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UNITED STATES DISTRICT COURT OF 

SOUTH BEND INDIANA "-t-1 - ., ' ,.. 

.. , .. r ii i: JO 

Mr. James Cross Pro'se) 

) 

) 

) 

) 

) 

Plaintiff 

Vs. 

) 

) 

CIVIL ACTION 

COMPLAINT FOR RACE DISCRMINATION 

DEMAND FOR JURY TRIAL 

Nike Inc. ) 

Defendant 

ALLEGATION COMPLAINT 

Plaintiff James Cross (hereinafter referred to as Cross') 

demand a jury trial and complaint against the Defendant as 

follows: 

THE PARTIES 

1. Plaintiff's Mr. Cross is an black inventor residing at 120 Glencove Dr. 

Michigan City, IN 46360. 

2. On information and belief, Defendant, Nike Inc. (hereinafter referred to as 

Nike Inc.') is a corporation organized under the law of Oregon and Indiana 

having two places of businesses at Nike Factory Store located at 917 

Lighthouse Place, Michigan City, IN 46360 , and Nike Inc. 

Headquarters located at One Bowerman Drive Beaverton, 

Oregon 97005-6453 

(1) 

USDC IN/ND case 3:16-cv-00588-RLM-MGG document 1 filed 09/02/16 page 1 of 26
PERSONAL JURISDICTION AND VENUE 

3. This action arises under the Title VII and by Section 1981 of the Civil 

Rights Act of 1964 Prohibits Race Discrimination Under Laws of the United 

States of America. Under Civil Rights Act of Title 42, US Code § 

1981(a)(1) Subsection (b) section 706 Civil Right Act of 1964. 

Under Federal laws 42 U.S.C Section 1983 and 1985 

This Court has personal jurisdiction of this action under Act 28 U.C. §§ 

1331 and 1338 (a). 

4. Venue is proper in this judicial district pursuant to 28 U.S.C §§ 1391 and 

1400(b) 

STATUE OF LIMITATION 

5. The Plaintiff's statue is proper under law of Title VII and by Section 

1981 of the Civil Rights Act 1964. Plaintiff has 4 years from the dated 

07 /19/16 of the discriminatory act to file his lawsuit_ Exhibit 2,p1 ,2,3. Exh 12 

INTRODUCTION 

6. The Defendants allegations for the Plaintiff's two 

design patents in letter dated: December 18, 2015 

stated this matter is closed. The Defendant clarified to Plaintiff's 

reference patent in question Mr. Beard ( U.S Patent No. 

3,281,863, "Garment Construction") being an expired utility patent, 

not a design patent. Exhibit oo, 02, 03. Exh1 p1 ,2 

(2) 

USDC IN/ND case 3:16-cv-00588-RLM-MGG document 1 filed 09/02/16 page 2 of 26
7. The Plaintiff's allegation Letter mailed of Tent for race 

discrimination on 07/19/16 referenced to Defendant for nonconsideration of Plaintiff' trademark logo Reg. No.4,343,916. 

8. The Defendant received letter on 07/22/16 Exhibit 01.EXH 2p1,2,3.Exh 12 

9. Plaintiff, Cross repeat and incorporate herein the entirety of the 

allegations contained in paragraphs 1 through 8 above. 

Plaintiff Claims for Title VII and by Section 1981 of the Civil 

Rights Act of 1964 Prohibits Race Discrimination 

Willful violations; false and misleading statements 

15 U.S. Code § 78ff - Penalties 

Indiana Dec ive Trade laws 35.,,43.5 .. 3 

2010 Indiana Code TITLE 23. BUSINESS AND OTHER 

ASSOCICATIONS ARTICLE 19. INDIANA UNIFORM 

SECURITIES ACT CHAPTER 5. FRAUD AND LIABILITIES 

CLAIM FOR RACE DISCRIMINATION 

COUNT 1 

10. The Plaintiff claims that the Defendant intentionally used the 

company's policy to protect the company from appearing to be 

discriminatory on the basis of race. However, the Defendant's 

dishonest statements and fraudulent conduct are deceptive 

trade practices and are contrary to the company's policy and as 

{3} 

USDC IN/ND case 3:16-cv-00588-RLM-MGG document 1 filed 09/02/16 page 3 of 26
a result has had an unlawful adverse impact on the Plaintiff on 

account of the Plantiff's race or color, by denying the Plaintiff, 

a black inventor the same effective product trade mark 

submission opportunities as afforded the Caucasians. Exh lpl,2 

COUNT2 

11. The Plaintiff claims the Defendant has a historic trail that failed 

to follow Defendant's own statement to follow its company's 

policy "in strict accord," over several years starting 

around 1984, up to and including 1990, 1997, 2012, 2015 

and any other similar matters therein. The Defendant did 

prefer Caucasion's trademarks, logos, marketing suggestions, 

out-side product submissions of ideas etc. that did not meet 

the guidelines listed in the company's policy anymore than 

the Plaintiff's. Therefore, the Plaintiff was denied the same 

submission opportunities. Exh Spl,2. Exh 

6p1,2,3. Exh7 pl,2,3. Exh 8p1,2 

COUNT3 

12. Plaintiff claims the Defendant refused Plaintiff's 

Design patent for product submission on the basis of the 

company's policy, letter dated: 12-18-15, "NIKE's refusal to 

consider your designs is "in strict accord" with the company's 

{4) 

USDC IN/ND case 3:16-cv-00588-RLM-MGG document 1 filed 09/02/16 page 4 of 26
• I 

policy regarding outside submissions of ideas." On the basis 

of the same company policy Defendant stated : "NIKE will not 

consider submissions of designs (including design patents}, 

artwork, advertising, marketing suggestions, copyright 

registrations, slogans, logos, brands, trademarks, or similar 

matters. Product submissions that do not meet the guidelines 

of our program are not considered."Exhlpl,2 Exh 4 pl,2 

COUNT4 

13. The Plaintiff claims the Defendant showed indifference in 

preferring the Caucasians over the Plaintiff by considering 

and accepting the Caucasians trademark out-side submissions 

without adhereing to its company policy "in strict accord." 

However, the Defendant did follow its company's policy "in strict 

accord" not to consider the Plaintiff's trademark out-side 

submissions. Both parties, the Plaintiff and the Caucasians 

submitted trademarks and logos outside the company's policy 

guidelines. But, the Defendant's discriminatory business 

practices intentionally favored one race over the other. See 

company's policy Exhibits 1 pl,2. Exh Spl. Exh Gpl,2,3. Exh7 

pl,2,3. Exh Spl,2 

(5) 

USDC IN/ND case 3:16-cv-00588-RLM-MGG document 1 filed 09/02/16 page 5 of 26
COUNT 5 

14. Plaintiff, claims that Defendant's willingly and wantonly circumvented 

the Plaintiff's due process in submitting out-side trademark 

submissions by use of its company's policy not to consider such 

submissions. The Defendant knowingly opened up the opportunity 

to prefer Caucasians out- side trademark submissions without 

adhereing to the company policy that acted as a barrier to keep out the 

undesireables. The Defendant's discriminatory business practices 

occurred on numerous occasions considering, accepting and 

purchasing 7 Caucasian out- side trademark submissions in 1984, 1990, 

1997, 2012, and 2015, against the Defendant's own statement to 

follow "in strict accord" its company policy shows unlawful intentional 

discrimination against the Plaintiff. Exh 4p1 ,2,3 Exh Spl. Exh 

6pl,2,3. Exh7 pl,2,3. Exh 8pl,2 

COUNT 6 

15. Plaintiff claims that Defendant failed to follow its own policies 

not one time but 7 times, before and after making the statement 

that the Defendant followed the company's policy "in strict 

accord," in 1984, up and including 1997, and 1990, 2012, and 

2015 . The Plaintiff claims the Defendant's concealed discrimination 

by using the company's policy. The Plaintiff claims 

(6) 

USDC IN/ND case 3:16-cv-00588-RLM-MGG document 1 filed 09/02/16 page 6 of 26
.. . ' 

herein to unveil the Defendant's deceitful, willful and wanton 

unlawful discriminatory business practices for the deceitful 

purpose of deceiving minorities. The Plaintiff claims the 

Defendant has deceived the Plaintiff of an equal opportunity to 

submit outside trademark submissions by using the company 

policy in a fraudulent and deceitful manner. The Defendant stated 

and defended in writing to follow the company's policy "in strict 

accord," when the Defendant knew the statement was untrue. 

The Plaintiff claims the Defendant own dishonest, deceitful, 

willful and wanton biased business practices has exposed the 

Defendant's true intent to prefer one race over the other. 

Exh Spl. Exh 6pl,2,3. Exh7 pl,2,3. Exh 8pl,2 

COUNT 7 

16. The Plaintiff claims Defendant also failed to honor company 

policy for their Product Submission Program against the Plaintiff. 

Exhibit 4p1 

COUNT 8 

17. Plaintiff Cross claims the Defendant knew that Plaintiff 

was an Black Inventor in letter dated 12-10-12. Exh 3p1,2,3 

(7) 

USDC IN/ND case 3:16-cv-00588-RLM-MGG document 1 filed 09/02/16 page 7 of 26
18. Plaintiff Cross claims the Defendant rejected Plaintiff's design 

patent for product submission on the basis of the company's 

policy, letter dated: 12-18-15, "NIKE's refusal to consider your 

designs is in strict accord with the company's policy regarding 

outside submissions of ideas." Yet, on the basis of same 

company policy, "NIKE will not consider submissions of 

designs(including design patents), artwork, advertising, 

marketing suggestions, copyright registrations, slogans, logos, 

brands, trademarks, or similar matters. Product submissions that 

do not meet the guidelines of our program are not considered." 

The Defendant preferred using 7 Caucasian trademark and logos 

out-side submission ideas that did not meet the company's 

guidelines. Exhibit 1,p1 ,2 Exh Spl. Exh 6pl,2,3. Exh7 pl,2,3. 

Exh Spl,2 

COUNT9 

19. Plaintiff claims that Defendant's showed racial discrimination 

because Defendant has a strong history to not follow the 

company's policy "in strict accord" with all races. The Defendant 

racially biased and fraudulent conduct using the company's 

policy as a deterrent to eliminate minorities out-side trademark 

(8) 

USDC IN/ND case 3:16-cv-00588-RLM-MGG document 1 filed 09/02/16 page 8 of 26
and logos products and prefer the Caucasian race, the 

Defendant therefore, violates the Civil Rights Act making 

racial bias clear against the Plaintiff. Exh Spl. Exh 6p1,2,3. 

Exh7 pl,2,3. Exh 8p1,2 

COUNT10 

20. Plaintiff claims that Defendant prefers not to consider Plaintiff's 

trademark or logo based on the Defendant's strict adherence to 

willfully and wantonly misrepresent its company's policy regarding 

out-side trademark submissions. Exhibit 1 p1 ,2 

COUNT 11 

21. Plaintiff claims the Defendant's willful, wanton, and fraudulent 

business practices herein, making formal written statements to 

follow its own policy concerning Plaintiff's out-side trademark 

submissions and failing to do the same with the Caucasians. 

The Plaintiff now disputes the creditability of the Defendant's 

statement made in letter dated: December 18, 2015; "NIKE now 

considers this matter closed. You should refrain from contacting 

us again regarding this or any other matters in the future." 

.Exhibit 1 p1,2, 

(9) 

USDC IN/ND case 3:16-cv-00588-RLM-MGG document 1 filed 09/02/16 page 9 of 26
COUNT12 

23. Plaintiff claims Defendant have violated Title VII and by 

Section1981 of the Civil Rights Act of 1964. Indiana 

Deceptive Trade Practice Law, and policy 

obligations 2010 Indiana Code TITLE 23. BUSINESS AND 

OTHER ASSOCIATIONS ARTICLE 19. INDIANA UNIFORM 

SECURITIES ACT CHAPTER 5. FRAUD AND LIABILITIES, and 

Willful violations; false and misleading statements 

15 U.S. Code§ 78ff- Penalties by making intimidating, 

threatening, and misleading statements about their Trademark 

and logos Product Submission Program. Exhibit1 p2. 4 

COUNT14 

25. Plaintiff Cross, has been damaged by such acts of race 

discrimination by the Defendant's Under Title VII and by 

Section 1981 of the CivilRights Act of 1964 

COUNT15 

26. Plaintiffs, Cross repeat and incorporate herein the entirety 

of the allegations contained in paragraphs 1 through 24 

above. 

(10) 

USDC IN/ND case 3:16-cv-00588-RLM-MGG document 1 filed 09/02/16 page 10 of 26
' l ' I! 

AUTHENTIC Z-ZIP-A-TEE TRADEMARK AND LOGO EXHIBIT 0 p.4 

26. NIKE INC. OUTSIDE SUBMISSION POLICY 

Nl!IB oillJ ron~iUern iOea~ !Ila! are em~oOieO in an i~~ueil uhlicy~a!en4 uillify moOel, or a 

renilin~non-~rovi~ional uhlifyralenl ar~lkalion !Ila! n~ Dem fileO wiili an ~rro~Ila!e 

iovemmenral a~en~J. NIKE\\~ not con1iller mOmi1!ion! of ~e!ion1 inclufilnu lle!i~ 

~' artwor~ aUverti~in~, marKe!in~ ~u~e~!ion~, w~~~l re~~traliofil, ~loiafil, loio~, 

~ranO~, traOemarh, or ~~liar mattern. ~roUud ~u~mii~iom !Ilat Oo no! meet !he ~iOeline~ of 

our ~ro~am are no! ~on~iUernU. 

Exh 4,p1,2,3, Exh 10, 11 

(11) 

USDC IN/ND case 3:16-cv-00588-RLM-MGG document 1 filed 09/02/16 page 11 of 26
27. NIKE INC. ACCEPT 7 OUTSIDE TRADEMARK 

SUBMISSIONS 

Plaintiff claims that Nike Inc. licensed a {Caucasian} Mr. Jacobus 

Rentmeester photo logos for $15,000 for "slide presentations only in 

1984. The invoice for the $15,000 payment indicated that the photo 

was to be used in "North America only" for 2 years, with all other rights 

reserved by Mr. Rentmeester. Please see the attachment below. Mr. 

Rentmeester Copyright Number see Exhibit 5 

Copyright# VA00019373723. 

(12) 

USDC IN/ND case 3:16-cv-00588-RLM-MGG document 1 filed 09/02/16 page 12 of 26
28. Plaintiff claims NIKE INC. had bought exclusive right to license for commercial 

purposes in 1997. Nike again paid for 8 more years in 2016 for the use of the 

names, symbols, emblems, designs, logo, identifications and uniforms of the 

NBA which is a (Caucasian Corporation). NIKE INC. License Deal with the NBA 

PAID 1 BILLION DOLLARS. See JIN EXHIBIT 6 

LEE/BLOOMBERG NATIONAL BASKETBALL ASSOICATION TRADEMARK AND 

LOGO. 

{13) 

USDC IN/ND case 3:16-cv-00588-RLM-MGG document 1 filed 09/02/16 page 13 of 26
29. Plaintiff claims NIKE INC. had bought exclusive right to license for 

commercial purposes in 1990. Nike again paid for 5 more years in 2012 

for the use of the names, symbols, emblems, designs, logo, trademark, 

to identifications and uniforms of the NFL which is a (Caucasian 

Corporation). Sport Business this week detailing the league's revenue 

sources said Nike PAID $1.1 billion to land the lucrative NFL apparel 

sponsorship. See Exhibit 7 

NATIONAL FOOTBALL LEAGUE TRADEMARK AND LOGO 

(14) 

USDC IN/ND case 3:16-cv-00588-RLM-MGG document 1 filed 09/02/16 page 14 of 26
30. Plaintiff claims NIKE INC. bought exclusive right 

to license for commercial purpose for the use of the 

names, symbols, emblems, designs, logo, trademark 

identifications and uniforms of the MLB which is a 

(Caucasian Corporation). NIKE INC. LICENSE MLB LEAGUE 

MAJOR LEAGUE BASEBALL TRADEMARK AND LOGO Exhibit 8 

(15) 

USDC IN/ND case 3:16-cv-00588-RLM-MGG document 1 filed 09/02/16 page 15 of 26
COLLEGIATE LICENSED PRODUCT 

TRADEMARK AND LOGO Exhibit 9 

31. Plaintiff claims that Nike Inc. bought exclusive rights to license for 

commercial purposes for the use of the names, symbols, emblems, 

designs, log91 trildemark identifications and uniforms of the which is a 

Collegiate company a {Caucasian Corporation}. Collegiate LICENSE with 

NIKE INC. 

(16) 

USDC IN/ND case 3:16-cv-00588-RLM-MGG document 1 filed 09/02/16 page 16 of 26
PRAYER FOR RELIEF 

Wherefore, The Plaintiff, Cross prays for Judgment against the Defendant 

on all counts and for the following claims for relief. 

Title VII and by Section 1981 of the Civil Rights Act of 1964. 

Willful violations; false and misleading statements 

15 U.S. Code§ 78ff - Penalties 

The Indiana Deceptive Trade laws (35--43-5-3 

2010 Indiana Code TITLE 23. BUSINESS AND OTHER 

ASSOCIATIONS ARTICLE 19. INDIANA UNIFORM SECURITIES 

ACT CHAPTER 5. FRAUD AND LIABILITIES 

CLAIM FOR RACE DISCRIMINATION 

. A. The Plaintiff Cross claims that the Defendant intentionally used the 

company's policy to protect the company from appearing to be 

discriminatory on the basis of race. However, the Defendant's 

dishonest statements and fraudulent unlawful business conduct 

proves to be contrary to the company's policy and has had an 

unlawful adverse impact on the Plaintiff, denying the Plaintiff, the 

same effective product trademark submission opportunities as the 

Caucasians. 

(17) 

USDC IN/ND case 3:16-cv-00588-RLM-MGG document 1 filed 09/02/16 page 17 of 26
• ' .... ' ti 

B. The Plaintiff claims the Defendant has a history of failing to 

follow "in strict accord" its own company policies concerning 

Caucasians trademarks, logos, marketing suggestions, outside 

product submissions of ideas etc. that does not meet the 

guidelines listed in the company's policy since1984, and includes 

1990, 1997, 2012, 2015 and any other similar matters therein, 

but did use the company policy to reject the Plaintiff the same 

opportunities. 

C. Plaintiff claims that Defendant failed to follow its own policies 

not one time but 7 times, before and after making the statement 

that the Defendant followed the company's policy "in strict 

accord," in 1984, up and including 1997, and 1990, 2012, and 

2015. The Plaintiff claims the Defendant's concealed 

discrimination by using the company's policy. The Plaintiff 

claims herein to unveil the Defendant's deceitful, willful and 

wanton unlawful discriminatory business practices for the 

deceitful purpose of deceiving minorities. The Plaintiff claims the 

Defendant has deceived the Plaintiff of an equal opportunity to 

submit outside trademark submissions by using the company policy 

in a fraudulent and deceitful manner. 

(18) 

USDC IN/ND case 3:16-cv-00588-RLM-MGG document 1 filed 09/02/16 page 18 of 26
'·' 

The Defendant stated and defended in writing to follow the 

company's policy "in strict accord," when the Defendant knew the 

statement was untrue. The Plaintiff claims the Defendant's own 

dishonest, deceitful, willful and wanton conduct has exposed the 

Defendant's fraudulent business practices that does intentionally 

prefer one race over the other. 

D. The Plaintiff claims the Defendant did consider 7 Caucasian 

trademark and logos outside product submission ideas that did 

not meet the company's detailed guidelines. The Plaintiff was 

refused consideration and the Caucasians was preferred and 

accepted. 

E. Plaintiff Cross claims upon Defendant learning that Plaintiff had 

submitted letter on 12/10/12 stating the Plaintiff was a Black 

Inventor, the Defendant refused to accept Plaintiff's trademark and 

logo for product submission by upholding company policy. 

However, the Defendant's decision to override company policy and 

perfer 7 Caucasian trademark and logos out-side submission idea, 

showed the Defendant indifference to people of color. 

(19) 

USDC IN/ND case 3:16-cv-00588-RLM-MGG document 1 filed 09/02/16 page 19 of 26
F. Plaintiff claims that Defendant fails to follow its own policies 

by perferring 7 Caucasian trademark and logos against their policy 

since 1984,1990, 1997,2015. Exhibit4,5, 6p1-3. 7p.1-3 

G. Plaintiff claims the Defendant has violated The Indiana 

Deceptive Trade laws (35-43-5-), Willful violations; false and misleading 

statements 15 U.S. Code § 78ff- by company policy 

making misleading statements about their Trademark and 

Logos Product Submission Program. Exhibit 4 

H. Plaintiff claims violated Title VII and by Section 1981 of the Civil 

Rights Act of 1964 Defendant has Violated Indiana Deceptive 

Trade laws (35-43-5-3 against the Plaintiff by intimidating, 

threatening, and making misleading statements on letter dated 

12/18/15 about their company policy. Exhibit 1 p1-2 

I. The Plaintiff claims Defendant also failed to honor 

company policy for Plaintiff Trademark, and logo Product 

Submission. Exhibit 4 p1 ,2,3,4 

J. Plaintiff Cross claims that Defendant's motive was to use 

the company's policy to mislead minorities from due process 

from submitting out-side submissions. Defendant's policy did 

(20) 

USDC IN/ND case 3:16-cv-00588-RLM-MGG document 1 filed 09/02/16 page 20 of 26
not interfere with Defendant's decision from preferring 7 

out- side trademark or logo submission by Caucasian 

members in 1984,1990,2012, and 2015.Exhibit 5, 6p1-3,7p1-3-8p1,2,3 

K. Plaintiff claims that Defendant failed to consider James 

Cross, who is Black Inventor and then subsequently 

denied him, because of Plaintiff's race. Exhibit 3 

L. Plaintiff Cross claims the Defendant rejected Plaintiff's design 

patent for product submission on the basis of the company's 

policy, letter dated: 12-18-15, "NIKE's refusal to consider your 

designs is in strict accord with the company's policy regarding 

outside submissions of ideas." In addition, same 

company policy, "NIKE will not consider submissions of 

designs(including design patents), artwork, advertising, 

marketing suggestions, copyright registrations, slogans, logos, 

brands, trademarks, or similar matters. Product submissions 

that do not meet the guidelines of our program are not 

considered." The Defendant preferred 7 Caucasian trademark 

and logos out- side submission ideas that did not meet the 

company's guidelines over the Plaintiff. Exhibit 1p1,2. 4,5,6 p1-3.-7p.1-3 

(21) 

USDC IN/ND case 3:16-cv-00588-RLM-MGG document 1 filed 09/02/16 page 21 of 26
M. Plaintiff claims the Defendant failed to follow its own 

policy concerning Plaintiff's trademark out-side submissions. 

Therefore, Plaintiff disputes the Defendant's statement made 

in letter Dated: December 18, 2015; "NIKE now considers this 

matter closed. You should refrain from contacting us again 

regarding this or any other matters in the future" Exhibit 1 p1 ,2 

N. Plaintiff Cross claims upon Defendant receiving information that 

Plaintiff was Black Inventor on 12/10/12. The Defendant refused 

to accept Plaintiff trademark and logo for product submission. The 

Defendant's did override the company's strict adherence to company 

policy and perferred 7 Caucasian trademark and logos out-side 

submission ideas, discriminating against the Plaintiff, staying "in strict 

accord" to the Plaintiff's out-side trademark submission. 

0 . Plaintiff claims that Defendant showed racially biased 

discrimination because Defendant has a strong history to not 

follow the company's policy "in strict accord" in the same 

manner with all races. The Defendant racially biased and fraudulent 

business conduct using the company's policy proved to be 

a successful deterrent to 

(22) 

USDC IN/ND case 3:16-cv-00588-RLM-MGG document 1 filed 09/02/16 page 22 of 26
eliminate the Plaintiff, a minority's out-side trademark 

submission. Plaintiff claims that Defendant refusal to consider 

James Cross Z-Zip-A-Tee trademark logo based on their strict false 

misrepresentation of its company's policy regarding trademark, and 

logos out-side submission is unlawful and discriminatory business 

practices. 

Q. As Plaintiffs claims actions do not constitute a violation of 

Defendant company policy such actions by Defendant are 

in violation of Plaintiff Title VII and by Section 1981 of 

the Civil Rights Act of 1964. Under 201 o Indiana Code 

TITLE 23. BUSINESS AND OTHER ASSOCIATIONS ARTICLE 19. 

INDIANA UNIFORM SECURITIES ACT CHAPTER 5. FRAUD AND 

LIABILITIES. The Indiana Deceptive Trade laws (35-43-5-3 

Willful violations; false and misleading statements 

15 U.S. Code§ 78ff-Penalties. 

R. Plaintiff be granted a declaratory judgment under Title 

VII and by Section 1981 of the Civil Rights Act of 1964 

respect to Defendant's allegations of company policy. 

(23) 

USDC IN/ND case 3:16-cv-00588-RLM-MGG document 1 filed 09/02/16 page 23 of 26
S. Plaintiff be granted an immediate and permanent 

injunction preventing Defendant from interfering with 

Plaintiffs business; and in the alternative, that 

T. Plaintiffs be awarded unspecified monetary damage 

included lost profit and benefit of ($500,000,000.00) 

Five Hundred Million Dollars for each time Defendant 

use out-side trademark submission that Defendant 

accepted under their company policy. 

U. The Plaintiff be award punitive damages as 

allowed in subsection (b) of this section, in addition 

to any relief authorized by section 706(g) of the 

Civil Rights Act of 1964. _Willful violations; false and 

misleading statements 15 U.S. Code§ 78ff - Penalties 

V. Plaintiff ask that the jury awards punitive damages to 

the Sum of One Billion Dollars. ($1,000,000,000.00) 

because the Defendant's intentional willfull and 

(24) 

USDC IN/ND case 3:16-cv-00588-RLM-MGG document 1 filed 09/02/16 page 24 of 26
wanton, egregiously, and insidious unlawful business 

practices. 

W. Award of Cross' costs and expenses, and 

X. Such other and further relief as this Court matter 

proper, just and equitable. 

Y. Any other remedy this Court determines is just. 

Z. The Plaintiff prays for trial by jury. 

I hereby declare under penalty of perjury that the fore going is true 

and correct. Executed Michigan City, Indiana on 09/02/16 

I f 

~ Ja' es Cross Pro'se 

( 20 Glencove Dr. 

ichigan City, IN 46360 

219-879-1620 

2195613251 

zipatee55@att.net or zipatee60@att.net 

(25) 

USDC IN/ND case 3:16-cv-00588-RLM-MGG document 1 filed 09/02/16 page 25 of 26
CERTIFICATE OF SERVICE 

I hereby certify that on 02 day of September 2016, I caused a 

copy of the foregoing document to be mailed by United States 

Postal Service to the following participants: 

(26) 

Mr. Brian Forgarty 

Nike Inc. 

One Bowerman Drive 

Beaverton, Oregon 97005 

USDC IN/ND case 3:16-cv-00588-RLM-MGG document 1 filed 09/02/16 page 26 of 26