1971, it has done business under the trade names "Starbucks", "Starbucks Coffee Company" and

"Starbucks Coffee."

        6.       Plaintiff Starbucks U.S. Brands, Inc. ("U.S. Brands") is a corporation organized

and existing under the laws of the State of California, with its principal place of business located

in Burlingame, California. U.S. Brands is a wholly owned subsidiary of Starbucks. Ownership

of the trademarks described in this complaint is vested in U.S. Brands. Starbucks is a licensee of

such trademarks.

        7.       Plaintiffs are informed and believe and thereupon allege that defendant Black

Bear is a corporation organized and existing under the laws of the State of New Hampshire with

its principal place of business located in Tuftonborough, New Hampshire.  Plaintiffs are

informed and believe that Black Bear manufactures and sells to the general public, including to

consumers who reside in the State of New York and the Southern District of New York, roasted

coffee beans and related goods.

ALLEGATIONS COMMON TO ALL CLAIMS FOR RELIEF

Starbucks and its Business

        8.        Starbucks is the best-known vendor of specialty coffees in America today.

Beginning in 1971 as a single, Seattle-based coffee shop, Starbucks has grown to operate more

 than 4,310 retail locations throughout North America and in 19 foreign countries. Starbucks also

 supplies premium, fresh-roasted coffees to thousands of restaurants and other accounts

 throughout the world. Starbucks revenues in 2000 exceeded $2.1 billion - an increase of more

 than 29% over the previous year. Starbucks achievements have generated tremendous attention

 in the media - hundreds of articles have been written about the company over the last few years

 - and growing, widespread awareness of Starbucks and its products among consumers

 worldwide.