2022-cv-05227

COMPLAINT filed by Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited; Filing fee $ 402, receipt number AILNDC-19877402.

Exhibit 1

Exhibit 2

Exhibit 3

Exhibit 4

Exhibit 5

Exhibit 6

SEALED EXHIBIT by Plaintiffs Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited Schedule A regarding complaint, [1]

MOTION by Plaintiffs Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited for leave to file under seal

CIVIL Cover Sheet

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Manchester United Football Club Limited

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Tottenham Hotspur Limited

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by The Liverpool Football Club and Athletic Grounds Limited

Notice of Claims Involving Trademarks by Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited

ATTORNEY Appearance for Plaintiffs Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited by Justin R. Gaudio

ATTORNEY Appearance for Plaintiffs Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited by Amy Crout Ziegler

ATTORNEY Appearance for Plaintiffs Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited by Justin Tyler Joseph

ATTORNEY Appearance for Plaintiffs Manchester United Football Club Limited, The Liverpool Football Club and Athletic Grounds Limited, Tottenham Hotspur Limited by Kasey Leigh Ewald

CLERK'S NOTICE: Pursuant to Local Rule 73.1(b), a United States Magistrate Judge of this court is available to conduct all proceedings in this civil action. If all parties consent to have the currently assigned United States Magistrate Judge conduct all proceedings in this case, including trial, the entry of final judgment, and all post-trial proceedings, all parties must sign their names on the attached Consent To form. This consent form is eligible for filing only if executed by all parties. The parties can also express their consent to jurisdiction by a magistrate judge in any joint filing, including the Joint Initial Status Report or proposed Case Management Order. (jk2,)

MAILED trademark report to Patent Trademark Office, Alexandria VA.

MAILED to plaintiff(s) counsel Lanham Mediation Program materials.

MOTION by Plaintiffs Liverpool Football Club and Athletic Grounds Limited, The, Manchester United Football Club Limited, Tottenham Hotspur Limited for temporary restraining order including a Temporary Injunction, a Temporary Transfer of the Domain Names, a Temporary Asset Restraint, and Expedited Discovery

MEMORANDUM by Liverpool Football Club and Athletic Grounds Limited, The, Manchester United Football Club Limited, Tottenham Hotspur Limited in support of motion for temporary restraining order, 15

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 16

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

DECLARATION of Laura Harrington regarding memorandum in support of motion 16

Exhibit 1

(Exhibit 2)

DECLARATION of Matthew Collecott regarding memorandum in support of motion 16

Exhibit 1

(Exhibit 2)

DECLARATION of Paul Dicken regarding memorandum in support of motion 16

Exhibit 1

(Exhibit 2)

SEALED EXHIBIT by Plaintiffs Liverpool Football Club and Athletic Grounds Limited, The, Manchester United Football Club Limited, Tottenham Hotspur Limited Exhibit 3 - Parts 1-8 regarding declaration 18, declaration 19, declaration 20

Exhibit 3-1

Exhibit 3-2

Exhibit 3-3

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Exhibit 3-7

(Exhibit 3-8)

MOTION by Plaintiffs Liverpool Football Club and Athletic Grounds Limited, The, Manchester United Football Club Limited, Tottenham Hotspur Limitedfor Electronic Service of Process Pursuant to Fed. R. Civ. P. 4(f)(3)

MEMORANDUM by Liverpool Football Club and Athletic Grounds Limited, The, Manchester United Football Club Limited, Tottenham Hotspur Limited in support of motion for miscellaneous relief 22

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion 23

Exhibit 1

(Exhibit 2)

MOTION by Attorney Kasey L. Ewald to withdraw as attorney for Liverpool Football Club and Athletic Grounds Limited, The, Manchester United Football Club Limited, Tottenham Hotspur Limited. No party information provided

MINUTE entry before the Honorable Manish S. Shah: Plaintiff's ex parte motion to seal, motion for a temporary restraining order, domain transfer, asset restraint, and expedited discovery, and motion for electronic service of process [3] [15] [22] are granted. The plaintiff's written submissions establish that if defendants were informed of this proceeding before a TRO could issue, assets would likely be redirected, defeating plaintiff's interests in identifying defendants, stopping the infringement, and obtaining an accounting. In addition, the submitted evidence establishes a likelihood of success on the merits, the harm to plaintiff is irreparable and an injunction is in the public interest because infringement interferes with the plaintiff's ability to control its intellectual property. Those rights cannot be fully compensated by money damages. There is no countervailing harm to defendants from an order directing them to stop infringement. Electronic service of process does not violate any treaty and is consistent with due process because it is an effective, perhaps the most effective, way to communicate with defendants. Expedited discovery is warranted to identify defendants and implement the asset freeze. If any defendant were to appear and object, the court will take a fresh look at the asset freeze, joinder, and personal jurisdiction. A $50,000 bond is sufficient to secure the injunctive relief. Enter Sealed Temporary Restraining Order. Notices mailed.

SEALED TEMPORARY RESTRAINING ORDER. Signed by the Honorable Manish S. Shah on 10/25/2022. Notices mailed.

MINUTE entry before the Honorable Manish S. Shah: The motion to withdraw as attorney [25] is granted. Attorney Kasey Leigh Ewald is terminated as counsel of record. Notices mailed.

SUMMONS Issued as to Defendant The Partnerships and Unincorporated Associations Identified on Schedule A

SURETY BOND in the amount of $ $50,000.00 posted by Manchester United Football Club Limited et al

MOTION by Plaintiffs Liverpool Football Club and Athletic Grounds Limited, The, Manchester United Football Club Limited, Tottenham Hotspur Limited for extension of time of Temporary Restraining Order

MEMORANDUM by Liverpool Football Club and Athletic Grounds Limited, The, Manchester United Football Club Limited, Tottenham Hotspur Limited in support of extension of time[29]

Declaration of Justin T. Joseph

MINUTE entry before the Honorable Manish S. Shah: The motion for extension of time 29 is granted. The TRO is extended to 11/22/22. Notices mailed.

MOTION by Plaintiffs Liverpool Football Club and Athletic Grounds Limited, The, Manchester United Football Club Limited, Tottenham Hotspur Limited for preliminary injunction, MOTION by Plaintiffs Liverpool Football Club and Athletic Grounds Limited, The, Manchester United Football Club Limited, Tottenham Hotspur Limited for extension of time of Temporary Restraining Order

Exhibit A

MEMORANDUM by Liverpool Football Club and Athletic Grounds Limited, The, Manchester United Football Club Limited, Tottenham Hotspur Limited in support of motion for preliminary injunction, extension of time, [33]

Declaration of Justin T. Joseph

Exhibit 1

SUMMONS Returned Executed by Manchester United Football Club Limited, Liverpool Football Club and Athletic Grounds Limited, The, Tottenham Hotspur Limited as to The Partnerships and Unincorporated Associations Identified on Schedule A on 11/17/2022, answer due 12/8/2022.

Declaration of Justin T. Joseph

Exhibit A

MINUTE entry before the Honorable Manish S. Shah: Any objections to the motion for a preliminary injunction must be properly filed by 11/21/22. If no objections are filed, the motion will be considered unopposed. Notices mailed.

MINUTE entry before the Honorable Manish S. Shah: No defendants have appeared or objected to the motion for a preliminary injunction. The evidence in support of the TRO continues to support the entry of a preliminary injunction. The motion 33 is granted. Enter preliminary injunction. The Clerk is directed to unseal any previously sealed documents in this matter. Plaintiff's counsel is directed to add all defendants listed on Schedule A to the court's docket within three business days. Instructions on how to do so may be located on the court's website at www.ilnd.uscourts.gov/instructions. Notices mailed.

PRELIMINARY INJUNCTION ORDER. Signed by the Honorable Manish S. Shah on 11/22/2022. Notices mailed.

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NOTICE of Voluntary Dismissal by Liverpool Football Club and Athletic Grounds Limited, The, Manchester United Football Club Limited, Tottenham Hotspur Limited as to certain defendant

NOTICE of Voluntary Dismissal by All Plaintiffs as to certain defendant

MOTION by Plaintiffs Liverpool Football Club and Athletic Grounds Limited, The, Manchester United Football Club Limited, Tottenham Hotspur Limited for entry of default, MOTION by Plaintiffs Liverpool Football Club and Athletic Grounds Limited, The, Manchester United Football Club Limited, Tottenham Hotspur Limited for default judgment as to all Defendants

Exhibit A

MEMORANDUM by Liverpool Football Club and Athletic Grounds Limited, The, Manchester United Football Club Limited, Tottenham Hotspur Limited in support of motion for entry of default, motion for default judgment, [41]

Exhibit 1

DECLARATION of Justin R. Gaudio regarding memorandum in support of motion, [42]

Exhibit 1

NOTICE of Motion by Justin Tyler Joseph for presentment of motion for entry of default, motion for default judgment, [41] before Honorable Manish S. Shah on 12/28/2022 at 09:45 AM.

Exhibit A

MINUTE entry before the Honorable Manish S. Shah: Any objections to the motion for default judgment must be properly filed by 9:30 a.m. (U.S. Central Standard Time), on 12/28/22. If no objections are filed, the motion will be considered unopposed. No appearance on the motion is necessary. The motion is taken under advisement.

MINUTE entry before the Honorable Manish S. Shah: No objections to the motion for default judgment have been filed. The motion [41] is granted. Enter Default Judgment and terminate civil case. Notices mailed.

DEFAULT JUDGMENT ORDER. Signed by the Honorable Manish S. Shah on 12/28/2022. Notices mailed.

MAILED Trademark report with Copy of Closing Order dated 12/28/22 to Patent Trademark Office, Alexandria VA.

NOTICE of Removal of Material from the Custody of the Clerk's Office. (Attachment) (Received for docketing 2/17/2023)

FULL SATISFACTION of Judgment regarding order[47] in the amount of $100,000 as to certain defendants