damages sustained as a result of defendant's unlawful conduct, including: (i) defendant's profits;

(ii) Plaintiffs' damages; (iii) Plaintiffs' costs of suit; and (iv) Plaintiffs' reasonable attorneys'

fees.

Count II

(for Trademark Infringement, 15 U.S.C. § 1114(1))

        21.    Plaintiffs specifically reallege and incorporate by reference each and every

allegation set forth above.

        22.    The United States Patent and Trademark Office has granted federal trademark

registrations to the Starbucks Mark. Copies of certain of these registrations are attached hereto

as Exhibit "A." U.S. Brands owns the exclusive trademark rights and privileges in and to the

Starbucks Mark in the United States. U.S. Brands licenses its trademark rights in the Starbucks

Mark to Starbucks, which uses the Starbucks Mark as a designation of source and quality for its

goods and services. Starbucks uses the registration symbol"^® " on its goods and in advertising

 associated with the Starbucks Mark.

        23.    Defendant is using a copy or colorable imitation of the Starbucks Mark in a

 manner that is likely to confuse, deceive and/or cause mistake among consumers and therefore is

 infringing Plaintiffs' rights in the Starbucks Mark in violation of 15 U.S.C. § 1114(1).

        24.    Plaintiffs have no adequate remedy at law for defendant's infringement of the

 Starbucks Mark, in that: (i) the Starbucks Mark is unique and valuable property, injury to which

 cannot adequately be compensated by monetary damages; (ii) the damages to Plaintiffs resulting

 from the infringement are not precisely and fully ascertainable; (iii) the infringement injures and

 threatens to continue to injure Plaintiffs' reputation and goodwill; and (iv) the damage resulting

 to Plaintiffs from defendant's wrongful conduct, and the conduct itself, are continuing, and

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