Case: 1:22-cv-05458 Document #: 1 Filed: 10/05/22 Page 1 of 34 PageID #:1
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF ILLINOIS
`EASTERN DIVISION
`
`
`Case No. 22-cv-05458
`
`
`
`
`
`
`
`NBA PROPERTIES, INC.,
`
`Plaintiff,
`
`
`v.
`
`THE PARTNERSHIPS and
`UNINCORPORATED ASSOCIATIONS
`IDENTIFIED ON SCHEDULE “A,”
`
`Defendants.
`
`
`
`COMPLAINT
`
`Plaintiff NBA Properties, Inc. (“NBAP” or “Plaintiff”) 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 (collectively, the “Seller Aliases”). Specifically, Defendants have
`
`
`1 The e-commerce store urls are listed on Schedule A hereto under the Online Marketplaces and Domain
`Names.
`
`

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`Case: 1:22-cv-05458 Document #: 1 Filed: 10/05/22 Page 2 of 34 PageID #:2
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`
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`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, have sold and
`
`continue to sell products using infringing and counterfeit versions of Plaintiff’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 Plaintiff substantial
`
`injury in the State of Illinois.
`
`II. INTRODUCTION
`
`3.
`
`This action has been filed by Plaintiff to combat e-commerce store operators who
`
`trade upon Plaintiff’s reputation and goodwill by offering for sale and/or selling unauthorized
`
`and unlicensed products using infringing and counterfeit versions of one or more of the
`
`trademarks owned and/or licensed by Plaintiff (the “Counterfeit NBA Products”). Plaintiff is a
`
`member of the Coalition to Advance the Protection of Sports logos (“CAPS”), which is
`
`administered by Trademark Management LLC (“TML”). In collaboration with CAPS, Plaintiff
`
`has established a comprehensive program of trademark protection and enforcement. In
`
`particular, CAPS has created an extensive anti-counterfeiting program for Plaintiff, which
`
`includes regularly investigating suspicious e-commerce stores and enforcing Plaintiff’s
`
`trademark rights to prevent the sale of Counterfeit NBA Products.
`
`4.
`
`Defendants create e-commerce stores operating under one or more Seller Aliases
`
`that are advertising, offering for sale and selling Counterfeit NBA Products to unknowing
`
`consumers. E-commerce stores operating under the Seller Aliases share unique identifiers,
`
`establishing a
`
`logical relationship between
`
`them and demonstrating
`
`that Defendants’
`
`counterfeiting operation arises out of the same transaction, occurrence, or series of transactions
`
`
`
`2
`
`

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`Case: 1:22-cv-05458 Document #: 1 Filed: 10/05/22 Page 3 of 34 PageID #:3
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`
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`or occurrences. Defendants attempt to avoid and mitigate liability by operating under one or
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`more Seller Aliases to conceal both their identities and the full scope and interworking of their
`
`counterfeiting operations. Plaintiff is forced to file these actions to combat Defendants’
`
`counterfeiting of the trademarks owned or licensed by Plaintiff, as well as to protect unknowing
`
`consumers from purchasing Counterfeit NBA Products over the Internet. Plaintiff has been
`
`irreparably harmed 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.
`
`NBA Properties, Inc.
`
`III. THE PARTIES
`
`5.
`
`Plaintiff NBAP is a corporation duly organized and existing under the laws of the
`
`State of New York with its principal place of business at 645 Fifth Avenue, New York, New
`
`York.
`
`6.
`
`The National Basketball Association (“NBA”) is an unincorporated association
`
`and professional basketball league, comprised of thirty (30) member teams (“NBA Teams”),
`
`including the Chicago Bulls, that provide professional basketball entertainment services and that
`
`collectively own NBAP.
`
` NBAP manages trademark affairs, including licensing and
`
`enforcement, for the NBA and NBA Teams.
`
`7.
`
`NBAP is the owner and/or the exclusive licensee of the famous and distinctive
`
`trademarks of the NBA and the NBA Teams, and is authorized to enforce the rights in those
`
`trademarks. NBAP commercially exploits, protects and enforces rights in the famous and
`
`distinctive trademarks, names, logos, symbols, emblems, uniform designs, uniform trade dress
`
`colors, and other identifying indicia associated with the NBA and the NBA Teams (collectively,
`
`
`
`3
`
`

`

`Case: 1:22-cv-05458 Document #: 1 Filed: 10/05/22 Page 4 of 34 PageID #:4
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`
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`the “NBA Trademarks”), including, but not limited to, those that are the subject of valid and
`
`subsisting trademark registrations on the Principal Register of the United States Patent and
`
`Trademark Office and those that NBAP and the NBA Teams have adopted and used in
`
`commerce throughout the United States, including in Illinois. NBAP owns more than one
`
`hundred fifty (150) United States Federal Trademark Registrations in a variety of classes and for
`
`a variety of different goods and services, including, without limitation, many for apparel, such as
`
`jerseys, shirts, caps, and other products in international class 25. Among the NBA Trademarks
`
`owned by NBAP and registered before the United States Patent and Trademark Office are the
`
`word mark “NBA” (reg. no. 1,833,902) and the NBA Player Silhouette Logo:
`
` (reg. no.
`
`1,966,924). A partial list of the famous and distinctive NBA Trademarks owned by NBAP,
`
`registered before the United States Patent and Trademark Office, and currently in use in
`
`commerce includes the following:
`
`Registration
`Number
`
`Trademark
`
`Goods and Services
`
`1,833,902
`
`NBA
`
`2,183,983
`
`NATIONAL
`BASKETBALL
`ASSOCIATION
`
`1,525,782
`
`
`
`For: clothing, namely, hosiery, footwear, sweat shirts,
`sweatpants, pants, tank tops, jerseys, shorts, pajamas,
`sport shirts, rugby shirts, belts, ties, nightshirts, hats,
`warm-up suits, jackets, parkas, coats, cloth bibs, head
`bands and wrist bands in class 025.
`For: clothing, namely, hosiery, footwear, t-shirts, sweat
`shirts, sweatpants, pants, tank tops, jerseys, shorts,
`pajamas, sport shirts, rugby shirts, sweaters, belts, ties,
`nightshirts, hats, warm-up suits, jackets, parkas, coats,
`cloth bibs, head bands, wrist bands, aprons, boxer
`shorts, slacks, caps, ear muffs and gloves in class 025.
`For: hosiery, footwear, t-shirts, sweat shirts, tank tops,
`pajamas, sport shirts, belts, nightshirts, stocking caps,
`warm-up or jogging suits, jackets, bibs, head bands and
`wrist bands in class 025.
`
`For: entertainment services, namely, organizing and
`conducting basketball exhibitions in class 041.
`
`
`
`4
`
`

`

`Case: 1:22-cv-05458 Document #: 1 Filed: 10/05/22 Page 5 of 34 PageID #:5
`
`1,715,549
`
`1,966,924
`
`2,157,039
`
`2,079,493
`
`5,237,767
`
`1,946,924
`
`
`
`
`
`For: jewelry; namely, wrist watches, pins, earrings,
`necklaces, rings, cuff links and belt buckles in class
`014.
`
`For: clothing, namely hosiery, footwear, t-shirts, sweat
`shirts, sweatpants, pants, tank tops, jerseys, shorts,
`pajamas, sport shirts, rugby shirts, sweaters, belts, ties,
`nightshirts, hats, warm-up suits, jackets, parkas, coats,
`cloth bibs, head bands, wrist bands, aprons, boxer
`shorts, slacks, caps, ear muffs, and gloves in class 025.
`
`For: clothing, namely, hosiery, footwear, sweat shirts,
`sweatpants, pants, tank tops, jersey, shorts, pajamas,
`sport shirts, rugby shirts, sweaters, belts, ties,
`nightshirts, warm-up suits, parkas, coats, cloth bibs,
`head bands and wrist bands in class 025.
`
`For: clothing, namely, hosiery, footwear, sweat shirts,
`sweatpants, pants, tank tops, jerseys, shorts, pajamas,
`sport shirts, rugby shirts, sweaters, belts, ties,
`nightshirts, warm-up suits, parkas, coats, cloth bibs,
`head bands and wrist bands in class 025.
`
`
`
`
`
`
`
`
`
`For: Jewelry; costume jewelry; beaded jewelry; rubber
`or silicon wristbands in the nature of a bracelet, beaded
`necklaces; beads for use in the manufacture of jewelry;
`earrings, necklaces, rings, bracelets, cuff links,
`pendants, charms for collar jewelry and bracelets;
`clocks; watches; watch bands and watch straps, watch
`cases, watch fobs; jewelry boxes, tie clips; medallions;
`non-monetary coins of precious metal; precious
`metals; key chains of precious metal; key chains as
`jewelry; figures and figurines of precious metal;
`trophies of precious metals in class 014.
`ATLANTA HAWKS For: clothing, namely hosiery, footwear, T-shirts,
`sweat shirts, sweatpants, pants, tank tops, jerseys,
`shorts, pajamas, sport shirts, rugby shirts, sweaters,
`belts, ties, nightshirts, hats, warm-up suits, jackets,
`parkas, coats, cloth bibs, head bands, wrist bands,
`
`
`
`5
`
`

`

`Case: 1:22-cv-05458 Document #: 1 Filed: 10/05/22 Page 6 of 34 PageID #:6
`
`4,778,504
`
`1,003,131
`
`1,806,185
`
`4,175,932
`
`
`
`
`
`
`
`aprons, boxer shorts, slacks, caps, ear muffs, and
`gloves in class 025
`For: Clothing, namely, hosiery, footwear, basketball
`shoes, basketball sneakers, T-shirts, shirts, polo shirts,
`sweatshirts, sweatpants, pants, tank tops, jerseys,
`shorts, pajamas, sport shirts, rugby shirts, sweaters,
`belts, ties, nightshirts, hats, caps, visors, warm-up
`suits, warm-up pants, warm-up tops/shooting shirts,
`jackets, wind resistant jackets, parkas, coats, baby bibs
`not of paper, head bands, wrist bands, aprons,
`undergarments, boxer shorts, slacks, ear muffs, gloves,
`mittens, scarves, woven and knit shirts, jersey dresses,
`dresses, cheerleading dresses and uniforms, swim
`wear, bathing suits, swimsuits, bikinis, tankinis, swim
`trunks, bathing trunks, board shorts, wet suits, beach
`cover-ups, bathing suit cover-ups, bathing suit wraps,
`sandals, beach sandals, beach hats, sun visors, swim
`caps, bathing caps, novelty headwear with attached
`wigs in class 025
`BOSTON CELTICS For: sports apparel, comprising sweatshirts in class 025
`
`For: hosiery, footwear, T-shirts, sweat shirts,
`sweatpants, pants, tank tops, jerseys, shorts, pajamas,
`sport shirts, rugby shirts, sweaters, belts, nightshirts,
`hats, warm-up suits, jackets, parkas, coats, cloth bibs,
`head bands and wrist bands in class 025
`
`
`
`BROOKLYN NETS For: Clothing, namely, hosiery, footwear, basketball
`shoes, basketball sneakers, T-shirts, shirts, polo shirts,
`sweatshirts, sweatpants, pants, tank tops, jerseys,
`shorts, pajamas, sport shirts, rugby shirts, sweaters,
`belts, ties, nightshirts, hats, caps, visors, warm-up
`suits, warm-up pants, warm-up tops, shooting shirts,
`jackets, wind resistant jackets, parkas, coats, baby bibs
`not of paper, head bands, wrist bands, aprons,
`undergarments, boxer shorts, slacks, ear muffs, gloves,
`mittens, scarves, woven and knit shirts, jersey dresses,
`dresses, cheerleading dresses and uniforms, swim
`wear, bathing suits, swimsuits, bikinis, tankinis, swim
`trunks, bathing trunks, board shorts, wet suits, beach
`cover-ups, bathing suit cover-ups, bathing suit wraps,
`sandals, beach sandals, beach hats, sun visors, swim
`caps, bathing caps, novelty headwear with attached
`wigs in class 025
`
`6
`
`

`

`Case: 1:22-cv-05458 Document #: 1 Filed: 10/05/22 Page 7 of 34 PageID #:7
`
`4,264,484
`
`
`
`1,650,195
`
`4,784,171
`
`CHARLOTTE
`HORNETS
`
`1,836,873
`
`BULLS
`
`4,501,347
`
`
`
`
`
`For: Clothing, namely, hosiery, footwear, basketball
`shoes, basketball sneakers, T-shirts, shirts, polo shirts,
`sweatshirts, sweatpants, pants, tank tops, jerseys,
`shorts, pajamas, sport shirts, rugby shirts, sweaters,
`belts, ties, nightshirts, hats, caps, visors, warm-up
`suits, warm-up pants, warm-up tops/shooting shirts,
`jackets, wind resistant jackets, parkas, coats, baby bibs
`not of paper, head bands, wrist bands, aprons,
`undergarments, boxer shorts, slacks, ear muffs, gloves,
`mittens, scarves, woven and knit shirts, jersey dresses,
`dresses, cheerleading dresses and uniforms, swim
`wear, bathing suits, swimsuits, bikinis, tankinis, swim
`trunks, bathing trunks, board shorts, wet suits, beach
`cover-ups, bathing suit cover-ups, bathing suit wraps,
`sandals, beach sandals, beach hats, sun visors, swim
`caps, bathing caps, novelty headwear with attached
`wigs in class 025
`For: clothing; namely, tee shirts in class 025
`
`For: Clothing, namely, T-shirts, shirts, polo shirts,
`sweatshirts, sweatpants, pants, shorts, pajamas, sport
`shirts, hats, caps, jackets, wind resistant jackets, baby
`bibs not of paper, sandals, beach sandals in class 025
`
`For: clothing; namely, hosiery, footwear, T-shirts,
`sweat shirts, sweatpants, pants, tank tops, jerseys,
`shorts, pajamas, sport shirts, rugby shirts, sweaters,
`belts, ties, nightshirts, hats, warm-up suits, jackets,
`parkas, coats, cloth bibs, head bands and wrist bands in
`class 025
`For : Clothing, namely, hosiery, footwear, basketball
`shoes, basketball sneakers, T-shirts, shirts, polo shirts,
`sweatshirts, sweatpants, pants, tank tops, jerseys,
`shorts, pajamas, sport shirts, rugby shirts, sweaters,
`belts, ties, nightshirts, hats, caps, visors, warm-up
`suits, warm-up pants, warm-up tops/shooting shirts,
`jackets, wind resistant jackets, parkas, coats, baby bibs
`not of paper, head bands, wrist bands, aprons,
`undergarments, boxer shorts, slacks, ear muffs, gloves,
`mittens, scarves, woven and knit shirts, jersey dresses,
`dresses, cheerleading dresses and uniforms, swim
`wear, bathing suits, swimsuits, bikinis, tankinis, swim
`trunks, bathing trunks, board shorts, wet suits, beach
`cover-ups, bathing suit cover-ups, bathing suit wraps,
`sandals, beach sandals, beach hats, sun visors, swim
`
`7
`
`
`
`
`
`

`

`Case: 1:22-cv-05458 Document #: 1 Filed: 10/05/22 Page 8 of 34 PageID #:8
`
`3,028,591
`
`CLEVELAND
`CAVALIERS
`
`2,983,889
`
`
`
`3,100,138
`
`DALLAS
`MAVERICKS
`
`
`
`
`
`caps, bathing caps, novelty headwear with attached
`wigs in class 025
`For: Clothing, namely hosiery, footwear, basketball
`shoes, basketball sneakers, T-shirts, shirts, polo shirts,
`sweatshirts, sweatpants, pants, tank tops, jerseys,
`shorts, pajamas, sport shirts, rugby shirts, sweaters,
`belts, ties, nightshirts, hats, caps, visors, warm-up
`suits, warm-up pants, warm-up tops/shooting shirts,
`jackets, wind resistant jackets, parkas, coats, baby bibs
`not of paper, head bands, wrist bands, aprons,
`undergarments, boxer shorts, slacks, caps, ear muffs,
`gloves, mittens, scarves, woven and knit shirts, jersey
`dresses, dresses, cheerleading dresses and uniforms,
`swim wear, bathing suits, swimsuits, bikinis, tankinis,
`swim trunks, bathing trunks, board shorts, wet suits,
`beach cover-ups, bathing suit cover-ups, bathing suit
`wraps, sandals, beach sandals, beach hats, sun visors,
`swim caps, bathing caps, novelty headwear with wigs
`in class 025
`
`For: clothing, namely hosiery, footwear, basketball
`shoes, basketball sneakers, T-shirts, shirts, sweatshirts,
`sweatpants, pants, tank tops, jerseys, shorts, pajamas,
`sport shirts, rugby shirts, sweaters, belts, ties,
`nightshirts, hats, caps, warm-up suits, warm-up pants,
`warm-up tops, jackets, wind resistant jackets, parkas,
`coats, cloth baby bibs, head bands, wrist bands, aprons,
`boxer shorts, slacks, ear muffs, gloves, mittens,
`scarves, woven and knit shirts, cheerleading dresses
`and uniforms in class 025
`For: Clothing, namely hosiery, footwear, basketball
`shoes, basketball sneakers, T-shirts, shirts, polo shirts,
`sweatshirts, sweatpants, pants, tank tops, jerseys,
`shorts, pajamas, sport shirts, rugby shirts, sweaters,
`belts, ties, nightshirts, hats, caps, visors, warm-up
`suits, warm-up pants, warm-up tops/shooting shirts,
`jackets, wind resistant jackets, parkas, coats, baby bibs
`not of paper, head bands, wrist bands, aprons,
`undergarments, boxer shorts, slacks, caps, ear muffs,
`gloves, mittens, scarves, woven and knit shirts, jersey
`dresses, dresses, cheerleading dresses and uniforms,
`swim wear, bathing suits, swimsuits, bikinis, tankinis,
`swim trunks, bathing trunks, board shorts, wet suits,
`beach cover-ups, bathing suit cover-ups, bathing suit
`wraps, sandals, beach sandals, beach hats, sun visors,
`swim caps, bathing caps, novelty headwear with
`
`8
`
`

`

`Case: 1:22-cv-05458 Document #: 1 Filed: 10/05/22 Page 9 of 34 PageID #:9
`
`DENVER
`NUGGETS
`
`2,754,325
`
`3,078,918
`
`3,607,613
`
`3,023,617
`
`
`
`
`
`9
`
`
`
`
`
`attached wigs in class 025
`For: Clothing, namely, hosiery, footwear, T-shirts,
`sweatshirts, sweatpants, pants, tank tops, jerseys,
`shorts, pajamas, sport shirts, rugby shirts, sweaters,
`belts, ties, nightshirts, hats, warm-up suits, jackets,
`parkas, coats, cloth bibs, head bands, wrist bands,
`aprons, boxer shorts, slacks, caps, ear muffs, gloves,
`mittens, woven and knits shirts in class 025
`
`For: Clothing, namely, hosiery, footwear, basketball
`shoes, basketball sneakers, T-shirts, shirts, polo shirts,
`sweatshirts, sweatpants, pants, tank tops, jerseys,
`shorts, pajamas, sport shirts, rugby shirts, sweaters,
`belts, ties, nightshirts, hats, caps, visors, warm-up
`suits, warm-up pants, warm-up tops/shooting shirts,
`jackets, wind resistant jackets, parkas, coats, baby bibs
`not of paper, head bands, wrist bands, aprons,
`undergarments, boxer shorts, slacks, ear muffs, gloves,
`mittens, scarves, woven and knit shirts, jersey dresses,
`dresses, cheerleading dresses and uniforms, swim
`wear, bathing suits, swimsuits, bikinis, tankinis, swim
`trunks, bathing trunks, board shorts, wet suits, beach
`cover-ups, bathing suit cover-ups, bathing suit wraps,
`sandals, beach sandals, beach hats, sun visors, swim
`caps, bathing caps, novelty headwear with wigs in
`class 025
`For: Clothing, namely, hosiery, footwear, basketball
`shoes, basketball sneakers, T-shirts, shirts, polo shirts,
`sweatshirts, sweatpants, pants, tank tops, jerseys,
`shorts, pajamas, sport shirts, rugby shirts, sweaters,
`belts, ties, nightshirts, hats, caps, visors, warm-up
`suits, warm-up pants, warm-up tops/shooting shirts,
`jackets, wind resistant jackets, parkas, coats, baby bibs
`not of paper, head bands, wrist bands, aprons,
`undergarments, boxer shorts, slacks, ear muffs, gloves,
`mittens, scarves, woven and knit shirts, jersey dresses,
`dresses, cheerleading dresses and uniforms, swim
`wear, bathing suits, swimsuits, bikinis, tankinis, swim
`trunks, bathing trunks, board shorts, wet suits, beach
`cover-ups, bathing suit cover-ups, bathing suit wraps,
`sandals, beach sandals, beach hats, sun visors, swim
`caps, bathing caps, novelty headwear with attached
`wigs in class 025
`
`DETROIT PISTONS For: Clothing, namely hosiery, footwear, basketball
`shoes, basketball sneakers, T-shirts, shirts, polo shirts,
`
`

`

`Case: 1:22-cv-05458 Document #: 1 Filed: 10/05/22 Page 10 of 34 PageID #:10
`
`sweatshirts, sweatpants, pants, tank tops, jerseys,
`shorts, pajamas, sport shirts, rugby shirts, sweaters,
`belts, ties, nightshirts, hats, caps, visors, warm-up
`suits, warm-up pants, warm-up tops/shooting shirts,
`jackets, wind resistant jackets, parkas, coats, baby bibs
`not of paper, head bands, wrist bands, aprons,
`undergarments, boxer shorts, slacks, caps, ear muffs,
`gloves, mittens, scarves, woven and knit shirts, jersey
`dresses, dresses, cheerleading dresses and uniforms,
`swim wear, bathing suits, swimsuits, bikinis, tankinis,
`swim trunks, bathing trunks, board shorts, wet suits,
`beach cover-ups, bathing suit cover-ups, bathing suit
`wraps, sandals, beach sandals, beach hats, sun visors,
`swim caps, bathing caps, novelty headwear with wigs
`in class 025
`For: hosiery, footwear, t-shirts, sweat shirts,
`sweatpants, tank tops, jerseys, shorts, pajamas, sport
`shirts, sweaters, belts, nightshirts, hats, warm-up suits,
`jackets, bibs, head bands and wrist bands in class 025
`
`For: Clothing, namely, hosiery, footwear, basketball
`shoes, basketball sneakers, T-shirts, shirts, polo shirts,
`sweatshirts, sweatpants, pants, tank tops, jerseys,
`shorts, pajamas, sport shirts, rugby shirts, sweaters,
`belts, ties, nightshirts, hats, caps, visors, warm-up
`suits, warm-up pants, warm-up tops/shooting shirts,
`jackets, wind resistant jackets, parkas, coats, baby bibs
`not of paper, head bands, wrist bands, aprons,
`undergarments, boxer shorts, slacks, caps, ear muffs,
`gloves, mittens, scarves, woven and knit shirts, jersey
`dresses, dresses, cheerleading dresses and uniforms,
`swim wear, bathing suits, swimsuits, bikinis, tankinis,
`swim trunks, bathing trunks, board shorts, wet suits,
`beach cover-ups, bathing suit cover-ups, bathing suit
`wraps, sandals, beach sandals, beach hats, sun visors,
`swim caps, bathing caps, novelty headwear in the
`nature of hats, caps or headbands with wigs attached
`sold as a unit in class 025
`For: Clothing, namely, hosiery, footwear, T-shirts,
`shirts, polo shirts, sweatshirts, sweatpants, pants, tank
`tops, jerseys, shorts, pajamas, sweaters, belts, ties,
`nightshirts, hats, caps, warm-up suits, warm-up pants,
`warm-up tops/shooting shirts, jackets, wind resistant
`jackets, coats, baby bibs not of paper, head bands,
`wrist bands, aprons, undergarments, boxer shorts,
`
`10
`
`1,598,692
`
`
`
`3,718,639
`
`GOLDEN STATE
`WARRIORS
`
`4,023,727
`
`
`
`
`
`
`
`

`

`Case: 1:22-cv-05458 Document #: 1 Filed: 10/05/22 Page 11 of 34 PageID #:11
`
`3,235,838
`
`2,931,889
`
`3,100,157
`
`
`
`
`
`HOUSTON
`ROCKETS
`
`slacks, ear muffs, gloves, mittens, scarves, woven and
`knit shirts, jersey dresses, dresses, cheerleading dresses
`and uniforms, swim wear, bathing suits, swimsuits,
`bikinis, tankinis, swim trunks, bathing trunks, board
`shorts, sandals, beach sandals, novelty headwear with
`attached wigs in class 025
`For: Clothing, namely hosiery, footwear, basketball
`shoes, basketball sneakers, T-shirts, shirts, polo shirts,
`sweatshirts, sweat pants, pants, tank tops, jerseys,
`shorts, pajamas, sport shirts, rugby shirts, sweaters,
`belts, ties, nightshirts, hats, caps, visors, warm-up
`suits, warm-up pants, warm-up tops/shooting shirts,
`jackets, wind resistant jackets, parkas, coats, baby bibs
`not of paper, head bands, wrist bands, aprons,
`undergarments, boxer shorts, slacks, caps, ear muffs,
`gloves, mittens, scarves, woven and knit shirts, jersey
`dresses, dresses, cheerleading dresses and uniforms,
`swim wear, bathing suits, swimsuits, bikinis, tankinis,
`swim trunks, bathing trunks, board shorts, wet suits,
`beach cover-ups, bathing suit cover-ups, bathing suit
`wraps, sandals, beach sandals, beach hats, sun visors,
`swim caps, bathing caps, novelty head wear with wigs
`in class 025
`For: Clothing, namely hosiery, footwear, basketball
`shoes, basketball sneakers, T-shirts, shirts, sweatshirts,
`sweatpants, pants, tank tops, jerseys, shorts, pajamas,
`sport shirts, rugby shirts, sweaters, belts, ties,
`nightshirts, hats, caps, warm-up suits, warm-up pants,
`warm-up tops, jackets, wind resistant jackets, parkas,
`coats, cloth baby bibs, head bands, wrist bands, aprons,
`boxer shorts, slacks, caps, ear muffs, gloves, mittens,
`scarves, woven and knit shirts, dresses, cheerleading
`dresses and uniforms in class 025
`INDIANA PACERS For: Clothing, namely hosiery, footwear, basketball
`shoes, basketball sneakers, T-shirts, shirts, polo shirts,
`sweatshirts, sweatpants, pants, tank tops, jerseys,
`shorts, pajamas, sport shirts, rugby shirts, sweaters,
`belts, ties, nightshirts, hats, caps, visors, warm-up
`suits, warm-up pants, warm-up tops/shooting shirts,
`jackets, wind resistant jackets, parkas, coats, baby bibs
`not of paper, head bands, wrist bands, aprons,
`undergarments, boxer shorts, slacks, caps, ear muffs,
`gloves, mittens, scarves, woven and knit shirts, jersey
`dresses, dresses, cheerleading dresses and uniforms,
`swim wear, bathing suits, swimsuits, bikinis, tankinis,
`swim trunks, bathing trunks, board shorts, wet suits,
`
`
`
`11
`
`

`

`Case: 1:22-cv-05458 Document #: 1 Filed: 10/05/22 Page 12 of 34 PageID #:12
`
`1,981,366
`
`
`
`3,035,417
`
`LOS ANGELES
`CLIPPERS
`
`5,120,178
`
`
`
`3,095,079
`
`LOS ANGELES
`LAKERS
`
`beach cover-ups, bathing suit cover-ups, bathing suit
`wraps, sandals, beach sandals, beach hats, sun visors,
`swim caps, bathing caps, novelty headwear with wigs
`in class 025
`For: clothing; namely, hosiery, footwear, T-shirts,
`sweat shirts, sweatpants, pants, tank tops, jerseys,
`shorts, pajamas, sport shirts, rugby shirts, sweaters,
`belts, ties, nightshirts, hats, warm-up suits, jackets,
`parkas, coats, cloth bibs, head bands and wrist bands in
`class 025
`For: Clothing, namely hosiery, footwear, basketball
`shoes, basketball sneakers, T-shirts, shirts, polo shirts,
`sweatshirts, sweatpants, pants, tank tops, jerseys,
`shorts, pajamas, sport shirts, rugby shirts, sweaters,
`belts, ties, nightshirts, hats, caps, visors, warm-up
`suits, warm-up pants, warm-up tops/shooting shirts,
`jackets, wind resistant jackets, parkas, coats, baby bibs
`not of paper, head bands, wrist bands, aprons,
`undergarments, boxer shorts, slacks, caps, ear muffs,
`gloves, mittens, scarves, woven and knit shirts, jersey
`dresses, dresses, cheerleading dresses and uniforms,
`swim wear, bathing suits, swimsuits, bikinis, tankinis,
`swim trunks, bathing trunks, board shorts, wet suits,
`beach cover-ups, bathing suit cover-ups, bathing suit
`wraps, sandals, beach sandals, beach hats, sun visors,
`swim caps, bathing caps, novelty headwear with wigs
`in class 025
`For: Clothing, namely, hosiery, footwear, basketball
`shoes, basketball sneakers, slippers, T-shirts, shirts,
`polo shirts, sweatshirts, sweatpants, pants, tank tops,
`jerseys, shorts, pajamas, sport shirts, rugby shirts,
`sweaters, belts, ties, nightshirts, hats, caps, visors,
`warm-up suits, warm-up pants, warm-up tops/shooting
`shirts, jackets, wind resistant jackets, parkas, coats,
`baby bibs not of paper, head bands, wrist bands,
`aprons, undergarments, boxer shorts, slacks, ear muffs,
`gloves, mittens, scarves, woven and knit shirts, jersey
`dresses, dresses, cheerleading dresses and uniforms,
`swim wear, bathing suits, swimsuits, bikinis, tankinis,
`swim trunks, bathing trunks, board shorts, wet suits,
`beach cover-ups, bathing suit cover-ups, bathing suit
`wraps, sandals, beach sandals, beach hats, sun visors,
`swim caps, bathing caps, novelty headwear with
`attached wigs in class 025
`For: Clothing, namely hosiery, footwear, basketball
`shoes, basketball sneakers, T-shirts, shirts, polo shirts,
`
`12
`
`
`
`
`
`

`

`Case: 1:22-cv-05458 Document #: 1 Filed: 10/05/22 Page 13 of 34 PageID #:13
`
`
`
`
`
`3,095,083
`
`
`
`2,861,210
`
`MEMPHIS
`GRIZZLIES
`
`sweatshirts, sweatpants, pants, tank tops, jerseys,
`shorts, pajamas, sport shirts, rugby shirts, sweaters,
`belts, ties, nightshirts, hats, caps, visors, warm-up
`suits, warm-up pants, warm-up tops/shooting shirts,
`jackets, wind resistant jackets, parkas, coats, baby bibs
`not of paper, head bands, wrist bands, aprons,
`undergarments, boxer shorts, slacks, caps, ear muffs,
`gloves, mittens, scarves, woven and knit shirts, jersey
`dresses, dresses, cheerleading dresses and uniforms,
`swim wear, bathing suits, swimsuits, bikinis, tankinis,
`swim trunks, bathing trunks, board shorts, wet suits,
`beach cover-ups, bathing suit cover-ups, bathing suit
`wraps, sandals, beach sandals, beach hats, sun visors,
`swim caps, bathing caps, novelty headwear with wigs
`in class 025
`For: Clothing, namely hosiery, footwear, basketball
`shoes, basketball sneakers, T-shirts, shirts, polo shirts,
`sweatshirts, sweatpants, pants, tank tops, jerseys,
`shorts, pajamas, sport shirts, rugby shirts, sweaters,
`belts, ties, nightshirts, hats, caps, visors, warm-up
`suits, warm-up pants, warm-up tops/shooting shirts,
`jackets, wind resistant jackets, parkas, coats, baby bibs
`not of paper, head bands, wrist bands, aprons,
`undergarments, boxer shorts, slacks, caps, ear muffs,
`gloves, mittens, scarves, woven and knit shirts, jersey
`dresses, dresses, cheerleading dresses and uniforms,
`swim wear, bathing suits, swimsuits, bikinis, tankinis,
`swim trunks, bathing trunks, board shorts, wet suits,
`beach cover-ups, bathing suit cover-ups, bathing suit
`wraps, sandals, beach sandals, beach hats, sun visors,
`swim caps, bathing caps, novelty headwear with wigs
`in class 025
`For: Clothing, namely hosiery, footwear, T-shirts,
`shirts, sweatshirts, sweatpants, pants, tank tops,
`jerseys, shorts, pajamas, sport shirts, rugby shirts,
`sweaters, belts, ties, nightshirts, hats, warm-up suits,
`warm-up pants, warm-up tops, jackets, parkas, coats,
`cloth bibs, head bands, wrist bands, aprons, boxer
`shorts, slacks, caps, ear muffs, gloves, mittens, woven
`and knit shirts in class 025
`
`13
`
`

`

`Case: 1:22-cv-05458 Document #: 1 Filed: 10/05/22 Page 14 of 34 PageID #:14
`
`3,056,500
`
`2,179,772
`
`MIAMI HEAT
`
`1,962,650
`
`3,081,981
`
`MILWAUKEE
`BUCKS
`
`
`
`
`
`For: Clothing, namely hosiery, footwear, basketball
`shoes, basketball sneakers, T-shirts, shirts, sweatshirts,
`sweatpants, pants, tank tops, jerseys, shorts, pajamas,
`sport shirts, rugby shirts, sweaters, belts, ties,
`nightshirts, hats, caps, visors, warm-up suits, warm-up
`pants, warm-up tops/shooting shirts, jackets, wind
`resistant jackets, parkas, coats, baby bibs not of paper,
`head bands, wrist bands, aprons, undergarments, boxer
`shorts, slacks, caps, ear muffs, gloves, mittens, scarves,
`woven and knit shirts, jersey dresses, dresses,
`cheerleading dresses and uniforms, swim wear, bathing
`suits, beach cover-ups, bathing suit cover-ups, bath suit
`wraps, and beach sandals, novelty headwear with wigs
`in class 025
`For: clothing, namely, tee-shirts, all sold in promotion
`of, and in connection with, the professional basketball
`team known as Miami Heat, or a professional
`basketball team which is the successor-in-interest of
`that name, or a professional basketball association in
`class 025
`For: clothing, namely hosiery, footwear, T-shirts,
`sweat shirts, sweatpants, pants, tank tops, jerseys,
`shorts, pajamas, sport shirts, rugby shirts, sweaters,
`belts, ties, nightshirts, hats, warm-up suits, jackets,
`parkas, coats, cloth bibs, head bands and wrist bands in
`class 025
`For: Clothing, namely hosiery, footwear, basketball
`shoes, basketball sneakers, T-shirts, shirts, polo shirts,
`sweatshirts, sweatpants, pants, tank tops, jerseys,
`shorts, pajamas, sport shirts, rugby shirts, sweaters,
`belts, ties, nightshirts, hats, caps, visors, warm-up
`suits, warm-up pants, warm-up tops, shooting shirts,
`jackets, wind resistant jackets, parkas, coats, baby bibs
`not of paper, head bands, wrist bands, aprons,
`undergarments, boxer shorts, slacks, caps, ear muffs,
`gloves, mittens, scarves, woven and knit shirts, jersey
`dresses, dresses, cheerleading dresses and uniforms,
`swim wear, bathing suits, swimsuits, bikinis, tankinis,
`swim trunks, bathing trunks, board shorts, wet suits,
`beach cover-ups, bathing suit cover-ups, bathing suit
`wraps, sandals, beach sandals, beach hats, sun visors,
`swim caps, bathing caps, novelty headwear with wigs
`in class 025
`
`14
`
`
`
`
`
`

`

`Case: 1:22-cv-05458 Document #: 1 Filed: 10/05/22 Page 15 of 34 PageID #:15
`
`5,087,429
`
`
`
`1,513,653
`
`5,414,453
`
`MINNESOTA
`TIMBERWOLVES
`
`
`
`4,632,955
`
`NEW ORLEANS
`PELICANS
`
`For: Clothing, namely, hosiery, footwear, basketball
`shoes, basketball sneakers, slippers, T-shirts, shirts,
`polo shirts, sweatshirts, sweatpants, pants, tank tops,
`jerseys, shorts, pajamas, sport shirts, rugby shirts,
`sweaters, belts, ties, nightshirts, hats, caps, visors,
`warm-up suits, warm-up pants, warm-up tops/shooting
`shirts, jackets, wind resistant jackets, parkas, coats,
`baby bibs not of paper, head bands, wrist bands,
`aprons, undergarments, boxer shorts, slacks, ear muffs,
`gloves, mittens, scarves, woven and knit shirts, jersey
`dresses, dresses, cheerleading dresses and uniforms,
`swim wear, bathing suits, swimsuits, bikinis, tankinis,
`swim trunks, bathing trunks, board shorts, wet suits,
`beach cover-ups, bathing suit