"Defendant [Primetime] has competed unfairly with
Plaintiff [Aaron's] in several ways. Defendant has misstated
prices being charged by Aaron's. Defendant has used
confusingly similar designation "Really Do The Math" in
conjunction with such misstated prices. Defendant has
adopted and used the confusingly similar designations
"Really Do The Math," Dream Machine" and "Sales and Lease
Purchase For Less" in connection with directly competitive
goods and services. Defendant has used these designations
and other indicia in a cumulative manner so as to mimic or
parrot trade dress owned by Aaron Investment and used by
Aaron's.
Aaron's Sales and Lease Ownership division, who is a member
of the national Rent-to-Own trade association, often produces
ads using the "Do the math" slogan to discourage consumers from
renting-to-own. The company offers consumers a lease with
purchase option.
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