The Defendants have created and distributed downloadable files for use in 3-D printers to extrude gun parts and accessories. These files include the identical Everytown Marks in the file names and/or on the resulting extruded gun parts and accessories emblazoned with the Everytown Marks. The downloadable “printing kits” are accessible to consumers in New York and bear unauthorized identical copies of Everytown’s registered trademarks. Each Defendant has targeted New York consumers by uploading these files to a full interactive online website that is viewable by and accessible to New York consumers.
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