Case 1:16-cv-01645 Document 1 Filed 03/03/16 Page 1 of 5

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK

ALVIN & SPARKY, LLC,

Plaintiff,
v.

16 Civ. 1645
(Jury Trial Demanded)

RALPH LAUREN CORPORATION,

Defendants.

COMPLAINT
Plaintiff Alvin & Sparky, LLC (A&S), by and through its attorneys Ostrager Chong
Flaherty & Broitman P.C., for its Complaint against defendant Ralph Lauren Corporation (RL)
avers as follows:
PARTIES
1.

A&S is a limited liability company organized and existing under the laws of the

state of New York with its principal place of business located at 698 West End Avenue, #15D,
New York, New York 10025.
2.

RL is a corporation organized and existing under the laws of the state of Delaware

with its principal place of business located at 650 Madison Avenue, New York, New York
10022.
JURISDICTION AND VENUE
3.

This is an action for copyright infringement arising under the Copyright Act of

1976, as amended, 17 U.S.C. 101 et seq.

Case 1:16-cv-01645 Document 1 Filed 03/03/16 Page 2 of 5

4.

This Court has jurisdiction over this action pursuant to 28 U.S.C. 1331 and

5.

Venue is proper in this District pursuant to 28 U.S.C. 1391 (b) and (c) and

1338.

1400 (a).
BACKGROUND FACTS
6.

A&S and its sole owner, Samantha Goldberg, designs and handcrafts cashmere

stuffed animals and accessory products of the finest quality for babies and young children.
A&Ss stuffed animal line includes, among others, teddy bears, puppy dogs, rabbits, turtles, and
elephants. A&S has been marketing its handcrafted stuffed animals to specialty retailers and
department stores throughout the world since 1998. A&Ss stuffed animals are made by hand in
New York City of the highest quality cashmere imported from Scotland.
7.

A&S markets its stuffed animal line and accessories under the brand name

ALVIN & SPARKY, and on a private label basis to select clients, including RL and Harrods.
The ALVIN & SPARKY product line is shown and offered for sale to the public at A&Ss
website www.alvinandsparky.com.
8.

Among A&Ss most notable stuffed animals is a teddy bear with an original

design as shown in Exhibit A (the A&S Teddy Bear).

9.

The A&S Teddy Bear has been duly registered in the United States Copyright

Office under United States Copyright Registration No. VA 1-936-632 dated November 20, 2014,
annexed as Exhibit A.
10.

At all relevant times herein, A&S has been and still is the sole owner of all

copyright rights in the A&S Teddy Bear and the U.S. Copyright Registration for such rights.

Case 1:16-cv-01645 Document 1 Filed 03/03/16 Page 3 of 5

11.

In or about the summer of 2001, RL placed orders with A&S for its cashmere

puppy dog stuffed animal. Thereafter, in the fall of 2001, RL ordered A&Ss Teddy Bear. RL
continues to order the A&S Teddy Bear in four sizes and other animals from A&Ss stuffed
animal line up to the present time. A&S provided its animal designs to RL on a private label
basis. A representative collection of A&Ss designs which RL presently features in its childrens
stores and through its on-line store at www.ralphlauren.com is shown in Exhibit B.
RLs Infringement of the A&S Teddy Bear
12.

In or about September 2013, A&S learned that RL had commenced marketing

non-cashmere teddy bears which are copied from and substantially identical to the A&S Teddy
Bear. As contrasted with A&Ss Teddy Bears which market at retail for $170 (Little Teddy)
and $195 (Big Teddy), RL has offered and continues to offer its non-cashmere teddy bears for
retail prices in the range of $24.50 to $49.50. RL markets its non-cashmere teddy bears at retail
throughout the United States, including in this Judicial District, and abroad through mass market
channels including RLs company stores, RLs outlet stores, RLs on-line store at
www.ralphlauren.com, and through third-party retailers such as Bloomingdales, Lord & Taylor,
Macys, Saks Fifth Avenue, Dillards and BonTon. Examples of RLs non-cashmere teddy bears
are shown in Exhibit C-1 (www.ralphlauren.com), Exhibit C-2 (www.bloomingdales.com),
Exhibit C-3 (www.saksfifthavenue.com), Exhibit C-4 (www.lordandtaylor.com), Exhibit C-5
(www1.macys.com/shop), Exhibit C-6 (www.dillards.com) and Exhibit C-7
(www.bonton.com).
13.

In or about the same period, RL began to market cashmere top and pant sets for

babies with images of the A&S Teddy Bear reproduced from A&Ss website. A&Ss website

Case 1:16-cv-01645 Document 1 Filed 03/03/16 Page 4 of 5

showing an image of its A&S Teddy Bear, and the RL top and pant set including the A&S Teddy
Bear are shown in Exhibits D-1 and D-2, respectively.
14.

At no time did A&S give permission to RL to copy or create derivative works

based upon the A&S Teddy Bear. On the contrary, A&S has objected to RLs marketing of the
unauthorized RL non-cashmere teddy bears and sweaters including images of the A&S Teddy
Bear, and has continued to lodge objection to the present.
AS AND FOR A CAUSE OF ACTION
(Copyright Infringement)
15.

A&S repeats and realleges each and every allegation contained in paragraphs 1

through 14 as if fully set forth herein.

16.

The aforementioned acts of RL constitute infringement of plaintiffs copyright in

the A&S Teddy Bear in violation of Sections 106 and 501 et seq. of the Copyright Act of 1976,
as amend (17 U.S.C. 501 et seq.).
17.

Unless permanently enjoined by order of this Court, RLs infringement of

plaintiffs copyright rights in the A&S Teddy Bear will cause plaintiff irreparable injury for
which he has no adequate remedy at law.
18.

Plaintiff is entitled to actual damages for this infringement and RLs profits

pursuant to Sections 501, 502 and 504 of the Copyright Act of 1976, as amended (17 U.S.C.
501, 502, and 504).
WHEREFORE, plaintiff Alvin & Sparky, LLC prays for judgment against Ralph Lauren
Corporation as follows:
1.

Declaring that RL violated Section 106 of the Copyright Act of 1976, as amended

(17 U.S.C. 106) by infringing plaintiffs copyright rights and awarding actual damages and lost

Case 1:16-cv-01645 Document 1 Filed 03/03/16 Page 5 of 5

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(;+,%,7$

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EXHIBIT B

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EXHIBIT C-1

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Case 1:16-cv-01645 Document 1-6 Filed 03/03/16 Page 1 of 8

EXHIBIT C-2

3/2/2016

Page 1 of 2
Case 1:16-cv-01645 Document 1-6 Filed 03/03/16 Page 2 of 8

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Ralph Lauren
Infant Boys' Plush Bear - Ages 0+
ORIG. $49.50
WAS $26.25
SALE $19.69
Sale ends 3/9/16
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COLOR: Blue
SHIP: In Stock
Usually leaves our facility within 2 business days.

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This adorable plush toy is sure to become one of your

little one's favorite stuffed animals. Ralph Lauren's
signature embroidered pony accents the bear's scarf,
giving it a heritage-inspired look.
Pre-tied scarf attached at the neck
Signature embroidered pony accents the scarf
11" height when seated
Suitable from birth
Shell and fill: polyester
Machine wash
Imported
Web ID: 1539375

POPULAR RELATED SEARCHES:

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3/2/2016

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Case 1:16-cv-01645 Document 1-6 Filed 03/03/16 Page 3 of 8

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PRICE: $29.50

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COLOR: Suffield Blue

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This adorable plush toy is sure to become one of your

little one's favorite stuffed animals. Ralph Lauren's
signature embroidered pony accents the bear's scarf,
giving it a heritage-inspired look.
Pre-tied scarf attached at the neck
Signature embroidered pony accents the scarf
Striped detail at each ear and foot
11" height when seated
Shell, scarf and striped details: cotton; fill:
polyester
Machine wash
Imported
Web ID: 1453414

POPULAR RELATED SEARCHES:

Ralph Lauren, Ralph Lauren baby, Ralph Lauren baby boy, Ralph Lauren childrenswear, Ralph Lauren for boys, Ralph Lauren infant, Ralph Lauren sale, baby, baby boy, baby
toys, boys, di Ralph Lauren baby, di Ralph Lauren baby boy, infant, infant boys, kids, new born, newborn, ralph, toys

RECENTLY VIEWED ITEMS (1)

EDIT

http://www1.bloomingdales.com/shop/product/ralph-lauren-childrenswear-infant-boys-plush-bear-age...

3/2/2016

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Case 1:16-cv-01645 Document 1-6 Filed 03/03/16 Page 4 of 8

STORES & EVENTS

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Ralph Lauren Childrenswear

Infant Girls' Plush Bear
PRICE: $35.00

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COLOR: Powder Pink

SHIP: In Stock
Usually leaves our facility within 2 business days.

QUANTITY:

IN-STORE AVAILABILITY:
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SHIPPING & RETURNS

This adorable plush bear is sure to be one of her

favorite stuffed animals. Ralph Lauren's signature
embroidered pony accents the bear's scarf, giving it a
heritage-inspired look.
Pre-tied scarf attached at the neck. Ralph
Lauren's signature embroidered pony accents
the scarf
Rosebud pattern at the ears and the feet. 11"
height when seated
Shell and fill: polyester
Machine wash
Imported
Web ID: 1409298

POPULAR RELATED SEARCHES:

Baby-G, Ralph Lauren, Ralph Lauren baby, Ralph Lauren baby girl, Ralph Lauren childrenswear, Ralph Lauren girls, baby, baby girl, di Ralph Lauren baby, girls, infant, infant girls,
kids, lauren, layette, new born, newborn, pink, ralph, toys

RECENTLY VIEWED ITEMS (2)

EDIT

http://www1.bloomingdales.com/shop/product/ralph-lauren-childrenswear-infant-girls-plush-bear-age...

3/2/2016

Page 1 of 2
Case 1:16-cv-01645 Document 1-6 Filed 03/03/16 Page 5 of 8

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Baby Products Details

Ralph Lauren Childrenswear

Infant Boys' Bear Print Plush Bear
PRICE: $29.50

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COLOR: White Multi

SHIP: In Stock
Usually leaves our facility within 2 business days.

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He won't want to leave home without his new favorite

teddy bear from Ralph Lauren, complete with a happy
face and an adorable little scarf.
An attached scarf with Ralph Lauren's
signature embroidered pony ties at the neck
Shell: cotton; fill: polyester
Spot clean
Imported
Web ID: 1409301

POPULAR RELATED SEARCHES:

Baby-G, Ralph Lauren, Ralph Lauren baby, Ralph Lauren baby boy, Ralph Lauren childrenswear, Ralph Lauren for boys, baby, baby boy, boys, di Ralph Lauren baby, infant, infant
boys, kids, lauren, layette, new born, newborn, ralph, toys, white

RECENTLY VIEWED ITEMS (3)

EDIT

http://www1.bloomingdales.com/shop/product/ralph-lauren-childrenswear-infant-boys-bear-print-plus...

3/2/2016

Page 1 of 2
Case 1:16-cv-01645 Document 1-6 Filed 03/03/16 Page 6 of 8

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100% DESIGNERS WHAT'S NEW WOMEN SHOES HANDBAGS JEWELRY & ACCESSORIES BEAUTY MEN KIDS HOME GIFTS THE REGISTRY SALE OUTLET

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Badger Basket Company Moses Basket - Free With $150 Purchase of Select
Baby Products Details

Ralph Lauren Childrenswear

Infant Girls' Stuffed Bear
PRICE: $29.50

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COLOR: Bermuda Pink

SHIP: In Stock
Usually leaves our facility within 2 business days.

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Available at 59th Street
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SHIPPING & RETURNS

This adorable plush bear is sure to be one of her

favorite stuffed animals. Ralph Lauren's signature
embroidered pony accents the bear's scarf, giving it a
heritage-inspired look.
Pre-tied scarf attached at the neck. Ralph
Lauren's signature embroidered pony accents
the scarf
11" height when seated
Shell: cotton; fill: polyester
Imported
Web ID: 1424437

POPULAR RELATED SEARCHES:

Baby-G, Ralph Lauren, Ralph Lauren baby, Ralph Lauren baby girl, Ralph Lauren childrenswear, Ralph Lauren girls, baby, baby girl, di Ralph Lauren baby, girls, infant, infant girls,
kids, lauren, layette, new born, newborn, pink, ralph, toys

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http://www1.bloomingdales.com/shop/product/ralph-lauren-childrenswear-infant-girls-stuffed-bear-a...

3/2/2016

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Case 1:16-cv-01645 Document 1-6 Filed 03/03/16 Page 7 of 8

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Ralph Lauren Childrenswear

Infant Girls' Floral Plush Teddy Bear
PRICE: $29.50

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COLOR: White Multi

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A must-have for your little one, this ultra-soft teddy

bear features a beautiful floral pattern and Ralph
Lauren's signature pony.
Striped details at the ears, the scarf and the
feet
Ralph Lauren's signature embroidered pony
accents the scarf
Shell: cotton/elastane; fill: polyester
Hand wash
Imported
Web ID: 1424419

POPULAR RELATED SEARCHES:

Ralph Lauren, Ralph Lauren baby, Ralph Lauren baby girl, Ralph Lauren childrenswear, Ralph Lauren for girls, Ralph Lauren sale, baby, baby girl, di Ralph Lauren baby, girls,
infant, infant girls, kids, kids girls, new born, newborn, ralph, teddy, teddy bear, toys

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http://www1.bloomingdales.com/shop/product/ralph-lauren-childrenswear-infant-girls-floral-plush-te...

3/2/2016

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Case 1:16-cv-01645 Document 1-6 Filed 03/03/16 Page 8 of 8

STORES & EVENTS

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BROWN BAG: ( 0)

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100% DESIGNERS WHAT'S NEW WOMEN SHOES HANDBAGS JEWELRY & ACCESSORIES BEAUTY MEN KIDS HOME GIFTS THE REGISTRY SALE OUTLET

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BONUS OFFER
Badger Basket Company Moses Basket - Free With $150 Purchase of Select
Baby Products Details

Ralph Lauren Childrenswear

Infant Girls' Bear Print Plush Bear
PRICE: $29.50

write a review

COLOR: White Multi

SHIP: In Stock
Usually leaves our facility within 2 business days.

QUANTITY:

PICK UP IN STORE:
Available at 59th Street
Check another store

Like

DETAILS

REVIEWS

OFFERS

ADD TO WISH LIST

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SHIPPING & RETURNS

She won't want to leave home without her new

favorite teddy bear from Ralph Lauren, complete with
a happy face and an adorable little scarf.
An attached scarf with Ralph Lauren's
signature embroidered pony ties at the neck
Shell: cotton; fill: polyester
Spot clean
Imported
Web ID: 1409284

POPULAR RELATED SEARCHES:

Ralph Lauren, Ralph Lauren baby, Ralph Lauren baby girl, Ralph Lauren childrenswear, Ralph Lauren for girls, Ralph Lauren sale, baby, baby girl, baby toys, di Ralph Lauren
baby, girls, infant, infant girls, kids, kids girls, new born, newborn, newborn girl, ralph, toys

RECENTLY VIEWED ITEMS (6)

EDIT

http://www1.bloomingdales.com/shop/product/ralph-lauren-childrenswear-infant-girls-bear-print-plus...

Case 1:16-cv-01645 Document 1-7 Filed 03/03/16 Page 1 of 9

EXHIBIT C-3

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EXHIBIT C-4

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EXHIBIT C-5

3/2/2016

Page 1 of 2
Case 1:16-cv-01645 Document 1-9 Filed 03/03/16 Page 2 of 6

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Ralph Lauren Baby Girls' Solid Bear Toy

Reg. $29.50

Sale $20.65
Sale ends 3/7/16

EXTRA 20% OFF Enjoy 20% off your purchase. Promo Code: CUTE

details

FREE SHIP AT $50 Enjoy Free Shipping at $50! details

Color: Bermuda Pink

Size:

size chart

ONE SIZE
in stock
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LARGER VIEW

11 shopper(s) love this

Product Details
This adorable plush bear is sure to be one of her favorite stuffed
animals. Ralph Lauren's signature embroidered pony accents the
bear's scarf, giving it a heritage-inspired look.

Pre-tied scarf attached at the neck

Ralph Lauren's signature embroidered pony accents the scarf
11" height when seated
Shell: cotton; Fill: polyester
Machine washable
Imported
Web ID: 2393139

macys.com and Macy's stores operate separately; products and prices offered at each may be different.
For more information read our Online Pricing Policy at www.macys.com/pricingpolicy

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Everyday Value
$12.98

http://www1.macys.com/shop/product/ralph-lauren-baby-girls-solid-bear-toy?ID=2393139&Category...

3/2/2016

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Case 1:16-cv-01645 Document 1-9 Filed 03/03/16 Page 3 of 6

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Ralph Lauren Baby Boys' Printed Bear Toy

Reg. $29.50

Sale $20.65
Sale ends 3/7/16

EXTRA 20% OFF Enjoy 20% off your purchase. Promo Code: CUTE

details

FREE SHIP AT $50 Enjoy Free Shipping at $50! details

Color: White
size chart

Size:
ONE SIZE
in stock
Check availability in your area
LARGER VIEW

7 shopper(s) love this

Product Details
He won't want to leave home without his new favorite teddy bear,
complete with a happy face and an adorable little scarf.
An attached scarf with Ralph Lauren's signature embroidered
pony ties at the neck
Shell: cotton; Fill: polyester
Spot clean
Imported
Web ID: 2393154

macys.com and Macy's stores operate separately; products and prices offered at each may be different.
For more information read our Online Pricing Policy at www.macys.com/pricingpolicy

frequently bought together

Ralph Lauren Baby

Boys' Inte...

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Boys' 3-Pi...

Nike Baby Boys'

3-Piece Oran...

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2-Piece...

Now $71.25

Sale $45.50

$20.00

Sale $45.50

Now $27.00

http://www1.macys.com/shop/product/ralph-lauren-baby-boys-printed-bear-toy?ID=2393154&Categ...

3/2/2016

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Case 1:16-cv-01645 Document 1-9 Filed 03/03/16 Page 4 of 6

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Ralph Lauren Baby Girls' Printed Bear

Reg. $29.50

Sale $20.65
Sale ends 3/7/16

EXTRA 20% OFF Enjoy 20% off your purchase. Promo Code: CUTE

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Color: White
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Size:
ONE SIZE
in stock
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10 shopper(s) love this

Product Details
She won't want to leave home without her new favorite teddy
bear, complete with a happy face and an adorable little scarf.
An attached scarf with Ralph Lauren's signature embroidered
pony ties at the neck
Shell: cotton; Fill: polyester
Spot clean
Imported
Web ID: 2393140

macys.com and Macy's stores operate separately; products and prices offered at each may be different.
For more information read our Online Pricing Policy at www.macys.com/pricingpolicy

frequently bought together

Ralph Lauren Baby

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Now $71.25

Everyday Value
$12.98

Sale $11.99

Now $41.25

Sale $35.70

http://www1.macys.com/shop/product/ralph-lauren-baby-girls-printed-bear?ID=2393140&CategoryI...

3/2/2016

Page 1 of 2
Case 1:16-cv-01645 Document 1-9 Filed 03/03/16 Page 5 of 6

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Ralph Lauren Baby Boys' Bear Toy

1 review

Reg. $29.50

Sale $20.65
Sale ends 3/7/16

EXTRA 20% OFF Enjoy 20% off your purchase. Promo Code: CUTE

details

FREE SHIP AT $50 Enjoy Free Shipping at $50! details

Color: Blue
size chart

Size:
ONE SIZE
in stock
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8 shopper(s) love this

Product Details
This adorable plush toy is sure to become one of yRalph Lauren's
little one's favorite stuffed animals. Ralph Lauren's signature
embroidered pony accents the bear's scarf, giving it a heritageinspired look.

Pre-tied scarf attached at the neck

Striped detail at each ear and foot
Signature embroidered pony accents the scarf
11" height when seated
Shell, scarf and striped details: cotton; Fill: polyester
Machine washable
Imported
Web ID: 2398632

macys.com and Macy's stores operate separately; products and prices offered at each may be different.
For more information read our Online Pricing Policy at www.macys.com/pricingpolicy

frequently bought together

Ralph Lauren Baby

Boys' Inte...

Carter's Baby Boys'

3-Piece ...

Carter's Baby Boys'

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2-Piece C...

Now $71.25

Sale $11.99

Sale $18.99

Sale $11.99

Sale $8.99

http://www1.macys.com/shop/product/ralph-lauren-baby-boys-bear-toy?ID=2398632&CategoryID=5...

3/2/2016

Page 1 of 2
Case 1:16-cv-01645 Document 1-9 Filed 03/03/16 Page 6 of 6

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Ralph Lauren Baby Boys' Solid Bear Toy

Reg. $29.50

Sale $20.65
Sale ends 3/7/16

EXTRA 20% OFF Enjoy 20% off your purchase. Promo Code: CUTE

details

FREE SHIP AT $50 Enjoy Free Shipping at $50! details

Color: French Navy

Size:

size chart

ONE SIZE
in stock
Check availability in your area
LARGER VIEW

8 shopper(s) love this

Product Details
This adorable plush toy is sure to become one of Ralph Lauren's
little one's favorite stuffed animals. Ralph Lauren's signature
embroidered pony accents the bear's scarf, giving it a heritageinspired look.

Pre-tied scarf attached at the neck

Signature embroidered pony accents the scarf
Striped detail at each ear and foot
11" height when seated
Shell, scarf and striped details: cotton; Fill: polyester
Machine washable
Imported
Web ID: 2393144

macys.com and Macy's stores operate separately; products and prices offered at each may be different.
For more information read our Online Pricing Policy at www.macys.com/pricingpolicy

frequently bought together

Ralph Lauren Baby

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Now $71.25

Sale $45.50

Sale $41.65

Now $15.00

$20.00

http://www1.macys.com/shop/product/ralph-lauren-baby-boys-solid-bear-toy?ID=2393144&Category...

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EXHIBIT C-7

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EXHIBIT D-1

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EXHIBIT D-2

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