IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

DECKERS OUTDOOR CORPORATION, 

 Plaintiff, 

 v. 

DOES 1-100 and DOES 101-500, 

 Defendants. 

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Case No. 12-cv-00377 

 Honorable Ronald A. Guzman 

 Magistrate Sheila M. Finnegan

PLAINTIFF’S MEMORANDUM IN SUPPORT OF ITS MOTION FOR 

ENTRY OF DEFAULT AND FOR ENTRY OF DEFAULT JUDGMENT

 Plaintiff Deckers Outdoor Corporation (“Deckers”) submits the following memorandum 

in support of its Motion for Entry of Default and Entry of Default Judgment under Fed.R.Civ.P. 

55 against the defendants, DOES 1-100, d/b/a the aliases identified on Schedule “A” to Deckers’ 

Complaint (collectively “the Defendants”) based on Deckers’ action for trademark infringement 

and counterfeiting. 

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STATEMENT OF FACTS

 Deckers is famous throughout the United States and elsewhere as a source of high quality 

footwear products, including the UGG® brand of premium sheepskin footwear. Complaint, 

Docket Entry 1 at ¶ 4. Deckers holds registrations for the UGG Trademark (and stylized 

variations) in more than 100 countries around the world including U.S. Trademark Registration 

No. 3,050,925. Id. at ¶ 6. Additional factual assertions regarding Deckers in Paragraphs 4 – 7 

of the Complaint are incorporated herein. Id. at ¶¶ 4 – 7. See also, Adopted Report and 

Recommendation regarding motion by Deckers Outdoor Corporation for preliminary injunction, 

Docket Entries 27, 34 and 36. 

 On information and belief, Defendants are an interrelated group of counterfeiters acting 

in active concert or copying from each other and are knowingly and willfully manufacturing, 

importing, distributing, offering for sale and selling products bearing counterfeit versions of the 

UGG Trademark to Illinois residents. Id. at ¶ 9. Defendants conduct business throughout the 

United States, including within the State of Illinois and this Judicial District, through the 

operation of the fully interactive commercial websites operating under the domain names 

identified in Schedule A attached to the Complaint (collectively the “Defendant Domain 

Names).” Id. Each Defendant targets Illinois residents and has offered to sell, and on 

information and belief, has sold and continues to sell his/her counterfeit products to consumers 

within the State of Illinois. Id. Additional factual assertions regarding Defendants in Paragraphs 

9 – 17 of the Complaint are incorporated herein. Id. at ¶¶ 9 – 17. 

 Deckers filed this action on January 18, 2012, alleging federal trademark infringement 

and counterfeiting (Count I), false designation of origin (Count II), cyberpiracy (Count III) and 

violation of the Illinois Uniform Trade Practices Act (Count IV) and seeks statutory damages and 

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injunctive relief. (Docket Entry 5). On January 27, 2012, the Court granted Deckers’ ex parte 

Application for Entry of a temporary restraining order and subsequently converted it into a 

preliminary injunction. (Docket Entries 14, 20, 30, 34 and 36). 

 On February 28, 2012, this Court entered an Order (Docket Entry 44) permitting Deckers 

to complete service of process to Defendants by (1) sending a copy of the Complaint via 

electronic mail at the e-mail addresses identified in Schedule A to Deckers’ Complaint; (2) 

electronic publication of the Complaint on a website at the Defendant Domain Names which 

have been transferred to Deckers’ control; and (3) publication of sections 1-3 of this Order in 

China Industry & Commerce News or a comparable Chinese based publication in English or in 

mandarin language. The Defendants were properly served by all three methods on or before 

March 2, 2012. (Docket Entry 45). None of the Defendants has entered an appearance or 

otherwise defended this action. (See Declaration of Justin Gaudio (the “Gaudio Declaration”) at 

¶ 2). 

Pursuant to Federal Rule of Civil Procedure 55(b)(2), Deckers now moves this Court for 

an Order entering default and default judgment finding that Defendants are liable on all counts of 

Deckers’ Complaint. Fed.R.Civ.P. 55(b)(2). Deckers further seeks an award of statutory 

damages as authorized by 15 U.S.C. § 1117(c)(2) for willful trademark counterfeiting against 

each of the 100 Defendants1

 in the amount of up to $2,000,000 per Defendant for use of a 

counterfeit UGG Trademark on products sold through each of the Defendant Domain Names and 

statutory damages of up to $100,000 for each of the 1,2282 Defendant Domain Names that 

incorporate Deckers’ UGG Trademark pursuant to 15 U.S.C. §1117(d). Deckers also seeks entry 

of a permanent injunction prohibiting Defendants from selling products containing counterfeit 

 

1

 Deckers is counting each unique registrant e-mail address as a separate Defendant. See Schedule A. 

2

 See Gaudio Declaration at ¶ 3. 

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UGG marks, an Order that domain names used by Defendants to sell products containing 

counterfeit UGG marks be permanantly transferred to Deckers, and that all assets in Defendants’ 

financial accounts operated by PayPal, Inc. be transferred to Deckers. 

ARGUMENT

I. JURISDICTION AND VENUE ARE PROPER IN THIS COURT 

 This Court has original subject matter jurisdiction over the claims in this action pursuant 

to the provisions of the Lanham Act, 15 U.S.C. § 1051 et seq., 28 U.S.C. § 1338(a), (b) and 28 

U.S.C. § 1331. This Court has jurisdiction over the claims in this action that arise under the laws 

of the State of Illinois pursuant to 28 U.S.C. § 1367(a), because the state law claims are so 

related to the federal claims that they form part of the same case or controversy and derive from 

a common nucleus of operative facts. Venue is proper in this Court pursuant 28 U.S.C. § 1391, 

and this Court may properly exercise personal jurisdiction over Defendants since each of the 

Defendants directly targets business activities toward consumers in Illinois and causes harm to 

Deckers’ business within this Judicial District. See Complaint at ¶¶ 2, 4, 8, 9 and 11 – 17; uBID, 

Inc. v. GoDaddy Group, Inc. 623 F.3d 421, 423-424 (7th Cir. 2010) (Without the benefit of an 

evidentiary hearing, the plaintiff bears only the burden of making a prima facie case for personal 

jurisdiction and all of plaintiff's asserted facts should be accepted as true and any factual 

determinations should be resolved in its favor). Through at least the fully interactive commercial 

Internet websites operating under the Defendant Domain Names, each of the Defendants has 

targeted and solicited sales from Illinois residents by operating English language websites that 

offer shipping to Illinois, accept payment in U.S. dollars and, on information and belief, have 

sold counterfeit UGG products to residents of Illinois. As such, personal jurisdiction is proper 

since each of the Defendants is committing tortious acts in Illinois, is engaging in interstate 

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commerce and has wrongfully caused Deckers substantial injury in the State of Illinois. See

Deckers Outdoor Corporation v. Does, 1-55, No. 11 Civ. 10 (N.D. Ill. October 14, 2011). 

II. DECKERS HAS MET THE REQUIREMENTS FOR ENTRY OF DEFAULT

Pursuant to Rule 55(a) of the Federal Rules of Civil Procedure, “when a party against 

whom a judgment for affirmative relief is sought has failed to plead or otherwise defend, and that 

failure is shown by affidavit or otherwise, the clerk must enter the party's default.” Fed.R.Civ.P 

55(a). Deckers filed its Complaint alleging federal trademark infringement and counterfeiting, 

15 U.S.C. §§ 1114 (Count I), false designation of origin, 15 U.S.C. §§ 1125(a) (Count II), 

cyberpiracy, 15 U.S.C. § 1125(d) (Count III) and violation of the Illinois Uniform Trade 

Practices Act, 815 ILCS § 510 (Count IV). (Docket Entry 1). The Defendants were properly 

served on March 2, 2012. (Docket Entry 45). Despite having been served with process, the 

Defendants have ignored these proceedings and failed to plead or otherwise defend this action. 

(Gaudio Declaration at ¶ 2). Upon information and belief, Defendants are not active-duty 

members of the U.S. armed forces. (Id. at ¶ 4). Accordingly, Deckers asks for entry of default 

against Defendants. 

III. DECKERS HAS MET THE REQUIREMENTS FOR ENTRY OF DEFAULT

JUDGMENT

 Rule 55(b)(2) of the Federal Rules of Civil Procedure provides for a court-ordered default 

judgment. A default judgment establishes, as a matter of law, that Defendants are liable to 

Plaintiff on each cause of action alleged in the complaint. United States v. Di Mucci, 879 F.2d 

1488, 1497 (7th Cir. 1989). When the Court determines that a defendant is in default, the factual 

allegations of the Complaint are taken as true and may not be challenged and the defendants are 

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liable as a matter of law as to each cause of action alleged in the complaint. Black v. Lane, 22 

F.3d 1395, 1399 (7th Cir. 1994). 

 As noted above, on March 2, 2012, Deckers served Defendants, more than 21 days have 

passed since Defendants were served, and no answer or other responsive pleading has been filed. 

See Fed.R.Civ.P. 15(1)(3). Accordingly, default judgment is appropriate and Deckers requests 

an award of up to the maximum statutory damages authorized by 15 U.S.C. § 1117(c)(2) for 

willful trademark counterfeiting against each of the 100 Defendants in the amount of up to 

$2,000,000 per Defendant ($200,000,000 total) for use of a counterfeit UGG Trademark on 

products sold through the Defendant Domain Names and up to $100,000 for each of the 1,228 

Defendant Domain Names3

 that incorporate Deckers’ UGG Trademark pursuant to 15 U.S.C. 

§1117(d) ($122,800,000 total). Deckers also seeks entry of a permanent injunction prohibiting 

Defendants from selling products containing counterfeit UGG marks, an order that domain 

names used by Defendants to sell products containing counterfeit UGG marks be permanantly 

transferred to Deckers, and that all assets in Defendants’ financial accounts operated by PayPal, 

Inc. be transferred to Deckers. 

A. Trademark Infringement and Counterfeiting 

 To properly plead a claim of trademark infringement and counterfeiting pursuant to the 

Lanham Act, a plaintiff must allege that (1) its mark is distinctive enough to be worthy of 

protection, (2) Defendants are not authorized to use its mark; and (3) Defendants’ use of its mark 

causes a likelihood of confusion as to the origin or sponsorship of Defendants’ products. See 

Neopost Indus. B.V. v. PFE Int’l Inc., 403 F. Supp. 2d 669, 684 (N.D. Ill. 2005) (citing Bliss 

Salon Day Spa v. Bliss World LLC, 268 F.3d 494, 496-97 (7th Cir.2001)). 

 

3 See Gaudio Declaration at ¶ 3, list of the 1,228 Defendant Domain Names that incorporate the UGG Trademark. 

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 Deckers’ Complaint alleges that its marks are highly distinctive, that Defendants are not 

authorized to use the Deckers marks, and that Defendants’ use of the Deckers marks causes a 

likelihood of confusion. Complaint at ¶¶ 20 and 21. Since the Defendants have failed to respond 

or otherwise plead in this matter, the Court must accept the allegations contained in Deckers’ 

Complaint as true. See Fed.R.Civ.P. 8(b)(6); Am. Taxi Dispatch, Inc., v. Am. Metro Taxi & Limo 

Co., 582 F. Supp. 2d 999, 1004 (N.D. Ill. 2008) (See also Hotel Employees and Rest. Employees 

Int’l Union Welfare Fund v. Billy’s 1870 d/b/a Billy’s Rest., 2004 WL 1879986, *1 (N.D. Ill. 

2004) (“If a party fails to plead or otherwise defend against a claim for affirmative relief in 

accordance with the Federal Rules, that party is in default. Upon entry of default, all factual 

allegations contained within the complaint are deemed admitted.”)) Accordingly, Deckers 

requests entry of judgment with respect to Count 1 for willful infringement of the UGG 

Trademark. 

B. False Designation of Origin 

A plaintiff bringing a false designation of origin claim under 15 U.S.C. § 1125(a) must 

allege: (1) defendants used a false designation of origin, (2) defendants’ use of the products was 

in interstate commerce, and (3) the likelihood that consumers will be confused by defendants’ 

false designation of origin. Web Printing Controls Co., Inc. v. Oxy-Dry Corp., 906 F.2d 1202, 

1204 (7th Cir. 1990). The test to be used in determining whether a violation has occurred is 

whether “the evidence indicates a likelihood of confusion, deception or mistake on the part of the 

consuming public.” Id. at 1205. This is the same test that is used for bringing a trademark 

infringement claim under the Lanham Act. See Neopost Indus. B.V. v. PFE Int’l Inc., 403 F. 

Supp. 2d 669, 684 (N.D. Ill. 2005). 

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Deckers alleges in its Complaint that Defendants’ counterfeit products are the same 

nature and type, and look virtually identical to Deckers’ UGG products, but Defendants’ 

counterfeit products are not of the same quality as Deckers’ UGG products. As such, this creates 

a likelihood of confusion, mistake, and deception among the general public as to the affiliation or 

sponsorship of Defendants’ counterfeit products with Deckers’ genuine UGG products. 

Complaint at ¶ 26. Furthermore, by using a counterfeit of Deckers’ UGG Trademark on the 

counterfeit products, Defendants create a false designation of origin and a misleading 

representation of fact as to the origin and sponsorship of the counterfeit products. Id. at ¶ 27. As 

such, Deckers requests entry of judgment with respect to Count 2 for willful false designation of 

origin. 

C. Cybersquatting 

In order to state a claim under the Anticybersquatting Consumer Protection Act, a 

plaintiff must allege that (1) it had a distinctive or famous mark at the time the domain names 

were registered, (2) the defendants registered, trafficked in, or used domain names that are 

identical or confusingly similar to plaintiff's mark, and (3) the defendants had a bad faith intent 

to profit from that mark. 15 U.S.C. § 1125(D)(1)(a); see also Vulcan Golf, LLC v. Google, Inc., 

552 F. Supp. 2d 752, 763 (N.D. Ill. 2008). 

 Deckers’ Complaint alleges that Deckers owns the exclusive rights to the UGG 

Trademark, which is in full force and effect, and is a famous mark pursuant to 15 U.S.C. § 1125. 

Complaint at ¶ 31. Deckers further alleges that Defendants have acted with the bad faith intent 

to profit from the UGG Trademark and the goodwill associated with the UGG Trademark by 

registering domain names that are identical or confusingly similar to or dilutive of the UGG 

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Trademark. Id. at ¶ 32. As such, Deckers requests entry of judgment with respect to Count 3 for 

willful cybersquatting. 

D. Violation of the Illinois Uniform Deceptive Trade Practices Act 

 In Illinois, courts resolve unfair competition and deceptive trade practices claims 

“according to the principles set forth in the Lanham Act.” Spex, Inc. v. The Joy of Spex, Inc., 847 

F. Supp. 567, 579 (N.D. Ill. 1994). Illinois courts look to federal case law and apply the same 

analysis to state infringement claims. Spex, 847 F. Supp. at 579 (citing Thompson v. SpringGreen Lawn Care Corp., 126 Ill. App. 3d 99, 104-105 (Ill. App. Ct. 1984)). As such, the 

determination as to whether there is a likelihood of confusion under the Illinois Uniform 

Deceptive Trade Practices Act is similar to the Latham Act analysis. Am. Broad. Co. v. Maljack 

Prod., Inc., 34 F. Supp. 2d 665, 681 (N.D. Ill. 1998). 

Deckers alleged in its Complaint that Defendants have engaged in acts violating Illinois 

law including, but not limited to, passing off their products as those of Deckers, causing a 

likelihood of confusion and/or misunderstanding as to the source of their goods, causing a 

likelihood of confusion and/or misunderstanding as to affiliation, connection, or association with 

Deckers’ products, representing that their products have Deckers’ approval when they do not, 

and engaging in other conduct which creates a likelihood of confusion or misunderstanding 

among the public. Complaint at ¶ 37. Deckers requests entry of judgment with respect to Count 

4 for willful violation of the Illinois Uniform Deceptive Trade Practices Act. 

IV. DECKERS IS ENTITLED TO MONETARY AND INJUNCTIVE RELIEF

 Pursuant to Rule 55(b)(2), Plaintiff requests statutory damages under 15 U.S.C. §1117 

and injunctive relief as specified below and in the separately submitted Proposed Order. 

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A. The Court Should Award the Maximum Statutory Damages Permitted Under 

the Lanham Act for Defendants’ Willful Trademark Counterfeiting 

 As discussed above, Defendants willfully infringed Deckers’ UGG Trademark by selling, 

offering for sale, and distributing products bearing counterfeit UGG trademarks. Such 

willfulness is further established by Defendants’ failure to respond to these proceedings. Under 

the Lanham Act, Deckers moves for statutory damages for willful trademark counterfeiting in an 

amount up to $2,000,000 for each use of a counterfeit mark from each of the 101 Defendants. 15 

U.S.C. § 1117(c)(2). Deckers also moves for statutory damages pursuant to 15 U.S.C. § 1117(d) 

on the grounds that Defendants violated Section 43(d) of the Lanham Act, 15 U.S.C. §1125(d). 

As such, Deckers seeks statutory damages of up to $100,000 for each of the 1,228 Defendant 

Domain Names that incorporate Deckers’ UGG Trademark. 

 “Willful infringement may be attributed to the defendant's actions where he had 

knowledge that his conduct constituted infringement or where he showed a reckless disregard for 

the owner's rights.” Lorillard Tobacco Co. v. S&M Cent. Service Corp., 2004 WL 2534378, *7 

(N.D. Ill. 2004). As such, knowledge need not be proven directly, but can be inferred from a 

defendant's conduct. Id. Willful infringement may be shown by the fact that the “defendant 

ignored the plaintiff's notices ..., did not seek advice of an attorney, and passed the matter off as a 

nuisance.” Id. Moreover, the Seventh Circuit has long held that willful blindness is a sufficient 

basis for a finding of violation of the Lanham Act. Hard Rock Café Licensing Corp. v. 

Concession Serv., Inc., 955 F.2d 1143, 1148 (7th Cir. 1992) (citing Louis Vuitton S.A. v. Lee, 875 

F.2d 584, 590 (7th Cir. 1989)). In addition, district courts have deemed infringement willful 

when defendants default. See Deckers Outdoor Corporation v. Does, 1-55, No. 11 Civ. 10 (N.D. 

Ill. October 14, 2011); The Gen. Council of the Assemblies of God v. The Ranger Supply Store, 

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Inc. et al., No. 10-cv-07050 (N.D. Ill June 29, 2011); see also Tiffany (NJ) Inc. v. Luban, 282 F. 

Supp. 2d 123, 124 (S.D.N.Y. 2003). 

 The awarding of statutory damages serves dual interests in that it is remedial in nature, 

but also intended to protect an important public interest. As such, the remedy imposed under 

statute must provide sufficient deterrent effect to ensure that the guilty party will not engage in 

further infringing conduct. Sands, Taylor & Wood v. The Quaker Oats Co., 34 F.3d 1340, 1348 

(7th Cir. 1994). Statutory damages are appropriate to “penalize the infringer and deter future 

violations” when the infringement is willful. Lorillard Tobacco Co., 2004 WL 2534378 at *4 

(quoting Chi-Boy Music v. Charlie Club, Inc., 930 F.2d 1224, 1230 (7th Cir. 1991)). 

 Courts have wide latitude in awarding statutory damages and have granted other plaintiffs 

significant statutory damages including up to the maximum statutory amount in similar actions 

against Internet-based counterfeiters. See, e.g., Deckers Outdoor Corporation v. Does, 1-55, No. 

11 Civ. 10 (N.D. Ill. October 14, 2011) (awarding $43,750,000 in statutory damages); The Gen. 

Council of the Assemblies of God v. The Ranger Supply Store, Inc. et al., No. 10 Civ. 07050 

(N.D. Ill June 29, 2011) (awarding $4,500,000 in statutory damages); Tory Burch, LLC., et al. v. 

Yong Sheng Int’l Trade Co., LTD, No. 10 Civ. 9336 (S.D.N.Y. May 13, 2011) (awarding 

$164,000,000 in statutory damages); Farouk Systems, Inc. v. Eyou Int’l Trading Company, Ltd., 

et al., No. 10 Civ. 2672 (S.D. Tex. Oct. 14, 2010) (awarding $300,000,000 in statutory 

damages); The North Face Apparel Corp. and PRL USA Holdings, Inc. v. Fujian Sharing Import 

& Export Ltd., Co. d/b/a b2bsharing.com, No. 10 Civ. 1630 (S.D.N.Y. Sept. 8, 2010) (awarding 

$78,000,000 in statutory damages); Gucci Am., Inc. v. Curveal Fashion, No. 09 Civ. 8458 

(S.D.N.Y. Jan. 20, 2010) (awarding $13,500,000 in statutory damages). 

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 Deckers respectfully requests entry of judgment against each of the 101 Defendants in the 

amount of up to $2,000,000 ($200,000,000 total) for use of a counterfeit UGG trademark on 

products sold though websites linked to the Defendant Domain Names and up to $100,000 for 

each of the 1,228 Defendant Domain Names that incorporate Deckers’ UGG Trademark 

($122,800,000 total). Deckers submits that in light of the Defendants’ extensive counterfeiting 

activities which generated and continue to generate massive profits, as well as their efforts to 

conceal their identities and failure to appear in this action to answer for their infringing conduct, 

the amount of statutory damages sought is appropriate. Further, a statutory award in the amount 

sought by Deckers is essential to creating a deterrent to both these Defendants and to future 

counterfeiters. 

B. Deckers is Entitled to Permanent Injunctive Relief 

In addition to the foregoing relief, Deckers respectfully requests entry of a permanent 

injunction enjoining Defendants from infringing or otherwise violating Deckers’ registered 

trademark rights in the UGG mark, including at least all injunctive relief previously awarded by 

this Court to Deckers in the temporary restraining order and preliminary injunction. 

CONCLUSION

 Deckers respectfully requests that the Court enter default and default judgment against 

each Defendant, awarding statutory damages in the amount up to $200,000,000 pursuant to 15 

U.S.C. § 1117(c) and up to $122,800,000 pursuant to 15 U.S.C. 1117(d), entry of a permanent 

injunction prohibiting Defendants from selling products bearing a counterfeit UGG mark, an 

order that domain names used by Defendants to sell products bearing a counterfeit UGG mark be 

permanently transferred to Deckers and that all assets in Defendants’ financial accounts operated 

by PayPal, Inc. be transferred to Deckers. 

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Dated this 26th day of March 2012. 

Respectfully submitted, 

__/s/ Justin R. Gaudio_______________

Kevin W. Guynn 

Amy Ziegler 

Justin R. Gaudio 

Greer, Burns & Crain, Ltd. 

300 South Wacker Drive 

Suite 2500 

Chicago, Illinois 60606 

312.360.0080 

312.360.9315 (facsimile) 

jgaudio@gbclaw.net 

kguynn@gbclaw.net 

aziegler@gbclaw.net 

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CERTIFICATE OF SERVICE

 I hereby certify that on the 26th day of March, 2012, I will electronically file the 

foregoing with the Clerk of the Court, using the CM/ECF system and that I will e-mail the 

documents to all Defendants at the e-mail addresses identified in Schedule A to Deckers’ 

Complaint. 

 

Greer, Burns & Crain Ltd. 

Attorneys for Plaintiff Deckers, 

__/s/ Justin R. Gaudio_______________

Kevin W. Guynn 

Amy Ziegler 

Justin R. Gaudio 

Greer, Burns & Crain, Ltd. 

300 South Wacker Drive 

Suite 2500 

Chicago, Illinois 60606 

312.360.0080 

312.360.9315 (facsimile) 

jgaudio@gbclaw.net 

kguynn@gbclaw.net 

aziegler@gbclaw.net 

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