Chase

Plaintiff, Hotels Statler Company, Inc., a corporation, sues for an injunction to restrain defendants from using the name “Statler Flower Shop’’ or “Statler Flowers and Gifts” in connection with defendants’ flower and gift shop which it is now operating in the City of Los Angeles at a site approximately one and one-half miles from the address where plaintiff is nearing completion of what has been publicized by it as one of the Los Angeles area’s largest hotels.

The business now owned by plaintiff was founded in New York in 1900 by Ellsworth M. Statler who caused plaintiff to be incorporated in that State in 1914. Since 1900 Mr. Statler and the plaintiff have continuously maintained an actively expanding high class hotel business which has become one of the three largest hotel chains operating in the United States. With rare exceptions, the hotels operated by plaintiff have used the word “Statler” as part of the hotel name and in those instances where this has not been done, public use of the hotel name was prominently accompanied by a legend “Statler Operated”. Constant publicity has been given plaintiff’s hotels since the date of their acquisition, namely, in Cleveland, Ohio,…