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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 

THE NORTH FACE APPAREL CORP.,

VANS, INC., 

TBL LICENSING LLC, and 

ICEBREAKER APPAREL, LLC,

Plaintiffs,

vs.

THE INDIVIDUALS, BUSINESS ENTITIES, 

AND UNINCORPORATED ASSOCIATIONS 

IDENTIFIED ON SCHEDULE “A,”

Defendants.

_________________________________________/

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF

Plaintiffs, The North Face Apparel Corp., Vans, Inc., TBL Licensing LLC, and 

Icebreaker Apparel, LLC (collectively “Plaintiffs”),1 hereby sue Defendants, the Individuals, 

Business Entities, and Unincorporated Associations identified on Schedule “A” (collectively 

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

bearing and using counterfeits and confusingly similar imitations of Plaintiffs’ respective 

trademarks within this district through various fully interactive commercial Internet websites

operating under the domain names set forth on Schedule “A” (the “Subject Domain Names”). In 

support of their claims, Plaintiffs allege as follows: 

JURISDICTION AND VENUE

1. This is an action for damages and injunctive relief for federal trademark 

counterfeiting and infringement, false designation of origin, cybersquatting, common law unfair 

1 The Plaintiffs, The North Face Apparel Corp., Vans, Inc., TBL Licensing LLC, and Icebreaker 

Apparel, LLC are related ultimate subsidiaries of V.F. Corporation which is a global leader in 

branded lifestyle apparel, footwear and accessories. 

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competition, and common law trademark infringement pursuant to 15 U.S.C. §§ 1114, 1116 and 

1125(a) and 1125(d), 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 direct 

business activities toward and conduct business with consumers throughout the United States, 

including within the State of Florida and this district through, at least, their fully interactive 

commercial Internet websites accessible and doing business in Florida and operating under the 

Subject Domain Names. Alternatively, based on their contacts with the United States, 

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, non-resident in the United States and engaged in infringing 

activities and causing harm within this district by advertising, offering to sell, selling, and/or 

shipping infringing products into this district. 

THE PLAINTIFFS 

4. Plaintiff The North Face Apparel Corp. (“The North Face”) is a company 

organized and existing under the laws of the State of Delaware, having its principal place of 

business at 3411 Silverside Road, Wilmington, DE 19810. 

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5. Plaintiff Vans, Inc. (“Vans”) is a company organized and existing under the laws 

of the State of Delaware, having its principal place of business at 1588 South Coast Dr, Costa 

Mesa, CA 92626.

6. Plaintiff TBL Licensing LLC (“TBL”) is a company organized and existing under 

the laws of the State of Delaware, having its principal place of business at 200 Domain Drive,

Stratham, NH 03885.

7. Plaintiff Icebreaker Apparel, LLC (“Icebreaker”) is a company organized and 

existing under the laws of the State of Delaware, having its principal place of business at 251

Little Falls Drive, Wilmington, DE 19808.

8. Goods bearing the Plaintiffs’ registered trademarks set forth below are offered for 

sale and sold by Plaintiffs and/or their licensees which are related operating companies within 

the V.F. Corporation’s family of companies, through various channels of trade within the State 

of Florida, including this district, and throughout the United States. Defendants, through the sale 

and offer to sell counterfeit and infringing versions of Plaintiffs’ branded products, are directly 

and unfairly competing with Plaintiffs’ economic interests in the United States, including the 

State of Florida, and causing Plaintiffs harm within this jurisdiction.

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

sustained violations of their respective trademark rights at the hands of counterfeiters and 

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

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

and (ii) earning substantial profits across their e-commerce stores. The natural and intended 

byproduct of Defendants’ combined actions is the erosion and destruction of the goodwill 

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associated with Plaintiffs’ names and associated trademarks and the destruction of the legitimate 

market sector in which they operate. 

10. To combat the indivisible harm caused by the concurrent actions of Defendants 

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

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

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

The exponential growth of counterfeiting over the Internet, including through online marketplace 

and social media platforms, has created an environment that requires companies, such as 

Plaintiffs, to expend significant resources across a wide spectrum of efforts in order to protect 

both consumers and themselves from confusion and the erosion of the goodwill embodied in

Plaintiffs’ respective brands. 

THE DEFENDANTS

11. Defendants are individuals, business entities of unknown makeup, or 

unincorporated associations each of whom, upon information and belief, either reside and/or 

operate in foreign jurisdictions, redistribute products from the same or similar sources in those 

locations, and/or ship their goods from the same or similar sources in those locations to 

consumers as well as shipping and fulfillment centers within the United States to redistribute 

their products from 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, their fully interactive commercial Internet websites under the Subject Domain 

Names. 

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12. Defendants use aliases in connection with the operation of their businesses, 

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

13. Defendants are the past and present controlling forces behind the sale of products 

bearing and/or using counterfeits and infringements of Plaintiffs’ trademarks as described herein.

14. Defendants directly engage in unfair competition with Plaintiffs by advertising, 

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

one or more of Plaintiffs’ individual trademarks to consumers within the United States and this 

district through at least the fully interactive commercial Internet websites using, at least, the 

Subject Domain Names, as well as additional names, aliases, domain names, or websites not yet 

known to Plaintiffs. Defendants have purposefully directed some portion of their unlawful 

activities towards consumers in the State of Florida through the advertisement, offer to sell, sale, 

and/or shipment of counterfeit and infringing branded versions of Plaintiffs’ goods into the State. 

15. Defendants have registered, established or purchased, and maintained their 

Subject Domain Names. 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 some of their Subject Domain Names for 

the sole purpose of engaging in unlawful counterfeiting and/or infringing activities.

16. Defendants will likely continue to register or acquire new aliases and domain 

names, as well as related payment accounts, for the purpose of selling and offering for sale goods 

bearing and/or using counterfeit and confusingly similar imitations of one or more of Plaintiffs’ 

respective trademarks unless preliminarily and permanently enjoined.

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17. Defendants’ Subject Domain Names, associated payment accounts, and any other 

alias domain or e-commerce store names used in connection with the sale of counterfeit and 

infringing goods bearing and/or using one or more of Plaintiffs’ respective 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’ respective 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. 

COMMON FACTUAL ALLEGATIONS

The North Face’s Trademark Rights

18. The North Face is the owner of all rights, title, and interest in and to the following 

trademarks, which are valid and registered on the Principal Register of the United States Patent 

and Trademark Office (collectively, the “TNF Marks”): 

Trademark Registration 

Number Registration Date Class(es)/Goods

THE NORTH 

FACE 0,983,624 May 14, 1974 

USC 003 - Backpacks 

USC 022 - Sleeping bags; tents, 

snowshoes, and skis 

USC 039 - Camping clothing 

namely rainwear, parkas, vests, 

trousers, shoes, gloves and headgear

1,030,071 January 13, 1976

IC 018 - Backpacks 

IC 020 - Sleeping bags 

IC 022 - Tents 

IC 025 - Camping clothing, namely, 

rainwear, parkas, vests, trousers, 

shoes, gloves, headgear and 

snowshoes

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Trademark Registration 

Number Registration Date Class(es)/Goods

2,097,715 September 16, 1997

IC 018 - Backpacks

IC 020 - Sleeping bags

IC 022 - Tents 

IC 025 - Clothing, namely, parkas, 

vests, jackets, anoraks, pants, ski 

bibs, gloves, mittens, underwear, 

hats, headbands, caps, ski suits, 

gaiters, shorts, and shirts

3,538,773 November 25, 2008

IC 009 - Computer bags 

IC 018 - All purpose sporting bags, 

backpacks, day packs, knapsacks, 

rucksacks, book bags, tote bags, 

handbags, duffel bags, knap sacks 

and duffel sacks, hip and lumbar 

packs, shoulder bags, book bags, 

waist packs, fanny packs, day 

packs, shoulder bags, satchels, 

mountaineering bags, Boston bags, 

internal frame packs, backpack 

bottle pockets, rain covers used to 

cover the aforesaid; hydration 

packs, namely, backpack hydration 

systems consisting of a backpack, a 

reservoir, and a mouthpiece 

connected to the reservoir by a tube; 

parts and fittings for all the 

aforesaid goods

IC 020 - Sleeping bags; covers for 

sleeping bags; sacks for carrying 

and storing sleeping bags; nonmetal tent poles and tent stakes 

IC 021 - Hydration packs, namely, 

hydration system consisting of a 

reservoir and a mouthpiece 

connected to the reservoir by a tube 

IC 022 - Tents; tent accessories, 

namely, tent storage bags, rain flies, 

vinyl ground cloths, tent pole 

storage sacks

IC 025 - Clothing, namely, men's, 

women's, and children's T-shirts, 

shirts, tops, sweatshirts, sweatpants, 

pants, side zip pants, shorts, 

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Trademark Registration 

Number Registration Date Class(es)/Goods

trousers, vests, parkas, anoraks, 

coats, jackets, wind-resistant 

jackets, jacket hoods, pullovers, 

sweaters, underwear, thermal 

underwear, tights, gloves, mittens; 

outerwear, namely, shells, onepiece shell suits, ski wear, ski suits, 

ski vests, ski jackets, ski bibs, bib 

overalls, bib pants, snowboard 

wear, snow pants, snow suits, rain 

wear, rain jackets, rain pants, 

gaiters, namely, neck gaiters; skirts, 

skorts, dresses, swim trunks; 

footwear, namely, athletic shoes, 

sneakers, trail running shoes, 

climbing shoes, hiking shoes, 

slippers, boots, trekking boots, 

hiking boots, snowshoes, sandals; 

headgear, namely, caps, hats, 

headbands, scarves, earbands, 

balaclavas, visors, beanies 

IC 035 - On-line retail store 

services, retail store services, mail

order, catalogue and distributorship 

services, all featuring camping and 

outdoor gear and equipment, 

hardware, clothing, sportswear, 

eyewear, footwear, headgear, sports 

equipment and related accessories

3,630,846 June 2, 2009 IC 025 - Footwear; head wear; 

rainwear; scarves; ski wear

3,630,850 June 2, 2009

IC 025 - Footwear; gloves; 

headgear, namely, hats, caps, 

headbands, visors, hosiery, namely 

long underwear; jackets; mittens; 

pants; parkas; shirts; shorts; ski 

jackets; skirts; tights; vests

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

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

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

19. The TNF Marks have been used in interstate commerce to identify and distinguish 

high-quality goods for an extended period of time and serve as symbols of The North Face’s

quality, reputation, and goodwill. 

20. Further, The North Face and its related companies expend substantial resources 

developing, advertising and otherwise promoting the TNF Marks. The TNF Marks qualify as 

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

21. The North Face and its related companies extensively use, advertise, and promote 

the TNF Marks in the United States in connection with the sale of high-quality goods. As a 

result, the TNF Marks are among the most widely recognized trademarks in the United States, 

and the trademarks have achieved secondary meaning among consumers as identifiers of highquality goods.

22. The North Face has carefully monitored and policed the use of the TNF Marks

and has never assigned or licensed the TNF Marks to any Defendant in this matter.

23. Genuine goods bearing and/or using the TNF Marks are widely legitimately 

advertised and promoted by The North Face, its related companies, authorized distributors, and 

unrelated third parties via the Internet. Visibility on the Internet, particularly via Internet search 

engines and social media platforms, is important to The North Face’s overall marketing and 

consumer education efforts. Thus, The North Face, its related companies, and authorized 

distributors expend significant monetary and other resources on Internet marketing and consumer 

education regarding its products, including search engine optimization (“SEO”), search engine 

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marketing (“SEM”), and social media strategies. Those strategies allow The North Face, its 

related companies, and authorized distributors to educate consumers fairly and legitimately about 

the value associated with the TNF Marks and the goods sold thereunder. 

Vans’s Trademark Rights

24. Vans is the owner of all rights in and to the following trademarks, which are valid 

and registered on the Principal Register of the United States Patent and Trademark Office 

(collectively, the “VANS Marks”):

Trademark Registration 

Number Registration Date Class(es)/Goods

1,244,537 July 5, 1983 IC 025 - Shoes 

VANS 1,267,262 February 14, 1984 IC 025 - Shoes 

1,353,939 August 13, 1985 

IC 014 - Jewelry

IC 018 - Wallets, handbags 

and all purpose tote bags 

IC 025 - Wearing apparel, 

namely, sport shirts, t-shirts, 

hats, short, jogging suits, 

socks, swimsuits and shoes

VANS 1,861,013 November 1, 1994

IC 025 - Clothing and 

footwear; namely, sport 

shirts, T-shirts, hats, shorts, 

jogging suits, socks and 

shoes for men, women and 

children

2,177,772 August 4, 1998 IC 025 - Footwear 

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Trademark Registration 

Number Registration Date Class(es)/Goods

2,817,392 February 24, 2004

IC 025 – Clothing, namely, 

t-shirts, shirts, sweatshirts, 

shorts, pants, jackets; 

footwear and headgear, 

namely, caps and hats for 

men, women and children. 

5,070,470 November 1, 2016 IC 025 - Footwear, namely, 

twin-gore slip-on shoes

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

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

Registration for the VANS Marks are attached hereto as Composite Exhibit “2.”

25. The VANS Marks have been used in interstate commerce to identify and 

distinguish high-quality goods for an extended period of time and serve as symbols of Vans’s 

quality, reputation and goodwill. 

26. Further, Vans and its related companies expend substantial resources developing, 

advertising and otherwise promoting the VANS Marks. The VANS Marks qualify as famous 

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

27. Vans and its related companies extensively use, advertise, and promote the VANS

Marks in the United States in connection with the sale of high-quality goods. As a result, the 

VANS Marks are among the most widely recognized trademarks in the United States, and the 

trademarks have achieved secondary meaning among consumers as identifiers of high-quality 

goods.

28. Vans has carefully monitored and policed the use of the VANS Marks and has 

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

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29. Genuine goods bearing and/or using the VANS Marks are widely legitimately 

advertised and promoted by Vans, its related companies, and authorized distributors via the 

Internet. Visibility on the Internet, particularly via Internet search engines and social media 

platforms is important to Vans’s overall marketing and consumer education efforts. Thus, Vans

expends significant monetary and other resources on Internet marketing and consumer education

regarding its products, including SEO, SEM, and social media strategies. Those strategies allow 

Vans and its related companies to educate consumers fairly and legitimately about the value 

associated with the VANS Marks and the goods sold thereunder. 

TBL’s Trademark Rights

30. TBL is the owner of all rights in and to the following trademarks, which are valid 

and registered on the Principal Register of the United States Patent and Trademark Office

(collectively, the “TBL Marks”):

Trademark Registration 

Number Registration Date Class(es)/Goods

1,075,061 October 11, 1977

IC 025 - Footwear, namely 

boots, work shoes, and 

hiking shoes 

TIMBERLAND 2,932,268 March 15, 2005 

IC 025 - Footwear; clothing, 

namely coats, jackets, 

rainwear, sweaters, shirts, 

pants, shorts, headwear, 

gloves, neckwear, belts, 

sweatshirts, t-shirts, vests, 

socks

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Trademark Registration 

Number Registration Date Class(es)/Goods

2,947,228 May 10, 2005

IC 025 - Footwear; clothing, 

namely coats, jackets, 

rainwear, sweaters, shirts, 

pants, shorts, headwear, 

gloves, neckwear, belts, 

sweatshirts, t-shirts, vests, 

socks

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

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

Registration for the TBL Marks are attached hereto as Composite Exhibit “3.”

31. The TBL Marks have been used in interstate commerce to identify and distinguish

high-quality goods for an extended period of time and serve as symbols of TBL’s quality, 

reputation and goodwill. 

32. Further, TBL and its related companies expend substantial resources developing, 

advertising and otherwise promoting the TBL Marks. The TBL Marks qualify as famous marks

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

33. TBL and its related companies extensively use, advertise, and promote the TBL

Marks in the United States in connection with the sale of high-quality goods. As a result, the 

TBL Marks are among the most widely recognized trademarks in the United States, and the 

trademarks have achieved secondary meaning among consumers as identifiers of high-quality 

goods.

34. TBL has carefully monitored and policed the use of the TBL Marks and has never 

assigned or licensed the TBL Marks to any Defendant in this matter.

35. Genuine goods bearing and/or using the TBL Marks are widely legitimately 

advertised and promoted by TBL, its related companies, and unrelated third parties via the 

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Internet. Visibility on the Internet, particularly via Internet search engines and social media 

platforms is important to TBL’s overall marketing and consumer education efforts. Thus, TBL

expends significant monetary and other resources on Internet marketing and consumer education

regarding its products, including SEO, SEM, and social media strategies. Those strategies allow 

TBL and its related companies to educate consumers fairly and legitimately about the value 

associated with the TBL Marks and the goods sold thereunder. 

Icebreaker’s Trademark Rights

36. Icebreaker is the owner of all rights in and to the following trademarks, which are 

valid and registered on the Principal Register of the United States Patent and Trademark Office 

(collectively, the “ICEBREAKER Marks”):

Trademark Registration 

Number Registration Date Class(es)/Goods

ICEBREAKER 4,565,860 July 15, 2014 

IC 025 - Outerwear, 

namely, muffs; footwear, 

namely, insulated over

boots

ICEBREAKER 4,893,214 January 26, 2016

IC 025 - Clothing, namely, 

pullovers, scarves, shirts, 

sweatshirts, singlets, socks, 

sweaters, tee shirts, 

underclothes, boxer shorts, 

jockey shorts, underpants, 

underwear, thermal 

underwear, camisoles, 

shorts, pants, jackets, coats, 

jerseys, jumpers, vests, 

leggings, neck warmers, and 

gloves; headgear, namely, 

caps, hats, balaclavas

The ICEBREAKER Marks are used in conjunction with the manufacture and distribution of 

high-quality goods in the categories identified above. True and correct copies of the Certificates 

of Registration for the ICEBREAKER Marks are attached hereto as Composite Exhibit “4.” 

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37. The ICEBREAKER Marks have been used in interstate commerce to identify and 

distinguish high-quality goods for an extended period of time and serve as symbols of 

Icebreaker’s quality, reputation, and goodwill.

38. Further, Icebreaker and its related companies expend substantial resources 

developing, advertising and otherwise promoting the ICEBREAKER Marks. The 

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

39. Icebreaker and its related companies extensively use, advertise, and promote the 

ICEBREAKER Marks in the United States in connection with the sale of high-quality goods. As 

a result, the ICEBREAKER Marks are among the most widely recognized trademarks in the 

United States, and the trademarks have achieved secondary meaning among consumers as 

identifiers of high-quality goods.

40. Icebreaker has carefully monitored and policed the use of the ICEBREAKER 

Marks and has never assigned or licensed the ICEBREAKER Marks to any Defendant in this 

matter.

41. Genuine goods bearing and/or using the ICEBREAKER Marks are widely 

legitimately advertised and promoted by Icebreaker, its related companies, and unrelated third 

parties via the Internet. Visibility on the Internet, particularly via Internet search engines and 

social media platforms, is important to Icebreaker’s overall marketing and consumer education 

efforts. Thus, Icebreaker expends significant monetary and other resources on Internet marketing 

and consumer education regarding its products, including SEO, SEM, and social media 

strategies. Those strategies allow Icebreaker and its related companies to educate consumers

fairly and legitimately about the value associated with the ICEBREAKER Marks and the goods 

sold thereunder.

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Defendants’ Infringing Activities

42. Defendants are each promoting, advertising, distributing, selling, and/or offering 

for sale goods in interstate commerce bearing and/or using counterfeit and confusingly similar 

imitations of one or more of the TNF Marks, the VANS Marks, the TBL Marks, and/or the 

ICEBREAKER Marks (the “Counterfeit Goods”) through at least the commercial Internet 

websites operating under the Subject Domain Names. Specifically, Defendants are using the 

TNF Marks, VANS Marks, TBL Marks, and/or Icebreaker Marks (collectively, “Plaintiffs’ 

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 Plaintiffs’ Marks for different quality goods. Plaintiffs have used their respective Marks 

extensively and continuously before Defendants began offering counterfeit and confusingly 

similar imitations of Plaintiffs’ merchandise. 

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

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

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

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

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

use Plaintiffs’ Marks. The net effect of Defendants’ actions is 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 offered for sale in or through Defendants’ Internet websites are genuine 

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

44. Defendants advertise their websites, including their Counterfeit Goods offered for 

sale, to the consuming public via at least the fully interactive, commercial Internet websites 

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operating under the Subject Domain Names. In so doing, Defendants improperly and unlawfully 

use one or more of Plaintiffs’ Marks without Plaintiffs’ permission.

45. Most Defendants are concurrently employing and benefitting from substantially 

similar advertising and marketing strategies based, in large measure, upon an unauthorized use of 

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

counterfeits and infringements of one or more of Plaintiffs’ famous names and Plaintiffs’ Marks

to make their website stores selling unauthorized 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 unlawful

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 and other third parties of their right to fairly 

compete for space 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 Plaintiffs’ Marks, and (iii) increasing Plaintiffs’ overall cost to market their 

goods and educate consumers about their brands via the Internet.

46. 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.

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

respective ownership of Plaintiffs’ Marks, including their respective, exclusive rights to use and 

license such intellectual property and the goodwill associated therewith.

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48. Defendants’ use of Plaintiffs’ Marks, including the promotion and advertisement, 

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

Plaintiffs’ consent or authorization.

49. 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’ respective 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.

50. 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 

consumers, the public, and the trade into believing there is a connection or association between 

Plaintiffs’ respective genuine goods and Defendants’ Counterfeit Goods, which there is not.

51. Moreover, upon information and belief, at least Defendant Numbers 1, 49, 51, and 

54 have registered at least one of their respective Subject Domain Names using marks that are 

nearly identical and/or confusingly similar to at least one of Plaintiffs’ Marks (the 

“Cybersquatted Subject Domain Names”).

52. Defendant Numbers 1, 49, 51, and 54 do not have, nor have they ever had, the 

right or authority to use the Plaintiffs’ Marks. Further, the Plaintiffs’ Marks have never been 

assigned or licensed to be used on any of the websites, including the websites operating under 

the Cybersquatted Subject Domain Names.

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53. Defendant Numbers 1, 49, 51, and 54 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.

54. Defendant Numbers 1, 49, 51, and 54 have never used the Cybersquatted Subject 

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

55. Defendant Numbers 1, 49, 51, and 54 have not made any bona fide noncommercial or fair use of Plaintiffs’ Marks on a website accessible under the Cybersquatted 

Subject Domain Names. 

56. Defendant Numbers 1, 49, 51, and 54 have intentionally incorporated at least one 

of Plaintiffs’ respective Marks in their Cybersquatted Subject Domain Names to divert

consumers looking for Plaintiffs’ respective Internet websites to their own websites for 

commercial gain.

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

concurrent 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 because of Defendants’ concurrent actions.

58. 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.

59. Defendants’ payment and financial accounts, including but not limited to those 

specifically set forth on Schedule “A,” are being used by Defendants to accept, receive, and 

deposit profits from Defendants’ trademark counterfeiting and infringing, and unfairly 

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competitive activities connected to their Subject Domain Names and any other alias websites or 

domain names being used and/or controlled by them. 

60. Further, Defendants, upon information and belief, are likely to transfer or secret 

their assets to avoid payment of any monetary judgment awarded to Plaintiffs. 

61. Plaintiffs have no adequate remedy at law.

62. Plaintiffs are suffering irreparable injury because of Defendants’ unauthorized 

and wrongful use of Plaintiffs’ Marks. If Defendants’ counterfeiting and infringing and unfairly 

competitive activities are not preliminarily and permanently enjoined by this Court, Plaintiffs 

and the consuming public will continue to be harmed while Defendants wrongfully earn a 

substantial profit. 

63. The harm 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. 

COUNT I - TRADEMARK COUNTERFEITING AND INFRINGEMENT

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

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

through 63 above. 

65. This is an action for trademark counterfeiting and infringement against 

Defendants based on their use of counterfeit and confusingly similar imitations of Plaintiffs’ 

Marks in commerce in connection with the promotion, advertisement, distribution, offering for 

sale, and sale of the Counterfeit Goods. 

66. Specifically, Defendants are promoting and otherwise advertising, selling, 

offering for sale, and distributing goods bearing and/or using counterfeits and/or infringements 

of one or more of Plaintiffs’ Marks. Defendants are continuously infringing and inducing others 

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to infringe Plaintiffs’ Marks by using one or more of them to advertise, promote, offer to sell, 

and/or sell counterfeit and infringing goods bearing and/or using Plaintiffs’ Marks. 

67. 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. 

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

unquantifiable and irreparable harm to Plaintiffs and are unjustly enriching Defendants with 

profits at Plaintiffs’ expense. 

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

infringement of Plaintiffs’ Marks in violation of Plaintiffs’ respective rights under § 32 of the 

Lanham Act, 15 U.S.C. § 1114. 

70. Plaintiffs have each suffered and will continue to suffer irreparable injury while 

Defendants are earning a substantial profit due to Defendants’ above-described activities if 

Defendants are not preliminarily and permanently enjoined. 

COUNT II - FALSE DESIGNATION OF ORIGIN

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

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

through 63 above. 

72. Defendants’ Counterfeit Goods bearing, using, offered for sale, and sold using 

copies of one or more of Plaintiffs’ Marks have been widely advertised and offered for sale 

throughout the United States via the Internet. 

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

at least one or more of Plaintiffs’ Marks are virtually identical in appearance to Plaintiffs’ 

respective, genuine goods. However, Defendants’ Counterfeit Goods are different in quality. 

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Accordingly, Defendants’ activities are likely to cause confusion in the trade and among 

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

74. Defendants have used in connection with their advertisement, offers for sale, and 

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

representations, including words or other symbols and designs, which tend to 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.

75. Defendants have each authorized infringing uses of one or more of Plaintiffs’

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.

76. Additionally, Defendants are simultaneously using counterfeits and infringements 

of one or more of Plaintiffs’ 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.

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

Lanham Act, 15 U.S.C. §1125(a).

78. Plaintiffs have no adequate remedy at law and have each sustained both individual

and indivisible injury caused by Defendants’ concurrent conduct. Absent an entry of an 

injunction by this Court, each Plaintiff will continue to suffer irreparable injury to their 

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respective goodwill and business reputation, while Defendants are earning a substantial profit.

COUNT III - CLAIM FOR RELIEF FOR CYBERSQUATTING 

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

(Against Defendant Numbers 1, 49, 51, and 54, only)

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

through 63 above. 

80. At all times relevant hereto, Plaintiffs have been and still are the owners of the 

rights, title, and interest in and to their respective trademarks. 

81. Defendant Numbers 1, 49, 51, and 54 have acted with the bad faith intent to profit 

from the TNF Marks, TBL Marks, and/or ICEBREAKER Marks and the goodwill associated 

with the Marks by registering and using the Cybersquatted Subject Domain Names. 

82. The TNF Marks, TBL Marks, and ICEBREAKER Marks were already distinctive 

and famous at the time Defendant Numbers 1, 49, 51, and 54 registered the Cybersquatted

Subject Domain Names. 

83. Defendant Numbers 1, 49, 51, and 54 have no intellectual property rights in or to 

the TNF Marks, TBL Marks, and ICEBREAKER Marks. The Cybersquatted Subject Domain

Names are identical to, confusingly similar to, or dilutive of at least one of the TNF Marks, TBL 

Marks, or ICEBREAKER Marks. 

84. Defendant Numbers 1, 49, 51, and 54’s conduct is done with knowledge and 

constitutes a willful violation of Plaintiffs’ rights in their respective Marks. At a minimum, the 

conduct of these Defendants constitutes reckless disregard for and willful blindness to Plaintiffs’ 

respective rights. 

85. Defendant Numbers 1, 49, 51, and 54’s actions constitute cybersquatting in 

violation of §43(d) of the Lanham Act, 15 U.S.C. § 1125(d). 

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86. Plaintiffs have no adequate remedy at law and have suffered and will continue to 

suffer irreparable injury while Defendants Numbers 1, 49, 51, and 54 profit due to the abovedescribed activities if those Defendants are not preliminarily and permanently enjoined. 

COUNT IV - COMMON LAW UNFAIR COMPETITION

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

through 63 above. 

88. This is an action against Defendants based on their promotion, advertisement, 

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

identical to one or more of Plaintiffs’ Marks in violation of Florida’s common law of unfair 

competition. 

89. Specifically, Defendants are promoting and otherwise advertising, selling, 

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

one or more of Plaintiffs’ Marks. Defendants are also each using counterfeits and infringements 

of one or more of Plaintiffs’ 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 (ii) visibility on the 

World Wide Web. 

90. 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 Plaintiffs’ Marks.

91. Plaintiffs have no adequate remedy at law and are suffering irreparable injury

because of Defendants’ actions, while Defendants are earning a substantial profit. 

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COUNT V - COMMON LAW TRADEMARK INFRINGEMENT

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

through 63 above. 

93. 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 

bearing and/or using one or more of Plaintiffs’ Marks. Plaintiffs are the owners of all common 

law rights in and to Plaintiffs’ Marks. 

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

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

Plaintiffs’ Marks. 

95. 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 and/or using Plaintiffs’ Marks.

96. Plaintiffs have no adequate remedy at law and are suffering irreparable injury 

because of Defendants’ actions, while Defendants are earning a substantial profit. 

PRAYER FOR RELIEF

97. 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 

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 

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infringing, counterfeiting, or diluting Plaintiffs’ Marks; from using Plaintiffs’ Marks, or any 

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

using any logo, trade name or 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 Plaintiffs’

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’ respective name or trademarks; and from 

otherwise unfairly competing with Plaintiffs.

b. Entry of a 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 

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

and/or infringements of Plaintiffs’ Marks.

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c. 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, those acting in concert or 

participation as service providers to Defendants, who have notice of the injunction, 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 using counterfeits and/or 

infringements of Plaintiffs’ Marks.

d. 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 that 

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

sale, and/or sale of goods using and/or bearing counterfeits and/or infringements of Plaintiffs’ 

Marks.

e. 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 the domain name 

registrar(s) and/or the privacy protection service(s) for the Subject Domain Names to disclose to 

Plaintiffs the true identities and contact information for the registrant of the Subject Domain 

Name.

f. 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 the Subject Domain Names, and any other domains 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 

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period for any such domain names, 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 

counterfeits and infringements of Plaintiffs’ Marks, to the IP addresses where the associated 

websites are hosted.

g. 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 to engage in their counterfeiting of Plaintiffs’ Marks at issue to Plaintiffs’ control so 

they may no longer be used for unlawful purposes.

h. Entry of an order pursuant to 15 U.S.C. § 1116 and the Court’s inherent 

authority, requiring Defendants, their agent(s) or assign(s), to assign all rights, title, and interest, 

to their Subject Domain Name(s) and any other domain names used by Defendants to Plaintiffs

and, if within five (5) days of entry of such order Defendants fail to make such an assignment, 

the Court order the act to be done by another person appointed by the Court at Defendants’

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

i. Entry of an order pursuant to 15 U.S.C. § 1116 and the Court’s inherent 

authority, requiring Defendants, their agent(s) or assign(s), to instruct in writing, all search 

engines to permanently delist or deindex the Subject Domain Name(s) and any other domain 

names used by Defendants and, if within five (5) days of entry of such order Defendants fail to 

make such a written instruction, the Court order the act to be done by another person appointed 

by the Court at Defendants’ expense, such as the Clerk of Court, pursuant to Federal Rule of 

Civil Procedure 70(a).

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j. 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, administrators, registrars 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 

e-mail address known to be associated with Defendants’ respective Subject Domain Names.

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

all profits earned from Defendants’ trademark counterfeiting and infringing and unfairly 

competitive activities and that the profit 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 offered for sale or sold, as provided by 15 U.S.C. §1117(c)(2) of the Lanham Act.

l. Entry of an order requiring Defendant Numbers 1, 49, 51, and 54 to

account to and pay Plaintiffs for all profits resulting from those Defendants’ cybersquatting 

activities and that the profit 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, 49, 51, and 54

in the amount of one hundred thousand dollars ($100,000.00) per cybersquatted name used as 

provided by 15 U.S.C. § 1117(d) of the Lanham Act.

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

All Writs Act, Federal Rule of Civil Procedure 65, and the Court’s inherent authority that, upon 

Plaintiffs’ request, Defendants and any financial institutions, payment processors, banks, escrow 

services, money transmitters, or marketplace platforms, and their related companies and 

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affiliates, identify and restrain all funds, up to and including the total amount of judgment, in all 

financial accounts and/or sub-accounts used in connection with the Subject Domain Names or 

other alias names, domain names and/or websites used by Defendants presently or in the future, 

as well as any other related accounts of the same customer(s) and any other accounts which 

transfer funds into the same financial institution account(s), and remain restrained until such 

funds are surrendered to Plaintiffs in partial satisfaction of the monetary judgment entered 

herein. 

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

p. Entry of an order requiring Defendants, at Plaintiffs’ request, 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. 

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

proper. 

DATED: November 16, 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 

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SCHEDULE “A”

[This page is the subject of Plaintiffs’ Motion to File Under Seal. As such, this page has 

been redacted in accordance with L.R. 5.4(b)(1)] 

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