Plaintiffs allege also that the defendants have published a dictionary.nder the title of '"Webster's Collegiate Dictionary with Chinese Transhition," and thad they have issued a prospectus advising the public of the same and soliciting orders to purchase, and have obtained advance subscriptions for it. They allege that thd defendants have simulated plaintiffs' trademark in such a man, ner as to deceive the ordinary person into believing that the dictionary published by the defendants is the same as that published by the plaintiffs with the addition of a Chinese translation; that the defendants have in fact copied verbatim thd plaintiff's dictionary and have merely added a Chinese trans+ lation. The plaintiffs claim that the actions of the defendants ara in. violation of their dopyrightl and trademark rights; that the defendants have incurred no expense in compiling the dictionary, and are able to produce and sell Knglish dictionary—with a Chinese translation ab a pried lower than plaintiffs can produce and sell their English dictionary in China.
The plaintiffs pray for a permanent injunction restraining the defendants from publishing and selling the dictionary en. titled '"Webster's Collegiate Dictionary with Chinese Translation," and from using the de+ sign which the plaintiffs claim as a trademark; for an order of the Court requiring the destruction of all plates, moulds, and other property in alleged infringing matter; an order restraining the defendants from selling or delivering the dictionary, and for damages and costs.
The defendants admit that they are publishing a dictionary under the title '"Webster's Collegiate Dictionary with Chinese Translation"; that they have issued a prospectus with the same and obtained orders and advance subscriptions, but deny each and every other material allegation in the petition.
Text read from the printed page and cleaned; old type leaves the occasional error.