Cisco Systems, Inc. v. Dexon Computer, Inc.

I. BACKGROUND

1 Cisco manufactures networking and communications hardware, software, and 2 related products and services. Amend. Compl. ¶ 12. Cisco has built its brand through 3 significant investment in its CISCO trademark and other related trademarks (Cisco Marks) 4 that Cisco uses in connection with its products and services. Id. ¶¶ 14–17. 5 Dexon is a Minnesota corporation with its headquarters and sole office in 6 Bloomington, Minnesota. Id. ¶ 4; MTD Amend. Compl. at 6. Cisco alleges that “[f]rom at 7 least July 2006 through the present, Dexon has repeatedly and systematically engaged in 8 schemes to traffic counterfeit Cisco products.” Amend. Compl. ¶ 24. Dexon would tell 9 customers that it was selling genuine Cisco products, then deliver the customers 10 counterfeit products bearing Cisco Marks. Id. And when Cisco repeatedly demanded that 11 Dexon both (i) stop selling counterfeit products, and (ii) help Cisco identify the sources of 12 those products, “[i]in almost every instance, Dexon refused to cooperate with Cisco, and 13 refused to identify the counterfeit traffickers who supply it.” Id. 14 Cisco bases these general allegations on numerous specific…