IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

CANADA GOOSE INC.,

Plaintiff,

v.

CANADAGOOSEOUTLET.XYZ, et al.,

Defendants.

Case No. 20-cv-02302

Judge Manish S. Shah

Magistrate Judge M. David Weisman

PLAINTIFF’S MEMORANDUM IN SUPPORT OF ITS

MOTION FOR ENTRY OF DEFAULT AND DEFAULT JUDGMENT

Plaintiff Canada Goose Inc. (“Canada Goose” or “Plaintiff”) submits the following 

memorandum in support of its Motion for Entry of Default and Default Judgment under Fed. R. 

Civ. P. 55 against the defendants identified on Schedule A to the Amended Complaint

(collectively, the “Defaulting Defendants”) based on Canada Goose’s action for trademark 

infringement, counterfeiting, and false designation of origin. 

STATEMENT OF FACTS

Founded in a small warehouse in Toronto, Canada, Canada Goose has grown to be an 

internationally recognized manufacturer, distributor and retailer of high quality, functional, 

down-filled outerwear, including parkas, jackets, and coats and associated accessories for men, 

women and children, all of which prominently display its famous, internationally-recognized and 

federally-registered trademarks, including CANADA GOOSE (collectively, the “Canada Goose 

Products”). Amended Complaint [13] at ¶ 4. Canada Goose holds registrations for its 

trademarks CANADA GOOSE and with the United States Patent and Trademark 

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Office (collectively, the “CANADA GOOSE Trademarks”). Id. at ¶ 6. Additional factual 

assertions regarding Plaintiff in Paragraphs 4 – 11 of the Amended Complaint are incorporated 

herein. Id. at ¶¶ 4 – 11. 

Defaulting Defendants are individuals and business entities of unknown makeup who, 

either individually or jointly, own and/or operate one or more of the e-commerce stores under at 

least the seller aliases identified on Schedule A to the Amended Complaint (collectively, the 

“Seller Aliases”) Id. at ¶ 16. Each Defaulting Defendant targets sales to Illinois residents by 

setting up and operating e-commerce stores that target U.S. consumers using one or more Seller 

Aliases, offer shipping to the U.S., including Illinois, accept payment in U.S. dollars, and has 

offered for sale and/or sold unauthorized and unlicensed products using infringing and 

counterfeit versions of Canada Goose’s federally registered CANADA GOOSE Trademarks (the 

“Counterfeit Canada Goose Products”) to residents of Illinois. Id. Additional factual assertions 

regarding Defaulting Defendants in Paragraphs 12 – 26 of the Amended Complaint are 

incorporated herein. Id. at ¶¶ 12 – 26.

Canada Goose filed this action on April 14, 2020 [1] and soon thereafter filed an 

Amended Complaint [13]. On April 16, 2020, this Court granted Canada Goose’s Ex Parte 

Motion for Entry of a Temporary Restraining Order (the “TRO”) [31], and subsequently

converted the TRO [31] into a Preliminary Injunction [41]. Paragraph 9 of the TRO permitted 

Plaintiff to complete service of process to Defendants by electronic publication on a website to 

which the Domain Names which were transferred to Canada Goose’s control redirect, or by 

sending an e-mail to the e-mail addresses identified in Exhibits 5 and 6 to the Declaration of 

Geoffrey Marr and any e-mail addresses provided for Defendants by third parties that includes a 

link to said website. [31] at ¶ 9. The Defendants were properly served on May 18, 2020. [34]. 

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None of the Defaulting Defendants have filed an answer or otherwise pled in this action. See

Declaration of Justin R. Gaudio (the “Gaudio Declaration”) at ¶ 2.

Pursuant to Federal Rule of Civil Procedure 55(a) and (b)(2), Canada Goose now moves 

this Court for an Order entering default and default judgment finding that Defaulting Defendants 

are liable on all counts of Canada Goose’s Amended Complaint. Fed. R. Civ. P. 55(a) and 

(b)(2). Canada Goose further seeks an award of statutory damages as authorized by 15 U.S.C. § 

1117(c)(2) for willful trademark counterfeiting against each of the Defaulting Defendants for use 

of counterfeit CANADA GOOSE Trademarks on products sold through each of the e-commerce 

stores operating under the Seller Aliases. Canada Goose also seeks entry of a permanent 

injunction prohibiting Defaulting Defendants from selling Counterfeit Canada Goose Products, 

an Order that the Domain Names used by Defaulting Defendants to sell Counterfeit Canada 

Goose Products be permanently transferred to Canada Goose, and that all assets in Defaulting 

Defendants’ financial accounts, including those operated by PayPal, Inc. (“PayPal”), Alipay,

Amazon and Wish.com, as well as any newly discovered assets, be transferred to Canada Goose.

ARGUMENT

I. JURISDICTION AND VENUE ARE PROPER IN THIS COURT

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., 28 U.S.C. § 1338(a)-(b) and 28 

U.S.C. § 1331. Venue is proper in this Court pursuant to 28 U.S.C. § 1391, and this Court may 

properly exercise personal jurisdiction over Defendants since each of the Defendants directly 

targets business activities toward consumers in Illinois and causes harm to Canada Goose’s

business within this Judicial District. See [13] at ¶¶ 2, 16, 28 and 29; uBID, Inc. v. GoDaddy 

Grp., Inc. 623 F.3d 421, 423-24 (7th Cir. 2010) (without benefit of an evidentiary hearing, 

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plaintiff bears only the burden of making a prima facie case for personal jurisdiction; all of 

plaintiff's asserted facts should be accepted as true and any factual determinations should be 

resolved in its favor). 

Through at least the fully interactive e-commerce stores operating under the Seller 

Aliases, each of the Defaulting Defendants has targeted sales to Illinois residents by setting up 

and operating e-commerce stores that target United States consumers using one or more Seller 

Aliases, offer shipping to the United States, including Illinois, accept payment in U.S. dollars,

and, on information and belief, has sold Counterfeit Canada Goose Products to residents of 

Illinois. [13] at ¶¶ 2, 16. Personal jurisdiction exists over Defaulting Defendants since they 

directly target their business activities toward consumers in the United States, including Illinois. 

Id. at ¶ 2. Specifically, Defaulting Defendants are reaching out to do business with Illinois 

residents by operating one or more commercial, interactive e-commerce store under the Seller 

Aliases through which Illinois residents can purchase Counterfeit Canada Goose Products. Id. 

See Monster Energy Co. v. Chen Wensheng, et al., 2015 U.S. Dist. LEXIS 132283, at *11 (N.D. 

Ill. Sept. 29, 2015). 

II. CANADA GOOSE HAS MET THE REQUIREMENTS FOR ENTRY OF 

DEFAULT

Pursuant to Rule 55(a) of the Federal Rules of Civil Procedure, “when a party against 

whom a judgment for affirmative relief is sought has failed to plead or otherwise defend, and that 

failure is shown by affidavit or otherwise, the clerk must enter the party's default.” Fed. R. Civ. 

P. 55(a). On April 14, 2020, Canada Goose filed its Amended Complaint alleging federal 

trademark infringement and counterfeiting, 15 U.S.C. § 1114 (Count I), and false designation of 

origin, 15 U.S.C. § 1125(a) (Count II). [13]. The Defendants were properly served with the 

Amended Complaint on May 18, 2020. [34]. Despite having been served with process, none of 

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the Defaulting Defendants have filed an answer or otherwise pled in this action. Gaudio 

Declaration at ¶ 2. Upon information and belief, the Defaulting Defendants are not active-duty 

members of the U.S. armed forces. Id. at ¶ 3. Accordingly, Canada Goose asks for entry of 

default against the Defaulting Defendants.

III. CANADA GOOSE HAS MET THE REQUIREMENTS FOR ENTRY OF 

DEFAULT JUDGMENT

Rule 55(b)(2) of the Federal Rules of Civil Procedure provides for a court-ordered default 

judgment. A default judgment establishes, as a matter of law, that defendants are liable to 

plaintiff on each cause of action alleged in the complaint. United States v. Di Mucci, 879 F.2d 

1488, 1497 (7th Cir. 1989). When the Court determines that a defendant is in default, the factual 

allegations of the complaint are taken as true and may not be challenged, and the defendants are 

liable as a matter of law as to each cause of action alleged in the complaint. Black v. Lane, 22 

F.3d 1395, 1399 (7th Cir. 1994).

As noted above, Canada Goose served Defendants on May 18, 2020. [34]. The answer 

deadline has passed, and no answer or other responsive pleading has been filed by any of the 

Defaulting Defendants. See Fed. R. Civ. P. 12(a)(1)(A).

1

 Accordingly, default judgment is 

appropriate, and consistent with previous similar cases in front of this Court, Canada Goose

requests an award of statutory damages as authorized by 15 U.S.C. § 1117(c)(2) for willful 

trademark counterfeiting against each of the Defaulting Defendants for use of counterfeit

CANADA GOOSE Trademarks on products sold through the e-commerce stores operating under 

the Seller Aliases. Canada Goose also seeks entry of a permanent injunction prohibiting 

Defaulting Defendants from selling Counterfeit Canada Goose Products, an order that Domain 

1 Pursuant to this Court’s Amended General Order 20-0012, the response deadline for Defendants was 

extended until July 6, 2020.

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Names used by Defaulting Defendants to sell Counterfeit Canada Goose Products be 

permanently transferred to Canada Goose, and that all assets in Defaulting Defendants’ financial 

accounts, including those operated by PayPal, Alipay, Amazon and Wish.com, and any newly 

identified accounts be transferred to Canada Goose. 

A. Trademark Infringement, Counterfeiting and False Designation of Origin

To properly plead a claim of trademark infringement and counterfeiting pursuant to the 

Lanham Act, a plaintiff must allege that (1) its mark is distinctive enough to be worthy of 

protection, (2) defendants are not authorized to use the mark; and (3) defendant’s use of the mark 

causes a likelihood of confusion as to the origin or sponsorship of defendant’s products. See 

Bliss Salon Day Spa v. Bliss World LLC, 268 F.3d 494, 496-97 (7th Cir. 2001). 

Canada Goose alleged in its Amended Complaint that it is the exclusive owner of the 

CANADA GOOSE Trademarks and that Defaulting Defendants have sold, offered to sell, 

marketed, distributed, and advertised, and are still selling, offering to sell, marketing, 

distributing, and advertising products using infringing and counterfeit versions of the CANADA 

GOOSE Trademarks, that Defaulting Defendants have knowledge of Canada Goose’s rights in 

the CANADA GOOSE Trademarks, that Defaulting Defendants are not authorized to use the 

CANADA GOOSE Trademarks for any reason, and that Defaulting Defendants’ use of the 

CANADA GOOSE Trademarks causes a likelihood of confusion. [13] at ¶¶ 25-26. 

Canada Goose also alleged in its Amended Complaint that Defaulting Defendants are 

using the federally registered CANADA GOOSE Trademarks on the Counterfeit Canada Goose 

Products. [13] at ¶ 36. As such, this creates a likelihood of confusion, mistake, and deception 

among the general public as to the affiliation, connection, or association with Canada Goose or 

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the origin, sponsorship, or approval of Defaulting Defendants’ Counterfeit Canada Goose 

Products by Canada Goose. Id. at ¶ 35.

Since the Defaulting Defendants have failed to respond or otherwise plead in this matter, 

the Court must accept the allegations contained in Canada Goose’s Amended Complaint as true. 

See Fed. R. Civ. P. 8(b)(6); Am. Taxi Dispatch, Inc., v. Am. Metro Taxi & Limo Co., 582 F. 

Supp. 2d 999, 1004 (N.D. Ill. 2008). Accordingly, Canada Goose requests entry of judgment 

with respect to Counts I and II for willful trademark infringement and counterfeiting of the 

CANADA GOOSE Trademarks, and false designation of origin against the Defaulting 

Defendants.

IV. CANADA GOOSE IS ENTITLED TO A STATUTORY DAMAGES AWARD

A. Statutory Damages Are Appropriate in this Case 

Pursuant to the statutory damages provision of the Lanham Act, 15 U.S.C. § 1117(c), a 

plaintiff in a case involving the use of a counterfeit mark may elect to receive “not less than 

$1,000 or more than $200,000 per counterfeit mark per type of goods or services sold, offered 

for sale, or distributed, as the court considers just.” 15 U.S.C. § 1117(c)(1). When the 

counterfeiting is found to be willful, 15 U.S.C. § 1117(c)(2) provides for statutory damages of up 

to “$2,000,000 per counterfeit mark per type of goods or services sold, offered for sale, or 

distributed, as the court considers just.” 15 U.S.C. § 1117(c)(2). 

The lack of information regarding Defaulting Defendants’ sales and profits makes

statutory damages particularly appropriate for default cases like the instant case. Lorillard 

Tobacco Co., 2004 U.S. Dist. LEXIS 22563, at *9, (N.D. Ill. 2004) (citing S. Rep. No. 177, 

104th Cong. 1995). Likewise, Courts have recognized that statutory damages should be awarded 

without requiring an evidentiary hearing. See Lorillard Tobacco Co. v. Montrose Wholesale 

Candies & Sundries, Inc., 2008 U.S. Dist. LEXIS 31761, at *11 (N.D. Ill. Apr. 17, 2008).

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B. A Statutory Damages Award Is Warranted

Although 15 U.S.C. § 1117(c) contains the dollar range for possible statutory damage 

awards, the only guidance provided by the statute for how to determine a damage award within 

the statutory dollar range is “as the court considers just.” 15 U.S.C. § 1117(c). Courts 

interpreting 15 U.S.C. § 1117(c) have analogized case law applying the statutory damage 

provision of the Copyright Act contained in 17 U.S.C. § 504(c). See Lorillard Tobacco Co., 

2004 U.S. Dist. LEXIS 22563, at *10; Luxottica USA LLC v. The Partnerships, et al., 2015 U.S. 

Dist. LEXIS 78961, at *5 (N.D. Ill. 2015); Sara Lee v. Bags of New York, Inc., 36 F. Supp. 2d 

161, 166 (S.D.N.Y. 1999).

The Seventh Circuit's standard for awarding statutory damages for copyright 

infringement under 17 U.S.C § 504(c) is articulated in Chi-Boy Music v. Charlie Club, 930 F.2d 

1224, 1229 (7th Cir. 1991). Under the Chi-Boy standard, a court awarding statutory damages is 

“not required to follow any rigid formula,” but instead “enjoys wide discretion.” Id. In 

computing the award amount, a court may consider factors such as “the difficulty or 

impossibility of proving actual damages, the circumstances of the infringement, and the efficacy 

of the damages as a deterrent.” Id. Courts in this district have also considered the significant 

value of a plaintiff’s brand and the efforts taken to protect, promote and enhance that brand in 

determining the appropriate dollar figure for the award. Lorillard Tobacco Co., 2004 U.S. Dist. 

LEXIS 22563, at *16. 

In addition, courts have awarded significant damage amounts where a defendant’s 

counterfeiting activities attracted wide market exposure through Internet traffic or advertisement.

See Coach, Inc. v. Ocean Point Gifts, 2010 U.S. Dist. LEXIS 59003, *15-16 (D.N.J. Jun. 14, 

2010) (significant damage awards in counterfeit cases were “due in part to the wide market 

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exposure that the Internet can provide”); Burberry Ltd. v. Designers Imports, Inc., 2010 U.S. 

Dist. LEXIS 3605, *28-29 (S.D.N.Y. Jan. 19, 2010) (damages amount based, in part, on

“Defendant's ability to reach a vast customer base through internet advertising”).

In similar cases involving willful Internet-based counterfeiting, courts have awarded 

statutory damages, including up to the maximum provided by law, to the plaintiff to serve the 

purposes of: (1) deterring the defendant and others situated like him from bringing into 

commerce counterfeit goods, (2) compensating the plaintiff for damages caused by defendant’s 

infringement, and (3) punishing the defendant appropriately for his counterfeiting activities. See, 

e.g., Burberry Limited, et al. v. XIE JI PING, et al, No. 18-cv-07442 (N.D. Ill. Jan. 15, 2019) 

(unpublished) (Docket Nos. 42 and 43) (awarding $1,000,000 in statutory damages per 

defendant); NBA Properties, Inc., et al. v. YU ZICHENG, et al., 19-cv-04412 (N.D. Ill. Oct. 8, 

2019) (unpublished) (Docket Nos. 60 and 61) (awarding $500,000 in statutory damages per 

defendant); H-D U.S.A., LLC v. DLLL, et al., No. 19-cv-07629 (N.D. Ill. Feb. 18, 2020) 

(unpublished) (Docket Nos. 64 and 65) (same). Given the Court’s clear discretion in 

determining the appropriate amount of the statutory damages award within the statutory limits of 

15 U.S.C. § 1117(c), Plaintiff respectfully requests the Court’s entry of an award of one hundred 

thousand dollars ($100,000) per Defaulting Defendant. 

i. Defaulting Defendants’ Willful Counterfeiting Supports the Requested Award

Defaulting Defendants’ counterfeiting was willful and, therefore, at a minimum, warrants 

the requested statutory damages award. “Willful infringement may be attributed to the 

defendant’s actions where he had knowledge that his conduct constituted infringement or where 

he showed a reckless disregard for the owner’s rights.” Lorillard Tobacco Co. v. S & M Cent. 

Serv. Corp., 2004 LEXIS 22563, *19-20 (N.D. Ill. Feb. 25, 2005). Knowledge need not be 

proven directly, but can be inferred from a defendant’s conduct. Id. at 20. As alleged in 

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Plaintiff’s Amended Complaint, Defaulting Defendants facilitated sales by designing the ecommerce stores so that they appeared to unknowing consumers to be authorized online retailers, 

outlet stores, or wholesalers. [13] at ¶ 23. As such, Defaulting Defendants clearly had 

knowledge that their activities constituted infringement or at least a reckless disregard for 

Plaintiff’s rights in the CANADA GOOSE Trademarks. [13] at ¶¶ 24-26; see also [19], [21]. 

Finally, District Courts have deemed counterfeiting willful when defendants default. See 

Burberry Limited, et al. v. The Partnerships, et al, No. 14-cv-08220 (N.D. Ill. Dec. 11, 2014) 

(unpublished) (Docket Nos. 44 and 45); Oakley, Inc. v. The Partnerships, et al., No. 13-cv-02958 

(N.D. Ill. June 17, 2013) (unpublished) (Docket Nos. 36 and 37).

ii. The Value of the CANADA GOOSE Trademarks and Plaintiff’s Efforts to 

Promote, Protect and Enhance the Canada Goose Brand Justify the Requested

Award

In determining an appropriate statutory damage award, this Court should be guided by the 

Lorillard case and consider the “significant value of [the brand] and the efforts taken to protect, 

promote and enhance [that brand].” Lorillard Tobacco Co., 2004 U.S. Dist. LEXIS 22563, at 

*16. Canada Goose has expended substantial time, money, and other resources in developing, 

advertising and otherwise promoting the CANADA GOOSE Trademarks. [18] at ¶ 15. Thus, 

the requested statutory damages award should be given favorable consideration in view of the 

value of the Canada Goose brand and the extensive steps being taken by Plaintiff to protect, 

promote and enhance it. See Monster Energy Company, 2015 U.S. Dist. LEXIS 86956, at *11; 

Luxottica USA LLC v. The Partnerships, et al., 2015 U.S. Dist. LEXIS 78961, at *7-8 (N.D. Ill. 

June 18, 2015).

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iii. Defaulting Defendant’s Wide Exposure over the Internet Merits the Requested

Award

Defendants who operate online attract wide market exposure through Internet traffic 

and/or advertisement. Defaulting Defendants’ wide market exposure over the Internet warrants 

the requested statutory damages award. See H-D U.S.A., LLC v. Guangzhou Tomas Crafts Co., 

et al., 2017 U.S. Dist. LEXIS 207613 (N.D. Ill. Dec. 18, 2017) (awarding $150,000 in statutory

damages, noting “the fact that defendant’s counterfeiting took place online favors a higher 

statutory damages award because online counterfeiting can reach a much wider audience than 

counterfeiting through a physical store.”); Luxottica USA LLC v. The Partnerships, et al., 2017 

U.S. Dist. LEXIS 29999, at *11-12 (Mar. 2, 2017 N.D. Ill.) (summary judgment and awarding 

$100,000 in statutory damages “because [defendant] advertised [counterfeit goods] on the 

internet, allowing for distribution far greater than if it sold the hats in a brick-and-mortar store.”). 

iv. The Requested Statutory Damages Award Must Sufficiently Deter Defaulting 

Defendants and Similar Online Counterfeit Sellers

The remedy imposed must provide a sufficient deterrent effect to ensure that the guilty 

party will not engage in further infringing conduct. Sands, Taylor & Wood, 34 F.3d at 1348. In 

Phillip Morris USA Inc. v. Marlboro Express, the Court stated that due to “the size of the 

potential profit given the quantities of [counterfeit goods] involved, and the need for a substantial 

deterrent to future misconduct by defendants and other counterfeit traffickers ... plaintiff is 

entitled to the maximum statutory award under 15 U.S.C. § 1117(c)(2).” 2005 U.S. Dist. LEXIS 

40359, at *28 (E.D.N.Y. Aug. 26, 2005). See also Luxottica USA LLC v. The Partnerships, et 

al., 2015 U.S. Dist. LEXIS 78961, at *8.

To reach global consumers, counterfeiters advertise, offer for sale, and sell their products 

via social media platforms and popular e-commerce sites. In the 2018 fiscal year alone, U.S. 

government seizures of counterfeit goods totaled more than $1.3 billion MSRP. [17-1]. China 

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and Hong Kong remained the primary sources of counterfeit and pirated goods seized, 

accounting for more than 87 percent of all seizures. Id. Additionally, a February 2017 report 

commissioned by Business Action to Stop Counterfeiting and Piracy (BASCAP) and the 

International Trademark Association (INTA) titled The Economic Impacts of Counterfeiting and 

Piracy included findings that counterfeit and pirated products account for billions in economic 

losses, resulting in tens of thousands of lost jobs for legitimate businesses and broader economic 

losses, including lost tax revenue. [17-3]. As such, the requested statutory damages award is 

necessary to deter both Defendants and other similarly situated online sellers.

V. CANADA GOOSE IS ENTITLED TO PERMANENT INJUNCTIVE RELIEF

In addition to the foregoing relief, Canada Goose respectfully requests entry of a 

permanent injunction enjoining Defaulting Defendants from infringing or otherwise violating 

Canada Goose’s rights in the federally registered CANADA GOOSE Trademarks, including at 

least all injunctive relief previously awarded by this Court to Canada Goose in the TRO and 

Preliminary Injunction. Canada Goose is also entitled to injunctive relief so it can quickly take 

action against any new e-commerce stores selling Counterfeit Canada Goose Products that are 

found to be linked to Defaulting Defendants. See Burberry Limited, et al. v. The Partnerships, et 

al, No. 1:14-cv-08220 (N.D. Ill. Dec. 11, 2014) (unpublished) (Docket Nos. 44 and 45); Oakley, 

Inc. v. The Partnerships, et al., No. 1:13-cv-02958 (N.D. Ill. June 17, 2013) (unpublished) 

(Docket Nos. 36 and 37).

CONCLUSION

Canada Goose respectfully requests that the Court enter default and default judgment 

against each Defaulting Defendant, award statutory damages in the amount of one hundred 

thousand dollars ($100,000) per Defaulting Defendant pursuant to 15 U.S.C. § 1117(c) and enter 

a permanent injunction order prohibiting Defaulting Defendants from selling Counterfeit Canada 

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Goose Products, permanently transferring the Domain Names used by Defaulting Defendants to 

sell Counterfeit Canada Goose Products to Canada Goose, and transferring all assets in 

Defaulting Defendants’ financial accounts, including those operated by PayPal, Alipay, Amazon 

and Wish.com, to Canada Goose. 

Dated this 7th day of July 2020. Respectfully submitted,

/s/ Justin R. Gaudio

Amy C. Ziegler

Justin R. Gaudio

Jake M. Christensen

Isaku M. Begert

Greer, Burns & Crain, Ltd.

300 South Wacker Drive, Suite 2500

Chicago, Illinois 60606

312.360.0080

312.360.9315 (facsimile)

aziegler@gbc.law

jgaudio@gbc.law

jchristensen@gbc.law

ibegert@gbc.law

Counsel for Plaintiff Canada Goose Inc.

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CERTIFICATE OF SERVICE

I hereby certify that on the 7th day of July 2020, I will electronically file the foregoing 

with the Clerk of the Court using the CM/ECF system, I will electronically publish the 

documents on a website to which the Domain Names that have been transferred to Canada 

Goose’s control now redirect, and I will send an e-mail to the e-mail addresses identified in 

Exhibits 5 and 6 to the Declaration of Geoffrey Marr and any e-mail addresses provided for 

Defendants by third parties that includes a link to said website.

/s/ Justin R. Gaudio

Amy C. Ziegler

Justin R. Gaudio

Jake M. Christensen

Isaku M. Begert

Greer, Burns & Crain, Ltd.

300 South Wacker Drive, Suite 2500

Chicago, Illinois 60606

312.360.0080

312.360.9315 (facsimile)

aziegler@gbc.law

jgaudio@gbc.law

jchristensen@gbc.law

ibegert@gbc.law

Counsel for Plaintiff Canada Goose Inc.

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