PLAINTIFF’S ORIGINAL COMPLAINT PAGE 1

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IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

EL PASO DIVISION

G&G CLOSED CIRCUIT EVENTS, LLC, §

as Broadcast Licensee of the March 18, 2017 §

Gennady Golovkin v. Daniel Jacobs WBA Super 

World Middleweight Championship Fight Program,

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 Plaintiff, §

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v. §

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1) 528 INV-JEV, LLC, individually, and d/b/a 1810 

TAQUERIA & BORRACHERIA and d/b/a 

TAQUERIA Y BORRACHERIA 1810 and d/b/a 

1810;

2) CARLOS J. MARQUEZ, individually, and d/b/a

1810 TAQUERIA & BORRACHERIA and d/b/a 

TAQUERIA Y BORRACHERIA 1810 and d/b/a 

1810;

3) JAIME E. VELAZQUEZ, individually, and 

d/b/a 1810 TAQUERIA & BORRACHERIA and 

d/b/a TAQUERIA Y BORRACHERIA 1810 and 

d/b/a 1810; and

4) ALLAN DILLON a/k/a ALLAN DIJON, 

individually, and d/b/a 1810 TAQUERIA & 

BORRACHERIA and d/b/a TAQUERIA Y 

BORRACHERIA 1810 and d/b/a 1810,

 Defendants.

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Civil Action No. 3:20-cv-00095

PLAINTIFF’S ORIGINAL COMPLAINT

Plaintiff G&G Closed Circuit Events, LLC (“Plaintiff”) files Plaintiff’s Original

Complaint against Defendants (1) 528 Inv-Jev, LLC, individually, and d/b/a 1810 Taqueria & 

Borracheria and d/b/a Taqueria y Borracheria 1810 and d/b/a 1810 (“528 Inv-Jev”); (2) Carlos J. 

Marquez, individually, and d/b/a 1810 Taqueria & Borracheria and d/b/a Taqueria y Borracheria 

1810 and d/b/a 1810 (“Marquez”); (3) Jaime E. Velazquez, individually, and d/b/a 1810 Taqueria 

& Borracheria and d/b/a Taqueria y Borracheria 1810 and d/b/a 1810 (“Velazquez”); and (4)

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PLAINTIFF’S ORIGINAL COMPLAINT PAGE 2

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Allan Dillon a/k/a Allan Dijon, individually, and d/b/a 1810 Taqueria & Borracheria and d/b/a 

Taqueria y Borracheria 1810 and d/b/a 1810 (collectively “Defendants”).

PARTIES

1. Plaintiff. G&G Closed Circuit Events, LLC, as Broadcast Licensee of the March 

18, 2017 Gennady Golovkin v. Daniel Jacobs WBA Super Middleweight Championship Fight 

Program, is a foreign corporation. Plaintiff’s business address is 2380 South Bascom Avenue, 

Suite 200, Campbell, California 95008.

2. Defendant 528 Inv-Jev, LLC. 528 Inv-Jev, LLC is a Texas limited liability 

company doing business as 1810 Taqueria & Borracheria (also known as Taqueria y Borracheria 

1810 and 1810) and having its business mailing address as 1441 N. Zaragoza Road, Suite A3, El 

Paso, Texas 79936. On the date of the Event (as defined herein), Defendant 528 Inv-Jev:

A. held the license/permit issued by the Texas Alcoholic Beverage 

Commission for the commercial establishment named Taqueria y 

Borracheria 1810 and located at 1441 N. Zaragoza, Suite A 3-4, El Paso, 

Texas 79936 (“Establishment”);

B. owned and/or operated the Establishment;

C. had a right and ability to supervise the activities of the Establishment; and

D. had an obvious and direct financial interest in the activities of the 

Establishment. 

Defendant 528 Inv-Jev may be served by delivering the Summons and a copy of Plaintiff’s 

Original Complaint to its registered agent for service of process, Carlos J. Marquez, at 6837 La 

Cadena, El Paso, Texas 79912.

3. Defendant Carlos J. Marquez. Carlos J. Marquez is an individual residing in the 

State of Texas. On the date of the Event (as defined herein), Defendant Marquez:

A. held the license/permit issued by the Texas Alcoholic Beverage 

Commission for the Establishment;

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B. was an owner and/or manager of the Establishment;

C. was an officer and/or owner of the entity that owned the property where 

the Establishment was located;

D. was an officer and/or owner of the entity owning the Establishment;

E. had a right and ability to supervise the activities of the Establishment; and 

F. had an obvious and direct financial interest in the activities of the 

Establishment.

Defendant Marquez may be served by delivering the Summons and a copy of Plaintiff’s Original

Complaint to Defendant Marquez at 6837 La Cadena, El Paso, Texas 79912.

4. Defendant Jaime E. Velazquez. Jaime E. Velazquez is an individual residing in 

the State of Texas. On the date of the Event (as defined herein), Defendant Velazquez:

A. held the license/permit issued by the Texas Alcoholic Beverage 

Commission for the Establishment;

B. was an owner and/or manager of the Establishment;

C. was an officer and/or owner of the entity that owned the property where 

the Establishment was located;

D. was an officer and/or owner of the entity owning the Establishment;

E. had a right and ability to supervise the activities of the Establishment; and 

F. had an obvious and direct financial interest in the activities of the 

Establishment.

Defendant Velazquez may be served by delivering the Summons and a copy of Plaintiff’s 

Original Complaint to Defendant Velazquez at 3164 Sarina, El Paso, Texas 79938.

5. Defendant Allan Dillon. Allan Dillon a/k/a Allan Dijon is an individual residing 

in the State of Texas. On the date of the Event (as defined herein), Defendant Dillon:

A. held the license/permit issued by the Texas Alcoholic Beverage 

Commission for the Establishment;

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B. was an owner and/or manager of the Establishment;

C. was an officer and/or owner of the entity that owned the property where 

the Establishment was located;

D. was an officer and/or owner of the entity owning the Establishment;

E. had a right and ability to supervise the activities of the Establishment; and 

F. had an obvious and direct financial interest in the activities of the 

Establishment.

Defendant Dillon may be served by delivering the Summons and a copy of Plaintiff’s Original

Complaint to Defendant Dillon at 1441 N. Zaragoza Road, Suite A3-4, El Paso, Texas 79936.

STATEMENT OF JURISDICTION

6. This action arises under the Communications Act of 1934, as amended, 47 U.S.C. 

§§ 553 or 605 in Texas. 

VENUE

7. Venue is proper in this District because Defendants reside in this District and a 

substantial part of the events giving rise to the claim occurred in this District. 

STATEMENT OF THE CLAIM

8. Authorization to License Event. Plaintiff is the license company that was

exclusively authorized to sub-license the closed-circuit telecast of the March 18, 2017 Gennady 

Golovkin v. Daniel Jacobs WBA Super Middleweight Championship Fight Program, including 

all of the undercard or preliminary bouts (collectively the “Event”),

1 at closed-circuit locations 

such as theaters, arenas, bars, clubs, lounges, restaurants and the like throughout Texas. 

1 One of the bouts for the Event included the fight between Gennady Golovkin and Daniel Jacobs, which 

was the main event.

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9. The closed-circuit broadcast of the Event was not intended for the use of the 

general public. In Texas, the closed-circuit broadcast of the Event could only be exhibited in a 

commercial establishment, if the establishment was contractually authorized to do so by Plaintiff.

10. Pursuant to its authority to sub-license the Event, Plaintiff marketed and 

distributed the closed-circuit rights granted to it. Plaintiff, through its agents, contracted with 

various establishments throughout Texas and granted such establishments the right to broadcast 

the Event in exchange for a fee. 

11. Exhibition of the Event. The transmission of the Event originated via satellite and 

was electronically coded or “scrambled.” In order for the signal to be received and telecast 

clearly, it had to be decoded with electronic decoding equipment.

12. The transmission of the Event was available to Defendants to purchase for 

broadcast in the Establishment. Had Defendants chosen to purchase the Event, Defendants would 

have been authorized to receive, transmit and publish the Event in the Establishment. 

Defendants did not, however, contract with Plaintiff or any of its agents, to obtain the rights to 

broadcast the Event.

13. The establishments that contracted with Plaintiff to broadcast the Event were 

provided with the electronic decoding capability and/or satellite coordinates necessary to receive 

the signal of the Event.

14. On March 18, 2017, either by satellite transmission or through unauthorized 

receipt over a cable system, Defendants willfully intercepted or received the interstate 

communication of the Event. In the alternative, Defendants assisted in the receipt of the interstate 

communication of the Event. Defendants then transmitted, divulged and published said 

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communication, or assisted in transmitting, divulging and publishing said communication, to 

patrons within the Establishment.

15. Defendants misappropriated Plaintiff’s licensed exhibition of the Event and 

infringed upon Plaintiff’s exclusive rights while avoiding proper payment to Plaintiff. 

Defendants’ actions were committed willfully and with the express purpose and intent to secure a 

commercial advantage and private financial gain.

16. Defendants enabled the patrons within the Establishment to view the Event to 

which neither Defendants nor the Establishment’s patrons were entitled to do.

17. The persons whom Defendants permitted to view the Event would otherwise have 

been able to view it at a commercial establishment only if said commercial establishment was 

properly licensed and authorized by Plaintiff.

18. Defendants were not authorized to intercept, receive or transmit the 

communication of the Event or to assist in such actions in any form or at any time.

VIOLATION OF 47 U.S.C. § 553 OR § 605

19. Defendants’ wrongful actions in connection with the Event, as described above, 

violate 47 U.S.C. Section 605, or Section 553.

DEMAND FOR RELIEF SOUGHT

Plaintiff demands that the Court sign and cause to be entered a judgment in favor of 

Plaintiff and against Defendants, jointly and severally, for:

(a) Statutory damages in an amount up to Ten Thousand Dollars ($10,000.00) 

pursuant to 47 U.S.C. § 553(c)(3)(A)(ii);

(b) Statutory damages for willfulness in an amount up to Fifty Thousand 

Dollars ($50,000.00), pursuant to 47 U.S.C. § 553(c)(3)(B);

(c) Statutory damages in an amount up to Ten Thousand Dollars ($10,000.00) 

pursuant to 47 U.S.C. § 605(e)(3)(C)(i)(II);

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(d) Statutory damages in an amount up to One Hundred Thousand Dollars 

($100,000.00) pursuant to 47 U.S.C. § 605(e)(3)(C)(ii);

(e) Full costs and expenses of this action, including reasonable attorney’s 

fees, pursuant to 47 U.S.C. §§ 553(c)(2)(C) and 605(e)(3)(B)(iii);

(f) Pre and post-judgment interest at the highest rate permitted by law; and

(g) Such other and further relief to which Plaintiff is entitled. 

Respectfully submitted,

 

By: 

 David M. Diaz

State Bar No. 24012528

david@diazlawtx.com

Attorney-in-charge 

LAW OFFICES OF DAVID DIAZ, PLLC

825 Watters Creek Blvd.

Building M, Suite 250

Allen, Texas 75013

(972) 996-4588 – Telephone

ATTORNEY FOR PLAINTIFF

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