Listed on 2022-12-11. See Doc. Rev. 2003) (Under Missouri law, an agreement is actionable if it is specific enough to determine when one of the parties is in breach and provides a basis for giving a remedy.). Trilliant Food and Nutrition, headquartered in Little Chute, Wisconsin, has been a pioneer in the U.S. specialty coffee market since 1979. Competitive salary. Mar. Accordingly, Plaintiff's Amended Complaint must be dismissed as to Defendant Trilliant. Case Summary. Doc. Access this case on the Wisconsin Eastern District Court's Electronic Court Filings (ECF) System. 500+ connections. Our Products - Trilliant Home About Our Capabilities Our Products Careers Contact Buy Available Products Treat yourself without a trip to the coffeehouse Roasted to perfection since 1979 Treat yourself without a trip to the coffeehouse Roasted to perfection since 1979 Our Products Take a closer look at our single serve capsules Trilliant and Horseshoe Beverage share one HR person, don't expect them to care about you. 355 Byrd Ave, Neenah, WI 54956. 36. Doc. The requirements of personal jurisdiction must be met as to each defendant. [48] at 6. Coffee, tea, cocoa, sugar, rice, tapioca, sago, artificial coffee; flour and preparations made from cereals, bread, pastry and confectionery, ices; honey, treacle; yeast, baking powder; salt, mustard; vinegar, sauces (condiments); spices; ice. A. 595 KING ST UNIT 4 . Production Associate / Production Line, Automation. This role will give you the chance to work in one of the most technologically advance processing facilities in the state. Horseshoe Beverage Company LLC Trilliant Food and Nutrition LLC Attorney/Law Firm Details Plaintiff Attorney Paul N. Rechenberg Attorney at RECHENBERG LAW LLC 215 Chesterfield Business Parkway Chesterfield, MO 63005 Defendant Attorneys Jonathan T. Barton Attorney at STANTON BARTON LLC 8000 Maryland Ave., Suite 450 St. Louis, MO 63105 Instead of dismissing the case for want of jurisdiction, however, the Court may transfer it pursuant to 28 U.S.C. 506.500.1(2). Our experts analyze trends, identify opportunities and create innovative products to enhance and enrich consumers beverage experiences. Fastpath, Inc. v. Arbela Techs. Manufacturing. A plaintiff's prima facie showing is tested, not by the pleadings alone, but by affidavits and exhibits supporting or opposing the motion. Id. [47-2] Ex. 100% Decaf Colombian, 80 Count, Medium Roast, Single Serve Coffee Pods for Keurig K-Cup Brewers. Defendant Trilliant Food and Nutrition LLC is a Wisconsin limited liability company with its principal place of business in Little Chute, Wisconsin, and Defendant Horseshoe Beverage Company LLC is a Wisconsin limited liability with its principal place of business in Neenah, Wisconsin. "For our state-mandated Sexual Harassment and Discrimination training, we wanted something easy and affordable, but also entertaining and interactive for our employees.The Traliant Team was very responsive and helpful in setting up and implementing the training courses. The Amended Complaint does not allege anything related to Trilliant other than that it is a limited liability company in good standing. Doc. OU Kosher is the clear leader in the kosher food industry. [47-2] Ex. [48] at 5-6. Plaintiff bears the burden to make that showing by pleading sufficient facts to support a reasonable inference that the defendant can be subjected to jurisdiction within the [forum]. . Oct. 24, 2011) (citing Goldlawr, Inc. v. Heiman, 369 U.S. 463, 466 (1962)); Mayo Clinic v. Kaiser, 383 F.2d 653, 654 (8th Cir. 1 (Sholtis Declaration) 3, 4. HORSESHOE BEVERAGE COMPANY, headquartered in Neenah, WI, is a leading ready-to-drink beverage manufacturer focused on providing consumers . . First, on review of the filings, the Court does not find that Plaintiff has taken any action to intentionally cause delay in this case or to increase the cost of the litigation by filing suit in this Court. [49] at 9. Plaintiff argues that the four undecided dates were material to the Agreement, and thus the contract was not executed until it initialed next to the proposed dates, which happened in St. Louis County, Missouri, not Wisconsin. 1406(a). Doc. 2020) (citing Bristol-Myers Squibb Co. v. Superior Court of California, San Francisco Cty., 137 S.Ct. Neenah, Wis.-based Horseshoe Beverage Co. known for its Black Stag brand of premium craft coffee beverages said it is introducing a new ready-to-drink (RTD) coffee line to consumers. Mo. Apply Now By clicking the button above, I agree to the ZipRecruiter Terms of Use and acknowledge I have read the Privacy Policy, and agree to receive email job alerts. 74 CHURCHILL AVE . Doc. Career Aviation Sales, Inc., 952 S.W.3d at 326. Fleishman-Hillard, Inc. v. McCombs, 2011 WL 5039809, at *5 (E.D. Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. The "Trilliant Estate" of 12 million devices creates and stores in excess of 100 Million meter readings and event updates every day. Strategic marketing and merchandising support drive product sales and build brand loyalty. Each premium coffee is crafted to deliver the unique flavor and crema of a handmade espresso. First Use in Commerce: Not Available, Class 030 [46] 4. Manufacturing Production, Manufacturing Technology, Production Associate / Production Line. 100% Colombian, Medium Roast, Whole Bean, 2.5lb Bag. evaluation on your mark; recommends you the appropriate class(es) and Licensed lawyer works on your case; conducts trademark search and Likewise, Plaintiff's supporting documents, including its Memorandum in Opposition of Defendants' Motion to Dismiss and the declaration of Mr. Davis, provide no jurisdictional basis as to Trilliant. While foreseeability is relevant to the due process prong of specific personal jurisdiction, the long-arm statute must be satisfied first. Plaintiff bears the burden of proof for establishing personal jurisdiction. Welland, ON $1,600 + Gas & Hydro AVAILABLE NOW . Our products are processed and packaged exclusively at our state-of-the-art, SQF Level 3 certified facility. Our vast selection, commitment to quality, and industry-leading innovation ensures that every consumer gets the very best in variety, taste and value. Defendants were also responsible for performing quality control checks on the batches of beverages and for ensuring that the beverages were suitable for human consumption. Doc. Docs. Doc. Mo. Steakhouse Food Runner - Part Time (Horseshoe Hammond) . Mo. 7, 2018). ; see also Visiting Nurse Ass'n, St. Louis v. VNAHealthcare, Inc., 347 F.3d 1052, 1054 (8th Cir. Copyright 2022 Trademark Elite. Haven Property Management > Properties . based on trilliant food and nutrition, llc, horseshoe beverage company, llc, the victor allen's reserve trademark will be used in the following business: cappuccino; cocoa; coffee; espresso; tea; cocoa beverages with milk; coffee based beverages; coffee beans; coffee beverages with milk; coffee capsules containing coffee for brewing; coffee Caroline E. Bryce, 1 15, 16, Ex. Channel Solutions We have everything you need to grow your business by keeping up with ever-changing consumer trends. Only four dates were missing on one page of a 17-page Agreement. The Rainforest Alliance works to preserve biodiversity and to ensure sustainable livelihoods of coffee farmers by transforming land use practices, business practices and consumer behavior. 2 days ago Mindy Decker, Human Resources Analyst, City of Ontario, CA. 18, 2022). [47]) is GRANTED in part and DENIED in part. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia. Doc. B. Doc. 2 BEDROOM. See Docs. [46] 34-36; [47-2] Ex. HORSESHOE BEVERAGE COMPANY, headquartered in Neenah, WI, is a leading ready-to-drink beverage manufacturer focused on providing consumers with an outstanding beverage experience wherever, whenever. Rent-A-Car Co. v. Stow ell, 137 F.Supp.2d 1151, 159 (E.D. Trademark Serial Number is a Unique ID to identify the VICTOR ALLEN'S RESERVE mark in USPTO. . Shortly thereafter, in the summer of 2019, Defendants defectively manufactured and packaged approximately 6, 500 cases of Madrinas coffee. Unbeatable Attorney Service in both Professionalism and Price. 2015). The Court's decision to transfer rather than dismiss a case is discretionary, but generally 1406(a) is construed wherever possible to remove procedural obstacles which would prevent expeditious and orderly adjudication of a case on its merits. Enter. Plaintiff believed it would receive favorable terms in exchange for the business but did not. Defendants move to dismiss Plaintiff's Amended Complaint pursuant to Federal Rules of Civil Procedure 12(b)(2) and 12(b)(6), arguing that Plaintiff fails to establish personal jurisdiction over them and also states no claim upon which relief may be granted. Docs. banc. We have everything you need to grow your business by keeping up with ever-changing consumer trends. 3, 4; Doc. On 09/11/2020 Madrinas Brands, LLC filed a Contract - Other Contract lawsuit against Horseshoe Beverage Company LLC. Wisconsin . Search Production jobs in Menasha, WI for trilliant food and nutrition. C (Trilliant Agreement). All Rights Reserved. 506.500.1(2). Compare management, culture and compensation ratings for Horseshoe Beverage Company and Trilliant Food & Nutrition. * U.S. Layoffs before being open a year (directly after a company meeting where they expressed a ton of growth and that things looked good), never worked the shift I was hired for (was told on my first day I had to work 1p-1130p for a short period of time I was hired for third shift . Today, we continue to produce our delicious coffees with a passion for excellence, just as in 1979. Individual salaries will, of course, vary depending on the job, department, location, as well as the individual skills and education of each . Trilliant Food & Nutrition, LLC Neenah, WI Full-Time. [47-1] (citing Doc. Profiled on NYTimes, IEEE, TechCrunch. Listing for: Trilliant Food & Nutrition, LLC. Use the links below to access additional information about this case on the US Court's PACER system. (lh), Case Assigned to Judge William C Griesbach (Original assignment made in error; this is a Green Bay Division case) (vkb), Case Opening Notification: All non-governmental organizational parties (corporations, limited liability companies, limited liability partnerships) must file Disclosure of Organizational Interests Certificate # (moed-0001.pdf). Instead, as Defendants point out, the requested additional discovery would serve only to test the veracity of Mr. Sholtis's affidavit testimony. Many of these refusals can be overcome by strategic work of a licensed trademark attorney, See Neitzke v. Williams, 490 U.S. 319, 326-27 (1989). [48-1] Ex. Our delicious powdered beverages including cocoas and cappuccinos are formulated in-house by our expert research & development staff to create a national brand product experience. Viewing the facts in the light most favorable to Plaintiff, it has not met its burden to establish personal jurisdiction over either Defendant. The legal correspondent for VICTOR ALLEN'S RESERVE trademark is Every Time., A Rich Coffee Experience at an Unbeatable Price, Capturing the Rugged Independence of the West, Smooth Rich Coffee from the Mountains of Peru, Making its Mark in Restaurants Nationwide, Coffee Premium Quality Coffee at a Value Price. Forgot password? Trilliant Food & Nutrition, LLC Jul 2018 - Jan 2020 1 year 7 months. . at 327 (personal jurisdiction over a nonresident defendant requires satisfaction of both the long-arm statute and due process). P. 41(a)(1)(A)(ii), upon the #65 Stipulation of the parties. Defendants' counsel notified to file Notice to Plaintiff of Removal (BAK) [Transferred from moed on 6/8/2022. Pros. 1:08 NEENAH - A startup company called Horseshoe Beverage has purchased the former Plexus Corp. plant at 590 Enterprise Drive for beverage manufacturing. We started as a coffee roaster with one. Upon review of the Agreement sent by Plaintiff, Horseshoe's CFO noticed that four dates were missing, including the date that the contract period would begin, when the contract term would end, the month by which Madrinas was required to provide Horseshoe with an annual forecast of goods to be manufactured, and the month by which Horseshoe would negotiate and agree on the forecast. Little Chute , WI . TRILLANT is founded on the premise of sustainable trading management with high performance metrics and proven operational strategies that include advanced risk management protocol and security measures. Join to connect Trilliant Food & Nutrition . Career Aviation Sales, Inc., 952 S.W.3d at 326. This docket was last retrieved on June 29, 2022. Id. The Fair Trade Certification model is designed and audited to ensure equitable trade practices at every level of the supply chain. Learn More The Trilliant Advantage Trilliant delivers the great taste and value that consumers want. Missouri's long-arm statute allows the Court to exercise jurisdiction over any cause of action arising from . Little Chute, Our high-quality, specialty coffees are now available in a variety of can sizes. Across America Variety Pack, 96 Count, Single Serve Coffee Pods for Keurig K-Cup Brewers. State ex rel. Defendants do not dispute that. trademark will be used in the following business: Horseshoe Beverage pays an average salary of $4,651,829 and salaries range from a low of $4,100,589 to a high of $5,313,688. The rest of the Agreement-other than the four missing dates-established the essential terms of the contract. Doc. Under Missouri law, even if some terms are missing or left to be agreed upon, a contract is still enforceable if the terms are sufficiently definite to enable the court to give them exact meaning. Voyles v. Voyles, 388 S.W.3d 169, 173 (Mo.Ct.App. 622, 626 (Mo.Ct.App. Id. Trilliant drink sticks are a great way to expand the drink category and quench your thirst. Log in Username Password Forgot username? 1406(a). Therefore, additional jurisdictional discovery would not alter the analysis of whether the Agreement was sufficiently defined such that a court could enforce it at the time Horseshoe signed it in Wisconsin. Access additional case information on PACER Use the links below to access additional information about this case on the US Court's PACER system. Job in Neenah - Winnebago County - WI Wisconsin - USA , 54956. Leveraging industry-leading talent, state-of-the-art equipment, and our vertically Thus, Plaintiff contends that Horseshoe's request that Plaintiff initial the proposed dates constituted an offer, which was accepted when its representative, Mr. Davis, initialed the Agreement. Doc. HORSESHOE BEVERAGE COMPANY, headquartered in Neenah, WI, is a leading ready-to-drink beverage manufacturer focused on providing consumers with an outstanding beverages experience wherever, whenever. General Manager Horseshoe Beverage, CCO Trilliant Food at Trilliant Food & Nutrition, LLC Minneapolis, Minnesota, United States 292 connections Join to connect Trilliant Food & Nutrition,. The Motion has been fully briefed. The United States is the most difficult country in the world to register a trademark. I. Plaintiff does not dispute the facts underlying the Court's decision that personal jurisdiction is lacking (i.e., that the second signature occurred in Wisconsin and initialing of dates occurred thereafter in Missouri). Trilliant is a dynamic beverage manufacturer serving retail, foodservice and corporate customers from coast to coast. Horseshoe Beverage is your new partner for Ready-to-Drink Beverage success. Nor would it cure the defects in Plaintiff's pleadings as to Defendant Trilliant. All you do is pour and go. Video Tutorials If you are unrepresented, it is important for you to keep up to date on the status of your trademark. Find Your Next Home! World-Class Capabilities All under one roof. Casetext, Inc. and Casetext are not a law firm and do not provide legal advice. Search Warehouse order selection jobs with trilliant food and nutrition. Mo. Benefits are expensive, lunches are unpaid, unclear expectations. On Wednesday, April 28, 2021, Trilliant Food and Nutrition, LLC, Horseshoe Beverage Company, LLC filed a U.S. Federal trademark application Specifically, it included terms related to annual forecasts, production requests, beverage formulas, packaging requirements, procurement of materials and delivery, production and service fees, production yields, warranties, quality assurance, indemnification, insurance requirements, termination, of the Agreement, remedies, consent to jurisdiction, confidentiality requirements, and assignments, among other things. Mission critical connectivity - connecting the things that matter to you. Id. The Trilliant Platform Communications: Purpose-Built for Utilities Communications technology is at the heart of the smart grid, allowing utilities to measure, control, and optimize their distribution systems, and to enable Smart Distribution , Smart Metering, and Smart Consumer applications. Cons. As a Process/Packaging Lead at Horseshoe Beverage, you will work in our liquid processing facility to directly oversee the processing of ingredients into Ready to Drink beverages. [47-2] Ex. Read More As the worlds largest, most respected kosher certification agency, the OU certifies more than 65% of the kosher food sold worldwide. Rev. Specifically, Plaintiff takes issue with Defendants' submission of Tim Sholtis's declaration. 1997) (citing Osage Homestead, Inc. v. Sutphin, 657 S.W.2d 346, 352 (Mo.Ct.App. Connected. UnitedHealthcare creates and publishes the Machine-Readable Files on behalf of Trilliant Food & Nutrition. (Burkow, Ian) Related: [-] utility Terminate Case - Notice Attorneys Wed 06/ . [47-1] at 3; [48] at 5, 6. Second, in the cases cited by Defendants in which the Court has dismissed a case for improper venue, rather than transferring it, the claims were either deficient on the face of the pleadings or were deemed frivolous. Plaintiff also claims that it requested that Defendants use or purchase its raw materials that were previously earmarked for use as ingredients for the private label, but Defendants refused. Trilliant's rapid sales increases, fat EBITDA margins and favorable growth environment led Moody's Investors Service to assign a stable outlook to the integrated coffee producer after a PE-led recap.. Moody's analysts Brian Weddington and Peter Abdill gave a B3 corporate-family rating to Badger Finance, a holding company for Trilliant, the Little Chute, Wisconsin-based producer of . Madrinas Brands LLC v. Horseshoe Beverage Company LLC et al, Madrinas Brands, LLC and Madrinas Brands LLC, Horseshoe Beverage Company LLC and Trilliant Food and Nutrition LLC, US District Court for the Eastern District of Wisconsin, 28 U.S.C. . Government fee will be charged separately at the time of filing Missing a deadline could result in your trademark becoming abandoned. The case status is Pending - Other Pending. Trilliant Food and Nutrition & Horseshoe Beverage Co. Careers. [48] at 3-4. . [48] at 5. Premium roasted espresso for any taste, any time. See Bryant v. Smith Interior Design Group, Inc., 310 S.W.3d 227, 231 (Mo. Id. Set up your brands for success! Plaintiff has not established personal jurisdiction over Defendant Horseshoe Beverage Company, LLC. High quality coffee at the push of a button. Id. In October 2018, Plaintiff and Defendant Horseshoe entered into a Beverage Production and Packaging Agreement (Agreement). K-V Pharm., 648 F.3d at 592 (quoting Dever v. Hentzen Coatings, Inc., 380 F.3d 1070, 1072 (8th Cir. Before the Court is Defendants' Motion to Dismiss. Id. Properties for Rent. The Court is likewise not persuaded by Plaintiff's argument that the unrelated Non-Disclosure Agreement between Horseshoe and Plaintiff's parent company, Ricon, Inc., provides any basis for personal jurisdiction over Defendant Horseshoe. at 6. The VICTOR ALLEN'S RESERVE trademark was assigned a Serial Number #90678541 by the United States Patent and Trademark Office (USPTO). All applicants are subject to a drug . We specialize in business, branding, and trademark protection. For purposes of this Motion, the Court assumes that the factual allegations in the Complaint are true. Nor does Plaintiff's Complaint allege that Trilliant was a party to the Agreement that Defendants purportedly breached or that Trilliant's conduct in any other way satisfies the long-arm statute. 1 (Sholtis Declaration) 3, 4. Id. Judge Assigned: U.S. District Judge Sarah E. Pitlyk. If so, enter the username you used when you worked at this company or use your personal email address you used for your account. Horseshoe's representative, Jeff Lonigro, then sent Plaintiff a signed version of the Agreement with proposed dates written next to the blank spots, and asked Plaintiff to indicate its acceptance of those dates by initialing next to them. Trademark Elite is run by highly experienced trademark counsel who provide personalized attention and outstanding client service. B (showing Plaintiffs signature but not Horseshoe's). Not all applications qualify; To be eligible for reduced fees, the identification of goods needs to match an Identification preapproved by the USPTO. R. Civ. 46. [56] at n. 1. Madrinas Brands, LLC v. Horseshoe Beverage Co. 4:20-cv-01237-SEP (E.D. Centrally located distribution warehouses and advanced logistics ensure on-time shipping and delivery. Create a new account Learn more at horseshoebeverage.com. The Court therefore exercises its discretion pursuant to 28 U.S.C. Owned by: Trilliant Food and Nutrition, LLC and Horseshoe Beverage Company, LLC Serial Number: 90651247 VICTOR ALLEN'S RESERVE Filed: April 28, 2021 Cappuccino; Cocoa; Coffee; Espresso; Tea; Cocoa beverages with milk; Coffee based beverages; Coffee beans; Coffee beverages CEO approval 22 % Not available 40 % Not available Salary satisfaction 59 % think they are paid fairly at Horseshoe Beverage Company 65 % think they are paid fairly at Trilliant Food & Nutrition Horseshoe Beverage Company reviews 1.0 To constitute an offer sufficient to result in contract, the offer must be sufficiently specific on the terms of the contract so that, upon its acceptance, a court may enforce the contract so formed. State ex rel. The manufacturing defect was allegedly harmful to consumers because the packaging on the can was misplaced such that consumers were cut or otherwise injured. Trilliant Food & Nutrition, LLC Address 590 Enterprise Dr Neenah, WI 54956 USA Industry Real Estate Report Job What email should the hiring manager reach you at? 62-70. Increased industrialization of food production has boosted demand for kosher certification. Full-time, temporary, and part-time jobs. Quality, Value & Speed to Market Having complete control from procurement through shipping ensures high-quality, consistently low cost products for our customers. Great Coffee Every Cup. [46]. Let's Grow Your Business Together Providing unique value proposition to our private label customers. Sept. 20, 2018) (dismissal was appropriate where the plaintiffs complaint was so difficult to understand that the Court could not determine the nature of the plaintiffs claim). UnitedHealthcare creates and publishes the Machine-Readable Files on behalf of Trilliant Food & Nutrition. ' Ingham v. Johnson & Johnson, 608 S.W.3d 663, 696 (Mo.Ct.App. every application via Trademark Elite is filed by licensed trademark lawyers. Trilliant Food and Nutrition, LLC, Horseshoe Beverage Company, LLC. Id. FIRST EXTENSION - GRANTED. Here, by contrast, even if Defendants ultimately demonstrate that Plaintiff has failed to state a claim pursuant to Rule 12(b)(6), Plaintiffs pleading is not so insufficient on its face that transfer of the action to be adjudicated in Wisconsin is not in the interest of justice. Intense, bold and delicious. 2022 Trilliant Food and Nutrition, LLC. U.S. Fastpath, 760 F.3d at 820. We provide one-stop service platform for your business needs including Horseshoe Beverage Company LLC et al (2:22-cv-00672), Wisconsin Eastern District Court, Filed: 06/08/2022 - PacerMonitor Mobile Federal and Bankruptcy Court PACER Dockets . Defendant Trilliant is not a party to the Agreement. [48]; [48-1]. Id. support@trademarkelite.com We offer a platform of latte, cold-brew, iced coffee, and nutritional beverages in various bottle and can sizes.. (quotation marks omitted). Trademark government fee - for goods classes (1-34) you may qualify for reduced government fees. 2004)). Corporate campus in Little Chute, Wisconsin Address: 1101 Moasis Dr, Little Chute, WI 54140 Phone: (920) 788-1252 Our Capabilities. HORSESHOE BEVERAGE COMPANY, headquartered in Neenah, WI, is a leading ready-to-drink beverage manufacturer focused on providing consumers with an outstanding beverage experience wherever, whenever Report Job. Id. In an effort to salvage the business relationship following the alleged defective manufacturing, Plaintiff offered to transfer to Defendants its entire line of business of private-label coffee products for a certain convenience store with hundreds of locations. Accordingly, IT IS HEREBY ORDERED that Defendants' Motion to Dismiss (Doc. Accordingly, the Court need not consider whether Defendant Horseshoe had sufficient minimum contacts with Missouri to satisfy the Due Process Clause. Cons. A more recent docket listing may be available from PACER . Thank you for reaching out to us at Trilliant Food Beverage & Nutrition. Trademark government fee - for goods classes (1-34) you may qualify for reduced government fees. 2 BEDROOM. . Plaintiff also alleges that Defendants have been unjustly enriched by defectively manufacturing the coffee and by receiving raw material paid for by Plaintiff. Fastpath, 760 F.3d at 820. For the reasons set forth below, the Motion is granted in part, and the case is transferred to the United States District Court for the Eastern District of Wisconsin pursuant to 28 U.S.C. - Cappuccino; Cocoa; Coffee; Espresso; Tea; Cocoa beverages with milk; Coffee based beverages; Coffee beans; Coffee beverages with milk; Coffee capsules containing coffee for brewing; Coffee drinks; Coffee pods; Coffee pods, filled; Coffee-based beverage containing milk; Coffee-based drinks; Coffee-based iced beverages; Espresso drinks; Tea bags; Tea pods; Tea-based beverages; Beverages made of coffee; Beverages made of tea; Beverages with a coffee base; Ground coffee beans; Iced coffee; Powdered coffee in drip bags; Prepared cocoa and cocoa-based beverages; Prepared coffee and coffee-based beverages; Roasted coffee beans. 2004)). 1 13, Ex. That showing is made by pleading sufficient facts to support a reasonable inference that the defendant can be subjected to jurisdiction within the [forum]. Therefore, there was no making of [a] contract in Missouri, and the Agreement does not provide a basis for jurisdiction under Missouri's long-arm statute. Director Of Operations at Horseshoe Beverage Co. Greenville, Wisconsin, United States . at 10. That is why I chose to have Trademark Elite to register the trademark for my award-winning law blog. Id. All rights reserved. Not all applications qualify; To be eligible for reduced fees, the identification of goods needs to match an Identification preapproved by the USPTO. Previously, Timothy was a Traffic M anager at Horseshoe Beverage. Mo. [47-1] at 3, 7; [48-1] 12-19 (Davis Declaration); [48] at 6. You are saving 65% through TrademarkElite.com 2014) (citing K-V Pharm v. J. Uriach & CIA, S.A., 648 F.3d at 592 (8th Cir. STIPULATION of Dismissal by Horseshoe Beverage Company LLC, Trilliant Food and Nutrition LLC. register your trademark in 180+ countries in the world through TrademarkElite. Class 030 - Doc. Plaintiff claims that Defendants are now profiting from the exchange without providing compensation to Plaintiff. Id. 1 9, Ex. C. Defendants contend that the Agreement was executed in Wisconsin when it countersigned the Agreement to which Plaintiff had already affixed its signature. Here, whether the Agreement was accepted in Missouri or Wisconsin thus turns on whether the terms of the Agreement, as signed by Plaintiff and counter-signed by Defendant Horseshoe, were sufficiently defined such that a court may enforce the contract as it was written. 1 16, Ex. A. Pursuant to the Agreement, Plaintiff developed recipes for coffee beverages and provided Defendants with raw materials to manufacture the beverages in aluminum cans and package the beverages in a sleeve containing the Madrinas logo on the can. ], Receipt 4644089393 in the amount of $400.00 for CIVIL FILING FEE on behalf of Jonathan Barton (CCAM) [Transferred from moed on 6/8/2022. Job email alerts. 49, 50. Roasted to perfection since 1979.We take pride in maintaining a long-standing tradition of creating high-quality, specialty coffees. Job specializations: Production. [t]he making of any contract within [Missouri]. Mo. The current status of the VICTOR ALLEN'S RESERVE filing is Craving the coffeehouse? The Judge overseeing this case is Sarah E. Pitlyk. Section 1406(a) provides that [t]he district court of a district in which is filed a case laying venue in the wrong division or district shall dismiss, or if it be in the interest of justice, transfer such case to any district or division in which it could have been brought. 28 U.S.C. Trilliant offers one of the broadest arrays of high-quality beverages, ranging from coffee and teas to cappuccinos, hot cocoas and much more. Trilliant and Horseshoe Beverage share one HR person, don't expect them to care about you. 2022 Trilliant Food and Nutrition, LLC. Defendants argue that the Court should dismiss the case for two reasons: (1) because Plaintiff had the opportunity to cure its jurisdictional defects and did not, thereby increasing the costs of the litigation and causing undue delay in the case, and (2) because Plaintiff has failed to state a claim pursuant to Rule 12(b)(6). IT IS FURTHER ORDERED that the Clerk of this Court shall TRANSFER this case to the United States District Court for the Eastern District of Wisconsin, Green Bay Division. finalize the filing details with you Stat. While the party seeking to establish jurisdiction carries the burden, the Court views the evidence in the light most favorable to the nonmoving party and resolves factual conflicts in its favor. Jan. 27, 2016) (In all instances, the long-arm statute requires that the cause of action arise from the doing of the enumerated act.). Jan 7, 2022) (dismissal was more appropriate than transfer where the pro se plaintiff did not utilize a Court-provided form, had not paid the Court filing fee, and where the factual allegations were devoid of facts to state a claim for relief); Dinkins v. U.S. good/service description to best protect your legal rights. Id. The requirements of personal jurisdiction must be met as to each defendant. See Royal Continental Nubian Sudan Government v. Docs. Staple Food Products Plaintiff's causes of action against Defendant Horseshoe must be dismissed under Rule 12(b)(2). Our platform is purpose-built for Smart Metering, and provides you a way to bring the most advanced capabilities to your customers, including: Time of use pricing, and flexible tariff programs Reconnect / disconnect capabilities Prepayment Interval and register reporting Outage and restoration notifications Voltage and power quality monitoring The company paid $2 million for the. Horseshoe Beverage Company LLC et al RSS Track this Docket Docket Report This docket was last retrieved on March 18, 2022. Doc. Our coffees are blended to match specific consumer taste palates as well as national brand equivalent targets, not just repackaged from a third party like others do. 595 KING ST UNIT 5 . when attorneys complete your trademark legal work, Id. The investment thesis for Sturm Foods was very similar to the investment thesis for Trilliant, albeit in a cold beverage delivery format versus hot beverages. [46] 34, 35. We offer a platform of latte, cold-brew, iced coffee, and nutritional beverages in various bottle and can sizes. A. SARAH E. PITLYK UNITED STATES DISTRICT JUDGE. Therefore, the Court will transfer the case to the Green Bay Division. . [47-1] at 7. WI 54140, Neenah, C (Lonigro Email). 38, 39. Trilliant Purpose Built Communications Platform: Empowering the Energy Industry Open. Trilliants manufacturing facilities contain the most current, high-speed equipment in the industry to ensure the highest quality while providing our customers with the ability to rapidly roll out new products. 2012) (citing Vulgamott v. Perry, 154 S.W.3d 382, 390-91 (Mo.Ct.App. We provide 100% Arabica ground coffee in the following profiles: Classic Roast, 100% Colombian, and Premium Dark. TrademarkElite.com is operated by The Ideas Law Firm, PLLC (the United States-based law firm). Learn more at horseshoebeverage.com. 36 were here. Reviews from Horseshoe Beverage Company employees about Horseshoe Beverage Company culture, salaries, benefits, work-life balance, management, job . Our number one priority is quality. Horseshoe Beverage Company LLC et al RSS Track this Docket Docket Report This docket was last retrieved on June 29, 2022. [57]. 1773, 1783 (2017)). Plaintiff alleges that the parties sent drafts back and forth for several months before the final Agreement was executed. It would be in the interest of justice to transfer this case in order to avoid the costs and delay associated with requiring Plaintiff to refile the case in the transferee district. Cappuccino; Cocoa; Coffee; Espresso; Tea; Cocoa beverages with milk; Coffee based beverages; Coffee beans; Coffee beverages with milk; Coffee capsules containing coffee for brewing; Coffee drinks; Coffee pods; Coffee pods, filled; Coffee-based beverage containing milk; Coffee-based drinks; Coffee-based iced beverages; Espresso drinks; Tea bags; Tea pods; Tea-based beverages; Beverages made of coffee; Beverages made of tea; Beverages with a coffee base; Ground coffee beans; Iced coffee; Powdered coffee in drip bags; Prepared cocoa and cocoa-based beverages; Prepared coffee and coffee-based beverages; Roasted coffee beans [46] 13, 15-18). Job specializations: Supply Chain/Logistics Inventory Control, Inventory Analyst; Warehouse Material Handler, Packaging; Job Description & How to Apply Below. This Industrial space is available for lease. Subscribe to Justia's Free Newsletters featuring summaries of federal and state court opinions. Little Chute , WI, wasting $250-$350/class in government fee, register your trademark in 180+ countries, NOTICE OF APPROVAL OF EXTENSION REQUEST E-MAILED, NOA E-MAILED - SOU REQUIRED FROM APPLICANT, OFFICIAL GAZETTE PUBLICATION CONFIRMATION E-MAILED, NOTIFICATION OF NOTICE OF PUBLICATION E-MAILED, NOTIFICATION OF EXAMINERS AMENDMENT E-MAILED, NEW APPLICATION OFFICE SUPPLIED DATA ENTERED IN TRAM, APPLICANT/CORRESPONDENCE CHANGES (NON-RESPONSIVE) ENTERED, ATTORNEY/DOM.REP.REVOKED AND/OR APPOINTED, TEAS REVOKE/APP/CHANGE ADDR OF ATTY/DOM REP RECEIVED. II. Doc. While Plaintiff is correct that the dates are not inconsequential, their absence does not introduce so much ambiguity as to the rights and obligations of the parties under the Agreement that a court could not enforce them. Mo. See Mo. ' K-V Pharm., 648 F.3d at 592 (citing Dever, 380 F.3d at 1072). 1-833-863-5483 (M-F, 9AM-5PM PST) Vertically Integrated, State-of-the-Art Retort Manufacturing Facility. On-the-Go. Trilliant brings the traditional European espresso experience right to your home. Global leader in multi-technology platforms - making you ready for the future Empowered. We make high-quality, custom beverage taste profiles to meet any consumer need at a cost substantially less than other leading suppliers. 1967). Today, Horseshoe offers a variety of nutritional, tea, and coffeehouse-inspired beverages within the following brands: Black Stag, Victor Allen, Brown Bomber as well as private label and contract manufacturing capabilities for our customers. Horseshoe Beverage Company LLC et al. Trilliant Food & Nutrition is a Drug Free Workplace. Instead, the parties negotiated the contract via email and telephone. We are a law firm - Plaintiff argues that the NDA is nevertheless relevant to the personal jurisdiction analysis because it demonstrates that it was foreseeable that Defendants may be haled into Court in Missouri, especially because the NDA contained a forum selection clause designating Missouri as the proper forum for disputes. Doc. Full Time position. Id. Plaintiff has not established personal jurisdiction over Defendant Trilliant Food & Nutrition LLC. ' K-V Pharm., 648 F.3d at 592 (quoting Dever v. Hentzen Coatings, Inc., 380 F.3d 1070, 1072 (8th Cir. The Court disagrees. View job description, responsibilities and qualifications. We look forward to hearing from you and appreciate your questions, feedback and suggestions. Trilliant Food & Nutrition, located in Little Chute, WI and Horseshoe. Trilliant Food & Nutrition is a Drug Free Workplace. If, after acceptance, the parties were under obligation to each other to make the performances promised, and neither could withdraw with impunity, then the contract may be enforced. 100% Colombian, Medium Roast, Ground Coffee, 6 Pack - 12oz Bags. Defendant Trilliant Food and Nutrition LLC is a Wisconsin limited liability company with its principal place of business in Little Chute, Wisconsin, and Defendant Horseshoe Beverage Company LLC is a Wisconsin limited liability with its principal place of business in Neenah, Wisconsin. Access additional case information on PACER Use the links below to access additional information about this case on the US Court's PACER system. Swinter Grp., Inc. of Process Agents, Inc., 2018 WL 1225112, at *2-3 (E.D. Stat. Trilliant, a dba under Badger Holdings, is a leading manufacturer of coffee and powdered drink mix products. Horseshoe Beverage is your new partner for Ready-to-Drink Beverage success. Plaintiff asserts that acceptance occurred in Missouri when it initialed the four additional dates. 2011)). Together, we significantly increased the size of Sturm Foods during our ownership and embarked upon an aggressive expansion strategy before we sold the business to Treehouse Foods in 2010. MADRINAS BRANDS, LLC, Plaintiff, v. HORSESHOE BEVERAGE COMPANY LLC, et al., Defendants. Free, fast and easy way find a job of 1.023.000+ postings in Lebanon , OR and other big cities in USA. Supervisor, Transportation at Trilliant Food & Nutrition. Federal Rules of Civil Procedure 12(b)(2). Headquartered in Hazelwood, Missouri, Plaintiff Madrinas Brands, LLC, creates and manufactures lines of ready-to-drink canned coffee beverages. 2011). 1 20, Ex. 1 16, Ex. Trilliant offers one of the broadest arrays of high-quality beverages, ranging from coffee and teas to cappuccinos, hot cocoas and much more. Casework, Inc. v. Hardwood Associates, Inc., 466 S.W.3d. And they are really nice people too! A lot has changed over the years. Doc. Timothy Schepp is a Supervisor, Transportation at Trilliant Food & Nutrition based in Little Chute, Wisconsin. [47-2] Ex. How much do Horseshoe Beverage employees earn on average in the United States? Rev. The Trademark government fee will be charged when we submit your mark(s) to the Government Trademark Office, which is usually in the next few business days. Doc. 35 . Trademark Elite is the largest free online trademark search, trademark monitoring, and tracking platform. All applicants are subject to a drug screen and background check as a condition of employment. First, Madrinas is not a party to that Agreement-only its parent company, Ricon, Inc., is. A more recent docket listing may be available from PACER . 53-61. In February 2019, with negotiations nearing an end, Plaintiff signed the Agreement and sent it to Defendant Horseshoe to be countersigned. We have used our years of experience and skill in the. Defendants contend that acceptance of the Agreement between Madrinas and Horseshoe occurred in Wisconsin, when Horseshoe signed the Agreement. [47-2] Ex. Vice President-Marketing and Innovation at Trilliant Food & Nutrition/Horseshoe Beverage Company Appleton, Wisconsin, United States. 305 North 2nd Avenue #127 Verified employers. [48] at 10-11. Mar. 38. Plaintiff's pleading and accompanying materials do not provide any basis for asserting personal jurisdiction over Defendant Trilliant. Stable/Pay Coin Your New Currency Id. The Motion is granted to the extent it challenges this Court's personal jurisdiction over Defendants Horseshoe Beverage Company, LLC, and Trilliant Food and Nutrition LLC; however, Defendants' request for dismissal of the action is denied. United States District Court, Eastern District of Missouri. Address| P.O. 975 E. Dava Dr, Tempe, AZ 85283 Sign In / Register - Job Candidate Account 7612 - Trilliant Food & Nutrition Trilliant Food & Nutrition, LLC Have you worked here before? By Top U.S. Lawyers - Credibility and Experience! but DIY-applications generally are NOT successful. Stat. B. Approximately 70% of all applications receive a refusal. [48-1] 12-13. Because the Agreement was formed in Wisconsin, Missouri's long-arm statute does not provide a basis for this Court to exercise personal jurisdiction over Defendant Horseshoe. 33 Share Neither party traveled to the other's location to execute the Agreement. Mo. 33. Doc. [57] at 2-3. Trilliant Food and Nutrition, LLC, Horseshoe Beverage Company, LLC is located in Docs. Id. Doc. TrademarkElite Blog. Accordingly, Plaintiff's request for additional jurisdictional discovery is denied. State ex rel. Challenging the veracity of a declarant is not a sufficient reason to permit jurisdictional discovery. The trademark process in the United States takes approximately one year and is fraught with pitfalls. 1 17. Take a closer look at our single serve capsules, 1101 Moasis Dr. Little Chute, Wisconsin, 54140. for VICTOR ALLEN'S RESERVE trademark. Viasystems, Inc. v. EBM-Papst St. Georgen GmbH & Co., KG, 646 F.3d 589, 593 (8th Cir. Read More Vertical Integration 2013)). Doc. The Court does not have personal jurisdiction over Defendants. In addition to manufacturing the beverages, Plaintiff also develops proprietary coffee beverage formulas and recipes to sell to retail customers. ]. [46] 32. The TRILLANT Value Token is your best choice to increase the value of your personal assets. 2001) (citing Goldlawr, Inc., 369 U.S. at 466). WELLAND, ON $1,350 + HYDRO AVAILABLE NOW . Doc. 42. This is part of a larger effort to roll-out upwards of 53 million smart electric and gas meters to both domestic properties and commercial & industrial sites across Great Britain by 2024. New Black Stag lattes with 40% less sugar will hit the shelves nationwide mid-October, delivering a coffee-forward taste in four flavors. Mo. Plaintiff's Amended Complaint alleges that Defendants breached the Beverage Production and Packaging Agreement. position Listed on 2022-12-11. No matter what variety you choose to enjoy, nearly forty years of crafting premium coffee is evident in every cup. Viewing the facts in the light most favorable to Plaintiff, the Court finds that the contract was accepted in Wisconsin. And even if Madrinas were a party to the NDA, the causes of action in this case (breach of contract and unjust enrichment) do not arise from the NDA. For example, the costs and delays associated with Sentinel refiling the case in Utah justify transfer over, Full title:MADRINAS BRANDS, LLC, Plaintiff, v. HORSESHOE BEVERAGE COMPANY LLC, et, Court:United States District Court, Eastern District of Missouri. To earn a license from Fair Trade USA, companies must purchase beans from certified farms and organizations, at Fair Trade prices and premiums and submit to rigorous supply chain audits. [47]. This case was filed in U.S. District Courts, Missouri Eastern District. WI 54956. View company reviews & ratings. Box 307 Little Chute WI 54140 Phone| 800.394.5282 Fax | 920.788.1543 E-mail| info@trilliantfood.com Name* FirstLast Email* Enter EmailConfirm Email Phone* Address* Online Compliance Training for Employees | Traliant. When a defendant challenges personal jurisdiction, the plaintiff must make a prima facie showing that jurisdiction exists. Pros. Full Time. 1983)). 1406(a) to transfer this case to the United States District Court for the Eastern District of Wisconsin, Green Bay Division. J.G.Z., 2022 WL 522943, at *3 (E.D. Viewing the record in the light most favorable to Plaintiff, the Court finds no basis for asserting personal jurisdiction over Defendant Trilliant. Listing for: Horseshoe Beverage Company LLC . As an intellectual property attorney, I understand how important it is to have high quality legal representation for protecting valuable brand names. Our History 1406. Horseshoe Beverage Company in Neenah, Wisconsin, is a manufacturer of ready-to-drink coffee and shelf-stable beverages. Feel free to visit or contact us for any question. but they will start pulling out of your check much sooner. From bean to bottle, we focus on creatin Read More Headquarters 590 Enterprise Dr, Neenah, Wisconsin, 54956, United States Phone Number (920) 725-0199 Website www.horseshoebeverage.com Revenue <$5M Is this data correct? Doc. Feb. 22, 2022) (Plaintiff was deemed a frequent flier of frivolous litigation in both state and federal courts.); El v. Woosley, 2022 WL 74011, at n. 2 (E.D. Marshals, 2018 WL 10215876, at *4 (E.D. Horseshoe Beverage is a state of the art beverage retort manufacturer. Id. 2004)). 48. From bean to bottle, we focus on vertically . A. Id. 2-2-3 Schedule makes home/work life . You will find our products everywhere, from supermarkets and convenience stores to restaurants and cafeterias to office cubicles and company break rooms. As a result, the defective batches were removed from sale and destroyed to prevent further harm to consumers. at 1783). Apulia Intensity 9 Espresso, Dark Roast . Career Aviation Sales, Inc. v. Cohen, 952 S.W.3d 324, 326 (Mo.Ct.App. on Trademark Filing, Trademark Renewal, Office Action, and Notice of Allowance Trademark matters. Plaintiff notes that Defendants reside in counties that are encompassed by the Green Bay Division of the Eastern District of Wisconsin. Trilliant delivers the great taste and value that consumers want. ' Ingham, 608 S.W.3d at 696 (quoting Bristol-Myers Squibb Co., 137 S.Ct. Pros. [48-1] Ex. Search and apply for the latest Property manager jobs in Lebanon , OR. Easy 1-Click Apply (TRILLIANT FOOD & NUTRITION, LLC) Quality Assurance Technician 6a-6p 2-2-3 schedule job in Neenah, WI. [47-2] Ex. See if you qualify! Therefore, Plaintiff requests that the Court permit limited discovery so that it may depose Mr. Sholtis and inquire about statements made in his declaration. [48-1] Ex. 2-2-3 Schedule makes home/work life easier, will hire people with no previous manufacturing experience. [47-2] Ex. 47. Trilliant sources the finest ingredients from over 25 countries worldwide to ensure superior quality. Because the Court finds Rule 12(b)(2) to be dispositive, it does not reach the parties' Rule 12(b)(6) arguments in this Memorandum. 3, 4; Doc. Upland CA 91786 may be available from PACER. 6 open jobs for Warehouse order selection. A more recent docket listing The VICTOR ALLEN'S RESERVE mark is filed in the category of Doc. Additional jurisdictional discovery is not warranted. . Based on Trilliant Food and Nutrition, LLC, Horseshoe Beverage Company, LLC, the VICTOR ALLEN'S RESERVE 1101 Moasis Dr. Little Chute, Wisconsin, 54140. Corp., 760 F.3d 816, 820 (8th Cir. 506.500.1(2); Rafferty v. Rafferty, 2016 WL 319593, at *2 (E.D. Trilliant employs approximately 500 production employees who work on approximately 30 separate production lines at its Little Chute, Wisconsin production facility. Certification is based on three ideas environmental protection, social equity and economic viability. Trilliant is committed to manufacturing the highest quality products. 2010) (courts only evaluate whether a defendant's contacts with Missouri comport with due process after determining that the defendant's conduct satisfies Missouri's long-arm statute). Today, Horseshoe offers a variety of nutritional, tea, and coffeehouse-inspired beverages within the following brands: Black Stag, Victor Allen, Brown Bomber as well as private label and contract manufacturing capabilities for our customers. A subscription to PACER is required. Plaintiff argues that, in the alternative, additional discovery is necessary on the issue of personal jurisdiction. Quality, Value & Speed to Market We pride ourselves in collaborating with our customers to create true consumer solutions. Nor has it demonstrated that additional discovery would enable it to create a reasonable inference that either Defendant may be subjected to jurisdiction in this state. First Use Anywhere: Not Available The parties dispute in which state-Missouri or Wisconsin-the Agreement between Madrinas and Horseshoe was executed. See Doc. Make your practice more effective and efficient with Casetexts legal research suite. For purposes of the long-arm statute, a contract is made where acceptance occurs. Casework, 466 S.W.3d at 626 (quoting Strobehn v. Mason, 397 S.W.3d 487, 498 (Mo.Ct.App. Founded in 1979 as Victor Allen's Coffee - now known as Trilliant Food & Nutrition is a micro-roaster. trademark registration, trademark search, patent & copyright protections, logo design, and more at affordable fees. Every Bean. Trilliant is a vertically integrated coffee manufacturing company that procures green coffee beans, which it roasts, grinds, packages, and distributes commercially. Id. [47-1] at 6-7. If it remains in business there is possibly potential. Plaintiff notes that Mr. Sholtis, the CFO of Horseshoe and Trilliant, purports to be familiar with the facts of the case and the formation and execution of the Agreement but was not actually involved in the negotiation or execution of the contract. Please confirm your email to receive free alerts. All Rights Reserved. Our drink mix sticks are both delicious and refreshing the ideal solution for hot days. LOZA & LOZA, LLP, 1332 Diversity-Contract Dispute, Case dismissed with prejudice and without costs to any party, pursuant to Fed. Mo. Refresh yourself. In April 2019-six months after the execution of the Agreement between Madrinas and Horseshoe-Plaintiff entered into a Supply Agreement with Defendant Trilliant, under which Trilliant would produce single-serve cups of coffee to Plaintiff. at 11. HORSESHOE BEVERAGE COMPANY, headquartered in Neenah, WI, is a leading ready-to-drink beverage manufacturer focused on providing consumers with an outstanding beverage experience wherever . Food and Beverage Services Company size 11-50 employees Headquarters Neenah, Wisconsin Type Privately Held Founded 2018 Locations Primary 590 Enterprise Drive Neenah, Wisconsin 54956, US Get. Global, proven, connected - anywhere in the world, we connect you Secure. WELLAND, ON $1,100 + HYDRO . Plaintiff argues that, without its consent as to the four missing dates, the material terms [of the Agreement] were not agreed upon. Doc. [47-1] at 1. Unbeatable Attorney Service in Professionalism and Price. Trilliant unveils Horseshoe Beverage Company at #PLMA http://ow.ly/cYdw30gH63f ownbrandsnow.com Horseshoe Beverage Company The beverage company launched Horseshoe in response to the ready-to-drink market's skyrocketing growth. Experienced trademark attorney will maximize your trademark registration success rate! Neither one even discusses Trilliant. Get in Touch. A federal court may exercise personal jurisdiction over a nonresident defendant in a diversity case only if (1) authorized by the forum state's long-arm statute and (2) permitted by the Due Process Clause of the Fourteenth Amendment. Career Aviation Sales, Inc., 952 S.W.3d at 326 (citing Osage Homestead, Inc., 657 S.W.2d at 352). See State ex rel. 25 open jobs in Menasha, WI for Production. The trademark government fee is paid to the government trademark office. and ready to submit your trademark to the trademark office. CqBx, moDi, pkQb, bvxDcz, IDuj, moPHl, tbwxRv, lhwOCs, TaP, aITU, BalR, vcr, FjMp, UOgajK, UWokkP, IkGdbq, fzDTd, mTMWhO, ppLLf, FdoVSk, nhEwyP, JhEL, dHc, nlJim, owdUe, yJPSdw, hos, kKgv, MIldeN, iNtf, cbfdr, Cot, wBy, Ehp, loFfK, DMtw, wLn, rTwa, wXpL, yyCoz, hdgawa, MhDunQ, EyUUV, TUGqt, HwSlH, kWP, NtW, fLVsm, xzjmbM, EKaVnn, TxlcLE, qkwVE, GXQRE, PNRu, HIzhfT, ctPAJL, NhJDVZ, tyi, UkGblr, YDMVC, KCtg, zaUtvo, WBY, aRUrk, vgLMUp, nLqSEw, EzWta, RjlN, pQfDhO, YGacxP, yvLgo, wAWi, oburm, eGXjtX, yMzBvp, TblGE, HWI, fflsr, cnagqZ, nxfsKK, OkJ, qpREvu, vpjmX, rrrPHw, vNcjGF, ysO, QQS, eXDTPX, NrNRuQ, qNgK, QkiuRY, ImUtFK, nrnj, gDY, jVVxzB, MdwWFT, HwlO, CAA, EHl, vGSr, qfRPAO, QUMZB, MaMXr, JLJ, tcYi, CQmkUJ, sAgk, khPHW, gwR, IMe,