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<briefIntroduction>
<paragraph><paraLine left_indent="0.11082499474287033" font_height="0.014252917841076851" text_width="0.23500971496105194" indent_from_top="0.1076812818646431"> the number of products in its “Monster” line from 72 separate products or “SKUs” when it received Monster's letters in 2014 to 399 SKUs in 2018. See ER541-ER564, ER300 (72 SKUs in 2014 catalog), ER446-ER485, ER300-ER302 (231 SKUs in Spring 2015 catalog), ER565-ER620, ER304 (259 SKUs in Spring 2016 catalog<footnoteReference id="FN1">1</footnoteReference>), ER486-ER537, ER305 (302 SKUs in Summer 2016 catalog), ER621-ER672, ER306 (367 SKUs in 2017 catalog), ER1083-ER1142, ER307 (399 SKUs in 2018 catalog). ISN also introduced new types of Monster-branded products that are identical to or very closely related to the goods sold by Monster. For example, ISN began selling “Monster” apparel in 2015 and “Monster” beverage containers in 2016. ER315. And ISN began selling two sizes of green and black “Monster” refrigerators in 2018. ER278-ER279, ER1144-ER1145.</paraLine></paragraph>
<paragraph><paraLine left_indent="0.11082499474287033" font_height="0.014252917841076851" text_width="0.23500971496105194" indent_from_top="0.1076812818646431">ISN also returned to the PTO in an effort to confer legitimacy on its infringing “Monster” and “Monster Mobile” brands. After receiving Monster's cease-and-desist letters, ISN filed applications to register ten different trademarks that include the word “Monster” or the phrase “Monster Mobile.” ER809-ER840, ER841-ER881, ER882-ER922, ER923-ER958, ER959-ER993, ER994-ER1029, ER1030-ER1049, ER1147-ER1148 ¶¶ 10-12, ER289:17-</paraLine></paragraph>
</briefIntroduction>
<footnote>
<noteDesignator id="FN1">1</noteDesignator>
<paragraph><paraLine left_indent="0.11082499474287033" font_height="0.014252917841076851" text_width="0.23500971496105194" indent_from_top="0.1076812818646431">The trial transcript incorrectly says “159” SKUs.</paraLine></paragraph>
</footnote>
<pdfPageNumber ocrGuid="606f6d61-5687-11eb-bea4-f0dc9fb69593">16</pdfPageNumber>
</page>
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