Page 1 | 2 | 3 | 4 | 5 | 6 | 7 | 8 FIFTH CAUSE OF ACTION (Unfair Competition and Common Law Trademark Infringement)   88. Plaintiffs repeat and reallege Paragraphs 1 through 56 herein, inclusive, as though more fully set forth at length herein. Defendants' actions and activities, as hereinabove set forth, also constitute trademark infringement and unfair competition under the laws of the State of New Jersey and at common law, including but not limited to Plaintiff's rights under N.J.S.A. 56:3-13.11 et seq. 90. As a result of the foregoing, Defendants have unfairly competed with Plaintiff. 91. As a result of the foregoing, Defendants have each received substantial monies and other benefits which rightfully belong to Plaintiff. 92. As a result of the foregoing, Plaintiff has suffered damages. 93. Such infringement and unfair competition has caused and is causing irreparable damage and injury to Plaintiff and is likely to continue unabated unless Defendants are enjoined and restrained by this Court. WHEREFORE, the Plaintiff demands judgment against Defendants, and each of them: (a) For compensatory damages and damages sustained by Plaintiff; (b) For punitive damages against each Defendant; (c) For permanent injunctive relief restraining and prohibiting any use of Mike Hailwood's name, initials, likeness, identifying characteristics or reputation in connection with the manufacture, creation, marketing, promotion, advertising, sale and/or distribution of the Motorcycles or any other commercial product by Defendants or their agents, representatives or those acting in concert with same; (d) For such other and further relief as the Court may deem just and/or proper. Page 1 | 2 | 3 | 4 | 5 | 6 | 7 | 8