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2 history stretching back to 1891, Dublin Dr Pepper is one of the oldest bottlers of soft drinks of any kind anywhere in the world. 2.

Incredibly, Corporate Dr Pepper in its Complaint has chosen to omit any reference to the prior history of Dublin Dr Pepper and its relationship with Corporate Dr Pepper for more than a century. More importantly, Corporate Dr Pepper’s Complaint fails to even mention any of its own prior actions and conduct by which it has endorsed and approved the use of Dublin Dr Pepper, as both the name of a business and as a brand, and the manner in which Dublin Dr Pepper has conducted business. Believing in justice and that this case should be decided based on all the facts, Dublin Dr Pepper will fill in that which Corporate Dr Pepper has conveniently ignored.

History of Dublin Dr Pepper

3.

Sam Houston Prim, a Texan with a classic name and the founder of Dublin Dr Pepper, discovered Dr Pepper soft drinks in 1891, while vi siting Waco, Texas. At the time, Dr Pepper soft drinks were being made and sold at an old fashioned soda fountain in Wade Morrison’s Old Corner Drug Store, in Waco, Texas. There, a local pharmacist, Charles Alderton, had invented the drink five years earlier. For a time, the drink was called a “Waco” by the local patrons, but Charles Alderton later decided to name his new drink “Dr Pepper” after the father of a lost love back in hi s home state of Vir ginia. Being a visionary, Sam Houston Prim, recognized the soft drink’s potential, particularly if packaged in bottles which allowed the drink to be consumed away from a soda fountain. Shortly thereafter, he arranged to take the concentrate back to Dublin, Texas and start bottl ing Dr Pepper. Sam Houston Prim promoted the Dr Pepper brand throughout his life until his death in 1946, when the torch was passed to his