(1.) The plaint alleges infringement, by Defendant 1, of the trademarks "WESTERN DIGITAL", "WD", "MY PASSPORT" and "MY CLOUD" (referred to, jointly, in the plaint as the "Western Digital Trademarks").
(2.) The plaintiff claims to be a world renowned manufacturer of storage devices, media player, routers/switches/bridges, solid state drives, software and mobile applications, manufactured and sold under the Western Digital Trademarks.
(3.) The plaint alleges that Defendant 1 has registered the domain names "wd-my-passport.com", "wdmypassport.co" and "support-wdc.com". In registering these domain names, the plaint alleges that the defendants are attempting to make it appear that they are associated with the plaintiff by incorporating, in the domain names, the plaintiff's registered trademarks "WD" and "MY PASSPORT".