IN THE UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION 

LEVI STRAUSS & CO., 

 Plaintiff, 

 v. 

THE PARTNERSHIPS and 

UNINCORPORATED ASSOCIATIONS 

IDENTIFIED ON SCHEDULE “A”, 

 Defendants. 

Case No. 20-cv-04380 

COMPLAINT 

Plaintiff Levi Strauss & Co. (“LS&Co.”) hereby brings the present action against the 

Partnerships and Unincorporated Associations identified on Schedule A attached hereto 

(collectively, “Defendants”) and alleges as follows: 

I. JURISDICTION AND VENUE 

1. 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. 

2. 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 the United States, including Illinois, through at 

least the fully interactive, e-commerce stores1

 operating under the seller aliases identified in 

Schedule A attached hereto (the “Seller Aliases”). Specifically, Defendants have targeted sales 

to Illinois residents by setting up and operating e-commerce stores that target United States 

1

 The e-commerce store urls are listed on Schedule A hereto under the Online Marketplaces.

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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, have sold products using 

infringing and counterfeit versions of LS&Co.’s federally registered trademarks to residents of 

Illinois. Each of the Defendants is committing tortious acts in Illinois, is engaging in interstate 

commerce, and has wrongfully caused LS&Co. substantial injury in the State of Illinois. 

II. INTRODUCTION

3. This action has been filed by LS&Co. to combat e-commerce store operators who 

trade upon LS&Co.’s reputation and goodwill by offering for sale and/or selling unauthorized 

and unlicensed products, including jeans, jean jackets, and other apparel items, using infringing 

and counterfeit versions of LS&Co.’s federally registered trademarks (the “Counterfeit Levi’s 

Products”). Defendants create e-commerce stores operating under one or more Seller Aliases 

that are advertising, offering for sale and selling Counterfeit Levi’s Products to unknowing 

consumers. E-commerce stores operating under the Seller Aliases share unique identifiers 

establishing a logical relationship between them and that Defendants’ counterfeiting operation 

arises out of the same transaction, occurrence, or series of transactions or occurrences. 

Defendants attempt to avoid and mitigate liability by operating under one or more Seller Aliases 

to conceal both their identities and the full scope and interworking of their counterfeiting 

operation. LS&Co. is forced to file this action to combat Defendants’ counterfeiting of its 

registered trademarks, as well as to protect unknowing consumers from purchasing Counterfeit 

Levi’s Products over the Internet. LS&Co. has been and continues to be irreparably damaged 

through consumer confusion, dilution, and tarnishment of its valuable trademarks as a result of 

Defendants’ actions and seeks injunctive and monetary relief. 

 

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III. THE PARTIES 

Plaintiff 

4. Plaintiff LS&Co. is a corporation organized and existing under the laws of the 

State of Delaware, having its principal place of business at Levi’s Plaza, 1155 Battery Street, San 

Francisco, California 94111. 

5. Operating since the 1850s, LS&Co. is one of the oldest and best known apparel 

companies in the world. It manufactures, markets and sells a variety of apparel, including its 

traditional LEVI’S® brand products, all of which are marked with a set of trademarks that are 

famous around the world. LEVI’S® brand products have become enormously popular and even 

iconic, driven by LS&Co.’s arduous quality standards and innovative design. Among the 

purchasing public, LEVI’S® brand products are instantly recognizable as such. In the United 

States and around the world, the LEVI’S® brand has come to symbolize high quality, and 

LEVI’S® brand products are among the most recognizable apparel products in the world. 

6. LEVI’S® brand products are distributed and sold to consumers through retailers 

throughout the United States, including through authorized retailers in Illinois, the official 

levi.com website which was launched in 1994, and LEVI’S® Stores, including locations at 600 

N. Michigan Avenue and 1552 N. Milwaukee Avenue in Chicago, Illinois. 

7. LS&Co. incorporates a variety of distinctive marks in the design of its various 

LEVI’S® brand products. LEVI’S® brand products typically include at least one of the LEVI’S 

Trademarks. Often several LS&Co. marks are displayed on a single LEVI’S® brand product. 

LS&Co. further uses its trademarks in connection with the marketing of its LEVI’S® brand 

products. As a result of its long-standing use, LS&Co. owns common law trademark rights in its 

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trademarks. LS&Co. has also registered multiple trademarks with the United States Patent and 

Trademark Office. Among the marks registered are the Levi’s trademarks listed below. 

REGISTRATION 

NUMBER

TRADEMARK

REGISTRATION 

DATE

GOODS AND SERVICES

1,140,011 LEVI’S September 30, 1980 For garments-namely, pants, 

shirts, and shorts in class 

025. 

1,124,018 LEVI’S August 14, 1979 For purses, denim shopping 

bags, back packs, duffle 

bags, briefcase portfolios, 

key cases and wallets in class 

018. 

For belts, hats, caps, visors, 

and shoes in class 025. 

1,130,486 LEVI’S February 5, 1980 For socks in class 025. 

4,660,979 LEVI’S December 23, 2014 For underwear in class 025. 

250,265 December 4, 1928 For jeans in class 025. 

581,610 October 27, 1953 For men's, women's and 

children's overalls, jackets, 

outer shirts, slacks, and 

pants; skirts in classes 010, 

025, 026. 

2,320,789 February 22, 2000 For clothing, namely, men's, 

women's and children's 

pants, slacks, trousers, jeans, 

shorts, overalls, shirts, tshirts, vests, skirts, jackets, 

coats, sweaters, sweatshirts, 

hats and shoes in class 025. 

849,437 May 21, 1968 For trousers, jackets, shorts, 

shirts, skirts in classes 010, 

025, 026. 

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1,135,196 May 13, 1980 For garments-namely, pants 

in class 025. 

928,351 February 1, 1972 For men's, women's and 

children's pants, jackets in 

classes 010, 025, 026. 

8. In addition to the above Levi’s trademarks, LS&Co. has registered the famous 

Arcuate Stitching Design trademark, the Tab Device trademark, the Two Horse Design and Two 

Horse Label Design trademarks, and the 500 Series trademarks. 

LS&Co.’s Two Horse Label Design patch 

and 501 marks

LS&Co.’s Arcuate Stitching Design and Tab 

Device marks

LS&Co.’s Arcuate Trademark 

9. The Arcuate Stitching Design trademark (“Accurate trademark”) consists of a 

distinctive pocket stitching design that is the oldest known apparel trademark in the United States 

still in continuous use. LS&Co. has used the Arcuate trademark continuously since 1873 in 

interstate commerce on clothing products. LS&Co. first used the Arcuate trademark on jeans 

and later used it on other products, as well. 

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10. LS&Co. owns, among others, the following United States Registrations for its 

Arcuate trademark. 

REGISTRATION 

NUMBER

TRADEMARK

REGISTRATION 

DATE

GOODS AND SERVICES

404,248 November 16, 1943 For waistband type overalls 

in class 025. 

1,139,254 September 2, 1980 For pants, jackets, skirts, 

and shorts in class 025. 

2,794,649 December 16, 2003 For pants, jeans, shorts, 

skirts, and jackets in class 

025. 

11. The Arcuate trademark is valid and protectable, and exclusively owned by 

LS&Co. The Arcuate trademark is famous and is recognized around the world and throughout 

the United States by consumers as signifying authentic, high quality LEVI’S® brand products. 

The Arcuate trademark became famous prior to Defendants’ conduct that is the subject of this 

Complaint. 

LS&Co.’s Tab Trademark 

12. LS&Co.’s famous Tab Device Trademark (the “Tab trademark”), consists of a 

textile marker or other material sewn into one of the regular structural seams of the garment. 

LS&Co. uses the Tab trademark on LEVI’S® brand jeans and a variety of other clothing 

products. LS&Co. began to display the Tab trademark on the rear pocket of its pants in 1936 

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when its National Sales Manager, Leo Christopher Lucier, proposed placing a folded cloth 

ribbon in the structural seams of the rear pocket. The purpose of this “tab” was to provide “sight 

identification” of LEVI’S® brand products. Given the distinctiveness of the Tab trademark, Mr. 

Lucier asserted that “no other maker of overalls can have any other purpose in putting a colored 

tab on an outside patch pocket, unless for the express and sole purpose of copying our mark, and 

confusing the customer.” 

13. LS&Co. owns, among others, the following United States Registrations for its 

Tab trademark. 

REGISTRATION 

NUMBER

TRADEMARK

REGISTRATION 

DATE

GOODS AND SERVICES

356,701 May 10, 1938 For pants of the patchpocket type worn by men, 

women and children in class 

025. 

516,561 October 18, 1949 For men's, women's and 

children's jeans and jackets 

in class 025. 

577,490 July 21, 1953 For jeans in class 025. 

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720,376 August 22, 1961 For pants in classes 010, 

025, 026. 

774,625 August 4, 1964 For garments, particularly 

trousers in class 025.

775,412 August 18, 1964 For garments, particularly 

trousers in class 025.

1,157,769 June 16, 1981 For trousers in class 025.

2,726,253 June 17, 2003 For clothing, namely, shirts 

in class 025. 

14. The Tab trademark is valid and protectable, and exclusively owned by LS&Co. 

The Tab trademark is famous and recognized around the world and throughout the United States 

by consumers as signifying authentic, high quality LEVI’S® brand products. The Tab trademark 

became famous prior to Defendants’ conduct that is the subject of this Complaint. 

15. LS&Co. also has a trademark registration for a combination of the Arcuate 

trademark and the Tab trademark shown in the chart below. 

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REGISTRATION 

NUMBER TRADEMARK REGISTRATION DATE GOODS AND SERVICES

2,791,156 December 9, 2003 For pants, jeans, shorts, 

skirts and jackets in class 

025. 

LS&Co.’s Two Horse Trademarks 

16. LS&Co. has used its Two Horse Design and Two Horse Label Design trademarks 

(collectively, the “Two Horse trademarks”) continuously since as early as 1886 in interstate 

commerce on jeans and pants. LS&Co. owns, among others, the following United States 

Registrations for its Two Horse trademarks. 

REGISTRATION 

NUMBER

TRADEMARK

REGISTRATION 

DATE

GOODS AND SERVICES

523,665 April 11, 1950 For men's, women's, boys', 

and girls' trousers in classes 

010, 025, 026. 

1,044,246 July 20, 1976 For shoes in class 025. 

4,576,208 July 29, 2014 For jackets; jeans; pants; tshirts; vests in class 025. 

1,030,033 January 13, 1976 For wallets in class 018. 

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1,095,986 July 11, 1978 For luggage-namely, back 

packs, shoulder bags, and 

purses in class 018. 

For caps in class 025. 

1,140,853 October 28, 1980 For garments-namely, pants, 

jackets, overalls and shoes 

in class 025. 

LS&Co.’s 500 Series Trademarks 

17. LS&Co. also owns the distinctive trademarks 501, 505, 517, and 569, among 

other marks that consist of three digits starting with a “5” (collectively, the “500 Series 

trademarks”). LS&Co. has used the 500 Series trademarks continuously since as early as 1983 

in interstate commerce on jeans and pants and, by virtue of LS&Co.’s use and promotion of the 

500 Series trademarks together, the public recognizes LS&Co. as the source of apparel products 

falling within the 500 series. 

18. LS&Co. owns, among others, the following United States Registrations for its 500 

Series trademarks. 

REGISTRATION 

NUMBER TRADEMARK REGISTRATION DATE GOODS AND SERVICES

1,313,554 505 January 8, 1985 For pants in class 025. 

1,319,462 517 February 12, 1985 For pants in class 025. 

1,552,985 501 August 22, 1989 For jeans in class 025. 

2,503,976 569 November 6, 2001 For jeans and pants in class 

025. 

4,053,137 550 November 8, 2011 For jeans; pants; shorts in 

class 025. 

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19. The U.S. trademark registrations discussed above shall collectively be referred to 

herein as the “LEVI’S Trademarks.” The LEVI’S Trademarks are valid, subsisting, in full force 

and effect, and many are incontestable pursuant to 15 U.S.C. § 1065. The LEVI’S Trademarks 

have been used exclusively and continuously by LS&Co., some since at least as early as 1873, 

and have never been abandoned. The registrations for the LEVI’S Trademarks constitute prima 

facie evidence of their validity and of LS&Co.’s exclusive right to use the LEVI’S Trademarks 

pursuant to 15 U.S.C. § 1057(b). Attached hereto as Exhibit 1 are true and correct copies of the 

United States Registration Certificates for the LEVI’S Trademarks. 

20. The LEVI’S Trademarks are exclusive to LS&Co. and are displayed extensively 

on LEVI’S® brand products and in LS&Co.’s marketing and promotional materials. LEVI’S® 

brand products have long been among the most popular jeans and apparel in the world and have 

been extensively promoted and advertised at great expense. In fact, LS&Co. has expended 

millions of dollars annually in advertising, promoting and marketing featuring the LEVI’S 

Trademarks. LEVI’S® brand products have also been the subject of extensive unsolicited 

publicity resulting from their high-quality, timeless designs and worldwide renown. Because of 

these and other factors, the LEVI’S® brand and the LEVI’S Trademarks have become famous 

throughout the United States. 

21. The LEVI’S Trademarks are distinctive when applied to the LEVI’S® brand 

products, signifying to the purchaser that the products come from LS&Co. and are manufactured 

to LS&Co.’s quality standards. Whether LS&Co. manufactures the products itself or licenses 

others to do so, LS&Co. has ensured that products bearing its LEVI’S Trademarks are 

manufactured to the highest quality standards. The LEVI’S Trademarks have achieved 

tremendous fame and recognition, which has only added to the distinctiveness of the marks. As 

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such, the goodwill associated with the LEVI’S Trademarks is of incalculable and inestimable 

value to LS&Co. 

22. Since at least as early as 1994, LS&Co. has operated a website where it promotes 

and sells LEVI’S® brand products at levi.com. Sales of LEVI’S® brand products via the 

levi.com website represent a significant portion of LS&Co.’s business. The levi.com website 

features proprietary content, images and designs exclusive to LS&Co. 

23. LS&Co.’s innovative marketing and product designs have enabled LS&Co. to 

achieve widespread recognition and fame and have made the LEVI’S Trademarks some of the 

most well-known marks in the apparel industry. The widespread fame, outstanding reputation, 

and significant goodwill associated with the LEVI’S® brand have made the LEVI’S Trademarks 

valuable assets of LS&Co. 

24. LS&Co. has expended substantial time, money, and other resources in 

developing, advertising and otherwise promoting the LEVI’S Trademarks. As a result, products 

bearing the LEVI’S Trademarks are widely recognized and exclusively associated by consumers, 

the public, and the trade as being high-quality products sourced from LS&Co. LS&Co. is a 

multi-million-dollar operation, and LEVI’S® brand products have become among the most 

popular of their kind in the world. 

The Defendants 

25. Defendants are individuals and business entities of unknown makeup who own 

and/or operate one or more of the e-commerce stores under at least the Seller Aliases identified 

on Schedule A and/or other seller aliases not yet known to LS&Co. On information and belief, 

Defendants reside and/or operate in the People’s Republic of China or other foreign jurisdictions 

with lax trademark enforcement systems, or redistribute products from the same or similar 

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sources in those locations. Defendants have the capacity to be sued pursuant to Federal Rule of 

Civil Procedure 17(b). 

26. On information and belief, Defendants, either individually or jointly, operate one 

or more e-commerce stores under the Seller Aliases listed in Schedule A attached hereto. Tactics 

used by Defendants to conceal their identities and the full scope of their operation make it 

virtually impossible for LS&Co. to discover Defendants’ true identities and the exact 

interworking of their counterfeit network. If Defendants provide additional credible information 

regarding their identities, LS&Co. will take appropriate steps to amend the Complaint. 

IV. DEFENDANTS’ UNLAWFUL CONDUCT 

27. The success of the LEVI’S® brand has resulted in its significant counterfeiting. 

Consequently, LS&Co. has a worldwide anti-counterfeiting program and regularly investigates 

suspicious e-commerce stores identified in proactive Internet sweeps and reported by consumers. 

In recent years, LS&Co. has identified numerous fully interactive e-commerce stores, including 

those operating under the Seller Aliases, that were offering for sale and/or selling Counterfeit 

Levi’s Products to consumers in this Judicial District and throughout the United States. Ecommerce sales, including through e-commerce stores like those of Defendants, have resulted in 

a sharp increase in the shipment of unauthorized products into the United States. Exhibit 2, 

Excerpts from Fiscal Year 2018 U.S. Customs and Border Protection (“CBP”) Intellectual 

Property Seizure Statistics Report. Over 90% of all CBP intellectual property seizures were 

smaller international mail and express shipments (as opposed to large shipping containers). Id. 

Over 85% of CBP seizures originated from mainland China and Hong Kong. Id. 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. 

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28. Third party service providers like those used by Defendants do not adequately 

subject new sellers to verification and confirmation of their identities, allowing counterfeiters to 

“routinely use false or inaccurate names and addresses when registering with these e-commerce 

platforms.” Exhibit 3, Daniel C.K. Chow, Alibaba, Amazon, and Counterfeiting in the Age of 

the Internet, 40 NW. J. INT’L L. & BUS. 157, 186 (2020); see also, report on “Combating 

Trafficking in Counterfeit and Pirated Goods” prepared by the U.S. Department of Homeland 

Security’s Office of Strategy, Policy, and Plans (Jan. 24, 2020), attached as Exhibit 4 and 

finding that on “at least some e-commerce platforms, little identifying information is necessary 

for a counterfeiter to begin selling” and recommending that “[s]ignificantly enhanced vetting of 

third-party sellers” is necessary. Counterfeiters hedge against the risk of being caught and 

having their websites taken down from an e-commerce platform by preemptively establishing 

multiple virtual store-fronts. Exhibit 4 at p. 22. Since platforms generally do not require a seller 

on a third-party marketplace to identify the underlying business entity, counterfeiters can have 

many different profiles that can appear unrelated even though they are commonly owned and 

operated. Exhibit 4 at p. 39. Further, “E-commerce platforms create bureaucratic or technical 

hurdles in helping brand owners to locate or identify sources of counterfeits and counterfeiters.” 

Exhibit 3 at 186-187. 

29. Defendants have targeted sales to Illinois residents by setting up and operating ecommerce 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, have sold Counterfeit Levi’s Products to residents of Illinois. 

30. Defendants concurrently employ and benefit from substantially similar 

advertising and marketing strategies. For example, Defendants facilitate sales by designing the 

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e-commerce stores operating under the Seller Aliases so that they appear to unknowing 

consumers to be authorized online retailers, outlet stores, or wholesalers. E-commerce stores 

operating under the Seller Aliases look sophisticated and accept payment in U.S. dollars via 

credit cards, Alipay, Amazon Pay, Western Union, and/or PayPal. E-commerce stores operating 

under the Seller Aliases often include content and images that make it very difficult for 

consumers to distinguish such stores from an authorized retailer. LS&Co. has not licensed or 

authorized Defendants to use any of the LEVI’S Trademarks, and none of the Defendants are 

authorized retailers of LEVI’S® brand products. 

31. Many Defendants also deceive unknowing consumers by using the LEVI’S 

Trademarks without authorization within the content, text, and/or meta tags of their e-commerce 

stores in order to attract various search engines crawling the Internet looking for websites 

relevant to consumer searches for LEVI’S® brand products. Other e-commerce stores operating 

under Seller Aliases omit using the LEVI’S Trademarks in the item title to evade enforcement 

efforts while using strategic item titles and descriptions that will trigger their listings when 

consumers are searching for LEVI’S® brand products. 

32. On information and belief, Defendants have engaged in fraudulent conduct when 

registering the Seller Aliases by providing false, misleading and/or incomplete information to ecommerce platforms. On information and belief, certain Defendants have anonymously 

registered and maintained Seller Aliases to prevent discovery of their true identities and the 

scope of their e-commerce operation. 

33. On information and belief, Defendants regularly register or acquire new seller 

aliases for the purpose of offering for sale and selling Counterfeit Levi’s Products. Such seller 

alias registration patterns are one of many common tactics used by the Defendants to conceal 

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their identities and the full scope and interworking of their counterfeiting operation, and to avoid 

being shut down. 

34. Even though Defendants operate under multiple fictitious aliases, the e-commerce 

stores operating under the Seller Aliases often share unique identifiers, such as templates with 

common design elements that intentionally omit any contact information or other information for 

identifying Defendants or other Seller Aliases they operate or use. E-commerce stores operating 

under the Seller Aliases include other notable common features, such as use of the same 

registration patterns, accepted payment methods, check-out methods, keywords, illegitimate 

search engine optimization (SEO), advertising tactics, similarities in price and quantities, the 

same incorrect grammar and misspellings, and/or the use of the same text and images. 

Additionally, Counterfeit Levi’s Products for sale by the Seller Aliases bear similar irregularities 

and indicia of being counterfeit to one another, suggesting that the Counterfeit Levi’s Products 

were manufactured by and come from a common source and that Defendants are interrelated. 

35. On information and belief, Defendants are in constant communication with each 

other and regularly participate in QQ.com chat rooms and through websites such as 

sellerdefense.cn, kaidianyo.com and kuajingvs.com regarding tactics for operating multiple 

accounts, evading detection, pending litigation, and potential new lawsuits. 

36. Further, counterfeiters such as Defendants typically operate under multiple seller 

aliases and payment accounts so that they can continue operation in spite of LS&Co.’s 

enforcement efforts. On information and belief, Defendants maintain off-shore bank accounts 

and regularly move funds from their financial accounts to off-shore bank accounts outside the 

jurisdiction of this Court to avoid payment of any monetary judgment awarded to LS&Co. 

Indeed, analysis of financial account transaction logs from previous similar cases indicates that 

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off-shore counterfeiters regularly move funds from U.S.-based financial accounts to offshore 

bank accounts outside the jurisdiction of this Court. 

37. On information and belief, Defendants are an interrelated group of counterfeiters 

working in active concert to knowingly and willfully manufacture, import, distribute, offer for 

sale, and sell Counterfeit Levi’s Products in the same transaction, occurrence, or series of 

transactions or occurrences. Defendants, without any authorization or license from LS&Co., 

have jointly and severally, knowingly and willfully used and continue to use the LEVI’S 

Trademarks in connection with the advertisement, distribution, offering for sale, and sale of 

Counterfeit Levi’s Products into the United States and Illinois over the Internet. 

38. Defendants’ unauthorized use of the LEVI’S Trademarks in connection with the 

advertising, distribution, offering for sale, and sale of Counterfeit Levi’s Products, including the 

sale of Counterfeit Levi’s Products into the United States, including Illinois, is likely to cause 

and has caused confusion, mistake, and deception by and among consumers and is irreparably 

harming LS&Co. 

COUNT I 

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

39. LS&Co. hereby re-alleges and incorporates by reference the allegations set forth 

in the preceding paragraphs. 

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

unauthorized use in commerce of counterfeit imitations of the federally registered LEVI’S 

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

infringing goods. The LEVI’S Trademarks are highly distinctive marks. Consumers have come 

to expect the highest quality from LEVI’S® brand products sold or marketed under the LEVI’S 

Trademarks. 

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41. Defendants have sold, offered to sell, marketed, distributed, and advertised, and 

are still selling, offering to sell, marketing, distributing, and advertising products using 

counterfeit reproductions of the LEVI’S Trademarks without LS&Co.’s permission. 

42. LS&Co. is the exclusive owner of the LEVI’S Trademarks. LS&Co.’s United 

States Registrations for the LEVI’S Trademarks (Exhibit 1) are in full force and effect. On 

information and belief, Defendants have knowledge of LS&Co.’s rights in the LEVI’S 

Trademarks, and are willfully infringing and intentionally using counterfeits of the LEVI’S 

Trademarks. Defendants’ willful, intentional and unauthorized use of the LEVI’S Trademarks is 

likely to cause and is causing confusion, mistake, and deception as to the origin and quality of 

the Counterfeit Levi’s Products among the general public. 

43. Defendants’ activities constitute willful trademark infringement and 

counterfeiting under Section 32 of the Lanham Act, 15 U.S.C. § 1114. 

44. LS&Co. has no adequate remedy at law, and if Defendants’ actions are not 

enjoined, LS&Co. will continue to suffer irreparable harm to its reputation and the goodwill of 

its well-known LEVI’S Trademarks. 

45. The injuries and damages sustained by LS&Co. have been directly and 

proximately caused by Defendants’ wrongful reproduction, use, advertisement, promotion, 

offering to sell, and sale of Counterfeit Levi’s Products. 

COUNT II 

FALSE DESIGNATION OF ORIGIN (15 U.S.C. § 1125(a)) 

46. LS&Co. hereby re-alleges and incorporates by reference the allegations set forth 

in the preceding paragraphs. 

47. Defendants’ promotion, marketing, offering for sale, and sale of Counterfeit 

Levi’s Products has created and is creating a likelihood of confusion, mistake, and deception 

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among the general public as to the affiliation, connection, or association with LS&Co. or the 

origin, sponsorship, or approval of Defendants’ Counterfeit Levi’s Products by LS&Co. 

48. By using the LEVI’S Trademarks in connection with the sale of Counterfeit 

Levi’s Products, Defendants create a false designation of origin and a misleading representation 

of fact as to the origin and sponsorship of the Counterfeit Levi’s Products. 

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

origin and/or sponsorship of the Counterfeit Levi’s Products to the general public involves the 

use of counterfeit marks and is a willful violation of Section 43 of the Lanham Act, 15 U.S.C. § 

1125. 

50. LS&Co. has no adequate remedy at law and, if Defendants’ actions are not 

enjoined, LS&Co. will continue to suffer irreparable harm to its reputation and the goodwill of 

its LEVI’S® brand. 

PRAYER FOR RELIEF 

WHEREFORE, LS&Co. prays for 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 LEVI’S Trademarks or any reproductions, counterfeit 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 a genuine LEVI’S® 

brand product or is not authorized by LS&Co. to be sold in connection with the 

LEVI’S Trademarks; 

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b. passing off, inducing, or enabling others to sell or pass off any product as a genuine 

LEVI’S® brand product or any other product produced by LS&Co., that is not 

LS&Co.’s or not produced under the authorization, control, or supervision of LS&Co. 

and approved by LS&Co. for sale under the LEVI’S Trademarks; 

c. committing any acts calculated to cause consumers to believe that Defendants’ 

Counterfeit Levi’s Products are those sold under the authorization, control or 

supervision of LS&Co., or are sponsored by, approved by, or otherwise connected 

with LS&Co.; 

d. further infringing the LEVI’S Trademarks and damaging LS&Co.’s goodwill; and 

e. manufacturing, shipping, delivering, holding for sale, transferring or otherwise 

moving, storing, distributing, returning, or otherwise disposing of, in any manner, 

products or inventory not manufactured by or for LS&Co., nor authorized by LS&Co. 

to be sold or offered for sale, and which bear any of LS&Co.’s trademarks, including 

the LEVI’S Trademarks, or any reproductions, counterfeit copies or colorable 

imitations thereof; 

2) Entry of an Order that, upon LS&Co.’s request, those with notice of the injunction, 

including, without limitation, any online marketplace platforms such as eBay, AliExpress, 

Alibaba, Amazon, Wish.com, and Dhgate (collectively, the “Third Party Providers”) shall 

disable and cease displaying any advertisements used by or associated with Defendants in 

connection with the sale of counterfeit and infringing goods using the LEVI’S Trademarks; 

3) That Defendants account for and pay to LS&Co. all profits realized by Defendants by reason 

of Defendants’ unlawful acts herein alleged, and that the amount of damages for 

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infringement of the LEVI’S Trademarks be increased by a sum not exceeding three times the 

amount thereof as provided by 15 U.S.C. § 1117; 

4) In the alternative, that LS&Co. be awarded statutory damages for willful trademark 

counterfeiting pursuant to 15 U.S.C. § 1117(c)(2) of $2,000,000 for each and every use of the 

LEVI’S Trademarks; 

5) That LS&Co. be awarded its reasonable attorneys’ fees and costs; and 

6) Award any and all other relief that this Court deems just and proper. 

Dated this 27th day of July 2020. Respectfully submitted, 

/s/ Justin R. Gaudio 

Amy C. Ziegler 

Justin R. Gaudio 

 RiKaleigh C. Johnson 

 Martin F. Trainor 

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 

 rjohnson@gbc.law 

 mtrainor@gbc.law 

 

 Counsel for Plaintiff Levi Strauss & Co.

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