Olshan Grundman Frome Rosenzweig & Wolosky LLP Safia A. Anand Martin J. Feinberg 744 Broad Street, 16 th Floor Newark, New Jersey 07102 (212) 451-2300 Attorneys for Plaintiff and Michael W.O. Holihan Holihan Law 1101 North Lake Destiny Road, Suite 275 Maitland, FL 32751 (407) 660-8575 Attorneysfor Plaintiff UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY NIKE, INC., Plaintiff, -against- JOHN DOE 1 A/KiA ACE FRAMING INC.; JOHN DOE 2 A/KIA ACL INC.; JOHN DOE 3 AlKiA AL-B BEAUTY & BARBER EQUIPMENT; JOHN DOE 4 A/KIA AL-B BEAUTY & BARBER EQUIPMENT; JOHN DOE 5 A/KiA ATLANTA SHUTTERS; JOHN DOE 6 A/KIA CAMPING WORLD INC.; JOHN DOE 7 A/KIA CARVER INC.; JOHN DOE 8 AlKiA CARVER INC. JOHN DOE 9 A/KIA COMECO INC.; JOHN DOE 10 A/KIA COPETEX INTERNATIONAL INC.; JOHN DOE 11 AlK/A DANIEL K INC.; JOHN DOE 12 AlK/A ELEGANT FURNITURE GROUP INC.; JOHN DOE 13 A/K/A EVERYDAY GROUP LLC; JOHN DOE 14 A/K/A EXTREMOR INTERNATIONAL GROUP; JOHN DOE 15 A/K/A FLORA INTERNATIONAL INC.; JOHN 1 1635870-1 Civil Action No. COMPLAINT Case 2:12-cv-02564-CCC-JAD Document 1 Filed 04/30/12 Page 1 of 23 PageID: 1
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Olshan Grundman Frome Rosenzweig & Wolosky LLPSafia A. AnandMartin J. Feinberg744 Broad Street, 16th FloorNewark, New Jersey 07102(212) 451-2300Attorneys for Plaintiff
and
Michael W.O. HolihanHolihan Law1101 North Lake Destiny Road, Suite 275Maitland, FL 32751(407) 660-8575Attorneys for Plaintiff
UNITED STATES DISTRICT COURTDISTRICT OF NEW JERSEY
NIKE, INC.,
Plaintiff,
-against-
JOHN DOE 1 A/KiA ACE FRAMING INC.;JOHN DOE 2 A/KIA ACL INC.; JOHN DOE 3AlKiA AL-B BEAUTY & BARBEREQUIPMENT; JOHN DOE 4 A/KIA AL-BBEAUTY & BARBER EQUIPMENT; JOHNDOE 5 A/KiA ATLANTA SHUTTERS; JOHNDOE 6 A/KIA CAMPING WORLD INC.; JOHNDOE 7 A/KIA CARVER INC.; JOHN DOE 8AlKiA CARVER INC. JOHN DOE 9 A/KIACOMECO INC.; JOHN DOE 10 A/KIACOPETEX INTERNATIONAL INC.; JOHNDOE 11 AlK/A DANIEL K INC.; JOHN DOE 12AlK/A ELEGANT FURNITURE GROUP INC.;JOHN DOE 13 A/K/A EVERYDAY GROUPLLC; JOHN DOE 14 A/K/A EXTREMORINTERNATIONAL GROUP; JOHN DOE 15A/K/A FLORA INTERNATIONAL INC.; JOHN
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Civil Action No.
COMPLAINT
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DOE 16 A/KJA FURNITlTRE BRANDSINTERNATIONAL; JOHN DOE 17 A/KJAGINA HOSIERY LTD.; JOHN DOE 18 A/KJAGLOBAL LINK LOGISTICS; JOHN DOE 19A/KJA HAMRICK'S INC.; JOHN DOE 20A/KJA HAMRICK'S INC. JOHN DOE 21 A/KJAHYMAN PODRUSNIK CO INC.; JOHN DOE22 A/KJA HYMAN PODRUSNIK CO INC.;JOHN DOE 23 A/KJA INTEGRITY OUTDOORBRANDS LLC; JOHN DOE 24 A/KIAKAYLINE PROCESSING; JOHN DOE 25A/KIA LEGGETT & PLATT, INC.; JOHN DOE26 A/KJA MAESSA INC.; JOHN DOE 27 A/KIAMIKE AND ALLY; JOHN DOE 28 A/KIA NEWYORK CRAFT & SOUVENIR, INC.; JOHNDOE 29 A/KJA NSI INDUSTRIES INC.; JOHNDOE 30 A/KIA PLASTIC ENGINEERING CO.;JOHN DOE 31 A/KIA PORTAGEWORLDWIDE INC.; JOHN DOE 32 A/KJAPOWER FASTNERS INC.; JOHN DOE 33A/K/A PRIME INSTRUMENTS INC.; JOHNDOE 34 A/KJA SIEGEL'S CORPORATE GIFTS& PROMOTION; JOHN DOE 35 A/KJASLENNECKS INC.; JOHN DOE 36 A/KJASNAPCO MANlTFACTURING CO.; and JOHNDOE 37 A/KJA SPLITS 59
Defendants.
COMPLAINT FOR TRADEMARK COUNTERFEITING, TRADEMARKINFRINGEMENT, FALSE DESIGNATION OF ORIGIN AND
VIOLATION OF TARIFF ACT
Plaintiff, Nike, Inc., by its attorneys, Olshan Grundman Frome Rosenzweig &
Wolosky LLP and Holihan Law, allege on knowledge as to its own acts and otherwise on
information and belief as follows:
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NATURE OF THE ACTION
1. This is an action for trademark counterfeiting, trademark infringement, false
designation of origin and violation of the Tariff Act. Plaintiff, Nike, Inc. ("Nike") seeks
expedited discovery, an injunction, damages and related relief.
JURISDICTION AND VENUE
2. The Court has jurisdiction over this matter pursuant to 15 U.S.C. § 1121 and
28 U.S.C. §§ 1331, 1338 and 1367. Plaintiffs claims are predicated upon the Lanham
Trademark Act of 1946, as amended, 15 U.S.C. § 1051, et seq. Venue is properly founded in
this district pursuant to 28 U.S.C. § 1391 (b) and (c).
THE PARTIES
3. Nike is an Oregon corporation and maintains its principal place of business at
One Bowerman Drive, Beaverton, Oregon 97005.
4. Defendant, JOHN DOE 1 AlKlA ACE FRAMING INC. ("Doe #1" or
"Defendants") is an individual who is doing business in New Jersey and this District, who
imported counterfeit shoes bearing unauthorized reproductions, counterfeits, copies and
colorable imitations of Nike's Trademarks through the Port of Newark on or about
November 21, 2010, as depicted in the U.S. Customs and Border Protection seizure notice
attached hereto as Exhibit "A-I". Doe #1 's current address and location is not presently
known.
5. Defendant, JOHN DOE 2 AlK/A ACL INC. ("Doe #2" or "Defendants") is an
individual who is doing business in New Jersey and this District, who imported counterfeit
shoes bearing unauthorized reproductions, counterfeits, copies and colorable imitations of
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Nike's Trademarks through the Port of Newark on or about August 25, 2010, as depicted in
the U.S. Customs and Border Protection seizure notice attached hereto as Exhibit "A-2". Doe
#2' s current address and location is not presently known.
6. Defendant, JOHN DOE 3 A/K/A AL-B BEAUTY & BARBER EQUIPMENT
("Doe #3" or "Defendants") is an individual who is doing business in New Jersey and this
District, who imported counterfeit shoes bearing unauthorized reproductions, counterfeits,
copies and colorable imitations of Nike's Trademarks through the Port of Newark on or
about August 22, 2010, as depicted in the U.S. Customs and Border Protection seizure notice
attached hereto as Exhibit "A-3". Doe #3's current address and location is not presently
known.
7. Defendant, JOHN DOE 4 A/KJA AL-B BEAUTY & BARBER EQUIPMENT
("Doe #4" or "Defendants") is an individual who is doing business in New Jersey and this
District, who imported counterfeit shoes bearing unauthorized reproductions, counterfeits,
copies and colorable imitations of Nike's Trademarks through the Port of Newark on or
about November 30, 2010, as depicted in the U.S. Customs and Border Protection seizure
notice attached hereto as Exhibit "A-4". Doe #4's current address and location is not
presently known.
8. Defendant, JOHN DOE 5 A/K/A ATLANTA SHUTTERS ("Doe #5" or
"Defendants") is an individual who is doing business in New Jersey and this District, who
imported counterfeit shoes bearing unauthorized reproductions, counterfeits, copies and
colorable imitations ofNike's Trademarks through the Port of Newark on or about March 19,
2010, as depicted in the U.S. Customs and Border Protection seizure notice attached hereto
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as Exhibit "A-5". Doe #5's current address and location is not presently known.
9. Defendant, JOHN DOE 6 A/KIA CAMPING WORLD INC. ("Doe #6" or
"Defendants") is an individual who is doing business in New Jersey and this District, who
imported counterfeit shoes bearing unauthorized reproductions, counterfeits, copies and
colorable imitations of Nike's Trademarks through the Port of Newark on or about
November 21, 2010, as depicted in the U.S. Customs and Border Protection seizure notice
attached hereto as Exhibit "A-6". Doe #6's current address and location is not presently
known.
10. Defendant, JOHN DOE 7 A/KIA CARVER INC. ("Doe #7" or "Defendants")
is an individual who is doing business in New Jersey and this District, who imported
counterfeit shoes bearing unauthorized reproductions, counterfeits, copies and colorable
imitations of Nike's Trademarks through the Port of Newark on or about January 27, 2010,
as depicted in the U.S. Customs and Border Protection seizure notice attached hereto as
Exhibit "A-7". Doe #7's current address and location is not presently known.
11. Defendant, JOHN DOE 8 A/KIA CARVER INC. ("Doe #8" or "Defendants")
IS an individual who is doing business in New Jersey and this District, who imported
counterfeit shoes bearing unauthorized reproductions, counterfeits, copies and colorable
imitations ofNike's Trademarks through the Port of Newark on or about March 30, 2010, as
depicted in the U.S. Customs and Border Protection seizure notice attached hereto as Exhibit
"A-8". Doe #8's current address and location is not presently known.
12. Defendant, JOHN DOE 9 AIKJA COMECO INC. ("Doe #9" or "Defendants")
IS an individual who is doing business in New Jersey and this District, who imported
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counterfeit shoes bearing unauthorized reproductions, counterfeits, COpieS and colorable
imitations of Nike's Trademarks through the Port of Newark on or about April 7, 2010, as
depicted in the U.S. Customs and Border Protection seizure notice attached hereto as Exhibit
"A-9". Doe #9's current address and location is not presently known.
13. Defendant, JOHN DOE 10 A/KlA COPETEX INTERNATIONAL INC.
("Doe #10" or "Defendants") is an individual who is doing business in New Jersey and this
District, who imported counterfeit shoes bearing unauthorized reproductions, counterfeits,
copies and colorable imitations of Nike's Trademarks through the Port of Newark on or
about February 11, 2010, as depicted in the U.S. Customs and Border Protection seizure
notice attached hereto as Exhibit "A-I0". Doe #10's current address and location is not
presently known.
14. Defendant, JOHN DOE 11 A/KJA DANIEL K INC. ("Doe #11" or
"Defendants") is an individual who is doing business in New Jersey and this District, who
imported counterfeit shoes bearing unauthorized reproductions, counterfeits, copies and
colorable imitations of Nike's Trademarks through the Port of Newark on or about October
19, 2010, as depicted in the U.S. Customs and Border Protection seizure notice attached
hereto as Exhibit "A-II". Doe #11 's current address and location is not presently known.
15. Defendant, JOHN DOE 12 AIKJA ELEGANT FURNITURE GROlTP INC.
("Doe #12" or "Defendants") is an individual who is doing business in New Jersey and this
District, who imported counterfeit shoes bearing unauthorized reproductions, counterfeits,
copies and colorable imitations of Nike's Trademarks through the Port of Newark on or
about February 6, 2011, as depicted in the U.S. Customs and Border Protection seizure notice
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attached hereto as Exhibit "A-12". Doe #12's current address and location is not presently
known.
16. Defendant, JOHN DOE 13 A/KIA EVERYDAY GROUP LLC ("Doe #13" or
"Defendants") is an individual who is doing business in New Jersey and this District, who
imported counterfeit shoes bearing unauthorized reproductions, counterfeits, copies and
colorable imitations ofNike's Trademarks through the Port of Newark on or about August 8,
2010, as depicted in the U.S. Customs and Border Protection seizure notice attached hereto
as Exhibit "A-13". Doe #13's current address and location is not presently known.
17. Defendant, JOHN DOE 14 AlKJA EXTREMOR INTERNATIONAL GROUP
("Doe #14" or "Defendants") is an individual who is doing business in New Jersey and this
District, who imported counterfeit shoes bearing unauthorized reproductions, counterfeits,
copies and colorable imitations of Nike's Trademarks through the Port of Newark on or
about September 24, 2010, as depicted in the U.S. Customs and Border Protection seizure
notice attached hereto as Exhibit "A-14". Doe #14's current address and location is not
presently known.
18. Defendant, JOHN DOE 15 A/KiA FLORA INTERNATIONAL INC. ("Doe
#15" or "Defendants") is an individual who is doing business in New Jersey and this District,
who imported counterfeit shoes bearing unauthorized reproductions, counterfeits, copies and
colorable imitations ofNike's Trademarks through the Port of Newark on or about April 30,
2010, as depicted in the U.S. Customs and Border Protection seizure notice attached hereto
as Exhibit "A-IS". Doe #15's current address and location is not presently known.
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19. Defendant, JOHN DOE 16 A/KIA FURNITURE BRANDS
INTERNATIONAL ("Doe #16" or "Defendants") is an individual who is doing business in
New Jersey and this District, who imported counterfeit shoes bearing unauthorized
reproductions, counterfeits, copies and colorable imitations of Nike' s Trademarks through
the Port of Newark on or about February 4, 2010, as depicted in the U.S. Customs and
Border Protection seizure notice attached hereto as Exhibit "A-16". Doe #16's current
address and location is not presently known.
20. Defendant, JOHN DOE 17 AlKJA GINA HOSIERY LTD. ("Doe #11" or
"Defendants") is an individual who is doing business in New Jersey and this District, who
imported counterfeit shoes bearing unauthorized reproductions, counterfeits, copies and
colorable imitations of Nike's Trademarks through the Port of Newark on or about
September 27, 2010, as depicted in the U.S. Customs and Border Protection seizure notice
attached hereto as Exhibit "A-IT'. Doe #17's current address and location is not presently
known.
21. Defendant, JOHN DOE 18 AlKiA GLOBAL LINK LOGISTICS ("Doe #18"
or "Defendants") is an individual who is doing business in New Jersey and this District, who
imported counterfeit shoes bearing unauthorized reproductions, counterfeits, copies and
\
colorable imitations of Nike's Trademarks through the Port of Newark on or about April 5,
2010, as depicted in the U.S. Customs and Border Protection seizure notice attached hereto
as Exhibit "A-18". Doe #18's current address and location is not presently known.
22. Defendant, JOHN DOE 19 A/KIA HAMRICK'S INC. ("Doe #19" or
"Defendants") is an individual who is doing business in New Jersey and this District, who
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imported counterfeit shoes bearing unauthorized reproductions, counterfeits, copIes and
colorable imitations of Nike's Trademarks through the Port of Newark on or about
September 27, 2010, as depicted in the U.S. Customs and Border Protection seizure notice
attached hereto as Exhibit "A-19". Doe #19's current address and location is not presently
known.
23. Defendant, JOHN DOE 20 A/KIA HAMRICK'S INC. ("Doe #20" or
"Defendants") is an individual who is doing business in New Jersey and this District, who
imported counterfeit shoes bearing unauthorized reproductions, counterfeits, copies and
colorable imitations ofNike's Trademarks through the Port of Newark on or about April 11,
2010, as depicted in the U.S. Customs and Border Protection seizure notice attached hereto
as Exhibit "A-20". Doe #20's current address and location is not presently known.
24. Defendant, JOHN DOE 21 A/KIA HYMAN PODRUSNIK CO INC. ("Doe
#21" or "Defendants") is an individual who is doing business in New Jersey and this District,
who imported counterfeit shoes bearing unauthorized reproductions, counterfeits, copies and
colorable imitations of Nike's Trademarks through the Port of Newark on or about January
28, 2010, as depicted in the U.S. Customs and Border Protection seizure notice attached
hereto as Exhibit "A-21". Doe #21 's current address and location is not presently known.
25. Defendant, JOHN DOE 22 A/KIA HYMAN PODRUSNIK CO INC. ("Doe
#22" or "Defendants") is an individual who is doing business in New Jersey and this District,
who imported counterfeit shoes bearing unauthorized reproductions, counterfeits, copies and
colorable imitations of Nike's Trademarks through the Port of Newark on or about
September 17, 2010, as depicted in the U.S. Customs and Border Protection seizure notice
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attached hereto as Exhibit "A-22". Doe #22's current address and location is not presently
known.
26. Defendant, JOHN DOE 23 A/KIA INTEGRITY OUTDOOR BRANDS LLC
("Doe #23" or "Defendants") is an individual who is doing business in New Jersey and this
District, who imported counterfeit shoes bearing unauthorized reproductions, counterfeits,
copies and colorable imitations of Nike's Trademarks through the Port of Newark on or
about April 29, 2011, as depicted in the U.S. Customs and Border Protection seizure notice
attached hereto as Exhibit "A-23". Doe #23's current address and location is not presently
known.
27. Defendant, JOHN DOE 24 A/KIA KAYLINE PROCESSING ("Doe #24" or
"Defendants") is an individual who is doing business in New Jersey and this District, who
imported counterfeit shoes bearing unauthorized reproductions, counterfeits, copies and
colorable imitations of Nike's Trademarks through the Port of Newark on or about February
1, 2010, as depicted in the U.S. Customs and Border Protection seizure notice attached hereto
as Exhibit "A-24". Doe #24's current address and location is not presently known.
28. Defendant, JOHN DOE 25 A/KIA LEGGETT & PLATT INC. ("Doe #25" or
"Defendants") is an individual who is doing business in New Jersey and this District, who
imported counterfeit shoes bearing unauthorized reproductions, counterfeits, copies and
colorable imitations of Nike's Trademarks through the Port of Newark on or about February
3,2010, as depicted in the U.S. Customs and Border Protection seizure notice attached hereto
as Exhibit "A-25". Doe #25's current address and location is not presently known.
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29. Defendant, JOHN DOE 26 A/KIA MAESSA INC. ("Doe #26" or
"Defendants") is an individual who is doing business in New Jersey and this District, who
imported counterfeit shoes bearing unauthorized reproductions, counterfeits, copies and
colorable imitations ofNike's Trademarks through the Port of Newark on or about April 23,
2010, as depicted in the U.S. Customs and Border Protection seizure notice attached hereto
as Exhibit "A-26". Doe #26's current address and location is not presently known.
30. Defendant, JOHN DOE 27 A/KJA MIKE AND ALLY ("Doe #27" or
"Defendants") is an individual who is doing business in New Jersey and this District, who
imported counterfeit shoes bearing unauthorized reproductions, counterfeits, copies and
colorable imitations of Nike's Trademarks through the Port of Newark on or about January
14, 2010, as depicted in the U.S. Customs and Border Protection seizure notice attached
hereto as Exhibit "A-27". Doe #27's current address and location is not presently known.
31. Defendant, JOHN DOE 28 A/KIA NEW YORK CRAFT & SOUVENIR INC.
("Doe #28" or "Defendants") is an individual who is doing business in New Jersey and this
District, who imported counterfeit shoes bearing unauthorized reproductions, counterfeits,
copies and colorable imitations of Nike's Trademarks through the Port of Newark on or
about October 1, 2008, as depicted in the U.S. Customs and Border Protection seizure notice
attached hereto as Exhibit "A-28". Doe #28's current address and location is not presently
known.
32. Defendant, JOHN DOE 29 A/KIA NSI INDUSTRIES INC. ("Doe #29" or
"Defendants") is an individual who is doing business in New Jersey and this District, who
imported counterfeit shoes bearing unauthorized reproductions, counterfeits, copies and
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colorable imitations ofNike's Trademarks through the Port of Newark on or about December
28, 2009, as depicted in the U.S. Customs and Border Protection seizure notice attached
hereto as Exhibit "A-29". Doe #29's current address and location is not presently known.
33. Defendant, JOHN DOE 30 A/KIA PLASTIC ENGINEERING CO. ("Doe
#30" or "Defendants") is an individual who is doing business in New Jersey and this District,
who imported counterfeit shoes bearing unauthorized reproductions, counterfeits, copies and
colorable imitations of Nike's Trademarks through the Port of Newark on or about January
27, 2010, as depicted in the U.S. Customs and Border Protection seizure notice attached
hereto as Exhibit "A-30". Doe #30's current address and location is not presently known.
34. Defendant, JOHN DOE 31 A/KIA PORTAGE WORLDWIDE INC. ("Doe
#31" or "Defendants") is an individual who is doing business in New Jersey and this District,
who imported counterfeit shoes bearing unauthorized reproductions, counterfeits, copies and
colorable imitations of Nike's Trademarks through the Port of Newark on or about January
30, 2010, as depicted in the U.S. Customs and Border Protection seizure notice attached
hereto as Exhibit "A-31". Doe #31' s current address and location is not presently known.
35. Defendant, JOHN DOE 32 A/KIA POWER FASTENERS INC. ("Doe #32"
or "Defendants") is an individual who is doing business in New Jersey and this District, who
imported counterfeit shoes bearing unauthorized reproductions, counterfeits, copies and
colorable imitations of Nike's Trademarks through the Port of Newark on or about February
11, 2010, as depicted in the U.S. Customs and Border Protection seizure notice attached
hereto as Exhibit "A-32". Doe #32's current address and location is not presently known.
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36. Defendant, JOHN DOE 33 A/KIA PRIME INSTRlTMENTS INC. ("Doe #33"
or "Defendants") is an individual who is doing business in New Jersey and this District, who
imported counterfeit shoes bearing unauthorized reproductions, counterfeits, copies and
colorable imitations ofNike's Traden1arks through the Port of Newark on or about December
19, 2010, as depicted in the U.S. Customs and Border Protection seizure notice attached
hereto as Exhibit "A-33". Doe #33 's current address and location is not presently known.
37. Defendant, JOHN DOE 34 AIKIA SIEGEL'S CORPORATE GIFTS &
PROMOTION ("Doe #34" or "Defendants") is an individual who is doing business in New
Jersey and this District, who imported counterfeit shoes bearing unauthorized reproductions,
counterfeits, copies and colorable imitations of Nike's Trademarks through the Port of
Newark on or about January 13, 2010, as depicted in the U.S. Custon1S and Border Protection
seizure notice attached hereto as Exhibit "A-34". Doe #34's current address and location is
not presently known.
38. Defendant, JOHN DOE 35 A1K1A SLENNECKS INC. ("Doe #35" or
"Defendants") is an individual who is doing business in New Jersey and this District, who
imported counterfeit shoes bearing unauthorized reproductions, counterfeits, copies and
colorable imitations of Nike's Trademarks through the Port of Newark on or about January
30, 2010, as depicted in the U.S. Customs and Border Protection seizure notice attached
hereto as Exhibit "A-35". Doe #35's current address and location is not presently known.
39. Defendant, JOHN DOE 36 A1K1A SNAPCO MANUFACTURING CO.
("Doe #36" or "Defendants") is an individual who is doing business in New Jersey and this
District, who imported counterfeit shoes bearing unauthorized reproductions, counterfeits,
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copies and colorable imitations of Nike's Trademarks through the Port of Newark on or
about January 20, 2010, as depicted in the U.S. Customs and Border Protection seizure notice
attached hereto as Exhibit "A-36". Doe #36's current address and location is not presently
known.
40. Defendant, JOHN DOE 37 A/KJA SPLITS 59 ("Doe #37" or "Defendants") is
an individual who is doing business in New Jersey and this District, who imported
counterfeit shoes bearing unauthorized reproductions, counterfeits, copies and colorable
imitations of Nike's Trademarks through the Port of Newark on or about February 1,2010,
as depicted in the U.S. Customs and Border Protection seizure notice attached hereto as
Exhibit "A-37". Doe #37's current address and location is not presently known.
41. The Complaint herein will be amended, if appropriate, to include the name or
names of the John Doe individuals and/or entities when such information becomes available.
NlKE'S FAMOUS TRADEMARKS
42. Since 1971, Nike has advertised, offered for sale, and sold footwear and other
related products throughout the United States. Nike's sneakers have been widely advertised,
offered for sale and sold throughout the United States under various distinctive trademarks,
including but not limited to, "NIKE," "NIKE AIR," the distinctive "Swoosh" Design, which
sometimes is used in conjunction with the "NIKE" trademark or the "NIKE AIR" trademark,
THE "AIR JORDAN" trademark, the "Jumpman" Design trademark, the "JUST DO IT"
trademark, and the "AIR FORCE 1" trademark. The Nike trademarks have at all relevant
times been owned by Nike or its predecessor.
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43. As a result of their exclusive and extensive use, the Nike trademarks have
acquired enormous value and recognition in the United States and throughout the world. The
Nike trademarks are well known to the consuming public and trade as identifying and
distinguishing Nike exclusively and uniquely as the source of origin of the high quality
products to which the marks are applied. The Nike trademarks are both inherently distinctive
and famous.
44. The Nike trademarks registered in the United States Patent and Trademark
Office for footwear include the following:
DATE OFMARK DESIGN REGISTRATION NO. ISSUANCE CLASS