2022-cv-61038

2022-cv-61038 Taylor Made Golf Company, Inc. et al v. The Individuals, Business Entities, and Unincorporated Associations

Date :6/2/2022
Court :Southern District of Florida
Law FirmSMG

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Date

Document

1

June 2, 2022

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. Filing fees $ 402.00 receipt number AFLSDC-15686495, filed by KARSTEN MANUFACTURING CORPORATION, CALLAWAY GOLF COMPANY, PARSONS XTREME GOLF, LLC, ACUSHNET COMPANY, ROGER CLEVELAND GOLF COMPANY, INC., TAYLOR MADE GOLF COMPANY, INC., SUMITOMO RUBBER INDUSTRIES, LTD.

Civil Cover Sheet

Exhibit 1 to Complaint Certificates of Registration for the Taylor Made Tradema

Exhibit 2 to Complaint Certificates of Registration for the Acushnet Trademarks

Exhibit 3 to Complaint Certificates of Registration for the Callaway Golf Trade

Exhibit 4 to Complaint Certificates of Registration for the Roger Cleveland Gol

Exhibit 5 to Complaint Certificates of Registration for the Karsten Trademarks

Exhibit 6 to Complaint Certificates of Registration for the PXG Trademarks

2

June 2, 2022

Clerks Notice of Judge Assignment to Judge Raag Singhal. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Alicia O. Valle is available to handle any or all proceedings in this case. If agreed, parties should complete and file the Consent form found on our website. It is not necessary to file a document indicating lack of consent.

3

June 3, 2022

FORM AO 120 SENT TO DIRECTOR OF U.S. PATENT AND TRADEMARK

4

June 6, 2022

NOTICE OF COURT PRACTICE Unless otherwise specified by the Court, every motion, legal memorandum, brief, and otherwise shall: be double-spaced, in justified alignment, in 12-point font, using either Times New Roman or Arial typeface. This Notice does not supplant the requirements and provisions of Local Rule 7.1(c). The Court cautions parties against excessive use of footnotes. Multiple Plaintiffs or Defendants shall file joint motions with co-parties unless there are clear conflicts of position. If conflicts of position exist, parties shall explain the conflicts in their separate motions. Parties are encouraged to seek extensions of time in a timely fashion. "A motion for extension of time is not self-executing; no motion is, unless expressly provided for by the applicable rule. Yet, by filing these motions on or near the last day, and then sitting idle pending the Court's disposition of the motion, parties essentially grant their own motion. The Court will not condone this." Compere v. Nusret Miami, LLC, 2020 WL 2844888, at *2 (S.D. Fla. May 7, 2020) (internal citations omitted). Exhibits to pleadings and motions shall be docketed in accordance with the Courts CM/ECF procedures, Rule 3L.(2): (2) Describing an Attachment to a Docket Entry A party filing an attachment to a document shall select one of the prescribed attachment categories from the drop-down menu (e.g., affidavit, transcript), provide an alphabetical or numerical designation (e.g., Exhibit A, Exhibit 1), and descriptively name each attachment (e.g., Exhibit 1 - Affidavit of Boo Radley) in a manner that enables the Court to easily locate and distinguish attachments. (Emphasis added.) Local Rule 16.4, Local Rules for the United States District Court for the Southern District of Florida, requires that a Notice of Settlement "shall be filed and served jointly by counsel for all parties to the settlement." A unilateral notice of settlement will not stay pre-trial deadlines or hearings. Failure to comply with any of these procedures may result in the imposition of appropriate sanctions. Signed by Judge Raag Singhal on 6/6/2022.

5

June 6, 2022

PAPERLESS ORDER TO FILE CERTIFICATE OF INTERESTED PERSONS Within SEVEN (7) DAYS of entry of an appearance, each party, including governmental parties, must file certificates of interested parties and corporate disclosure statements that contain a complete list of persons, associated persons, firms, partnerships, or corporations that have a financial interest in the outcome of this case, including subsidiaries, conglomerates, affiliates, parent corporations, and other identifiable legal entities related to a party. The parties shall not include Judge Singhal or the paired magistrate judges as interested parties unless they have an interest in the litigation. Throughout the pendency of the action, the parties are under a continuing obligation to amend, correct, and update the certificates. Signed by Judge Raag Singhal on 6/6/2022.

6

June 6, 2022

Plaintiff's Certificate of Other Affiliates/Corporate Disclosure Statement by ACUSHNET COMPANY, CALLAWAY GOLF COMPANY, KARSTEN MANUFACTURING CORPORATION, PARSONS XTREME GOLF, LLC, ROGER CLEVELAND GOLF COMPANY, INC., SUMITOMO RUBBER INDUSTRIES, LTD., TAYLOR MADE GOLF COMPANY, INC. identifying Other Affiliate Sumitomo Rubber Industries, Ltd. for ROGER CLEVELAND GOLF COMPANY, INC., SUMITOMO RUBBER INDUSTRIES, LTD.; Corporate Parent Acushnet Holdings Corp. for ACUSHNET COMPANY; Corporate Parent 19th Holdings (Delaware), Inc for TAYLOR MADE GOLF COMPANY, INC.

7

June 6, 2022

Plaintiff's MOTION to Seal per Local Rule 5.4 by ACUSHNET COMPANY, CALLAWAY GOLF COMPANY, KARSTEN MANUFACTURING CORPORATION, PARSONS XTREME GOLF, LLC, ROGER CLEVELAND GOLF COMPANY, INC., SUMITOMO RUBBER INDUSTRIES, LTD., TAYLOR MADE GOLF COMPANY, INC.

Text of Proposed Order

10

June 7, 2022

PAPERLESS ORDER granting 7 Motion to Seal. Signed by Judge Raag Singhal on 6/7/2022.

Order (Text entry; no document attached.)

15

June 13, 2022

PLAINTIFFS' NOTICE OF FILING Seizure Bond in the amount of $10,000.00 posted by ACUSHNET COMPANY, CALLAWAY GOLF COMPANY, KARSTEN MANUFACTURING CORPORATION, PARSONS XTREME GOLF, LLC, ROGER CLEVELAND GOLF COMPANY, INC., SUMITOMO RUBBER INDUSTRIES, LTD., TAYLOR MADE GOLF COMPANY, INC. Approved by Judge Raag Singhal

SYSTEM ENTRY - Docket Entry 18 [order] restricted/sealed until further notice. (Text entry; no document attached.)

SYSTEM ENTRY - Docket Entry 18 [order] restricted/sealed until further notice. (Text entry; no document attached.)

Order (Text entry; no document attached.)

19

July 8, 2022

Plaintiff's MOTION to Unseal by ACUSHNET COMPANY, CALLAWAY GOLF COMPANY, KARSTEN MANUFACTURING CORPORATION, PARSONS XTREME GOLF, LLC, ROGER CLEVELAND GOLF COMPANY, INC., SUMITOMO RUBBER INDUSTRIES, LTD., TAYLOR MADE GOLF COMPANY, INC.

Text of Proposed Order

20

July 10, 2022

PAPERLESS ORDER granting 19 Motion. The Clerk of Court is directed to unseal all docket entries in this case and return those portions of the Court file to the public records. Signed by Judge Raag Singhal on 7/11/2022.

21

July 11, 2022

CLERK'S NOTICE of Compliance by Unsealing documents 8, 9, 11, 12, 13, 14, 16, 17 & 18 pursuant 20 Order.

22

July 12, 2022

NOTICE by ACUSHNET COMPANY, CALLAWAY GOLF COMPANY, KARSTEN MANUFACTURING CORPORATION, PARSONS XTREME GOLF, LLC, ROGER CLEVELAND GOLF COMPANY, INC., SUMITOMO RUBBER INDUSTRIES, LTD., TAYLOR MADE GOLF COMPANY, INC. re [18] Order on Ex Parte Motion, [10] Order on Motion to Seal, [11] Order on Ex Parte Motion, [1] Complaint, upon Defendants via Electronic Mail

Exhibit Certificate of Sevice

23

July 12, 2022

CERTIFICATE OF SERVICE by ACUSHNET COMPANY, CALLAWAY GOLF COMPANY, KARSTEN MANUFACTURING CORPORATION, PARSONS XTREME GOLF, LLC, ROGER CLEVELAND GOLF COMPANY, INC., SUMITOMO RUBBER INDUSTRIES, LTD., TAYLOR MADE GOLF COMPANY, INC. re [5] Order, [15] Bond, [14] Sealed Document, [18] Order on Ex Parte Motion, [9] Plaintiff's EX PARTE MOTION for Order Authorizing Alternate Service of Process on Defendants Pursuant to Federal Rule of Civil Procedure 4(f)(3) and Memorandum of Law In Support Thereof, [3] Form AO 120/121, [10] Order on Motion to Seal, [8] Plaintiff's EX PARTE MOTION Entry of Temporary Restraining Order, Preliminary Injunction, and Order Restraining Transfer of Assets and Memorandum of Law In Support Thereof, [17] Plaintiff's EX PARTE MOTION to Extend Temporary Restraining Order and Continue Hearing Scheduled for June 24, 2022 in Connection with the Motion for Preliminary Injunction, [11] Order on Ex Parte Motion, [7] Plaintiff's MOTION to Seal per Local Rule 5.4, [2] Clerk's Notice of Judge Assignment, [13] Sealed Document, [1] Complaint, [12] Order on Ex Parte Motion, [6] Certificate of Other Affiliates/Corporate Disclosure Statement, [4] Notice of Court Practice/to Appear/Other, upon Defendants via website posting

24

July 12, 2022

CERTIFICATE OF SERVICE by ACUSHNET COMPANY, CALLAWAY GOLF COMPANY, KARSTEN MANUFACTURING CORPORATION, PARSONS XTREME GOLF, LLC, ROGER CLEVELAND GOLF COMPANY, INC., SUMITOMO RUBBER INDUSTRIES, LTD., TAYLOR MADE GOLF COMPANY, INC. re [18] Order on Ex Parte Motion, [8] Plaintiff's EX PARTE MOTION Entry of Temporary Restraining Order, Preliminary Injunction, and Order Restraining Transfer of Assets and Memorandum of Law In Support Thereof, [17] Plaintiff's EX PARTE MOTION to Extend Temporary Restraining Order and Continue Hearing Scheduled for June 24, 2022 in Connection with the Motion for Preliminary Injunction, [11] Order on Ex Parte Motion, [1] Complaint, upon Defendants via Registrar

25

July 12, 2022

AMENDED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants, filed by KARSTEN MANUFACTURING CORPORATION, CALLAWAY GOLF COMPANY, PARSONS XTREME GOLF, LLC, ACUSHNET COMPANY, ROGER CLEVELAND GOLF COMPANY, INC., TAYLOR MADE GOLF COMPANY, INC., SUMITOMO RUBBER INDUSTRIES, LTD.

Exhibit 1 to Amended Complaint Certificates of Registration for the Taylor Made

Exhibit 2 to Amended Complaint Certificates of Registration for the Acushnet Tr

Exhibit 3 to Amended Complaint Certificates of Registration for the Callaway Go

Exhibit 4 to Amended Complaint Certificates of Registration for the Roger Cleve

Exhibit 5 to Amended Complaint Certificates of Registration for the Karsten Tra

Exhibit 6 to Amended Complaint Certificates of Registration for the PXG Tradema

26

July 13, 2022

PAPERLESS Minute Entry for proceedings held before Judge Raag Singhal: Motion Hearing held on 7/13/2022 re 8 Plaintiff's EX PARTE MOTION Entry of Temporary Restraining Order, Preliminary Injunction, and Order Restraining Transfer of Assets and Memorandum of Law In Support Thereof filed by KARSTEN MANUFACTURING CORPORATION, ROGER CLEVELAND GOLF COMPANY, INC., ACUSHNET COMPANY, PARSONS XTREME GOLF, LLC, Sumitomo Rubber Industries, Ltd., CALLAWAY GOLF COMPANY, TAYLOR MADE GOLF COMPANY, INC., SUMITOMO RUBBER INDUSTRIES, LTD. Total time in court: 15 minutes. Attorney Appearance(s): T. Raquel Wiborg-Rodriguez, Court Reporter: Karl Shires, 954-769-5496 / Karl_Shires@flsd.uscourts.gov.

27

July 13, 2022

ORDER Granting 8 Plaintiff's Application for Entry of Preliminary Injunction. Signed by Judge Raag Singhal on 7/14/2022. See attached document for full details.

28

Sept. 7, 2022

ORDER ON DEFAULT PROCEDURE re DE#[23][24] Signed by Judge Raag Singhal on 9/7/2022. See attached document for full details.

29

Sept. 13, 2022

NOTICE by ACUSHNET COMPANY, CALLAWAY GOLF COMPANY, KARSTEN MANUFACTURING CORPORATION, PARSONS XTREME GOLF, LLC, ROGER CLEVELAND GOLF COMPANY, INC., SUMITOMO RUBBER INDUSTRIES, LTD., TAYLOR MADE GOLF COMPANY, INC. re [27] Order upon Defendants via Electronic Mail

Exhibit Certificate of Sevice

30

Sept. 13, 2022

CERTIFICATE OF SERVICE by ACUSHNET COMPANY, CALLAWAY GOLF COMPANY, KARSTEN MANUFACTURING CORPORATION, PARSONS XTREME GOLF, LLC, ROGER CLEVELAND GOLF COMPANY, INC., SUMITOMO RUBBER INDUSTRIES, LTD., TAYLOR MADE GOLF COMPANY, INC. re [27] Order upon Defendants via Registrar

31

Sept. 13, 2022

CERTIFICATE OF SERVICE by ACUSHNET COMPANY, CALLAWAY GOLF COMPANY, KARSTEN MANUFACTURING CORPORATION, PARSONS XTREME GOLF, LLC, ROGER CLEVELAND GOLF COMPANY, INC., SUMITOMO RUBBER INDUSTRIES, LTD., TAYLOR MADE GOLF COMPANY, INC. re [27] Order upon Defendants via website posting

32

Sept. 13, 2022

SUMMONS (Affidavit) Returned Executed on [25] Amended Complaint/Amended Notice of Removal, [1] Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by ACUSHNET COMPANY, SUMITOMO RUBBER INDUSTRIES, LTD., PARSONS XTREME GOLF, LLC, TAYLOR MADE GOLF COMPANY, INC., KARSTEN MANUFACTURING CORPORATION, CALLAWAY GOLF COMPANY, ROGER CLEVELAND GOLF COMPANY, INC. 100% cotton t-shirt aw store served on 8/10/2022, response/answer due 8/31/2022; 100% cotton t-shirts uu store served on 8/10/2022, response/answer due 8/31/2022; 101sp store served on 8/10/2022, response/answer due 8/31/2022; 58888888 store served on 8/10/2022, response/answer due 8/31/2022; aagolf store served on 8/10/2022, response/answer due 8/31/2022; adymyshophome.shop served on 8/10/2022, response/answer due 8/31/2022; agjshop.com served on 8/10/2022, response/answer due 8/31/2022; alaskab.co served on 8/10/2022, response/answer due 8/31/2022; allisones.shop served on 8/10/2022, response/answer due 8/31/2022; alteritalter.shop served on 8/10/2022, response/answer due 8/31/2022; aofcho.com served on 8/10/2022, response/answer due 8/31/2022; aucrab.co served on 8/10/2022, response/answer due 8/31/2022; azdshop.com served on 8/10/2022, response/answer due 8/31/2022; bags2020s.com served on 8/10/2022, response/answer due 8/31/2022; base-area.site served on 8/10/2022, response/answer due 8/31/2022; besttaylormade.xyz served on 8/10/2022, response/answer due 8/31/2022; biger orange served on 8/10/2022, response/answer due 8/31/2022; bizgolf store served on 8/10/2022, response/answer due 8/31/2022; bravosport store served on 8/10/2022, response/answer due 8/31/2022; callawaymart.com served on 8/10/2022, response/answer due 8/31/2022; callawayuac.com served on 8/10/2022, response/answer due 8/31/2022; caoying50509 served on 8/10/2022, response/answer due 8/31/2022; casualigee.com served on 8/10/2022, response/answer due 8/31/2022; cheng xi 8866 store served on 8/10/2022, response/answer due 8/31/2022; chuangxindian store served on 8/10/2022, response/answer due 8/31/2022; cindygolfzone served on 8/10/2022, response/answer due 8/31/2022; cookutens.xyz served on 8/10/2022, response/answer due 8/31/2022; coopg served on 8/10/2022, response/answer due 8/31/2022; cotton 100% men tshirt store served on 8/10/2022, response/answer due 8/31/2022; cotton t-shirt i store served on 8/10/2022, response/answer due 8/31/2022; cotton t-shirts a store served on 8/10/2022, response/answer due 8/31/2022; cotton t-shirts l store served on 8/10/2022, response/answer due 8/31/2022; crosscom served on 8/10/2022, response/answer due 8/31/2022; czxl served on 8/10/2022, response/answer due 8/31/2022; dagu020 served on 8/10/2022, response/answer due 8/31/2022; davidgolf served on 8/10/2022, response/answer due 8/31/2022; de zhou de sheng yi bo store served on 8/10/2022, response/answer due 8/31/2022; defensee.top served on 8/10/2022, response/answer due 8/31/2022; dewalepro.shop served on 8/10/2022, response/answer due 8/31/2022; dirtsurfer.ca served on 8/10/2022, response/answer due 8/31/2022; dksports store served on 8/10/2022, response/answer due 8/31/2022; dugutx served on 8/10/2022, response/answer due 8/31/2022; dustin jf store served on 8/10/2022, response/answer due 8/31/2022; egjoqshop.com served on 8/10/2022, response/answer due 8/31/2022; elliarpin.com served on 8/10/2022, response/answer due 8/31/2022; exceenllt.shop served on 8/10/2022, response/answer due 8/31/2022; fans club-golf store served on 8/10/2022, response/answer due 8/31/2022; fidget5 served on 8/10/2022, response/answer due 8/31/2022; fidget7 served on 8/10/2022, response/answer due 8/31/2022; fightgolf66 served on 8/10/2022, response/answer due 8/31/2022; fiza._75 served on 8/10/2022, response/answer due 8/31/2022; freemaller.top served on 8/10/2022, response/answer due 8/31/2022; gaara_akira served on 8/10/2022, response/answer due 8/31/2022; gaolanhao8442 served on 8/10/2022, response/answer due 8/31/2022; gksky store served on 8/10/2022, response/answer due 8/31/2022; golden putting green store served on 8/10/2022, response/answer due 8/31/2022; golden-elephant e-commerce store served on 8/10/2022, response/answer due 8/31/2022; goldenmana.top served on 8/10/2022, response/answer due 8/31/2022; golf-sporting.com served on 8/10/2022, response/answer due 8/31/2022; golf-top-sports store served on 8/10/2022, response/answer due 8/31/2022; golfmakers served on 8/10/2022, response/answer due 8/31/2022; golfoutdoor served on 8/10/2022, response/answer due 8/31/2022; golfstore66 served on 8/10/2022, response/answer due 8/31/2022; golfstore88 served on 8/10/2022, response/answer due 8/31/2022; golfwear store served on 8/10/2022, response/answer due 8/31/2022; good loft store served on 8/10/2022, response/answer due 8/31/2022; gudusheng served on 8/10/2022, response/answer due 8/31/2022; guisuoyan45643 served on 8/10/2022, response/answer due 8/31/2022; hatsky store served on 8/10/2022, response/answer due 8/31/2022; heartlanddeal.com served on 8/10/2022, response/answer due 8/31/2022; hepburne.com served on 8/10/2022, response/answer due 8/31/2022; hmnike served on 8/10/2022, response/answer due 8/31/2022; honmagolf store served on 8/10/2022, response/answer due 8/31/2022; htb520 served on 8/10/2022, response/answer due 8/31/2022; ipfurniture.shop served on 8/10/2022, response/answer due 8/31/2022; itya store served on 8/10/2022, response/answer due 8/31/2022; jiayuting5699 served on 8/10/2022, response/answer due 8/31/2022; jikyy store served on 8/10/2022, response/answer due 8/31/2022; kaminari burger served on 8/10/2022, response/answer due 8/31/2022; kjgiuou served on 8/10/2022, response/answer due 8/31/2022; lcyhqmail.com served on 8/10/2022, response/answer due 8/31/2022; lichunyan1159 served on 8/10/2022, response/answer due 8/31/2022; liikemart.com served on 8/10/2022, response/answer due 8/31/2022; limengying6337 served on 8/10/2022, response/answer due 8/31/2022; linzhikang668 served on 8/10/2022, response/answer due 8/31/2022; lisuan7672 served on 8/10/2022, response/answer due 8/31/2022; liuyangout served on 8/10/2022, response/answer due 8/31/2022; longming06 served on 8/10/2022, response/answer due 8/31/2022; lookmm.shop served on 8/10/2022, response/answer due 8/31/2022; luokun0047 served on 8/10/2022, response/answer due 8/31/2022; matecolor.store served on 8/10/2022, response/answer due 8/31/2022; mazurn served on 8/10/2022, response/answer due 8/31/2022; mrfitting store served on 8/10/2022, response/answer due 8/31/2022; ngkkr.com served on 8/10/2022, response/answer due 8/31/2022; niuyingying8538 served on 8/10/2022, response/answer due 8/31/2022; noaishop.com served on 8/10/2022, response/answer due 8/31/2022; pamanagolf store served on 8/10/2022, response/answer due 8/31/2022; panshuang6713 served on 8/10/2022, response/answer due 8/31/2022; ponnne.com served on 8/10/2022, response/answer due 8/31/2022; princess nc served on 8/10/2022, response/answer due 8/31/2022; professional-sport-2 store served on 8/10/2022, response/answer due 8/31/2022; qq17611478602 served on 8/10/2022, response/answer due 8/31/2022; rafi_6220 served on 8/10/2022, response/answer due 8/31/2022; rainshine served on 8/10/2022, response/answer due 8/31/2022; roylafave.shop served on 8/10/2022, response/answer due 8/31/2022; rzctsc.com served on 8/10/2022, response/answer due 8/31/2022; sapphireorbit.com served on 8/10/2022, response/answer due 8/31/2022; shannongolf store served on 8/10/2022, response/answer due 8/31/2022; shop5187017 store served on 8/10/2022, response/answer due 8/31/2022; shop5255059 served on 8/10/2022, response/answer due 8/31/2022; shop5400015 store served on 8/10/2022, response/answer due 8/31/2022; shop5439006 store served on 8/10/2022, response/answer due 8/31/2022; shop5633232 store served on 8/10/2022, response/answer due 8/31/2022; shop5793282 store served on 8/10/2022, response/answer due 8/31/2022; shop5952138 store served on 8/10/2022, response/answer due 8/31/2022; shop910320060 store served on 8/10/2022, response/answer due 8/31/2022; shop910457094 store served on 8/10/2022, response/answer due 8/31/2022; shop910723026 store served on 8/10/2022, response/answer due 8/31/2022; shop910921021 store served on 8/10/2022, response/answer due 8/31/2022; shop911044019 store served on 8/10/2022, response/answer due 8/31/2022; shuangyin001 served on 8/10/2022, response/answer due 8/31/2022; slmbet.com served on 8/10/2022, response/answer due 8/31/2022; smileluck.shop served on 8/10/2022, response/answer due 8/31/2022; ssstars store served on 8/10/2022, response/answer due 8/31/2022; stosshop.com served on 8/10/2022, response/answer due 8/31/2022; suetykjkvs served on 8/10/2022, response/answer due 8/31/2022; sufree store served on 8/10/2022, response/answer due 8/31/2022; sun5931 served on 8/10/2022, response/answer due 8/31/2022; supergolf store served on 8/10/2022, response/answer due 8/31/2022; sweaty store served on 8/10/2022, response/answer due 8/31/2022; sxiuc served on 8/10/2022, response/answer due 8/31/2022; tanggolf served on 8/10/2022, response/answer due 8/31/2022; tanqinghua9217 served on 8/10/2022, response/answer due 8/31/2022; taylgolf.com served on 8/10/2022, response/answer due 8/31/2022; taylormadeproduct.cc served on 8/10/2022, response/answer due 8/31/2022; taylormadeproduct.top served on 8/10/2022, response/answer due 8/31/2022; taylormadewelfare.shop served on 8/10/2022, response/answer due 8/31/2022; tefjx.shop served on 8/10/2022, response/answer due 8/31/2022; tienstores.com served on 8/10/2022, response/answer due 8/31/2022; timebayle served on 8/10/2022, response/answer due 8/31/2022; top-sports-golf store served on 8/10/2022, response/answer due 8/31/2022; topemart2020 served on 8/10/2022, response/answer due 8/31/2022; topnotch store served on 8/10/2022, response/answer due 8/31/2022; tq1985 store served on 8/10/2022, response/answer due 8/31/2022; tyoutlet.xyz served on 8/10/2022, response/answer due 8/31/2022; ufvo993 served on 8/10/2022, response/answer due 8/31/2022; ulovehome served on 8/10/2022, response/answer due 8/31/2022; upscale store served on 8/10/2022, response/answer due 8/31/2022; us.skyphorn.com served on 8/10/2022, response/answer due 8/31/2022; us.thismes.com served on 8/10/2022, response/answer due 8/31/2022; venuefrigate.com served on 8/10/2022, response/answer due 8/31/2022; vlonevip7 served on 8/10/2022, response/answer due 8/31/2022; volatilization store served on 8/10/2022, response/answer due 8/31/2022; vvan store served on 8/10/2022, response/answer due 8/31/2022; wandongming3300 served on 8/10/2022, response/answer due 8/31/2022; wanglixin5778 served on 8/10/2022, response/answer due 8/31/2022; wanliudanquan served on 8/10/2022, response/answer due 8/31/2022; wassaile.com served on 8/10/2022, response/answer due 8/31/2022; well,well store served on 8/10/2022, response/answer due 8/31/2022; wuyongpeng9536 served on 8/10/2022, response/answer due 8/31/2022; xdiscountshop.shop served on 8/10/2022, response/answer due 8/31/2022; xiaoruirui store served on 8/10/2022, response/answer due 8/31/2022; xuandiyam served on 8/10/2022, response/answer due 8/31/2022; yangyiran store served on 8/10/2022, response/answer due 8/31/2022; yaojinhang3874 served on 8/10/2022, response/answer due 8/31/2022; yigu006 served on 8/10/2022, response/answer due 8/31/2022; yintingting4586 served on 8/10/2022, response/answer due 8/31/2022; yohi wenore served on 8/10/2022, response/answer due 8/31/2022; youmiao served on 8/10/2022, response/answer due 8/31/2022; yuanmu23 served on 8/10/2022, response/answer due 8/31/2022; yueraoz served on 8/10/2022, response/answer due 8/31/2022; yuiji served on 8/10/2022, response/answer due 8/31/2022; yunlanzong served on 8/10/2022, response/answer due 8/31/2022; yushui11 served on 8/10/2022, response/answer due 8/31/2022; zhangyimin1102 served on 8/10/2022, response/answer due 8/31/2022; zhongfusport served on 8/10/2022, response/answer due 8/31/2022; zssstores served on 8/10/2022, response/answer due 8/31/2022.

Affidavit of Service

Affidavit of Service

33

Sept. 13, 2022

Plaintiff's MOTION for Clerk's Entry of Default as to 100% cotton t-shirt aw store, 100% cotton t-shirts uu store, 101sp store, 58888888 store, The Individuals, Business Entities, and Unincorporated Associations, aagolf store, adymyshophome.shop, agjshop.com, alaskab.co, allisones.shop, alteritalter.shop, aofcho.com, aucrab.co, azdshop.com, bags2020s.com, base-area.site, besttaylormade.xyz, biger orange, bizgolf store, bravosport store, callawayuac.com, caoying50509, casualigee.com, cheng xi 8866 store, chuangxindian store, cindygolfzone, cookutens.xyz, coopg, cotton 100% men tshirt store, cotton t-shirt i store, cotton t-shirts a store, cotton t-shirts l store, crosscom, czxl, dagu020, davidgolf, de zhou de sheng yi bo store, defensee.top, dewalepro.shop, dirtsurfer.ca, dksports store, dugutx, dustin jf store, exceenllt.shop, fans club-golf store, fidget5, fidget7, fightgolf66, fiza._75, gaara_akira, gaolanhao8442, gksky store, golden putting green store, golden-elephant e-commerce store, goldenmana.top, golf-top-sports store, golfmakers, golfoutdoor, golfstore66, golfstore88, golfwear store, good loft store, gudusheng, guisuoyan45643, hatsky store, hepburne.com, hmnike, honmagolf store, htb520, ipfurniture.shop, itya store, jiayuting5699, jikyy store, kaminari burger, kjgiuou, lcyhqmail.com, lichunyan1159, liikemart.com, limengying6337, linzhikang668, lisuan7672, liuyangout, longming06, lookmm.shop, luokun0047, matecolor.store, mazurn, mrfitting store, ngkkr.com, niuyingying8538, noaishop.com, pamanagolf store, panshuang6713, ponnne.com, princess nc, professional-sport-2 store, qq17611478602, rafi_6220, rainshine, roylafave.shop, rzctsc.com, sapphireorbit.com, shannongolf store, shop5187017 store, shop5255059, shop5400015 store, shop5439006 store, shop5633232 store, shop5793282 store, shop5952138 store, shop910320060 store, shop910457094 store, shop910723026 store, shop910921021 store, shop911044019 store, shuangyin001, smileluck.shop, ssstars store, stosshop.com, suetykjkvs, sufree store, sun5931, supergolf store, sweaty store, sxiuc, tanggolf, tanqinghua9217, taylgolf.com, taylormadeproduct.cc, taylormadeproduct.top, taylormadewelfare.shop, tefjx.shop, tienstores.com, timebayle, top-sports-golf store, topemart2020, topnotch store, tq1985 store, tyoutlet.xyz, ulovehome, upscale store, us.thismes.com, venuefrigate.com, vlonevip7, volatilization store, vvan store, wandongming3300, wanglixin5778, wanliudanquan, wassaile.com, well,well store, wuyongpeng9536, xdiscountshop.shop, xiaoruirui store, xuandiyam, yangyiran store, yaojinhang3874, yigu006, yintingting4586, yohi wenore, youmiao, yuanmu23, yueraoz, yuiji, yunlanzong, yushui11, zhangyimin1102, zhongfusport, zssstores by ACUSHNET COMPANY, SUMITOMO RUBBER INDUSTRIES, LTD., PARSONS XTREME GOLF, LLC, TAYLOR MADE GOLF COMPANY, INC., KARSTEN MANUFACTURING CORPORATION, CALLAWAY GOLF COMPANY, ROGER CLEVELAND GOLF COMPANY, INC.

Exhibit Declaration of Virgilio Gigante in Support of Request for Clerk's E

Text of Proposed Order

34

Sept. 14, 2022

Clerk's Entry of Default as to 100% cotton t-shirt aw store, 100% cotton t-shirts uu store, 101sp store, 58888888 store, The Individuals, Business Entities, and Unincorporated Associations, aagolf store, adymyshophome.shop, agjshop.com, alaskab.co, allisones.shop, alteritalter.shop, aofcho.com, aucrab.co, azdshop.com, bags2020s.com, base-area.site, besttaylormade.xyz, biger orange, bizgolf store, bravosport store, callawaymart.com, callawayuac.com, caoying50509, casualigee.com, cheng xi 8866 store, chuangxindian store, cindygolfzone, cookutens.xyz, coopg, cotton 100% men tshirt store, cotton t-shirt i store, cotton t-shirts a store, cotton t-shirts l store, crosscom, czxl, dagu020, davidgolf, de zhou de sheng yi bo store, defensee.top, dewalepro.shop, dirtsurfer.ca, dksports store, dugutx, dustin jf store, egjoqshop.com, elliarpin.com, exceenllt.shop, fans club-golf store, fidget5, fidget7, fightgolf66, fiza._75, freemaller.top, gaara_akira, gaolanhao8442, gksky store, golden putting green store, golden-elephant e-commerce store, goldenmana.top, golf-sporting.com, golf-top-sports store, golfmakers, golfoutdoor, golfstore66, golfstore88, golfwear store, good loft store, gudusheng, guisuoyan45643, hatsky store, heartlanddeal.com, hepburne.com, hmnike, honmagolf store, htb520, ipfurniture.shop, itya store, jiayuting5699, jikyy store, kaminari burger, kjgiuou, lcyhqmail.com, lichunyan1159, liikemart.com, limengying6337, linzhikang668, lisuan7672, liuyangout, longming06, lookmm.shop, luokun0047, matecolor.store, mazurn, mrfitting store, ngkkr.com, niuyingying8538, noaishop.com, pamanagolf store, panshuang6713, ponnne.com, princess nc, professional-sport-2 store, qq17611478602, rafi_6220, rainshine, roylafave.shop, rzctsc.com, sapphireorbit.com, shannongolf store, shop5187017 store, shop5255059, shop5400015 store, shop5439006 store, shop5633232 store, shop5793282 store, shop5952138 store, shop910320060 store, shop910457094 store, shop910723026 store, shop910921021 store, shop911044019 store, shuangyin001, slmbet.com, smileluck.shop, ssstars store, stosshop.com, suetykjkvs, sufree store, sun5931, supergolf store, sweaty store, sxiuc, tanggolf, tanqinghua9217, taylgolf.com, taylormadeproduct.cc, taylormadeproduct.top, taylormadewelfare.shop, tefjx.shop, tienstores.com, timebayle, top-sports-golf store, topemart2020, topnotch store, tq1985 store, tyoutlet.xyz, ufvo993, ulovehome, upscale store, us.skyphorn.com, us.thismes.com, venuefrigate.com, vlonevip7, volatilization store, vvan store, wandongming3300, wanglixin5778, wanliudanquan, wassaile.com, well,well store, wuyongpeng9536, xdiscountshop.shop, xiaoruirui store, xuandiyam, yangyiran store, yaojinhang3874, yigu006, yintingting4586, yohi wenore, youmiao, yuanmu23, yueraoz, yuiji, yunlanzong, yushui11, zhangyimin1102, zhongfusport, zssstores Granting 33 Motion for Clerk's Entry of Default. Signed by DEPUTY CLERK on 9/14/2022.

35

Sept. 23, 2022

ORDER ON DEFAULT FINAL JUDGMENT PROCEDURE re [34] Clerk's Entry/Non-Entry of Default, filed by 58888888 store, 101sp store, 100% cotton t-shirt aw store, 100% cotton t-shirts uu store, sweaty store, adymyshophome.shop, guisuoyan45643, fidget5, wuyongpeng9536, shop910921021 store, dksports store, wandongming3300, taylormadewelfare.shop, shop5633232 store, limengying6337, aagolf store, top-sports-golf store, suetykjkvs, cotton t-shirts l store, besttaylormade.xyz, timebayle, tq1985 store, honmagolf store, golfstore88, us.skyphorn.com, lcyhqmail.com, hepburne.com, yintingting4586, hmnike, good loft store, alteritalter.shop, linzhikang668, smileluck.shop, kaminari burger, yushui11, liuyangout, taylormadeproduct.cc, fidget7, coopg, gksky store, well,well store, sufree store, vlonevip7, fiza._75, vvan store, princess nc, panshuang6713, ulovehome, bizgolf store, lichunyan1159, ponnne.com, shop5255059, us.thismes.com, zhongfusport, shop910723026 store, biger orange, cindygolfzone, czxl, supergolf store, tanqinghua9217, crosscom, golden-elephant e-commerce store, zhangyimin1102, yunlanzong, heartlanddeal.com, mrfitting store, shop910320060 store, callawayuac.com, topnotch store, tyoutlet.xyz, freemaller.top, davidgolf, agjshop.com, yuiji, golfstore66, callawaymart.com, roylafave.shop, yohi wenore, yuanmu23, gaolanhao8442, slmbet.com, yigu006, taylgolf.com, professional-sport-2 store, itya store, htb520, dustin jf store, casualigee.com, wanliudanquan, shop5952138 store, lisuan7672, dagu020, egjoqshop.com, xiaoruirui store, cotton t-shirts a store, fightgolf66, tienstores.com, dugutx, golfwear store, dirtsurfer.ca, xdiscountshop.shop, yueraoz, pamanagolf store, venuefrigate.com, ipfurniture.shop, golf-sporting.com, golden putting green store, de zhou de sheng yi bo store, yangyiran store, sxiuc, fans club-golf store, jiayuting5699, qq17611478602, rzctsc.com, niuyingying8538, shop910457094 store, azdshop.com, rafi_6220, liikemart.com, xuandiyam, shop911044019 store, volatilization store, zssstores, shop5187017 store, ngkkr.com, allisones.shop, shuangyin001, taylormadeproduct.top, jikyy store, kjgiuou, rainshine, sapphireorbit.com, ssstars store, cotton 100% men tshirt store, dewalepro.shop, shop5439006 store, sun5931, aofcho.com, gaara_akira, golfoutdoor, exceenllt.shop, golfmakers, chuangxindian store, upscale store, wanglixin5778, elliarpin.com, wassaile.com, The Individuals, Business Entities, and Unincorporated Associations, tefjx.shop, tanggolf, defensee.top, alaskab.co, mazurn, cotton t-shirt i store, shop5400015 store, ufvo993, goldenmana.top, bravosport store, golf-top-sports store, topemart2020, lookmm.shop, longming06, youmiao, aucrab.co, cookutens.xyz, yaojinhang3874, shop5793282 store, noaishop.com, base-area.site, bags2020s.com, hatsky store, luokun0047, gudusheng, cheng xi 8866 store, shannongolf store, stosshop.com, matecolor.store, caoying50509 Signed by Judge Raag Singhal on 9/23/2022. See attached document for full details.

36

Sept. 27, 2022

NOTICE of Voluntary Dismissal Without Prejudice of Certain Defendants by ACUSHNET COMPANY, CALLAWAY GOLF COMPANY, KARSTEN MANUFACTURING CORPORATION, PARSONS XTREME GOLF, LLC, ROGER CLEVELAND GOLF COMPANY, INC., SUMITOMO RUBBER INDUSTRIES, LTD., TAYLOR MADE GOLF COMPANY, INC.

(Text of Proposed Order)

37

Sept. 27, 2022

Plaintiff's MOTION for Default Judgment and Memorandum of Law In Support Thereof by ACUSHNET COMPANY, CALLAWAY GOLF COMPANY, KARSTEN MANUFACTURING CORPORATION, PARSONS XTREME GOLF, LLC, ROGER CLEVELAND GOLF COMPANY, INC., SUMITOMO RUBBER INDUSTRIES, LTD., TAYLOR MADE GOLF COMPANY, INC.

Text of Proposed Order Granting Motion for Final Default Judgment

Supplement Final Judgment and Permanent Injunction

(Declaration of Virgilio Gigante in Support Thereof)

38

Oct. 26, 2022

ORDER GRANTING MOTION FOR FINAL DEFAULT JUDGMENT granting [37] Motion for Default Judgment. Signed by Judge Raag Singhal on 10/26/2022. See attached document for full details.

39

Oct. 26, 2022

DEFAULT FINAL JUDGMENT AND PERMANENT INJUNCTION in favor of ACUSHNET COMPANY, CALLAWAY GOLF COMPANY, KARSTEN MANUFACTURING CORPORATION, PARSONS XTREME GOLF, LLC, ROGER CLEVELAND GOLF COMPANY, INC., SUMITOMO RUBBER INDUSTRIES, LTD., TAYLOR MADE GOLF COMPANY, INC. against 100% cotton t-shirt aw store, 100% cotton t-shirts uu store, 101sp store, 58888888 store, The Individuals, Business Entities, and Unincorporated Associations, aagolf store, adymyshophome.shop, agjshop.com, alaskab.co, allisones.shop, alteritalter.shop, aofcho.com, aucrab.co, azdshop.com, bags2020s.com, base-area.site, besttaylormade.xyz, biger orange, bizgolf store, bravosport store, callawaymart.com, callawayuac.com, caoying50509, casualigee.com, cheng xi 8866 store, chuangxindian store, cindygolfzone, cookutens.xyz, coopg, cotton 100% men tshirt store, cotton t-shirt i store, cotton t-shirts a store, cotton t-shirts l store, crosscom, czxl, dagu020, davidgolf, de zhou de sheng yi bo store, defensee.top, dewalepro.shop, dirtsurfer.ca, dksports store, dugutx, dustin jf store, egjoqshop.com, elliarpin.com, exceenllt.shop, fans club-golf store, fidget5, fidget7, fightgolf66, fiza._75, freemaller.top, gaara_akira, gaolanhao8442, gksky store, golden putting green store, golden-elephant e-commerce store, goldenmana.top, golf-sporting.com, golf-top-sports store, golfmakers, golfoutdoor, golfstore66, golfstore88, golfwear store, good loft store, gudusheng, guisuoyan45643, hatsky store, heartlanddeal.com, hepburne.com, hmnike, honmagolf store, htb520, ipfurniture.shop, itya store, jiayuting5699, jikyy store, kaminari burger, kjgiuou, lcyhqmail.com, lichunyan1159, liikemart.com, limengying6337, linzhikang668, lisuan7672, liuyangout, longming06, lookmm.shop, luokun0047, matecolor.store, mazurn, mrfitting store, ngkkr.com, niuyingying8538, noaishop.com, pamanagolf store, panshuang6713, ponnne.com, princess nc, professional-sport-2 store, qq17611478602, rafi_6220, rainshine, roylafave.shop, rzctsc.com, sapphireorbit.com, shannongolf store, shop5187017 store, shop5255059, shop5400015 store, shop5439006 store, shop5633232 store, shop5793282 store, shop5952138 store, shop910320060 store, shop910457094 store, shop910723026 store, shop910921021 store, shop911044019 store, shuangyin001, slmbet.com, smileluck.shop, ssstars store, stosshop.com, suetykjkvs, sufree store, sun5931, supergolf store, sweaty store, sxiuc, tanggolf, tanqinghua9217, taylgolf.com, taylormadeproduct.cc, taylormadeproduct.top, taylormadewelfare.shop, tefjx.shop, tienstores.com, timebayle, top-sports-golf store, topemart2020, topnotch store, tq1985 store, tyoutlet.xyz, ufvo993, ulovehome, upscale store, us.skyphorn.com, us.thismes.com, venuefrigate.com, vlonevip7, volatilization store, vvan store, wandongming3300, wanglixin5778, wanliudanquan, wassaile.com, well,well store, wuyongpeng9536, xdiscountshop.shop, xiaoruirui store, xuandiyam, yangyiran store, yaojinhang3874, yigu006, yintingting4586, yohi wenore, youmiao, yuanmu23, yueraoz, yuiji, yunlanzong, yushui11, zhangyimin1102, zhongfusport, zssstores Closing Case. Signed by Judge Raag Singhal on 10/26/2022. See attached document for full details.

40

Oct. 27, 2022

FORM AO 120 SENT TO DIRECTOR OF U.S. PATENT AND TRADEMARK

41

Oct. 27, 2022

Clerk's Notice of Docket Correction re 39 Default Judgment, Correction Other. Corrected image attached.

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