Adidas AG v. 2012jerseyssale.com Complaint

7/31/2019 Adidas AG v. 2012jerseyssale.com Complaint

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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDACASE NO.

ADIDAS AG, ADIDAS INTERNATIONAL

MARKETING B.V., ADIDAS AMERICA, INC.,REEBOK INTERNATIONAL LIMITED,REEBOK INTERNATIONAL LTD., and

SPORTS LICENSED DIVISION OF THE

ADIDAS GROUP, LLC,

Plaintiffs,

vs.

THE PARTNERSHIPS and

UNINCORPORATED ASSOCIATIONS

IDENTIFIED ON SCHEDULE A and

DOES 1-1,000,

Defendants,

/

COMPLAINT FOR INJUNCTIVE RELIEF

Plaintiffs, adidas AG, adidas International Marketing B.V., adidas America, Inc., Reebok

International Limited, Reebok International Ltd., and Sports Licensed Division of the Adidas

Group, LLC (collectively Plaintiffs) hereby sue Defendants the Partnerships or

Unincorporated Associations identified on Schedule A hereto and Does 1-1000 (collectively

Defendants). Defendants are promoting, selling, offering for sale and distributing goods

bearing counterfeits and confusingly similar imitations of Plaintiffs respective trademarks

within this judicial district through various fully interactive Internet websites operating under

their partnership and/or business association names identified on Schedule A hereto (the Subject

Domain Names). In support of their claims, Plaintiffs allege as follows:

JURISDICTION AND VENUE

1. This is an action for federal trademark infringement, counterfeiting, falsedesignation of origin, cybersquatting, common law unfair competition, and common law civil

Case 1:12-cv-22263-PAS Document 1 Entered on FLSD Docket 06/18/2012 Page 1 of 59


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conspiracy pursuant to 15 U.S.C. 1114, 1116, 1121, 1125(a), and 1125(d) and The All Writs

Act, 28 U.S.C. 1651(a). Accordingly, this Court has subject matter jurisdiction under 15 U.S.C.

1121 and 28 U.S.C. 1331 and 1338. This Court has supplemental jurisdiction pursuant to

28 U.S.C. 1367 over Plaintiffs state law claims because those claims are so related to the

federal claims that they form part of the same case or controversy.

2. Defendants are subject to personal jurisdiction in this judicial district because theydirect business activities toward and conduct business with consumers within the State of Florida

and this judicial district through at least the fully interactive Internet websites operating under the

Subject Domain Names.

3. Venue is proper in this Court pursuant to 28 U.S.C. 1391since Defendants are,upon information and belief, aliens who engage in infringing activities and cause harm within

this judicial district. Defendants have also advertised, and, upon information and belief, made

sales and shipped infringing products into this judicial district.

THE PLAINTIFFS

4. Plaintiff adidas AG (adidas AG) is a joint stock company organized andexisting under the laws of the Federal Republic of Germany, having its office and principal place

of business at Postach 1120, D-91072 Herzogenaurach, Federal Republic of Germany. adidas

AG is currently, and for years has been, one of the worlds leading manufacturers of athletic

footwear and apparel, including products bearing the distinctive adidas Mark, Trefoil Mark, and

3 Bars Logo.

5. Plaintiff adidas International Marketing B.V. (adidas International) is acorporation organized and existing under the laws of Netherlands, having its principal place of



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business in the Netherlands. adidas International is wholly owned by adidas AG and its

affiliates.

6. Plaintiff adidas America, Inc. (adidas America) is a corporation organized andexisting under the laws of the State of Delaware, having its principal place of business at 5055 N.

Greeley Avenue, Portland, Oregon, 97217. adidas America is wholly owned by adidas AG and

its affiliates, and within this country adidas America is a licensed distributor of adidas-branded

merchandise, including goods bearing the distinctive adidas Mark, Trefoil Mark, and 3 Bars

Logo. adidas AG, adidas International, and adidas America shall be referred to herein

collectively as adidas.

7. Plaintiff Reebok International Limited (Reebok International) is a corporationorganized and existing under the laws of England, having its principal place of business at 11/12

Pall Mall, London SWI Y 5LU, England. Reebok International is wholly owned by adidas AG

and its affiliates. Reebok International currently is, and for many years has been, one of the

world's leading manufacturers of footwear and sportswear, including products bearing the

Reebok Mark, RBK Mark, and the Vector Mark.

8. Plaintiff Reebok International Ltd. (Reebok Ltd.) is a corporation organized andexisting under the laws of the Commonwealth of Massachusetts, having its principal place of

business at 1895 J.W. Foster Boulevard, Canton, Massachusetts, 02021. Reebok Ltd. is wholly-

owned by adidas AG and its affiliates. Reebok International and Reebok Ltd., and any

predecessors or related entities, shall be collectively referred to herein as Reebok.

9. Plaintiff Sports Licensed Division of the Adidas Group, LLC (SLD) is a limitedliability company organized and existing under the laws of the State of Delaware, having its

principal place of business at 8677 Logo Athletic Ct., Indianapolis, IN 46219.



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10. Like many other famous trademark owners, Plaintiffs suffer ongoing daily andsustained violations of their respective trademark rights at the hands of counterfeiters and

infringers, such as Defendants herein, who wrongfully reproduce and counterfeit Plaintiffs

individual trademarks for the twin purposes of (i) duping and confusing the consuming public

and (ii) earning substantial profits.

11. In order to combat the indivisible harm caused by the combined actions ofDefendants and others engaging in similar conduct, each year Plaintiffs expend significant

amounts of money in connection with trademark enforcement efforts, including legal fees,

investigative fees, and support mechanisms for law enforcement, such as field training, guides

and seminars. The recent explosion of counterfeiting over the Internet has created an

environment which requires companies such as Plaintiffs to file a large number of lawsuits, often

it later turns out, against the same individuals and groups, in order to protect both consumers and

themselves from the ill effects of confusion and the erosion of the goodwill connected to

Plaintiffs respective brands. The financial burden on Plaintiffs and companies similarly situated

is staggering, as is the resulting burden on the Federal court system.

THE DEFENDANTS

12. Defendants are partnerships or unincorporated business associations whichoperate through domain names registered with registrars in multiple countries, and are comprised

of individuals and/or business entities of unknown makeup, all of whom, upon information and

belief, reside in the Peoples Republic of Chinaor other foreign jurisdictions with lax trademark

enforcement systems. Defendants have the capacity to be sued pursuant to Federal Rule of Civil

Procedure 17(b). Defendants conduct pervasive business throughout the United States, including

within this judicial district through the operation of fully interactive commercial websites



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existing under the Subject Domain Names. The partnership or unincorporated association names

used by Defendants are set forth on Schedule A hereto. Plaintiffs are presently unaware of the

true names of Does 1-1,000, although they are generally identified as the owners, operators,

partners, managing agents and/or co-conspirators of the Defendant partnerships or

unincorporated associations operating under the Subject Domain Names. Plaintiffs will amend

this Complaint upon discovery of the identities of such fictitious Defendants.

13. Defendants are part of an ongoing conspiracy to create and maintain an illegalmarketplace enterprise on the World Wide Web, the purposes of which are to (i) confuse

consumers regarding the source of the Defendants goods for profit, and (ii) expand the

marketplace for illegal, counterfeit branded goods while shrinking the legitimate marketplace for

Plaintiffs respective genuine goods. The natural and intended byproduct of Defendants actions

is the erosion and destruction of the overall marketplace in which Plaintiffs operate and the

goodwill associated with the Plaintiffs respective famous names and associated trademarks.

14. Defendants are the past and present controlling forces behind the operation ofcommercial Internet websites operating under at least the Subject Domain Names.

15. Upon information and belief, Defendants directly engage in unfair competitionwith Plaintiffs by (i) offering for sale and selling goods bearing counterfeits and infringements of

each of Plaintiffs individual trademarks to consumers within the United States and this judicial

district through multiple fully interactive commercial websites operating under the Subject

Domain Names and additional domain names not yet known to Plaintiffs and (ii) creating and

maintaining an illegal marketplace enterprise for the purpose of diverting business from

Plaintiffs legitimate marketplace for its genuine goods. Defendants have purposefully directed

some portion of their illegal activities towards consumers in the State of Florida through the



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advertisement, offer to sell, sale, and shipment of counterfeit branded goods into the State, and

by operating an illegal marketplace enterprise which impacts and interferes with commerce

throughout the United States, including within the State of Florida.

16. Defendants have registered, established or purchased, and maintained the SubjectDomain Names. Upon information and belief, Defendants have engaged in fraudulent conduct

with respect to the registration of the Subject Domain Names by providing false and/or

misleading information to their various Registrars during the registration or maintenance process.

Upon information and belief, Defendants have anonymously registered and maintained some of

the Subject Domain Names for the sole purpose of engaging in illegal counterfeiting activities.

17. Upon information and belief, Defendants will continue to register new domainnames for the purpose of selling and/or offering for sale goods bearing counterfeit and

confusingly similar imitations of Plaintiffs respective trademarks unless preliminarily and

permanently enjoined. Moreover, upon information and belief, Defendants and their

coconspirators will continue to maintain and grow their illegal marketplace enterprise at

Plaintiffs expense unless preliminarily and permanently enjoined.

18. Defendants entire Internet-based website businesses and associated marketplaceamount to nothing more than illegal operations established and operated in order to infringe the

intellectual property rights of Plaintiffs and others.

19. Defendants business names, i.e., the Subject Domain Names and any otherdomain names used in connection with the sale of counterfeit and infringing goods bearing

Plaintiffs respective trademarks are essential components of Defendants counterfeiting and

infringing activities and are the means by which Defendants further their counterfeiting scheme

and cause harm to Plaintiffs. Moreover, Defendants are using Plaintiffs respective famous



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names and trademarks to drive Internet consumer traffic to their websites operating under the

Subject Domain Names, thereby increasing the value of the Subject Domain Names and

decreasing the size and value of Plaintiffs legitimate common marketplace at Plaintiffs

expense.

COMMON FACTUAL ALLEGATIONS

adidass Trademark Rights

20. adidas is currently, and for years has been, one of the worlds leadingmanufacturers of athletic footwear, apparel, and sporting equipment. adidas has used its famous

and distinctive adidas Mark, Trefoil Mark and 3 Bars Logo (collectively, the adidas Marks),

depicted below, for more than fifty-five years, thirty-five years, and twenty years, respectively,

in connection with the above-mentioned goods.

The adidas Marks signify the quality and reputation of adidas products.

21. adidas is the owner of multiple trademark registrations for the adidas Marks,including the following valid and incontestable trademark registrations, issued by the United

States Patent and Trademark Office:

TrademarkRegistration

Number

Registration

DateClass / Goods

ADIDAS 0,891,222 May 19, 1970

IC25 - sportswear namely, suits, shorts,

pants, tights, shirts, gloves, and the like;jerseys; socks; sport shoes namely,

track and field training shoes,

basketball shoes, and tennis shoes.

0,973,161November 20,

1973

IC 13 - tote bags

IC 25 - specific purpose athletic shoes;general purpose sport shoes, sports

wear-namely, suits, shorts, pants, tights,

shirts, jerseys, socks, and gloves.



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Number

Registration

DateClass / Goods

1,300,627

October 16,

1984

IC 025 - sportswear namely, suits,

shorts, pants, tights, shirts, jerseys,socks, gloves, jackets, coats, swimwear,

sweaters, caps, pullovers, warm-upsuits, rain suits, ski suits, jump suits,

boots, shoes, slippers.

1,310,140December 18,

1984

IC 025 - sportswear-namely, suits,shorts, pants, tights, shirts, jerseys,

socks, gloves, jackets, coats, swimwear,

sweaters, caps, pullovers, warm-upsuits, rain suits, ski suits, jump suits,

boots, shoes, slippers.

2,138,288February 24,

1998

IC 009 - eyeglasses and sunglasses.

IC 014 - watches and wrist watches.

2,411,802December 12,

2000

IC 018 - all purpose sport bags, athletic

bags, traveling bags, backpacks,knapsacks, beach bags

IC 025 - sports and leisure wear,

namely, shorts, pants, shirts, t-shirts,

jerseys, tights, socks, gloves, jackets,swimwear, caps and hats, pullovers,

sweat-shirts, sweat suits, track suits,

warm-up suits, rain suits; boots,

slippers, sandals, specific purposeathletic shoes and general all purpose

sports shoes

IC 028 - sports balls and playground

balls; guards for athletic use, namely,shin guards, knee guards and leg guards



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Number

Registration

DateClass / Goods

3,104,117 June 13, 2006

IC 009 - optical apparatus and

instruments, namely, eyeglasses andsunglasses

IC 014 - horological and chronometric

instruments, namely, watches

IC 018 - leather and imitations of

leather, and goods made from thesematerials in the nature of bags for

general and sport use, namely

handbags, tote bags, waist packs,overnight bags, backpacks, knapsacks

and beach bags; trunks; traveling bags

for general and sport use; leather and

imitations of leather and goods madefrom these materials, namely, wallets,

briefcases, and key cases

IC 025 - sports and leisure wear,

namely suits, shorts, pants, sweatpants,

skirts, skorts, dresses, blouses, shirts, t-shirts, sleeveless tops, polo shirts, vests,

jerseys, sweaters, sweatshirts,

pullovers, coats, jackets, track suits,training suits, warm-up suits,

swimwear, underwear, socks, gloves,scarves, wristbands and belts; headgear,namely caps, hats, visors, headbands;

athletic footwear and leisure foot wear,

namely boots, sandals, specific purpose

athletic shoes and general purposesports shoes

The adidas Marks are used in conjunction with the manufacture and distribution of high quality

goods in the categories identified above. Copies of the Certificates of Registration for the adidas

Marks are attached at Schedule B.

22. The adidas Marks have been used in interstate commerce to identify anddistinguish adidas products for an extended period of time and serve as symbols of adidass

quality, reputation, and goodwill.



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23. The adidas Marks are well-known and famous and have been for many years.adidas has expended substantial time, money and other resources developing, advertising and

otherwise promoting the adidas Marks. Specifically, adidas has used the adidas Marks in

connection with its frequent sponsorship of sports tournaments and organizations, as well as

professional athletes and collegiate sports teams. For example, adidas has long-term relationships

with Norte Dame, the University of California at Los Angeles, the University of Nebraska, the

University of Michigan, and the University of Tennessee. Among many others, NBA stars

Derrick Rose, Tim Duncan, and Dwight Howard, NFL stars Robert Griffin III, Ryan Tannehill,

Mario Williams, Deion Branch, and Reggie Bush, baseball player Ryan Howard, professional

golfer Sergio Garcia, and soccer stars David Beckman and Lionel Messi all are sponsored by

adidas. For many years, adidas has been a sponsor of the World Cup soccer tournament, has

sponsored the world-famous Boston Marathon for more than a decade, and has sponsored many

other events, teams, and individuals. Prominent use of the adidas Marks in connection with these

sponsorship activities has further enhanced the adidas Marks recognition and fame. The adidas

Marks qualify as famous marks as that term is used in 15 U.S.C. 1125(c)(1).

24. adidas has extensively used, advertised, and promoted the adidas Marks in theUnited States in association with the sale of high quality products. adidas has spent hundreds of

millions of dollars promoting the adidas Marks and products bearing the adidas Marks. In recent

years, annual sales of products bearing the adidas Marks have totaled in the billions of dollars

globally and in the hundreds of millions of dollars within the United States.

25. The adidas Marks have achieved secondary meaning as identifiers of high qualitygoods as a result of adidass advertisement, promotion, and sale of such goods thereunder.



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26. As a result of adidass efforts, members of the consuming public readily identifymerchandise bearing or sold under the adidas Marks, as being high quality merchandise

sponsored and approved by adidas.

27. adidas has carefully monitored and policed the use of the adidas Marks and hasnever assigned or licensed the adidas Marks to any of the Defendants in this matter.

28. Genuine goods bearing the adidas Marks are widely legitimately advertised andpromoted by adidas, authorized distributors and unrelated third parties via the Internet. Over the

course of the past five to seven years, visibility on the Internet, particularly via Internet search

engines such as Google, Yahoo!, and Bing has become increasingly important to adidass overall

marketing and consumer education efforts. Thus, adidas expends significant monetary resources

on Internet marketing and consumer education, including search engine optimization (SEO)

strategies. Those strategies allow adidas and its authorized retailers to fairly and legitimately

educate consumers about the value associated with the adidas Marks and the goods sold

thereunder.

Rebooks Trademark Rights

29. Reebok is currently, and for years has been, one of the worlds leadingmanufacturers of athletic footwear, apparel, and sporting equipment. Reebok has used its

REEBOK Mark, RBK Mark and Vector Mark, depicted below, (collectively, the Reebok

Marks) for more than forty-five and thirty-five years, respectively, in connection with the above

mentioned goods.

The Reebok Marks signify the quality and reputation of Reebok products.



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30. Reebok is the owner of multiple trademark registrations for the Reebok Marks,including the following valid and incontestable trademark registrations, issued by the United

States Patent and Trademark Office:


Number

Registration

DateClass / Goods

REEBOK 1,133,704 April 22, 1980 IC 25 - shoes for use in athletic sports

REEBOK 1,390,793 April 22, 1986

IC 18 - all purpose sport bags

IC 25 - sweatpants, shorts, sweaters,polo shirts, hats, visors, headbands,

sweatbands, t-shirts, sweatshirts

1,848,848 August 9, 1994

IC 018 - all purpose sport bags, duffel

bags, tote bags, knapsacks, and

shoulder bags.

IC 025 - footwear and apparel;namely, t-shirts, shirts, sweatshirts,

sweaters, jackets, hats, visors, socks,

sweatpants, pants, shorts, skirts,unitards, and leotards.



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Number

Registration

DateClass / Goods

RBK 3,074,802 March 28, 2006

IC 09 - eyewear, namely, eyewear

cases; eyewear cleaning cloths;

sunglasses; protective helmets forhockey, and skating.

IC 025 - footwear; headwear; apparel,

namely, sweatpants, sweatshirts,shirts, shorts, sweaters, socks, jackets,

sweat suits, warm-up suits, shooting

shirts, fleece tops, tank tops, poloshirts, pants, athletic bras, leggings,

skirts, turtlenecks, vests, dresses,

athletic uniforms, gloves, infant wear,

running suits.

IC 028 - sports equipment, namely,

basketballs, footballs, rugby balls,

soccer balls, in-line skates, hockey

skates; protective hockey equipment,namely shin pads, elbow pads,

shoulder pads, and pants; protective

in-line skating equipment, namelykneepads and elbow pads.

The Reebok Marks are used in conjunction with the manufacture and distribution of high quality

goods in the categories identified above. Copies of the Certificates of Registration for the

Reebok Marks are attached at Schedule C.

31. The Reebok Mark shave been used in interstate commerce to identify anddistinguish Reebok products for an extended period of time and serve as symbols of Reeboks


32. The Reebok Marks are well-known and famous and have been for many years.Reebok has expended substantial time, money and other resources developing, advertising and

otherwise promoting the Reebok Marks. Specifically, Reebok has used the Reebok Marks in

connection with its frequent sponsorship of sports tournaments and organizations, professional



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athletes, and celebrities/musicians. For example, Reebok presently sponsors football players

Peyton Manning (of the Indianapolis Colts) and Eli Manning (of the New York Giants);

basketball player John Wall (of the Washington Wizards); baseball players David Ortiz and Josh

Beckett (of the Boston Red Sox); hockey player Sidney Crosby (of the Pittsburgh Penguins); and

Formula One racer Lewis Hamilton. The Reebok Marks and Reebok products are further

endorsed by world renown celebrities including platinum producer, artist, and designer Swizz

Beatz. Reebok holds exclusive rights to manufacture and market authentic, replica, and practice

jerseys for the teams of the National Hockey League. The Reebok Marks qualify as famous

marks as that term is used in 15 U.S.C. 1125(c)(1).

33. Reebok has extensively used, advertised and promoted the Reebok Marks in theUnited States in association with the sale of high quality products. Reebok has spent millions of

dollars promoting the Reebok Marks and products bearing the Reebok Marks. In recent years,

Reebok has sold hundreds of millions of dollars of products bearing the Reebok Marks.

34. The Reebok Marks have achieved secondary meaning as identifiers of highquality goods as a result of Reeboks advertisement, promotion and sale of such goods

thereunder.

35. As a result of Reeboks efforts, members of the consuming public readily identifymerchandise bearing or sold under the Reebok Marks, as being high quality merchandise

sponsored and approved by Reebok.36. Reebok has carefully monitored and policed the use of the Reebok Marks and has

never assigned or licensed the Reebok Marks to any of the Defendants in this matter. 37. Genuine goods bearing the Reebok Marks are widely legitimately advertised and

promoted by Reebok, authorized distributors and unrelated third parties via the Internet. Over



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the course of the past five to seven years, visibility on the Internet, particularly via Internet

search engines such as Google, Yahoo!, and Bing has become increasingly important to

Reeboks overall marketing and consumer education efforts. Thus, Reebok expends significant

monetary resources on Internet marketing and consumer education, including search engine

optimization (SEO) strategies. Those strategies allow Reebok and its authorized retailers to

fairly and legitimately educate consumers about the value associated with the Reebok Marks and

the goods sold thereunder.SLDs Trademark Rights38.

SLD is the owner of the following trademark registered on the Principal Register

of the United States Patent and Trademark Office (the Mitchell & Ness Mark):


Number

Registration

DateClass / Goods

MITCHELL &

NESS2,860,283 July 6, 2004

IC 025 - sports jerseys, jackets, shirts,t-shirts, sweaters, caps, hats, head

bands and wrist bands

The Mitchell & Ness Mark is used in conjunction with the manufacture and distribution of high

quality goods in the category identified above. A copy of the Certificate of Registration for the

Mitchell & Ness Mark is attached at Schedule D.

39. The Mitchell & Ness Mark has been used in interstate commerce to identify anddistinguish SLDs products for an extended period of time and serves as a symbol of SLDs


40. The Mitchell & Ness Mark is well-known and famous and has been for manyyears. SLD has expended substantial time, money and other resources developing, advertising

and otherwise promoting the Mitchell & Ness Mark. The Mitchell & Ness Mark qualifies as a

famous mark as that term is used in 15 U.S.C. 1125(c)(1).



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41. SLD has extensively used, advertised, and promoted the Mitchell & Ness Mark inthe United States in association with the sale of high quality products. SLD has spent millions of

dollars promoting the Mitchell & Ness Mark and products bearing the Mitchell & Ness Mark. In

recent years, annual sales of products bearing the Mitchell & Ness Mark have totaled in the

hundreds of millions of dollars.

42. The Mitchell & Ness Mark has achieved secondary meaning as an identifier ofhigh quality goods as a result of SLDs advertisement, promotion, and sale of such goods

thereunder.

43.

As a result of SLDs efforts, members of the consuming public readily identify

merchandise bearing or sold under the Mitchell & Ness Mark, as being high quality merchandise

sponsored and approved by SLD.

44. SLD has carefully monitored and policed the use of the Mitchell & Ness Markand has never assigned or licensed the Mitchell & Ness Mark to any of the Defendants in this

matter.45. Genuine goods bearing the Mitchell & Ness Mark are widely legitimately

advertised and promoted by SLD, authorized distributors and unrelated third parties via the

Internet. Over the course of the past five to seven years, visibility on the Internet, particularly

via Internet search engines such as Google, Yahoo!, and Bing has become increasingly important

to SLDs overall marketing and consumer education efforts. Thus, SLD expends significant

monetary resources on Internet marketing and consumer education, including search engine

optimization (SEO) strategies. Those strategies allow SLD and its authorized retailers to fairly

and legitimately educate consumers about the value associated with the Mitchell & Ness Mark

and the goods sold thereunder.



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Defendants Infringing Activities

46. In blatant disregard of Plaintiffs rights, Defendants are promoting andadvertising, distributing, selling, and/or offering for sale goods in interstate commerce that bear

counterfeit and confusingly similar imitations of the adidas Marks, the Reebok Marks, and the

Mitchell & Ness Mark (collectively, Plaintiffs Marks) including without limitation footwear,

headgear, sport bags, sunglasses, and apparel (collectively, the Counterfeit Goods) through the

fully interactive commercial Internet websites operating under the Subject Domain Names.

Specifically, upon information and belief, Defendants are using identical copies of the Plaintiffs

Marks for different quality goods. Plaintiffs had used their respective Marks extensively and

continuously before Defendants began offering counterfeit and confusingly similar imitations of

Plaintiffs merchandise.

47. Upon information and belief, Defendants Counterfeit Goods are of a qualitysubstantially different than that of Plaintiffs respective genuine goods. Defendants, upon

information and belief, are actively using, promoting and otherwise advertising, distributing,

selling and/or offering for sale substantial quantities of their Counterfeit Goods with the

knowledge and intent that such goods will be mistaken for the genuine high quality goods

offered for sale by Plaintiffs despite Defendants knowledge that they are without authority to

use Plaintiffs Marks. The net effect of Defendants actions will cause confusion of consumers

who will believe Defendants Counterfeit Goods are genuine goods originating from, associated

with, and approved by Plaintiffs.

48. Defendants advertise their Counterfeit Goods for sale to the consuming public viawebsites operating under at least the Subject Domain Names. In so advertising these goods,

Defendants use Plaintiffs Marks without Plaintiffs permission. Indeed, Defendants herein



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misappropriated Plaintiffs advertising ideas and entire styles of doing business with regard to

the advertisement and sale of Plaintiffs respective, genuine goods. Upon information and belief,

the misappropriation of Plaintiffs advertising ideas in the form of Plaintiffs Marks is the

proximate cause of harm to Plaintiffs.

49. As part of their overall infringement and counterfeiting scheme, Defendants are,upon information and belief, all employing substantially similar, and often times coordinated,

paid advertising and SEO strategies based, in large measure, upon an illegal use of counterfeits

and infringements of Plaintiffs Marks. Specifically, Defendants are using counterfeits of

Plaintiffs respective famous names and Plaintiffs Marks in order to make their websites selling

illegal goods appear more relevant and attractive to search engines across an array of search

terms. By their actions, Defendants have created an illegal marketplace operating in parallel to

the legitimate marketplace for Plaintiffs respective, genuine goods. Defendants are causing

concurrent and indivisible harm to Plaintiffs and the consuming public by (i) depriving Plaintiffs

of their right to fairly compete for space within search engine results and reducing the visibility

of Plaintiffs respective, genuine goods on the World Wide Web, (ii) causing an overall

degradation of the value of the goodwill associated with Plaintiffs Marks, (iii) increasing

Plaintiffs overall cost to market their goods and educate consumers about their brands via the

Internet, and (iv) maintaining an illegal marketplace enterprise which perpetuates the ability of

Defendants and future entrants to that marketplace to confuse consumers and harm Plaintiffs

with impunity.

50. Upon information and belief, Defendants are concurrently targeting theircounterfeiting and infringing activities toward consumers and causing harm within this judicial



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district and elsewhere throughout the United States. As a result, Defendants are defrauding

Plaintiffs and the consuming public for Defendants own benefit.

51. Upon information and belief, at all times relevant hereto, Defendants in this actionhad full knowledge of Plaintiffs respective ownership of Plaintiffs Marks, including their

respective, exclusive rights to use and license such intellectual property and the goodwill

associated therewith.

52. Defendants use of Plaintiffs respective Marks, including the promotion andadvertisement, reproduction, distribution, sale and offering for sale of their Counterfeit Goods, is

without Plaintiffs consent or authorization.

53. Further, Defendants are engaging in the above-described illegal counterfeiting andinfringing activities knowingly and intentionally or with reckless disregard or willful blindness to

Plaintiffs rights for the purpose of trading on the respective goodwill and reputations of

Plaintiffs. If Defendants intentional counterfeiting and infringing activities are not preliminarily

and permanently enjoined by this Court, Plaintiffs and the consuming public will continue to be

harmed.

54. Defendants above identified infringing activities are likely to cause confusion,deception, and mistake in the minds of consumers, the public, and the trade before, during, and

after the time of purchase. Moreover, Defendants wrongful conduct is likely to create a false

impression and deceive customers, the public, and the trade into believing there is a connection

or association between Plaintiffs respective genuine goods and Defendants Counterfeit Goods,

which there is not.

55. Moreover, Defendants have registered at least one hundred thirty-six (136) of theSubject Domain Names, using marks which are nearly identical and/or confusingly similar to at



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least one of the adidas Marks, including, 4cheapadidas.com, adidas2cheap.com, adidas2u.com,

adidas4classic.com, adidas4u.com, adidas4usa.com, adidasadicolor.org,

adidasadipower2012.com, adidasbeta.com, adidasbouncestore.com, adidascleatsoutlet.com,

adidascrazylights.com, adidasf50-2012.com, adidasf50-adizero.org,

adidasforjeremyscott.com, adidasjeremylocker.com, adidas--jeremyscott.com,

adidasjeremyscott2.com, adidasjeremyscott2011.com, jeremyscottadidasshoes2012.com,

adidasjeremyscott2012.com, adidasjeremyscottde.com, adidasjeremyscottfr.com,

adidasjeremyscottit.com, adidasjeremyscottjswings.com, adidasjeremyscottobyo.com,

adidasjeremyscottpanda.com, adidasjeremyscotts.net, adidasjeremyscottshoess.com,

adidasjeremyscott-us.com, adidasjs2012.com, adidasjswings2.com, adidasjswingsforsale.com,

adidaswingsoutlet.com, adidasjswingss.net, adidasjswingss.org, adidasjswingssale.com,

adidasjswingsshoes.net, adidasjswingsshop.com, adidasjswingshop.com,

adidasobyojeremyscottmall.com, adidasonlineoutlet.com, adidasoriginalssale.com,

adidasoriginalshome.com, adidasoriginalwings.com, adidasoutlet.biz, adidasoutlet2012.com,

adidasoutletcleats.com, adidas-outlets.com, adidasoutletstores.com, adidas-porsche.com,

adidasporschebounceshoes.com, adidasporschedesign.com, adidas-porsche-design.com,

adidasporschedesignshoes.com, adidasporschedesignshoes.net, adidasporschedesignshoes.org,

adidaspredator.org, adidaspredatorboots.com, adidasscarpeit.com, adidasscarpeit.net,

adidasschoenennl.com, adidasschoenennl.net, adidassfootwear.com, adidas-shoe.com, adidas-

shoes.us, adidasshoes4u.com, adidasshoesdiscount.net, adidasshoesdiy.com, adidasshoes-

go.com, adidasshoesonlinesale.com, adidasshoesuk.com, adidasshopau.com,

adidasshoponline.nl, adidasskooutlet.com, adidasskooutlet.org, adidasskotilbud.com,

adidassoccercleats2012.com, adidassoccercleats-shop.com, adidassoccercleatscheap.com,



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adidassoccershop.com, adidasstarwars.com, adidasstoreitalia.com, adidasswings.com,

adidastoeshoesoutlets.com, adidastoeshoesoutlet.com, adidastopten.com, adidasukoutlet.net,

adidaswings.us, adidaswingsfr.com, adidaswingss.com, adidasy3trainers.com, adidas-js.com,

chaussuredefoot-adidas.com, cheap2adidasrun.com, cheapadidascampus.com,

cheapadidasf50.com, cheapadidasjeremyscott.com, cheapadidasjeremyscottoutlet.com, cheap-

adidasjeremyscottoutlet.com, cheapadidasjeremyscotts.com, cheapadidasnicekicks.com,

cheapadidas-shoes.com, cheapadidasshoescn.com, cheapadidasshoesonline.com,

cheapadidasstore.com, cheapjeremyscottadidas.com, chinaadidasshoes.com, fradidas.com,

fradidas.net, hotadidas.com, jeremymadidasscott.com, jeremyscottadidas.biz, jeremy-scott-

adidas.com, jeremyscottadidas.eu, jeremyscottadidasale.com, jeremyscottadidasde.com,

jeremyscottadidasfr.com, jeremyscottadidashop.net, jeremyscottadidashop.org,

jeremyscottadidasit.com, jeremyscottadidasshoeswings.org, jeremyscottadidassneakers.com,

jeremyscottadidasstore.net, jeremyscottadidas4u.com, jeremyscottbyadidas.net,

jeremyscottsadidas.net, jswingadidas.com, obyojeremyscottadidas.com, onlineadidascleats.com,

saleadidas.com, salejeremyscottadidas.com, shopadidasjeremyscottwings.com,

shopadidasporschedesign.com, and shopsadidas.com (the Infringing adidas Domain Names).

56. Additionally, Defendants have registered at least eightof the Subject DomainNames, which are nearly identical and/or confusingly similar to at least one of the Reebok

Marks, including, buyreebokshoes.com, cheapreebokshoes.us, rbkcustomjerseys.com,

reebokblackhawksjerseys.com, reebokeasytoneshoes.org, reebok-nflstore.com,

reeboknhljersey.com, and reebokshoes-shop.com (the Infringing Reebok Domain Names).

57. Additionally, Defendants have registered at least three of the Subject DomainNames, which are nearly identical and/or confusingly similar to the Mitchell & Ness Mark,



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including, mitchellandness.us, mitchellandnesshats.com, and mitchellandnessshops.com (the

Infringing Mitchell & Ness Domain Names).

58. Upon information and belief, Defendants have registered and/or used theInfringing adidas Domain Names, Infringing Reebok Domain Names, and Infringing Mitchell &

Ness Domain Names (collectively the Infringing Subject Domain Names) with the bad faith

intent to profit from Plaintiffs respective Marks.

59. Defendants do not have, nor have they ever had, the right or authority to usePlaintiffs Marks. Further, Plaintiffs Marks have never been assigned or licensed to be used on

any of the websites operating under the Infringing Subject Domain Names.

60. Upon information and belief, Defendants have provided false and/or misleadingcontact information when applying for the registration of the Infringing Subject Domain Names,

or have intentionally failed to maintain accurate contact information with respect to the

registration of the Infringing Subject Domain Names.

61. Upon information and belief, Defendants have never used any of the InfringingSubject Domain Names in connection with a bona fide offering of goods or services.

62. Upon information and belief, have not made any a bona fide non-commercial orfair use of Plaintiffs Marks on a website accessible under the any of the Infringing Subject

Domain Names.

63. Upon information and belief, Defendants have intentionally incorporatedPlaintiffs respective Marks in their domain names to divert consumers looking for Plaintiffs

respective Internet websites to their own Internet websites for commercial gain.

64. Plaintiffs have no adequate remedy at law.



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65. Plaintiffs are suffering irreparable and indivisible injury and harm as a result ofDefendants unauthorized and wrongful use of Plaintiffs Marks. If Defendants counterfeiting,

infringing, cybersquatting, and unfairly competitive activities and their illegal marketplace

enterprise are not preliminarily and permanently enjoined by this Court, Plaintiffs and the

consuming public will continue to be harmed.

66. The injury and harm sustained by Plaintiffs have been directly and proximatelycaused by Defendants wrongful reproduction, use, advertisement, promotion, offers to sell, and

sale of their Counterfeit Goods and by the creation, maintenance and very existence of the

Defendants illegal marketplace enterprise.

COUNT I - TRADEMARK COUNTERFEITING AND INFRINGEMENT

67. Plaintiffs hereby adopt and re-allege the allegations set forth in Paragraphs 1through 66 above.

68. This is an action for trademark counterfeiting and infringement againstDefendants based on their use of counterfeit and confusingly similar imitations of Plaintiffs

Marks in commerce in connection with the promotion, advertisement, distribution, sale and

offering for sale of the Counterfeit Goods.

69. Defendants are promoting and otherwise advertising, selling, offering for sale,and distributing at least footwear, headgear, sport bags, sunglasses, and apparel, using

counterfeits and infringements of one or more of the adidas Marks. Defendants are continuously

infringing and inducing others to infringe the adidas Marks by using them to advertise, promote

and sell counterfeit and infringing footwear, headgear, sport bags, sunglasses, and apparel.

70. Defendants are promoting and otherwise advertising, selling, offering for sale,and distributing at least footwear and apparel, using counterfeits and infringements of one or



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more of the Reebok Marks. Defendants are continuously infringing and inducing others to

infringe the Reebok Marks by using them to advertise, promote and sell counterfeit and

infringing footwear and apparel.

71. Defendants are promoting and otherwise advertising, selling, offering for sale,and distributing at least headwear and apparel, using counterfeits and infringements of the

Mitchell & Ness Mark. Defendants are continuously infringing and inducing others to infringe

the Mitchell & Ness Mark by using it to advertise, promote and sell counterfeit and infringing

headwear and apparel.

72.

Defendants coordinated, concurrent counterfeiting and infringing activities are

likely to cause and actually are causing confusion, mistake and deception among members of the

trade and the general consuming public as to the origin and quality of Defendants Counterfeit

Goods.

73. Defendants unlawful actions have individually and jointly caused and arecontinuing to cause unquantifiable and irreparable harm to Plaintiffs.

74. Defendants above-described illegal actions constitute counterfeiting andinfringement of Plaintiffs Marks in violation of Plaintiffs respective rights under 32 of the

Lanham Act, 15 U.S.C. 1114.

75. Plaintiffs have each suffered and will continue to suffer irreparable injury due tothe above described activities of Defendants if Defendants are not preliminarily and permanently

enjoined.

COUNT II - FALSE DESIGNATION OF ORIGIN

PURSUANT TO 43(a) OF THE LANHAM ACT




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77. Defendants Counterfeit Goods bearing and sold under copies of Plaintiffs Markshave been widely advertised and distributed throughout the United States.

78. Defendants Counterfeit Goods bearing and sold under copies of Plaintiffs Marksare virtually identical in appearance to each of Plaintiffs respective, genuine goods. However,

Defendants Counterfeit Goods are different and likely inferior in quality. Accordingly,

Defendants activities are likely to cause confusion in the trade and among the general public as

to at least the origin or sponsorship of their Counterfeit Goods.

79. Defendants, upon information and belief, have used in connection with their saleof the Counterfeit Goods, false designations of origin and false descriptions and representations,

including words or other symbols and trade dress which tend to falsely describe or represent such

goods and have caused such goods to enter into commerce with full knowledge of the falsity of

such designations of origin and such descriptions and representations, all to the detriment of

Plaintiffs.

80. Defendants have authorized infringing uses of Plaintiffs Marks in Defendantsadvertisement and promotion of their counterfeit and infringing products. Defendants have

misrepresented to members of the consuming public that the Counterfeit Goods being advertised

and sold by them are genuine, non-infringing goods.

81. Additionally, Defendants are using counterfeits and infringements of PlaintiffsMarks, in order to unfairly compete with Plaintiffs and others for space within search engine

organic results, thereby jointly depriving Plaintiffs of a valuable marketing and educational tool

which would otherwise be available to Plaintiffs and reducing the visibility of Plaintiffs genuine

goods on the World Wide Web.



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82. Defendants above-described actions are in violation of Section 43(a) of theLanham Act, 15 U.S.C. 1125(a).

83. Plaintiffs have each sustained indivisible injury and harm caused by Defendantsconcurrent conduct, and absent an entry of an injunction by this Court, each Plaintiff will

continue to suffer irreparable injury to their respective goodwill and business reputations.

COUNT III - CLAIM FOR RELIEF FOR CYBERSQUATTING

UNDER 43(d) OF THE LANHAM ACTION (15 U.S.C. 1125(d))


85. Upon information and belief, Defendants have acted with the bad faith intent toprofit from the adidas Marks and the goodwill associated with the adidas Marks by registering

the Infringing adidas Domain Names.

86. The adidas Marks were distinctive and famous at the time Defendants registeredthe Infringing adidas Domain Names.

87. The Infringing adidas Domain Names are identical to, confusingly similar to ordilutive of at least one of the adidas Marks.

88. Upon information and belief, Defendants have acted with the bad faith intent toprofit from the Reebok Marks and the goodwill associated with the Reebok Marks by registering

the Infringing Reebok Domain Names.

89. The Reebok Marks were distinctive and famous at the time Defendants registeredthe Infringing Reebok Domain Names.

90. The Infringing Reebok Domain Names are identical to, confusingly similar to ordilutive of at least one of the Reebok Marks.



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91. Upon information and belief, Defendants have acted with the bad faith intent toprofit from the Mitchell & Ness Mark and the goodwill associated with the Mitchell & Ness

Mark by registering the Infringing Mitchell & Ness Mark Domain Names.

92. The Mitchell & Ness Mark was distinctive and famous at the time Defendantsregistered the Infringing Mitchell & Ness Mark Domain Names.

93. The Infringing Mitchell & Ness Mark Domain Names are identical to,confusingly similar to or dilutive of the Mitchell & Ness Mark.

94. Defendants actions constitute cybersquatting in violation of 43(d) of theLanham Act, 15 U.S.C. 1125(d).

95. Plaintiffs have each suffered and will continue to suffer irreparable injury due tothe above described activities of Defendants if Defendants are not preliminarily and permanently

enjoined.

COUNT IV - COMMON LAW UNFAIR COMPETITION


97. This is an action against Defendants based on their (i) manufacture, promotion,advertisement, distribution, sale and/or offering for sale of goods bearing marks which are

virtually identical, both visually and phonetically, to Plaintiffs Marks, and (ii) creation and

maintenance of an illegal, ongoing marketplace enterprise operating in parallel to the legitimate

marketplace in which Plaintiffs sell their respective genuine goods in violation of Floridas

common law of unfair competition.

98. Specifically, Defendants are promoting and otherwise advertising, selling,offering for sale and distributing infringing and counterfeit footwear, headgear, sport bags,



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sunglasses, and apparel. Defendants are also using counterfeits and infringements of Plaintiffs

Marks to unfairly compete with Plaintiffs and others for (1) space in search engine results across

an array of search terms and (2) visibility on the World Wide Web.

99. Defendants infringing activities are likely to cause and actually are causingconfusion, mistake and deception among members of the trade and the general consuming public

as to the origin and quality of Defendants products by their use of Plaintiffs Marks.

100. Plaintiffs have no adequate remedy at law and are suffering irreparable injury as aresult of Defendants' actions.

COUNT V COMMON LAW CIVIL CONSPIRACY


102. Upon information and belief, a conspiracy exists between and among Defendantsand other co-conspirators, to harm Plaintiffs by unlawfully promoting and otherwise advertising,

distributing, selling, and/or offering to sell Defendants Counterfeit Goods bearing marks which

are exact copies or colorable imitations of Plaintiffs Marks in violation of Plaintiffs respective

rights.

103. Specifically, Defendants knowingly agreed to engage, and did engage, in (i) theoffering for sale and sale of counterfeit and infringing adidas-branded goods and Reebok-

branded goods within this judicial district through multiple fully interactive commercial websites

operating under the at least the Subject Domain Names and (ii) creating and maintaining an

illegal marketplace for the purpose of selling non-genuine goods bearing counterfeits of

Plaintiffs Marks on the World Wide Web, thereby diverting business from Plaintiffs legitimate

marketplace for their genuine goods, and confusing consumers.



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104. Plaintiffs have been proximately damaged by the conspiracy and Defendantsactions in furtherance of the conspiracy. Plaintiffs have no adequate remedy at law and are

suffering irreparable injury as a result of Defendants' conduct.

PRAYER FOR RELIEF

105. WHEREFORE, Plaintiffs demand judgment on all Counts of this Complaint andan award of equitable relief against Defendants as follows:

a. Entry of a preliminary and permanent injunction pursuant to Federal Ruleof Procedure 65 enjoining Defendants, their agents, representatives, servants, employees, and all

those acting in concert or participation therewith, from manufacturing or causing to be

manufactured, importing, advertising or promoting, distributing, selling or offering to sell their

Counterfeit Goods; from infringing, counterfeiting, or diluting the adidas Marks, the Reebok

Marks, and/or the Mitchell & Ness Mark; from using the adidas Marks, the Reebok Marks,

and/or the Mitchell & Ness Mark, or any mark or trade dress similar thereto, in connection with

the sale of any unauthorized goods; from using any logo, trade name or trademark or trade dress

which may be calculated to falsely advertise the services or goods of Defendants as being

sponsored by, authorized by, endorsed by, or in any way associated with Plaintiffs; from falsely

representing themselves as being connected with Plaintiffs, through sponsorship or association,

or engaging in any act which is likely to falsely cause members of the trade and/or of the

purchasing public to believe any goods or services of Defendants are in any way endorsed by,

approved by, and/or associated with Plaintiffs; from using any reproduction, counterfeit, copy, or

colorable imitation of the adidas Marks, the Reebok Marks, and/or the Mitchell & Ness Mark in

connection with the publicity, promotion, sale, or advertising of any goods sold by Defendants,

including, without limitation, footwear, headgear, sport bags, sunglasses, and apparel; from



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affixing, applying, annexing or using in connection with the sale of any goods, a false description

or representation, including words or other symbols tending to falsely describe or represent

Defendants goods as being those of Plaintiffs, or in any way endorsed by Plaintiffs and from

offering such goods in commerce; from engaging in search engine optimization strategies using

colorable imitations of Plaintiffs respective name or trademarks and from otherwise unfairly

competing with Plaintiffs.

b. Entry of a preliminary and permanent injunction pursuant to 28 U.S.C1651(a), The All Writs Act, enjoining Defendants and all third parties from creating,

maintaining, operating, joining, participating in, including providing financial, technical or other

support to, the World Wide Web based illegal marketplace conspiracy to market, offer for sale,

sell or distribute non-genuine goods bearing counterfeits of the adidas Marks, the Reebok Marks,

and/or the Mitchell & Ness Mark.

c. Entry of an order requiring the Subject Domain Names, and any otherdomain names being used by Defendants to engage in the business of marketing, offering to sell

and\or selling goods bearing counterfeits and infringements of the adidas Marks, the Reebok

Marks, and/or the Mitchell & Ness Mark be disabled and/or immediately transferred by

Defendants, their Registrars, and/or the Registries to Plaintiffs control.

d. Entry of an Order that, upon Plaintiffs request, the top level domain(TLD) Registry for each of the Subject Domain Names or their administrators place the Subject

Domain Names on Registry Hold status for the remainder of the registration period for any such

domain name, thus removing them from the TLD zone files maintained by the Registries which

link the Subject Domain Names to the IP address where the associated websites are hosted.



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e. Entry of an Order that, upon Plaintiffs request, any Internet searchengines, Web hosts, domain-name registrars and domain-name registries or administrators which

are provided with notice of the injunction, cease facilitating access to any or all websites through

which Defendants engage in promotion, offering for sale and/or sale of goods bearing

counterfeits and/or infringements of the adidas Marks, the Reebok Marks, and/or the Mitchell &

Ness Mark.

f. Entry of an Order that, upon Plaintiffs request, the Internet Corporationfor Assigned Names and Numbers (ICANN) shall take all actions necessary to ensure that the

top level domain Registries or their administrators responsible for the Subject Domain Names

facilitate the transfer and/or disable the Subject Domain Names.

g. Entry of an award of Plaintiffs costs and reasonable attorneys fees andinvestigative fees associated with bringing this action.

h. Entry of an Order for any further relief as the Court may deem just andproper.

DATED: June ___, 2011. Respectfully submitted,

STEPHEN M. GAFFIGAN, P.A.

By: ______s:/smgaffigan/_________________

Stephen M. Gaffigan (Fla. Bar No. 025844)Virgilio Gigante (Fla. Bar No. 082635)

401 East Las Olas Blvd., Suite 130-453

Ft. Lauderdale, Florida 33301

Telephone: (954) 767-4819Facsimile: (954) 767-4821

Email: [email protected]

E-mail:[email protected]

Attorneys for Plaintiffs

mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]


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SCHEDULE A

DEFENDANTS BY NUMBER AND SUBJECT DOMAIN NAMES

Defendant 001: 2012jerseyssale.com

Defendant 002: 2012jerseysusonline.net

Defendant 003: 2012londonsoccer.com

Defendant 004: 2012nbahours.com

Defendant 005: 2012usashopping.com

Defendant 006: 2014nike.com

Defendant 007: 20ce.com

Defendant 008: 30nhljersey.com

Defendant 009: 365golfclubs.com

Defendant 010: 4cheapadidas.com

Defendant 011: 66nhl.com6nhl.com

Defendant 012: 9th-zone.com

Defendant 013: adidas2cheap.com

Defendant 014: adidas2u.com

Defendant 015: adidas4classic.com

Defendant 016: adidas4u.com

Defendant 017: adidas4usa.com

Defendant 018: adidasadicolor.org

Defendant 019: adidasadipower2012.com

Defendant 020: adidasbeta.com

Defendant 021: adidasbouncestore.com

Defendant 022: adidascleatsoutlet.com

Defendant 023: adidascrazylights.com

Defendant 024: adidasf50-2012.com

adidasf50-adizero.org

Defendant 025: adidasforjeremyscott.com

Defendant 026: adidasjeremylocker.comDefendant 027: adidas--jeremyscott.com

Defendant 028: adidasjeremyscott2.com


jeremyscottadidasshoes2012.com


Defendant 031: adidasjeremyscottde.com



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Defendant 032: adidasjeremyscottfr.com

Defendant 033: adidasjeremyscottit.com

Defendant 034: adidasjeremyscottjswings.com

Defendant 035: adidasjeremyscottobyo.com

Defendant 036: adidasjeremyscottpanda.com

Defendant 037: adidasjeremyscotts.net

Defendant 038: adidasjeremyscottshoess.com

Defendant 039: adidasjeremyscott-us.com

Defendant 040: adidasjs2012.com

Defendant 041: adidasjswings2.com

Defendant 042: adidasjswingsforsale.com

adidaswingsoutlet.com

Defendant 043: adidasjswingss.net

adidasjswingss.org

Defendant 044: adidasjswingssale.com

Defendant 045: adidasjswingsshoes.net

Defendant 046: adidasjswingsshop.com

adidasjswingshop.com

Defendant 047: adidasobyojeremyscottmall.com

Defendant 048: adidasonlineoutlet.com

Defendant 049: adidasoriginalssale.com

adidasoriginalshome.com

Defendant 050: adidasoriginalwings.com

Defendant 051: adidasoutlet.biz

Defendant 052: adidasoutlet2012.com

Defendant 053: adidasoutletcleats.com

Defendant 054: adidas-outlets.com

Defendant 055: adidasoutletstores.com

Defendant 056: adidas-porsche.com

Defendant 057: adidasporschebounceshoes.com

Defendant 058: adidasporschedesign.comDefendant 059: adidas-porsche-design.com

Defendant 060: adidasporschedesignshoes.com

Defendant 061: adidasporschedesignshoes.net

adidasporschedesignshoes.org

Defendant 062: adidaspredator.org



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Defendant 063: adidaspredatorboots.com

Defendant 064: adidasscarpeit.com

adidasscarpeit.net

Defendant 065: adidasschoenennl.com

adidasschoenennl.net

Defendant 066: adidassfootwear.com

Defendant 067: adidas-shoe.com

Defendant 068: adidas-shoes.us

Defendant 069: adidasshoes4u.com

Defendant 070: adidasshoesdiscount.net

Defendant 071: adidasshoesdiy.com

Defendant 072: adidasshoes-go.com

Defendant 073: adidasshoesonlinesale.com

Defendant 074: adidasshoesuk.com

Defendant 075: adidasshopau.com

Defendant 076: adidasshoponline.nl

Defendant 077: adidasskooutlet.com

adidasskooutlet.org

Defendant 078: adidasskotilbud.com

Defendant 079: adidassoccercleats2012.comadidassoccercleats-shop.com

adidassoccercleatscheap.com

Defendant 080: adidassoccershop.comDefendant 081: adidasstarwars.com

Defendant 082: adidasstoreitalia.com

Defendant 083: adidasswings.com

Defendant 084: adidastoeshoesoutlets.com

adidastoeshoesoutlet.com

Defendant 085: adidastopten.com

Defendant 086: adidasukoutlet.net

Defendant 087: adidaswings.us

Defendant 088: adidaswingsfr.com

Defendant 089: adidaswingss.com

Defendant 090: adidasy3trainers.com

Defendant 091: adijswingshoes.com

Defendant 092: adistarmall.com

Defendant 093: adistarwars.com



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jeremyscottshoe.com

Defendant 094: adiwingsjs.com

adidas-js.com

Defendant 095: adizerocrazylight.net

Defendant 096: adroitsys.comDefendant 097: adrunningshoes.com

Defendant 098: aeebeecee.com

Defendant 099: airjordanshoper.com

Defendant 100: airmaxsoldes.com

Defendant 101: airmaxs-store.com

Defendant 102: airmaxus.com

airmaxuspascher.com

Defendant 103: animate-shoes.com

Defendant 104: anyjackets.com

Defendant 105: aoleytrade.com

Defendant 106: aol-shoes.com

aol-shoes.net

Defendant 107: apacebuy.com

Defendant 108: authentic-jerseys.org

Defendant 109: authenticsoccerjersey.com

Defendant 110: autobotshop.net

Defendant 111: basketball-gareok.com

Defendant 112: basketball-parkgo.net

Defendant 113: baybaybags.com

Defendant 114: bigbigdiscount.com

Defendant 115: bootfr.com

Defendant 116: botas2futbol.com

Defendant 117: bounceshoessale.com

Defendant 118: brandfansmall.com

Defendant 119: brandmalls.com

Defendant 120: Brandshoes987.comDefendant 121: brandshoesvoid.com

Defendant 122: brands-sunglasses-store.com

Defendant 123: brandtrade09.com

top-worldwholesale.com

Defendant 124: bronpay.com



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Defendant 125: bullsjerseyoutlet.com

Defendant 126: buycheapjordans.net

Defendant 127: buychile62.com

Defendant 128: buyreebokshoes.com

Defendant 129: buyshoes-shop.combuyshoe-shop.com

Defendant 130: buysoccerjerseyscheap.com

buysoccerjerseyscheap.net

Defendant 131: buystoreclothing.com

Defendant 132: camisetas-futbol.info

Defendant 133: camisetasfutbolthai.com

Defendant 134: capshunting.com

Defendant 135: ccvstockshopping.com

ccvstockonline.comDefendant 136: celticsjerseysroom.com

Defendant 137: cg4w.com

Defendant 138: chaussuredefoot-adidas.com

Defendant 139: chaussuresdefootstore.comchaussuresdefootboutiquefr.com

Defendant 140: chaussures-foot-boutique.com

Defendant 141: cheap2adidasrun.com

Defendant 142: cheap86.com

Defendant 143: cheapadidascampus.com

Defendant 144: cheapadidasf50.com

Defendant 145: cheapadidasjeremyscott.com

Defendant 146: cheapadidasjeremyscottoutlet.com

cheap-adidasjeremyscottoutlet.com

Defendant 147: cheapadidasjeremyscotts.com

Defendant 148: cheapadidasnicekicks.com

Defendant 149: cheapadidas-shoes.com

Defendant 150: cheapadidasshoescn.com

Defendant 151: cheapadidasshoesonline.com

Defendant 152: cheapadidasstore.com

Defendant 153: cheapadizerorose.com

Defendant 154: cheapapparel.org

Defendant 155: cheapauthenticjersey.com



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Defendant 156: cheapballjerseys.com

Defendant 157: cheapdiscountshoes.org

Defendant 158: cheaphandbagsaaa.com

Defendant 159: cheapjeremyscottadidas.com

Defendant 160: cheapjerseys4wholesale.com

Defendant 161: cheapnbabasketballjerseys.com

Defendant 162: cheapnbajerseyskey.com

Defendant 163: cheaponlinesneaker.comprettysneaker.com

Defendant 164: cheappursemall.net

Defendant 165: cheapreebokshoes.us

Defendant 166: cheapshoebags.com

Defendant 167: cheapshoesrunner.com

cheapshoesrunners.com

Defendant 168: cheapshopgoods.com

Defendant 169: cheapsoccer4you.com

Defendant 170: cheap-soccercleats.com

socceroutlet.biz

Defendant 171: cheapsoccercleats.eu

Defendant 172: cheapsoccerjerseyssale.netsoccerjerseyonsale.net

Defendant 173: cheapsoccerjerseysstore.com

Defendant 174: cheap-supra-shoes-mall.comcheap-suprashoesshop.com

Defendant 175: chinaadidasshoes.com

Defendant 176: chinajerseysretail.org

Defendant 177: chinastaroutlet.org

chinastaroutlet.net

Defendant 178: chinawholesale114.com

Defendant 179: clearancesoccerjerseys.net

Defendant 180: clearancesoccerjerseys.org

Defendant 181: clothes4cheap.comclothing4cheap.com

Defendant 182: commeleschaussures.com

Defendant 183: cooljerseysoutlet.com

Defendant 184: cs4world.com

Defendant 185: derrickrose2012.com



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Defendant 186: derrickrosenewshoes.com

Defendant 187: derrickroseshoe.org

Defendant 188: designerbagsbiz.com

Defendant 189: discount-cheap.net

discount4cheap.comDefendant 190: discountsoccerclothing.com

Defendant 191: enoft.com

Defendant 192: esneakeroutlet.com

Defendant 193: esoccersshoes.com

Defendant 194: f50adizerocleats.com

Defendant 195: f50-pascher.com

Defendant 196: fantaccy.net

Defendant 197: fcmcs.com

Defendant 198: fcsoccerstore.com

Defendant 199: ffashion.biz

Defendant 200: footballbootsale.com

Defendant 201: footballbootsforsale.org

Defendant 202: footballbootsoutlet.com

Defendant 203: footballchaussuresmagasinfr.com

Defendant 204: fotbalove.com

Defendant 205: fradidas.com

fradidas.netDefendant 206: fussballschuh8.com

Defendant 207: gcheap.com

Defendant 208: golfclubsoutlet4u.com

Defendant 209: google-jerseys.net

Defendant 210: griffin2sneakers.com

Defendant 211: guagon.com

Defendant 212: hatsday.com

Defendant 213: hotadidas.com

Defendant 214: hotfootballjersey.com

Defendant 215: hotsoccercleats.com

Defendant 216: ijeremyscott.com

Defendant 217: indoor-cleats.com

Defendant 218: integrated-soccercleats.com

Defendant 219: itemsclass.com



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Defendant 220: i-topbrand.com

Defendant 221: jeremymadidasscott.com

Defendant 222: jeremyscottadidas.biz

Defendant 223: jeremy-scott-adidas.com

jeremyscottestore.comDefendant 224: jeremyscottadidas.eu

Defendant 225: jeremyscottadidasale.com

Defendant 226: jeremyscottadidasde.com

Defendant 227: jeremyscottadidasfr.com

Defendant 228: jeremyscottadidashop.net

jeremyscottadidashop.org

Defendant 229: jeremyscottadidasit.com

Defendant 230: jeremyscottadidasshoeswings.org

Defendant 231: jeremyscottadidassneakers.com

Defendant 232: jeremyscottadidasstore.netjeremyscottadidas4u.com

Defendant 233: jeremyscottbyadidas.net

Defendant 234: jeremyscottkicks.net

Defendant 235: jeremyscottsadidas.net

Defendant 236: jeremy-scott-shoes.org

Defendant 237: jeremyscottshoesstroe.com

Defendant 238: jeremyscottwings.co.uk

jeremyscottwingshoes.co.uk

Defendant 239: jeremyscottwingssale.com

Defendant 240: jersey101shop.com

Defendant 241: jersey777.com

Defendant 242: jersey-in-china.com

Defendant 243: jerseyscanadian.com

Defendant 244: jerseys-deals.com

Defendant 245: jerseysforcheap.net

Defendant 246: jerseyslife.netDefendant 247: jerseys-pink.com

jerseyspink.com

Defendant 248: jerseystock.com

Defendant 249: jersey-trade.com

Defendant 250: jersey-trainers.com



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Defendant 251: jixuya.com

Defendant 252: jjeremyscott.com

Defendant 253: joesontrade.com

Defendant 254: js-sale.com

Defendant 255: jswingadidas.com

Defendant 256: kengriffeysstore.net

Defendant 257: kickstalk.net

Defendant 258: kidsshoescheap.com

Defendant 259: kuailejiaobu.com

Defendant 260: leaguejerseyroom.com

Defendant 261: lovecleats.com

Defendant 262: loveonlineshop.com

Defendant 263: magliecalcio.org

Defendant 264: maillotsdefoot.com

maillotsdefootfr.com

Defendant 265: mainbelt.com

Defendant 266: mario-shoes.net

Defendant 267: mitchellandness.us

Defendant 268: mitchellandnesshats.com

Defendant 269: mitchellandnessshops.com

Defendant 270: morioshoes.com

Defendant 271: myecstar.comDefendant 272: mygolfshops.net

Defendant 273: nacelook.com

Defendant 274: newage-trade.com

Defendant 275: newfootballshoes.com

Defendant 276: nhljerseys-mall.com

Defendant 277: nikejordanfr.com

Defendant 278: obyojeremyscottadidas.com

Defendant 279: occidenttrade.com

Defendant 280: okaybrands.net

okay-brands.com

Defendant 281: okgoodshoes.com

Defendant 282: onlineadidascleats.com

Defendant 283: onlineshoesbiz.com

Defendant 284: onlineshop-shoes.com



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Defendant 285: onlinestoresmarket.com

Defendant 286: onlinetopseller.com

Defendant 287: outletjerseys.net

Defendant 288: penny2shoes.com

Defendant 289: pickshirts.com

Defendant 290: popsoccerjersey.com

popsoccerjersey.net

Defendant 291: porschedesignshoess.com

Defendant 292: predatorlethalzones.com

Defendant 293: premiernbasale.com

Defendant 294: pro-footballshirt.com

Defendant 295: rbkcustomjerseys.com

Defendant 296: realsoccercleats.com

Defendant 297: reebokblackhawksjerseys.com

Defendant 298: reebokeasytoneshoes.org

Defendant 299: reebok-nflstore.com

Defendant 300: reeboknhljersey.com

Defendant 301: reebokshoes-shop.com

Defendant 302: rosebasketballshoes.com

Defendant 303: roseshoesoutlet2012.com

Defendant 304: saleadidas.com

adishoes.netDefendant 305: salejeremyscottadidas.com

Defendant 306: salesoccercleats.com

Defendant 307: seecheapshop.com

Defendant 308: shoes24sale.com

Defendant 309: shoesbags-wholesale.com

shoesbags4wholesale.com

Defendant 310: shoesclothingchina.com

Defendant 311: shoestopbuy.com

Defendant 312: shopadidasjeremyscottwings.comDefendant 313: shopadidasporschedesign.com

Defendant 314: shopbasketballshoes.com

Defendant 315: shopcheapjerseys.com

Defendant 316: shopsadidas.com

Defendant 317: sneakerulove.com



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Defendant 318: soccercityoutlet.com

Defendant 319: soccercleatscheaper.com

Defendant 320: soccercleatsdigg.comsoccercleatsshopdigg.com

Defendant 321: soccercleatsoutlet.comDefendant 322: soccerfootballpro.com

Defendant 323: soccerjerseybest.com

Defendant 324: soccerjerseyinshop.com

Defendant 325: soccerjerseystosale.net

Defendant 326: soccerjerseyswholesalers.com

soccerjerseyswholesalers.net

Defendant 327: soccer-jerseys-world.com

Defendant 328: soccerjerseywholesale.com

Defendant 329: soccernjstore.comsoccerjerseyshop-online.com

Defendant 330: soccersalestore.com

Defendant 331: soccershoes365shop.com

Defendant 332: soccershoesaler.com

Defendant 333: soccershoesonsale4u.com

Defendant 334: soccershoeswow.com

Defendant 335: soccersuperflycleats.com

Defendant 336: soccersuppliesshop.com

Defendant 337: sportsproshoponline.com

Defendant 338: storesbasketball.com

Defendant 339: storynike.com

Defendant 340: sumshoes.com

Defendant 341: super-wholesalestore.com

Defendant 342: supply-cheapjerseys.com

Defendant 343: takedunk.org

Defendant 344: topsoccershoesonline.com

Defendant 345: uefastores.comDefendant 346: wayfarer-glasses.org

Defendant 347: wholesalebagscn.com

Defendant 348: wholesalebiz.org

Defendant 349: wholesalechinastore.com

Defendant 350: wholesalejerseysbiz.com



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Defendant 351: wholesalepanda.com

Defendant 352: wholesale-plaza.com

Defendant 353: wholesaleqq.com

Defendant 354: wholesaleroutletshop.com

Defendant 355: wholesalesanny.comwholesales-anny.com

Defendant 356: wholesaleshoes-shop.com

online-shoes-shopping.com

Defendant 357: wholesale-shoes-shop.com

Defendant 358: wholesale-soccer.com

Defendant 359: wholesale-soccer-jersey.com

Defendant 360: wholesale-soccer-uniforms.com

Defendant 361: wholesalewholesale.us

Defendant 362: wingjshoe.com

Defendant 363: winort.net

Defendant 364: worldsoccerboots.com

Defendant 365: worldsoccershoesshop.com

Defendant 366: xsoccershop.com

Defendant 367: y3trainerssale.com

Defendant 368: yiwuxiyi.com



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Schedule B



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Schedule C



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58/59

Schedule D



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Adidas AG v. 2012jerseyssale.com Complaint

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Transcript of Adidas AG v. 2012jerseyssale.com Complaint