Alseeiadi

I. BACKGROUND

1 A. Factual Background 2 When a defendant is in default, the factual allegations of the complaint are generally 3 taken as true, except those relating to damages. Geddes v. United Fin. Grp., 559 F.2d 557, 4 560 (9th Cir. 1977). GS alleges the following. 5 Since 2020, GS has become widely recognized as a high-quality brand for glass 6 infusers. SAC ¶¶ 8, 14, 18. GS distinguishes the Stündenglass brand by using high quality 7 materials that facilitate “a superior smoking experience.” Id. ¶ 9. GS markets and sells its 8 products using the following Stündenglass trademarks: 9 a. U.S Trademark Registration Number 6,633,884 for the 10 standard character mark “Stündenglass” in association with goods further identified in registration class 011. Id. ¶ 11. b. U.S Trademark Registration Number 6,174,292 for the design plus words mark “S” and its logo in association with 13 goods further identified in the registration in international class 034. Id. c. U.S Trademark Registration Number 6,174,291 for the standard character mark “Stündenglass” in association with 16 goods …