UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 

ADIDAS AG, ADIDAS INTERNATIONAL MARKETING B.V., and

ADIDAS AMERICA, INC.,

Plaintiffs,

vs.

ADIDAS--AUSTRALIA.COM a/k/a ADIDASBUDAPEST.COM a/k/a 

ADIDAS-BUDAPEST.COM a/k/a ADIDAS-COLOMBIA.COM a/k/a 

ADIDAS-DANMARK.COM a/k/a ADIDAS-EGYPT.COM a/k/a 

ADIDASFACTORYOUTLETUK.COM a/k/a 

ADIDASGREECEGR.COM a/k/a ADIDASGUATEMALA.COM a/k/a 

ADIDASHONDURAS.COM a/k/a ADIDASHRVATSKAHR.COM 

a/k/a ADIDASHU.TOP a/k/a ADIDAS-HUNGARY.COM a/k/a 

ADIDASHUNGARYAKCIOS.COM a/k/a 

ADIDASINROMANIA.COM a/k/a ADIDASINSVERIGE.COM a/k/a 

ADIDAS--IRELAND.COM a/k/a ADIDASITALIASCONTI.COM 

a/k/a ADIDASKSA.COM a/k/a ADIDASLOVENSKOSK.COM a/k/a 

ADIDASMAGYARORSZAG.COM a/k/a 

ADIDASMARIMEKKOSUOMI.COM a/k/a ADIDASMAROC.COM 

a/k/a ADIDASNICARAGUA.COM a/k/a 

ADIDASNMDROMANIA.TOP a/k/a ADIDASNZ-SALE.COM a/k/a 

ADIDASONLINEROMANIA.COM a/k/a ADIDASOUTLETMX.COM 

a/k/a ADIDAS-OUTLETNZ.COM a/k/a ADIDASOUTLETTR.COM 

a/k/a ADIDASPAKISTAN.COM a/k/a ADIDASPANAMA.COM a/k/a 

ADIDASPOLSKAPL.COM a/k/a ADIDAS-REDUCERI.COM a/k/a 

ADIDASROMANIA.BIZ a/k/a ADIDAS--ROMANIA.COM a/k/a 

ADIDASROMONLINESHOP.COM a/k/a ADIDAS--SCHWEIZ.COM 

a/k/a ADIDASSHOESGR.COM a/k/a ADIDASSHOESGREECE.COM 

a/k/a ADIDAS-SHOES-NZ.COM a/k/a ADIDASSKONORGE.COM 

a/k/a ADIDASSLEVACZ.COM a/k/a ADIDASSROMANIA.COM 

a/k/a ADIDASYEEZYSHOESUK.COM a/k/a ECUADORADIDAS.COM a/k/a OSTERREICH-ADIDAS.COM a/k/a PERUADIDAS.COM a/k/a SVERIGE-ADIDAS.COM, ADIDAS1949.CLUB 

a/k/a ADIDAS1949.ONLINE a/k/a ADIDAS1949.TOP a/k/a 

ADIDAS1984.FUN a/k/a ADIDASAIR.TOP a/k/a ADIDASALE.FUN 

a/k/a ADIDASFUN.SHOP a/k/a ADIDASFUN.TOP a/k/a 

ADIDASNEAKER.CLUB a/k/a ADIDASNEAKER.SHOP a/k/a 

ADIDASSALE.TOP a/k/a ADIDAS-SERIES.TOP a/k/a ADIDASSHOPPING.CLUB a/k/a ADIDAS-TRIBAL.CLUB a/k/a ADIDASTRIBAL.TOP a/k/a ADIDASTUNR.CLUB a/k/a 

NEOADIDAS.SPACE a/k/a ONADIDAS.TOP a/k/a 

SUPERADIDAS.SHOP a/k/a TTADIDAS.COM a/k/a 

Case 0:22-cv-61683-RS Document 1 Entered on FLSD Docket 09/08/2022 Page 1 of 32
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USADIDASRUN.SHOP, ADIDASALES.TOP a/k/a 

ADIDASNEAKERS.SHOP a/k/a ADIDASOUTLET.TOP a/k/a 

ADIDASRUN1949.TOP a/k/a ADIDAS-RUNNER.SHOP a/k/a 

ADIDASSALES.TOP a/k/a ADIDASSNEAKERS.TOP a/k/a 

USADIDAS.CLUB a/k/a USADIDAS-RUN.ONLINE a/k/a 

USADIDAS-SPORT.ONLINE, ADIDAS-BELGIE.COM, 

ADIDASBUTYPL.COM a/k/a 

ADIDASFACTORYOUTLETSINGAPORE.COM a/k/a ADIDAS--

MALAYSIA.COM a/k/a ADIDASNORGEOUTLET.COM a/k/a 

ADIDAS-PHILIPPINES.COM a/k/a ADIDASSCHUHEAT.COM, 

ADIDAS--CANADA.COM a/k/a ADIDASENCOSTARICA.COM 

a/k/a ADIDASFACTORYOUTLET.COM a/k/a 

ADIDASHOESCANADA.COM a/k/a ADIDASIRELANDIE.COM 

a/k/a ADIDASNZ.COM a/k/a ADIDASONLINEHRVATSKA.COM 

a/k/a ADIDASOUTLETWOODMEAD.COM a/k/a ADIDASSINGAPORE.COM a/k/a CANADAADIDAS.COM, 

ADIDASHOEJP.COM, ADIDASOUTLETNL.COM, 

ADIDASPOWER.TOP, ADIDASSHOESALEFR.COM, 

ADIDASYEEZYOUTLET.ORG a/k/a ADIDASYEEZYOUTLET.US 

a/k/a FAKEYEEZYS.US a/k/a SLINEXON.COM a/k/a 

YEEZYOUTLET.US a/k/a YEEZYS-350.COM a/k/a 

YEEZYSSLIDES.COM a/k/a YEEZY-STORE.COM a/k/a 

YEEZYV2.COM a/k/a YEEZYV2SALES.ORG, ADIDASYEEZYS.COM a/k/a ADIDASYEEZYSHOES.US a/k/a ADIDASYEEZY-SHOES.US a/k/a ADIDASYEEZYSSHOES.COM a/k/a 

CHEAPYEEZYSUPPLY.COM a/k/a YEEZYFOAMRUNNER.US 

a/k/a YEEZYSHOESS.NET a/k/a YEEZY-SLIDES.COM a/k/a 

YEEZYSLIDES.NET a/k/a YEEZY-SLIDES.US a/k/a 

YEEZYSLIDESHOE.COM a/k/a YEEZY-SLIDESS.COM a/k/a 

YEEZY-SLIDESUS.COM a/k/a YEEZY-SLIDES-US.COM a/k/a 

YEEZYSLIDESUS.NET a/k/a YEEZYSLIDESUS.US a/k/a 

YEEZYSLIDES-US.US a/k/a YEEZY-SLIDESUS.US a/k/a YEEZYSLIDES-US.US a/k/a YEEZYSSHOESS.COM a/k/a YEEZYSSLIDES.COM a/k/a YEEZYSSLIDES.US a/k/a YEEZY-SUPPLY.NET 

a/k/a YEEZYSUPPLYS.US a/k/a YEEZY-SUPPLYS.US a/k/a 

YEEZYSUPPLYSHOES.COM, ADIDASYEEZYS.ORG, 

ADIDASYEEZYSHOE.COM a/k/a ADIDASYEEZYUS.COM a/k/a 

YEEZY350BOOST-V2.US a/k/a YEEZYBOOST350.ORG a/k/a 

YEEZYSSHOES.US, BOOSTYEEZY.US a/k/a 

FABIOYEEZYS.CHEAP a/k/a REALCHEAPYEEZYS.COM a/k/a 

SHOPCHEAPSHOES.COM a/k/a YEEZYSV2.US, 

WOMENSADIDAS.XYZ, AMANDA888.COM, ANSHOES.STORE, 

APAIROFWALK.COM a/k/a DAILYSCHOENEN.COM a/k/a 

FAMOUSLINESHOE.COM, BUYARRIVE.COM, 

CHEAPCHINAJERSEYS.ORG a/k/a JERSEYSFATORY.COM a/k/a 

OFFICIALONLINESTORE.CO a/k/a VIPSPORTSUNIFORMS.COM 

Case 0:22-cv-61683-RS Document 1 Entered on FLSD Docket 09/08/2022 Page 2 of 32
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a/k/a WHOLESALEFLJERSEYSGEST.COM a/k/a 

WHOLESALEJERSEYS2022.COM, CHEAP-SHOESYEEZY.COM, 

CHEAPYEEZYS.CO, CHEAPYEEZYS.ORG, FAKEYEEZYS.ORG, 

FASHIONSREP.CO, FLIGHTCLUBSHOES.NET, GOGOYEEZY.CN 

a/k/a GOGOYEEZY.VIP, HERESTORE.SHOP a/k/a 

HOTKICKSBUY.COM a/k/a HOTKICKSSHOP.COM a/k/a 

KICKSBUYOK.COM a/k/a KICKSFINE.COM a/k/a 

MYNICESHOES.SHOP a/k/a STOCKXBUY.COM a/k/a ZRUX.SHOP 

a/k/a ZRVS.SHOP a/k/a ZVUY.SHOP, HOTAIRJORDAN.COM a/k/a 

MG7SNEAKERS.COM, HYPEBEASTSHOES.COM, 

ITALYYEEZY.COM, LUXXSPORTS.LIVE a/k/a 

LUXXSPORTS.XYZ a/k/a ROSECLOTHINGBAG.COM, 

SHOPYEEZY.SHOP a/k/a TIGERSJERSEYCAP.COM, 

YEEZYSCHEAP.COM a/k/a YEEZYSUPPLYY.US, 

SNEAKERSBP.COM a/k/a YEEZYESALE.COM, Y3SHOES.ORG 

a/k/a YEEZYBOOST700.US a/k/a YEEZYBOOSTUFFICIALE.COM, 

YEEZYBOOSTOUTLET.COM, YEEZYALINR.COM, 

YEEZYCR.INFO, and YEEZYLLC.COM, each an Individual, Business 

Entity, or Unincorporated Association, 

Defendants.

_________________________________________________________/ 

COMPLAINT FOR INJUNCTIVE RELIEF AND DAMAGES

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

(collectively “Plaintiffs”), hereby sue Defendants the Individuals, Business Entities, and 

Unincorporated Associations identified in the caption, which are set forth on Schedule “A” hereto 

(collectively “Defendants”). Defendants are promoting, selling, offering for sale and/or 

distributing goods within this district using counterfeits and confusingly similar imitations of 

Plaintiffs’ trademarks within this district through various fully interactive commercial Internet 

websites operating under the domain names set forth 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 counterfeiting and infringement, false 

designation of origin, cybersquatting, common law unfair competition, and common law 

Case 0:22-cv-61683-RS Document 1 Entered on FLSD Docket 09/08/2022 Page 3 of 32
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trademark infringement, pursuant to 15 U.S.C. §§ 1114, 1116, 1125(a) and (d), and The All Writs 

Act, 28 U.S.C. § 1651(a), and Florida’s common law. Accordingly, this Court has subject matter 

jurisdiction over this action pursuant to 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 district because they operate 

commercial websites accessible in this district, conduct business by registering and maintaining 

the Subject Domain Names within the United States, and direct business activities towards

consumers throughout the United States, including within the State of Florida and this district 

through at least the fully interactive1 commercial Internet websites accessible in Florida and 

operating under the Subject Domain Names. Alternatively, Defendants are subject to personal 

jurisdiction in this district pursuant to Federal Rule of Civil Procedure 4(k)(2) because (i) 

Defendants are not subject to jurisdiction in any state’s court of general jurisdiction; and (ii) 

exercising jurisdiction is consistent with the United States Constitution and laws.

3. Venue is proper in this Court pursuant to 28 U.S.C. § 1391 since Defendants are, 

upon information and belief, aliens engaged in infringing activities and causing harm within this 

district by advertising, offering to sell, and/or selling infringing products into this district.

1 Some Defendants use their Subject Domain Names to act as supporting domain names to direct 

traffic to their fully interactive, commercial websites operating under other Subject Domain 

Names, from which consumers can complete purchases. Accordingly, the web pages for the 

Subject Domain Names which operate as redirecting websites are included with the web pages to 

which those sites redirect, as shown in Composite Exhibit “2” hereto.

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THE PLAINTIFFS

4. Plaintiff adidas AG (“adidas AG”) is a joint stock company organized and existing 

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 world’s leading manufacturers of athletic footwear 

and apparel, including products bearing the distinctive , , , Three-Stripe Mark, 

THE BRAND WITH THE 3 STRIPES Mark, BOOST Mark, STAN SMITH Mark, NMD Mark, 

and SPLY-350 Mark. 

5. Plaintiff adidas International Marketing B.V. (“adidas International”) is a 

corporation organized and existing under the laws of Netherlands, having its principal place of 

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 and 

existing under the laws of the State of Oregon, 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 using the distinctive , , , Three-Stripe Mark, THE 

BRAND WITH THE 3 STRIPES Mark, BOOST Mark, STAN SMITH Mark, NMD Mark, and 

SPLY-350 Mark. adidas AG, adidas International, and adidas America shall be referred to herein 

collectively as “adidas.” 

7. Plaintiffs’ goods are sold through various channels of trade within the State of 

Florida, including this district. Defendants, through the advertising, sale, and offering for sale of 

counterfeit and infringing versions of Plaintiffs’ branded products, are directly and unfairly 

Case 0:22-cv-61683-RS Document 1 Entered on FLSD Docket 09/08/2022 Page 5 of 32
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competing with Plaintiffs’ economic interests in the United States, including the State of Florida 

and causing Plaintiffs irreparable harm and damage within this jurisdiction.

8. Like many other famous trademark owners, Plaintiffs suffer ongoing daily and 

sustained violations of their trademark rights at the hands of counterfeiters and infringers, such as 

Defendants herein, who wrongfully reproduce and counterfeit Plaintiffs’ trademarks for the twin 

purposes of (i) duping and confusing the consuming public and (ii) earning substantial profits. 

9. To combat the indivisible harm caused by the combined actions of Defendants and 

others engaging in similar conduct, each year Plaintiffs expend significant monetary and other 

resources in connection with trademark enforcement efforts, including legal fees, investigative 

fees, and support mechanisms for law enforcement. The exponential growth of counterfeiting over 

the Internet has created an environment that require companies such as Plaintiffs to expend 

significant resources across a wide spectrum of efforts to protect both consumers and themselves 

from the confusion and erosion of the goodwill embodied in Plaintiffs’ brands. 

THE DEFENDANTS

10. Defendants operate through domain names registered with registrars in multiple 

countries, including the United States, and are comprised of individuals, business entities of 

unknown makeup, or unincorporated associations each of whom, upon information and belief, 

likely reside and/or operate in foreign jurisdictions or redistribute products from the same or 

similar sources in those locations. Defendants have the capacity to be sued pursuant to Federal 

Rule of Civil Procedure 17(b). Defendants target their business activities toward consumers 

throughout the United States, including within this district, through the simultaneous operation of, 

at least, the fully interactive commercial websites under the Subject Domain Names. 

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11. Defendants use aliases in conjunction with the operation of their businesses, 

including but not limited to those identified by Defendant Number on Schedule “A.”

12. Defendants are directly and personally contributing to, inducing and engaging in 

the sale of counterfeit branded products as alleged herein, often as partners, co-conspirators and/or 

suppliers.

13. Defendants are part of an ongoing scheme to create and maintain an illegal 

marketplace enterprise on the World Wide Web, which (i) confuses consumers regarding the 

source of Defendants’ goods for profit, and (ii) expands the marketplace for illegal, counterfeit

versions of Plaintiffs’ branded goods while shrinking the legitimate marketplace for Plaintiffs’ 

genuine branded goods. The natural and intended byproduct of Defendants’ combined actions is 

the erosion and destruction of the goodwill associated with Plaintiffs’ famous names and 

associated trademarks, as well as the destruction of the legitimate market sector in which they

operate.

14. Defendants are the past and/or present controlling forces behind the operation of 

websites operating under at least the Subject Domain Names.

15. Defendants directly engage in unfair competition with Plaintiffs by (i) advertising, 

offering for sale and/or selling goods each using counterfeits and infringements of one or more of 

Plaintiffs’ trademarks to consumers within the United States and this district through at least the 

fully interactive, commercial Internet websites operating under the Subject Domain Names, as 

well as additional domains and websites 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 their 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, and/or sale of counterfeit branded goods into the State, and by 

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

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

16. Defendants have registered, established, or purchased and maintained the Subject 

Domain Names, and the websites operating thereunder. Defendants may have engaged in 

fraudulent conduct with respect to the registration of the Subject Domain Names by providing 

false and/or misleading information during the registration or maintenance process related to their 

respective Subject Domain Names. Many Defendants have registered and/or maintained their

Subject Domain Names for the sole purpose of engaging in unlawful infringing and counterfeiting 

activities. 

17. Defendants will likely continue to register or acquire new domain names for the 

purpose of selling and offering for sale goods using counterfeit and confusingly similar imitations 

of Plaintiffs’ trademarks unless preliminarily and permanently enjoined. Moreover, Defendants 

will likely continue to maintain and grow their illegal marketplace enterprise at Plaintiffs’ expense 

unless preliminarily and permanently enjoined.

18. Defendants’ Subject Domain Names and any other domain names and aliases used 

in connection with the sale of counterfeit and infringing goods using one or more of Plaintiffs’ 

trademarks are essential components of Defendants’ online activities and are the means by which 

Defendants further their counterfeiting and infringement scheme and cause harm to Plaintiffs. 

Moreover, Defendants are using Plaintiffs’ famous 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 

marketplace and intellectual property rights at Plaintiffs’ expense.

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COMMON FACTUAL ALLEGATIONS

adidas’s Trademark Rights

19. adidas is currently, and for years has been, one of the world’s leading manufacturers 

of athletic footwear, apparel, and sporting equipment. adidas has used its famous and distinctive

trademarks , , , Three-Stripe Mark, THE BRAND WITH THE 3 STRIPES Mark, 

BOOST Mark, STAN SMITH Mark, NMD Mark, and SPLY-350 Mark (collectively, the “adidas 

Marks”), for many years in connection with the above-mentioned goods. The adidas Marks signify 

the quality and reputation of adidas products. 

20. adidas is the owner of multiple trademark registrations for the adidas Marks, 

including the following valid trademark registrations, issued by the United States Patent and 

Trademark Office: 

Trademark Registration 

Number

Registration 

Date Class / Goods 

ADIDAS 0,891,222 May 19, 1970 

IC25. sport shoes namely, track and field 

shoes, baseball, boxing, football, skating, 

golf, and soccer shoes; 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. 

0,973,161 November 20, 

1973 

IC 018. tote bags.

IC 25. specific purpose athletic shoes; 

general purpose sport shoes, sportswearnamely, suits, shorts, pants, tights, shirts, 

jerseys, socks, and gloves.

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-Up Suits, Boots, Shoes, Slippers.

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1,310,140 December 18, 

1984

IC 025. Sportswear-Namely, Suits, 

Shorts, Pants, Tights, Shirts, Jerseys, 

Socks, Gloves, Jackets, Coats, 

Swimwear, Sweaters, Caps, Pullovers, 

Warm-Up Suits, Rain Suits, Ski Suits, 

Jump Suits, Boots, Shoes, Slippers. 

THE BRAND 

WITH THE 3 

STRIPES

1,674,229 February 4, 1992

IC 025. boots, slippers, sandals; shoes, 

boots and after ski boots for hiking and 

trekking, athletic shoes and generalpurpose sports shoes.

2,411,802 December 12, 

2000

IC 018. All purpose sport bags, athletic 

bags, traveling bags, backpacks, 

knapsacks.

IC 025. Sports and leisure wear, namely, 

shorts, pants, shirts, T-shirts, jerseys, 

socks, gloves, jackets, swimwear, caps 

and hats, pullovers, sweat-shirts, sweat 

suits, track suits, warm-up suits; boots, 

sandals, specific purpose athletic 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.

3,029,129 December 13, 

2005 IC 025. Footwear.

3,029,135 December 13, 

2005 IC 025. Footwear.

3,104,117 June 13, 2006

IC 009. Optical apparatus and 

instruments, namely, eyeglasses and 

sunglasses.

IC 014. Horological and chronometric 

instruments, namely, watches

IC 018. Leather and imitations of leather, 

and goods made from these materials 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 made from these materials, 

namely, wallets, briefcases. 

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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, warmup 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 

purpose sports shoes.

3,580,958 February 24, 

2009

IC 025. Clothing, namely, shirts; 

footwear.

STAN SMITH 3,590,187 March 17, 2009 IC 025. Footwear.

NMD 5,218,628 June 6, 2017 IC 025. Footwear.

SPLY-350 5,413,495 February 27, 

2018 IC 025. Footwear

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

goods in the categories identified above. True and correct copies of the Certificates of Registration 

for the adidas Marks are attached hereto as Composite Exhibit “1.”

21. The adidas Marks have been used in interstate commerce to identify and distinguish 

adidas products for an extended period of time and serve as symbols of adidas’s quality, reputation, 

and goodwill.

22. The adidas Marks are well-known and famous and have been for many years. 

adidas has expended substantial 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 the University of Nebraska, 

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and the University of Louisville. Among many others, NBA stars Derrick Rose and James Harden, 

NFL stars Aaron Rodgers and Dak Prescott, NHL star P.K. Subban, baseball player Kris Bryant, 

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.

23. adidas extensively uses, advertises, and promotes the adidas Marks in the United 

States in association with the sale of quality products. adidas expends enormous resources 

promoting the adidas Marks and products bearing the adidas Marks. In recent years, annual sales 

of products using the adidas Marks have totaled in the billions of dollars globally and in the 

hundreds of millions of dollars within the United States.

24. The adidas Marks have achieved secondary meaning among consumers as 

identifiers of quality goods as a result of adidas’s advertisement, promotion, and sale of such goods 

thereunder.

25. As a result of adidas’s efforts, members of the consuming public readily identify 

merchandise bearing or sold using the adidas Marks, as being quality merchandise sponsored and 

approved by adidas. 

26. adidas has carefully monitored and policed the use of the adidas Marks and has 

never assigned or licensed the adidas Marks to any Defendant in this matter.

27. Genuine goods bearing the adidas Marks are widely legitimately advertised and 

promoted by adidas, authorized distributors and unrelated third parties via the Internet. Visibility 

on the Internet, particularly via Internet search engines such as Google, Yahoo!, and Bing is 

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important to adidas’s overall marketing and consumer education efforts. Thus, adidas expends 

significant monetary and other resources on Internet marketing and consumer education, including 

search engine optimization (“SEO”) and search engine marketing (“SEM”) strategies. Those 

strategies allow adidas and its authorized retailers to educate consumers fairly and legitimately 

about the value associated with the adidas Marks and the goods sold thereunder. Similarly, many 

of Defendants’ websites are indexed on search engines and compete directly with Plaintiffs for 

space and consumer attention in search results. 

Defendants’ Infringing Activities

28. In blatant disregard of Plaintiffs’ rights, Defendants are each promoting and 

advertising, distributing, offering for sale, and/or selling goods in interstate commerce using 

counterfeits and confusingly similar imitations of one or more of the adidas Marks (the 

“Counterfeit Goods”) through at least the fully interactive commercial Internet websites operating 

under the Subject Domain Names. True and correct copies of the web pages reflecting samples of 

the Internet websites operating under the Subject Domain Names displaying Plaintiffs’ branded 

items offered for sale are attached hereto as Composite Exhibit “2.” Specifically, Defendants are 

each using the adidas Marks to initially attract online consumers and drive them to Defendants’ 

websites operating under the Subject Domain Names. Defendants are each using identical copies 

of one or more of the adidas Marks for different quality goods. Plaintiffs have used the adidas

Marks extensively and continuously before Defendants began offering counterfeit and confusingly 

similar imitations of Plaintiffs’ merchandise. 

29. Defendants’ Counterfeit Goods are of a quality substantially different than that of 

Plaintiffs’ genuine goods. Defendants are actively using, promoting and otherwise advertising, 

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

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

for sale by Plaintiffs despite Defendants’ knowledge that they are without authority to use the 

adidas Marks. Defendants’ actions are likely to cause confusion of consumers at the time of initial 

interest, sale, and in the post-sale setting, who will believe all of Defendants’ goods are genuine 

goods originating from, associated with, and/or approved by Plaintiffs.

30. Defendants advertise their websites, including their Counterfeit Goods, to the 

consuming public via at least the websites operating under the Subject Domain Names. In so 

advertising their stores and products, Defendants improperly and unlawfully use one or more of 

the adidas Marks without authority.

31. Defendants are, upon information and belief, concurrently employing and 

benefitting from substantially similar, advertising and marketing strategies based, in large 

measure, upon an illegal use of counterfeits and infringements of the adidas Marks. Specifically, 

Defendants are using counterfeits and infringements of Plaintiffs’ famous names and the adidas 

Marks to make their websites selling illegal goods appear more relevant and attractive to 

consumers searching for both Plaintiffs’ and non-Plaintiffs’ goods and information online. By their 

actions, Defendants are contributing to the creation and maintenance of an illegal marketplace 

operating in parallel to the legitimate marketplace for Plaintiffs’ genuine goods. Defendants are 

causing individual, concurrent and indivisible harm to Plaintiffs and the consuming public by (i) 

depriving Plaintiffs of their right to fairly compete for space online and within search engine results 

and reducing the visibility of Plaintiffs’ genuine goods on the World Wide Web, (ii) causing an 

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

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

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

Case 0:22-cv-61683-RS Document 1 Entered on FLSD Docket 09/08/2022 Page 14 of 32
15

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

impunity.

32. Defendants are concurrently conducting and targeting their counterfeiting and 

infringing activities toward consumers and likely causing unified harm within this district and 

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

consuming public for Defendants’ own benefit.

33. At all times relevant hereto, Defendants have had full knowledge of Plaintiffs’ 

ownership of the adidas Marks, including their exclusive rights to use and license such intellectual 

property and the goodwill associated therewith.

34. Defendants’ use of the adidas Marks, including the promotion and advertisement, 

reproduction, distribution, sale and offering for sale of their Counterfeit Goods, is without

Plaintiffs’ consent or authorization.

35. Defendants are engaging in the above-described illegal counterfeiting and

infringing activities knowingly and intentionally or with reckless disregard or willful blindness to 

Plaintiffs’ rights for the purpose of trading on Plaintiffs’ goodwill and reputations. 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.

36. Defendants’ above identified infringing activities are likely to cause confusion, 

deception, and mistake in the minds of consumers before, during, and after the time of purchase. 

Moreover, Defendants’ wrongful conduct is likely to create a false impression and deceive 

customers into believing there is a connection or association between Plaintiffs’ genuine goods 

and Defendants’ Counterfeit Goods, which there is not.

Case 0:22-cv-61683-RS Document 1 Entered on FLSD Docket 09/08/2022 Page 15 of 32
16

37. Additionally, Defendant Numbers 1–16 have registered their respective Subject 

Domain Names, using marks that are nearly identical and/or confusingly similar to at least one of 

the adidas Marks, (the “Cybersquatted Subject Domain Names”).

38. Defendant Numbers 1–16 have registered and/or used the Cybersquatted Subject 

Domain Names with the bad faith intent to profit from the adidas Marks.

39. Defendants do not have, nor have they ever had, the right or authority to use the 

adidas Marks for any purpose. Further, the adidas Marks have never been assigned or licensed to 

be used on any of the websites operating under the Cybersquatted Subject Domain Names.

40. Upon information and belief, Defendant Numbers 1–16 have provided false and/or 

misleading contact information when applying for the registration of the Cybersquatted Subject 

Domain Names, or have intentionally failed to maintain accurate contact information with respect 

to the registration of the Cybersquatted Subject Domain Names.

41. Defendant Numbers 1–16 have never used the Cybersquatted Subject Domain 

Names in connection with a bona fide offering of goods or services.

42. Defendant Numbers 1–16 have not made any bona fide non-commercial or fair use 

of the adidas Marks on a website accessible under the Cybersquatted Subject Domain Names.

43. Defendant Numbers 1–16 have intentionally incorporated at least one of the adidas 

Marks in their Cybersquatted Subject Domain Names to divert consumers looking for Plaintiffs’ 

websites to their own websites for commercial gain.

44. Given the visibility of Defendants’ various websites and the similarity of their 

actions, it is clear Defendants are either affiliated or at a minimum, cannot help but know of each 

other’s existence and the unified harm likely to be caused to Plaintiffs and the overall consumer 

market in which they operate as a result of Defendants’ concurrent actions.

Case 0:22-cv-61683-RS Document 1 Entered on FLSD Docket 09/08/2022 Page 16 of 32
17 

45. Although some Defendants may be physically acting independently, they may 

properly be deemed to be acting in concert because the combined force of their actions serves to 

multiply the harm caused to Plaintiffs.

46. Plaintiffs have no adequate remedy at law.

47. Plaintiffs are suffering irreparable injury and have suffered substantial damages

because of Defendants’ unauthorized and wrongful use of the adidas Marks. 

48. The harm and damages sustained by Plaintiffs have been directly and proximately 

caused 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 Defendants’ 

illegal marketplace enterprise. 

COUNT I - TRADEMARK COUNTERFEITING AND INFRINGEMENT

PURSUANT TO § 32 OF THE LANHAM ACT (15 U.S.C. § 1114) 

49. Plaintiffs hereby adopt and re-allege the allegations set forth in Paragraphs 1 

through 48 above. 

50. This is an action for trademark counterfeiting and infringement against Defendants 

based on their use of counterfeit and confusingly similar imitations of the adidas Marks in 

commerce in connection with the promotion, advertisement, distribution, offering for sale, and/or 

sale the Counterfeit Goods. 

51. Specifically, Defendants are promoting and otherwise advertising, selling, offering 

for sale, and distributing goods 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 one or more of the adidas Marks to advertise, promote, offer to sell, and/or sell counterfeit 

and infringing branded goods. 

Case 0:22-cv-61683-RS Document 1 Entered on FLSD Docket 09/08/2022 Page 17 of 32
18 

52. Defendants’ concurrent counterfeiting and infringing activities are likely to cause 

and 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. 

53. Defendants’ unlawful actions have caused and are continuing to cause 

unquantifiable damage to Plaintiffs and are unjustly enriching Defendants with profits at Plaintiffs’ 

expense. 

54. Defendants’ above-described unlawful actions constitute counterfeiting and 

infringement of the adidas Marks in violation of Plaintiffs’ rights under § 32 of the Lanham Act, 

15 U.S.C. § 1114. 

55. Plaintiffs have no adequate remedy at law. Plaintiffs have suffered and will 

continue to suffer irreparable injury and damages due to Defendants’ above-described activities if 

Defendants are not preliminarily and permanently enjoined. Additionally, Defendants will 

continue to wrongfully profit from their illegal activities.

COUNT II - FALSE DESIGNATION OF ORIGIN

PURSUANT TO § 43(a) OF THE LANHAM ACT (15 U.S.C. § 1125(a)) 

56. Plaintiffs hereby adopt and re-allege the allegations set forth in Paragraphs 1 

through 48 above. 

57. Defendants’ Counterfeit Goods bearing, offered for sale, and sold using copies of 

one or more of the adidas Marks have been widely advertised and offered for sale throughout the 

United States via the Internet. 

58. Defendants’ Counterfeit Goods bearing, offered for sale, and sold using copies of 

one or more of the adidas Marks are virtually identical in appearance to Plaintiffs’ genuine goods. 

However, Defendants’ Counterfeit Goods are different in quality. Accordingly, Defendants’ 

Case 0:22-cv-61683-RS Document 1 Entered on FLSD Docket 09/08/2022 Page 18 of 32
19

activities are likely to cause confusion among consumers as to at least the origin or sponsorship of 

their Counterfeit Goods. 

59. Defendants have used in connection with their advertisement, offer for sale, and 

sale of the Counterfeit Goods, false designations of origin and false descriptions and 

representations, including words or symbols which falsely describe or represent such goods and 

have caused such goods to enter commerce in the United States with full knowledge of the falsity 

of such designations of origin and such descriptions and representations, all to Plaintiffs’ 

detriment.

60. Defendants have each authorized infringing uses of one or more of the adidas Marks

in Defendants’ advertisement and promotion of their counterfeit and infringing branded goods.

Some Defendants have also misrepresented to members of the consuming public that the 

Counterfeit Goods being advertised and sold by them are genuine, non-infringing goods.

61. Additionally, many Defendants are simultaneously using counterfeits and 

infringements of one or more of the adidas Marks to unfairly compete with Plaintiffs and others 

for space within organic and paid search engine and social media results. Defendants are thereby

jointly (i) depriving Plaintiffs of valuable marketing and educational space online which would 

otherwise be available to Plaintiffs, and (ii) reducing the visibility of Plaintiffs’ genuine goods on 

the World Wide Web, and across social media platforms.

62. Defendants’ above-described actions are in violation of Section 43(a) of the 

Lanham Act, 15 U.S.C. §1125(a).

63. Plaintiffs have no adequate remedy at law. Plaintiffs have suffered and will 

continue to suffer both individual and indivisible irreparable injury and damages due to 

Case 0:22-cv-61683-RS Document 1 Entered on FLSD Docket 09/08/2022 Page 19 of 32
20 

Defendants’ above-described activities if Defendants are not preliminarily and permanently 

enjoined. Additionally, Defendants will continue to wrongfully profit from their illegal activities. 

COUNT III - CLAIM FOR RELIEF FOR CYBERSQUATTING

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

(Against Defendants Numbers 1–16 only) 

64. Plaintiffs hereby adopt and re-allege the allegations set forth in Paragraphs 1 

through 48 above. 

65. Defendant Numbers 1–16 have acted with the bad faith intent to profit from the 

adidas Marks and the goodwill associated with the adidas Marks by registering and using the 

Cybersquatted Subject Domain Names.

66. The adidas Marks were distinctive and famous at the time Defendant Numbers 1–

16 registered the Cybersquatted Subject Domain Names.

67. The Cybersquatted Subject Domain Names are identical to, confusingly similar to 

or dilutive of at least one of the adidas Marks. 

68. Defendant Numbers 1–16’s registration and maintenance of the Cybersquatted 

Subject Domain Names was done with knowledge and constitutes a willful violation of Plaintiffs’ 

rights in the adidas Marks. At a minimum, Defendants’ conduct constitutes reckless disregard for 

and willful blindness to Plaintiffs’ rights. 

69. Defendant Numbers 1–16’s actions constitute cybersquatting in violation of §43(d) 

of the Lanham Act, 15 U.S.C. §1125(d). 

70. Plaintiffs have no adequate remedy at law. Plaintiffs have suffered and will 

continue to suffer irreparable injury and damages due to Defendant Numbers 1–16’s abovedescribed activities if Defendant Numbers 1–16’s are not preliminarily and permanently enjoined. 

Case 0:22-cv-61683-RS Document 1 Entered on FLSD Docket 09/08/2022 Page 20 of 32
21 

Additionally, Defendant Numbers 1–16’s will continue to wrongfully profit from their illegal 

activities.

COUNT IV - COMMON LAW UNFAIR COMPETITION

71. Plaintiffs hereby adopt and re-allege the allegations set forth in Paragraphs 1 

through 48 above. 

72. This is an action against Defendants based on their (i) promotion, advertisement, 

distribution, offering for sale, and/or sale of goods using or bearing marks that are virtually 

identical to one or more of the adidas Marks, and (ii) creation and maintenance of an illegal, 

ongoing marketplace enterprise operating in parallel to the legitimate marketplace in which 

Plaintiffs sell their genuine goods, in violation of Florida’s common law of unfair competition. 

73. Specifically, Defendants are each promoting and otherwise advertising, selling, 

offering for sale, and/or distributing goods using counterfeits and infringements of one or more of 

the adidas Marks. Defendants are also each using counterfeits and infringements of one or more

of the adidas Marks to unfairly compete with Plaintiffs and others for (i) space in search engine 

and social media results across an array of search terms and/or (ii) visibility on the World Wide 

Web.

74. Defendants’ infringing activities are likely to cause and are causing confusion, 

mistake and deception among consumers as to the origin and quality of Defendants’ websites as a 

whole and all products sold therein by their use of the adidas Marks. 

75. Plaintiffs have no adequate remedy at law. Plaintiffs have suffered and will 

continue to suffer irreparable injury and damages due to Defendants’ above-described activities if 

Defendants are not preliminarily and permanently enjoined. Additionally, Defendants will 

continue to wrongfully profit from their illegal activities.

Case 0:22-cv-61683-RS Document 1 Entered on FLSD Docket 09/08/2022 Page 21 of 32
22 

COUNT V - COMMON LAW TRADEMARK INFRINGEMENT

76. Plaintiffs hereby adopt and re-allege the allegations set forth in Paragraphs 1 

through 48 above. 

77. This is an action for common law trademark infringement against Defendants based 

on their promotion, advertisement, offering for sale, and sale of their Counterfeit Goods using one 

or more of the adidas Marks. 

78. Plaintiffs are the owners of all common law rights in and to the adidas Marks. 

79. Specifically, each Defendant is promoting and otherwise advertising, distributing, 

offering for sale, and selling goods using or bearing infringements of one or more of the adidas 

Marks. 

80. Defendants’ infringing activities are likely to cause and are causing confusion, 

mistake and deception among consumers as to the origin and quality of Defendants’ Counterfeit 

Goods bearing the adidas Marks. 

81. Plaintiffs have no adequate remedy at law. Plaintiffs have suffered and will 

continue to suffer irreparable injury and damages due to Defendants’ above-described activities if 

Defendants are not preliminarily and permanently enjoined. Additionally, Defendants will 

continue to wrongfully profit from their illegal activities. 

PRAYER FOR RELIEF

82. WHEREFORE, Plaintiffs demand judgment on all Counts of this Complaint and 

an award of equitable relief and monetary relief against Defendants as follows:

a. Entry of temporary, preliminary, and permanent injunctions pursuant to 15 

U.S.C. § 1116, 28 U.S.C. § 1651(a), The All Writs Act, and Federal Rule of Civil Procedure 65 

enjoining Defendants, their agents, representatives, servants, employees, and all those acting in 

Case 0:22-cv-61683-RS Document 1 Entered on FLSD Docket 09/08/2022 Page 22 of 32
23

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; from using the adidas Marks, or any mark 

or design similar thereto, in connection with the sale of any unauthorized goods; from using any 

logo, trade name, trademark or design that 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 that 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, infringement, copy, or colorable imitation of the adidas Marks in connection with the 

publicity, promotion, sale, or advertising of any goods sold by Defendants; from 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’ names or trademarks; and from otherwise unfairly competing 

with Plaintiffs.

b. Entry of temporary, preliminary, and permanent injunctions pursuant to 28 

U.S.C §1651(a), The All Writs Act, and the Court’s inherent authority, enjoining Defendants and 

all third parties with actual notice of an injunction issued by the Court from participating in, 

including providing financial services, technical services or other support to, Defendants in 

Case 0:22-cv-61683-RS Document 1 Entered on FLSD Docket 09/08/2022 Page 23 of 32
24

connection with the sale and distribution of non-genuine goods bearing and/or using counterfeits 

or infringements of the adidas Marks.

c. Entry of an order pursuant to 28 U.S.C. § 1651(a), The All Writs Act, and 

the Court’s inherent authority, than, upon Plaintiffs’ request, those acting in concert or 

participation with Defendants who have notice of the injunction, as service providers cease 

hosting, facilitating access to, or providing any supporting service to any and all domain names, 

including but not limited to the Subject Domain Names, and websites through which Defendants 

engage in the promotion, offering for sale and/or sale of goods bearing and/or using counterfeits 

and/or infringements of the adidas Marks.

d. Entry of an order pursuant to 15 U.S.C. § 1116, 28 U.S.C. § 1651(a), The 

All Writs Act, and the Court’s inherent authority, that upon Plaintiffs’ request, Defendants and the 

top level domain (TLD) Registry for each of the Subject Domain Names, and any other domain

names used by Defendants, or their administrators, including backend registry operators or 

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 which 

link the Subject Domain Names, and any other domain names being used and/or controlled by 

Defendants to engage in the business of marketing, offering to sell, and/or selling goods bearing 

and/or using counterfeits or infringements of Plaintiffs Marks, to the IP addresses where the 

associated websites are hosted.

e. Entry of an order pursuant to 28 U.S.C. § 1651(a), The All Writs Act, and 

the Court’s inherent authority, canceling for the life of the current registration or, at Plaintiffs’ 

election, transferring the Subject Domain Names and any other domain names used by Defendants 

Case 0:22-cv-61683-RS Document 1 Entered on FLSD Docket 09/08/2022 Page 24 of 32
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to engage in their counterfeiting of the adidas Marks to Plaintiffs’ control so they may no longer 

be used for unlawful purposes.

f. Entry of an order pursuant to 28 U.S.C. § 1651(a), The All Writs Act, and 

the Court’s inherent authority, that, upon Plaintiffs’ request, any Internet marketplace website 

operators and/or administrators, registrar and/or top level domain (TLD) Registry for the Subject 

Domain Names who are provided with notice of an injunction issued by the Court identify any email address known to be associated with Defendants’ respective Subject Domain Name.

g. Entry of an order pursuant to 28 U.S.C. § 1651(a), The All Writs Act, and 

the Court’s inherent authority, authorizing Plaintiffs to serve the injunction on any e-mail service 

provider with a request that the service provider permanently suspend the e-mail addresses which

are or have neem used by Defendants in connection with Defendants’ promotion, offering for sale, 

and/or sale of goods using counterfeits and/or infringements of the adidas Marks.

h. Entry of an order pursuant to 28 U.S.C. § 1651(a), The All Writs Act, and 

the Court’s inherent authority, authorizing Plaintiffs to request any Internet search engines which 

are provided with notice of the order, to permanently disable, de-index or delist all URLs of the 

Subject Domain Names by Defendants to promote, offer for sale and/or sell goods bearing 

counterfeits and/or infringements of the adidas Marks, based upon Defendants’ unlawful activities 

being conducted via the Subject Domain Names as a whole and via the URLs identified by 

Plaintiffs.

i. Entry of an order requiring each Defendant, its agent(s) or assign(s), to 

assign all rights, title, and interest, to its Subject Domain Name(s), and any other domains 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, to Plaintiffs and, if within five 

Case 0:22-cv-61683-RS Document 1 Entered on FLSD Docket 09/08/2022 Page 25 of 32
26

(5) days of entry of such order any Defendant fails to make such an assignment, the Court order 

the act to be done by another person appointed by the Court at any non-complying Defendant’s 

expense, such as the Clerk of Court, pursuant to Federal Rule of Civil Procedure 70(a).

j. Entry of an order requiring each Defendant, its agent(s) or assign(s), to 

instruct all search engines to permanently delist or deindex the Subject Domain Name(s), and any 

other domains 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, and, if 

within five (5) days of entry of such order any Defendant fails to make such a written instruction, 

the Court order the act to be done by another person appointed by the Court at any non-complying 

Defendant’s expense, such as the Clerk of Court, pursuant to Federal Rule of Civil Procedure 

70(a).

k. Entry of an order requiring Defendants to account to and pay Plaintiffs for 

all profits and damages resulting from Defendants’ trademark counterfeiting and infringing and 

unfairly competitive activities and that the award to Plaintiffs be trebled, as provided for under 15 

U.S.C. §1117, or that Plaintiffs be awarded statutory damages from each Defendant in the amount 

of two million dollars ($2,000,000.00) per each counterfeit trademark used and product type sold, 

as provided by 15 U.S.C. §1117(c)(2) of the Lanham Act.

l. Entry of an order requiring Defendant Numbers 1–16 to account to and pay 

Plaintiffs for all profits and damages resulting from Defendant Numbers 1–16’s cybersquatting 

activities and that the award to Plaintiffs be trebled, as provided for under 15 U.S.C. §1117, or that 

Plaintiffs be awarded statutory damages from Defendant Numbers 1–16 in the amount of one 

hundred thousand dollars ($100,000.00) per cybersquatted domain name used as provided by 15 

U.S.C. §1117(d) of the Lanham Act.

Case 0:22-cv-61683-RS Document 1 Entered on FLSD Docket 09/08/2022 Page 26 of 32
27 

m. Entry of an award pursuant to 15 U.S.C. § 1117 (a) and (b) of Plaintiffs’ 

costs and reasonable attorneys’ fees and investigative fees associated with bringing this action.

n. Entry of an award of pre-judgment interest on the judgment amount. 

o. Entry of an Order requiring Defendants to pay the cost necessary to correct 

any erroneous impression the consuming public may have received or derived concerning the 

nature, characteristics, or qualities of Defendants’ products, including without limitation, the 

placement of corrective advertising and providing written notice to the public. 

p. Entry of an order for any further relief as the Court may deem just and 

proper. 

DATED: September 8, 2022. Respectfully submitted,

 STEPHEN M. GAFFIGAN, P.A.

 

 By: Stephen M. Gaffigan__________ 

 Stephen M. Gaffigan (Fla. Bar No. 025844) 

 Virgilio Gigante (Fla. Bar No. 082635) 

 T. Raquel Wiborg-Rodriguez (Fla. Bar. No. 103372) 

 401 East Las Olas Blvd., #130-453 

 Ft. Lauderdale, Florida 33301 

 Telephone: (954) 767-4819 

 E-mail: stephen@smgpa.net 

 E-mail: leo@smgpa.net 

 E-mail: raquel@smgpa.net

 Attorneys for Plaintiffs 

Case 0:22-cv-61683-RS Document 1 Entered on FLSD Docket 09/08/2022 Page 27 of 32
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SCHEDULE A

DEFENDANTS BY NUMBER AND SUBJECT DOMAIN NAME 

Defendant 

Number Defendant / Domain Name

1 adidas--australia.com

1 adidasbudapest.com

1 adidas-budapest.com

1 adidas-colombia.com

1 adidas-danmark.com

1 adidas-egypt.com

1 adidasfactoryoutletuk.com

1 adidasgreecegr.com

1 adidasguatemala.com

1 adidashonduras.com

1 adidashrvatskahr.com

1 adidashu.top

1 adidas-hungary.com

1 adidashungaryakcios.com

1 adidasinromania.com

1 adidasinsverige.com

1 adidas--ireland.com

1 adidasitaliasconti.com

1 adidasksa.com

1 adidaslovenskosk.com

1 adidasmagyarorszag.com

1 adidasmarimekkosuomi.com

1 adidasmaroc.com

1 adidasnicaragua.com

1 adidasnmdromania.top

1 adidasnz-sale.com

1 adidasonlineromania.com

1 adidasoutletmx.com

1 adidas-outletnz.com

1 adidasoutlettr.com

1 adidaspakistan.com

1 adidaspanama.com

1 adidaspolskapl.com

1 adidas-reduceri.com

1 adidasromania.biz

1 adidas--romania.com

1 adidasromonlineshop.com

1 adidas--schweiz.com

Case 0:22-cv-61683-RS Document 1 Entered on FLSD Docket 09/08/2022 Page 28 of 32
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1 adidasshoesgr.com

1 adidasshoesgreece.com

1 adidas-shoes-nz.com

1 adidasskonorge.com

1 adidasslevacz.com

1 adidassromania.com

1 adidasyeezyshoesuk.com

1 ecuador-adidas.com

1 osterreich-adidas.com

1 peru-adidas.com

1 sverige-adidas.com

2 adidas1949.club

2 adidas1949.online

2 adidas1949.top

2 adidas1984.fun

2 adidasair.top

2 adidasale.fun

2 adidasfun.shop

2 adidasfun.top

2 adidasneaker.club

2 adidasneaker.shop

2 adidassale.top

2 adidas-series.top

2 adidas-shopping.club

2 adidas-tribal.club

2 adidas-tribal.top

2 adidastunr.club

2 neoadidas.space

2 onadidas.top

2 superadidas.shop

2 ttadidas.com

2 usadidasrun.shop

3 adidasales.top

3 adidasneakers.shop

3 adidasoutlet.top

3 adidasrun1949.top

3 adidas-runner.shop

3 adidassales.top

3 adidassneakers.top

3 usadidas.club

3 usadidas-run.online

3 usadidas-sport.online

4 adidas-belgie.com

Case 0:22-cv-61683-RS Document 1 Entered on FLSD Docket 09/08/2022 Page 29 of 32
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5 adidasbutypl.com

5 adidasfactoryoutletsingapore.com

5 adidas--malaysia.com

5 adidasnorgeoutlet.com

5 adidas-philippines.com

5 adidasschuheat.com

6 adidas--canada.com

6 adidasencostarica.com

6 adidasfactoryoutlet.com

6 adidashoescanada.com

6 adidasirelandie.com

6 adidasnz.com

6 adidasonlinehrvatska.com

6 adidasoutletwoodmead.com

6 adidas-singapore.com

6 canadaadidas.com

7 adidashoejp.com

8 adidasoutletnl.com

9 adidaspower.top

10 adidasshoesalefr.com

11 adidasyeezyoutlet.org

11 adidasyeezyoutlet.us

11 fakeyeezys.us

11 slinexon.com

11 yeezyoutlet.us

11 yeezys-350.com

11 yeezysslides.com

11 Yeezy-store.com

11 yeezyv2.com

11 yeezyv2sales.org

12 adidas-yeezys.com

12 adidasyeezyshoes.us

12 adidas-yeezy-shoes.us

12 adidasyeezysshoes.com

12 cheapyeezysupply.com

12 yeezyfoamrunner.us

12 yeezyshoess.net

12 yeezy-slides.com

12 yeezyslides.net

12 yeezy-slides.us

12 yeezyslideshoe.com

12 yeezy-slidess.com

12 yeezy-slidesus.com

Case 0:22-cv-61683-RS Document 1 Entered on FLSD Docket 09/08/2022 Page 30 of 32
31

12 yeezy-slides-us.com

12 yeezyslidesus.net

12 yeezyslidesus.us

12 yeezyslides-us.us

12 yeezy-slidesus.us

12 yeezy-slides-us.us

12 yeezysshoess.com

12 yeezys-slides.com

12 yeezysslides.us

12 yeezy-supply.net

12 yeezysupplys.us

12 yeezy-supplys.us

12 yeezysupplyshoes.com

13 adidasyeezys.org

14 adidasyeezyshoe.com

14 adidasyeezyus.com

14 yeezy350boost-v2.us

14 yeezyboost350.org

14 yeezysshoes.us

15 boostyeezy.us

15 fabioyeezys.cheap

15 realcheapyeezys.com

15 shopcheapshoes.com

15 yeezysv2.us

16 womensadidas.xyz

17 amanda888.com

18 anshoes.store

19 apairofwalk.com

19 dailyschoenen.com

19 famouslineshoe.com

20 buyarrive.com

21 cheapchinajerseys.org

21 jerseysfatory.com

21 officialonlinestore.co

21 vipsportsuniforms.com

21 wholesalefljerseysgest.com

21 wholesalejerseys2022.com

22 cheap-shoesyeezy.com

23 cheapyeezys.co

24 cheapyeezys.org

25 fakeyeezys.org

26 fashionsrep.co

27 flightclubshoes.net

Case 0:22-cv-61683-RS Document 1 Entered on FLSD Docket 09/08/2022 Page 31 of 32
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28 gogoyeezy.cn

28 gogoyeezy.vip

29 herestore.shop

29 hotkicksbuy.com

29 hotkicksshop.com

29 kicksbuyok.com

29 kicksfine.com

29 myniceshoes.shop

29 stockxbuy.com

29 zrux.shop

29 zrvs.shop

29 zvuy.shop

30 hotairjordan.com

30 mg7sneakers.com

31 hypebeastshoes.com

32 italyyeezy.com

33 luxxsports.live

33 luxxsports.xyz

33 roseclothingbag.com

34 shopyeezy.shop

34 tigersjerseycap.com

35 yeezyscheap.com

35 yeezysupplyy.us

36 sneakersbp.com

36 yeezyesale.com

37 y3shoes.org

37 yeezyboost700.us

37 yeezyboostufficiale.com

38 yeezyboostoutlet.com

39 yeezyalinr.com

40 yeezycr.info

41 yeezyllc.com

Case 0:22-cv-61683-RS Document 1 Entered on FLSD Docket 09/08/2022 Page 32 of 32