DR Distributors, LLC v. 21 Century Smoking, Inc., No. 12 C 50324, Slip Op. (N.D. Ill. Nov. 20, 2014) (Johnston, Mag. J.).

Judge Johnston granted defendant’s motion to amend adding state law disparagement and defamation claims in this Lanham Act case involving plaintiff’s 21ST CENTURY SMOKE and defendant’s 21ST CENTURY SMOKING marks.  Defendant’s disparagement and defamation claims were at least “loosely” connected to the facts that defendant’s Lanham Act unfair competition and trademark infringement claims because they arose from allegations surrounding plaintiff’s conduct and statements made at a 2013 trade show.