Beckman vs. Chicago Bears

Case: 1:17-cv-04551 Document #: 1 Filed: 06/16/17 Page 1 of 43 PageID #:1
REEEIVED
t-cD
JUN 1 0 2017
IN THE UNITED STATES DISTRICT COURT
FORTHE NORTHERN DISTRICT OF ILLINOIS ."-ll?j$B8ffiI33,*,
EASTERN DIVISION
RUSSELL BECKMAN, and any other

similarly situated individual, 17 CV 4551
Plaintiff, Judge Gottschall
Magistrate Judge Gilbert
v.
CHICAGO BEAR FOOTBALL CLUB,

INC., a Delaware Corporation, and the
NATIONAL FOOTBALL LEAGUE, an
unincorporated association,
Defendant(s).
COMPLAINT AND REOUEST FOR INJUNCTIONI

I. The Parties to This Complaint
A. The Plaintiff
Russell Beckman
431I Durand Avenue, #209
Mount Pleasant, Racine County
Wisconsin 53405
(262)94s-124e
rbeckman62@yahoo.com
B. The Defendants(s)
DefendantNo. 1
Chicago Bear Football Club, lnc.

A Delaware Corporation
1920 Football Drive,
Lake Forest, Lake County
Illinois,60045
(847)6ts-2390
ticket.offi ce@bears.nfl .net
1 The Plaintiffl, a pro se litigant, in order to conform with Rule LR.52.[c) has adapted this complaint
format from the following source: "pro se 2 (rev. 72/16) complaint and requestfor injunction"
Retrieved on May 31,20!7 from
http://www.uscourts.gov/sites/default/files/complaint and request for injunction.pdf .
Defendant No. 2
National Football League (I.IFL)

An unincorporated association of 32 professional football teams
345 Park Avenue
New York, New York County
New York, 10154
Unknown phone number and email address
II Basis for Jurisdiction
The basis for federal court jurisdiction is both "federal question" and "diversity of
citizenship."
A. If the Basis for Jurisdiction Is a Federal Question
List the specific federal statutes, federal treaties, and/or provisions of the United
States Constitution that are at issue in this case-
United States Constitution; The right of the plaintiff and his companions to
freedom of speech guaranteed by the First Amendment via the due process clause
of the Fourteenth Amendment. (Soldier Field is a public facility that was publicly
financed and is owned by the City of Chicago Park District.)
B. If the Basis for Jurisdiction is Diversity of Citizenship
l. The Plaintiff
a. The Plaintiff, Russell Beckman, is an individual and is a citizen of
the State of Wisconsin.
2. The Defendan(s)
a. The Defendant, the Chicago Bear Football Club, Inc., is a
corporation and is incorporated under the laws of the State of Delaware"
and has its principal place of business in the State of illinois.

b. The Defendant, the National Football League (NFL) ts an
unincorporated association consistin g of separately owned professional
football teams that operate out of many different cities and states in this
country. The NFL has its principal place of business in the State of New
York and maintains its offices at345 Park Avenue, New York, New York.
It has thirty-two franchise teams that are based in or play home games in
twenty-two states. One of these franchise teams is the Chicago Bears, the
other defendant in this action. The Bears are based in the Eastern Division
of the Northern Judicial District of illinois. The NFL also has a franchise
team, the Green Bay Packers, based in the Eastern Judicial District of
Wisconsin. The Bears play the Packers once a year during the regular
season in Green Bay. The Plaintiff in this action resides in the Eastern
District of Wisconsin.
3. The Amount in Controversy
The Plaintiff is not seeking compensatory or punitive damages from the
Defendants. This action is seeking injunctive relief and the
reimbursement of the Plaintiff s court and service fees for this action.
ur. Statement of Claim
A. Where did the events giving rise to your claim(s) occur?
Soldier Field, Chicago, Illinois. Soldier Field is a publicly financed facility owned
by the Chicago Park District.

B. What date and approximate time did the events giving rise to your claim(s) occur?
December 18,2016 at approximately 10:30am. This is also an ongoing and
repeatable annual event.
C. What are the facts underlying your claim(s)?
1. I am a Chicago Bear personal seat license (PSL) owner who has five
corresponding season tickets (STFD. As part of the benefits of my PSL and STH
status with the Bears, myself and a companion were allowed to stand on the edge
of the playing field to observe pre-game warrn ups for the 2014 and 2015 season
gzrmes between the Bears and the Green Bay Packers at Soldier Field. At each of
these games and while participating in each of those year's experiences, my
companion and I wore Green Bay Packer apparel. It appears that these 2014 and
2015 experiences were a Bears initiative in providing experiences for a select
group of season ticket holders and was a pilot program for a more formalized and
expansive "STH experience" program it would unveil at the start of the 2016
season.
2. During the off season prior to the 2016 season, the Bear's mailed a
solicitation to season ticket holders offering the opportunity to purchase personal
seat licenses for seats they occupied with their season tickets. I already owned
PSL's for my two club seats. However, I did not own PSL's for my three other
seats in the south end zone. [n large part because I wanted to maintain my ability
for me, my family, including future grandchildren, and friends, to be able to

continue to enjoy this on-field experience long into the future, I purchased PSL's
for my three end zone seats. The ability to participate in this experience only
added to the tremendous enjoyment I experience, with my family and friends, at
this annual game.
3. Prior to the start of 2016 seztson, the Bears enacted a progrilm to reward
season ticket holders with "points" from which they could purchase
"Experiences." On July 13, 2016,I received an email from the Bears. This email
informed me that I had been awarded--or had actually earned, based upon a
formula developed by the Bears--eleven points that I could use to purchase
"experiences."(exhibit A, pp. 7-9.) On August 1,2016,I used the points I was
awarded to purchase three spots for the "pregame warn-up field experience" at
the December 18, 2016 game between the Bears and the Packers. (exhibit A, pp.
11-13.)
4. On December 12,2016,I received an email from the Bears that provided
specific information regarding participation in this December 18,2016
experience. Among other stated rules and conditions, this email indicated "NO
OPPOSING TEAM GEAR WILL BE ALLOWED."2 (exhibit A, pp. 14-16)
5. Since I intended to wear Packer apparel to this game and during my
participation in this experience, over the next few days, I exchanged several
emails and telephone calls with Bear's ticket office staff. In the end, I was
specifically and clearly informed that I would not be allowed to participate in this
2 The wording was in all caps in the email.

experience if I wore any Packer apparel. I informed the Bears that I would show
up to the experience registration location on game day wearing my Packer
apparel. I did so, and I was denied participation in the experience. My two
companions wore no apparel representing any NFL team so they would not be
denied participation in this very unique experience. Both of these companions
were allowed to participate in this experience. (exhibit A, pp. 17-24.)
6. On January 3,2017,I mailed, via United States Postal Service certified
mail (exhibit B.), a detailed written appeal to NFL Commissioner Roger Goodell.
(exhibit A.) In this written appeal, I asked that he intervene in this dispute and
order or persuade the Bears to stop imposing this rule in the future. There was no
response. A copy of this appeal was also emailed to Brendan Pierce, of the Bears
ticket office, on January 2,1017.
7 . On May 15,2017,I received an email from the Bears informing me that
for the 2017 season I will have twelve points that I can use to purchase
experiences and other benefits through this ongoing program. (exhibit C.) The
twelve points I have been awarded for this year will allow me to purchase four
"pregame wann-up field credentials" for the November 12,2017 game between
the Bears and the Packers.ilr: This email contained a link that provided further
details about the program that provides these experiences to season ticket holders.
(http ://www. ch ica gobears. com/ti ckets-and-
stadium/experiences.html?camefrom=EMCl_ I 645 896 642365 5I ) What follows
is a copy and paste directly from the "Frequently Asked Questions" portion of this
web page:
" Freq uently Asked Questions
What is the STH Experiences program?

STH Experiences is afree benefits program that allows Chicago Bears Season Ticket Holders to
create q customized and memorable Bears eyent experience. The program delivers exclusive perks
and exciting events to Season Ticlet Holders via the Chicago Bears Oficial Mobile App.
l{ho is eligible to access STH Experiences?

STH Experiences is a program designed exclusivelyfor all Chicago Bears Season Ticlet
Holders. "
8. On May 25,2017,I was accessing the Bear's mobile app on my cell
phone. [t is through this app that all of these benefits and experiences for Bears
season ticket holders are purchased. At this time, I checked this app for the listing
for the "pregame wann-up field credential" for the November 12,2017 garne
between the Bears and the Packers. This listing had the following under a heading
titled "Things to know:": "No visiting team clothing allowed." (exhibit D.)[E
9. This published rule indicates the Bears will, once again, deny me and any
companions access to the held on November 12,2017, when I attempt to redeem
my duly purchased "pregame warm-up field credentials" while I am clad in
Packer apparel.
10. Additionally, I checked the Bears mobile app for the listed rules for the
"pregame warrn-up field credential" for each of the 2017 Bear home games. The
listing for every 2017 home game had this prohibition against wearing visiting
team apparel. Thus, there are likely other similarly situated Bear season ticket
holders and their companions who, like me, already have and will continue to be
denied access to this experience simply because they are dressed in opposing team
gear.
IV. Irreparable Injur.v
Explain why monetary damages at a later time would not adequately compensate you for
the injuries you sustained, are sustaining, or will sustain as a result of the events
described above, or why such compensation could not be measured.
11. As previously indicated, I was able to enjoy this on-field pregame warrn-
up experience in both the2014 and 2015 seasons at the annual game between the
Bears and Packers at Soldier Field. It is these years that the Bears first started its
pilot program for STH Experiences. During these two experiences, my
companions and I wore Packer apparel and we were not denied participation in
this experience. These two experiences were very enjoyable for both me and my
companion.
12. The Bears host the Packers at Soldier Field only once per regular season.
Because I am a Bear Season ticket holder, I have attended the Bear Packer game
in Chicago every year since I became a season ticket holder in 2003. Also, i
attended the NFC Championship game between the Bears and the Packers at
Soldier Field on January 23,2011. I generally attend these games with my
children, who are now all young adults. I have always wom Packer apparel to
these games. It is part of a long time tradition for my family to attend both home
and away Packer games.
13. Due to the prohibition that forbids wearing visiting team apparel while
participating in this specific experience, the Bears have, without any compelling
or reasonable cause, or Constifutionally mandated reason, deprived me of my
ability to fully enjoy this specific on-field experience and the general experience
of the Bears Packer game at Soldier Field. Because it is impossible to place a
monetary value on this loss, I am not seeking compensation, other than court
costs, from the defendants. I am only seeking that the Bears and the NFL be
ordered by the court to not enforce this rule for the 2017 season and beyond. If the
defendants are allowed to continue to enforce this rule, my harm continues
indefinitely.
v. Relief
State briefly and precisely what damages or other relief the plaintiff asks the court to
order. Do not make legal arguments. Include any basis for claiming that the wrongs
alleged are continuing at the present time. Include the amounts of any actual damages
claimed for the acts alleged and the basis for these amounts. Include any punitive or
exemplary damages claimed, the amounts, and the reasons you claim you are entitled to
the actual punitive money damages.
14. The relief I seek is simply that the Bears and the NFL be ordered by the
court to not enforce this rule for the 2017 season and subsequent seasons.
15. I am not seeking monetary damages. I would only ask that the defendants
be ordered to pay my court filing fees and service fees. I have decided to not hire
an attomey and I will represent myself to pursue this matter because I have no
desire to incur large costs that could be possibly assessed to the defendants. I
believe this matter is simple enough that I can pursue it on my own and I am
doing so in good faith, only after exhausting all reasonable attempts to resolve this
matter with the two defendants prior to filing this action.

VI. Certification and Closing
Under Federal Rule of Civil Procedure 11, by signing below, I certiff to the best of my
knowledge, information, and belief that this complaint: (l) is not being presented for an
improper purpose, such as to harass, cause unnecessary delay, or needlessly increase the
cost of litigation; (2) is supported by existing law or by a nonfrivolous argument for
extending, modiffing, or reversing existing law; (3) the factual contentions have
evidentiary support or, if specifically so identified, will likely have evidentiary support
after a reasonable opportunity for further investigation or discovery; and (4) the
complaint otherwise complies with the requirements of Rule 11.
A. For Parties Without an Attorney
I agree to provide the Clerk's Office with any changes to my address where case-
related papers may be served. I understand that my failure to keep a current
address on file with the Clerk's Office may result in the dismissal of my case.
Dateorsign rrr, 6- I 6' I 7

Signature of Plaintiff
Printed Name of Plaintiff Russell Beckman
The Plaintiff is a pro se litigant. His contact information is as follows:
Russell Beckman
4311 Durand Avenue, #209
Mount Pleasant, Racine County
Wisconsin 53405
(262)94s-1249
rbec.kman62@yahoo.com
L0
List of Exhibits
ffudge's Copy)
ExhibitA: This was the written appeaf dated |anuary 2,20L7, thatwas mailed to
NFL Commissioner Rodger Goodell asking that he intervene in this dispute with the
Chicago Bears. This packet of materials consists of the following items:
. Actual letter (5 pages) to Mr. Goodell with the following attachments:

o Email from Bears dated fuly 13, 20L6. [three pagesJ
o Attachment to |uly t3 20t6 email. (one page)
o Experience receipt email from the Bears on August L,20L6. (three
pages)
o Email from Bears dated December L2,2AL6. (two pages)
o Attachment to December 12,20L6 email. (one page)
o Email exchange between me and Bears ticket offlce staff. December
13-15, 2AL6 fthree pages)
o Attachment to my December L3,20L6 email to the aforementioned
December 13-15th exchange. [This is a photo of me and one of my
daughters at the Packer/Buccaneers game on Decemb er 2L,201,4. I
wore the same outfit to the Bears/Packer game on Decemb er 12,
2015J(one page)
o Email exchange between me and Brendan Pierce of the Bears.
December t5-L7 . 20L6. (three pagesJ
o Photo of me atthe September t3,20LS Packer/Bears game while I am
was on the field enjoying the "Pregame Warm-up Field Credential
Experience." fone page)
Exhibit B: United States Postal Service certified mail receipt documenting proof
of deliver of the aforementioned Exhibit A to the NFL offices in New York. (one
page)
Exhibit C: Email from the Chicago Bears to the plaintiff dated May 15, 20L7.
(two pages)
Exhihit D: Screen Shot from my cellular phone accessing part of my Chicago

Bears "STH Experiences" account on the Chicago Bears cellular phone app on May
25,20L7. (one page)
Exhibit
Rus*llBeckman Exhibft#/2
4311 Durand Avenue, S209
Mount Fleasant, Wl 534Os
(?52)*45-1249
Page 2ofu
Rbeckman62@vahoo.com
January 2,?:077
Co rnmissioner Roger Goodell

f'lational Football League
345 Park Avenue,
New York, NY 1t)154
Oelivered uia Unitrd States Po*al Serv{ce f.grtiffd lvkil-
Dear Mr. Goodell:
that you and the NFL intervene in a dispute that I am having with the
I am asking
Chicago Bears- This letter, which willbe lengthy, will provide detailed information about me,
my history as a fan *nd seassn ticket holder with two NFLteams, and the basis for this dispute.
I am bringing this dispute to you whh the best of intentions and with the goal of avoiding
titigation, Please know that t feel very strongly about this matter. I will bt respectfully
persistent in my attmpts to resolve this matter.
The basis of my dispute with the Chicago Sears istheir refusal to allow rne to participate
in a season ticket holder'Pregame Warm*up Field Credeotial Experiefic" duringthe Becenrber
18, 2016 Bears/Packer garne because I declined to not wear, or co\rer'up, my Packer apparel-
(See attached emails between ma and the Chicago Bears ticket office that provide some specific
infornration related to the implementation of this neu, policy.)
I believe ttre Bears intend to aontinue to eaforce this new rule into the future. I believe
this new policy is rnisguided and eCIntrary to both cornffion sens and to the NFL's operational
mission $tetemeot.! I also believe this new policy will cause harrn to all HFL stakeholders, which
include fans like me. t hope that you will see the folly in this new policy and use your power as
the chief exec$tive officer of the franchisor to direct the Bears to revert to their original pollcy
that addressed this specific season tickt holder experience-
Footbdll Operotions' missiaa is to ests0lisl, o cufture of clority, consrsfeary and credibility in all
' 'rVFl
aspec6 of the grrliltest gaffie. Faotbatt is an essential piece af Amerieo's fakic, uniting fons, players ond
carnmunities with a simpte yet gtrerfut bo*d- We honor aur Eome's histary while continuing to innwate
and preserve oursp*t lwfutwe generc$io{rs af fans, play,ers, toothes, tesfiB aN offiials.'
Copied and pasted from the fotlowi*g web site on January 1, 2O17: http:#q*eta!i+,?*.fitl"eqm/
Exhibi t#/-
What follows are the relevant facts related to this dispute:
hily persofial history as an llFl/Packer fun:

Page Lof 4
first became a football fan as a child in the late 196&. I grew up in a city cn the
I
Wisconsin/lllinois border and followed both the Bears and the Packers. However, I uhimately
committed to being a Packer fan. I attended my first NFL game as a twelve year old at the old
Milwaukee County Stadium.
tn the early 198Sr I put myself an the waiting list for Packer season tickets for both
6reen Bay and Milwaukee game$. I obtained tiekets for the three gamet the Packers played at
the old Milwaukee County Stadium in the mid 198Os. When the Packers moved all games to
Green Bay in 1995, my Milwaukee season tickets turned to "Gold Package" Packer season
tickets. ln 2013, after waiting nearly three decades. I was finally offered an opportunity to
purchase 'Green Package" season tickets from the Packers.
Throughout the 1980s and untilthe arrival of Erett Farve, I rrrras always able to obtain
Lambeau Field Packer season tickets at face value from regular seagon ticket holders who no
{onger attended games due to the poor product the Packers put on the field, I chuckle when
people claim that the Packers have sold out Eames for decades. The truth is that during those
lean years, it was often dfficult to give tickets away to Packer home gemes. {l find it ironic that
the Bears are currently experiencingthe same phenomenon. lt is a fact that no tEam is immune
from down times. All that is required for reduced dernand for tickets are a few years of on-field
mediocracy.) Also, from the mid L980's to 2003, I attended the PackerlBear game in Chicago
most years- I also frequently traveled to other NFL venues to enioy Packer away Sarnes-
I should also note that I have three young aduh children. I put each child on the Packer
season ticket waiting list on the day after they were born. Due to their cure*t ages, and their
relatively low position on that list, I expect that each of them will have their own $eeson Packer
se8son tickets in the next ten years.
Specific Infonnatioc regarding my rtat$ as a Chicago Eeam seasoo tickt holder:
put myself on the list for five Bears season tickets $ometirne after 1985. ln the eady
I
2O0Os the Chicago Park Distrist started a nearty one billion dollar renovation of Soldier Field to
accommodate the Chicago Bears. I was offered an oppo*unity to purchase personal seat
licenses in the new Bea/s home stadium- I purehased two club seat personalseat licenses and
obtained three other non-PSL seats in the south ead eone.
first game at this neu, venue on September 29, 2003 against the Packers. I
I was at the
was there with two of my children. tln fact, my children went with me to most of the NFL
games I attended from the time they were beyond first grade.) Since that first game, I have not
missed a PackerlBear game in f,hicago. I am also proud that rny narne is listed on a public
display at Soldier Field of Eears Charter Personal Seat Ucense Holders.
Prior to the 2014 season, the Bears started a well-intended program to reward club seat
season ticket holders with perks or experiences. I took advantage of many of these
Exhibit#l
Page 3 oQt
experiences. I attended several eventr at Hallas Hall. I alto regularly attended the exclt"lsive
club seat holder events at the Bear's Family night in early August" lt i5 important to note that I
have never worn NFL team apparel of any team to these Bear events. I do so because these
events are more intimate and I want to respect my fellow Eear se;son ticket holders at these
events. flowever, I consider aaual PmkerlBear games at Soldier Field to be events in which I
can proudly wear my Packer colors.
ln 2014, the tsears initiated the "Fregarne Warm-up Field Credential Experience."
Eecause of my status as a club seat PSL holder, I was entitled to two passes for this experience"
On September 28, 2AL4,l enjoyed this experience at the Bear/Packer game with my daughter.
Both of us wore Packer gear. lt was en absolutely great time. Myself and other Bear season
ticket holders were able to stand on the field for the pre-game warmups, in the north end zone,
right next to visitor team or. for this Eame, the Packer tunnel-
ln 2015, I was able to enjoy this same experience. At the September 13, 2015
BearlPacker garne in Chicago myself and a dear friend, both wearing Paclcer apparel, enjoyed
this experience. We stood in the same location as the previous year. During this experience, it
was my privilege to share a warrn conversation with Packer President Mark Murphy. I also
exchanged pleasantries with and shook your hand, Mr. Goodell. I doubt that ynu remember
this encounter since these are very (ommon for you. However, for me, a regular fan of the NFL,
it was very cool" (l enclosed a photo of me et this game while I was on the field for that garne.
You can see how I was dressed and maybe it will refresh your memory of our encounter. )
Rll of thsse experiences, especially the "Pregame Warm-up Field Credential Experience,'
offered by the Bears to their Season ticket holders, were excellent. During the off season, I
reflected about how great it was to be a season tirket holder for two NFL teams end how
fortunate I was to have the foresight to st myself up decades earlier when I first put myself an
both teams' isa$sn ticket waiting lists. One of nry major motivations in doing this was to
establish opportunities for my children and future grandchildren to also enjoy HFL games and
experiences. Even though the Packers are my team, I am reatly a fan of the game and all that
surrounds it. I believe I am a true example of the suc{ess of the NFL operations mission
staternent that I cite in footnote #1 of this letter"
ln large part because of the quality of the Bears "Pregame Warm-up Field Credential
Experience," in the spring of 2016, t responded to a Bear's offer and purchased personal seat
licenses for my three end zone sats. Afterthis purchase, I owned personal seat licenses for
all of my five Bear season tickets. I was also motivated to purchase these three PSLs in orderto
make sure that my Bear tickets, and the included experiences, would be able to be passed
down to my children and grandchitdren .
On July 13, 2016, I received an email from the Bears notifying me that I earned eleven
points in which I could use to purchase experiences for the upmming season. {A copy of this
email is also attached to this letter.) On August 1, 2016, the first day that I could book these
experiences, I used the official Bears app on my cellular phone and booked three spots forthe
"Pre6arne Warm-up field Credential Experience " for the Decernber 18. 2016 Bear/Packer
Exhibi t#/-
Page !_ofI reded
2y
game. This was a nine point purchase from my earned eleven points. OnTtrat6[e,
an email receipt frsm the 8ears. (A copy of this email is also attached to this letter.,
This August 1, 2016 email receipt frorn the Bears was the last communication that I had
with Sears regarding my purchased Oecember 18, 2016 "Pregame Warm-up Field Credential
Experience" until I received the December L2, ?016 email from the Eears that had specific
instructions regarding how to check in *or the experience on game day. lt was in this email that
I was, for the first time, notified that opposing team apparel was prohibited. lt was my receipt
of this email that was the stert of this disput*.t
At the December 18, ?016 Bear/Packer gEme, I showed up at the experience

rsgistration station with one of my daughters and a friend. I asked both of them to wear no
HFL team apparel since I did nst want them to be denied access. Howevet, I chose to wear my
Packer gear knowing that I r*ould be denied accss. Ar warned in the December L6, 2016
emall, I was denied access because I was wearin6 Facker apparel. As promised, there was no
confrontation. I have the utmott respect for the employees in the Eear Ticket office. They did
not rnake this new rule. They are stuck enforci*g h.
' ln his December 16, 2016 email, Brenden Pierce, Bears Direclor of Ticltet Sales and Service wrote the follorring
about the prohibition on opposing team apparel rule relating to thir rpecific experience: "- - . fhs rules goveming
rlre 57lI Experienc*s arc wry dear thor" na vkiting team clothing or sttirc will b< prmitted- This Norfl Endzone
*xgeriencc was sor".tifkally creoted as s untque opprtunity for Chicago Eears fans. The terrns pasfd on &e SfH
frperiencas *obile app sycificatly stote ttratl*S yrSfOR &AIHNG will be allowed.*
Itake issue roith Mr, Pierce's 3tatement that $l$ rules governing this experien* are very dear. They are certainly
not clearly stated. tu indicated, the first I found out about fiis rule rsas in the Dscernbr la ?016 email. This rule
$ras not stated in both the July 13, 2016 and August l, 2gt6 emalls from the Bsars. lf it l*as visible when I booked
the experienee on the Bears app on August 1, 20lA it was not prominent e*ough for mp tq rrahe note of it. Had h
been there and if I saw it, this dirpute would harre started back in August.
o.
It also bothers me that Mr. Pierce states that thir experi*nce " , was specifically created as a unigue opportunity
for Chicago Bears fans." This statement is simply not tru and inconsistent with the actual practice in providing
is
this experience. lf it was true then any and all Eear's fans would be eligible. A lottery would be reguired in order
*ut}rque
to fill the spots- Wlrat is true is that this r.Wrience was specifically created as a opportunitf for Bear*
sason ticket holders- lt is now ssld to seapn ticket holders who htve earned enough polnts- This means that I
am eligible for this experience because I am a Berr season ticket holder who earns enough points- Further,
becaute I own lirre perscnal seat lirenses, I believe t arn being denied, rnithout any logical or reasonable cause, my
property rights as a holder of thc psts. Should I be d*nied accesr simply heeause t just happen to be a Pa*er fan?
Doe$n't the fuct that the Bars are Ery second favorite HFt team qualify me as a "8ars Fan?" Further. Soldier
Field is a publically financfd facility which is oramed by the Chicago Park District- lt is not a prirate fucility ourned by
the Bears- This fact certaiaty limits urhat restrictions the Eears can place upon their fand free expression rights. lt
is clear that this new rule is fraught with legal issues that I hope can all he atroided with common sense
intervention by the NFL
Also, please know that all ol my intera$io*s with Mr" Pisrse orier the yearr have been exrellent. I have the utmost
respect for him and his staff. He is merely doing what his supervisof$ expect him to do. I wauld ba very rurprised
if he was not specilically directed what to write in this emeil.
Exhibit # A
Because I \ ias not atlowed on the field, I was able to observerrl*"rgni#,t-?T*
experienc* frorn the stands. I noted that the participants were in the far part of the northeast
end zone. They stood on the paved track that separates the grass fiom the wa{l of the stands.
Since the participants stand by the Packer tunnel, the stands directly next to and above the
participants are filled with Packer clad fans clamoring for autographs from Packer players and
coaches, Just to the south of these participants, right across from the access open point of the
tunnel stand large numbers Packer team staff and fans, who were also granted access to the
field for the pregame warm-ups. All of these Seople were wearing Pac*er gear.
My point is that the participants in this experience are not on a prominent part of the
field. From the perspective of a spectator in the stands, there is nothing renrarkable about
their physical position on the field, Had any of these participants been wearing opposingteam
apparel, they would have also btended in and no oile would have noted anything remarkable
about their presence- There are so rnany things and so many people scattered on all parts of
the field during the pre-game warm ups, the participants in this experience, regardless of what
they are wearing, are simpty r very small part of a visual cacophony, indistinguishable from the
other on field activities
I believe the Bears would be wtthin their rights to restrict the clothing chokes of season
tickets holders who purchase the opportunity to hold the "Bear Dsutr" flag during the Sarne
opening introductisns. This is becausa it is a matter of aesthetics for the opening cerernsny,
which is an important part of the game. These opening game rituals contribute to the overall
fan experience at NFL game*. This is an important goal of trlFl Operation's Mission Statement
that is cited in fostnote fl. However, allof the participants in the "Prgame Warm-up Field
Credential Experience' leave the field before any of these official game opening ceremonies
take place and are not part of it. Due to this, there is absolutely no legitimate reason for the
Bears to restrict the wearing of opposing team apparel by season ticket holders for this
"Pregame Warm-up Field CredentiaI Experience"*
Please know that it important for me. and I belieue for other true NFL fant that
is very
such milguided restrictions on fan expression not be allowed" As indicated, I request that you
intervene and stop the Sears from implementing this speciftc rule relating to this specific
experience next season.
would be happy to provid any other information that you require a$ you lotlk into this
I
request. Please contact rne and lwillfully cooperative and provide what you require.
I also respectfutly request that you respond to this letter within 60 days from your
receipt. I hesitate to impose any type of deadline. However, should you fail to act on this
requ*t or decline to intervene, I i*tend to file an action wlth a court seeking an orderthat the
Bears change this rule prior to next season. Please know that this is the last thing that I want to
do and willonly do so if we cannot come up with an acceptable solution. Should you need time
beyond 6O days, upon your request, it would be granted. I want to work with you to solve this
problem. I am not motivated by rnoney. I just want to change what I believe is a poorly
Exhibit#1-
Page Lof d
thought out rule that actually diminishes fnom the experience of all fans and runs contrary to
the NFL Operation's Mission Staternent"
I appreciate your anticlpeted attention to this matter. I took forward to hearing from
you.
Best fiegards,
fiussell Beckman
As a courtesy, this letter and the following attachrnents were sent to Brendan Pisrce,
Director of Ticket Sales and Service for the Chicago Bears, as a PDF attachment to an email.
What follows is a lirt of the attachments to thir letter;
a Email from Bears dated July 13, 1015. {three pages}

t Attachment to July 13 2016 email. (one page)
I Experience receipt email*om the Bears ori August 1, 2015. (three pages|
a Ernailfrom Bears dated Decernber 12,2016" {two pages}
t Attachment to December 12, 2016 email. {one page}
a Email exchange between me and Bears ticket office staff. Oecernber 13-15, 2016 {three
pages)
Attachment to rny December 13, 2016 emailto the aforementioned December 13-15th
exchange. (This is a photo of me and one of my daughters at the Packer/Buceaneers
game on Dacember ?L 2014. I wore the same outfit to the BearsfPacker game on
December 14 2016Xone page)
Email exchange betvtreen me and Bre*dan Pierce of the 8sars. Decemher 1&"17. 2015.
{three pages}
Photo of me at the September X.3, 2015 PackerlSears game while I am was on the field
enjoying the "Pregarne Warm-up Field Credential Experience." {one pagel
Case: 1:17-cv-04551 Document #: 1 Filed: 06/16/17 Page 19 of 43 PageID
https;r.irng,s111il",vahoo.comineor'launeh?.rcnrl #:19
bdcBtoq2a9j I n#76714?8940
Eubjecl: STH Eperbnces: Upcoming 2015 STH Expenences Dates!
From: Chiego Bears Tickets (bearsticket@bears"nfl .net) Exhibit #-4_

To: RBECKMATS2@Y$rOO. COM ; Page _Z_of 4
Date: lfi&dn*day, July 13,2018 4:38 PM
To vers th& *mail &s n lrb pag. gtl }''{rr.J
EXCLustrVfr ACCE$$. EVgilITS AI{B PEftI(5 FOR $EASO}I TTCI(ET HOLOERS
July 13, 2016
Dear Mr. Beckman.
Wth the 2016 season fast approaching, yve are announcing STH Experiences that
will be offered throughout the year. Belaw you can find a list of upcomrng
experiences that will be available through the Chicago Ofiicial Bears Mobile App on
the dates listed.
You cureatly have 11 points & usa this Eeason-

From your mobile phone, click here to view available events and redeem an
experience today!
: ui3
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"fillore Halas Hall events will be offercd throughout the season for 2-4 points
per person. Please remember all expriences are first come, first served,*
Need help accessing your account or navigating the STH Experiences App? Call
I ofi lili:{,}17 8:24 PN,l

nfips:/rmg.m&l,y{n0o.cffilncdlamcll?-r5t{lsD(5fioqla? In#,o, I.},tr rlu
(847) 615-2327 to speak wilfr a Ticr(efi $ervims Representative.
Ch*ryo Bear licket Sale* & Smtice

Exhibit # A
(s44 615-SEAR t232fi
Trckeil- Offi ce@ Bears. nfl
@SHlBearsSTH
. net
Page
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All sIH Pfegrrn ltsntqp Fldd Pes$ gils*s $r6t ffmdn fi the.k dB3isnated
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($aDsr6-232,
GATIO
httpr:l/mg meil.yahero c*ralnedltlrnch?.ran&7g6anil 9tqft #?36.-"
SrSpci: Huese{ Beclwsn, tris is your recei* from Chicaqo Bcars v$. 6reen Bay Packets on Oecernber
Fmrn: Experience([sten@eryapp.com]
To; rhedmflr6A@yahoo.com; Exhibit#L
lhtr: [iorday, AqBust 1. ml8 12S0 Pl,l Page lLot I
Enioyps t&grsdet
Congrats! We hope ycu have an

awgsorne tinp"
Your Older Fummary

Pregarne Wanrrup Field Sradentials
Group Size:3
Chicago tsears w. Green Bay Packers
Event Date: Drcmber|8, 2016
I Bears $TH Points used
You have 2 Bmrs STH Points remaining"
Your redemption came with the lollowing

instructions:
Thank you for rcd*aming your

Pregame ttlbrn-up Fidd experience!
You will be conbct*d via email bry a
mernber of the Bearr Tickat Sales and
$ervice Taem with furBterdehit$
shorty.
Yierr my rcdernption
I of 3 l/l/l?- $:}lt PM
Print htryn:ifuigrnEil.vahoororr/odlmmh?-rad=7qfu?2il9sqltfi86.."
tiflq!# I do nerf?
To r.rw your upgr#e at the 6v6nt, you Exhibit#-L
can elick here on an iPtrcne orAndroid
plpne, or follow the irmffucthns bebw.
Page LofZI
Strp 1: Openthaapp orwebsiteyou
used to re&{n }nour Beers STH Points
0n yorJr iPh$rG orAndrpid phCIne
$fep *Select the evwt where you made

your redemptfo:n
$tap 3: &rter your infio incltding the ernail

ddresa rbeckmm$Z$yatno.corn and
tap'show msthsgoods"
Step 4; $ebctyoLB upgade *thetop ol

Fan HQ, and present this screen at fie
evemto redBem
Flease rerfierrlber tlwt you'll ttill tleed a

separafe pfimry dc,(et tp entsfhe stnt
and us,our up$radp {rnless ofien ris
$ansd.
Ask a que$tion
Nesd help? Have some fcedback? Want
sorrwreto chat tffith? Sfpot us an ernail
at lislenerpaptroom
Share your experlence

Tffeet a photo{iom theevert on'lirifier
or lnstagrxrr, and tag us $ExpApp
Follor the Chicago
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Exhibit#A
From:
To;
llcket Offbe-CHl (Ticket.Offm@Bears.ntl.nat)
Tlctcet Oftb@Bears.nfi.net:
Page llfi.l
Oate lronday, Orcrnber t2,20t6 4SI PU
Dear Season Ticket Holder.
Tha$k you for rcgistering tbr an exclusive STH Expcrience! 1#e look forward to sming y<ru tor pregffne
wefln-ups forrhe BEARS vs. Packers geme next Sunday, Dcreember tte. Pteaw fintl important
directions and guidclines altached.
To acoess your $TH Bxperic,re pa*er, plcree ctieBjl*|S on yaur smrrt pho*e"
. Once you've been scanned into the:fadium with ycur ticket {l would suggest entering Gate 0},
check in b*ween 10:15 AM and 10:30 AM *t the SfH Experiences table across from 6ate I hy the
elerrator in the South Courtyad {map attached}-
' Acce5s to the field level will begin no earli*-r than 10:30 AM.
- YoumustbrirqyorrrcfffiErdmotgtrphanetorlrednck-in. Artrtrrremhlr*{lld(toualklste
your e.crsdential xithin the StH Expedano:r App.
- lf a child will be yourgue*t on the ffeld, th* child must be at least ten t10l years old.
" NO OPPOSII'IG TEAM 6EAR Wltt ALt0l/t ED.
BE
- l1:fi) AM is the latst possible time to ch*ck in. Participants wfto arrive after 11:0O AM will not be
allowed to participate.
**The Prqeme lYarm.Up Fhld Psxo Fxptrime is veathcr pernitting. $hould tk ffpericme be
renffi,rt wiil smsil $ou amrdiuglp **
lf you arc unable to participat*" ple*se re.ply to thir e-mail sa aaother SeasCIn Ticket Holder cirn rcdeem
this experience.
Should you have any questions. contact thc Chicago Bears Tieket Serviees Team at (Sa?) 615-2337.
I of2 lllt17,8:51 AM
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Print
Subiec* Re: Cor.rld you phase fonrard this to Allison
Fnnrr: Russell Beckrnan {rbeckrnanS2@yahoo"mm} Exhibit #_L

To: Slison.Brauer@Beil$.nfi"net;
Thursday, Deqer*br 15. 2016 8.t9 AM

Page fl-of H
Hello Allison:
I hope you are well and staying warm.
I have not heard from your supervisor Elrendan regarding this matter I do not know if it
stipped his rnind or his failure to callme is intentional. I am still hoping he willcall me sa that
we can discuss and attempt to rcsolve this important issue,
Please know that at ttris tirne, I intend to show up at the check-in table in rny Prcker attim and
propr cr#entials so that my famis and I can enioy this experience- If I am denied the
opportunity to participate due to my choice of cloitfring, I will rmpectfully and polttely obiect to
your denial. Uttimately, I will comply with your denial despite my obiection. There will be no
need to have security present since I will be civil.
Please note that my kindnees do6 not mean that I do not take this matter seriously. lf I am
denied, I plan to file a civilaction against the Chicago Bears in orderto prevent this
harn-handed and ill conceived rule frsm being enforced next season. Quite honestty, the rule
reflects very pocrly on the Bear's organization- I flnd it sad that rny na$le appears on the wall
that lists the names of allcharter Ghicago Bears personal seat license holders at Soldier Field,
yet I am hreing denied this oppcrtunity. This is simpty wrong and is cmrtrary to the ethos of
good sport$Tanship and friendly cornpetition. $/hy do we have to continue to segrognte
each other based on our differences, even if the difference is simply supporting the visiting
team?
Iam still hoping that this legal conflict can be avoided. I would like to talk to Brendan. I am
avaitable after 5pm today and after 3pm on Friday. As I indicated to yau verbally, I appreciate
and respect the work that 1lou do and my dispute is with your en:$oyer, not you-
Bmt Regards,
Russell Beckman
On Tuesday, December 13, 2016 10:55 AM. Allison Eraus<Allbon.Brauer@Bears.nfi.net>wrote:
I of 3 lJlll7.8:35 A-Sl
Case: 1:17-cv-04551 Document #: 1 Filed: 06/16/17 Page 30 of 43 PageID #:30 *qft#7 3..,
hre,s:llmg.mail "yaboo.con#nco/l*r"P3'6sl=7q6472i I t
Hi Hussell-
I appreciate you reching o$t I willforward thh overto my suparvisor, Erendan, Eo he is aware.
Thank you!
Exhibi t # A
A[ison Brouer
Premium Seot Sales & Services Coordlnotor
Page Ltrfu
Chicogo Beors Footboll Club
l?20 FootbollDr
Loke Forest, lL 60O45
Phone: 847.739-5313
Altison.Bro uer@ Beors, nfl.net
# cHrcAEo swLE F',TEALL B * @ l,

This message contains confidentkl irrformation and is intended only for the individual named.
lf you are not the named addressee you should nat disseminate, distribute or copy this e-mail.
Please notifii the sender immediatety by e-mail if you have received this e-mail by mistake and
delete this e-mail tom your system. E-maittransmis$ion cannot be guaranted to be secure
or er&rr-free as information couH be interceptod, com:pted, b$t, destnryed, arrive late or
incomplete, or contain viruses. The sender thsefore doeE not accept liability for any effotB or
omissions in the contenB of this mes$age, which arise as a reeult of e-mailtransmission. lf
verification is required please rcquest a hatd-copy version.
From: Autumn Swinddl

S6nt Tumday, &cenrber 13,2016 10:08 AM
To: Alison tsrauer <Allison-Brauer&Bearc nfl "nst>
Cc'rbckman620yahoo.com' <rbecknan620yahoo.oom>
Srdlic* FllV: Could you please fonrard this to Allison
Allison-
Please see hlow frorn Russell-
Thanks,
Autumn
Fronr: Russell Beclsnan fnailto.dreekm*n$E@va*po,con]}

S6fit fuesOay, kernhr 13,401610:06 AM
To: Autumn $windell<ai[unryn-.S]"viQ5|.e,l. >; Autumn Swindell
<autumn. $qi ndel!4$A(s. Ttl, ne'!>
S&ieet Could you please fonrrard this to Allison
2 of 3 ltttl'l,8:35 AM
haprJimgrneil-yalroo.com/neollaunch?.rand=7q6472i I 9s{kff I 3'..
Exhibit # A
Hello Autumn: Page
$rQl
Thank you for fonnrading me to Alliscrr. I wanted io send her an Email, h.tt I did not have it in
my corfiact tist. lf you cor:ld forward this to her, I would appreciate iL
Hello Allison:
Thank you for being so decent during our com/ets.*ion. I wanted to share a photo of you with
exactly what I will be wearing when I go to the garne this Sunday. This photo was taken in
Tampatwo yeals ago. The youflg woman in the photo with me is my daughter. $he will also
be attending the game with me on $unday. This Sunday, we will have m$re layers underneath
our Packs apparel, but this will he what is on the outside. Maybe you could share tris photo
with the suparvisor who urill be calling me later. One thing I did not toll you during our very
nice conversation is that I also do not drink. This is imporlant because I also do not
apprecifie drunksr fans of any side who want b mix it up-
I look forward to talking with your eupervisor.
Best,
Hussell Beckman
Afiachmmts
. imagcl 36dba-PNG (4.40K8)
lof3 l/1117. S:35 AM

8{u
#A
*r-
Print Case: 1:17-cv-04551 Document #: 1 Filed: 06/16/17 Page 33 of 43 PageID #:33
htgallmg.nrail.yahoocomlilodl*unsh?.rand=?qfa72i I 9sqtk#936,...
Sub@: Re: BEARS vs. Pdters - December 1S,2016 Exhibit#J

From: FlussellBckman(rbeckman82@yahoo.mm) Page?l of{
To: Brardan. Pierce @Bears.nfl -net;
Cc: Lee.TwarllrE @ Bears.nff .net:
Data: Saturday" December 17,20161:$'t AM
Hello Brendan:
Thank your for the kind, tmpectful, and profeseional manner in which you have dealt uyith this
disagreenrent. Please know that I intend to continue to act in the same mannr, despite our
contrary positions"
Iwould like to note that my prirnary intention in calling your office this past yrreek was to seek
to resolve this matter in an amicable manner. The way in which you worded yorr email
creates an illusion that I only sought to state to Allison rny intent to defu your rule. My call
was astually a goed faith effort to try and find a solution to a problenr.
Your email makes it very clearthat I will be denied asces to the experience if I wear my
Packer gear. I will be wearing my Packer gear to the gnrne. Because of your very clear denial
in this email, tivhen I show up at the check in t*ble, I will not ask if I can be admitted to the
experience. My only reason for showing up at th* check-in site will be to check in my two
guests who will be participating in tha experience- Please note that my decision to not ask to
be admitted to ths experience this Sunday is only because of your very claarly stated notice
that I will be denied admission. lt should, in no way, be interpreted that I am acquiescing to
this rule without objection. Ultimate{y, the legality of ytrur rule will be decided by a court of law
in the off-season when I file my action.
My two guests are not Bear fans. However, both will be wearing full civilian attire that will
devoid of any synrbolism of any NFL team. I am not aurarc ol any loyafty test or oath to Sre
Eears that my two guests rnust padake in orderto enioy this exp,aisnce. lf such test or oath
is required, prior notice would be appfleciatd.
I have also purchased passes for the Midway Presented by Xfinrty for my guets and t. I
found nothing in it's rules that indicate I can not wear my Packer gear into that 'experieflce."
Of course, I paid for the passes and will purchase food and beverages in that vanue using my
green and gold "Packer NLF Extra Points" Msa card. Will your bartenders refuse to accept
that card and insist that I pay with a Bear version of this card? I doubt it. However, that could
change next season as your team continues to move towards the creation of sagregatad safe
spaces for Bear fans who suffer from anxiety due to the presence of greater numbers ol
opposing fans in your publicly owned and financed stadium. Plmse know that you really do
not understand that your fans are tough, rosilient, and worthy ol my respect" Maybe you
should also respect them, their grit, and stop coddling thern. A few years ago, the Tampa Bay
t nf -{ l/l/17, E:]0 AM
hup,s:/lmg.mail.yahoo.corn/ncrilaunch?-rand*7q6a72i I %qfk#93*..-
Lighting became the lauqhing stoek of the Gity of Bmad Shoulders and the rcst of the country FU
F'
when they banned Black Hawk jerseys in thdr ve{lue. How did that work out for them? s
oe
x
D
-
(D E.
Maybe sometirne I can sit down with your brain trust and have a few beers. I could show I-
f.
them two years worth of photos and videos of me on the field watching the pre-gams warn FI
:tt
IF
ups in full Packer colors, standing ann and arm with Bear fans proudly wearing Bear colors,
f*l
c
together basking in the glory of what is arguabty the NFL's most storied rivalry Why mess
tc l>
INJ
with that and who benefits from the meddling? Your fans would be much better served if you
would build your t6am so that th6e two great teams can play great garnes against each other
again at Soldier Fietd" I had the pnvileEe to w#h the 2011 NFC Championship game and the
2013 game that decided who won the NFC North in your house with my season tickets. Since
I have five personal seat licenses in your venue" I look for$/ard to a firtrrre in which gamee like
those happen trequentty" It is sad that whlle Bear's managentent drmses windows its fans are
dumping thousands of tickets on the secondary ma*et at below face value. The majonty of
fans at Sunday's game will be Packer fans lured into your venue by the fire sale on tickets.
Trust me when ltell you that a winning Bears team would bring tremendous joy to both your
fans and to me- True Bear and Packer fans love the excitement of meaningful games and the
intensity of the rivalry.
Please know that my interaction with you and your staff on $unday will be respecttul and civil-
I have no personal issues with you or any of your staff. I am &eated very weil by thern and I
will rceiprocate. My issue is with the Bear organization, not its ernployees. Also, the
snarkiness of some of my language in this rcspons is not meant to be disrespectful. lt is
intended to illustrate the folly of this nevrly imposed rule"
Best Regards,
Bussell Beckman
On Frirtlay, Deoembs 1S. 2016 5:05 PM, Erendan Pierm <Brendan.Piarce@Bear$.nfl.net> wrole:
Mr. Beckman,
Please allow this email to confirm our conversation on Eecember 15, 20'16, wtrerein I reiterated to you the rules
that apply to our Progame \IVarm-up Field Credential Experience. Yoq,, redeemed yor'rr STH Experiences points
for the Pre-game Warm-up Fidcl Experlerm in the Nor& Endzone for this Surday, Decemher 18" 201S against
the Green Bay Packers. You subseqr.enUy called &e ticket offree this week and advised that despite the rules
goveming th STH Experiencos you intandsd on wearing Greec Bay Packers attire when you attend the garne to
rcdeern this oxperience.
While you arc Grteinly lree to $rlpport the vi*iting team and urear Grwn Bay Packes gear as a pafon at the
garter the rules (pvemnq the STH Experbnce* are vary dear tfut rE visiiirrg taam clothing or attire wiil ba
permitted. This Nor$ ndzone experience rms specifically created as a unique opportun*y for Ghic*go Bears
fans, The term$ posted on the $TH Experiences mobile app specificalty state that NO VISTOR CLOTHING will
bs allCIwd. ln addition, ths confirmation emailthat was wnt to tou or! Dscmbr 12, 2016 furtherstatE'N0
2of,1 lllf l7.Srl0AM

Case: 1:17-cv-04551 Document #: 1 Filed: 06/16/17 Page 35crmlncc,Ilaumh?
htqr/lmg-rrail-yaho of 43 PageID #:35
rxndr7qfa?2i I 9sqftr936--.
OPPOSING TEAM GEAR WLL BE ALLOWED." Finally, thp tenns of purchase ge{rerr*ng the STH
Exporiwrces redernptlons providethattheexperbue iszubiectto additimal tenmthat rnary beset bythe
organ'ization and that the Chicags Bears have tle right, $ftf&$ refund or any anmlnt paid, to refue admission
to, or eject any pr6on . . . who fuils to cornply with r*enue sr svent pmnmler ndea.
Thercforc, this ernail will osrfirm that yru frar* be+n adrtid of the ter*p and condition* of fie STH Experi*nqec
and thd il you attemptto redeern tfre FrogameWarm-up Hdd Crd6r{id Expedene while wearing any vi*iling
tearn afiire, yair arlrnissio,n to this *xper*mm will b6 derded. Pleasa let me lmow if yotr havo any olhar
questions. Thankyou.
Brcrdur
Exhibit # 4
Erendon Pierce
Page Lof Z!
Director of Ticket Soles ond Service
Chicago Beors Footboll Club
1920 FootbollDr
Lske Forest, lL 60045
Phone: 847.739.5333
Brendon.Pierce@Beors.nfl.nel
# cHrcAril srYLE FooTBALL re r @ *

This mmage contains confidential informaton and ie intended only for the individual named.
lf you are not the named addrcsse you drould not disseminate, distribute or copy this e-mail.
Please notify the sender immediately by e-mail if you have received this e-mail by misfiake and
delete this *"mail*om your system. E-mail transnission cannot bc guaranted to be securs
or error-tee as irformatbn muld be intarcepted, comrptod. lost, destroyed, arivs late or
incomplete, or contain viruses. The smder therufore does not aecept liabilify for any eflors or
ornissions in the contents of this messa{,e, which arise as a result of *"mail trgsrnission. lf
verification is requird plmse request a hard-copy version.
Attnchments
. imaSe6TScBc.PNG {4.4OKBi
3 of3 I/l/17.E:3tlAM
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Exhibit
//mg.mail.yahoo.com/neo/launch?.rand=01vle2qjtkgq l# l8/;*+..,
Case: 1:17-cv-04551 Document #: 1 Filed: https:
06/16/17 Page 40 of 43 PageID #:40
,.
Subiect: STH Experiences:2017 Points and Events Available Exhibit # e
From: Chicago Bears Tlckets (bearstickets@bears.nfl.net) Page Lof L
To: RBEC KMAN62 @ YAHOO.COM;
Date: lVlonday, May 15, 2017 5:11 PM
To view this email as a web page, go here.
EXCLI'sIVE ACCEss, EVEIITS ANO FERKS FOR SEASOI{ TIEKET HOLDERS
May 1 5,2017
Dear Mr. Beckman,
New STH Experiences are now available for the 2017 season! As a valued STH,
you can once again register for STH Experiences and take advantage of the free
benefits program that delivers exclusive access, events and perks to you throughout
the year. Don't miss out on private Halas Hall events, pregame field access, STH
swag and more!
You have been credited with 12 points to use by February 1"1, 2018.
Please visit STH Central to view calendars, schedules and additional STH
Experiences updates. Also, be sure to sign up for text alerts in the app to receive
notifications when new events become available. Experiences are available on a
first-come, first-served basis.
For more information visit, chicagobears.com/experiences.
you have any questions, please contact our Ticket Services Team at
!f
847$1s-BEAR (2327).
Chicago Bears Ticket Sales & Service
I of2 5126117,8:19AM
&iil h@: //ry-mail.yfu .oom/usonsltre?rffi tv162q1d(gq1#18494...
Ticket. Office@Bears. nf l. net Exhibit #C

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Exhibit
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Pregame Warm-up Field Credential

AVAILABLE ON U1117 AT 12:00 PM
Sunday, November 12th ,2A17 al 12:00 PM
Kick-off a game with the Bears by standing on the field during

pre-game! Don-t miss this incredible opportunity to be up close
and personal during warmups as you stand in the North
Endzone!
Things to know:
. Further instructions provided week of the game via email
. Must arrive 75 minutes before kickotf behind Gate 8
. Children must be 10 years old
. This experience is weather permitting
. No visiting team clothing allowed.
#
Home
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Umrr,
Gameday
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Beckman vs. Chicago Bears

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Case: 1:17-cv-04551 Document #: 1 Filed: 06/16/17 Page 1 of 43 PageID #:1

RUSSELL BECKMAN, and any other

CHICAGO BEAR FOOTBALL CLUB,

COMPLAINT AND REOUEST FOR INJUNCTIONI

Chicago Bear Football Club, lnc.

National Football League (I.IFL)

II Basis for Jurisdiction

financed and is owned by the City of Chicago Park District.)

B. If the Basis for Jurisdiction is Diversity of Citizenship

a. The Plaintiff, Russell Beckman, is an individual and is a citizen of

the State of Wisconsin.

a. The Defendant, the Chicago Bear Football Club, Inc., is a

corporation and is incorporated under the laws of the State of Delaware"

and has its principal place of business in the State of illinois.

b. The Defendant, the National Football League (NFL) ts an

unincorporated association consistin g of separately owned professional

3. The Amount in Controversy

The Plaintiff is not seeking compensatory or punitive damages from the

Defendants. This action is seeking injunctive relief and the

ur. Statement of Claim

A. Where did the events giving rise to your claim(s) occur?

by the Chicago Park District.

December 18,2016 at approximately 10:30am. This is also an ongoing and

repeatable annual event.

C. What are the facts underlying your claim(s)?

these games and while participating in each of those year's experiences, my

2015 experiences were a Bears initiative in providing experiences for a select

solicitation to season ticket holders offering the opportunity to purchase personal

for me, my family, including future grandchildren, and friends, to be able to

added to the tremendous enjoyment I experience, with my family and friends, at

this annual game.

formula developed by the Bears--eleven points that I could use to purchase

"experiences."(exhibit A, pp. 7-9.) On August 1,2016,I used the points I was

4. On December 12,2016,I received an email from the Bears that provided

specific information regarding participation in this December 18,2016

OPPOSING TEAM GEAR WILL BE ALLOWED."2 (exhibit A, pp. 14-16)

5. Since I intended to wear Packer apparel to this game and during my

2 The wording was in all caps in the email.

up to the experience registration location on game day wearing my Packer

denied participation in this very unique experience. Both of these companions

were allowed to participate in this experience. (exhibit A, pp. 17-24.)

6. On January 3,2017,I mailed, via United States Postal Service certified

ticket office, on January 2,1017.

7 . On May 15,2017,I received an email from the Bears informing me that

(http ://www. ch ica gobears. com/ti ckets-and-

stadium/experiences.html?camefrom=EMCl_ I 645 896 642365 5I ) What follows

" Freq uently Asked Questions

What is the STH Experiences program?

l{ho is eligible to access STH Experiences?

8. On May 25,2017,I was accessing the Bear's mobile app on my cell

companions access to the held on November 12,2017, when I attempt to redeem

my duly purchased "pregame warm-up field credentials" while I am clad in

IV. Irreparable Injur.v

pilot program for STH Experiences. During these two experiences, my

Soldier Field on January 23,2011. I generally attend these games with my

and away Packer games.

or reasonable cause, or Constifutionally mandated reason, deprived me of my

of the Bears Packer game at Soldier Field. Because it is impossible to place a

defendants are allowed to continue to enforce this rule, my harm continues

matter with the two defendants prior to filing this action.

VI. Certification and Closing

A. For Parties Without an Attorney

Dateorsign rrr, 6- I 6' I 7

Printed Name of Plaintiff Russell Beckman

Chryo Bear licket Sale & Smtice

Pbase En& flil rnyqurstion

ftluiiI tbf I tdsi CEn I kfii Fe,tdt*6

Fronr: Russell Beclsnan fnailto.dreekmn$E@vapo,con]}