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IN THE UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

SUPERHYPE TAPES, LTD.,

Plaintiff,

v.

THE PARTNERSHIPS AND 

UNINCORPORATED ASSOCIATIONS 

IDENTIFIED ON SCHEDULE “A”,

Defendants.

Civil Action No.: 20-CV- 1589

COMPLAINT

Plaintiff, Superhype Tapes, Ltd. (“Superhype” or “Plaintiff”), by its undersigned counsel, 

hereby complains of the Partnerships and Unincorporated Associations identified on Schedule “A”

attached hereto (collectively, “Defendants”), and for its Complaint hereby alleges as follows:

INTRODUCTION

1. This action has been filed to combat the online trademark and copyright infringement

and counterfeiting of Defendants, who trade upon Plaintiff’s valuable trademark and copyrights by 

selling and/or offering for sale unauthorized, unauthentic, and counterfeit products in connection 

with Plaintiff’s federally registered trademark, as well as to stop and prevent Defendants’ selling of 

unauthorized products that use, are based on, and/or are derived from copyrighted subject matter 

created by Superhype. 

2. Plaintiff, Superhype Tapes, Ltd., is the owner of the federally registered Led

Zeppelin Trademarks, United States Trademark Registration No.s 4,340,692, 2,212,548, and 

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5,663,514 (referred to as the “Led Zeppelin Trademarks”) that covers the Led Zeppelin Products. 

The Registrations are valid, subsisting, and in full force and effect. A true and correct copy of the 

Registrations are attached hereto as Exhibit 1. Plaintiff is the owner of Copyright Registration Nos.

RE0000767432, RE0000767430, RE0000767435, RE0000767431, RE0000864464, 

RE0000767434, CSN0016803, CSN0016803, TX0008510562, TX0008510571, VAu001334047, 

PA0001941359, V3579D644, V3579D669, V3578D670, PAu002432643, VA0000591297, 

TX0000303053, TX0003080509, PA0000872283, SR0000174356, PA0000922942, 

RE0000767433, VAu001200331, VA0002042824, V3608D159, VA0000111211, V3612D614, 

V3578D670, V3579D669, V3608D159, V3608D159, V3608D159, V3608D159, V3608D159, 

PA0001995940, TXu000769890, TX0001281713, TX0007349298, V9935D314, V3620D258, 

VAu000083702, VA0000473995, V9926D277, V3510D110, PA0000718030, VAu001332137, 

V1744P359, RE0000840976, V1740P027, RE0000840977, RE0000840975, RE0000840986, 

RE0000840979, RE0000840980, RE0000840983, RE0000840981, RE0000840982, 

RE0000840984, RE0000840978, RE0000840985, TX0006937190, 0PA0001817015, V3446D287, 

V9957D007, V3527D039, PA0001383869, TX0008787718, CSN0098988, CSN0098988, 

VA0001734853, SR0000392357, SRu000625956, SRu000625959, V3609D139, TX0006273641, 

SRu000447667, TX0007164062, TX0007150962, VAu001308954, VA0000971257, 

VA0001292295, TX0003354252, RE0000840965, RE0000840961, RE0000840963, 

RE0000840962, RE0000840964, RE0000840966, RE0000767443, RE0000767440, V3578D670, 

V3579D644, V3579D669, RE0000767441, RE0000767439, PA0000872284, RE0000767442, 

RE0000767438, RE0000767437, RE0000767436, V9926D277, V3510D110, PA0001927748, 

V3579D644, V3578D670, V9926D277, V3510D110, PA0001926616, TX0001011575, 

VA0000047617, TX0004757756, V9932D170, V3579D644, V9926D277, V3579D669, 

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V3578D670, V3510D110, VA0000473967, V3612D588, V3473D415, TX0004010168, 

VAu001170110, VAu001170113, VAu001332953, TX0007990030, V3607D880, TX0001997258, 

TX0001788857, PA0000718016, SR0000626433, VAu000690000, VAu001170117, V3612D620, 

V3612D620, V3612D620, V3612D620, V3612D620, V3612D620, V3612D620, V3612D620, 

V3612D620, V3612D620, V3612D620, VAu001170114, VAu001170115, TX0007600661, 

V3532D501, VA0002080775, TX0000514805, VAu001170118, VAu001170112, PA0000930775, 

and TX0007324857, which have effective registration dates as early as 1969, and are attached 

hereto as Exhibit 2 (hereinafter referred to as the “Led Zeppelin Copyrights”).

3. In an effort to illegally and deceptively profit from the Led Zeppelin Trademarks and 

Led Zeppelin Copyrights, Defendants created numerous Seller Aliases and online stores (referred to 

as “Defendant Internet Stores”), intentionally designed in look, feeling, and suggestion to give the 

impression to consumers that they are legitimate websites selling authorized Led Zeppelin Products, 

with Defendants’ ultimate intention being to deceive unknowing consumers into purchasing 

Counterfeit Led Zeppelin Products. 

4. Defendant Internet Stores share numerous unique identifiers, such as design elements

and similarities of the unauthorized products offered for sale, establishing a logical relationship 

between Defendants, and suggesting that Defendants’ illegal operations arise out of the same 

transaction, occurrence, or series of transactions or occurrences. Defendants attempt to avoid liability 

by going to great lengths to conceal both their identities and the full scope and interworking of their 

illegal operation. 

5. Plaintiff is forced to file this action to combat Defendants’ ongoing infringement of 

Plaintiff’s Led Zeppelin Trademarks and Led Zeppelin Copyrights (collectively referred to as “Led 

Zeppelin Intellectual Property” or “Led Zeppelin IP”). Plaintiff has been and continues to be 

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irreparably damaged through consumer confusion, dilution, loss of control over the creative 

content, and tarnishment of its valuable trademarks and copyrights as a result of Defendants’ 

actions and is thus seeking injunctive and monetary relief.

JURISDICTION AND VENUE

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

pursuant to the provisions of the Lanham Act, 15 U.S.C. § 1051 et seq., the Federal Copyright Act, 

17 U.S.C. § 101, et seq., 28 U.S.C. § 1338(a)–(b), and 28 U.S.C. § 1331. This Court has jurisdiction 

over the claims in this action that arise under the laws of the State of Illinois pursuant to 28 U.S.C. 

§ 1367(a), because the state law claims are so related to the federal claims that they form part of 

the same case or controversy and derive from a common nucleus of operative facts.

7. This Court has personal jurisdiction over each Defendant, in that each Defendant 

conducts significant business in Illinois and in this Judicial District, and the acts and events giving 

rise to this lawsuit, of which each Defendant stands accused, were undertaken in Illinois and within

this Judicial District.

8. Venue is proper in this Court pursuant to 28 U.S.C. § 1391, since each Defendant 

directly targets consumers in the United States, including Illinois, through the fully interactive,

commercial Internet stores operating under the Defendant Seller Aliases and/or the Online 

Marketplace Accounts identified in Schedule “A.” Each of the Defendants has targeted sales from 

Illinois residents by operating online stores that offer shipping to the United States, including 

Illinois, accept payment in U.S. dollars and, on information and belief, has sold, and continues to 

sell counterfeit products that infringe Plaintiff’s trademarks and/or copyrights. Each Defendant is 

committing tortious acts, is engaging in interstate commerce, and has wrongfully caused 

substantial injury in the State of Illinois.

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THE PLAINTIFF

9. Superhype Tapes, Ltd. is a sound recording and music publishing company founded 

in 1968, by members of Led Zeppelin, an internationally recognized rock band that formed in 1968

in London, England. Through years of hard work, dedication, and incredible talent, Led Zeppelin 

became one of the most successful artists of all time. Due to this success, and the reputation and 

status that it has cultivated, the Led Zeppelin name and works have become invaluable.

10. Superhype Tapes, Ltd. is in the business of creating, developing, marketing, and 

licensing Led Zeppelin Products, including albums, recordings, apparel, and memorabilia. 

11. Superhype Tapes, Ltd. is the licensor of all Led Zeppelin products available in 

stores and on various e-commerce platforms, as for example, on store.ledzeppelin.com/allproducts:

https://store.ledzeppelin.com/all-products

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12. The Led Zeppelin Trademarks have been used exclusively by Superhype Tapes, Ltd., 

and have never been abandoned. The Led Zeppelin registrations are valid, subsisting, and in full 

force and effect. The registrations of the Led Zeppelin Trademarks constitutes prima facie evidence 

of their validity and of Superhype Tapes, Ltd.’s exclusive right to use the Led Zeppelin Trademarks

pursuant to 15 U.S.C. § 1057(b). 

13. Superhype has invested substantial time, money, and effort in building up and

developing consumer recognition, awareness, and goodwill in the Led Zeppelin Products.

14. The success of the Led Zeppelin Products is due in large part to the marketing, 

promotional, and distribution efforts of Superhype. These efforts include advertising and promotion 

through ledzeppelin.com, and other retailer websites, and are conducted through internet-based 

advertising, print, and other efforts both in the United States and internationally.

15. The success of the Led Zeppelin Brand is also due to the use of high-quality materials 

and processes in making the Led Zeppelin Products. 

16. Additionally, Superhype owes a substantial amount of the success of the Led 

Zeppelin Products to its licensees, consumers, and interest that its consumers have generated. 

17. As a result of the efforts of Superhype, the quality of its Led Zeppelin Products, the

promotional efforts for its products and designs, press and media coverage, and members of the 

public, have become familiar with the Led Zeppelin Products, Led Zeppelin Copyrights, and Led 

Zeppelin Trademarks, and associate them exclusively with Superhype.

18. Superhype Tapes, Ltd. has made efforts to protect its interests in and to the Led 

Zeppelin Intellectual Property. Superhype Tapes, Ltd. and its licensees are the only businesses 

and/or individuals authorized to manufacture, import, export, advertise, offer for sale, or sell any 

goods utilizing the Led Zeppelin Copyrights and/or Led Zeppelin Trademarks, without the express 

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written permission of Superhype Tapes, Ltd.. Plaintiff has not licensed or authorized Defendants to 

use the Led Zeppelin Trademarks and Copyrights.

THE DEFENDANTS

19. Defendants are individuals and business entities who, upon information and belief, 

reside in foreign jurisdictions, including the People’s Republic of China, Indonesia, Thailand, 

Vietnam, Singapore, and Malaysia. Defendants conduct business throughout the United States, 

including Illinois, and within this Judicial District, through the operation of fully interactive 

commercial websites and online marketplaces operating under the Defendant Internet Stores. Each 

Defendant targets the United States, including Illinois, and has offered to sell and, on information 

and belief, has sold and continues to sell unauthorized and/or counterfeit Led Zeppelin Products to 

consumers within the United States, Illinois, and this Judicial District.

THE DEFENDANTS’ UNLAWFUL CONDUCT

20. The success and widespread popularity and recognition of the Led Zeppelin Brand

and Led Zeppelin Products has resulted in significant counterfeiting and intentional copying. 

Plaintiff has identified numerous domain names linked to fully interactive websites and marketplace 

listings on platforms such as eBay, Amazon, Wish, and AliExpress, including the Defendant Internet 

Stores, which are offering for sale, selling, and importing counterfeit Led Zeppelin Products to 

consumers in this Judicial District and throughout the United States. Internet websites like the 

Defendant Internet Stores are estimated to receive tens of millions of visits per year and to generate 

over $135 billion in annual online sales. According to an intellectual property rights seizures 

statistics report issued by Homeland Security, the manufacturer’s suggested retail price (MSRP) of 

goods seized by the U.S. government in the fiscal year 2013 was over $1.74 billion, up from $1.26 

billion in 2012. Internet websites like the Defendant Internet Stores are also estimated to contribute 

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to tens of thousands of lost jobs for legitimate businesses and broader economic damages such as

lost tax revenue every year. 

21. As recently addressed in the Wall Street Journal, Fortune, and the New York Times, 

and as reflected in the federal lawsuits filed against sellers offering for sale and selling infringing 

and/or counterfeit products on the above mentioned digital marketplaces, an astronomical number 

of counterfeit and infringing products are offered for sale and sold on these digital marketplaces at a 

rampant rate. See Kathy Chu, Luxury brands get tougher with counterfeiters – and Alibaba, 

MARKETWATCH (Aug. 16, 2016), http://www.marketwatch.com/story/luxury-brands-gettough-with-counterfeiters-2016-08-16-91031611; Gilian Wong, Alibaba Sued Over Alleged 

Counterfeits, WALL STREET JOURNAL (May 17, 2015), http://www.wsj.com/articles/alibabasued-over-alleged-counterfeits-1431877734; Scott Cendrowski, There’s no end in sight for 

Alibaba’s counterfeit problem, FORTUNE (May 18, 2015), http://fortune.com/2015/05/18/theresno-end- in-sight-for-alibabas-counterfeit-problem/. 

22. Upon information and belief, Defendants facilitate sales by designing the Internet 

Stores to appear to unknowing consumers to be authorized online retailers, outlet stores, or 

wholesalers selling genuine Led Zeppelin Products through the use of Led Zeppelin Intellectual 

Property. Defendant Internet Stores look sophisticated and perpetuate an illusion of legitimacy –

they accept payment in U.S. dollars via credit cards, Western Union, and PayPal; they often include 

images and design elements that make it difficult for consumers to distinguish these unauthorized

sites from an authorized website; they offer “live 24/7” customer service; and, they use indicia of 

authenticity and security that consumers have come to associate with authorized retailers, including 

the McAfee® Security, VeriSign®, Visa®, MasterCard®, and PayPal® logos. 

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23. Upon information and belief, Defendants also deceive unknowing consumers by 

using the Led Zeppelin Trademarks without authorization within the content, text, and/or meta tags 

of their websites, in order to attract and manipulate search engines into identifying Defendants’

Online Stores as legitimate websites for Led Zeppelin Products. Defendants also employ other 

unauthorized search engine optimization (“SEO”) tactics and social media spamming so that 

Defendant Internet Stores show up at or near the top of relevant search results, including tactics to 

propel new domain names to the top of search results after others are shut down. These tactics are 

meant to, and are successful in, misdirecting consumers who are searching for genuine Led 

Zeppelin Products. 

24. There is a substantial evidentiary overlap in Defendants’ acts of infringement, thus 

constituting a collective enterprise.

25. Defendants go to great lengths to conceal their identities and often use multiple 

fictitious names and addresses to register and operate their massive network of Defendant Internet 

Stores. For example, many of Defendants’ names and physical addresses used to register the 

Defendant Domain Names are incomplete, contain randomly typed letters, or fail to include cities 

or states. Other Defendant Domain Names use privacy services that conceal the owners’ identity and 

contact information. Upon information and belief, Defendants regularly create new websites and 

online marketplace accounts on various platforms using the identities listed in Schedule “A” of the 

Complaint, as well as other unknown fictitious names and addresses. Such Defendant Internet Store 

registration patterns are one of many common tactics used by Defendants to conceal their identities, 

the full scope and interworking of their massive infringing operation, and to avoid being shut down.

26. Even though Defendants operate under multiple fictitious names, there are numerous 

similarities among the Defendant Internet Stores, including, but by no means limited to: (1) virtually 

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identical layouts, even though different aliases were used to register the respective domain names, (2) 

similarities of the unauthorized and/or counterfeit Led Zeppelin Products, and indicia of being related 

to one another, suggesting that the illegal products were manufactured by and come from a common 

source and that, upon information and belief, Defendants are interrelated, and (3) other notable 

common features such as use of the same domain name registration patterns, unique shopping cart 

platforms, accepted payment methods, check-out methods, meta data, illegitimate SEO tactics, 

HTML user-defined variables, domain redirection, lack of contact information, identically or 

similarly priced items and volume sales discounts, similar hosting services, similar name servers, 

and the use of the same text and images. 

27. Further, illegal operators, like Defendants, typically operate multiple credit card 

merchant accounts and third-party payment processor accounts, such as PayPal accounts, behind 

layers of payment gateways so they can continue operation in spite of any enforcement efforts. Upon 

information and belief, and as PayPal transaction logs in previous similar cases have shown, 

Defendants maintain off-shore bank accounts and regularly move funds from their PayPal accounts 

to off-shore bank accounts outside the jurisdiction of this Court. 

28. Defendants, without any authorization or license, have knowingly and willfully 

infringed the Led Zeppelin Trademarks and Copyrights in connection with the advertisement, 

distribution, offering for sale, and sale of illegal, infringing, and counterfeit products into the 

United States and Illinois. Each Defendant Internet Store offers to ship to the United States, 

including Illinois, and, on information and belief, each Defendant has offered to sell, or has already 

sold, infringing products therein.

29. In committing these acts, Defendants have, among other things, willfully and in bad 

faith committed the following, all of which have and will continue to cause irreparable harm to the 

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Led Zeppelin Brand: infringed upon and counterfeited the Led Zeppelin Trademarks and Led 

Zeppelin Copyrights; created, manufactured, sold, and/or offered to sell counterfeit products and/or 

products which infringe upon the Led Zeppelin Intellectual Property; used the Led Zeppelin IP in an 

unauthorized manner in order to sell, advertise, describe, mislead, disceive, and trade upon the Led 

Zeppelin Brand; engaged in unfair competition; and unfairly and unjustly profited from such 

activities at the expenses of Superhype Tapes, Ltd..

30. Unless enjoined, Defendants will continue to cause irreparable harm to Superhype 

Tapes, Ltd..

COUNT I

TRADEMARK INFRINGEMENT AND COUNTERFEITING (15 U.S.C. § 1114) 

31. Plaintiff repleads and incorporates by reference each and every allegation set forth 

in the preceding paragraphs as if fully set forth herein. 

32. This is a trademark infringement action against Defendants, based on their 

unauthorized use in commerce of counterfeit imitations of Plaintiff’s federally registered 

Trademarks in connection with the sale, offering for sale, distribution, and/or advertising of 

infringing goods.

33. Without the authorization or consent of Superhype, and with knowledge of

Superhype’s well-known ownership rights in its Led Zeppelin Trademarks, and with knowledge 

that Defendants’ Counterfeit Products bear counterfeit marks, Defendants intentionally 

reproduced, copied, and/or colorably imitated the Led Zeppelin Trademarks and/or used spurious 

designations that are identical with, or substantially indistinguishable from, the Led Zeppelin

Trademarks on or in connection with the manufacturing, import, export, advertising, marketing, 

promotion, distribution, display, offering for sale, and/or sale of Counterfeit Products. 

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34. Defendants have manufactured, imported, exported, advertised, marketed, 

promoted, distributed, displayed, offered for sale, and/or sold their Counterfeit Products to the 

purchasing public in direct competition with Superhype and the Led Zeppelin Products, in or 

affecting interstate commerce, and/or have acted with reckless disregard of Plaintiff’s rights in and 

to the Led Zeppelin Trademarks through their participation in such activities. 

35. Defendants have applied their reproductions, counterfeits, copies, and colorable 

imitations of the Led Zeppelin Trademarks to packaging, point-of-purchase materials, promotions, 

and/or advertisements intended to be used in commerce upon, or in connection with, the 

manufacturing, importing, exporting, advertising, marketing, promoting, distributing, displaying, 

offering for sale, and/or selling of Defendants’ Counterfeit Products, which is likely to cause 

confusion, mistake, and deception among the general purchasing public as to the origin of the 

Counterfeit Products, and is likely to deceive consumers, the public, and the trade into believing 

that the Counterfeit Products sold by Defendants originate from, are associated with, or are 

otherwise authorized by Superhype Tapes, Ltd., through which Defendants make substantial 

profits and gains to which they are not entitled in law or equity.

36. Defendants’ unauthorized use of the Led Zeppelin Trademarks on or in connection 

with the Counterfeit Products was done with notice and full knowledge that such use was not 

authorized or licensed by Superhype Tapes, Ltd., and with deliberate intent to unfairly benefit from 

the incalculable goodwill inherent in the Led Zeppelin Trademarks. 

37. Defendants’ actions constitute willful counterfeiting of the Led Zeppelin

Trademarks in violation of 15 U.S.C. §§ 1114(1)(a)-(b), 1116(d), and 1117(b)-(c). 

38. Defendants’ continued intentional use of the Led Zeppelin Trademarks without the 

consent or authorization of Superhype Tapes, Ltd., constitutes intentional infringement of

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Superhype Tapes, Ltd.’s federally registered Led Zeppelin Trademarks in violation of §32 of the

Lanham Act, 15 U.S.C. § 1114. 

39. As a direct and proximate result of Defendants’ illegal actions alleged herein, 

Defendants have caused substantial monetary loss, irreparable injury, and damage to Superhype 

Tapes, Ltd., its business, its reputation, and its valuable rights in and to the Led Zeppelin

Trademarks and the goodwill associated therewith, in an amount as yet unknown. Superhype 

Tapes, Ltd. has no adequate remedy at law for this injury, and unless immediately enjoined, 

Defendants will continue to cause such substantial and irreparable injury, loss, and damage to 

Superhype Tapes, Ltd. and its valuable Led Zeppelin Trademarks. 

40. Based on Defendants’ actions as alleged herein, Superhype Tapes, Ltd. is entitled 

to injunctive relief, damages for the irreparable harm that Superhype Tapes, Ltd. has sustained, 

and will sustain, as a result of Defendants’ unlawful and infringing actions, as well as all gains, 

profits, and advantages obtained by Defendants as a result thereof, enhanced discretionary 

damages, treble damages, and/or statutory damages of up to $2,000,000 per-counterfeit mark pertype of goods sold, offered for sale, or distributed, and reasonable attorneys’ fees and costs. 

COUNT II

FALSE DESIGNATION OF ORIGIN, PASSING OFF, & UNFAIR COMPETITION

(15 U.S.C. § 1125(a)/LANHAM ACT § 43(a))

41. Plaintiff repleads and incorporates by reference each and every allegation set forth 

in the preceding paragraphs as if fully set forth herein.

42. Plaintiff, as the owner of all right, title, and interest in and to the Led Zeppelin

Trademarks, has standing to maintain an action for false designation of origin and unfair 

competition under the Federal Trademark Statute, Lanham Act § 43(a) (15 U.S.C. § 1125). 

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43. Plaintiff’s Trademarks are inherently distinctive and is registered with the United 

States Patent and Trademark Office on the Principal Register; the Led Zeppelin Trademarks have

been continuously used and never abandoned; the registrations for the Led Zeppelin Trademarks 

are valid, subsisting, and in full force and effect; and incontestable pursuant to 15 U.S.C. § 1065.

44. Defendants’ promotion, marketing, offering for sale, and sale of infringing Led 

Zeppelin Products has created and continues to create a likelihood of confusion, mistake, and 

deception among the public as to the affiliation, connection, or association with Plaintiff or as to the 

origin, sponsorship, or approval of Defendants’ infringing products by Plaintiff.

45. By using the Led Zeppelin Trademarks in connection with the sale of unauthorized 

products, Defendants create a false designation of origin and a misleading representation of fact 

as to the origin and sponsorship of the unauthorized products.

46. Defendants’ false designation of origin and misrepresentation of fact as to the origin 

and/or sponsorship of the unauthorized products to the general public is a willful violation of 

Section 43 of the Lanham Act, 15 U.S.C. § 1125.

47. Upon information and belief, Defendants’ aforementioned wrongful actions have 

been knowing, deliberate, willful, and intended to cause confusion, to cause mistake, and to 

deceive the purchasing public, with the intent to trade on the goodwill and reputation of Superhype 

Tapes, Ltd., its Led Zeppelin Products, and the Led Zeppelin Trademarks. 

48. As a direct and proximate result of Defendants’ aforementioned actions, 

Defendants have caused irreparable injury to Superhype Tapes, Ltd. by depriving Plaintiff of sales 

of its Led Zeppelin Products and by depriving Superhype Tapes, Ltd. of the value of its Led 

Zeppelin Trademarks as commercial assets in an amount as yet unknown.

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49. Plaintiff has no adequate remedy at law and, if Defendants’ actions are not enjoined, 

Plaintiff will continue to suffer irreparable harm to its reputation and the goodwill of its brand.

COUNT III

VIOLATION OF ILLINOIS UNIFORM DECEPTIVE TRADE PRACTICES ACT

(815 ILCS § 510, et seq.)

50. Plaintiff repleads and incorporates by reference each and every allegation set forth 

in the preceding paragraphs as if fully set forth herein.

51. Defendants have engaged in acts violating Illinois law, including, but not limited 

to, passing off their unauthorized products as those of Plaintiff, causing a likelihood of confusion 

and/or misunderstanding as to the source of Defendants’ goods, thus causing a likelihood of 

confusion and/or misunderstanding as to an affiliation, connection, or association with genuine 

Led Zeppelin Products, through Defendants’ representation that Defendants’ Counterfeit Products

have Plaintiff’s approval, when they do not.

52. The foregoing Defendants’ acts constitute a willful violation of the Illinois Uniform 

Deceptive Trade Practices Act, 815 ILCS § 510, et seq..

53. Plaintiff has no adequate remedy at law, and Defendants’ conduct has caused 

Plaintiff to suffer damage to its reputation and goodwill. Unless enjoined by the Court, Plaintiff

will suffer future irreparable harm as a direct result of Defendants’ unlawful activities.

COUNT IV

COPYRIGHT INFRINGEMENT (17 U.S.C. § 501(a))

54. Plaintiff repleads and incorporates by reference each and every allegation set forth 

in the preceding paragraphs as if fully set forth herein.

55. The Led Zeppelin Copyrights are the subject of multiple valid copyright 

registrations.

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56. Plaintiff, at all relevant times, has been the holder of the copyright registrations,

and exclusive rights, of and belonging to Led Zeppelin and Superhype Tapes, Ltd., including, but 

not limited to, the Led Zeppelin Copyrights and derivative works. 

57. The Led Zeppelin Copyrights have significant value and have been produced and 

created at considerable expense. 

58. The trademarked and copyrighted products include a copyright notice advising the 

general public that the Led Zeppelin Products are protected by the Copyright Laws of the United 

States.

59. Upon information and belief, Defendants had access to the copyrighted work 

through Plaintiff’s normal business activities. After accessing Plaintiff’s work, Defendants 

wrongfully created copies of the copyrighted work without Plaintiff’s consent, and engaged in, 

and continue to engage in acts of widespread infringement. 

60. Superhype Tapes, Ltd. is informed, and thereon alleges, that Defendants further 

infringed Led Zeppelin Copyrights by making, or causing to be made, derivative works by 

producing and distributing unauthorized reproductions of the Led Zeppelin Copyrights, without

permission of Superhype Tapes, Ltd..

61. Each Defendant, without the permission or consent of the Plaintiff, has sold, and 

continues to sell, online infringing derivative works of Plaintiff’s Copyrights. Each Defendant has 

violated Plaintiff’s exclusive rights of reproduction and distribution. Each Defendant’s actions 

constitute an infringement of Plaintiff’s exclusive rights protected under the Copyright Act (17 

U.S.C. §101 et seq.).

62. Further, as a direct result of the Defendants’ acts of copyright infringement, 

Defendants have obtained profits they would not have otherwise realized but for their infringement

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of Plaintiff’s Copyrights. Superhype Tapes, Ltd. is entitled to disgorgement of Defendants’ profits, 

directly and indirectly, attributable to said infringement. 

63. As a result of each Defendant’s infringement of Plaintiff’s exclusive rights under 

U.S. Copyright Law, Plaintiff is entitled to relief pursuant to 17 U.S.C. §504.

64. The conduct of each Defendant is causing and, unless enjoined and restrained by 

this Court, will continue to cause Plaintiff great and irreparable injury that cannot fully be 

compensated or measured monetarily. Plaintiff has no adequate remedy at law. As such, pursuant 

to 17 U.S.C. §§502 and 503, Plaintiff is entitled to injunctive relief prohibiting each Defendant 

from further infringing Plaintiff’s Copyrights, and ordering that each Defendant destroy all 

unauthorized and/or infringing copies and reproductions of Plaintiff’s Copyrighted works.

Defendants’ copies, plates, and other embodiments of the copyrighted work from which copies 

can be reproduced should be impounded and forfeited to Superhype Tapes, Ltd. as instruments of 

infringement, under 17 U.S.C §503. 

PRAYER FOR RELIEF

WHEREFORE, Plaintiff requests judgment against Defendants as follows:

1) That Defendants, their affiliates, officers, agents, servants, employees, attorneys, 

confederates, and all persons acting for, with, by, through, under, or in active concert with them 

be temporarily, preliminarily, and permanently enjoined and restrained from:

a. using the Led Zeppelin Trademarks or any reproductions, copies, or colorable 

imitations thereof, in any manner in connection with the distribution, marketing, 

advertising, offering for sale, or sale of any product that is not an authorized Led 

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Zeppelin Product, or is not authorized by Plaintiff to be sold in connection with the 

Led Zeppelin Trademarks or Led Zeppelin Copyrights;

b. passing off, inducing, or enabling others to sell or pass off any product not produced 

under the authorization, control, or supervision of Plaintiff and approved by Plaintiff

for sale under the Led Zeppelin Trademarks or Led Zeppelin Copyrights;

c. shipping, delivering, holding for sale, transferring, or otherwise moving, storing, 

distributing, returning, or otherwise disposing of, in any manner, products or 

inventory not authorized by Plaintiff to be sold or offered for sale, and which bear 

the Led Zeppelin Trademarks, or which are derived from the Led Zeppelin

Copyrights;

d. further infringing the Led Zeppelin Trademarks and damaging Plaintiff’s goodwill;

e. using, linking to, transferring, selling, exercising control over, or otherwise owning 

the Online Marketplace Accounts, the Defendant Seller Stores, Defendant product 

listings, or any other domain name or online marketplace account that is being used 

to sell products or inventory not authorized by Plaintiff which bear the Led Zeppelin

Trademarks or which are derived from Plaintiff’s Led Zeppelin Copyrights;

f. operating and/or hosting websites at the Defendant Domain Names, and any other 

domain names registered to or operated by Defendants that are involved with the 

distribution, marketing, advertising, offering for sale, or sale of products or 

inventory not authorized by Plaintiff which bear the Led Zeppelin Trademarks, or

which are derived from Plaintiff’s Led Zeppelin Copyrights;

2) Entry of an Order that, upon Plaintiff’s request, those in privity with Defendants and 

those with notice of the injunction, including any online marketplaces and payment processors, 

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such as eBay, Amazon, Wish, iOffer, and Alibaba Group Holding Ltd., Alipay.com Co., Ltd., and 

any related Alibaba entities (collectively, “Alibaba”), social media platforms, Facebook, YouTube, 

LinkedIn, Twitter, Internet search engines such as Google, Bing, and Yahoo, web hosts for the 

Defendant Domain Names, and domain name registrars, shall:

a. disable and cease providing services for any accounts through which Defendants 

engage in the sale of products not authorized by Plaintiff which bear the Led 

Zeppelin Trademarks, including any accounts associated with the Defendants listed 

on Schedule “A”;

b. disable and cease displaying any advertisements used by or associated with 

Defendants in connection with the sale of products not authorized by Plaintiff which 

bear the Led Zeppelin Trademarks, or which are derived from Plaintiff’s copyrights

in the Led Zeppelin Copyrights; and,

c. take all steps necessary to prevent links to the Defendant Domain Names identified 

on Schedule “A” from displaying in search results, including, but not limited to, 

removing links to the Defendant Domain Names from any search index.

3) That Defendants account for, and pay to, Plaintiff all profits realized by Defendants by 

reason of Defendants’ unlawful acts herein alleged;

4) For Judgment in favor of Plaintiff against Defendants that they have willfully infringed 

Plaintiff’s rights in its federally registered Trademarks, pursuant to 15 U.S.C. § 1114;

5) That Plaintiff be awarded actual damages, statutory damages, and/or other available 

damages, at the election of Plaintiff; and that the amount of damages for infringement are increased 

by a sum not to exceed three times the amount thereof as provided by 15 U.S.C. § 1117;

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6) For Judgment in favor of Plaintiff against Defendants that they have: a) willfully

infringed Plaintiff’s rights in its federally registered copyrights pursuant to 17 U.S.C. §501; and, 

b) otherwise injured the business reputation and business of Plaintiff by Defendants’ acts and

conduct set forth in this Complaint;

7) That Plaintiff be awarded actual damages, statutory damages, and/or other available

damages pursuant to 17 U.S.C. §504, at the election of Plaintiff;

8) That Plaintiff be awarded its reasonable attorneys’ fees and costs; and,

9) Any and all other relief that this Court deems just and proper.

DATED: March 4, 2020 Respectfully submitted,

/s/ Ann Marie Sullivan

Ann Marie Sullivan

Alison Carter

Raymond Lang

AM Sullivan Law, LLC

1440 W. Taylor St., Suite 515

Chicago, Illinois 60607

Telephone: 224-258-9378

E-mail: ams@amsullivanlaw.com

ATTORNEYS FOR PLAINTIFF

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