitter account at @chinaokasi.

40.

Okasi's twitter account is accessible through the internet and to those

individuals who "follow" Okasi. The twitter messages are directed to "followers"
which include the residents of Georgia as she maintains twitter followers from the
state.
41.

Okasi's bio section of her twitter account announces "Also, I own

Madame Noire." See Exhibit "8," attached hereto.
42.

On November 7, 2011, Okasi applied for trademark protection for the

name "Madame Noire" under the same classification for goods and services as
MMG's currently registered mark. See Exhibits "C" and "D," attached hereto.

8

43.

Okasi is willfully and deliberately attempting to interfere with MMG's

business and their ability to serve the public using MMG's registered trademark.
44.

Okasi is willfully, intentionally, knowingly and in bad faith,

attempting to deceive the public as to the nature, origin, characteristics, or quality
ofMMG's goods, services, or commercial activities.
COUNT I

False Advertising Under § 43(a) of the Lanham Act

(15 U.S.C. § 1125(a»

46.

MMG repeats and realleges the allegations contained in paragraphs I

through 45 of the Complaint, and further states:
47.

Okasi is a person who has used in connection with her services,

advertised on her website and through her twitter account, MMG's registered
trademark "Madame Noire."
48.

Specifically, through her website and twitter account, Okasi has made

false representations as to the designation of origin and ownership of the mark
"Madame Noire."
49.

Okasi's false representations are likely to cause confusion, or to cause

mistake, or to deceive as to the affiliation, connection or association of Okasi with
MMG and/or Madame Noire as to the origin, sponsorship or approval ofMMG's
goods, services and commercial activities.
9

50.

Okasi's false representations as to origin and ownership of "Madame

Noire" misrepresents the nature, characteristics, and qualities ofMMG's goods,
services and commercial activities.
51.

For all ofOkasi's false representations and as to the designation of

origin and ownership of the mark "Madame Noire," MMG is entitled to, and seeks,
injunctive relief as set forth in 15 USC § 1116, and all remedies set forth in 15
USC §§ 1117(a) and 1118.
COUNT II
Dilution Under § 43(c) of the Lanham Act
(15 U.S.c. § 1125(c))

52.

MMG repeats and realleges the allegations contained in paragraphs 1

through 51 of the Complaint, and further states:
53.

MMG owns the distinctive mark "Madame Noire."

54.

Okasi has commenced to use MMG's mark in commerce in a manner

that is likely to cause dilution by blurring or dilution by tamishment.
55.

Okasi's use of and reference to MMG's mark "Madame Noire" impairs

the distinctiveness ofMMG's mark as MMG is engaging in exclusive use of the
mark in association with the goods and services associated with the same.

10

56.

Okasi's use of and reference to MMG's mark "Madame Noire" impairs

the distinctiveness of MMG's mark as "Madame Noire" is a well recognized and
famous mark.
57.

Okasi's use of and reference to MMG's mark "Madame Noire" impairs

the distinctiveness ofMMG's mark as Okasi's use and reference is intended to
create an impermissible association with MMG's mark.
58.

Further, Okasi's use of the mark "Madame Noire" on her personal

website and twitter account harms the reputation ofMMG's mark by association.
59.

Due to the likelihood of dilution of the mark "Madame Noire," MMG

is entitled to, and seeks, injunctive relief as set forth in 15 USC § 1116, and all
remedies set forth in 15 USC §§ 1117(a) and 1118.
COUNT III
Deceptive Trade Practices Under the Georgia Deceptive Trade Practices Act
(Ga. Code Ann. § 10-1-370 et seq.)

60.

MMG repeats and realleges the allegations contained in paragraphs I

through 59 of the Complaint, and further states:
61.

Okasi's representations as to the origin and ownership of the mark

"Madame Noire" on her website and twitter account are false or misleading.
62.

Okasi's representations as to the origin and ownership of the mark

"Madame Noire" on her website and twitter account is likely to cause confusion or

11

a misunderstanding as to the source, sponsorship, approval or certification of the
goods and services offered.
63.

Okasi's representations as to the origin and ownership of the mark

"Madame Noire" on her website and twitter account are likely to cause confusion
or a misunderstanding as to her affiliation, connection, or association with MMG
and it's mark "Madame Noire."
64.

MMG has been, or is likely to be, injured because ofOkasi's deceptive

trade practices. MMG is entitled to injunctive relief from Okasi's deceptive
practices. MMG is further entitled to recover the costs of this action, including
MMG's reasonable attorneys' fees, pursuant to Ga. Code. Ann. § 10-1-373.

COUNT IV
Unfair Competition Under Georgia Common Law

65.

MMG repeats and realleges the allegations contained in paragraphs 1

through 64 of the Complaint, and further states:
66.

Okasi's false representations as to the origin and ownership of the

mark "Madame Noire," as alleged herein above, constitutes unfair methods of
competition and unfair and deceptive acts and practices, including but not limited
to the use and employment of deception, fraud, false pretense, false promise,
misrepresentation and the concealment, suppression and omission of material facts,

12

with intent that others, including but not limited to consumers, rely upon the
concealment, suppression and omission of such material facts in violation of the
Georgia common law of unfair competition.
67.

Okasi's representations of fact are false and misleading representations

of fact which were willful and intentional, and made with deceptive intent.
68.

As a result ofOkasi's unfair competition, as alleged herein, MMG has

suffered and will continue to suffer damage and irreparable injury, including but
not limited to the loss of goodwill, loss of competitive advantage, and pecuniary
damages.
69.

MMG has no adequate remedy at law.

70.

MMG is entitled to compensatory damages, punitive damages, and

injunctive relief based on Okasi's violations of the Georgia common law of unfair
competition.
COUNT V
Willful Violations of the Lanham Act and Common Law Claims ­

Punitive Damages

71.

MMG repeats and realleges the allegations contained in paragraphs 1

through 70 of the Complaint, and further states:
72.

Okasi's violations of the Lanham Act and common law unfair

competition against MMG were committed willfully, intentional1y, knowingly and

13

in bad faith, with intent to deceive the public as to the nature, characteristics,
and/or origin ofOkasi's goods, services, or commercial activities. As such, MMG
is entitled to recover its damages, Okasi's profits, treble damages in amount up to
three times any damages award, the costs of the action, including its attorney's
fees, as provided for in 15 U.S.C. § 1117. MMG is further entitled to recover
punitive damages under the Lanham Act and as provided for in Ga. Code Ann. §
51-12-5.1.

WHEREFORE, Plaintiff, MMG, respectfully demands:
A.

That pursuant to 15 U.S.C. § 1116 and/or Ga. Code Ann. § 10-1-423,

a permanent injunction be issued restraining and enjoining Okasi, and all those
parties acting in concert with it, and its successors, agents, employees, officers and
assigns, from directly or indirectly:
1.

using MMG's registered mark "Madame Noire" in any form or

fashion which would tend to confuse the public as to the origin or ownership
of the mark; and
2.

otherwise falsely advertising, or otherwise falsely claiming, that

she is affiliated with MMG or its mark "Madame Noire."
B.

That MMG be awarded a monetary judgment against Okasi under the

Lanham Act, affording such monetary relief to which MMG is entitled pursuant to

14

IS U.S.c. § 1117, including actual damages, Defendant's profits, treble damages,
and reasonable attorneys' fees and costs;
C.

That Okasi be ordered to pay punitive damages, in an amount to be

determined at trial, as a result of Okasi's willful and malicious false advertising and
unfair competition under the Lanham Act and pursuant to Ga. Code Ann. § 51-12­
5. I and the Georgia common law;
E.

That Okasi be ordered to publish corrective advertising to dispel the

false, deceptive or impliedly false impressions created by her actions; or, in the
alternative, awarding damages to MMG in an amount sufficient to compensate
MMG for such corrective advertising as is appropriate to correct the deception
caused by Defendants' acts of false advertising;
F.

That Okasi be ordered to pay to MMG its reasonable attorneys' fees

pursuant to the Lanham Act, IS U.S.c. § 1117, and/or Ga. Code Ann. § 10-1-373,
and/or Ga. Code Ann. § 9-15-4, and/or Ga. Code Ann. § 13-6-11;
G.

That MMG recover all other costs and disbursements that may be

incurred by MMG in this action;
H.

That MMG have trial by jury on all issues so triable; and

I.

That the Court grant to MMG such other and further relief as it may

deem just, proper and equitable.

15

Respectfully Submitted, this 5th day of January, 2012.

HALL BOOTH SMITH & SLOVER, r.c,

191 Peachtree Street, Suite 2900

Atlanta, Georgia 30309

404-954-5000; (fax) 404-954-5020

16

China Okasi - Bio - Journalist I Education & Lifestyle Expert I Media Personality

Page I of2

I CHINA OKASI I

'We orc, each of IH, IlnfillHhed people - liVing wlely

tor rile pu'po~e of (fofting alld re-rratttnq (JIIfH'I'r'1"~."
- China Okasr

Jcumalut I Education & lifestyle Expert I Mtdla Personality

At 19, China okest became one of the youngest Ivy League alums to have graduated from Cornell
University within Just three years.

At 20, she was accepted to a Ph.D, program at Georgetown University, where she spent one year
before leaving to unleash her creative talents in the non-academic world.
By 21, she worked full-time for Georgetown, and part-time as a magazine editorial assistant; she
modeled, studied acting, and traveled to "cultivate her life," she says. She also began developing her
Check out China's latest appearances

new media expertise by launching various weesnes In the wee hours of the night -- one of which

and more!

would rake in thousands per month a few years later (see P & P below).

read more,

Never one to undervalue education, she began her first master's degree the next year at age 22, at
another Ivy League institution: the University of Pennsylvania's Graduate School of Education. There,
she would school while working as an advisor (and as an instructor at the neighboring Temple
University).

After finishing her Penn degree at 24, she scaled her teaching to part-time, in order to re-establish
her full-time career as an associate editor. She also freelanced on the side for several publications,
from Scholastic, to Philadelphia Inquirer, to MSNBC.com, to several magazInes and new media
companies. Her unique background & appetite for competition made her heavlly sought after by
corporate entities like KPMG & the City of New York, who used her expertise for high-stakes editorial
and medra projects.

With all her education and media work under her belt, she began serving as CEO of Penn &
paper.corn (P & P) and, on a part-time basis, chairing its Board, and overseeing its various
community projects that offer free services to underprivileged high school students in preparation for
college. She also began writing and producing news content for NBC & MSNBC on a full-time basis,
while completing yet another master's degree at her third Ivy League alma mater: the Columbia
University Graduate School of Journalism.
Now a formally trained journalist and educator, her work focuses on gender/women's issues,
lifestyle, pop culture, education, activism, politics and African/African-American issues. She has been
featured in numerous publications Including AOL Black Voices, BET, Loop 21, Huffington Post, Atlanta
Post, MSNBC.com, Uptown Magazine, Philadelphia Inquirer & more. She has Interviewed the likes of
Cathy Hughes, Soledad O'Brien, Jimmy Fallon, Faith Evans & many, many, more personas,
musicians, actors/actresses.

http://www.chinaokasi.com/bio.php

1/5/2012

· China Okasi - Bio - Journalist I Education & Lifestyle Expert I Media Personality

Page 2 of2

She Is the orit;linal creator and founder of "MadameNoire.com" as a lifestyle magazine, and will be
launching her new ccbncencn In October 2011. For most of the year, she serves as a local and cable
news commentator and lives In New York City, where she completes several books, lnch-bv-lnch.

(C) 2010 • All RIGHTS RESERVED

http://www.chinaokasi.comlbio.php

115/2012

. China Okasi (chinaokasi) on Twitter

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Search

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Already using Twitter via 51\15')

China Okasi
@ChinaOkasi

New York City

I do news counnentaru and brouk-duncinq. Kidding about
the breuk-dancinq. Kind of Also. IOWIl Madame Noire.
hup.z/« ww.chinaokasi.com

Text follow ChinaOkasi to 40404 in the United States

Follow

• T"j::els
• Favorites
•

1'0110\\ i ng

• Followers
• Lists
))

•
•

ChingQ_kasi China Okasi
If you're around your tube at 6:30pm tomorrow, catch China at 6:30pm on HLN - discussing something
other than... tb.me!XHNbhgQs
12 hours ago
))

Chinaokasi China Okasi

China - riding back from Fox morning...back home to PJs! tb.mc/Iqvwqocli
19 Dec
»

http.z/twitter.com/chinaokasi

1/5/2012

. China Okasi (chinaokasi) on Twitter

Page 2 of4

•
•
•
•
•

ChimlOkasi China Okasi
Hi, this is China! Just got off air with Angela McGlowan, former congressional candidate (R-MS) &
Doug Schoen..., Ib.me/I veDQ.inH4
18 Dec
»

ChinaOkasi China Okasi
New Time: China's on Fox & Friends tomorrow at 7:45am! Channel
17 Dec

=

Fox News.

»

ChinaOkasi China Okasi
Early birds! Catch China on Fox & Friends this Sun. w, former pollster for President Clinton, Doug
Schoen + Angela... tb.mc/Pskls-lxjh
15 Dec
»

ChinaOkasi China Okasi
Will try 2 develop my Twitter - I've been yelled at. I suck, Cant even keep my msg to 1. This
ish sux I Must link in LA! I have a that
17 Nov

~.Jokoy

»

ChinaOkasi China Okasi
@,lokoy Hi! Btw-caught ur water bottle TWICE-put in my purse, took out, rubbed my eyes, NOW I
HAVE PINK EYE! OK only 1st part of story's true

I'LN,,}'
more

Stay in touch with China Okasi
Join Twitter right now:

Full name
Email

http://twitter.eom/ehinaokasi

1/5/2012

. China Okasi (chinaokasi) on Twitter

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· Trademark Electronic Search System (TESS)

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United States Patent and Trademark Office

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MADAME NOIRE
Word Mark
Goods and
Services

MADAME NOIRE
IC 041. US 100101107. G & S: Entertainment services. namely. providing a web magazine, web
bulletin board postings, articles, internet blogs, and the like; providing online reviews of African
American celebrity gossip and entertainment news; entertainment services, namely, providing a
website featuring commentary, opinion and information on African American women pertaining to
current event news; providing a website featuring commentary, opinion and information on African
American woman, namely, lifestyles, celebrity gossip, entertainment news, current events news, and
personal relationships; providing an internet website featuring a blog dealing with subjects of interest to
African and American women website services; providing a website magazine; providing a web
magazine with social, career, lifestyle and political commentary of interest primarily to women; providing
a website with information of interest to women; commentary services, namely making information
reiating to social, relationship, style, political, fashion, lifestyle and other issues; providing online
reviews and commentary; providing website featuring online reviews and commentary including
allowing others to input content into the website

Standard
Characters

Claimed

Mark

(4) STANDARD CHARACTER MARK

Drawing
Code

Serial

85466502
Number

Filing Date November 7, 2011

Current
1B

Filing Basis

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Original
18

Filing Basis

Owner
(APPLICANT) Chinazor Okasi INDIVIDUAL NIGERIA 151 Sip Avenue #14 Jersey City NEW JERSEY

07306
Attorney of
Anthony H. Handal
Record

Type of

SERVICE MARK
Mark

Register
Live/Dead

Indicator

PRINCIPAL

LIVE

I·HOME I SITE INDEXI SEARCH I eBUSINESS I HELP I PRIVACY POliCY

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MADAME NOIRE
Word Mark

MADAME NOIRE

Translations

The English translation of "NOIRE" in the mark is "BLACK".

IC 041. US 100 101107. G & S: Entertainment services, namely, providing on-line reviews of

African American celebrity gossip and entertainment news; Entertainment services, namely,

providing a website featuring information on African American women pertaining to currenl event

news. FIRST USE: 20100506. FIRST USE IN COMMERCE: 20100506

Goods and
Services

IC 045. US 100 101. G & S: Providing a website featuring information on African American women,
namely, lifestyles and personal relationships. FIRST USE: 20100506. FIRST USE IN
COMMERCE: 20100506
Standard

Characters

Claimed

Mark Drawing
Code

(4) STANDARD CHARACTER MARK

Serial Number

77959622

Filing Date
Current Filing

Basis

March 16,2010

1A

Original Filing
Basis

1B

Published for
Opposition

November 9, 2010

http://tess2.uspto.gov/bin/showfield?f=doc&state=4002:8qreem.2.2

1/5/2012

, Trademark Electronic Search System (TESS)

Registration
Number

Registration

Date
Owner
Attorney of
Record
Type of Mark
Register
Other Data
Live/Dead
Indicator

Page 2 of2

3932565
March 15, 2011
(REGISTRANT) Moguldom Media Group, LLC LIMITED LIABILITY COMPANY NEW YORK 260
Madison Avenue, 8th Floor New York NEW YORK 10016
Justin M. Kerenyi
SERVICE MARK
PRINCIPAL
"MADAME NOIRE" does not identify a living individual.
LIVE

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I.HOME I SITE INDEX I SEARCH I eBUSINESS I HELP I PRIVACY POLICY

http://tess2.uspto.govlbinlshowfield?f=doc&state=4002:8qreem.2.2

1/5/2012