2025-cv-21495

COMPLAINT FOR INJUNCTIVE RELIEF against All Defendants. Filing fees $ 405.00 receipt number AFLSDC-18327995, filed by ADIDAS AG, ADIDAS AMERICA, INC., ADIDAS INTERNATIONAL MARKETING B.V.

Civil Cover Sheet

Exhibit 1 to Complaint - Certificates of Registration for the adidas Trademarks

Clerks Notice of Judge Assignment to Judge Kathleen M. Williams. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Jonathan Goodman is available to handle any or all proceedings in this case. If agreed, parties should complete and file the Consent form found on our website. It is not necessary to file a document indicating lack of consent.

FORM AO 120 SENT TO DIRECTOR OF U.S. PATENT AND TRADEMARK.

Complaint and Exhibits

Plaintiff's Corporate Disclosure Statement by Adidas AG, Adidas International Marketing B.V., Adidas America, Inc. identifying Corporate Parent adidas North America, Inc. for Adidas America, Inc.

Plaintiff's MOTION to Seal per Local Rule 5.4 by Adidas AG, Adidas International Marketing B.V., Adidas America, Inc.

Text of Proposed Order

ORDER OF REFERRAL AND NOTICE OF COURT PRACTICES AND PROCEDURES, referring case to Ch. Magistrate Judge Jonathan Goodman for all discovery disputes and non-dispositive pretrial motions. Signed by Judge Kathleen M. Williams on 4/3/2025. See attached document for full details.

PAPERLESS ORDER granting 5 MOTION to Seal per Local Rule 5.4 filed by adidas AG, adidas International Marketing B.V., and adidas America, Inc. (collectively, "Plaintiffs"). Plaintiffs request that Schedule "A" to Plaintiffs' Complaint and the Summonses be filed under seal until the Court has the opportunity to rule on Plaintiffs' request for temporary ex parte relief and, if granted, the relief ordered therein has been effectuated, and at which time Plaintiffs will subsequently enter Defendants' names into the Court's CM/ECF system. Schedule "A" to Plaintiffs' Complaint and the Summonses shall be filed under seal and shall remain under seal until further order from this Court. Within seven (7) days of completing service, Plaintiffs must move to unseal Schedule "A" and add Defendants as parties through CM-ECF. Signed by Ch. Magistrate Judge Jonathan Goodman on 4/3/2025.

MAGISTRATE JUDGE GOODMAN'S DISCOVERY PROCEDURES ORDER. Signed by Ch. Magistrate Judge Jonathan Goodman on 4/3/2025. See attached document for full details.

Order

NOTICE of emailing copies of sealed filings [ECF Nos. 11; 12] to stephen@smgpa.cloud, raquel@smgpa.cloud, and leo@smgpa.cloud.

Order

NOTICE that a copy of the Sealed Order [ECF No. 16] was emailed on 4/14/2025 to Plaintiffs' counsel at leo@smgpa.cloud; Raquel@smgpa.cloud; and stephen@smgpa.cloud.

PAPERLESS ORDER setting a Zoom Evidentiary Hearing set for 4/18/2025 at 10:00 AM in the Miami Division before Chief Magistrate Judge Jonathan Goodman. All parties will need to download the Zoom App for cell phone, tablet (iPad), and for those using a desktop or a laptop equipped with a webcam to click on the meeting link and install the plug-in when prompted. Then enter the Meeting ID and Password. Each participant needs to log in 10 minutes early, to make sure there are no glitches. The hearing will be conducted via ZOOM, as follows Join ZoomGov Meeting https://www.zoomgov.com/j/1608780619?pwd=1FporstEQXcunMrmzXKdlNXOOy6ciJ.1. Meeting ID: 160 878 0619. Passcode: 678605. This Zoom hearing is the digital equivalent of an actual, in-court hearing, so counsel are expected to dress as though they are in an actual federal courtroom. Persons granted remote access to proceedings are reminded of the general prohibition against photographing, recording, and rebroadcasting of court proceedings. Violation of these prohibitions may result in sanctions, including removal of court issued media credentials, restricted entry to future hearings, denial of entry to future hearings, or any other sanctions deemed necessary by the court. Signed by Chief Magistrate Judge Jonathan Goodman on 4/14/2025.

Plaintiff's MOTION to Unseal Document by Adidas AG, Adidas International Marketing B.V., Adidas America, Inc. Responses due by 4/29/2025.

Text of Proposed Order

NOTICE of Filing Proposed Summons(es) by Adidas AG, Adidas International Marketing B.V., Adidas America, Inc.

Summon(s)

PAPERLESS ORDER granting 19 Plaintiff's MOTION to Unseal Documents. The Clerk of the Court is directed to unseal all documents that have been restricted/sealed on CM/ECF. Signed by Ch. Magistrate Judge Jonathan Goodman on 4/15/2025.

NOTICE of Compliance re 21 Order on Motion to Unseal Documents. All documents in this case have been unsealed per order at DE#21.

AMENDED COMPLAINT FOR INJUNCTIVE RELIEF against All Defendants, filed by Adidas AG, Adidas America, Inc., Adidas International Marketing B.V.

Exhibit 1 to Amended Complaint - Certificates of Registration for the adidas Tra

Plaintiff's NOTICE upon Defendants via Electronic Mail by Adidas AG, Adidas International Marketing B.V., Adidas America, Inc. re [8] Order Referring Case to Magistrate Judge, Notice of Court Practice/to Appear/Other, [10] Order, [11] SEALED REPORT AND RECOMMENDATIONS re [6] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order and Preliminary Injunction and Memorandum of Law In Support Thereof MOTION for Temporary Restraining Order MOTION for Prelimina, [6] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order and Preliminary Injunction and Memorandum of Law In Support Thereof MOTION for Temporary Restraining Order MOTION for Preliminary Injunction, [1] Complaint, [18] Order, Set/Reset Deadlines/Hearings, [16] Order on Motion for Temporary Restraining Order, Order on Sealed Report and Recommendations

Exhibit Certificate of Service

CERTIFICATE OF SERVICE by Adidas AG, Adidas International Marketing B.V., Adidas America, Inc. re [8] Order Referring Case to Magistrate Judge, Notice of Court Practice/to Appear/Other, [10] Order, [11] SEALED REPORT AND RECOMMENDATIONS re [6] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order and Preliminary Injunction and Memorandum of Law In Support Thereof MOTION for Temporary Restraining Order MOTION for Prelimina, [6] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order and Preliminary Injunction and Memorandum of Law In Support Thereof MOTION for Temporary Restraining Order MOTION for Preliminary Injunction, [1] Complaint, [18] Order, Set/Reset Deadlines/Hearings, [16] Order on Motion for Temporary Restraining Order, Order on Sealed Report and Recommendations, upon Defendants via Registrar

CERTIFICATE OF SERVICE by Adidas AG, Adidas International Marketing B.V., Adidas America, Inc. re [5] Plaintiff's MOTION to Seal per Local Rule 5.4, [8] Order Referring Case to Magistrate Judge, Notice of Court Practice/to Appear/Other, [10] Order, [3] Form AO 120/121, [13] Notice (Other), [7] Plaintiff's EX PARTE MOTION for Order Authorizing Alternate Service of Process on Defendants Pursuant to Federal Rule of Civil Procedure 4(f)(3) and Memorandum of Law In Support Thereof, [4] Certificate of Other Affiliates/Corporate Disclosure Statement, [15] Sealed Document, [11] SEALED REPORT AND RECOMMENDATIONS re [6] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order and Preliminary Injunction and Memorandum of Law In Support Thereof MOTION for Temporary Restraining Order MOTION for Prelimina, [2] Clerks Notice of Judge Assignment, [9] Order on Motion to Seal, [6] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order and Preliminary Injunction and Memorandum of Law In Support Thereof MOTION for Temporary Restraining Order MOTION for Preliminary Injunction, [17] Notice (Other), [1] Complaint, [14] Sealed Document, [18] Order, Set/Reset Deadlines/Hearings, [12] Sealed Order on Motion, Order on Ex Parte Motion, [16] Order on Motion for Temporary Restraining Order, Order on Sealed Report and Recommendations, upon Defendants via website posting

PAPERLESS ORDER requiring service of 23 AMENDED COMPLAINT FOR INJUNCTIVE RELIEF on all Defendants. Plaintiffs filed three certificates of service [ECF Nos. 24-1; 25 ; 26 ]. None of the certificates of service indicate that a copy of the 23 AMENDED COMPLAINT FOR INJUNCTIVE RELIEF was served on Defendants and the amended pleading itself does not include a certificate of service. Thus, the Undersigned is uncertain that a copy of the 23 AMENDED COMPLAINT FOR INJUNCTIVE RELIEF has been served on Defendants. This matter is set for a preliminary injunction hearing tomorrow at 10:00 AM. Therefore, by the end of today, Plaintiffs will serve a copy of the 23 AMENDED COMPLAINT FOR INJUNCTIVE RELIEF on all Defendants via e-mail and publication on Plaintiffs' designated website to serve notice (http://servingnotice.com/Ds42a1m/index.html). By the same deadline, Plaintiffs will file a notice of compliance on CM/ECF. Signed by Ch. Magistrate Judge Jonathan Goodman on 4/17/2025.

Summons Issued as to The Individuals, Business Entities, and Unincorporated Associations.

PLAINTIFF'S NOTICE OF FILING BOND in the amount of $10,000 posted by Adidas AG, Adidas International Marketing B.V., Adidas America, Inc. Approved by Judge Kathleen M. Williams

PAPERLESS ORDER regarding the preliminary injunction hearing set for 4/18/2025 at 10:00 AM before the Undersigned. The Court will require attorneys Stephen Gaffigan and Virgilio Gigante to attend this evidentiary hearing in person (since their presence is required at the 10:30 AM hearing before the Undersigned in Case No. 24-cv-24766-KMW Omega SA v. The Individuals, Business Entities, and Unincorporated Associations Identified on Schedule A). Defendants are permitted to attend this hearing via Zoom using the Zoom link and instructions provided in ECF No. 18. Signed by Ch. Magistrate Judge Jonathan Goodman on 4/17/2025.

SUMMONS (Affidavit) Returned Executed on [1] Complaint, [23] Amended Complaint/Amended Notice of Removal, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Adidas International Marketing B.V., Adidas AG, Adidas America, Inc. 888kicks.shop served on 4/17/2025, response/answer due 5/8/2025; 888kicksru.com served on 4/17/2025, response/answer due 5/8/2025; aakicks.com served on 4/17/2025, response/answer due 5/8/2025; adidas-be.com served on 4/17/2025, response/answer due 5/8/2025; adidas-dk.com served on 4/17/2025, response/answer due 5/8/2025; adidas-fi.com served on 4/17/2025, response/answer due 5/8/2025; adidas-france.com served on 4/17/2025, response/answer due 5/8/2025; adidas-hr.com served on 4/17/2025, response/answer due 5/8/2025; adidas-hungar.top served on 4/17/2025, response/answer due 5/8/2025; adidas-mx.com served on 4/17/2025, response/answer due 5/8/2025; adidas-pl.com served on 4/17/2025, response/answer due 5/8/2025; adidas-zxp.com served on 4/17/2025, response/answer due 5/8/2025; adidasac.com served on 4/17/2025, response/answer due 5/8/2025; adidasadizero.fr served on 4/17/2025, response/answer due 5/8/2025; adidasbelgique.com served on 4/17/2025, response/answer due 5/8/2025; adidasbelgium.com served on 4/17/2025, response/answer due 5/8/2025; adidascampus.us served on 4/17/2025, response/answer due 5/8/2025; adidascipela-hr.com served on 4/17/2025, response/answer due 5/8/2025; adidascostarica.co.za served on 4/17/2025, response/answer due 5/8/2025; adidascostarica.com served on 4/17/2025, response/answer due 5/8/2025; adidascroatia.com served on 4/17/2025, response/answer due 5/8/2025; adidasde.com served on 4/17/2025, response/answer due 5/8/2025; adidasgermany.com served on 4/17/2025, response/answer due 5/8/2025; adidasgreece.net served on 4/17/2025, response/answer due 5/8/2025; adidashungary-hu.com served on 4/17/2025, response/answer due 5/8/2025; adidasnmdsale.com served on 4/17/2025, response/answer due 5/8/2025; adidasoman.com served on 4/17/2025, response/answer due 5/8/2025; adidasoutdoorshoes.com served on 4/17/2025, response/answer due 5/8/2025; adidasrunningus.com served on 4/17/2025, response/answer due 5/8/2025; adidasshoespakistan.com served on 4/17/2025, response/answer due 5/8/2025; adidasuk.net served on 4/17/2025, response/answer due 5/8/2025; adidaswebshop.com served on 4/17/2025, response/answer due 5/8/2025; adidasyeezy-hrvatska.com served on 4/17/2025, response/answer due 5/8/2025; adidasyeezys-hrvatska.com served on 4/17/2025, response/answer due 5/8/2025; akicks.net served on 4/17/2025, response/answer due 5/8/2025; askickru.com served on 4/17/2025, response/answer due 5/8/2025; askickru.shop served on 4/17/2025, response/answer due 5/8/2025; askicks.shop served on 4/17/2025, response/answer due 5/8/2025; baskick.store served on 4/17/2025, response/answer due 5/8/2025; baskickru.com served on 4/17/2025, response/answer due 5/8/2025; baskickru.shop served on 4/17/2025, response/answer due 5/8/2025; bekicksru.com served on 4/17/2025, response/answer due 5/8/2025; bekicksru.shop served on 4/17/2025, response/answer due 5/8/2025; buyjordansok.com served on 4/17/2025, response/answer due 5/8/2025; cheapyeezyboostsneakers.shop served on 4/17/2025, response/answer due 5/8/2025; cheapyeezyshoesonline.com served on 4/17/2025, response/answer due 5/8/2025; coco-kicks.xyz served on 4/17/2025, response/answer due 5/8/2025; codykick.com served on 4/17/2025, response/answer due 5/8/2025; comfy-kicks.com served on 4/17/2025, response/answer due 5/8/2025; comfykicks.org served on 4/17/2025, response/answer due 5/8/2025; comfykicks.xyz served on 4/17/2025, response/answer due 5/8/2025; coolkick.shop served on 4/17/2025, response/answer due 5/8/2025; coolkicksla.net served on 4/17/2025, response/answer due 5/8/2025; deadidasa.com served on 4/17/2025, response/answer due 5/8/2025; discountadidasnmd.com served on 4/17/2025, response/answer due 5/8/2025; epkickru.com served on 4/17/2025, response/answer due 5/8/2025; epkickru.shop served on 4/17/2025, response/answer due 5/8/2025; finekick.store served on 4/17/2025, response/answer due 5/8/2025; finekickru.com served on 4/17/2025, response/answer due 5/8/2025; firekicks.online served on 4/17/2025, response/answer due 5/8/2025; firekicks.shop served on 4/17/2025, response/answer due 5/8/2025; goodkicks.shop served on 4/17/2025, response/answer due 5/8/2025; goodkicksru.com served on 4/17/2025, response/answer due 5/8/2025; heskickru.com served on 4/17/2025, response/answer due 5/8/2025; heskickru.shop served on 4/17/2025, response/answer due 5/8/2025; heskicksru.com served on 4/17/2025, response/answer due 5/8/2025; highkickru.com served on 4/17/2025, response/answer due 5/8/2025; highkickru.shop served on 4/17/2025, response/answer due 5/8/2025; hotkicksshop.com served on 4/17/2025, response/answer due 5/8/2025; iskickwho.com served on 4/17/2025, response/answer due 5/8/2025; italyadidas.com served on 4/17/2025, response/answer due 5/8/2025; keepskickru.com served on 4/17/2025, response/answer due 5/8/2025; keepskickru.shop served on 4/17/2025, response/answer due 5/8/2025; kickmax.shop served on 4/17/2025, response/answer due 5/8/2025; kickmax.store served on 4/17/2025, response/answer due 5/8/2025; kickmax.xyz served on 4/17/2025, response/answer due 5/8/2025; kickmaxru.com served on 4/17/2025, response/answer due 5/8/2025; kickmaxshoes.shop served on 4/17/2025, response/answer due 5/8/2025; kickscollect.com served on 4/17/2025, response/answer due 5/8/2025; kicksfind.shop served on 4/17/2025, response/answer due 5/8/2025; kicksfinder.shop served on 4/17/2025, response/answer due 5/8/2025; kicksonfire.shop served on 4/17/2025, response/answer due 5/8/2025; kickstorm.shop served on 4/17/2025, response/answer due 5/8/2025; kickstormru.com served on 4/17/2025, response/answer due 5/8/2025; kickwhocc.xyz served on 4/17/2025, response/answer due 5/8/2025; kickwhoxyz.org served on 4/17/2025, response/answer due 5/8/2025; kickzlucas.shop served on 4/17/2025, response/answer due 5/8/2025; kimikick.shop served on 4/17/2025, response/answer due 5/8/2025; kimikickru.com served on 4/17/2025, response/answer due 5/8/2025; kimikicks.shop served on 4/17/2025, response/answer due 5/8/2025; lookickshoes.com served on 4/17/2025, response/answer due 5/8/2025; lookkicks.com served on 4/17/2025, response/answer due 5/8/2025; mikicksru.com served on 4/17/2025, response/answer due 5/8/2025; niceaaa.com served on 4/17/2025, response/answer due 5/8/2025; one-kicks.com served on 4/17/2025, response/answer due 5/8/2025; onekick.shop served on 4/17/2025, response/answer due 5/8/2025; onekickbook.shop served on 4/17/2025, response/answer due 5/8/2025; onekickru.com served on 4/17/2025, response/answer due 5/8/2025; onekickru.shop served on 4/17/2025, response/answer due 5/8/2025; onekicks.online served on 4/17/2025, response/answer due 5/8/2025; onekicks.store served on 4/17/2025, response/answer due 5/8/2025; onekicksru.com served on 4/17/2025, response/answer due 5/8/2025; onekicksru.shop served on 4/17/2025, response/answer due 5/8/2025; ookicks.com served on 4/17/2025, response/answer due 5/8/2025; pankick.shop served on 4/17/2025, response/answer due 5/8/2025; pankickru.com served on 4/17/2025, response/answer due 5/8/2025; poshkicks.shop served on 4/17/2025, response/answer due 5/8/2025; poshkicksru.com served on 4/17/2025, response/answer due 5/8/2025; skykickru.com served on 4/17/2025, response/answer due 5/8/2025; skykickru.shop served on 4/17/2025, response/answer due 5/8/2025; smartkickru.shop served on 4/17/2025, response/answer due 5/8/2025; sofiakicks.shop served on 4/17/2025, response/answer due 5/8/2025; sofiakicksru.shop served on 4/17/2025, response/answer due 5/8/2025; starkick.shop served on 4/17/2025, response/answer due 5/8/2025; starkickru.com served on 4/17/2025, response/answer due 5/8/2025; stockxkicks.shop served on 4/17/2025, response/answer due 5/8/2025; stockxkicks.us served on 4/17/2025, response/answer due 5/8/2025; superkick.shop served on 4/17/2025, response/answer due 5/8/2025; superkickru.com served on 4/17/2025, response/answer due 5/8/2025; swagkick.shop served on 4/17/2025, response/answer due 5/8/2025; swagkickru.com served on 4/17/2025, response/answer due 5/8/2025; sweetkick.shop served on 4/17/2025, response/answer due 5/8/2025; sweetkickru.shop served on 4/17/2025, response/answer due 5/8/2025; tenkickru.com served on 4/17/2025, response/answer due 5/8/2025; tenkickru.shop served on 4/17/2025, response/answer due 5/8/2025; therunadidas.com served on 4/17/2025, response/answer due 5/8/2025; tikick.store served on 4/17/2025, response/answer due 5/8/2025; tikickru.com served on 4/17/2025, response/answer due 5/8/2025; tikickru.online served on 4/17/2025, response/answer due 5/8/2025; tikickru.shop served on 4/17/2025, response/answer due 5/8/2025; vlookick.com served on 4/17/2025, response/answer due 5/8/2025; winkick.shop served on 4/17/2025, response/answer due 5/8/2025; winkickru.shop served on 4/17/2025, response/answer due 5/8/2025; winkickru.store served on 4/17/2025, response/answer due 5/8/2025; wonder-kick.shop served on 4/17/2025, response/answer due 5/8/2025; wonderkicks.us served on 4/17/2025, response/answer due 5/8/2025; wonderkicks.xyz served on 4/17/2025, response/answer due 5/8/2025; yankeekicks.net served on 4/17/2025, response/answer due 5/8/2025; yankeekicks.org served on 4/17/2025, response/answer due 5/8/2025; yankeekicks.shop served on 4/17/2025, response/answer due 5/8/2025; yeezyoutletstore.com served on 4/17/2025, response/answer due 5/8/2025; yekick.com served on 4/17/2025, response/answer due 5/8/2025; yekickru.shop served on 4/17/2025, response/answer due 5/8/2025; yepkicks.net served on 4/17/2025, response/answer due 5/8/2025.

Affidavit of Service

Affidavit of Service

Affidavit of Service

NOTICE of Compliance by Adidas AG, Adidas International Marketing B.V., Adidas America, Inc. re [27] Order

CERTIFICATE OF SERVICE by Adidas AG, Adidas International Marketing B.V., Adidas America, Inc. re [30] Order, upon Defendants via Electronic Mail and via Website Posting

PAPERLESS Minute Order for proceedings held before Chief Magistrate Judge Jonathan Goodman: Evidentiary Hearing held on 4/18/2025. Report and Recommendations to follow.Total time in court: 11 minutes. Attorney Appearance(s): Stephen Michael Gaffigan, Virgilio Gigante, and T. Raquel Wiborg-Rodriguez. (Digital JG_01_04-18-2025/ Zoom)

REPORT AND RECOMMENDATIONS on [6] Plaintiff's MOTION for Preliminary Injunction. Objections to R&R due by 5/2/2025. Signed by Ch. Magistrate Judge Jonathan Goodman on 4/18/2025. See attached document for full details.

Plaintiff's NOTICE upon Defendants via Electronic Mail by Adidas AG, Adidas International Marketing B.V., Adidas America, Inc. re 35 REPORT AND RECOMMENDATIONS re 6 Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order and Preliminary Injunction and Memorandum of Law In Support Thereof MOTION for Temporary Restraining Order MOTION for Preliminary Inju

(Exhibit Certificate of Sevice)

CERTIFICATE OF SERVICE by Adidas AG, Adidas International Marketing B.V., Adidas America, Inc. re [35] REPORT AND RECOMMENDATIONS re [6] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order and Preliminary Injunction and Memorandum of Law In Support Thereof MOTION for Temporary Restraining Order MOTION for Preliminary Inju upon Defendants via website posting

CERTIFICATE OF SERVICE by Adidas AG, Adidas International Marketing B.V., Adidas America, Inc. re [35] REPORT AND RECOMMENDATIONS re [6] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order and Preliminary Injunction and Memorandum of Law In Support Thereof MOTION for Temporary Restraining Order MOTION for Preliminary Inju upon Defendants via Registrar

Plaintiff's MOTION to Extend Temporary Restraining Order re [16] Order on Motion for Temporary Restraining Order, Order on Sealed Report and Recommendations, by Adidas AG, Adidas International Marketing B.V., Adidas America, Inc.

Text of Proposed Order

ORDER granting [39] Motion to Extend Temporary Restraining Order. Signed by Judge Kathleen M. Williams on 4/23/2025. See attached document for full details.

NOTICE of Compliance by Adidas AG, Adidas International Marketing B.V., Adidas America, Inc. re [35] REPORT AND RECOMMENDATIONS re [6] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order and Preliminary Injunction and Memorandum of Law In Support Thereof MOTION for Temporary Restraining Order MOTION for Preliminary Inju

ORDER ADOPTING REPORT AND RECOMMENDATIONS ; Adopting 35 Report and Recommendations, granting 6 Motion for Preliminary Injunction Signed by Judge Kathleen M. Williams on 5/5/2025. See attached document for full details.

Plaintiff's MOTION for Clerk's Entry of Default as to 888kicks.shop, 888kicksru.com, The Individuals, Business Entities, and Unincorporated Associations, aakicks.com, adidas-be.com, adidas-dk.com, adidas-fi.com, adidas-france.com, adidas-hr.com, adidas-hungar.top, adidas-mx.com, adidas-pl.com, adidas-zxp.com, adidasac.com, adidasadizero.fr, adidasbelgique.com, adidasbelgium.com, adidascampus.us, adidascipela-hr.com, adidascostarica.co.za, adidascostarica.com, adidascroatia.com, adidasde.com, adidasgermany.com, adidasgreece.net, adidashungary-hu.com, adidasnmdsale.com, adidasoman.com, adidasoutdoorshoes.com, adidasrunningus.com, adidasshoespakistan.com, adidasuk.net, adidaswebshop.com, adidasyeezy-hrvatska.com, adidasyeezys-hrvatska.com, akicks.net, askickru.com, askickru.shop, askicks.shop, baskick.store, baskickru.com, baskickru.shop, bekicksru.com, bekicksru.shop, buyjordansok.com, cheapyeezyboostsneakers.shop, cheapyeezyshoesonline.com, coco-kicks.xyz, codykick.com, comfy-kicks.com, comfykicks.org, comfykicks.xyz, coolkick.shop, coolkicksla.net, deadidasa.com, discountadidasnmd.com, epkickru.com, epkickru.shop, finekick.store, finekickru.com, firekicks.online, firekicks.shop, goodkicks.shop, goodkicksru.com, heskickru.com, heskickru.shop, heskicksru.com, highkickru.com, highkickru.shop, hotkicksshop.com, iskickwho.com, italyadidas.com, keepskickru.com, keepskickru.shop, kickmax.shop, kickmax.store, kickmax.xyz, kickmaxru.com, kickmaxshoes.shop, kickscollect.com, kicksfind.shop, kicksfinder.shop, kicksonfire.shop, kickstorm.shop, kickstormru.com, kickwhocc.xyz, kickwhoxyz.org, kickzlucas.shop, kimikick.shop, kimikickru.com, kimikicks.shop, lookickshoes.com, lookkicks.com, mikicksru.com, niceaaa.com, one-kicks.com, onekick.shop, onekickbook.shop, onekickru.com, onekickru.shop, onekicks.online, onekicks.store, onekicksru.com, onekicksru.shop, ookicks.com, pankick.shop, pankickru.com, poshkicks.shop, poshkicksru.com, skykickru.com, skykickru.shop, smartkickru.shop, sofiakicks.shop, sofiakicksru.shop, starkick.shop, starkickru.com, stockxkicks.shop, stockxkicks.us, superkick.shop, superkickru.com, swagkick.shop, swagkickru.com, sweetkick.shop, sweetkickru.shop, tenkickru.com, tenkickru.shop, therunadidas.com, tikick.store, tikickru.com, tikickru.online, tikickru.shop, vlookick.com, winkick.shop, winkickru.shop, winkickru.store, wonder-kick.shop, wonderkicks.us, wonderkicks.xyz, yankeekicks.net, yankeekicks.org, yankeekicks.shop, yeezyoutletstore.com, yekick.com, yekickru.shop, yepkicks.net by Adidas International Marketing B.V., Adidas AG, Adidas America, Inc.

Exhibit Declaration of Stephen M. Gaffigan in Support of Request for Clerk'

Text of Proposed Order

Clerk's Entry of Default as to niceaaa.com, ookicks.com, vlookick.com, 888kicks.shop, 888kicksru.com, akicks.net, askickru.com, askickru.shop, askicks.shop, baskick.store, baskickru.com, baskickru.shop, bekicksru.com, bekicksru.shop, cheapyeezyshoesonline.com, coco-kicks.xyz, codykick.com, comfy-kicks.com, comfykicks.org, comfykicks.xyz, coolkick.shop, coolkicksla.net, epkickru.com, epkickru.shop, finekick.store, finekickru.com, firekicks.online, firekicks.shop, goodkicks.shop, goodkicksru.com, heskickru.com, heskickru.shop, heskicksru.com, highkickru.com, highkickru.shop, iskickwho.com, keepskickru.com, keepskickru.shop, kickmax.shop, kickmax.store, kickmax.xyz, kickmaxshoes.shop, kicksfind.shop, kicksfinder.shop, kicksonfire.shop, kickstorm.shop, kickstormru.com, kickwhocc.xyz, kickwhoxyz.org, kickzlucas.shop, mikicksru.com, onekick.shop, onekickbook.shop, onekickru.com, onekickru.shop, one-kicks.com, onekicks.online, onekicks.store, onekicksru.com, onekicksru.shop, pankick.shop, pankickru.com, poshkicks.shop, poshkicksru.com, skykickru.com, skykickru.shop, smartkickru.shop, sofiakicks.shop, sofiakicksru.shop, starkick.shop, starkickru.com, stockxkicks.shop, stockxkicks.us, superkick.shop, superkickru.com, swagkick.shop, swagkickru.com, sweetkick.shop, sweetkickru.shop, tenkickru.com, tenkickru.shop, tikick.store, tikickru.com, tikickru.online, tikickru.shop, winkick.shop, winkickru.shop, winkickru.store, wonder-kick.shop, wonderkicks.us, wonderkicks.xyz, yankeekicks.net, yankeekicks.org, yankeekicks.shop, yeezyoutletstore.com, yekick.com, yekickru.shop, yepkicks.net, adidasac.com, adidasadizero.fr, adidas-be.com, adidasbelgique.com, adidasbelgium.com, adidascampus.us, adidascipela-hr.com, adidascostarica.co.za, adidascostarica.com, adidascroatia.com, adidasde.com, adidas-dk.com, adidas-fi.com, adidas-france.com, adidasgermany.com, adidasgreece.net, adidas-hr.com, adidas-hungar.top, adidashungary-hu.com, adidas-mx.com, adidasnmdsale.com, adidasoman.com, adidasoutdoorshoes.com, adidas-pl.com, adidasrunningus.com, adidasshoespakistan.com, adidasuk.net, adidaswebshop.com, adidasyeezy-hrvatska.com, adidasyeezys-hrvatska.com, adidas-zxp.com, cheapyeezyboostsneakers.shop, deadidasa.com, discountadidasnmd.com, italyadidas.com, therunadidas.com, aakicks.com, buyjordansok.com, hotkicksshop.com, kickmaxru.com, kickscollect.com, kimikick.shop, kimikickru.com, kimikicks.shop, lookickshoes.com, lookkicks.com - Motions Terminated: 43 Motion for Clerks Entry of Default, Signed by DEPUTY CLERK on 5/19/2025.

PAPERLESS ORDER. THIS MATTER is before the Court on the Clerk's Entry of Default as to the Schedule A Defendants (DE 44). On or before June 18, 2025, Plaintiffs shall file a motion for final default judgment against Defendants and serve it in accordance with Rule 55(b)(2) of the Federal Rules of Civil Procedure. The motion must reference specific legal authority establishing Plaintiffs' entitlement to the relief sought and demonstrating that service was proper. The motion must be accompanied by (1) a proposed default final judgment order setting forth the sum certain owed as money damages and the sum certain sought for attorneys' fees and costs supported by sufficient evidence, through affidavits or otherwise, to establish the basis for damages and other relief sought in the pleadings and (2) a proposed final judgment. Signed by Judge Kathleen M. Williams on 5/19/2025.

Plaintiff's MOTION for Default Judgment and Memorandum of Law in Support Thereof by Adidas AG, Adidas America, Inc., Adidas International Marketing B.V.

Declaration of Virgilio Gigante in Support Thereof

Text of Proposed Order Granting Motion for Default Final Judgment

Text of Proposed Order Granting Default Final Judgment and Permanent Injunction

PAPERLESS ORDER REFERRING MOTION. THIS MATTER is before the Court sua sponte. Pursuant to 28 U.S.C. § 636 and the Magistrate Rules of the Local Rules for the Southern District of Florida, Plaintiffs' Motion for Entry of Default Final Judgment Against Defendants (DE 46) is REFERRED to Chief Magistrate Judge Jonathan Goodman for a report and recommendation. Signed by Judge Kathleen M. Williams on 6/19/2025.

REPORT AND RECOMMENDATIONS on 46 Plaintiff's MOTION for Default Judgment and Memorandum of Law in Support Thereof filed by Adidas America, Inc., Adidas International Marketing B.V. and Adidas AG. Objections to R&R due by 7/28/2025. Signed by Ch. Magistrate Judge Jonathan Goodman on 7/25/2025. See attached document for full details.

NOTICE of Voluntary Dismissal of Defendant Numbers 16, 116, 133, 142, and 144 by Adidas AG, Adidas America, Inc., Adidas International Marketing B.V.

CERTIFICATE OF SERVICE by Adidas AG, Adidas America, Inc., Adidas International Marketing B.V. re [48] REPORT AND RECOMMENDATIONS re [46] Plaintiff's MOTION for Default Judgment and Memorandum of Law in Support Thereof filed by Adidas America, Inc., Adidas International Marketing B.V., Adidas AG upon Defendants via website posting

CERTIFICATE OF SERVICE by Adidas AG, Adidas America, Inc., Adidas International Marketing B.V. re [48] REPORT AND RECOMMENDATIONS re [46] Plaintiff's MOTION for Default Judgment and Memorandum of Law in Support Thereof filed by Adidas America, Inc., Adidas International Marketing B.V., Adidas AG upon Defendants via Electronic Mail

CERTIFICATE OF SERVICE by Adidas AG, Adidas America, Inc., Adidas International Marketing B.V. re [48] REPORT AND RECOMMENDATIONS re [46] Plaintiff's MOTION for Default Judgment and Memorandum of Law in Support Thereof filed by Adidas America, Inc., Adidas International Marketing B.V., Adidas AG upon Defendants via Registrar

NOTICE of Compliance by Adidas AG, Adidas America, Inc., Adidas International Marketing B.V. re [48] REPORT AND RECOMMENDATIONS re [46] Plaintiff's MOTION for Default Judgment and Memorandum of Law in Support Thereof filed by Adidas America, Inc., Adidas International Marketing B.V., Adidas AG

Case Reassignment of Paired Magistrate Judge

Case Reassignment of Paired Magistrate Judge pursuant to Administrative Order(s) - 2025-52A to Magistrate Judge Enjolique A. Lett. Magistrate Judge Jonathan Goodman no longer assigned to case.

Paperless Order. THIS MATTER is before the Court on Plaintiffs' Notice of Voluntary Dismissal Without Prejudice as to Defendant Numbers 16, 116, 133, 142, and 144 (DE 49) ("Notice"). Upon review of the Notice and the record, it is ORDERED AND ADJUDGED that this action is DISMISSED WITHOUT PREJUDICE as to Defendants akicks.net (Defendant Number 16), adidascostarica.co.za (Defendant Number 116), adidasrunningus.com (Defendant Number 133), discountadidasnmd.com (Defendant Number 142), and therunadidas.com (Defendant Number 144), as identified in Schedule A of Plaintiffs' Amended Complaint (DE 23 at 24-27). Each party is to bear their own attorneys' fees and costs. This case will remain open as to the remaining Defendant. Signed by Judge Kathleen M. Williams on 8/1/2025.

DEFAULT FINAL JUDGMENT AND PERMANENT INJUNCTION in favor of Plaintiffs, adidas AG, adidas International Marketing B.V., and adidas America, Inc. "Plaintiffs" and against Defendants, the Individuals, Business Entities and Unincorporated Associations identified on Schedule "A". Signed by Judge Kathleen M. Williams on 8/11/2025. See attached document for full details.

ORDER AFFIRMING and ADOPTING DE [48] REPORT AND RECOMMENDATIONS ; Plaintiffs' Motion for Entry of Default Final Judgment Against Defendants is GRANTED and CLOSING CASE. Signed by Judge Kathleen M. Williams on 8/11/2025. See attached document for full details.

FORM AO 120 SENT TO DIRECTOR OF U.S. PATENT AND TRADEMARK

(Default Final Judgment and Permanent Injunction) (blc)