2023-cv-62191

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. Filing fees $ 402.00 receipt number AFLSDC-17082931, 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 Kathleen M. Williams. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Patrick M. Hunt 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.

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

Complaint with Logs

Clerk's Notice of Docket Correction re 2 Clerks Notice of Judge Assignment. Incorrect District Judge Selected; Corrected by the Clerk. Added District Judge Beth Bloom.

Order Requiring Joint Scheduling Report and Certificates of Interested Parties. Signed by Judge Beth Bloom on 11/17/2023. See attached document for full details.

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

ORDER granting [7] Motion to Seal. Signed by Judge Beth Bloom on 11/21/2023. See attached document for full details.

Notice of Filing Seizure Bond in the amount of $10000.00 posted by ADIDAS AG, ADIDAS AMERICA, INC., ADIDAS INTERNATIONAL MARKETING B.V. Approved by Judge Beth Bloom

Order (Text entry; no document attached.)

Plaintiff's MOTION to Unseal by ADIDAS AG, ADIDAS AMERICA, INC., ADIDAS INTERNATIONAL MARKETING B.V.

Text of Proposed Order

ORDER granting [18] Motion to Unseal. Signed by Judge Beth Bloom on 12/14/2023. See attached document for full details.

NOTICE of Compliance re [19] Order on Motion for Miscellaneous Relief. (All docket entries Unsealed)

AMENDED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants, filed by ADIDAS AG, ADIDAS AMERICA, INC., ADIDAS INTERNATIONAL MARKETING B.V.

Exhibit 1 to Amended Complaint Certificates of Registration for the adidas Trad

NOTICE of Filing Proposed Summons(es) by ADIDAS AG, ADIDAS AMERICA, INC., ADIDAS INTERNATIONAL MARKETING B.V. re [13] Order on Ex Parte Motion

Summon(s)

Clerk's Notice to Filer re: Summons(es) will not be issued. Multiple parties cannot be listed on a single summons. One summons is required for each party. Filer may file a Notice of Filing Proposed Summons(es) with the corrected summons attached.

NOTICE of Filing Proposed Summons(es) by ADIDAS AG, ADIDAS AMERICA, INC., ADIDAS INTERNATIONAL MARKETING B.V. re [13] Order on Ex Parte Motion

Summon(s)

Summons Issued as to The Individuals, Business Entities, and Unincorporated Associations Identified on Schedule A.

Plaintiff's NOTICE by ADIDAS AG, ADIDAS AMERICA, INC., ADIDAS INTERNATIONAL MARKETING B.V. re [5] Order Requiring Joint Scheduling Report, [1] Complaint, [16] Order on Ex Parte Motion, [12] Order on Ex Parte Motion, [17] Sealed Order, Set/Reset Sealed Deadlines/Hearings, upon Defendants via Electronic Mail

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by ADIDAS AG, ADIDAS AMERICA, INC., ADIDAS INTERNATIONAL MARKETING B.V. re [10] 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, [5] Order Requiring Joint Scheduling Report, [1] Complaint, [13] Order on Ex Parte Motion, [11] Sealed Document, [14] Bond, [16] Order on Ex Parte Motion, [15] Plaintiff's EX PARTE MOTION to Extend Temporary Restraining Order and Continue Hearing in Connection with the Motion for Preliminary Injunction, [2] Clerks Notice of Judge Assignment, [9] 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, [12] Order on Ex Parte Motion, [17] Sealed Order, Set/Reset Sealed Deadlines/Hearings, [3] Form AO 120/121, [6] Certificate of Other Affiliates/Corporate Disclosure Statement, [7] Plaintiff's MOTION to Seal per Local Rule 5.4, [8] Order on Motion to Seal upon Defendants via website posting

Plaintiff's NOTICE by ADIDAS AG, ADIDAS AMERICA, INC., ADIDAS INTERNATIONAL MARKETING B.V. of E-Mail Inquiry Received from Defendant Number 2

Exhibit 1 to the Notice of E-mail Inquiry

ORDER GRANTING PLAINTIFFS' MOTIONFOR ENTRY OF PRELIMINARY INJUNCTION. Signed by Judge Beth Bloom on 12/18/2023. See attached document for full details.

PAPERLESS Minute Entry for proceedings held before Judge Beth Bloom: Motion Hearing held on 12/18/2023 re. ECF No. 9, Plaintiff's MOTION for Entry of Preliminary Injunction filed by ADIDAS INTERNATIONAL MARKETING B.V., ADIDAS AMERICA, INC., ADIDAS AG. Total time in court: 10 minutes. Attorney Appearance(s): T. Raquel Wiborg-Rodriguez, Court Reporter: Yvette Hernandez, 305-523-5698 / Yvette_Hernandez@flsd.uscourts.gov.

SUMMONS (Affidavit) Returned Executed on [1] Complaint, [21] Amended Complaint/Amended Notice of Removal, 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. served on 12/14/2023, response/answer due 1/4/2024; 10-13 working days to arrive served on 12/14/2023, response/answer due 1/4/2024; Aditi vyas served on 12/14/2023, response/answer due 1/4/2024; CEUKIJMK served on 12/14/2023, response/answer due 1/4/2024; Football Sportswear Monopoly served on 12/14/2023, response/answer due 1/4/2024; George I served on 12/14/2023, response/answer due 1/4/2024; Highbene served on 12/14/2023, response/answer due 1/4/2024; Hui Cui Center served on 12/14/2023, response/answer due 1/4/2024; JEEKOS 5-15 days delivery served on 12/14/2023, response/answer due 1/4/2024; Jersey Customization served on 12/14/2023, response/answer due 1/4/2024; Pacinoble served on 12/14/2023, response/answer due 1/4/2024; Party supply Co.Ltd served on 12/14/2023, response/answer due 1/4/2024; Rotang served on 12/14/2023, response/answer due 1/4/2024; Victerui served on 12/14/2023, response/answer due 1/4/2024; WJCo.ltd served on 12/14/2023, response/answer due 1/4/2024; YBDL served on 12/14/2023, response/answer due 1/4/2024; wirpofesn served on 12/14/2023, response/answer due 1/4/2024; yaotaomaoyi served on 12/14/2023, response/answer due 1/4/2024; zs-hong0227 served on 12/14/2023, response/answer due 1/4/2024.

Affidavit of Service

Affidavit of Service

Plaintiff's NOTICE upon Defendants via Electronic Mail by ADIDAS AG, ADIDAS AMERICA, INC., ADIDAS INTERNATIONAL MARKETING B.V. re [29] Order

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by ADIDAS AG, ADIDAS AMERICA, INC., ADIDAS INTERNATIONAL MARKETING B.V. re [29] Order upon Defendants via website posting

Plaintiff's MOTION for Clerk's Entry of Default as to 10-13 working days to arrive, Aditi vyas, CEUKIJMK, Football Sportswear Monopoly, George I, Highbene, Hui Cui Center, JEEKOS 5-15 days delivery, Jersey Customization, Pacinoble, Party supply Co.Ltd, Rotang, The Individuals, Business Entities, and Unincorporated Associations Identified on Schedule A, Victerui, WJCo.ltd, YBDL, wirpofesn, yaotaomaoyi, zs-hong0227 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 Defendants in Schedule A. Signed by DEPUTY CLERK on 2/1/2024.

Plaintiff's MOTION for Default Judgment 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 Final Default Judgment

Text of Proposed Order Final Judgment and Permanent Injunction

Declaration of Mia Nidia Gutierrez in Support Thereof

Exhibit 1 to the Declaration of Mia Nidia Gutierrez

Declaration of Virgilio Gigante in Support Thereof

ORDER ON MOTION FOR ENTRY OF FINAL DEFAULT JUDGMENT. ORDER granting [36] Motion for Default Judgment. Accordingly, it is ORDERED AND ADJUDGED that Plaintiffs' Motion, ECF No. [36], is GRANTED against those Defendants listed in the attached Schedule A. Final Default Judgment will be entered by separate order. Signed by Judge Beth Bloom on 2/27/2024. See attached document for full details.

FINAL DEFAULT JUDGMENT AND PERMANENT INJUNCTION. FINAL DEFAULT JUDGMENT 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; in favor of ADIDAS AG, ADIDAS AMERICA, INC., ADIDAS INTERNATIONAL MARKETING B.V. against zs-hong0227, PERMANENT INJUNCTION Closing Case. The Clerk of Court shall RELEASE the bond posted by Plaintiffs in the amount of $10,000.00. The Clerk shall ADMINISTRATIVELY CLOSE the case. Signed by Judge Beth Bloom on 2/27/2024. See attached document for full details.

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

Final Default Judgment

SATISFACTION OF JUDGMENT as to DEFENDANT NUMBERS 13 AND 14 by ADIDAS AG, ADIDAS AMERICA, INC., Adidas International Marketing B.V.