Case 1:14maeues?eacumem1 Filed 11/12/14 Page 1 of 81 UNITED ST ES IST COUR SOUTHERND WYO 0 7 SPARK NETWORKS USA, LLC Plaintiff, No. 14 civ._ . V. COMPLA SMOOCH LABS INC. Jury Trial - . U.S.D.C. SI). N.Y, Defendant- CASHIERS Plaintiff, Spark Networks USA, LLC (?Spark Networks?), by and through its undersigned counsel, for its Complaint against Defendant, Smooch Labs Inc. (?Smooch Labs?), states and alleges as follows: NATURE OF THE CASE 1. This is an action for trademark in?ingement, false designation of origin, unfair competition, dilution, and patent infringement. 2. This action is based on Defendant?s infringement of: Plaintiff?s federally- registered trademarks for the mark DATE, in connection with Defendant?s online dating services product that directly competes with Plaintiff, and (ii) Plaintiff?s patent-in?suit that covers, among other things, methods for detection of reciprocal interests or feelings and subsequent noti?cation that underlies Defendant?s online dating services product. 241131125. 3. Plaintiff Spark Networks is a Delaware limited liability company with a principal place of business located at 11150 Santa Monica Boulevard, Suite 600, Los Angeles, California 90025. Case Document 1 Filed 11/12/14 Page 2 of 81 4. Upon information and belief, Defendant Smooch Labs is a Delaware corporation with its principal place of business at 435 Water Street, Portsmouth, Rhode Island 02871. JURISDICTION AND VENUE 5. The claims for federal trademark infringement, false designation of origin, unfair competition, and dilution asserted in Counts I, II, and in?a, arise under the Trademark Act of 1946 (as amended), namely, 15 U.S.C. 1051 et seq. Therefore, this Court has subject matter and original jurisdiction over Counts I, II, and pursuant to 15 U.S.C. 1121 and 28 U.S.C. 1331 and 1338(a). 6. The claims for trademark infringement, unfair competition, dilution and unjust enrichment asserted in Counts IV, V, VI, and VII, in?a, arise under the common law of the State of New York, and are so related to the federal claims asserted in Counts I, II, and infra, that they form part of the same case er controversy. Therefore, this Court has subject matter jurisdiction over counts IV, V, VI, and VII, pursuant to 28 U.S.C 133 8(b) and 1367(a). 7. The claim for patent infringement asserted in Count in?a, arises under the Patent Laws of the United States, namely, 35 U.S.C. 101 et seq. Therefore, this Court has subject matter and original jurisdiction over Count pursuant to 28 U.S.C. 1331 and 1338(a). 8. In the alternative, this Court has subject matter and original jurisdiction oVer all Counts asserted herein, pursuant to 28 U.S.C. 1332(a), because complete diversity of citizenship exists between Plaintiff and Defendant and the amount in controversy exceeds $75,000, exclusive of interest and costs. 9, This Court has personal jurisdiction over Defendant because, upon information and belief, Defendant conducts a substantial portion of its business in this District, and it has Case Document 1 Filed 11/12/14 ~Page 3 of 81 directly committed acts of patent infringement against the asserted patent, and trademark infringement against the asserted trademarks referenced in?a, in this District. 10. Venue is proper in this judicial district, pursuant to 28 U.S.C. 1391(b)(2), because, upon information?and belief, Defendant?s wrongful acts and conduct, as discussed in?a, occurred in substantial part in this judicial district. 11. In the alternative, venue is proper in this judicial district, pursuant to 28 U.S.C. 1391(b)(3), because, as discussed supra, Defendant is subject to personal jurisdiction in this judicial district. I. Plaintiff?s Business and Its InteHectual Property Portfolio a. History of Plaintiff?s Business I 12. Over 17 years ago, as an early pioneer in social networking and community Websites, Spark Networks (then known as MatchNet PLC) launched one of the most widely recognized online dating sites, date.com, setting a standard for online dating services, particularly in niche markets targeted towards speci?c ethnic and religious communities. Today, Spark Networks boasts an array of ?iconic, niche-focused brands that build and strengthen the communities they serve . . . [as a] leading provider of community?focused services, including online personals communities for single adults that offer safe, convenient places to meet and make special connections they may not have otherwise made.? Spark Networks, Company Overview, date.com remains one of Spark Networks? most well-known and signature brands, as the clear forerunner to subsequently founded online dating websites that continue to grow in popularity. 13. As early as 2001, ?one of every 10 Jewish singles in the United States? was using Case Document 1 Filed 11/12/14 Page 4 of 81 Date.com. See NY. Times, A Match Not Made in Heaven; How a Rabbi?s Foray into Online Dating Ended Up in Court (May 12, 2001), date.com was a pioneer in niche dating, and popularized the use of as a pre?x for such ventures geared towards the Jewish pOpulation. See, e. The Huf?ngton Post, Jewish Matchmaking Is Alive And Well, (With Some Post-Shtetl Updates (June 18, 2014) /06/18/jewish-matchmaking_ n_5488728.html (?Jewish dating sites like Date, perhaps the best known . . I 14. As of 2006, Jdate.com?s success was unparalleled, and of all date.com users, in 5 people experienced a marriage, engagement, or life partnership With someone they met on Date, and almost 1 in 3 people met someone on Date whom they dated for an extensive period of time.? Miriam Pullman Friedman, New Jewish Matchmaking: A Quantitative Analysis of JDate Users, 84 J. OF JEWISH COMMUNAL SERVICE 3/4, Summer/Fa112009, 345-52 (Summer/Fall 2009) 15. Based on a study conducted in 2011 by an independent research company, who surveyed almost 1,000 married Jewish internet users, it was found that date.com is ?responsible for more Jewish marriages than all other online dating sites combined.? Spark Networks, Company Overview, (emphasis in original); see also date.com, Date Reaches New Milestone for New Year (Sept. 30, 201 1), 1-09/j date-infographic/. b. Plaintiff? Trademark Portfolio and ?J?Family? of Marks 16. Plaintiff is the owner of a broad trademark portfolio related to its various products and services, including a large family of marks using the pre?x to indicate products and Case Do?cument 1 Filed 11/12/14 Page 5 of 81 services (?J-family?) designed to meet the needs of the Jewish community. 17. Plaintiff is the owner of the following active, federally?registered trademarks in connection with various products and services in connection with the Jewish community, including, but not limited to, online social media and dating websites and applications: Date? Date Mobile?i Mag? Date (logo)? Mom? JDating? Date Walking? Picks? Dater? Dollars? Pix? (logo) JRewards? See, e. g, Spark Networks, Intellectual Property, 18. Each of the fourteen trademarks listed supra in Paragraph 17 relate to products and services targeted towards the Jewish community, and Spark Networks actively uses and maintains all of the foregoing marks. Attached hereto as Exhibit A are the active records indicating federal registration of the fourteen marks. i. Plaintiff?s Federally-Registered JDATE Marks 19. Plaintiff has expended signi?cant time, labor, expense, skill, research and development over the course of over 17 years to develop, advertise, market, and promote its iconic -F amin of marks, all originating with its oldest mark, the progenitor of the -Family of Marks: DATE. I 20. In the course of protecting the DATE mark, Plaintiff obtained on January 16, 2001 and has since maintained, U.S. Trademark Registration No. 2,420,967 in Class 042 for ?[c]omputer services, namely a website for facilitating the introduction of individuals.? A true and correct copy of the Registration Certi?cate for the DATE Mark, dated January 16, 2001, is attached hereto as Exhibit B. 21. Further in the course of protecting the DATE mark, Plaintiff obtained on June Case Document 1 Filed 11/12/14 Page 6 of 81 17, 2008, and has since maintained, U.S. Trademark Registration No. 3,447,429 in Class 025 for ?[c]lothing, namely, t-shirts, sweatshirts, caps and. hats,? and in Class 045 for ?[p]roviding on?line personal introductions through a website, accessed via interconnected global computer networks, for the purpose of making acquaintances, ?iendship, and long term relationships,? for the DATE LOGO mark. A true and correct copy of the Registration Certi?cate for the DATE LOGO Mark, dated June 17, 2008, is attached hereto as Exhibit C. 22. Hereinafter, the DATE Registrations described in Paragraphs 20 and 21 shall be referred to as the DATE Marks?. 23. The DATE Marks are in effect, valid, and subsisting. 24. Plaintiff extensive advertising, marketing, promotion of its products and services offered under the DATE Marks have been extremely successful. Since 2002, Plaintiff has invested at least 73 million dollars in its efforts to promote, improve and maintain the products and services offered under the DATE Marks. One example of the broad marketing and branding efforts to promote the DATE Marks are annual social events like ?Schmooz~a- Palooza? that are designed to bring together members of date.com?s loyal consumer base. See, e. g, NBC Los Angeles, Social and Seasonal: Schmooz-a-Palooza (Dec. 20, 2013), Palooza-23 6745 83 .html. 25. 7 Plaintiff DATE Marks signify to consumers a singular source in the online dating marketplace for the Jewish Community. 26. The DATE Marks represent valuable assets for Spark Networks. 27. As stated supra, the registration for the ?rst DATE Mark was issued over 13 years ago. Case Document 1 Filed 11/12/14 Page 7 of 81 28. Since the issuance of the DATE Marks, Plaintiff has continuously offered goods and services under the DATE Marks for the classes of goods and services identi?ed in the aforementioned registrations. 29. Spark Networks has complied with all federal trademark registration requirements including, but not limited to, ?ling Af?davits of Use in compliance with Section 1605 of the Trademark Manual of Examining Procedure. 30. The JDATE Marks are incontestable pursuant to 15 U.S.C. 1065. c. Plaintiff?s US. Patent No. 5,950,200 31. On September 7, 1999, the United States Patent and Trademark Of?ce duly issued United States Patent No. 5,950,200 (?the ?200 patent? or entitled ?Method and Apparatus for Detection of Reciprocal Interests or Feelings and Subsequent Noti?cation?. A true and correct copy of the ?200 Patent is attached hereto as Exhibit D. Spark Networks owns by assignment all rights, title, and interest in the ?200 Patent, including the right to enforce and collect damages for all past, present, and future infringements. 32. The ?200 Patent was ?led very early in the history of Internet dating in January 1997, and claims a computerized method and apparatus for con?dentially determining whether two people are interested in one another based on speci?c information entered by users and notifying them of a match ?if and only if? both individuals expressed a reciprocal interest in each other. 33. Historical matchmaking did not allow for individuals to express proactive and anonymous interest in one another. The claimed invention thus provides a novel and technical solution to a problem in the art?the need for a way for two people who might be shy, fearful of rejection, or embarrassed, to express an interest in someone else in a manner that assured Case Document 1 Filed 11/12/14 Page 8 of 81 complete con?dentiality and anonymity. 34. In the ?Background of the Invention? and ?Summary of the Invention,? the patent-in?suit states: Often, even when two people want to initiate ?rst steps in a relationship, neither person takes action because of shyness, fear of rejection, or other societal pressures or constraints. . . . What is needed is a safe, simple, con?dential, and non-judgmental way for people to reveal their true feelings and interests without risk of embarrassment or rejection. The present invention overcomes the problems and disadvantages of the prior art by . . . confidentially determining, whether two people feel mutual attraction or interest . . . while maintaining complete anonymity unless a match of feelings or interests occurs. 4: Thus, the present invention provides a safe, con?dential and nonjudgmental way for people to make their feelings, and interests known without risk of embarrassment of fear of rejection. . . . The system maintains the anonymity of the participants beCause no noti?cation occurs unless the system determines that a match in feelings or interests exists. Ex. D, Abstract; 1:14, 17-20, 31-34, 61-222 (emphasis added). These stated objects and goals are achieved in the ?200 Patent by a specially pro grammed computer system for ?con?dentially determining matches in feelings and interests entered into the system by human beings and for notifying the human beings only in cases when a mutual match in feelings in interests occurs.? In the absence of a mutual match, ?only the computer system will be aware of the ?rst person?s feelings for the second person.? (Ex. D, Abstract), II. Defendant and its Infringement of Plaintiff?s Intellectual Preperty Rights 35. Upon information and belief, Defendant became a Delaware corporation as of January 6, 2014. 36. Upon information and belief, Defendant?s product ?rst came onto the market in April 2014. - Case Document 1 Filed 11/12/14 Page 9 of 81 37. Upon information and belief, Defendant?s product bearing the name is an internet mobile application that describes itself as ?the #1 Jewish dating; app . . . See Exhibit (indicating availability on the iTunes Store website). 38. It is widely accepted that the term ?swipe? connotes dating in 2014. See, e. g, Urban Dictionary, ?Swipe right?, %20right. See Exhibit F. 39. Plaintiff has never authorized Defendant to use SWIPE or any variation thereof in connection with products and services identical to those offered by Plaintiff. 40. The foregoing notwithstanding, Defendant?s product targets the same exact consumer base as Plaintiff through the same channel: the single, Jewish community seeking online dating products and services. 41.. Defendant and Plaintiff advertise through overlapping marketing channels insofar as they use the Internet to advertise their respective services. In addition, the parties? services are routinely the tepic of discussion on websites and blogs.1 42. Defendant?s conduct results in a likelihood of confusion. Due to the overlapping of marketing and sales channels, Defendant?s use of its SWIPE mark is also likely to cause initial interest and post-sale confusion to the irreparable harm and detriment of Plaintiff and the substantial goodwill it has developed in the DATE Marks. 1 For example, one popular social media site has dubbed JSWIPE as ?JDate for Jews on the go.? Buzzfeed, There?s a Tinder for Pretty Much Everything (Aug. 27, 2014), pretty-much?everything. Another technology?related website goes as far to characterize SWIPE as a ?clone ripoff of Jewish dating site Date.? TechCrunch, Matchmaking App Hinge Attracts To Beat Tinder?s Endless Swiping (July 1, 2014), see also Motherboard, I Asked the ?Jewish Tinder? to Make Me a Match (Oct. 21, 2014), (?But because of this fact I?ve always wondered how I would fare on a Jewish dating site like JDate, and now Betches Love This, The Five Bros You Meet On I swipe (Sept. 24, 20 14), swipe#6 [JSwipe] basically like JDate . . Case Document 1 Filed 11/12/14 Page 10 of 81 43. Defendant?s conduct ?thher causes irreparable harm to Plaintiff insomuch as its infringing product is available for free, and thus by causing confusion in the marketplace undermines Plaintiff 3 brand and causes a substantial and notable drop in subscribers. 44. Upon information and belief, Defendant?s product noti?es users of a match only when such users provide crossing indications of interest regarding one another. At least this I functionality, in combination with the'Defendant?s product receiving swipe-based user inputs and making resulting determinations of interest, infringes at least claim 1 of the ?200 Patent. 45. Without authorization, Defendant continues to use the JSWIPE mark and the underlying software to brand, promote and effectuate its product. COUNT I Federal Trademark Infringement under 15 U.S.C. 8 1114 46. Plaintiff repeats and re-alleges all paragraphs as if fully set forth herein. 47. As described above, Plaintiff is the owner of the incontestable federally registered trademarks for JDATE. Plaintiff?s ownership and exclusive use in commerce of DATE predates the use of Defendant?s SWIPE. 48. Defendant?s acts and conduct, as described supra, constitute trademark in?ingement in violation of 15 U.S.C. 114 in that Defendant?s use of the SWIPE mark is without authorization, in furtherance of its deliberate scheme to capitalize upon the extensive goodwill and name and brand recognition that Spark Networks has created with its -F amin of marks, and in particular, with its DATE Marks, for over 17 years. Defendant?s conduct is likely to cause confusion, mistake and/or deception among consumers. Such conduct has irreparany harmed and will continue to irreparany harm Plaintiff and the goodwill it has developed in the DATE Marks. 49. Upon information and belief, given the fame of the DATE Marks, Defendant?s 10 Case Document 1 Filed 11/12/14 Page 11 of 81 conduct is willful, intentional, and intended to trade off the goodwill associated with the DATE Marks. Defendant is and was aware of Plaintiffs prior use and ownership of the DATE Marks and Defendant?s conduct is will?il and intentional. 50. Defendant uses and will continue to use its confusingly similar JSWIPE mark in interstate commerce in connection with the sale, offering for sale, distribution, and/or advertising of its goods and services. 51. Upon information and belief, Defendant has made, and will continue to make, substantial gain from its unauthorized use of the JSWIPE mark to which it is not entitled in law or equity, all to the detriment of Plaintiff. 52. By reason of Defendant?s infringement and violation of 15 U.S.C. 11 14, Plaintiff has suffered, and will continue to suffer, damages and irreparable harm from Defendant?s unauthorized use of the SWIPE mark on competing services, targeting the identical consumer base, unless restrained by law. 53. Upon information and belief, Defendant has realized, and continues to realize, revenues, pro?ts and other bene?ts rightfully belonging to Plaintiff as a result of Defendant?s wrongful conduct. 54. Defendant?s conduct is causing and will continue to cause Plaintiff to suffer irreparable harm, and unless restrained, Plaintiff will continue to be damaged because Plaintiff has no adequate remedy at law. 55. Accordingly, Plaintiff reSpectfulIy requests that Defendant be permanently enjoined from using the JSWIPE mark and for damages in an amount to be determined at trial. COUNT II Federal Unfair Competition and False Designation of Origin under 15 U.S.C. 1125(3) 56. Plaintiff repeats and re-alleges all paragraphs as if fully set forth herein. 11 Case Document 1 Filed 11/12/14 Page 12 of 81 5 7. Defendant?s acts and conduct, as described supra, are likely to cause confusion, cause mistake, and/or deceive the public into mistakenly believing that the Defendant and Plaintiff are the same entity, or that Defendant is a licensee, authorized distributor, or af?liate of Plaintiff, or that Defendant, its activities, and/or its products or services are authorized, endorsed, sponsored or approved by Plaintiff, or that Defendant, its activities, and/or its products or services originate with, are connected with, or are associated with Plaintiff, or vice versa. 58. Defendant continues to use the SWIPE mark without authorization, in furtherance of its deliberate scheme to capitalize upon the extensive goodwill and name and brand recognition that Spark Networks has created with its -F amin of marks, and in particular, with its DATE Marks, for over 17 years. 59. Upon information and belief, given the fame of the DATE Marks, Defendant?s conduct is willful, intentional, and intended to trade off the goodwill associated with the DATE Marks. Defendant is and was aware of Plaintiff 3 prior use and ownership of the DATE Marks and Defendant?s conduct is willful and intentional. 60. Defendant uses and will continue to use-its confusingly similar SWIPE mark in interstate commerce in connection rwith the sale, offering for sale, distribution, and/or advertising of its goods and services. 61. Upon information and belief, Defendant has made, and will continue to make, substantial gain from its unauthorized use of the SWIPE mark to which it is not entitled in law or equity, all to the detriment of Plaintiff. 62. By reason of Defendant?s infringement, Plaintiff has suffered, and will continue to suffer, actual damages and irreparable harm from Defendant?s unauthorized use of the 12 Case Document 1 Filed 11/12/14 Page 13 of 81 SWIPE mark on competing services, targeting the identical consumer base, unless restrained by law. 63. Upon information and?belief, Defendant has realized, and continues to realize, revenues, pro?ts and other bene?ts rightfully belonging to Plaintiff as a result of Defendant?s wrong?il conduct. 64. Defendant?s conduct is causing and will continue to cause Plaintiff to suffer irreparable harm, and unless restrained, Plaintiff will continue to be damaged because Plaintiff has no adequate remedy at law. 65. Accordingly, Plaintiff respectfully requests that Defendant be permanently enjoined from using the JSWIPE mark and for damages in an amount to be determined at trial. COUNT Federal Dilu?on under 15 U.S.C. 8 1125(c) 66. Plaintiff repeats and re-alleges all paragraphs as if fully set forth herein. 67. As described above, Plaintiff is the owner of the distinctive and federally registered DATE Marks. 68. Plaintiff ownership and exclusive use in commerce of the DATE Marks in connection with online dating services predates the use of Defendant?s SWIPE mark. 69. Through consistent and continued use, promotion, and consumer and industry recognition, Plaintiff has developed the DATE Marks as the foundation of its -Family of Marks, to the point that they are famous. Defendant did not begin using the JSWIPE mark in commerce until long after Plaintiff? DATE and J?Family of Marks became famous. 70. Upon information and belief, Defendant?s conduct is willful and intentional and seeks to take advantage of the goodwill and recognition associated with the -Farr1ily, and, in particular, the DATE Marks. Defendant is and was at all relevant times both actually and 13 Case Document 1 Filed 11/12/14 Page 14 of 81 constructivelyraware of Plaintiff prior use, ownership, and registration, and Defendant?s conduct is therefore willful and intentional. For example, founder himself, David Yarus, admits: was a JDate user. . . TheJ ewishChannelTJ C, TJC is Jewish News Week in Review: August 22, 2014, YOUTUBE (Aug. 21, 2014), (relevant commentary beginning at 4 minutes, 30 seconds). 71. Defendant?s use of the SWIPE mark in connection with online dating services is likely to cause dilution of the distinctive qualities of Plaintiff?s DATE Marks, in violation of 15 U.S.C. 1125(0). . 72. By reason of Defendant?s infringement and violation of 15 U.S.C. 1125(0), Plaintiff has suffered, and will continue to suffer, actual damages and irreparable harm from Defendant?s unauthorized use of the SWIPE mark on competing services, targeting-the identical consumer base, unless restrained by law, and Defendant has realized, and continues to realize revenues, pro?ts-and other bene?ts rightfully belonging to Plaintiff as a result of Defendant?s wrongful conduct. 73. Defendant?s conduct is causing and will continue to cause Plaintiff to suffer irreparable harm, and unless restrained, Plaintiff will continue to be damaged because Plaintiff has no adequate remedy at law. 74. Accordingly, Plaintiff respect?illy requests that Defendant be permanently enjoined from using the SWIPE mark and for damages in an amount to be determined at trial. COUNT IV Trademark Infringement under New York?tatutory and Common Law - .Y. General Business 360 75. Plaintiff repeats and re?alleges all paragraphs as if fully set forth herein. 76. As described above, Spark Networks is the owner of valid and protectable trademark rights. Spark Networks? ownership and exclusive use in commerce of its trademarks 14 "Case Document 1 Filed 11/12/14 Page 15 of 81 predate use by Defendant. 77. Defendant?s adoption and use of a confusingly similar mark is likely to cause confusion among relevant consumers. 78. Speci?cally, Defendant continues to use the mark Without authorization, in furtherance of its deliberate scheme to capitalize upon the extensive goodwill and name and brand recognition that Spark Networks has created with its -Family of Marks, and in particular, with its DATE Marks, for over 17 years. I 79. Upon information and belief, Defendant has made, and will continue to make, substantial gain, revenues, and other bene?ts ?om its unauthorized use of the JSWIPE mark to which it is not entitled in law or equity, all to the detriment of Plaintiff. 80. By reason of Defendant?s infringement, Plaintiff has suffered, and will continue to suffer, actual damages and irreparable harm from Defendant?s unauthorized use of the SWIPE mark on competing services, targeting the identical consumer base, unless restrained by law. 81. Defendant?s conduct is causing and will continue to cause Plaintiff to suffer irreparable harm, and unless restrained, Plaintiff will continue to be damaged because Plaintiff has no adequate remedy at law. 82. Accordingly, Plaintiff reSpectfully requests that Defendant be permanently enjoined from using the mark and for damages in an amount to be determined at trial. COUNT Unfair Competllion under New York Common Law 83. Plaintiff repeats and re-alleges all paragraphs as if fully set forth herein. 84. Plaintiff is the owner of the incontestable federally registered trademarks for DATE. Plaintiffs ownership and exclusive use in commerce of DATE predates the use of 15 Case Document 1 Filed 11/12/14 Page 16 of 81 Defendant?s JSWIPE. 85. Defendant?s acts and conduct, as described supra, including, but not limited to Defendant?s use and adoption of a confusingly similar mark, constitute common law unfair competition and misappropriation of Spark Networks? trademark rights. 86. Defendant misappropriated the labors and expenditures of Spark Networks in bad faith. 87. As a direct and proximate result of Defendant?s unfair competition, Plaintiff has suffered, and will continue to suffer, actual damages and irreparable harm. 88. Upon information and belief, Defendant has made, and will continue to make, substantial gain, revenues, and other bene?ts ?om its unauthorized use of the SWIPE mark to which it is not entitled in law or equity, all to the detriment of Plaintiff. 89. Defendant?s conduct is causing and Will continue to cause Plaintiff to suffer irreparable harm, and unless restrained, Plaintiff will continue to be damaged because Plaintiff has no adequate remedy at law. 90. Accordingly, Plaintiff respectfully requests that Defendant be permanently enjoined from using the SWIPE mark and for damages in an amount to be determined at trial. - COUNT VI New York Statutory Dilution under New York General Business Law 8 360 91. Plaintiff repeats and re?alleges all paragraphs as if fully set forth herein. 92. As described above, Plaintiff is the owner of valid and protectable trademark rights. 93. Plaintiff ownership and exclusive use in commerce of its trademarks predate the use by Defendant. 94. Defendant?s adoption and use of a con?isingly?similar- mark is likely to cause 16 Case Document 1 Filed 11/12/14 Page 17 of 81 injury to Plaintiff? 3 business reputation and/or the dilution of the distinctive quality of its trademarks. 95. By reason of Defendant?s conduct, Plaintiff has suffered, and will continue to suffer, actual damages and irreparable harm from Defendant?s unauthorized use of the SWIPE mark on competing services, targeting the identical consumer base, unless restrained by law. 96. Defendant?s conduct is causing and will continue to cause Plaintiff to suffer irreparable harm, and unless restrained, Plaintiff will continue to be damaged because Plaintiff has no adequate remedy at law. 97. Accordingly, Plaintiff respectfully requests that Defendant be permanently enjoined from using the JSWIPE mark and for damages in an amount to be determined at trial. COUNT VII Unjust Enrichment 98. Plaintiff repeats and re-alleges all paragraphs as if fully set forth herein. 99. Through the conduct described supra, Defendant has been enriched at Spark Networks? expense and it is against good equity and conscience to permit Defendant to retain any pro?ts or other rewards from its conduct. 100. Defendant?s conduct was with deceptive intent. 101. Defendant?s conduct is causing and will continue to cause Plaintiff to suffer irreparable harm, and unless restrained, Plaintiff will continue to be damaged because Plaintiff has no adequate remedy at law. COUNT Infringeinent of the ?200 Patent under 35 U.S.C. 6 271(3) 102. Plaintiff repeats and re-alleges all paragraphs as if fully set forth herein. 103. Defendanthas infringed and continues to infringe at least claim 1 of the ?200 Patent, in direct violation of ?35 U.S.C. without Plaintiff? authority, making, 17 Case Document 1 Filed 11/12/14 Page 18 of 81 offering for sale, and selling products and services that are covered by one or more claims of the ?200 Patent. 104. Defendant?s conduct is causing and will continue to cause Plaintiff to suffer irreparable harm, and unless restrained, Plaintiff will continue to be damaged because Plaintiff has no adequate remedy at law. PRAYER FOR RELIEF WHEREF ORE, Plaintiff Spark Networks respectfully requests relief from this Court- against Defendant Smooch Labs as follows: a. An Order permanently enjoining and restraining Defendant, its subsidiaries, divisions, branches, af?liates, predecessors or successors in business, parents and wholly owned or partially owned entities of the party, and any entities acting or purporting to act for or on behalf of the foregoing, including any agents, employees, representatives, of?cers, directors, servants, partners, and those persons in active concert or participation with them, from engaging in, offering, or providing goods or services in connection with any mark that is identical to, or confusingly similar with, Spark Networks? DATE Marks, including enjoining use of the SWIPE mark and any mark confusingly similar thereto; b. An Order permanently enjoining and restraining Defendant, its subsidiaries, divisions, branches, af?liates, predecessorsor successors in business, parents and wholly Owned or partially owned entities of the party, and any entities acting or purporting to act for or on behalf of the foregoing, including any agents, employees, representatives, of?cers, directors, servants, partners, and those persons in active concert or participation with them, from engaging in any acts of unfair competition and/or deceptive acts and practices utilizing any mark that is identical to, or confusingly similar with Spark Networks? DATE Marks, including enjoining use of the JSWIPE mark and any mark confusingly similar thereto; 18 Case Document 1 Filed 11/12/14 Page 19 of 81 c. An Order requiring an accounting of Defendant?s wrongful pro?ts and/or compensatory damages in an amount to be determined at trial pursuant to Defendant?s unlawful use of the SWIPE Mark, (ii) awarding all of said amounts to Plaintiff as damages sustained by Plaintiff due to Defendant?s acts complained of herein, and awarding treble damages to Plaintiff; d. A Declaration that this case is ?exceptional? within the meaning of 15 U.S.C. 1117 and awarding Plaintiff its reasonable attorneys? fees and costs based thereon; e. A judgment that Defendant has directly in?inged Plaintiff? patent-in-suit in violation of 35 U.S.C. 271(a); f. An Order permanently enjoining and restraining Defendant, its subsidiaries, divisions, branches, af?liates, predecessors or successors in business, parents and wholly owned or partially owned entities of the party, and any entities acting or purporting to act for or on behalf of the foregoing, including any agents, employees, representatives, of?cers, directors, servants, partners, and those persons in active concert or participation with them, from making, distributing, licensing, using, offering for sale and/or selling prodatets or services that infringe Plaintiffs patent-in-suit; g. An Order requiring Defendant to account for and pay over to Plaintiff all damages sustained by Plaintiff as a result of Defendant?s infringement of Plaintiff patent-in?suit, including, but not limited to, a reasonable royalty and/or lost pro?ts due by reason of Defendant?s in?ingement, such reasonable royalty and/or lost pro?ts to be based on sales of Defendant?s competing products and services; h. A Declaration that this case is ?exceptional? within the meaning of 35 U.S.C. 285 and awarding Plaintiff its reasonable attorneys? fees and costs based thereon; and 19 Case Document 1 Filed 11/12/14 Page 20 of 81 i. I Award such other and further relief that the Court may deem just and equitable. DEMAND FOR JURY TRIAL Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Plaintiff demands a trial by jury of all issues so triable. 20 Case Document 1 Filed 11/12/14 Page 21 of 81 Dated: November 12, 2014 New York, New York CROWELL MORING LLP Lora A?fMoffatt Preetha Chakrabarti 590 Madison Avenue, 20th New York, NY 10022 Phone: (212) 223-4000 Fax: (212) 223-4134 Email: lmoffatt@crowell.com Email: pchakrabarti@crowell.com Attorneys for plaz'nzl?z?r Spark Networks USA, LLC. Case Document 1 Filed 11/12/14 Page 22 of 81 Exhibit A Case Document 1 Filed 11/12/14 Page 23 of 81 United States Patent and Trademark Of?ce Heme I Site Index I Search I FAQ IGIessar-y Gutdes I Contacts I eBus?ness I eBiz alerts I News I Hate Trademarks Trademark Electronic Search System (TESS) TESS was last updated on Tue Nov 4 03:21:00 EST 2014 SESRCH 06 . gems: Cues TESS. fat-mas, - NEETW Eli- F?gf giggly; {13m s- 1" {12132: Prat-xv [we {w Please logout when you are done to release system resources allocated for you. ListAt: 0R torecord: Record 6 out of 6 return to TSS) "r we (Use the ?Backi' button of the Internet Browser te DATE Word Mark JDATE Goods and IC 042. US 100 101. 8: Computer services, namely providing a website for facilitating the Services introduction of individuals. FIRST USE: 19970200. FIRST USE IN COMMERCE: 19970200 . Mark Drawing code (1) TYPED DRAWING Serial Number 75784815 Filing Date August 28, 1999 Current Basis 1A Original Filing Basis 1A Published for op position October 24, 2000 Registration 2420967 Number Registration Date January 16, 2001 Owner MatchNet CORPORATION UNITED KINGDOM 8670 Wilshire Boulevard Beverly Hills CALIFORNIA 90211 (LAST LISTED OWNER) SPARK NETWORKS USA, LLC LTD LIAB JT ST CO DELAWARE 11150 Santa Monica Boulevard Suite 600 Los Angeles CALIFORNIA 90025 Assignment . Recorded ASSIGNMENT RECORDED Attorney of Case Documentl Filed?11/12/14 Page 24 of 81 Record Victor T. Fu Type of Mark SERVICE MARK Register PRINCIPAL Affidavit Text SECT 15. SECT 8 (6-YR). SECTION 20110114. Renewal 1ST RENEWAL 20110114 33:42:? 1:2" 3 ng ?111,231 mm: 1mm I.HOME I SITE 1NDEXI SEARCH I I HELP I PRIVACY POLICY Case Document 1 Filed 11/12/14 Page 25 of 81 United Siates Patent and Trademark ?f?ce Home ISite index I Search I FAQ I Giossary I Guides I Centacts I eassiness I eBiz a?erts I News I ?eas Trademarks Trademark Electronic Search System (TESS) TESS was last updated on Tue Nov 4 03:21:00 EST 2014 SEARCH games: Easier TESS HOME I i 1: NEXT LAST has Please logout when you are done to release system resources allocated for you. ListAt: ORtorecord: Record 1 out of 2 rm Mum?swswa - - .. Use the ?Back" button of the Internet Browser to return to TESS) MAG Word Mark JMAG Goods and Ic 041. US 100 101 107. S: PROVIDING AN ON-LINE MAGAZINE FEATURING NEWS AND Services FEATURE ARTICLES CONCERNING DATING, RELATIONSHIPS, FRIENDSHIP AND LONG TERM RELATIONSHIPS. FIRST USE: 20060512. FIRST USE IN COMMERCE: 20050512 Standard Characters Claimed I Draw"?! (4) STANDARD CHARACTER MARK Serial Number 78890463 Filing Date May 23, 2006 Current Basis 1A Original Filing 1A Basis Published for opposition January 23, 2007 Registration Number 3227590 Registration Date April 10, 2007 Owner (REGISTRANT) Spark Networks PUBLIC LIMITED COMPANY (PLC) UNITED KINGDOM Suite 800 8383 Wilshire Blvd. Beverly Hills CALIFORNIA 90211 (LAST LISTED OWNER) SPARK NETWORKS USA, LLC LTD LIAB JT ST CO DELAWARE Case Document 1 Filed 11/12/14 Page 26 of 81 11150 Santa Monica Boulevard Suite 600 Los Angeles 90025 ?Sigma? ASSIGNMENT RECORDED Recorded Attorney of . ec or Victor T. Type of Mark SERVICE MARK Register PRINCIPAL Affidavit Text SECT 15. SECT 8 (6-YR). Live/Dead Indicator LIVE LHOME I SITE SEARCH 1 HELP i PRIVACY POLICY Case Document 1 Filed 11/12/14 Page 27 of 81 United States Patent and Trademark Office Heme I Site Index I Search I FAQ [Stessary I Guides I Centacts I eBusiness I eBiz alerts I News I Help Trademarks Trademark Electronic Search System (TESS) TESS was last updated on Tue Nov 4 03:21:00 EST 2014 SEARCH 0f; {were ?ier: it?s-w {3:343 - rte-ms.- a;ng F353: 11?3ng Logout i new?. Please logout when you are done to release system resources allocated for you. A List At: OR to record: I I Record 2 out Of 2 1 ?fi lit-?3} 1?33 aft-5; eturn to TSS) JDATING I .. m; Use the "Back" button of the internet Browser to Word Mark JDATING A Goods and IC 045. US 100 101. 8: Providing on-line personal introductions through a website, accessed Services via interconnected global computer networks, for the purpose of making acquaintances, friendship, and long term relationships. FIRST USE: 20011001. FIRST USE IN COMMERCE: 2001 1001 Standard Characters Claimed Draw'"9 (4) STANDARD CHARACTER MARK Serial Number "(7028678 Filing Date October 25, 2006 Current Basis 1A Original Filing Basis 1A Published for Opposition May 29' 2007 Registration Number 3278986 Registration Date August 14, 2007 Owner (REGISTRANT) Spark Networks PUBLIC LIMITED COMPANY (PLC) UNITED KINGDOM Suite 800 8383 Wilshire Blvd. Beverl Hills CALIFORNIA 90211 Case Document 1 Filed 11/12/14 Page 28 of 81 (LAST LISTED OWNER) SPARK NETWORKS USA, LLC LIMITED LIABILITY COMPANY DELAWARE 11150 Santa Monica Boulevard Suite 600 Los Angeles CALIFORNIA 90025 Assignment Recorded ASSIGNMENT RECORDED Attorney of . Record Victor T. P?or Registrations 2420967 Type of Mark SERVICE MARK Register PRINCIPAL Affidavit Text SECT 15. SECT 8 Live/Dead Indicator LIVE SEARCH ?313 TEES 353 it 1 SITE INDEXI SEARCH i eausmEss 1 HELP i PRIVACY POLICY Case Document 1 Filed 11/12/14 Page 29 of 81 matted States Retest and Trademafk ?f?ce Home I Site index I Search I FAQ I mosses-y I Guides I Contacts I eBusiness I eBiz alerts I News I Heip Trademarks Trademark Electronic Search System (TESS) TESS was last updated on Tue Nov 4 03:21:00 EST 2014 TEES HUME M, Please Iogout when you are done to release system resources allocated for you. Record 1 out of 1 3 a. its-$512311 at: atti Use the ?Back? batten of the Internet Browser to return to TESS) JDATER Word Mark Goods and Services Standard Characters Claimed Mark Drawing Code Serial Number Filing Date Current Basis Original Filing Basis Published for Opposition Registration Number Registration Date Owner Assignment JDATER IC 045. US 100 101. 8: Providing on-Iine personal introductions through a website, accessed via interconnected global computer networks, for the purpose of making acquaintances, friendship, and long term relationships. FIRST USE: 20061024. FIRST USE IN COMMERCE: 20061024 (4) STANDARD CHARACTER MARK 77028829 October 25, 2006 1A 1 A May 29, 2007 3278992 August 14, 2007 (REGISTRANT) Spark Networks PUBLIC LIMITED COMPANY KINGDOM Suite 800 8383 Wilshire Blvd. Beverly Hills CALIFORNIA 90211 (LAST LISTED OWNER) SPARK NETWORKS USA, LLC LIMITED LIABILITY COMPANY DELAWARE 11150 Santa Monica Boulevard Suite 600 Los Angeles CALIFORNIA 90025 ASSIGNMENT RECORDED Case Document 1 Filed 11/12/14 Page 30 of 81 Recorded Attorney of . Record Victor T. Fu Prior Registrations 2420967 Type of Mark SERVICE MARK Register PRINCIPAL Affidavit Text SECT 15. SECT 8 (B-YR). Live/Dead indicator LIVE If; 5'35 Ham-9' LHDME I SITE SEARCH I I HELP I PRWACY POLICY Case Document 1 Filed 11/12/14 Page 31 of 81 Getter! States Fatem and Trademark Office Home I Site index I Search I FAQ I Giessary I Guides I Centacts I eBusiness I e852 aierts I News I Help Trademarks Trademark Electronic Search System (TESS) TESS was last updated on Tue Nov 4 03:21:00 EST 2014 SEARCH 06 3 (twee LEET HOME. 535% 35;; Fg?m Eileex'?srar: Um": t-?i ear LASET {we Pet?s: if:ch F3 WW 599393?; Please logout when you are done to release system resources allocated for you. MW. ListAt: 0R torecord: I Record 5 out of 6 . Use the ?Back? button of the Internet Browser to seem-ii aim; eturn to TESS) JDate Word Mark JDATE Goods and IC 025. US 022 039. S: Clothing, namely, t-shirts, sweatshirts, caps and hats. FIRST USE: Services 20030101. FIRST USE IN COMMERCE: 20030101 IC 045. US 100 101. S: Providing on-line personal introductions through a website, accessed via interconnected global computer networks, for the purpose of making acquaintances, friendship, and long term relationships. FIRST USE: 20011127. FIRST USE IN COMMERCE: 20011127 Mark D'aWing (3) DESIGN PLUS WORDS, LETTERS, NUMBERS Code Design Search 01.01.04 - Star - a single star with six points Code 01.01.11 - Incomplete stars; Stars, incomplete 02.11.01 - Hearts excluding hearts as carriers or depicted on playing cards 26.05.14 - Three triangles; Triangles, exactly three triangles 26.05.21 - Triangles that are completely or partially shaded Trademark LETS-1 A single letter, multiples of a single letter or in combination with a design Search Facility SHAPES-ASTRO Astronomical shapes consisting of cetestial bodies, globes and geographical Classification maps - Code Design listing or lined for three or more colors Heart shaped design SHAPES-TRIANGLES Triangular shaped designs and marks including incomplete triangles Serial Number 77028673 Filing Date October 25, 2006 Current Basis 1A Original Filing Case Document 1 Filed 11/12/14 Page 32 of 81 Basis Published for Opposition Registration Number Registration Date Owner Assignment Recorded Attorney of Record Prior Registrations Description of Mark Type of Mark Register Affidavit Text LivelDead Indicator Home me": 1A April 1, 2008 3447429 June 17, 2008 (REGISTRANT) Spark Networks PUBLIC LIMITED COMPANY (PLC) ENGLAND 8383 Wilshire Boulevard Suite 800 Beverly Hills CALIFORNIA 90211 (LAST LISTED OWNER) SPARK NETWORKS USA, LLC LTD JT ST CO DELAWARE 11150 Santa Monica Boulevard Suite 600 Los Angeles CALIFORNIA 90025 ASSIGNMENT RECORDED Victor T. Fu 2420967 The color(s) light blue, blue and red is/are claimed as a feature of the mark. The mark consists of the word "JDate" in blue surrounded by three light blue triangles and a red heart shape motif all of which form the overall impression of the Star of David. TRADEMARK. SERVICE MARK PRINCIPAL SECT 15. SECT 8 (6-YR). LIVE twee i?u? ?ux-5 Bea: fire-EV New SITE SEARCH I I HELP I. PRIVACY POLICY Case Document 1 Filed 11/12/14 Page 33 of 81 waited States Patent and Yrademark ?ffice Home I Site index I Search I FAQ IGiossary I Guides I Contacts I eBusiness I e852 aiertsI News I Help Trademarks Trademark Electronic Search System (TESS) TESS was last updated on Tue Nov 4 03:21:00 EST 2014 SEARCH 06 - 3,53,93ng Please logout when you are done to release system resources allocated for you. Fag}: Fag? {Jitf 317E153 mm wmnm?mam, Record 1 out of 1 - at tit;- I return to TESS) Use the "Back" button of the Internet Browser to JDATE MOBILE Word Mark JDATE MOBILE Goods and 7 IC 045. US 100 101. 8: Personal introduction services for the purpose of making Services acquaintances, friendship, and long term relationships accessed via electronic communication network from mobile telephones, cellular telephones, personal digital assistants and other portable wireless electronic devices. FIRST USE: 20091209. FIRST USE IN COMMERCE: 20091209 Standard Characters Claimed Draw"?! (4) STANDARD CHARACTER MARK Trademark Search Facility Classification Code Serial Number 77813490 Filing Date August 26, 2009 Current Basis 1A LETS-1 A single letter, multiples of a single letter or in combination with?a design Original Filing 1B Basis Published for opposition November 3, 2009 Registration Number 3786158 Registration Date May 4. 2010 owner (REGISTRANT) Spark Networks Limited private limited company UNITED KINGDOM sun-E 800 8383 WILSHIRE BLVD BEVERLYHILLS CALIFORNIA 90211 Case Document 1 Filed 11/12/14 Page 34 of 81 Assignment Recorded Attorney of Record P?or a Registrations Disclaimer Type of Mark Register Live/Dead Indicator (LAST LISTED OWNER) SPARK NETWORKS USA, LLC LTD LIAB JT ST CO DELAWARE 11150 Santa Monica Boulevard Suite 600 Los Angeles CALIFORNIA 90025 ASSIGNMENT RECORDED Victor T. Fu OTHERS NO CLAIM IS MADE TO THE EXCLUSIVE RIGHT TO USE APART FROM THE MARK AS SHOWN SERVICE MARK PRINCIPAL LIVE TE t't?ME $33? Btk?i?w?5-zr? wim- I.HGME I SITE SEARCH 1 1 HELP I PRIVACY POLICY case Document 1 Filed 11/12/14 Page 35 Of 81 United States Patent add Trademark Office Home [Site index I Search I FAQ I Glossary I Guides I Contacts I eBusEness I 9312 alerts I News I Help Trademarks Trademark Electronic Search System (TESS) TESS was Iastupdated on Tue Nov 4 03:21 :00 EST 2014 SEARCH 06 Please logout when you are done to release system resources allocated for you! saw?, ww..,mm.,w.u TESS Home Record 1 out of 1 i 7? "$371152; tenet-1.. - it. 4:11? t: Word Mark JDATETV Goods and IC 045. US 100 101. S: online services in the nature of providing a website featuring audio- Services visual content in the form of non-downloadable videos featuring topics related to dating, relationships, friendship and long term relationships. FIRST USE: 20090301. FIRST USE IN COMMERCE: 20090301 Use the "Back" button of the Internet Browser to Standard Characters Claimed Drawing (4) STANDARD CHARACTER MARK Trademark Search Facility LETS-1 A single letter, multiples of a single letter or in combination with a design Classification LETS-2 TV Two letters or combinations of multiples of two letters Code Serial Number 77880276 Filing Date November 24, 2009 Current Basis 1A Original Filing Basis 1A 3:33:2an April 27, 2010 3817612 July 13, 2010 Owner (REGISTRANT) Spark Networks Limited limited company (ltd.) UNITED KINGDOM SUITE 800 8383 WILSHIRE BLVD BEVERLY HILLS CALIFORNIA 90211 Case Document 1 Filed 11/12/14 Page 36 of 81 (LAST LISTED OWNER) SPARK NETWORKS USA, LLC LTD LIAB JT ST CO DELAWARE 11150 Santa Monica Boulevard Suite 600 Los Angeles CALIFORNIA 90025 Assignment ASSIGNMENTRECORDED Recorded Ammey ?f Victor T. Fu Record Prior . . Registrations OTHERS Type of Mark SERVICE MARK Register PRINCIPAL Live/Dead Indicator LIVE FREE ?a?zz?wswr' sen $335.9; I SITE SEARCH I HELID PRIVACY POLICY Case Document 1 Filed 11/12/14 Page 37 of 81 {mated States Patent and Trademark Of?ce Home I Site EadexISearch I FAQ I Giossary I Guides I Contacts I eBusiness I 2332 aierts I News I ?eip Trademarks Trademark Electronic Search System (TESS) TESS was last updated on Tue Nov 4 03:21:00 EST 2014 TE. :35 times. 3.3513 {f'g?m Ettauwot. 140.910"th i Please logout when you are done to release system resources allocated for you. Record 1 out of 1 eturn to TES) fit? Eights-:5; Use the "Back" button of the Internet Browser to Rewards Word Mark Goods and Services Standard Characters Claimed Mark Drawing Code Serial Number Filing Date Current Basis Original Filing Basis Published for Opposition Registration Number Registration Date Owner Assignment Recorded Attorney of Record Type of Mark JREWARDS I IC 035. US 100 101 102. S: Incentive awards programs for customers of online personals website to promote the sale of consumer goods and travel, hospitality and entertainment services of others. FIRST USE: 20090728. FIRST USE IN COMMERCE: 20090728 (4) STANDARD CHARACTER. MARK 77919510 January 25, 2010 1A 1A March 22, 2011 3972421 June 7. 2011 (REGISTRANT) SPARK NETWORKS USA, LLC LTD LIAB JT ST CO DELAWARE 11150 Santa Monica Boulevard Suite 600 Los Angeles CALIFORNIA 90025 ASSIGNMENT RECORDED Victor T. Fu SERVICE MARK Case Document 1 Filed 11/12/14 Page 38 of 81 Register - PRINCIPAL LiveIDead Indicator LIVE I SITE SEARCH I I HELP I PRIVACY POLICY Case Document 1 Filed 11/12/14 Page 39 of 81 enema States Patent and Trademark Office Esme I Site index I Search I FAQ I Giossary I Strides I Centacts I eBusiness I e332 aiea-ts I News I Help Trademarks Trademark Electronic Search System (TESS) TESS was last updated on Tue Nov 4 03:21:00 EST 2014 t-tszeae. f? ?1 Please logout when you are done to release system resources allocated for you. Start} List At: ?1,211: Fe- I343ng Lars; 3" Neat ?33m: Record record: I Word Mark Goods and Services Mark Drawing Code Design Search Code Serial Number Filing Date Current Basis Original Filing Basis Published for Opposition Registration Number Registration Date Owner Attorney of Record Description of rum to TSS) Use the "Back" button of the Internet Browser to BLOG IC 041. US 100 101 107. S: online journals, namely blogs in the ?eld of on-line dating, relationships, friendships and personal introductions. FIRST USE: 20101215. FIRST USE IN COMMERCE: 20101215 (3) DESIGN PLUS WORDS, LETTERS, NUMBERS 01.15.17 Balloons, thought or speech; Clouds, thought or speech; Thought or speech clouds 85203436 December 21, 2010 1A 1A April 26, 2011 3993989 July 12, 2011 (REGISTRANT) Spark Networks Limited private limited company UNITED KINGDOM 11150 Santa Monica Boulevard Suite 600 Los Angetes CALIFORNIA 90025 Victor T. Fu Color is not claimed as a feature of the mark. The mark consists of the word "JBlog" with the Case Document 1 Filed 11/12/14 Page 40 of 81 Mark Type of Mark Register LiveIDead Indicator 17555 HDME and a portion of the appearing within a cartoon quote bubble. SERVICE MARK PRINCIPAL LIVE tier? I136: Ute?: SEARCH I I HELP I PRIVACY POLICY teem Case Document 1 Filed 11/12/14 Page 41 of 81 matted States Patent and Trademark Office Home I Site Index I Search I FAQ I GiossaryI Guides [Contacts I eBusiness I e352 alerts I News I Heip Trademarks Trademark Electronic Search System (TESS) TESS was last updated on Tue Nov 4 03:21 :00 EST 2014 $599333} Please logout when you are done to release system resources allocated for you. Reward pig'ng Hararawsr {arr-:2" Record Use the ?Back? button of the Internet Browser to return to TESS) PICKS Word Mark Translations Goods and Services Standard Characters Claimed Mark Drawing Code Serial Number Filing Date Current Basis Original Filing Basis Published for Opposition Registration Number Registration Date Owner Attorney of Record Type of Mark Register JPICKS The wording has no meaning in a foreign language. IC 035. US 100 101 102. 8: Promoting the goods and services of others by providing an interactive website featuring coupons, rebates, product reviews, discounts and promotional offers of other businesses. FIRST USE: 20110207. FIRST USE IN COMMERCE: 20110207 (4) STANDARD CHARACTER MARK 85222519 January 20, 2011 1A 13 July 19, 2011 4034180 October 4, 2011 (REGISTRANT) Spark Networks USA, LLC LIMITED LIABILITY COMPANY DELAWARE 11150 Santa Monica Boulevard Suite 600 Los Angeles CALIFORNIA 90025 Victor T. SERVICE MARK PRINCIPAL Live/Dead Indicator "-17.5135.- Case Document 1 Filed 11/12/14 Page 42 of 81 LIVE Emswm SEQRCH OG I.HOME SITE INDEXI SEARCH I I HELP I PRIVACY POLICY Case Document 1 Filed 11/12/14 Page 43 of 81 Bnited States Patent and Trademark Of?ce Rome I Site Index I Seasch I FAQ I Gtossary I Guides I Contacts I sausiness I 2312 aierts I News I Hate Trademarks Trademark Electronic Search System (TESS) TESS was last updated on Tue Nov 4 03:21:00 EST 2014 TESS Heme, . {w?mw?fm mwme ax; 143903;} Please logout when you are done to release system resources allocated for you. a? mme/WW. FREE Estate-mad 131:." 15" SEARCH as Record 1 out of1 eturn to TS) . Use the "Back" button of the Internet Browser to Dollars Word Mark Goods and Services Standard Characters Claimed Mark Drawing Code Serial Number Filing Date Current Basis Original Filing Basis Published for Opposition Registration- Number Registration Date Owner Attorney of Record Type of Mark Register Live/Dead JDOLLARS IC 035. US 100 101 102. 8: Promoting the goods and services of others by providing an interactive website featuring coupons, rebates, product reviews, discounts and promotional offers of other businesses. FIRST USE: 20110501. FIRST USE IN COMMERCE: 20110501 (4) STANDARD CHARACTER MARK 85389597 August 4, 2011 1A 1A November 1,2011 4088095 January 17, 2012 (REGISTRANT) Spark Networks USA, LLC LIMITED LIABILITY COMPANY DELAWARE 11150 Santa Monica Boulevard Suite 600 Los Angeles CALIFORNIA 90025 Victor T. SERVICE MARK PRINCIPAL Indicator E: Case . Document 1 Filed 11/12/14 Page 44 of 81 LIVE SECH GG I SITE SEARCH 1 I HELP I PRIVACY POLICY Case Document 1 Filed 11/12/14 Page 45 of 81 waited States Patent and Trademark Of?ce tieme I Site index I Search I FAQ IGiessary I Guides I Contacts I eBusiness I e352 aterts I News I Hetp Trademarks Trademark Electronic Search System (TESS) TESS was last updated on Tue Nov 4 03:21 EST 2014 @3393; Please logout when you are done to release system resources allocated for you. Record 1 out of 1 ?fsb?nmu return to TESS) i ?51 '12 Use the "Back" button of the Internet BrowSer to JMom Word Mark Goods and Services Standard Characters Claimed Mark Drawing Code Serial Number Filing Date Current Basis Original Filing Basis Published for Opposition Registration Number JMOM IC 045. US 100 101. S: Providing on?line personal introductions through a website, accessed I via interconnected global computer networks, for the purpose of making acquaintances, friendship, and long term relationships. FIRST USE: 20050501. FIRST USE IN COMMERCE: 20050501 (4) STANDARD CHARACTER MARK 85397826 August 15, 2011 1A 1A November 1, 2011 4088112 Registration Date January 17, 2012 Owner Attorney of Record Type of Mark Register (REGISTRANT) Spark Networks USA, LLC LIMITED LIABILITY COMPANY DELAWARE 11150 Santa Monica Boulevard Suite 600 Los Angeles CALIFORNIA 90025 Victor T. Fu SERVICE MARK PRINCIPAL Case Document 1 Filed 11/12/14 Page 46 of 81 LiveIDead Indicator LIVE LHOME I SITE SEARCH I I HELP i PRIVACY POLICY Case Document 1 Filed 11/12/14 Page 47 of 81 United States Patent and Trademark Office Home I Site Index I Search I FAQ I Giessary I Guides I Contacts I eBusiness I eBiz starts I News] Heap Trademarks Trademark Electronic Search System (TESS) TESS was last updated on Tue Nov 4 03:21:00 EST 2014 219%ng Please logout when you are done to release system resources allocated for you. Record 1 out of 1 it?s 14.1.3138 ?51 at 2.1 return to TESS) it Air? Use the "Back" button of the Internet Browser to DATE WALKING Word Mark Goods and Services Standard Characters Claimed Mark Drawing Code Serial Number Filing Date Current Basis Original Filing Basis Published for Opposition Registration Number Registration Date Owner Attorney of Record P?or Registrations Type of Mark JDATE WALKING IC 041. US 100 101 107. 8: Entertainment services, namely, providing on-going webisodes featuring comedy and commentary on online dating, relationships, friendships and personal introductions. FIRST USE: 20101101. FIRST USE IN COMMERCE: 20101101 (4) STANDARD CHARACTER MARK 85462408 November 2, 201 1 1A 1A February 14, 2012 4135612 May 1,2012 (REGISTRANT) Spark Networks USA, LLC LIMITED LIABILITY COMPANY DELAWARE 11150 Santa Monica Boulevard Suite 600 Los Angeles CALIFORNIA 90025 Victor T. OTHERS MARK Case Document 1 Filed 11/12/14 Page 48 of 81 Register PRINCIPAL Live! Dead Indicator LIVE TE HQM 1 SITE SEARCH 1 HELP PREVACY POLICY Case Document 1 Filed 11/12/14 Page 49 of 81 United States Patent and Trademark Office Home I Site Index I Search I I Stossary I Guides I {Contacts I eBusiness I e832 aiertsl News I ?etp Trademarks Trademark Electronic Search System (TESS) TESS was last updated on Fri Nov 7 03:22:13 EST 2014 SEARCH 06 3 (?teen "rise Ham; - Ln ?fe: {amt its Please logout when you are done to release system resources allocated for you. List At: OR to record: I Record :t-t--z"5itt at eturn to TS) PIX Use the "Back" button of the Internet Browser to Word Mark JPIX Goods and IC 009. US 021 023 026 036 038. S: Downloadable mobile applications for smartphones, Services mobile telephones, cellular telephones, personal digital assistants, tablets and other portable wireless electronic devices for viewing personal introduction and social networking pro?le pictures and information for the purpose of making acquaintances, friendship, and long term relationships. FIRST USE: 20130514. FIRST USE IN COMMERCE: 20130514 Standard Characters Claimed (4) STANDARD CHARACTER MARK Serial Number 86249835 Filing Date April 11, 2014 Current Basis 1A Original Filing Basis 1A Published for Opposition Registration Number 4632443 Registration Date November 4, 2014 Owner August 19, 2014 (REGISTRANT) Spark Networks USA, LLC LIMITED LIABILITY COMPANY DELAWARE Suite Case Document 1 Filed 11/12/14 Page 50 of 81 600 11150 Santa Monica Boulevard Los Angeles CALIFORNIA 90025 Attorney of . Record Victor T. Fu Prior Registrations 4034180 Type of Mark TRADEMARK Register PRINCIPAL Live/Dead Indicator LIVE I SITE SEARCH I EBUSINESS I HELP I PRIVACY POLICY (Su?-r7: Liz-?1? Case Document 1 Filed 11/12/14 Page 51 of 81 Exhibit Case Document 1 Filed 11/12/14 Page 52 of 81 42 Prior U.S. Cls.: 100 and 101 7 Reg. No. 2,420,967 United States Patent and Trademark Office Registered Jan. 16, 2001 SERVICE MARK PRINCIPAL REGISTER JDATE MATCHNET PLC (UNITED KINGDOM TRODUCTION 0F INDIVIDUALS, IN CLASS 42 (U5. CLS. 100 AND 181)- 3670 WILSHIRE BOULEVARD FIRST USE 2?6?1997; IN COMMERCE 2-0-1997. BEVERLY HILLS. CA 90211 SER. NO. 75484315, FILED 8-28?1999. FOR: COMPUTER SERVICES, NAMELY PRO- VIDING A WEBSITE FOR FACILITATING THE IN- JOHN LINCOSKI, EXAMINING ATTORNEY Case Document 1 Filed 11/12/14 Page 53 of 81 Exhibit Case Document 1 Filed 11/12/14 Page 54 of 81 Int. Cls.: 25 and 45 Prior U.S. Cls.: 22, 39, 100 and 101 Reg. No. 3,447,429 United States Patent and Trademark Office Registered June 17, 2008 TRADEMARK SERVICE MARK PRINCIPAL REGISTER SPARK NETWORKS PLC (ENGLAND PUBLIC LIMITED COMPANY 8383 WILSHIRE BOULEVARD SUITE 800 BEVERLY HILLS, CA 90211 FOR: CLOTHING, NAMELY, T-SHIRTS, SWEAT- SHIRTS, CAPS AND HATS, IN CLASS 25 (U5. CLS. 22 AND 39). FIRST USE 14-2003; IN CONEMERCE 14-2003. FOR: PROVIDING PERSONAL INTRO DUCTIONS THROUGH A WEBSITE, ACCESSED VIA INTERCONNECTED GLOBAL COMPUTER NETWORKS, FOR THE PURPOSE OF MAKING ACQUAINTANCES, FRIENDSHIP, AND LONG TERM RELATIONSHIPS, IN CLASS 45 (US. CLS. 100 AND 101). FIRST USE 11a27-2001; 1N COMMERCE 11-27-2001. OWNER OF US. REG. N0. 2,420,967. THE LIGHT BLUE, BLUE AND RED ARE CLAIMED AS A FEATURE OF THE MARK. THE MARK CONSISTS OF THE WORD IN BLUE SURROUNDED BY THREE LIGHT BLUE TRIANGLES AND A RED HEART SHAPE MOTIF ALL OF WHICH FORM THE OVERALL IMPRES- SION OF THE STAR OF DAVID. SER. NO. 77-028,673, FILED 10?25-2006. BRENDAN REGAN, EXAMINWG ATTORNEY Case Document 1 Filed 11/12/14 Page 55 of 81 Exhibit United States Patent [19] Sudai et al. [54] METHOD AND APPARATUS FOR DETECTION OF RECIPROCAL INTERESTS OR FEELINGS AND SUBSEQUENT NOTIFICATION [75] Inventors: Gil S. Sudai, 347 Fern St.; David J. Blumberg, 1340 Washington St. #11, both of San Francisco, Calif. 94108 [73] Assignees: Gil S. Sudai; David J. Blumberg, both of San Francisco, Calif. [21] Appl. No: 08/788,522 [22] Filed: Jan. 24, 1997 [51] Int. Cl.6 .. G06R 17/30 [52] US. Cl. .. 707/9 [58] Field of Search .. 707/1, 3, 5, 6, 707/9 [56] References Cited U.S. PATENT DOCUMENTS 5,659,731 8/1997 Gustafson .. 707/4 5,717,923 2/1998 Dedrick .. 707/102 5,754,939 5/1998 Herz et a1. 455/42 5,761,662 6/1998 Dasan 707/10 OTHER PUBLICATIONS Web Page for Match.Com; Online Matchmaking Service; cometpl, Copyright 1993?1996; 1 page. Web Page for Match.Com; publication date unknown; 2 pages. Web Page for MatchCom; publication date unknown; 4 pages. Web Page for PlanetAll Corp; etall.com/contacts/head.dbm; publication date unknown; .1 page. Web Page for PlanetAll Corp; etall.com/Press/press.dbm; apparently published on or after Jan. 24, 1997; 3 pages. Ill "Mill" 11/12ma0595agm56 1 Case Document 1 ?le [11] Patent Number: 5,950,200 [45] Date of Patent: Sep. 7, 1999 Web Page for PlanetAll Corp; publication date unknown; 1 page. Web Page for PlanetAll Corp; publication date unknown; 1 page. Web Page for PlanetAll Corp; etallcom/tour/sample?emailhtm; Dec. 6, 1996; 2 pages. Web Page for People Will Talk 1 page, Dec. 13, 1994. Web Page for Overview of Yenta 2 pages, Dec. 13, 1994. Web Page for Overview of Matchmaking Process ker?overview.html, 1 page, Dec. 13, 1994. Web Page for Yenta 2 pages, Feb. 11, 1997. Primary Examiner?Jack M. Choules Attorney, Agent, or Firm?Grahahm James LLP [57] ABSTRACT A method and apparatus for automating "the process of con?dentially determining whether people feel mutual attraction or have mutual interests and for automating the process of notifying the people involved of such a match in feelings or interests, while allowing anonymity if no mutual attraction or interests exist. A computer system receives inputs from various persons indicating the identities of persons for whom they feel attraction or with whom they share mutual interests. The system collects this information and periodically searches for matches, for mutual attrac- tions or interests that have been entered into the system. No noti?cation occurs unless the system determines that a match in attraction or interests exists. If a ?rst person?s feelings or interests are not mirrored by a second person, the system will not notify either person and only the computer system will be aware of the ?rst person?s feelings for the second person. 31 Claims, 15 Drawing Sheets Welcome to the Love Detector (description 8. instruction) 602 Please choose the type of feeling you want to netect: K, \0 love 0 like 0 desire 604 Please enter our 1D: 606 Please enter the ID for the obfectls of your feelings: 608 Thank you for using the Love Detector Case Document 1 Filed 11/12/14 Page 57 of 81 U. S. Patent Sep. 7, 1999 Sheet 1 of 15 5,950,200 19.9 . 132 1 34 Display Input Device Device Processor Computer Readable 1 16 . Devnce 1 04 1 12 Detector Database . \l Software FIG. 1 Case Document 1 Filed 11/12/14 Page 58 of 81 US. Patent 1 Sep.7, 1999 Sheetz of 15 5,950,200 202 New user wants to register? 204 input user's real name (and address or other personal information if required) 1 206 Assign password and give password to user (or let user enter a password) 208 I k? Store user name and password in database (and personal information if required) FIG. 2 Case Document 1 Filed 11/12/14 Page 59 of 81 US. Patent Sep.7,1999 Sheet 3 of 15 5,950,200 302 User wants to enter a new attraction or interest (or modify previous selection)? 304 KA Input user ID (and password if required) 306 Input user ID of object(s) (and type of interest if required) 308 Write to database: p} user ID, . user ID of object(s) (and type of interest) FIG. 3 Case Document 1 Filed 11/12/14 Page 60 of 81 US. Patent Sep.7,1999 Sheet 4 0f 15 402 Time for Detection Operation 404 Loop for each user ID in database for each current user) . cap for each object of the current user ID for each current object (or interest? 406 Is the current object attracted to the current user (or do two peOpIe share an interest)? 410 \d Notify the current user and the current object (or interest) 412 1 Loop End (Current object) 1 FIG. 4A 414 . Loop End (Current user) 5,950,200 Case Document 1 Filed 11/12/14 Page 61 of 81 US. Patent Sep. 7,1999 Sheet 5 0f 15 5,950,200 402 Time for Detection Operation 404 - Loop for each user ID in database for each current user) 406 Loop for each user \d database type for each type of attraction) 7 407 Loop for each object for the current user tD for each current object 408 the current object attracted to the current user (or have the same interest)? 410 k?N Notify the current user and the current object i 412 Loop End 43 (Current object) . 3 41 1 for each type of attracty Jr 414 . Loop End (Current user) 116 US. Patent Objects Type of JL Attraction/ User ID Interest User ID #1 Object ID #1 Object ID #2 Object ID #3 Object ID #4 Object ID #5 Sep. 7, 1999 User ID #2 Object ID #1 Object ID #2 UserID#3 ObjectID#?I User Object ID #1 Sheet 6 of 15 User ID Object ID #1 Object ID #2 Case Document 1 Filed 11/12/14 Page 62 of 81 FIG. 5 5,950,200 Case US. Patent 602 K, love 604 606 k, Document 1 Filed 11/12/14 Page 63 of 81 Sep.7,1999 Sheet 7 of 15 5,950,200 Welcome to the Love Detector (description instruction) Please choose the type of feeling you want to detect: 0 like 0 desire Please enter your ID: \7 Please enter the ID for the object/s of your feelings: 610 Enter Clear 608 Thank you for using the Love Detector FIG. 6A Case Document 1 Filed 11/12/14 Page 64 of 81 US. Patent Sep.7, 1999 Sheet 8 of 15 5,950,200 Welcome to the Love Detector (description instruction) 602 Please choose the type of feeling you want to detect: \0 love 0 like 0 desire 604 0 Please enter your ID: 612 606 . Please enter the ID for the object/s \uf I . 610 Enter Clear 608 Thank you for using the Love Detector User ID Objects Attraction Type of John@yahoo.com Kim@lycos.com love Paul@yahoo.com Kim@lycos.com John@yahoo.co Tom@Compuserve. corn like Linda@excite.com Tom@Compuserve. com Kim@lycos.com like Kim@Lycos.com John@yahoo.oom love Tom@Compuserve. com Linda@excite.com love FIG. 7A US. Patent Sep. 7, 1999 Case Document 1 Filed 11/12/14 Page 65 of 81 Sheet 9 of 15 5,950,200 User ID Objects Type of Attraction John Smith Kim Brown love Paul Smith Kim Brown John Smith Linda Jones Tom Green like Linda Jones Tom Green Kim Brown like Kim Brown John Smith love Tom Green Lind-a Jones love FIG. 7B Sep. 7, 1999 Sheet .10 0f 15 5,950,200 U. S. Patent Case 1:14-cv-O9027- LGS Documentl Filed 11/12/14 Page 66 of81 TO: John@Yahoo.com FROM: The Love Detector Congratulations. Both you and Kim@lycos.com have indicated mutual attraction. Good luck. TO: Kim@lycos.com FROM: The Love Detector Congratulations. Both you and John@yahoo.com have indicated mutual attraction. Good luck. FIG. SA Sep. 7, 1999 Sheet 11 of 15 5,950,200 US. Patent Case 1:14-cv-O9027- LGS Documentl Filed 11/12/14 Page 67 of81 TO: John@Yahoo.com FROM: The Love Detector Congratulations. Both you and your loVe interest #1 have indicated mutual attraction. Good luck. T0: Kim@lycos.com FROM: The Love Detector Congratulations. Both you and your love interest #1 have indicated mutual attraction. Good luck. FIG. 88 US. Patent Case 1:14-cv-O9027- Sep. 7, 1999 LGS Document 1 Filed 11/12/14 Page 68 of 81 Sheet 12 of 15 511 c: Case Document 1 Filed 11/12/14 Page 69 of 81 US. Patent Sep.7, 1999 Sheet 13 of 15' 5,950,200 1 01 k? 136 102 Processor Compute! 116 Readable 104 3 Device 1 1 2 Detector Software 113 Database 140 1 Server Software 132 134 Display Input Device Device 106 101' 1 02 k. Processor 104 1 1 15 rowser 9 Software Case Document 1 Filed 11/12/14 Page 70 of 81 US. Patent Sep.7, 1999 Sheet 14 0f 15 5,950,200 Adoption Diagram 1020 Are you a child or a birth-parent? 1030 1040 - loop for each case I00p for each case . number for each child . number for each birth parent ls the current case number of the child matches the case number of the birth parent? 1060 noti?es about matches FIG. 10 A Basic Interface I (for the personal page) (after entering user name and password) Personal YLD for John King, SFCA The One you Love The Ones You Like identified Matches Update FIG. 11 US. Patent Sep. 7, 1999 Case Document 1 Filed 11/12/14 Page 71 of 81 Sheet 15 of 15 5,950,200 Case Document 1 Filed 11/12/14 Page 72 of 81 5,950,200 1 METHOD AND APPARATUS FOR DETECTION OF RECIPROCAL INTERESTS OR FEELINGS AND SUBSEQUENT NOTIFICATION FIELD OF THE INVENTION This application relates to computer software and, speci?cally, to a method and apparatus for con?dentially determining matches in feelings and interests entered into the system by human beings and for notifying the human beings only in cases when a mutual match. in feelings or interests occurs. BACKGROUND OF THE INVENTION Human relationships are often fraught with dif?culties. In addition, human beings are risk-adverse. Often, even when two people want to initiate ?rst steps in a relationship, neither person takes action because of shyness, fear of rejection, or other societal pressures or constraints. Various systems exist that help people meet each other. For example, computer dating services allow people to view video tapes or pictures of prospective partners or to choose common areas of hobbies. Two people are introduced only if both agree with the idea. Unfortunately, in such situations, neither person has actually met the other when they are ?nally introduced. Neither person has ever met the other, and there is a certain amount of shyness and fear of rejection when they ?rst meet in such a situation. In addition, both persons must initially approach the dating service. For some people, such an action can also be embarrassing. What is needed is a safe, simple, con?dential, and non-judgmental way for people to reveal their true feelings and interests Without risk of embarrassment or rejection. SUMMARY OF THE INVENTION The present invention overcomes the problems and dis advantages of the prior art by automating the process of con?dentially determining whether two people feel mutual attraction or interest and, further, by automating the process of informing the people involved of such a match in feelings or interests, while maintaining complete anonymity unless a match of feelings or interests occurs. In a preferred embodiment of the present invention, a computer system receives inputs from various persons indi- cating the identities of persons they already know in person or online) that they like, are attracted to, or have mutual interests with. The system collects this information and searches for matches, for mutual feelings or inter- ests that have been entered into the system. In a simple case, for example, if A and know each other, if A enters information saying that A is attracted to B, and enters information saying that is attracted to A, then the system determines that a match has occurred and noti?es both A and of the mutual attraction. As a second example, if A and know each other, if A enters information saying that A has a mutual interest with B, and enters information saying that has a mutual interest with A, then the system determines that a match has occurred andnoti?es both A and of their shared interest. Thus, the present invention provides an provides a safe, con?dential and non-judgmental way for people to make their feelings and interests known without risk of embar? rassment of fear of rejection. The present invention also provides an automatic way of notifying people of shared attraction or interests. The system maintains the anonymity the participants because no noti?cation occurs unless the system determines that a match in feelings or interests exists, Thus, in the example, Awill not be embarrassed by having to publicly admit unrequited love or attraction for B. If A?s feelings are not mirrored by B, the system will not notify and only the computer system will be aware of A?s feelings for B. i In accordance with the purpose of the invention, as embodied and broadly described herein, the invention is a method notifying people that they feel mutual interest, comprising the steps, performed by a processor of a data processing system having a memory, of; receiving input from a ?rst user indicating a user ID of a ?rst object in whom the ?rst user has an interest; receiving input from a second user indicating a user ID of a second object in whom the second user has an interest; determining whether the user ID of the ?rst object matches a user ID of the second user and whether the user ID of the second object matches a user ID of the ?rst user; and if a match occurs in the determining step, notifying the ?rst user and the second user that a match has occurred. In further accordance with the purpose of this invention, as embodied and broadly described herein, the invention is an apparatus that con?dentially noti?es people that they feel mutual interest, comprising a ?rst input portion, con?gured to receive input from a ?rst user indicating a user ID of a ?rst object in whom the ?rst user has an interest; a second input portion, con?gured to receive input from a second user indicating a user ID of a second object in whom the second user has an interest; a determining portion, coupled to the ?rst and second input portions, con?gured to determine whether the user ID of the ?rst object matches a user ID of the second user and whether the user ID of the second object matches a user ID of the ?rst user; and a notifying portion, coupled to the determining portion, con?gured to notify the ?rst user and the second user that the determining portion has detected a match, wherein the determining step is performed at a predetermined interval. Advantages of the invention will be set forth in part in the description which follows and in part will be obvious from the description or may be learned by practice of the inven- tion. The objects and advantages of the invention will be realized and attained by means of the elements and combi- nations particularly pointed out in the appended claims and equivalents. BRIEF DESCRIPTION OF THE DRAWINGS The accompanying drawings, which are incorporated in and constitute a part of this speci?cation, illustrate several embodiments of the invention and, together with the description, serve to explain the principles of the invention. FIG. I is a block diagram of a computer system in accordance with a preferred embodiment of the present invention. FIG. 2 is a ?ow chart showing steps performed in accor- dance with a preferred embodiment of the present invention to register a new user in the system. FIG. 3 is a ?ow chart showing steps performed to allow a human user to register an attraction. FIGS. 4(a) and are flow charts showing steps to detect mutual attraction or interests. FIG. 5 is an exemplary format of a database used in conjunction with a preferred embodiment of, the present invention. FIGS. 6(a) and show examples of a screen shot of a form allowing a user to input an attraction for another person or an interest. Case Document 1 Filed 11/12/14 Page 73 of 81 5,950,200 3 FIGS. 7(a) and show examples of database entries representing mutual interest. FIGS. 8(a) and 8(b) show examples of e-mail messages indicating mutual interest. FIG. 9 is a block diagram showing an example of the present invention implemented using the World Wide Web. FIG. 10 is a ?ow chart showing a method performed to match persons whose interests are in ?nding their birthpar? ents and in ?nding children placed for adoption. FIG. 11 shows an example of a personal Web page used by a preferred embodiment of the present invention. DETAILED DESCRIPTION OF THE PREFERRED EMBODIMENTS Reference will now be made in detail to the preferred embodiments of the invention, examples of which are illus? trated in the accompanying drawings. Wherever possible, the same reference numbers will be used throughout the drawings to refer to the same or like parts. FIG. 1 is a block diagram of a computer system 100 in accordance with a preferred embodiment of the present invention. Computer system 100 includes a processor 102 and a memory 104. Memory 104 includes detector software 112 and a database 116. Database 116 contains information relating to attractions and/or interests entered by human beings. System 100 preferably connects to a display device 132, such as a display screen, and to an input device 134, such as a mouse or touchpad. Computer system 100 also includes a computer readable device 136, such as a disk drive or CD ROM device. Detector software 112 is- prefer? ably loaded into memory 104 via device 136. Computer system 100 is preferably connected to a network, such as the Internet or an intranet via a connection 140. Computer system 100 includes appropriate software to enable computer system 100 to communicate with other computer systems over connection 140. In other embodiments, various functions of detector soft- ware 112 may be distributed in various computer systems of the network. An example of a World Wide Web implemen? tation of detector software 1.12 is shown in FIG. 9, which is discussed below. It will be understood by persons of ordi- nary skill in the art that computer system 100 can include additional processors, memory, network connections, devices, software, etc. that are not shown in the Figures for the sake of clarity of example. The present invention can be implemented on a wide variety of hardware, including those shown in FIGS. 1 and 9, or other suitable hardware con?gurations, such as network computers (NCs) and sys- tems that bring the World Wide Web to TV. In an alternate preferred embodiment (not shown), com- puter system 100 includes an interactive telephone input system (not shown) that allows the user to input attraction or interests to detector software 112 using the keys on a touchtone telephone or a similar device. The present invention provides a way for people to indicate their mutual attraction or interests without fear of rejection, embarrassment, or public attention. The invention allows people to enter the names (or 1135) of other people for whom they feel love or attraction or with whom they believe they share an interest. These people are called ?objects.? The system periodically noti?es people who are mutually attracted or have mutual interests. The term ?interest? includes emotional interests, such as like, love, attraction, or other emotional feelings. The term ?interests? also includes non-emotional interests. Examples of persons having nonemotional interests include business people who are inter- ested in pursuing a deal or merger with another business, or persons wishing to enter into any other type of transactions where fear of non-con?dentiality, fear of rejection, a wish to avoid publicity, etc. are a factor. In other embodiments, various functions of detector soft- ware 112 may be a part of the Web, an online service such as America Online or Compuserve or part of an interactive telephone system. Thus, the software 112 may be distributed in various computer systems of the network. FIGS. 2?4 are ?ow charts showing steps performed in accordance with the present invention. The steps of FIGS. 2?4 are performed by processor 102 and preferably are implemented as computer instructions of software 112 executed by processor 102. Each of these ?ow charts is discussed below in turn. FIG. 2 is a ?ow chart showing steps performed in accor- dance with a preferred embodiment of the present invention to register a new user in the system. The registration operation is generally, but not always, performed. Registra- tion lessens the possibility that people are logging on under false names and increases the security of the system. If, however, the system has only a small number of trusted users, all of whom are known to the system, then it might not be as necessary to register the users. In step 202, the detector software determines that a new user wants to register with the system. In step 204, detector software prompts the user to enter his or her real name and address. In step 206, a password is assigned to the user and communicated to the user (or the user enters a password). Step 208 stores the user name, and password (and optional personal information) in memory 104. If a particular imple- mentation of the invention includes a registration procedure, the user will be required to enter his or her password before he or she is able to enter new objects into the database in the future or modify a previous selection. Use of a password makes it less likely that people will log on under a false name and enter false objects into the database. Other ways to authenticate user identity include the use of public/private keys, digital signatures, or biometrics, such as fingerprint or retinal scans. In general, any appropriate method can be used to authenticate users. FIG. 3 is a ?ow chart showing steps performed to allow a human user to register love or attraction. In step 302, the detector software determines that the user wants to enter a new object. For example, the user might select ?Enter New Object? from a menu. If the user wants to make new entries, in step 304, the user is prompted (via display device 132) to enter his or her user ID. A user II) can take various forms. For example, the user may have been assigned an alphanu- meric ?handle? or an ID number. Alternately, the user ID may simply be the user?s name or e~mail address. A user ID can also be any other type of personal identi?cation, such as social security number, drivers license number, telephone number. A user ID can also be any of the above, with a geographic identi?er ?gil sudai san francisco california?). Alternately, the geographic identi?er can be considered a part of the user ID. It is important to note, however, that the ID used user name) be known to the other users so that the users can enter the into the system. Alternately, any suitable identi?er can be used as a user ID. As discussed above, the user may also be prompted to enter a password (or chooses a password) before he or she is allowed to enter new objects. Step 306 prompts the user to enter the user of one or more ?objects.? A ?rst Case Document 1 Filed 11/12/14 Page 74 of 81 5,950,200 5 implementation requires the user to type the of the objects. In such a system, the identities of the users are not revealed to other users. Another implementation allows the user to select objects from a list of all possible objects (see areas 612 on FIG. In such a system, the identities of the users are revealed to other users. Step 306 also allows users to indicate the type of attrac? tion or interest?he or she feels for his or her objects. For example, if the system allows the user to enter an attraction, the user can indicate whether he or she feels ?love,? ?like,? or ?desire? for the objects. In a preferred embodiment, the user must choose these types from a predetermined list. Some implementations only have a single type of attraction. Other implementations default to ?like.? The present inven? tion may be implemented using any appropriate numbers and types of attraction. FIGS. 6(a) and 6(b) show examples of a computer screen of a form allowing a user to input an attraction for another person. The example of FIG. 6(a) shows a ?Web form? displayed on display device 132 by browser 115 of FIG. 9. This form can be implemented using HTML, Java, or any other suitable method. The user uses input device 134 of FIG. 9 to enter information and browser software 115 sends the information to server software 113, where it is passed to detector software 112. As discussed above, any appropriate technology can be used to implement the present invention. In FIG. the user chooses between ?love,? ?like,? and ?desire? 602. The user enters his or her ID in area 604. The user enters one or more objects in area 606. After inputting entries in areas 602, 604 and 606, the user can either ?enter? the information by clicking on area 608 or clear the infor- mation by choking on area 610. If the user indicates that the information should be entered, step 308 makes an entry in the database including the user ID, the user ID of the objects, and the types of attraction (if applicable). An alternate embodiment does not use a ?prompt and enter? model, but instead allows the user to register and to input his or her objects using e-rnail. Instead of being prompted for the information shown in FIG. 6, the user sends an e~mai1 message to the detector software 112, where the e-mail message contains the user?s ID, the IDs of the user?s object(s) of attraction, and the type of attraction (if applicable). Still another preferred embodiment allows the user to enter his or her ID and attraction or interest using an interactive telephone system. In this embodiment, the user calls a predetermined telephone number and is asked by a prerecorded message to enter his or her user ID using the keypad of their telephone (this could be, for example, a telephone number or any other type of appropriate user ID). The user is then prompted to enter the user ID of a person to whom he or she is attracted (or shares interests). The system then prompts the user to enter a type of interest of attraction. For example, the system may prompt ?for liking, press one, for desire, press two.? Once the user has entered information using such an interactive telephone system, detection and noti?cation proceed in any of the ways described herein. A preferred embodiment of the invention also allows the user to delete and change his or her objects. If the u5er indicates that a previously entered object should be deleted (and enters a correct password if required), the object is deleted from the database. FIG. 4(a) is a ?ow chart showing steps to detect mutual love or attraction. In a preferred embodiment of the invention, detector software 112 periodically performs the steps of FIG. For example, the steps may be performed once a day. In an alternate embodiment, the determining step is performed each time a user enters objects. In an alternate embodiment, the steps may be performed at a predetermined ?noti?cation time? such as every Monday morning between 8am and 9am. Steps 404 through 414 represent a loop performed for each user ID in the database. Steps 406 through 412 represent a loop performed for each object for the current user ID. It should be understood that, although the described system detects matches for two persons, the system can be expanded to detect matches among any number of persons. FIG. 5 shows an exemplary format of a database used in conjunction with the described embodiment. It will be understood that the format shown is provided only for the purposes of example and that any appropriate database and database format can be used to implement the present invention. Each entry in the database 116 includes a user ID, and one or more user IDs of objects. Each entry in the database can also include a single type of attraction or interest for all objects in the entry or can contain a type of attraction or interest for each object in the entry. Some implementations have predetermined number of objects per user ID. Other implementations allow an unlimited number of objects. In the described embodiment, it is known that each current user is attracted to (or has mutual interests with) his or her object(s). Step 408 of FIG. 4(a) determines whether the current object is also attracted to (or has mutual interests with) the current user ID. If the database has a ?eld indicating a type of attraction or interest, then step 408 also checks whether the type of attraction or interest indicated by the user and the 'object is the same. In some implementations, the type of attraction or interest must match. Inother implementations, all types match all types. In still other implementations, each user may indicate whether he or she wants to consider types of attractions or interests in determining whether a match has occurred. FIG. 7(a) shows an example of a match where the user iDs are e-mail addresses and the types of attraction must match. In FIG. a user having the user ID ?john@yahoo.com? (his e~mail address) has indicated that he loves a user having a user ID of ?kim@1ycos.com.? Conversely, has indicated a feeling of love for ?john@yahoo.com.? Thus, a match occurs and both parties are noti?ed as discussed below. In FIG. Tom and Linda entered each other"s IDs, but indicated different types of attraction, so no match occurred. In other implementations, Tom and Linda would also match, even though they indicated different types of attractions. FIG. 7(b) shows an example of a match where the user IDs are the full names of the users. Again. John Smith and Kim Brown match. FIG. 4(b) shows another preferred embodiment having three loops. In this embodiment, each type of attraction or interest is stored in a dilferent database. In FIG. the third loop is for each type of attraction or interest database. In this embodiment, both the user and the object must have indicated the same type of attraction or interest for a match to have occurred; If a match occurs, step 410 noti?es the user and object that a match has occurred. As discussed below, this noti?cation can take place in various ways. (A preferred embodiment checks to determine that only one noti?cation occurs for each user/object pair). FIGS. 8(a) and 8(b) show examples of e?mail messages notifying the users of FIG. 7 of a mutual Case Document 1 Filed 11/12/14 Page 75 of 81 5,950,200 7 attraction Similar messages would be used to notify users of a mutual interest. In the messages of FIG. the noti?- cation message identi?es the users to each other by their user ID. In this example, the users may or may not know each other?s true names. They are able to contact each other by e?mail and arrange a meeting if they so desire. In another preferred embodiment, shown in FIG. noti?cation may not include the ID of the objects, but may state only, for example, that ?your object has indicated mutual interest.? This increases security because only the user receiving the e-mail knows the identity of his ?object (In some systems, the user also can check the system to verify the identity of his various objects). in a preferred embodiment, noti?cation preferably is performed simultaneously for both parties, once a match is discovered. In an alternate-embodiment, both parties have previously agreed that one of the parties wants to be surprised, and noti?cation is not simultaneous. For example, both a man and a woman may have agreed when they registered that the man will be noti?ed 24 hours ahead of the woman when a match occurs. Thus, the man can initiate personal contact with his object once he is noti?ed of the match. Some persons may prefer this alternative, if they both believe that men should make the initial move. In another preferred embodiment, noti?cation can be performed by an automatic telephone call made by the computer system 100; the World Wide Web (via a personal page or a general page using a user?s II) and password); any other method of online communication; or any other appro- priate noti?cation method. In addition, detector software 112 can include sub? sections which would work independently and which would be de?ned by one or more of the following: the geographic location a sub-system that matches only users in the San Francisco area) the type of user a sub-system that would only match high school students with high school students, university students with university student, club members with club members, etc.) An alternate embodiment is implemented for a ?private label,? such as speci?cally for users belonging to a club, a company, a school, restaurant, bar, or another entity. For example, the users may enter their attractions and/or inter- ests via a Web page that requires a password to gain access. Other implementations would only match club or group members with other club or group members. Alternate embodiments of the present invention imple- ment ?rules? included, for example, in software 112, such as: a person can choose only one ?love? object and will not be able to change this object for at least one month. a person can choose up to ?ve ?like? objects and is able to change any one of the objects at any time. Such rules are implemented as computer instructions executed when the user is entering new objects. FIG. 10 is a ?ow chart showing a method performed to match persons whose interests are in ?nding their birthpar- cuts and in ?nding children placed for adoption. This is a special case of the general ?interest matching and noti?ca- tion? method described above. The adoption detector system detects and noti?es persons who gave children up for adoption (the ?birth parent?) and the children adopted (the ?child?). One implementation of such a system detects and noti?es both parties when the parties know each other?s name (or when the birthname of the child is known). Such a system detects matches similarly to the detection of mutual attrac- tion or interests described above: When A enters B?s name and enters A?s name, the system determines that the two people want to contact each other and noti?es them in any of the manners described above. In another implementation, each adoption ?le is assigned a case number. If two persons enter the same caso number, then noti?cation occurs using any of the methods described above. In another implementation, the birthparent and child each separately registers his or her name is a database, where it is stored along .With a case number for the adoption (Such as system requires that the registrant?s case number already be stored in the system). As shown in FIG. 10, if both the birthparent and the child have registered, this fact is deter- mined in step 1050. If a match is detected, both parties are noti?ed of the match in any of the manners described above. Such noti?cation may indicate merely that a birthparent/ child match has occurred and that the parties should now indicate a level of contact with which they feel comfortable. Other noti?cation methods notify the birthparent/child of each others names, addresses, or other suitable contact information. Note that the adoption detector maintains ano- njnnity of the birthparent and the child and does not notify either party unless it detects that there is mutual interest. FIG. 11 shows an example of a personal Web page used by a preferred embodiment of the present invention to receive input from a user. This is yet another method of combining the entry of input by users and noti?cation to users that can be used with any of the variations of the present invention described herein. The user enters the names of the person(s) to whom he or she is attracted or shares interests. At noti?cation time, the system modi?es the personal pages of the user and his object to display the IDs of the persons who entered mutual attraction (or interests). Thus, a user simply looks at his or her personal Web page (using a browser) to determine whether any matches necurred. . Other embodiments will be apparent to those skilled in the art from consideration of the speci?cation and practice of the invention disclosed herein. It is intended that the speci?ca~ tion and examples be considered as exemplary only, with a true scope of the invention being indicated by the following claims. What is claimed is: 1. A method that noti?es people that they feel reciprocal interest for each other, comprising the steps, performed by a processor of a data processing system having a memory, of: receiving input from a ?rst user indicating a user ID of a speci?c person in whom the ?rst user has an interest, the ?rst user already being aware of the existence of the person whose ID they entered; receiving input from a second user indicating a user ID of a speci?c person in whom the second user has an interest, the second user already being aware of the existence of the person whose ID they entered; determining whether the user ID of the person in whom the ?rst user has an interest matches a user ID of the second user; determining whether the user ID of the person in whom the second user has an interest matches a user ID of the ?rst user; and if and only if a match occurs in both of the determining steps, notifying the ?rst user and the second user that a match has occurred. 2. The method of claim 1, wherein the determining steps are performed at a predetermined interval. Case - Document 1 Filed 11/12/14 Page 76 of 81 5,950,200 9 3. The method of claim 1, where the determining steps are performed immediately after receiving user input. 4. The method of claim 1, where the determining steps and the noti?cation step are performed at a predetermined ?noti?cation time.? 5. The method of claim 1, wherein if the ?rst user?s feelings are not mirrored by the second user, the system will not notify either user and only the computer system will be aware of the ?rst user?s feelings for the second user. 6. The method of claim 1, wherein the step of receiving input from a ?rst user indicating a user ID of a person includes receiving input from the ?rst user through the World Wide Web. 7. The method of claim 1, wherein the step of receiving input from a ?rst user indicating a user ID of a person includes receiving input from the ?rst user by way of e-mail. 8. The method of claim 1, wherein the step of receiving input from a ?rst user indicating a user ID of a person includes receiving input from the ?rst user by way of an interactive telephone system. 9. The method of claim 1, wherein the step of receiving input from a ?rst user indicating a user ID of a person includes receiving input from the ?rst user by way of software executing on an online service. 10. The method of claim 1, wherein the step of receiving input from a ?rst user indicating a user ID of a person includes receiving input from the ?rst user by way of software executing on another data processing system in a network. 11. The method of claim 1, further comprising the steps of: registering the ?rst user; and assigning a password to the ?rst user. 12. The method of claim 1, wherein the ?rst and second users also enter a type of attraction and wherein the determining steps determine that a match has occurred only when the ?rst and second users also enter the same type of attraction. 1.3. The method of claim 1, wherein the ?rst and second users also enter a type of attraction, and . wherein the determining steps determine that a match has occurred no matter what types of attraction the ?rst and second users enter. 14. The method of claim 1, wherein the ?rst and second user IDs are one of the group including: a user name, an e-mail address, a social security number, a drivers license number, a telephone number, a name, a name with a geo? graphic location, and a public key. 15. The method of claim 1, wherein the ?rst and second user IDs also include a geographic designation. 16. The method of claim 1, further comprising the step of: receiving, from the ?rst user and the second user a type of attraction, including one of ?love,? ?like,? and ?desire.? 17. The method of claim 1, wherein at least one of the ?rst user or the second user enters the ID of more than one person in whom they have an interest. 18. The method of claim 1, wherein the noti?cation step automatically sends an e-mail message to the ?rst user and the second user notifying them that a match has occurred. 19. The method of claim 1, wherein the noti?cation step automatically places a telephone call to the ?rst user and the second user notifying them that a match has occurred. 20. The method of claim 1, wherein the noti?cation step automatically displays noti?cations on a personal Web pages 10 of the ?rst and of the second users, notifying them that a match has occurred. 21. The method of claim 1, wherein the step of receiving input from the ?rst user further includes the step of imple? menting a rule about how many persons can be chosen for each type of attraction. 22. The method of claim 1, wherein the step of receiving input from the ?rst user further includes the step of imple- menting a rule concerning the frequency with which persons can be changed by the users. 23. The method of claim 1, wherein the method is implemented for users of a speci?c geographic location. 24. The method of claim I, wherein the method is implemented for users who belong to a speci?c institution. 25. The method of claim 1, wherein the method is implemented for users who are af?liated with a speci?c organization. 26. The method of claim 1, wherein the ?rst user is a birthparent and the second user is an adopted child. 27. The method of claim 1, further comprising: in response to the data processing system receiving the input of the ?rst user, which indicates interest in the second user, but before receiving the input of the second user, sending a prompt to the second user that someone has indicated interest in the second user, without saying who it was that indicated interest, thereby prompting the second user to enter one or more IDs of people in whom the second user has an interest. 28. An apparatus that noti?es people that they feel recip- rocal interest for each other, comprising: a ?rst input portion, con?gured to receive input from a ?rst user indicating a user ID of a speci?c person in whom the ?rst user has an interest, the ?rst user already 'being aware of the existence of the person whose ID they entered; a second input portion, con?gured to receive input from a second user indicating a user ID of a speci?c person in whom the second user has an interest, the second user already being aware of the existence of the person whose ID they entered; a ?rst determining portion, coupled to the ?rst and second input portions, con?gured to determine whether the user ID of the person in whom the ?rst user has an interest matches a user ID of the second user; a ?rst determining portion, coupled to the ?rst and second input portions, con?gured to determine whether the user ID of the person in whom the second user has an interest matches a user ID of the ?rst user; and a notifying portion, coupled to the ?rst and second deter- mining portions, con?gured to notify the ?rst user and the second user if and only if the ?rst and second determining portions have detected a match. 29. An apparatus that noti?es people that they feel recip~ rocal interest for each other, comprising: means for receiving input from a ?rst user indicating a user ID of a speci?c person in whom the ?rst user has an interest, the ?rst user already being aware of the - existence of the person whose ID they entered; means for receiving input from a seconduser indicating a user ID of a speci?c person in whom the second user has an interest, the second user already being aware of the existence of the person whose ID they entered; means for determining whether the user ID of the person in whom the ?rst user has an interest matches a user ID of the second user and for determining whether the user ID of the person in whom the second user has an interest matches a user ID of the ?rst user; and Case Document 1 Filed 11/12/14 Page 77 of 81 5,950,200 11 means for, coupled to the determining means, if and only if a match occurs in both of the determining means, notifying the ?rst user and the second user that a match has occurred. 30. The apparatus of claim 28, further comprising: a portion con?gured to send, in response to the apparatus receiving the input of the ?rst user, which indicates interest in the second user, but before receiving the input of the second user, to send a prompt to the second user that someone has indicated interest in the second user, without saying who it was that indicated interest, thereby prompting the second user to enter one or more IDs of people in Whom the second user has an interest. 31. A computer program product, comprising: a computer usable medium having computer readable code embodied therein for notifying people that they feel reciprocal interest for each other, including: computer readable program code devices con?gured to cause a computer to effect receiving input from a ?rst user indicating a user ID of a speci?c person in whom the ?rst user has an interest, the ?rst user already being aware of the existence of the persdn whose ID they entered; 10 20 12 computer readable program code devices con?gured to cause a computer to effect receiving inth from a second user indicating a user ID of a speci?c person in whom the second user has an interest, the second user already being aware of the existence of the person whose ID they entered; computer readable program code devices con?gured to cause a computer to effect determining Whether the user ID of the person in whom the ?rst user has an interest matches a user ID of the second user; computer readable program code devices con?gured to cause a computer to effect determining whether the user ID of the person in whom the second user has an interest matches a user ID of the ?rst user; and computer readable program code devices con?gured to cause a computer to effect, if and only if a match occurs in both of the programming code devices, notifying the ?rst user and the second user that a match has occurred. Case Document 1 Filed 11/12/14 [Page 78 of 81 Exhibit . z? J'Swipe on the App Store . . 3mm i?wxgea ?ew ?on: {#133315 mm By Smooch Labs Open thmES to buy and download apps. Case 1 Description ijipe is the #3 Jewish dating app With users in over 70 caumrlesi We make ?nding that someone you take home for matzo ball mus: as fun as *should? be. Fina your long lam lave summer tampl Me 5mm? Jaime What's New in Version 2.6 Now you can update you: profile with latest Facebook interests by going lulu your Profile and tapping ?Ugdate Interests From Facebook?? Category: Lifestyle Wm? Updated: Nay (ll, .2014 Versmn? 2.6 Size 13.2 ms iPhone Screenshot Languages: English, Bakm?l, Norwegian. Catalan, Czech, Danish Dutch, French. German. Greek, Hebrew, Indonesian; ltallar'f, Japanese. Korean, Norwegian Nynorsk, 9035b} Portuguese, Russian; Simplified Chmesel Sgamsh, Swedish, Traditional Chinese, Turkish Ukrainian, Vtetnamese Selle: Smooch Labs incl 2014 Smooeh Labs Yw must be a: least 37 years old to downluad this amp. Sinwlatecf Gambling qunemilntense Matureg'Suggestlve Themes Compatib??ly; Requlr? i022 7.0 or later Compatible with I'Phrme, il7?aa2lx and IPnd touch? This app is aptimized for Whom: SA Documentl Filed 11/12/14 Page 79 of 81 Customet Ratings Current Velvsimm Case Document 1 Filed 11/12/14 Page 80 of 81 Exhibit" nay?; 39E ma ?nm Wmutn mi skuuki? u: a Urban Dictianmy?. Swipe right I We Edit View Favorites ?Fan Hefp {in {z'ntjr?xuav maximal Swipe right at 9 (math) A phrase used t0 describe your acceptance ofsomething. The term was originaify a reference to the Tinder app? 0n Tinder, swiping right means you; approve of a maEeXfemaie afterjudging them by a few picture and a short bio. "Swipe right" can he used anytime you make a good choice or awrwe of semething. migraine! usaga? f?atgf? Hannah ever there is realgjy hart. waufd de?niteafswme right on ?ea Other uses: ?These burritos are so go ad! I am glad we swiped right cm mjko?a? Tam: ?idyoa see the trailerfor Mat new Wa?eo game? Dan: Swwe right! Dana: How daymx feel about Nit: Cage? Peter: .9sz nfgb?. Na ?ame. by Manual Eran simmer 2m Case Document 1 Filed 11/12/14 Page 81 of 81