2023-cv-61857

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. Filing fees $ 402.00 receipt number AFLSDC-16954373, filed by ADIDAS AG, ADIDAS AMERICA, INC., ADIDAS INTERNATIONAL MARKETING B.V.

Civil Cover Sheet

Exhibit 1 to Complaint Certificates of Registration for the adidas Trademarks

Clerks Notice of Judge Assignment to Judge Rodney Smith. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Lisette M. Reid 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.

Clerk's Notice of Judge Assignment and Optional Consent (Text entry; no document attached.)

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

Complaint

Plaintiff's Corporate Disclosure Statement by ADIDAS AG, ADIDAS AMERICA, INC., ADIDAS INTERNATIONAL MARKETING B.V. identifying Corporate Parent adidas North America, Inc. for ADIDAS AMERICA, INC.

Plaintiff's MOTION to Seal per Local Rule 5.4 by ADIDAS AG, ADIDAS AMERICA, INC., ADIDAS INTERNATIONAL MARKETING B.V.

Text of Proposed Order

Notice of Ninety Days Expiring by ADIDAS AG, ADIDAS AMERICA, INC., ADIDAS INTERNATIONAL MARKETING B.V.

Notice of Ninety Days Expiring Second Notice Regarding Docket Entries 6 and 7 by ADIDAS AG, ADIDAS AMERICA, INC., ADIDAS INTERNATIONAL MARKETING B.V.

ORDER GRANTING MOTION TO SEAL granting [5] Motion to Seal. Signed by Judge Rodney Smith on 5/1/2024. See attached document for full details.

Order (Text entry; no document attached.)

Plaintiff's notice of filing bond by ADIDAS AG, ADIDAS AMERICA, INC., ADIDAS INTERNATIONAL MARKETING B.V.

Order (Text entry; no document attached.)

Plaintiff's MOTION to Unseal Case by ADIDAS AG, ADIDAS AMERICA, INC., ADIDAS INTERNATIONAL MARKETING B.V. Responses due by 5/28/2024.

Text of Proposed Order

ORDER GRANTING PLAINTIFFS' MOTION TO UNSEAL granting [15] Motion to Unseal Case. The Clerk shall UNSEAL all docket entries in this case. Signed by Judge Rodney Smith on 5/13/2024. See attached document for full details.

Clerk's NOTICE of Compliance re 16 Order on Motion to Unseal Case. All Docket Entries Unsealed.

Plaintiff's NOTICE upon Defendants via Electronic Mail by ADIDAS AG, ADIDAS AMERICA, INC., ADIDAS INTERNATIONAL MARKETING B.V. re [6] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order, Preliminary Injunction, and Order Restraining Transfer of Assets and Memorandum of Law In Support Thereof, [1] Complaint, [11] Order on Ex Parte Motion

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by ADIDAS AG, ADIDAS AMERICA, INC., ADIDAS INTERNATIONAL MARKETING B.V. re [6] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order, Preliminary Injunction, and Order Restraining Transfer of Assets and Memorandum of Law In Support Thereof, [1] Complaint, [9] Notice of Ninety Days Expiring, [8] Notice of Ninety Days Expiring, [5] Plaintiff's MOTION to Seal per Local Rule 5.4, [2] Clerks Notice of Judge Assignment, [12] Order on Ex Parte Motion, [13] Notice (Other), [4] Certificate of Other Affiliates/Corporate Disclosure Statement, [7] 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, [11] Order on Ex Parte Motion, [10] Order on Motion to Seal upon Defendants via website posting

Plaintiff's NOTICE upon Defendants via Electronic Mail by ADIDAS AG, ADIDAS AMERICA, INC., ADIDAS INTERNATIONAL MARKETING B.V. re [6] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order, Preliminary Injunction, and Order Restraining Transfer of Assets and Memorandum of Law In Support Thereof, [1] Complaint, [10] Order on Motion to Seal

Exhibit Certificate of Sevice

NOTICE of Striking [20] Notice (Other), filed by ADIDAS INTERNATIONAL MARKETING B.V., ADIDAS AMERICA, INC., ADIDAS AG by ADIDAS AG, ADIDAS AMERICA, INC., ADIDAS INTERNATIONAL MARKETING B.V.

Plaintiff's NOTICE upon Defendant via Electronic Mail by ADIDAS AG, ADIDAS AMERICA, INC., ADIDAS INTERNATIONAL MARKETING B.V. re [6] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order, Preliminary Injunction, and Order Restraining Transfer of Assets and Memorandum of Law In Support Thereof, [1] Complaint, [11] Order on Ex Parte Motion

Exhibit Certificate of Sevice

Notice of Entry of Parties Listed NOTE: New Filer(s) will appear twice, since they are also a new party in the case. New Filer(s)/Party(s): aajersey.com, adgsoccer.com, angeltoheaven.com, discountbloc.ru, eletees.com, ethershirt.org, fc24shop.com, fcfshop.com, gmkits1.com, gmkits10.com, gosportszone.com, ice-jerseys.com, jerseyio.io, jerseysell.store, isoccertime.com, jshop1.com, kitsociety.net, kkgoold.com, lindajersey.com, mmjerseys00.com, nebgift.com, nebjersey.com, onlinejersey.life, socceroliverf042.com, sptkit.com, vgearstore.com, wogifts.com, 2023jerseyshop.com and bumjersey.com.

Plaintiff's NOTICE of E-Mail Inquiry Received from Defendant by ADIDAS AG, ADIDAS AMERICA, INC., ADIDAS INTERNATIONAL MARKETING B.V.

Exhibit 1 to the Notice of E-mail Inquiry

NOTICE of Striking [24] Notice (Other) filed by ADIDAS INTERNATIONAL MARKETING B.V., ADIDAS AMERICA, INC., ADIDAS AG by ADIDAS AG, ADIDAS AMERICA, INC., ADIDAS INTERNATIONAL MARKETING B.V.

Plaintiff's NOTICE of E-Mail Inquiry Received from Defendant by ADIDAS AG, ADIDAS AMERICA, INC., ADIDAS INTERNATIONAL MARKETING B.V.

Exhibit 1 to the Notice of E-mail Inquiry

PAPERLESS Minute Entry for proceedings held before Judge Rodney Smith: Miscellaneous Hearing held on 5/14/2024, 11:30-11:35am. Preliminary Injunction to be entered. Attorney Appearance(s): Virgilio Gigante, Court Reporter: Patricia Bailey-Entin, 305-523-5635 / Patricia_BaileyEntin@flsd.uscourts.gov.

ORDER GRANTING MOTION FOR ENTRY OF PRELIMINARY INJUNCTION. Signed by Judge Rodney Smith on 5/15/2024. See attached document for full details.

NOTICE of Filing Proposed Summons(es) by ADIDAS AG, ADIDAS AMERICA, INC., ADIDAS INTERNATIONAL MARKETING B.V. re [12] Order on Ex Parte Motion

Summon(s)

Summons Issued as to THE INDIVIDUALS, BUSINESS ENTITIES, AND UNINCORPORATED ASSOCIATIONS IDENTIFIED ON SCHEDULE "A" hereto.

Plaintiff's NOTICE upon Defendants via Electronic Mail by ADIDAS AG, ADIDAS AMERICA, INC., ADIDAS INTERNATIONAL MARKETING B.V. re [28] Preliminary Injunction

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by ADIDAS AG, ADIDAS AMERICA, INC., ADIDAS INTERNATIONAL MARKETING B.V. re [28] Preliminary Injunction upon Defendants via website posting

SUMMONS (Affidavit) Returned Executed on [1] Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by ADIDAS INTERNATIONAL MARKETING B.V., ADIDAS AG, ADIDAS AMERICA, INC. 2023jerseyshop.com served on 5/17/2024, response/answer due 6/7/2024; aajersey.com served on 5/17/2024, response/answer due 6/7/2024; adgsoccer.com served on 5/17/2024, response/answer due 6/7/2024; angeltoheaven.com served on 5/17/2024, response/answer due 6/7/2024; bumjersey.com served on 5/17/2024, response/answer due 6/7/2024; discountbloc.ru served on 5/17/2024, response/answer due 6/7/2024; eletees.com served on 5/17/2024, response/answer due 6/7/2024; ethershirt.org served on 5/17/2024, response/answer due 6/7/2024; fc24shop.com served on 5/17/2024, response/answer due 6/7/2024; fcfshop.com served on 5/17/2024, response/answer due 6/7/2024; gmkits1.com served on 5/17/2024, response/answer due 6/7/2024; gmkits10.com served on 5/17/2024, response/answer due 6/7/2024; gosportszone.com served on 5/17/2024, response/answer due 6/7/2024; ice-jerseys.com served on 5/17/2024, response/answer due 6/7/2024; isoccertime.com served on 5/17/2024, response/answer due 6/7/2024; jerseyio.io served on 5/17/2024, response/answer due 6/7/2024; jerseysell.store served on 5/17/2024, response/answer due 6/7/2024; jshop1.com served on 5/17/2024, response/answer due 6/7/2024; kitsociety.net served on 5/17/2024, response/answer due 6/7/2024; kkgoold.com served on 5/17/2024, response/answer due 6/7/2024; lindajersey.com served on 5/17/2024, response/answer due 6/7/2024; mmjerseys00.com served on 5/17/2024, response/answer due 6/7/2024; nebgift.com served on 5/17/2024, response/answer due 6/7/2024; nebjersey.com served on 5/17/2024, response/answer due 6/7/2024; onlinejersey.life served on 5/17/2024, response/answer due 6/7/2024; socceroliverf042.com served on 5/17/2024, response/answer due 6/7/2024; sptkit.com served on 5/17/2024, response/answer due 6/7/2024; vgearstore.com served on 5/17/2024, response/answer due 6/7/2024; wogifts.com served on 5/17/2024, response/answer due 6/7/2024.

Affidavit of Service

Affidavit of Service

Plaintiff's MOTION for Clerk's Entry of Default as to 2023jerseyshop.com, THE INDIVIDUALS, BUSINESS ENTITIES, AND UNINCORPORATED ASSOCIATIONS IDENTIFIED ON SCHEDULE A, aajersey.com, adgsoccer.com, angeltoheaven.com, bumjersey.com, discountbloc.ru, eletees.com, ethershirt.org, fc24shop.com, fcfshop.com, gmkits1.com, gmkits10.com, gosportszone.com, ice-jerseys.com, isoccertime.com, jerseyio.io, jerseysell.store, jshop1.com, kitsociety.net, kkgoold.com, lindajersey.com, mmjerseys00.com, nebgift.com, nebjersey.com, onlinejersey.life, socceroliverf042.com, sptkit.com, vgearstore.com, wogifts.com by ADIDAS INTERNATIONAL MARKETING B.V., ADIDAS AG, ADIDAS AMERICA, INC.

Exhibit Declaration of Stephen M. Gaffigan in Support of Request for Clerk'

Text of Proposed Order

Clerk's Entry of Default as to Individuals, Business Entities, and Unincorporated Associations identified on Schedule "A" hereto, (collectively "Defendants") - Motions Terminated: [34] Motion for Clerks Entry of Default. Signed by DEPUTY CLERK on 6/13/2024.

Plaintiff's NOTICE of Identification of Additional Alias for Defendant Number 25 and Additional Financial Accounts Used by Defendant Numbers 5, 6, 7, 8, 13, 16, 21, 25, and 26 by ADIDAS AG, ADIDAS AMERICA, INC., ADIDAS INTERNATIONAL MARKETING B.V.

Declaration of Kathleen Burns in Support Thereof

Exhibit 1 to the Declaration of Kathleen Burns

Declaration of Virgilio Gigante in Support Thereof

Plaintiff's NOTICE of Identification of Additional Alias and Additional Financial Account Used by Defendant Number 6 by Adidas AG, Adidas America, Inc., Adidas International Marketing B.V.

Declaration of Kathleen Burns in Support Thereof

Exhibit 1 to the Declaration of Kathleen Burns

Declaration of Virgilio Gigante in Support Thereof

Plaintiff's MOTION for Default Judgment Against Defendants and Memorandum of Law in Support Thereof by Adidas AG, Adidas America, Inc., Adidas International Marketing B.V.

Text of Proposed Order Granting Motion for Default Final Judgment

Text of Proposed Order Granting Default Final Judgment and Permanent Injunction

Declaration of Virgilio Gigante in Support Thereof

Exhibit 1 to the Declaration of Virgilio Gigante

Notice of Ninety Days Expiring by Adidas AG, Adidas America, Inc., Adidas International Marketing B.V. re [38] Plaintiff's MOTION for Default Judgment Against Defendants and Memorandum of Law in Support Thereof filed by Adidas America, Inc., Adidas International Marketing B.V., Adidas AG

ORDER granting 38 Motion for Default Judgment. Case closed. Signed by Judge Rodney Smith on 11/15/2024. See attached document for full details.

Civil Case Terminated. Closing Case. (Text entry; no document attached.)

DEFAULT FINAL JUDGMENT AND PERMANENT INJUNCTION in favor of Adidas AG, Adidas America, Inc., Adidas International Marketing B.V. against The Individuals, Business Entities, and Unincorporated Associations Identified on Schedule A attached. Signed by Judge Rodney Smith on 11/15/2024. See attached document for full details.

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