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Case 0:18-cv-60221-RNS Document 1 Entered on FLSD Docket 02/01/2018 Page 1 of 31
UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA
CASE NO.
APPLE CORPS LIMITED and SUBAFILMS

LIMITED,
Plaintiffs,
vs.
SHIRTSFORYOU.NET, B..F STORE, GOOD

LUCK TO YOU, GREENMANGO STORE,
HOOK ON YOU, JUNLIANQI STORE, LUCK
FRIDAY STORE, LUCKYFRIDAY STORE,
MILESTONE 2013, MOONPRINT, NOAHCOSY
STORE, PEAR GARMENT STORE, UNCLE
LOONG STORE, X. STORE, XINGQIWU
STORE, ACE DIY, BRENDA HHH,
HZJIUIYYH, KDTMK, OSKAY, RUI FENG CO
LTD, TAOJING, ARLIANDO, BALADARON,
BILIM1, DEALEXINAYASTORE, ELLA2015
a/k/a UPONSTYLE, GIRLBEE, GREGHARSON,
IKA_LESTARI, MOCHISTORE88,
ROSALIA_COLLECTIONS, SHIRTS FOR YOU
a/k/a SHIRTS_FOR_YOU, UNIQUE WACKY
NECKTIES, WATCHES, BACKPACKS FOR
GEEKS NERDS COSPLAY MOVIEMANIACS
a/k/a LILUNDER, UNIQUE_STYLE, ADITYO77
a/k/a ADITYSIMORANGKI0,
BEAUTYANDLUCK, CAIXIAOYUNYUN,
CUSTOMDROPSHIPPING, DAN_ONLINE226,
FILYDONLINE, LETSTOYOUT, NIKITOS-1982
a/k/a ART AND COLLECTING, SHEVALUES,
SPEDO202, TOPISEOOD, PRINTS4CUTEKIDS,
ROCKSINS, EACH AN INDIVIDUAL,
PARTNERSHIP OR UNINCORPORATED
ASSOCIATION
Defendants.
/
COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF

Plaintiffs, APPLE CORPS LIMITED and SUBAFILMS LIMITED (“Plaintiffs”) hereby
sue Defendants, the Individuals, Partnerships, and Unincorporated Associations identified in the
caption, which are set forth on Schedule “A” hereto (collectively “Defendants”). Defendants are
promoting, selling, offering for sale and distributing goods bearing counterfeits and confusingly
similar imitations of Plaintiffs’ respective trademarks within this district through the Internet
website and various Internet based e-commerce stores operating under their domain name or seller
identities set forth on Schedule “A” hereto (collectively, the “Subject Domain Name and Seller
IDs”). In support of their claims, Plaintiffs allege as follows:
JURISDICTION AND VENUE
1. This is an action for federal trademark counterfeiting and infringement, false
designation of origin, common law unfair competition, and common law trademark infringement
pursuant to 15 U.S.C. §§ 1114, 1116, 1125(a), and 1125(d), and The All Writs Act, 28 U.S.C. §
1651(a). Accordingly, this Court has subject matter jurisdiction over this action pursuant to 15
U.S.C. § 1121 and 28 U.S.C. §§ 1331 and 1338. This Court has supplemental jurisdiction pursuant
to 28 U.S.C. § 1367 over Plaintiffs’ state law claims because those claims are so related to the
federal claims that they form part of the same case or controversy.
2. Defendants are subject to personal jurisdiction in this district, because they direct
business activities toward and conduct business with consumers throughout the United States,
including within the State of Florida and this district, through at least, the commercial Internet
website and Internet based e-commerce stores accessible in Florida and operating under their
Subject Domain Name and Seller IDs.
3. Venue is proper in this Court pursuant to 28 U.S.C. § 1391 since Defendants are,
upon information and belief, aliens who are engaged in infringing activities and causing harm
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within this district by advertising, offering to sell, and selling infringing products to consumers in
Florida.
THE PLAINTIFFS
4. Plaintiff, Apple Corps Limited (“Apple Corps”) is an incorporated limited company
organized under the laws of the United Kingdom with its principal place of business located in
London, United Kingdom. Apple Corps is owned by the former members of The Beatles and,
where applicable, their successors and its principal activities are the promotion, marketing, and
policing of the products and rights of The Beatles, such as merchandising rights and audio and
audio-visual content. Apple Corps owns the exclusive right by assignment from The Beatles to all
merchandising rights of the Beatles and all other intangible rights in the name “The Beatles.”
5. Plaintiff, Subafilms Limited (“Subafilms”) is an associated company of Apple
Corps Limited, with its principal place of business located in London, United Kingdom. Subafilms
is owned by Apple Corps, the former members of The Beatles and, where applicable, their
successors. Subafilms’ principal asset is the rights in respect of the cartoon film made in 1967
called “Yellow Submarine.”
6. Plaintiffs are engaged in the development, manufacture, promotion, distribution,
and sale in interstate commerce, throughout the United States, including within this district, of a
variety of quality goods, using multiple common law and federally registered trademarks,
including those discussed in Paragraphs 18 and 27 below and identified in Schedules “B” and “C”
hereto.
7. Plaintiffs’ trademarked goods are sold within the State of Florida, including this
district. Defendants, through the sale and offer to sell counterfeit and infringing versions of
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Plaintiffs’ respective branded products, are directly, and unfairly, competing with Plaintiffs’
economic interests in the State of Florida and causing Plaintiffs harm within this jurisdiction.
8. Like many other famous trademark owners, Plaintiffs suffer ongoing daily and
sustained violations of their respective trademark rights at the hands of counterfeiters and
infringers, such as Defendants herein, who wrongfully reproduce and counterfeit Plaintiffs’
individual trademarks for the twin purposes of (i) duping and confusing the consuming public and
(ii) earning substantial profits. The natural and intended byproduct of Defendants’ actions is the
erosion and destruction of the goodwill associated with Plaintiffs’ respective famous names and
trademarks and the destruction of the legitimate market sector in which they operate.
9. In order to combat the indivisible harm caused by the combined actions of
Defendants, Plaintiffs expend significant resources in connection with trademark enforcement
efforts. The expansion of counterfeiting on the World Wide Web has created an environment that
requires companies, such as Plaintiffs, to expend significant time and money across a wide
spectrum of efforts in order to protect both consumers and themselves from the ill effects of
confusion and the erosion of the goodwill connected to Plaintiffs’ respective brands.
THE DEFENDANTS
10. Defendants are individuals and/or business entities of unknown makeup each of
whom, upon information and belief, either reside and/or operate in foreign jurisdictions with lax
trademark enforcement systems or redistribute products from the same or similar sources in those
locations. Defendants have the capacity to be sued pursuant to Federal Rule of Civil Procedure
17(b). Defendants target their business activities toward consumers throughout the United States,
including within this district, and conduct pervasive business through the operation of, at least, the
fully interactive commercial Internet website existing under the Subject Domain Name or via the
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Internet based marketplace websites, AliEpress.com, Amazon.com, Bonanza.com, eBay.com, and
Etsy.com, under the Seller IDs.
11. Upon information and belief, Defendants use aliases in conjunction with the
operation of their business including but not limited to those identified by the same Defendant
Number on Schedule “A” hereto.
12. Defendants are the past and present controlling forces behind the sale of products
bearing counterfeits and infringements of Plaintiffs’ individual trademarks as described herein
using at least the Subject Domain Name and Seller IDs.
13. Upon information and belief, Defendants directly engage in unfair competition with
Plaintiffs by advertising, offering for sale, and selling goods, bearing counterfeits and
infringements of one or more of Plaintiffs’ individual trademarks to consumers within the United
States and this district through the Internet website and Internet based e-commerce stores operating
under, at least, the Subject Domain Name and Seller IDs, and additional domain names or seller
identification aliases not yet known to Plaintiffs. Defendants have purposefully directed some
portion of their illegal activities towards consumers in the State of Florida through the
advertisement, offer to sell, sale, and/or shipment of counterfeit and infringing goods into the State.
14. Defendants have registered, established or purchased, and maintained the Subject
Domain Name and Seller IDs, and the website and e-commerce stores operating thereunder. Upon
information and belief, Defendants may have engaged in fraudulent conduct with respect to the
registration of the Subject Domain Name and Seller IDs by providing false and/or misleading
information to their various registrars and/or to the Internet based e-commerce platforms where
they offer for sale and/or sell, during the registration or maintenance process related to their
respective Subject Domain Name and Seller ID. Upon information and belief, Defendants have
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anonymously registered and maintained the Subject Domain Name and Seller IDs for the sole
purpose of engaging in illegal counterfeiting activities.
15. Upon information and belief, Defendants will continue to register or acquire new
domain names and seller identification aliases for the purpose of selling and offering for sale goods
bearing counterfeit and confusingly similar imitations of Plaintiffs’ trademarks unless
preliminarily and permanently enjoined.
16. Defendants use their Internet-based businesses to infringe the intellectual property
rights of Plaintiffs.
17. Defendants’ business names, i.e., the Subject Domain Name and Seller IDs,
associated payment accounts, and any other alias domain names and seller identification names
used in connection with the sale of counterfeit and infringing goods bearing Plaintiffs’ trademarks
are essential components of Defendants’ online activities and are one of the means by which
Defendants further their counterfeiting and infringing scheme and cause harm to Plaintiffs.
Moreover, Defendants are using Plaintiffs’ respective famous brand names and trademarks to drive
Internet consumer traffic to their website and e-commerce stores operating under the Subject
Domain Name and Seller IDs, thereby increasing the value of the Subject Domain Name and Seller
IDs and decreasing the size and value of Plaintiffs’ legitimate marketplace at Plaintiffs’ expense.
COMMON FACTUAL ALLEGATIONS
Apple Corp’s Business and Trademark Rights
18. Apple Corps is the owner of all rights in and to the trademarks identified on
Schedule “B” hereto (collectively, the “BEATLES Marks”), which are valid and registered on the
Principal Register of the United States Patent and Trademark Office. The BEATLES Marks are
used in connection with the manufacture and distribution of quality goods in the classes also
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identified on Schedule “B.” True and correct copies of the Certificates of Registration for the
BEATLES Marks are attached hereto as Composite Exhibit “1.”
19. The BEATLES Marks have been extensively and continuously used in interstate
commerce to identify and distinguish a variety of quality goods. The BEATLES Marks have been
in use by Apple Corps since long before the Defendants’ use of counterfeits of the BEATLES
Marks.
20. The BEATLES Marks are symbols of Apple Corps’ quality, reputation and
enormous goodwill and have never been abandoned.
21. The BEATLES Marks are well known and famous. Apple Corps and its licensees
have expended substantial time, money and other resources in developing, advertising, and
otherwise promoting the BEATLES Marks. The BEATLES Marks qualify as famous marks as that
term is used in 15 U.S.C. §1125(c)(1).
22. Further, Apple Corps and its licensees have extensively used, advertised, and
promoted the BEATLES Marks in the United States in association with the sale of quality goods.
Apple Corps and its licensees have expended significant resources promoting the BEATLES
Marks and products bearing the BEATLES Marks on the Internet, and via its official website,
www.thebeatlesstore.com. Apple Corps’ prominent use of the BEATLES Marks has further
enhanced the BEATLES Marks’ recognition and fame with members of the consuming public. In
the last few years alone, Apple Corps has experienced substantial sales of its high quality goods.
23. The worldwide popularity of the Beatles musical compositions, musical recordings,
and the enormous sales of goods bearing the Beatles’ name, have resulted in the widespread
recognition of the “Beatles” brand. As a result of Apple Corps’ use, promotion and advertisement
of the Beatles brand, members of the consuming public readily identify merchandise bearing or
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sold under the BEATLES Marks as being quality merchandise sponsored and approved by Apple
Corps.
24. Accordingly, the BEATLES Marks are among the most widely recognized
trademarks in the United States, and the trademarks have achieved substantial secondary meaning
as identifiers of quality goods.
25. Apple Corps’ has carefully monitored and policed the use of the BEATLES Marks
and has never assigned or licensed the BEATLES Marks to any of the Defendants in this matter.
26. Genuine goods bearing the BEATLES Marks are widely legitimately advertised,
promoted, and offered for sale by Apple Corps, and its authorized licensees, via the Internet.
Visibility on the Internet, particularly via Internet search engines such as Google, Yahoo!, and
Bing has become increasingly important to Apple Corps’ overall marketing and consumer
education efforts. Thus, Apple Corps expends significant resources on Internet marketing and
consumer education which allow Apple Corps and its authorized licensees to fairly and
legitimately educate consumers about the value associated with the BEATLES Marks and the
goods sold thereunder.
Subafilms’ Trademark Rights
27. Subafilms is the owner of all rights in and to the trademark identified on Schedule
“C” hereto (collectively, the “YELLOW SUBMARINE Mark”), which is valid and registered on
the Principal Register of the United States Patent and Trademark Office. The YELLOW
SUBMARINE Mark is used in connection with the manufacture and distribution of quality goods
in the classes also identified on Schedule “C.” A true and correct copy of the Certificate of
Registration for the YELLOW SUBMARINE Mark is attached hereto as Composite Exhibit “2.”
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28. The YELLOW SUBMARINE Mark has been extensively and continuously used in
interstate commerce to identify and distinguish a variety of quality goods. The YELLOW
SUBMARINE Mark has been in use by Subafilms since long before the Defendants’ use of
counterfeits of the YELLOW SUBMARINE Mark.
29. The YELLOW SUBMARINE Mark is a symbol of Subafilms’ quality, reputation
and enormous goodwill and has never been abandoned.
30. The YELLOW SUBMARINE Mark is well known and famous. Subafilms and its
licensees have expended significant resources in developing, advertising, and otherwise promoting
the YELLOW SUBMARINE Mark. The YELLOW SUBMARINE Mark qualifies as a famous
mark as that term is used in 15 U.S.C. §1125(c)(1).
31. Further, Subafilms and its licensees have extensively used, advertised, and
promoted the YELLOW SUBMARINE Mark in the United States in association with the sale of
quality goods. Subafilms and its licensees have expended significant resources promoting the
YELLOW SUBMARINE Mark and products bearing the YELLOW SUBMARINE Mark, on the
Internet via the website, www.thebeatlesstore.com. Subafilms’ prominent use of the YELLOW
SUBMARINE Mark has further enhanced the YELLOW SUBMARINE Mark’s recognition and
fame with members of the consuming public. In the last few years alone, Subafilms has
experienced substantial sales of its high quality goods.
32. As a result of Subafilms’ efforts, members of the consuming public readily identify
merchandise bearing or sold under the YELLOW SUBMARINE Mark as being quality
merchandise sponsored and approved by Subafilms.
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33. Accordingly, the YELLOW SUBMARINE Mark is among the most widely
recognized trademarks in the United States, and the trademark has achieved substantial secondary
meaning as an identifier of high quality goods.
34. Subafilms’ has carefully monitored and policed the use of the YELLOW
SUBMARINE Mark and has never assigned or licensed the YELLOW SUBMARINE Mark to any
of the Defendants in this matter.
35. Genuine goods bearing the YELLOW SUBMARINE Mark are widely legitimately
advertised, promoted, and offered for sale by Subafilms through its authorized licensees via the
Internet. Visibility on the Internet, particularly via Internet search engines such as Google, Yahoo!,
and Bing has become increasingly important to Subafilms’ overall marketing and consumer
education efforts. Thus, Subafilms expends significant resources on Internet marketing and
consumer education which allow Subafilms and its authorized licensees to fairly and legitimately
educate consumers about the value associated with the YELLOW SUBMARINE Mark and the
goods sold thereunder.
Defendants’ Infringing Activities
36. Upon information and belief, Defendants are promoting and advertising,
distributing, selling, and/or offering for sale goods, including bed linen, such as pillowcases,
apparel for men, women, and toddlers, such as tank tops, t-shirts, jackets, hats, shoes, and onesies,
cases for mobile telephones, pendants, backpacks, and doormats, in interstate commerce bearing
counterfeit and infringing trademarks that are exact copies of the BEATLES Marks and/or
YELLOW SUBMARINE Mark (the “Counterfeit Goods”) through at least the Internet website
and Internet based e-commerce stores operating under the Subject Domain Name and Seller IDs.
Specifically, Defendants are using identical copies of the BEATLES Marks and/or YELLOW
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SUBMARINE Mark (collectively, “Plaintiffs’ Marks”) for different quality goods. Plaintiffs have
used their respective Marks extensively and continuously before Defendants began offering goods
using counterfeit and confusingly similar imitations of Plaintiffs’ merchandise.
37. Defendants’ Counterfeit Goods are of a quality substantially and materially
different than that of Plaintiffs’ respective, genuine goods. Defendants, upon information and
belief, are actively using, promoting and otherwise advertising, distributing, selling and/or offering
for sale substantial quantities of their Counterfeit Goods with the knowledge and intent that such
goods will be mistaken for Plaintiffs’ genuine quality goods despite Defendants’ knowledge that
they are without authority to use Plaintiffs’ Marks. The net effect of Defendants’ actions will
cause confusion of consumers, at the time of initial interest, sale, and in the post-sale setting, who
will believe Defendants’ Counterfeit Goods are genuine goods originating from, associated with,
and approved by Plaintiffs.
38. Defendants advertise their Counterfeit Goods for sale to the consuming public via
an Internet website and e-commerce stores operating under at least the Subject Domain Name and
Seller IDs. In so advertising these goods, Defendants improperly and unlawfully use Plaintiffs’
Marks without Plaintiffs’ permission. The misappropriation of Plaintiffs’ advertising ideas in the
form of Plaintiffs’ Marks is the proximate cause of damage to Plaintiffs.
39. As part of their overall infringement and counterfeiting scheme, Defendants are,
upon information and belief, all employing and benefitting from substantially similar marketing
strategies based, in large measure, upon an illegal use of counterfeits and infringements of
Plaintiffs’ Marks. Specifically, Defendants are using counterfeits and infringements of at least one
of Plaintiffs’ Marks in order to make their website and e-commerce stores selling illegal goods
appear more relevant and attractive to consumers online. By their actions, Defendants have created
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an illegal marketplace operating in parallel to the legitimate marketplace for Plaintiffs’ respective
genuine goods. Defendants are causing concurrent and indivisible harm to Plaintiffs and the
consuming public by (i) depriving Plaintiffs and other third parties of their right to fairly compete
for space within search engine results and reducing the visibility of Plaintiffs’ genuine goods on
the World Wide Web, and (ii) causing an overall degradation of the value of the goodwill
associated with Plaintiffs’ Marks.
40. Upon information and belief, Defendants are concurrently targeting their
counterfeiting and infringing activities toward consumers and causing harm within this district and
elsewhere throughout the United States. As a result, Defendants are defrauding Plaintiffs and the
consuming public for Defendants’ own benefit.
41. Upon information and belief, at all times relevant hereto, Defendants in this action
had full knowledge of Plaintiffs’ respective ownership of Plaintiffs’ Marks, including their
respective, exclusive rights to use and license such intellectual property and the goodwill
associated therewith.
42. Defendants’ use of Plaintiffs’ Marks, including the promotion and advertisement,
reproduction, distribution, sale and offering for sale of their Counterfeit Goods, is without
Plaintiffs’ consent or authorization.
43. Defendants are engaging in the above-described illegal counterfeiting and
infringing activities knowingly and intentionally or with reckless disregard or willful blindness to
Plaintiffs’ rights for the purpose of trading on Plaintiffs’ goodwill and reputation. If Defendants’
intentional counterfeiting and infringing activities are not preliminarily and permanently enjoined
by this Court, Plaintiffs and the consuming public will continue to be harmed.
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44. Defendants’ above identified infringing activities are likely to cause confusion,
deception, and mistake in the minds of consumers, the public, and the trade before, during and
after the time of purchase. Moreover, Defendants’ wrongful conduct is likely to create a false
impression and deceive customers, the public, and the trade into believing there is a connection or
association between Plaintiffs’ respective, genuine goods and Defendants’ Counterfeit Goods,
which there is not.
45. Upon information and belief, Defendants’ payment and financial accounts are
being used by Defendants to accept, receive, and deposit profits from Defendants’ trademark
counterfeiting and infringing and unfairly competitive activities connected to their Subject Domain
Name and Seller IDs and any other alias domain names and alias seller identification names being
used and/or controlled by them.
46. Further, upon information and belief, Defendants are likely to transfer or secret
their assets to avoid payment of any monetary judgment awarded to Plaintiffs.
47. Plaintiffs have no adequate remedy at law.
48. Plaintiffs are suffering irreparable and indivisible injury and have suffered
substantial damages as a result of Defendants’ unauthorized and wrongful use of Plaintiffs Marks.
If Defendants’ counterfeiting and infringing, and unfairly competitive activities are not
preliminarily and permanently enjoined by this Court, Plaintiffs and the consuming public will
continue to be harmed.
49. The harm and damages sustained by Plaintiffs have been directly and proximately
caused by Defendants’ wrongful reproduction, use, advertisement, promotion, offers to sell, and
sale of their Counterfeit Goods.
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COUNT I - TRADEMARK COUNTERFEITING AND INFRINGEMENT

PURSUANT TO § 32 OF THE LANHAM ACT (15 U.S.C. § 1114)
50. Plaintiffs hereby adopt and re-allege the allegations set forth in Paragraphs 1
through 49 above.
51. This is an action for trademark counterfeiting and infringement against Defendants
based on their use of counterfeit and confusingly similar imitations of Plaintiffs’ Marks in
commerce in connection with the promotion, advertisement, distribution, offering for sale and sale
of the Counterfeit Goods.
52. Defendants are promoting and otherwise advertising, selling, offering for sale, and
distributing goods using counterfeits and/or infringements of one or more of Plaintiffs’ Marks.
Defendants are continuously infringing and inducing others to infringe Plaintiffs’ Marks by using
them to advertise, promote and sell counterfeit and infringing goods.
53. Defendants’ concurrent counterfeiting and infringing activities are likely to cause
and actually are causing confusion, mistake, and deception among members of the trade and the
general consuming public as to the origin and quality of Defendants’ Counterfeit Goods.
54. Defendants’ unlawful actions have caused and are continuing to cause
unquantifiable damages to Plaintiffs and are unjustly enriching Defendants with profits at
Plaintiffs’ expense.
55. Defendants’ above-described illegal actions constitute counterfeiting and
infringement of Plaintiffs’ Marks in violation of Plaintiffs’ respective rights under § 32 of the
Lanham Act, 15 U.S.C. § 1114.
56. Plaintiffs have suffered and will continue to suffer irreparable injury and damages
due to Defendants’ above described activities if Defendants are not preliminarily and permanently
enjoined. Additionally, Defendants will continue to wrongfully profit from their illegal activities.
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COUNT II - FALSE DESIGNATION OF ORIGIN

PURSUANT TO § 43(a) OF THE LANHAM ACT (15 U.S.C. § 1125(a))
through 49 above.
58. Upon information and belief, Defendants’ Counterfeit Goods bearing, offered for
sale and sold using copies of at least one of Plaintiffs’ Marks have been widely advertised, offered
for sale, and distributed throughout the United States via at least Internet marketplace websites.
59. Defendants’ Counterfeit Goods bearing, offered for sale, and sold using copies of
at least one of Plaintiffs’ Marks are virtually identical in appearance to Plaintiffs’ respective
genuine goods. Accordingly, Defendants’ activities are likely to cause confusion in the trade and
among the general public as to at least the origin or sponsorship of their Counterfeit Goods.
60. Defendants, upon information and belief, have used in connection with their
advertisement, offer for sale, and sale of their Counterfeit Goods, false designations of origin and
false descriptions and representations, including words or other symbols and trade dress, which
tend to falsely describe or represent such goods and have caused such goods to enter into commerce
with full knowledge of the falsity of such designations of origin and such descriptions and
representations, all to Plaintiffs’ detriment.
61. Defendants have authorized infringing uses of at least one of Plaintiffs’ Marks in
Defendants’ advertisement and promotion of their counterfeit and infringing branded goods.
Defendants have misrepresented to members of the consuming public that the Counterfeit Goods
being advertised and sold by them are genuine, non-infringing goods.
62. Additionally, Defendants are using counterfeits and infringements of Plaintiffs’
Marks in order to unfairly compete with Plaintiffs and others for space within search engine
organic results, thereby depriving Plaintiffs of a valuable marketing and educational tool which
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would otherwise be available to Plaintiffs and reducing the visibility of Plaintiffs’ respective,
genuine goods on the World Wide Web.
63. Defendants’ above-described actions are in violation of Section 43(a) of the
Lanham Act, 15 U.S.C. §1125(a).
64. Plaintiffs have no adequate remedy at law, and have sustained indivisible injury
and damage caused by Defendants’ concurrent conduct. Absent an entry of an injunction by this
Court, Defendants will continue to wrongfully reap profits and Plaintiffs will continue to suffer
irreparable injury to their goodwill and business reputation, as well as monetary damages.
COUNT III - COMMON LAW UNFAIR COMPETITION.
through 49 above.
66. This is an action against Defendants based on their promotion, advertisement,
distribution, sale and/or offering for sale of goods bearing marks that are virtually identical, both
visually and phonetically, to Plaintiffs’ Marks in violation of Florida’s common law of unfair
competition.
67. Defendants are promoting and otherwise advertising, selling, offering for sale and
distributing goods bearing counterfeits and infringements of one or more of Plaintiffs’ Marks.
Defendants are also using counterfeits and infringements of Plaintiffs’ Marks to unfairly compete
with Plaintiffs and others for (1) space in search engine results across an array of search terms and
(2) visibility on the World Wide Web.
68. Defendants’ infringing activities are likely to cause and actually are causing
confusion, mistake and deception among members of the trade and the general consuming public
as to the origin and quality of Defendants’ products by their use of Plaintiffs’ Marks.
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69. Plaintiffs have no adequate remedy at law and are suffering irreparable injury and
damages as a result of Defendants’ actions.
COUNT IV - COMMON LAW TRADEMARK INFRINGEMENT
through 49 above.
71. This is an action for common law trademark infringement against Defendants based
on their promotion, advertisement, offering for sale, and sale of their Counterfeit Goods bearing
at least one of Plaintiffs’ Marks. Plaintiffs are the respective owners of all common law rights in
and to Plaintiffs’ Marks.
72. Specifically, Defendants, upon information and belief, are manufacturing,
promoting, and otherwise advertising, distributing, offering for sale, and selling goods bearing
infringements of at least one of Plaintiffs’ Marks.
73. Defendants’ infringing activities are likely to cause and actually are causing
confusion, mistake and deception among members of the trade and the general consuming public
as to the origin and quality of Defendants’ Counterfeit Goods bearing Plaintiffs’ Marks.
74. Plaintiffs have no adequate remedy at law and are suffering damages and
irreparable injury as a result of Defendants’ actions.
PRAYER FOR RELIEF
75. WHEREFORE, Plaintiffs demand judgment on all Counts of this Complaint and
an award of equitable relief and monetary relief against Defendants as follows:
a. Entry of temporary, preliminary, and permanent injunctions pursuant to 15
U.S.C. § 1116 and Federal Rule of Civil Procedure 65 enjoining Defendants, their agents,
representatives, servants, employees, and all those acting in concert or participation therewith,
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from manufacturing or causing to be manufactured, importing, advertising or promoting,
distributing, selling or offering to sell their Counterfeit Goods; from infringing, counterfeiting, or
diluting Plaintiffs’ Marks; from using Plaintiffs’ Marks, or any mark or trade dress similar thereto,
in connection with the sale of any unauthorized goods; from using any logo, trade name or
trademark or trade dress that may be calculated to falsely advertise the services or goods of
Defendants as being sponsored by, authorized by, endorsed by, or in any way associated with
Plaintiffs; from falsely representing themselves as being connected with Plaintiffs, through
sponsorship or association, or engaging in any act that is likely to falsely cause members of the
trade and/or of the purchasing public to believe any goods or services of Defendants, are in any
way endorsed by, approved by, and/or associated with Plaintiffs; from using any reproduction,
counterfeit, infringement, copy, or colorable imitation of Plaintiffs Marks in connection with the
publicity, promotion, sale, or advertising of any goods sold by Defendants; from affixing,
applying, annexing or using in connection with the sale of any goods, a false description or
representation, including words or other symbols tending to falsely describe or represent
Defendants’ goods as being those of Plaintiffs, or in any way endorsed by Plaintiffs and from
offering such goods in commerce; from engaging in search engine optimization strategies using
colorable imitations of Plaintiffs respective name or trademarks and from otherwise unfairly
competing with Plaintiffs.
b. Entry of an Order pursuant to 28 U.S.C. § 1651(a), The All Writs Act, that,
upon Plaintiffs’ request, the top level domain (TLD) Registry for the Subject Domain Name or its
administrator, including backend registry operators or administrators, place the Subject Domain
Name on Registry Hold status for the remainder of the registration period, thus removing it from
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the TLD zone files which link the Subject Domain Name to the IP address where the associated
website is hosted.
c. Entry of an Order pursuant to 28 U.S.C. § 1651(a), The All Writs Act,
canceling for the life of the current registration or, at Plaintiffs’ election, transferring the Subject
Domain Name and any other domain names used by Defendants to engage in their counterfeiting
of Plaintiffs’ Marks at issue to Plaintiffs’ control so they may no longer be used for illegal
purposes, and requiring the Seller IDs, and any other alias seller identification names being used
by Defendants to engage in the business of marketing, offering to sell and/or selling goods bearing
counterfeits and infringements of Plaintiffs’ Marks be disabled by the applicable governing
Internet marketplace.
d. Entry of an Order 28 U.S.C. § 1651(a), The All Writs Act, that, upon
Plaintiffs’ request, any Internet marketplace website operators and/or administrators who are
provided with notice of the injunction, including but not limited to Alibaba.com Hong Kong
Limited, which operates the AliExpress.com platform, Amazon.com, Inc., Bonanza.com, Inc.,
eBay.com and Etsy.com, permanently remove any and all listings and associated images of goods
bearing counterfeits and/or infringements of Plaintiffs’ Marks via the e-commerce stores operating
under the Seller IDs, including any and all listings and images of goods bearing counterfeits and/or
infringements of Plaintiffs’ Marks linked to the same seller or linked to any other alias seller
identification name being used and/or controlled by Defendants to promote, offer for sale and/or
sell goods bearing counterfeits and/or infringements of Plaintiffs’ Marks linked to the same seller
or linked to any other alias seller identification name being used and/or controlled by Defendants
to promote, offer for sale and/or sell goods bearing counterfeits and/or infringements of Plaintiffs’
Marks.
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e. Entry of an Order 28 U.S.C. § 1651(a), The All Writs Act, that, upon
Plaintiffs’ request, any Internet marketplace website operators and/or administrators who are
provided with notice of the injunction, including but not limited to Alibaba.com Hong Kong
Limited, which operates the AliExpress.com platform, Amazon.com, Inc., Bonanza.com, Inc.,
eBay.com and Etsy.com, immediately cease fulfillment of and sequester all goods of each
Defendant bearing one or more of Plaintiffs’ Marks in its inventory, possession, custody, or
control, and surrender those goods to Plaintiffs.
f. Entry of an Order requiring Defendants to account to and pay Plaintiffs for
all profits and damages resulting from Defendants’ trademark counterfeiting and infringing and
unfairly competitive activities and that the award to Plaintiffs be trebled, as provided for under 15
U.S.C. §1117, or, at Plaintiffs’ election with respect to Count I, that Plaintiffs be awarded statutory
damages from each Defendant in the amount of two million dollars ($2,000,000.00) per each
counterfeit trademark used and product sold, as provided by 15 U.S.C. §1117(c)(2) of the Lanham
Act.
g. Entry of an award pursuant to 15 U.S.C. § 1117 (a) and (b) of Plaintiffs’
costs and reasonable attorneys’ fees and investigative fees associated with bringing this action.
h. Entry of an Order 28 U.S.C. § 1651(a), The All Writs Act, that, upon
Plaintiffs’ request, any financial institutions, payment processors, banks, escrow services, money
transmitters, or marketplace platforms, including but not limited to, Alibaba.com Hong Kong
Limited, Zhejiang Ant Small and Micro Financial Services Group Co., Ltd., AliPay (China)
Internet Technology Co. Ltd., and Alipay.com Co., Ltd., Amazon Payments, Inc., PayPal, Inc.,
and their related companies and affiliates, identify and restrain all funds, up to and including the
total amount of judgment, in all financial accounts and/or sub-accounts used in connection with
20
the Subject Domain Name and Seller IDs or other domain names, alias seller identification names,
or e-commerce store names used by Defendants presently or in the future, as well as any other
related accounts of the same customer(s) and any other accounts which transfer funds into the same
financial institution account(s), to be surrendered to Plaintiffs in partial satisfaction of the
monetary judgment entered herein.
i. Entry of an award of pre-judgment interest on the judgment amount.
j. Entry of an Order for any further relief as the Court may deem just and
proper.
DATED: February 1, 2018. Respectfully submitted,
STEPHEN M. GAFFIGAN, P.A.
By: s/Stephen M. Gaffigan

Stephen M. Gaffigan (Fla. Bar No. 025844)
Virgilio Gigante (Fla. Bar No. 082635)
T. Raquel Wiborg-Rodriguez (Fla. Bar. No. 103372)
401 East Las Olas Blvd., Suite 130-453
Ft. Lauderdale, Florida 33301
Telephone: (954) 767-4819
Facsimile: (954) 767-4821
E-mail: Stephen@smgpa.net
E-mail: Leo@smgpa.net
E-mail: Raquel@smgpa.net
Attorneys for Plaintiffs
21
SCHEDULE “A”
DEFENDANTS BY NUMBER, SUBJECT DOMAIN NAME, AND SELLER ID
Defendant /
Def. No. Amazon Seller ID Number
Subject Domain Name or Seller ID
1 shirtsforyou.net
2 B..F Store
3 Good luck to you
4 GreenMango Store
5 HOOK ON YOU
6 Junlianqi Store
7 LUCK FRIDAY Store
8 LUCKYFRIDAY Store
9 Milestone 2013
10 Moonprint
11 NOAHCOSY Store
12 PEAR GARMENT Store
13 uncle Loong Store
14 X. Store
15 xingqiwu Store
16 Ace DIY A3BIY06C7QB8XW
17 Brenda HHH AAWBZIY68PL3P
18 hzjiuiyyh A1MMSOWUY80BVV
19 KDTMK A6VUGP0RUY3RC
20 Oskay ADA168YTKF44Y
21 Rui Feng Co Ltd A95XNZJ3JW38I
22 taojing A3BLD21B3DCW1H
23 Arliando
24 BaladAron
25 BiliM1
26 dealexinayastore
27 ella2015
27 uponstyle
28 girlbee
29 gregharson
30 ika_lestari
31 mochistore88
32 Rosalia_Collections
33 Shirts For You
33 Shirts_For_You
34 Unique wacky neckties, watches, backpacks
for geeks nerds cosplay moviemaniacs
34 lilunder
35 unique_style
36 adityo77
22
36 aditysimorangki0
37 beautyandluck
38 caixiaoyunyun
39 customdropshipping
40 dan_online226
41 filydonline
42 letstoyout
43 nikitos-1982
43 Art and collecting
44 shevalues
45 spedo202
46 topiseood
47 Prints4CuteKids
48 RockSins
23
SCHEDULE “B”
PLAINTIFF APPLE CORPS’ FEDERALLY REGISTERED TRADEMARKS
Registration
Trademark Registration Date Class(es) / Good(s)
Number
IC 025 - Clothing for men, women and children;

namely, aprons, bath robes, bathing trunks,
swimsuits, swimsuit covers, belts, coats, dresses,
THE BEATLES 1,752,120 February 16, 1993 smocks, skirts, headwear, jackets, jumpers, jerseys,
pullovers, sweaters, sweatshirts, t-shirts, shirts,
blouses, underwear, pajamas, nightgowns, socks,
trousers, dungarees, jeans, tank tops and sun-tops.
24
Registration
Number
IC 009 – Snorkels, goggles, and masks for

swimming; sandglass egg timers; downloadable
electronic magazine featuring articles, quizzes,
competitions, games, photographs, animation and
video stills in the field of music and musical
entertainment; exposed cinematographic and
photographic film; photographic and
cinematographic apparatus and
instruments, namely, cinematographic film
projectors, cinematographic film projection screens,
photographic slide projection screens, apparatus
for recording, transmission or reproduction of
sound or images, namely, cd players; digital audio
tape players; blank magnetic data carriers, blank
floppy and hard recording computer discs;
automatic vending machines; cash registers,
calculators, data processors and computer
hardware; musical sound and video recordings;
motion picture films featuring music, musicians,
caricatures, cartoons, animation, documentaries,
biographies, interviews of individuals in the music
and movie industry, fan interviews, movie and
music reviews, drama and fiction; computer
BEATLES 4,373,956 July 30, 2013
software, including virtual reality software, for
use in entertainment, namely, for storing,
displaying or playing music, images, animation,
information in the field of music, games, and quiz
games; computer software, including virtual reality
software, that may be downloaded from a global
computer network for storing, displaying or playing
sound, music, images, digital books, magazines,
games, ring tones, and screen savers, all in the field
of musical sound and video recordings; computer
software, including virtual reality software, that
may be downloaded from a global computer
network in the nature of applications for
entertainment or learning, namely, software for
displaying or playing music or images in the field
of musical sound and video recordings; computer
recording software for recording musical sounds
and video images; computer game software; video
game software; interactive entertainment software,
including virtual reality software, for displaying or
playing sound, music, images, digital books,
magazines, games, ring tones, and screen savers;
interactive entertainment software, namely,
25
Registration
Number
computer game software featuring music and

images; educational software featuring instruction
in music; video game cartridges and discs;
interactive compact discs featuring music,
musicians, caricatures, cartoons, animation,
documentaries, biographies, interviews of
individuals in the music and movie industry, fan
interviews, movie and music reviews, drama and
fiction; cd-roms featuring music, musicians,
caricatures, cartoons, animation, documentaries,
biographies, interviews of individuals in the music
and movie industry, fan interviews, movie and
music reviews, drama and fiction; magnetically
encoded pre-paid telephone calling cards;
sunglasses; decorative refrigerator magnets;
photographic slide transparencies; digital photo
frames for displaying digital photographic
slide transparencies; radios; cases specially adapted
for storing audio and video cassettes, computer
discs, computer cartridges and computer cards;
computer software featuring video games; racks
specially adapted to hold video and audio cassettes,
computer discs, cartridges and cards and computer
game software; electrical apparatus for generating,
processing and reproducing images, namely,
portable music tape players, compact disc and
digital audio players, portable personal digital video
players, portable personal video disc players, and
audio-visual musical juke boxes; computer
keyboard accessories, namely, mouse pads and
wrist rests in the form of pads for use with
computers; neon signs; phonograph records
featuring music, gramophone records featuring
music; pre-recorded audio cassettes featuring
music; audio compact discs featuring music; pre-
recorded digital audio tapes featuring music;
downloadable audio and video recordings featuring
music; prerecorded digital versatile compact
discs, video cassettes, video discs, interactive
compact discs, and multimedia computer software
recorded on cd-roms featuring music, films of
musicians, caricatures, cartoons or animation; blank
recordable audio cassettes, video cassettes, compact
discs and video discs; blank discs for computers;
computer game cartridges; computer game
discs; video game cartridges; video game discs;
26
Registration
Number
computer software for use in creating virtual reality

images for entertainment and educational
purposes; virtual reality entertainment software for
displaying or playing computer games, music,
sound, images, and graphics; interactive
virtual reality video game software; memory
devices for computer game equipment, namely,
disc memories, memory cards, secure
digital memory cards, flash memory cards, and
memories for use with computers in the form of
tapes and cassettes, and computer chips; coin
or token operated computer game equipment,
namely, computer game discs; musical juke boxes;
eyeglass cases; sunglass and eyeglass cords;
computer mice and computer roller balls, namely,
trackballs; radio receivers; video cassette recorders
and players; audio cassette recorders and players;
gramophone players; audio compact disc players;
digital versatile compact disc players; video disc
players; loudspeakers; photographic cameras;
luminous signs; electric door bells; telephone
apparatus, namely, telephones; telephone receivers,
telephone answering machines, mobile telephones;
cases for mobile telephones; cell phone covers;
covers for mobile telephones, namely, fitted plastic
films known as skins for covering and protecting
electronic apparatus in the nature of mobile
telephones; straps for mobile telephones; telephone
call indicator lights and electro-mechanical shakers
for detecting and signaling incoming telephone
calls; mechanical and electric egg timers; boxes and
cases specially adapted for holding audio cassettes,
video cassettes, gramophone records, audio
compact discs, audio mini discs, video discs, and
interactive compact discs or cd-roms; and
skateboard helmets.
IC 014 - Jewelry boxes not of metal, including

ceramic and porcelain jewelry boxes for trinkets;
jewelry; horological and chronometric instruments,
namely, watches and clocks; watch straps, cuff
links, brooches, bracelets, bangles, earrings,
pendants, medallions, trinkets being jewelry,
charms being jewelry, rings being jewelry, tie pins,
jewelers ornamental tie pins, lapel pins, tie clips,
collectible non-monetary coins, ornamental pins;
27
Registration
Number
articles of precious metal and their alloys, and

articles coated with precious metal and their alloys,
namely, belt buckles for clothing, coasters, jewelry
boxes, key rings, key chains; hat and shoe
ornaments and key fobs all of precious metal; rings
being jewelry; ornamental pins; cigarette and cigar
cases; precious stones; semi-precious stones;
statuettes and figurines of precious metal or
precious stone or coated therewith; scale model
vehicles, ships or submarines all made from, or
coated with precious metal or precious stone.
IC 018 - Goods made from leather or imitation

leather, namely, waist pouches for carrying purses
and wallets; luggage, carry on traveling bags, clutch
bags, trunks, business card cases, rucksacks,
backpacks, purses, wallets, key cases, luggage tags;
billfolds, leather key fobs, key cases, umbrellas;
bags, namely, handbags, shoulder bags, all purpose
sports bags, barrel bags, carry-on flight bags, and
duffel bags, suitcases, attaché cases, school bags,
satchels, gym bags, beach bags and credit card
cases; hand carry overnight cases of metal, plastic
or resin; tote bags, including metal totes; textile
shopping bags; identity card holders of leather and
imitations of leather.
IC 024 - Decorative window curtains of wood,

reed, bamboo, beads or plastic; household linen;
bed linen; bedspreads; table linen; table cloths not
of paper; table mats not of paper; textile table
napkins; coasters made of table linen or textile;
unfitted fabric furniture covers; bed sheets, pillow
cases, duvet covers; towels; face towels; face
washing cloths; curtains; wall hanging of textile;
cloth banners; cloth bunting; cloth flags;
handkerchiefs; cushion covers; pre-cut textiles for
making into cushions and cushion covers; traced
cloths for embroidery.
28
Registration
Number
IC 025 - Footwear and headgear, namely, hats and

caps; clothing, namely, shirts, polo shirts, T-shirts,
sweatshirts; sweatpants; jackets, coats; pullovers;
vests; articles of underclothing, namely, underwear;
shorts; scarves; silk pocket squares; neck-ties;
braces in the nature of suspenders; belts; socks;
long-sleeved shirts and long sleeved T-shirts; silk
scarves; silk scarves in the shape of squares for
wearing over the head or around the neck; pants;
fleece tops; thermal tops; jerseys; baseball jerseys;
hockey jerseys; sweaters; tank tops; waistcoats;
trousers; golf shirts; golf pants; golf shoes; swim
wear; beachwear; night gowns; pajamas; dressing
gowns; bathrobes; bathing caps; head bands;
slippers; beach shoes; sandals; clothing for toddlers,
infants and babies, namely, rompers, shortalls,
babies' sleep suits; cloth babies' bibs.
IC 027 - Carpets; rugs; linoleum for use on floors;

wall hangings not of textile; reed mats; rubber and
plastic bath mats; door mats; textile floor mats for
use in the home.
29
SCHEDULE “C”
PLAINTIFF SUBAFILMS’ FEDERALLY REGISTERED TRADEMARK
Registration
Number
IC 009 - Musical sound and video recordings;

gramophone records featuring music; pre-recorded
audio cassettes featuring music; audio compact
discs featuring music; pre-recorded digital
versatile discs featuring music; pre-recorded
video cassettes featuring music musicians,
caricatures, cartoons or animation; video discs
featuring music, musicians, caricatures, cartoons or
animation; motion picture films featuring music,
musicians, caricatures, cartoons or animation; pre-
recorded interactive compact discs featuring music,
musicians, caricatures, cartoons or animation;
multimedia software recorded on cd-roms featuring
music, musicians, caricatures, cartoons or
animation; blank recordable audio cassettes,
video cassettes, compact discs and video discs;
blank discs for computers; exposed photographic
films; photographic slide transparencies; computer
game software; computer game cartridges;
computer game discs; video game software; video
3,328,170 November 6, 2007 game cartridges; video game discs; computer
software for use in creating images; interactive
entertainment software for generating games,
puzzles, images, musical entertainment, visual
entertainment or movie clips; virtual reality
entertainment software for generating games,
puzzles, images, musical entertainment, visual
entertainment or movie clips; interactive video
games of virtual reality comprised of computer
hardware or computer software; computer game
joysticks; video game machines for use with
televisions or computers; virtual reality display
apparatus, namely, computer hardware and
software for generating images in virtual reality·
virtual reality cinemas and screens; motion
simulators for simulating the motion of a vehicle,
ship; automatic vending machines; cash registers;
computers; calculators; data processors;
juice boxes; magnetically encoded telephone
cards; sunglasses; eyeglass cases; sunglass and
eyeglass cords; magnets; fridge magnets; frames for
photographic transparencies in the nature of holders
30
Registration
Number
that enable a slide to be viewed in a slide viewer;

computer mouses and computer roller balls; mouse
pads and wrist pads, all being accessories for
keyboards; radio receners; video cassette recorders
and players; audio cassette recorders and players;
gramophone players; audio compact disc players;
digital versatile disc players; video disc players;
loudspeakers; photographic cameras; luminous
signs; electric door bells; telephone apparatus,
namely telephones, telephone receners, telephone
answering machines, mobile telephones, cases for
mobile telephones and covers for mobile
telephones; straps for mobile telephones; telephone
call indicator lights and shakers for detecting and
signaling incoming telephone calls; mechanical and
electric egg timers; boxes and cases for holding
audio cassettes, video cassettes, gramophone
records, audio compact discs, audio mini discs,
video discs, interactive compact discs or cd-roms;
skateboard helmets; and downloadable sound and
video records featuring music, musicians,
caricatures, cartoons, animation, movie clips, album
art or music memorabilia images provided over
broadcast, communications, satellite and computer
networks; egg timers, namely, sandglasses.
IC 025 - Footwear; shirts; polo shirts; t-shirts; long-

sleeved shirts and long-sleeved t-shirts; sweatshirts;
jackets; coats; pullovers; vests; articles of
underclothing; shorts; boxers shorts; scarves; silk
scarves; silk squares for wearing over the head or
around the neck; pocket squares made of silk; neck-
ties; hats; caps; suspenders; belts; sock; pants;
fleece tops; thermal tops; jerseys; baseball jerseys;
hockey jerseys; sweaters; tank tops; waistcoats;
trousers; golf shirts; golf pants; golf shoes;
swimwear; beachwear; night gowns; pajamas;
dressing gowns; bath robes; bathing caps;
headbands; slippers; beach shoes; sandals; clothing
for toddlers, infants and babies namely, one piece
garments for infants and toddlers, sleep suits,
hooded tops, t-shirts and long-sleeved t-shirts; cloth
babies bibs.
31
Case 0:18-cv-60221-RNS Document 1-1 Entered on FLSD Docket 02/01/2018 Page 1 of 12
Composite Exhibit 1
BEATLES
Reg. No. 4,373,956 APPLE CORPS LIMITED (UNITED KINGDOM LIMITED COMPANY)
27 OVINGTON SQUARE
Registered July 30, 2013 LONDON, UNITED KINGDOM SW3 ILJ
Int. Cls.: 4, 8, 9, 11, 14, FOR:CANDLES;NON-ELECTRICNIGHTLIGHTS,NAMELY,SLOWBURNINGCANDLEs

15, 16, 18, 20, 21, 24, 25, CONTAINED WITHIN A DISH; CANDLE AND OIL LAMP WICKS; FUELS FOR OIL AND
27 28 34 41 and 42 PARAFFIN LAMPS, NAMELY, LAMP OIL AND PARAFFIN, IN CLASS 4 (U.S. CLS. 1, 6
' ' ' AND 15).
TRADEMARK FOR: SMALL DOMESTIC TABLEWARE UTENSILS, NAMELY, FORKS, KNIVES AND
SPOONS, IN CLASS 8 (U.S. CLS. 23, 28 AND 44).
SERVICE MARK
FOR: SNORKELS, GOGGLES, AND MASKS FOR SWIMMING; SANDGLASS EGG TIMERS;
PRINCIPAL REGISTER DOWNLOADABLE ELECTRONIC MAGAZINE FEATURING ARTICLES, QUIZZES, COM-
PETITIONS, GAMES, PHOTOGRAPHS, ANIMATION AND VIDEO STILLS IN THE FIELD
OF MUSIC AND MUSICAL ENTERTAINMENT; EXPOSED CINEMATOGRAPHIC AND
PHOTOGRAPHIC FILM; PHOTOGRAPHIC AND CINEMATOGRAPHIC APPARATUS AND
INSTRUMENTS, NAMELY, CINEMATOGRAPHIC FILM PROJECTORS, CINEMATOGRAPHIC
FILM PROJECTION SCREENS, PHOTOGRAPHIC SLIDE PROJECTION SCREENS, APPAR-
ATUS FOR RECORDING, TRANSMISSION OR REPRODUCTION OF SOUND OR IMAGES,
NAMELY, CD PLAYERS; DIGITAL AUDIO TAPE PLAYERS; BLANK MAGNETIC DATA
CARRIERS, BLANK FLOPPY AND HARD RECORDING COMPUTER DISCS; AUTOMATIC
VENDING MACHINES; CASH REGISTERS, CALCULATORS, DATA PROCESSORS AND
COMPUTER HARDWARE; MUSICAL SOUND AND VIDEO RECORDINGS; MOTION PIC-
TURE FILMS FEATURING MUSIC, MUSICIANS, CARICATURES, CARTOONS,ANIMATION,
DOCUMENTARIES, BIOGRAPHIES, INTERVIEWS OF INDIVIDUALS IN THE MUSIC AND
MOVIE INDUSTRY, FAN INTERVIEWS, MOVIE AND MUSIC REVIEWS, DRAMA AND
FICTION; COMPUTER SOFTWARE, INCLUDING VIRTUAL REALITY SOFTWARE, FOR
USE IN ENTERTAINMENT, NAMELY, FOR STORING, DISPLAYING OR PLAYING MUSIC,
IMAGES, ANIMATION, INFORMATION IN THE FIELD OF MUSIC, GAMES, AND QUIZ
GAMES; COMPUTER SOFTWARE, INCLUDING VIRTUAL REALITY SOFTWARE, THAT
MAY BE DOWNLOADED FROM A GLOBAL COMPUTER NETWORK FOR STORING,
DISPLAYING OR PLAYING SOUND, MUSIC, IMAGES, DIGITAL BOOKS, MAGAZINES,
GAMES, RING TONES, AND SCREEN SAVERS, ALL IN THE FIELD OF MUSICAL SOUND
AND VIDEO RECORDINGS; COMPUTER SOFTWARE, INCLUDING VIRTUAL REALITY
SOFTWARE, THAT MAY BE DOWNLOADED FROM A GLOBAL COMPUTER NETWORK
IN THE NATURE OF APPLICATIONS FOR ENTERTAINMENT OR LEARNING, NAMELY,
SOFTWARE FOR DISPLAYING OR PLAYING MUSIC OR IMAGES IN THE FIELD OF MU-
SICAL SOUND AND VIDEO RECORDINGS; COMPUTER RECORDING SOFTWARE FOR
RECORDING MUSICAL SOUNDS AND VIDEO IMAGES; COMPUTER GAME SOFTWARE;
~
VIDEO GAME SOFTWARE; INTERACTIVE ENTERTAINMENT SOFTWARE, INCLUDING
_,,d ' VIRTUAL REALITY SOFTWARE, FOR DISPLAYING OR PLAYING SOUND, MUSIC, IM-
...-e~ 'to?--<' 7~
AGES, DIGITAL BOOKS, MAGAZINES, GAMES, RING TONES, AND SCREEN SAVERS;
ActingDrredo,oftheUnitedstat.. PatentandTrndema<kOffice INTERACTIVE ENTERTAINMENT SOFTWARE, NAMELY, COMPUTER GAME SOFTWARE
FEATURING MUSIC AND IMAGES; EDUCATIONAL SOFTWARE FEATURING INSTRUC-

Reg. No. 4 373 956 TION IN MUSIC; VIDEO GAME CARTRIDGES AND DISCS; INTERACTIVE COMPACT
' ' DISCS FEATURING MUSIC, MUSICIANS, CARICATURES, CARTOONS, ANIMATION,
DOCUMENTARIES, BIOGRAPHIES, INTERVIEWS OF INDIVIDUALS IN THE MUSIC AND
MOVIE INDUSTRY, FAN INTERVIEWS, MOVIE AND MUSIC REVIEWS, DRAMA AND
FICTION; CD-ROMS FEATURING MUSIC, MUSICIANS, CARICATURES, CARTOONS,
ANIMATION, DOCUMENTARIES, BIOGRAPHIES, INTERVIEWS OF INDIVIDUALS IN
THE MUSIC AND MOVIE INDUSTRY, FAN INTERVIEWS, MOVIE AND MUSIC REVIEWS,
DRAMA AND FICTION; MAGNETICALLY ENCODED PRE-PAID TELEPHONE CALLING
CARDS; SUNGLASSES; DECORATIVE REFRIGERATOR MAGNETS; PHOTOGRAPHIC
SLIDE TRANSPARENCIES; DIGITAL PHOTO FRAMES FOR DISPLAYING DIGITAL PHO-
TOGRAPHIC SLIDE TRANSPARENCIES; RADIOS; CASES SPECIALLY ADAPTED FOR
STORING AUDIO AND VIDEO CASSETTES, COMPUTER DISCS, COMPUTER CARTRIDGES
AND COMPUTER CARDS; COMPUTER SOFTWARE FEATURING VIDEO GAMES; RACKS
SPECIALLY ADAPTED TO HOLD VIDEO AND AUDIO CASSETTES, COMPUTER DISCS,
CARTRIDGES AND CARDS AND COMPUTER GAME SOFTWARE; ELECTRICAL APPAR-
ATUS FOR GENERATING, PROCESSING AND REPRODUCING IMAGES, NAMELY,
PORTABLE MUSIC TAPE PLAYERS, COMPACT DISC AND DIGITAL AUDIO PLAYERS,
PORTABLE PERSONAL DIGITAL VIDEO PLAYERS, PORTABLE PERSONAL VIDEO DISC
PLAYERS, AND AUDIO-VISUAL MUSICAL JUKE BOXES; COMPUTER KEYBOARD AC-
CESSORIES, NAMELY, MOUSE PADS AND WRIST RESTS IN THE FORM OF PADS FOR
USE WITH COMPUTERS; NEON SIGNS; PHONOGRAPH RECORDS FEATURING MUSIC,
GRAMOPHONE RECORDS FEATURING MUSIC; PRE-RECORDED AUDIO CASSETTES
FEATURING MUSIC; AUDIO COMPACT DISCS FEATURING MUSIC; PRE-RECORDED
DIGITAL AUDIO TAPES FEATURING MUSIC; DOWNLOADABLE AUDIO AND VIDEO
RECORDINGS FEATURING MUSIC; PRERECORDED DIGITAL VERSATILE COMPACT
DISCS, VIDEO CASSETTES, VIDEO DISCS, INTERACTIVE COMPACT DISCS, AND
MULTIMEDIA COMPUTER SOFTWARE RECORDED ON CD-ROMS FEATURING MUSIC,
FILMS OF MUSICIANS, CARICATURES, CARTOONS OR ANIMATION; BLANK RECORD-
ABLE AUDIO CASSETTES, VIDEO CASSETTES, COMPACT DISCS AND VIDEO DISCS;
BLANK DISCS FOR COMPUTERS; COMPUTER GAME CARTRIDGES; COMPUTER GAME
DISCS; VIDEO GAME CARTRIDGES; VIDEO GAME DISCS; COMPUTER SOFTWARE FOR
USE IN CREATING VIRTUAL REALITY IMAGES FOR ENTERTAINMENT AND EDUCA-
TIONAL PURPOSES; VIRTUAL REALITY ENTERTAINMENT SOFTWARE FOR DISPLAYING
OR PLAYING COMPUTER GAMES, MUSIC, SOUND, IMAGES, AND GRAPHICS; INTER-
ACTIVE VIRTUAL REALITY VIDEO GAME SOFTWARE; MEMORY DEVICES FOR COM-
PUTER GAME EQUIPMENT, NAMELY, DISC MEMORIES, MEMORY CARDS, SECURE
DIGITAL MEMORY CARDS, FLASH MEMORY CARDS, AND MEMORIES FOR USE WITH
COMPUTERS IN THE FORM OF TAPES AND CASSETTES, AND COMPUTER CHIPS; COIN
OR TOKEN OPERATED COMPUTER GAME EQUIPMENT, NAMELY, COMPUTER GAME
DISCS; MUSICAL JUKE BOXES; EYEGLASS CASES; SUNGLASS AND EYEGLASS CORDS;
COMPUTER MICE AND COMPUTER ROLLER BALLS, NAMELY, TRACKBALLS; RADIO
RECEIVERS; VIDEO CASSETTE RECORDERS AND PLAYERS; AUDIO CASSETTE RE-
CORDERS AND PLAYERS; GRAMOPHONE PLAYERS; AUDIO COMPACT DISC PLAYERS;
DIGITAL VERSATILE COMPACT DISC PLAYERS; VIDEO DISC PLAYERS; LOUDSPEAK-
ERS; PHOTOGRAPHIC CAMERAS; LUMINOUS SIGNS; ELECTRIC DOOR BELLS; TELE-
PHONE APPARATUS, NAMELY, TELEPHONES; TELEPHONE RECEIVERS, TELEPHONE
ANSWERING MACHINES, MOBILE TELEPHONES; CASES FOR MOBILE TELEPHONES;
CELL PHONE COVERS; COVERS FOR MOBILE TELEPHONES, NAMELY, FITTED PLASTIC
FILMS KNOWN AS SKINS FOR COVERING AND PROTECTING ELECTRONIC APPARATUS
IN THE NATURE OF MOBILE TELEPHONES; STRAPS FOR MOBILE TELEPHONES;
TELEPHONE CALL INDICATOR LIGHTS AND ELECTRO-MECHANICAL SHAKERS FOR
DETECTING AND SIGNALING INCOMING TELEPHONE CALLS; MECHANICAL AND
ELECTRIC EGG TIMERS; BOXES AND CASES SPECIALLY ADAPTED FOR HOLDING
AUDIO CASSETTES, VIDEO CASSETTES, GRAMOPHONE RECORDS, AUDIO COMPACT
DISCS, AUDIO MINI DISCS, VIDEO DISCS, AND INTERACTIVE COMPACT DISCS OR
CD-ROMS; AND SKATEBOARD HELMETS, IN CLASS 9 (U.S. CLS. 21, 23, 26, 36AND 38).
Page: 2 I RN# 4,373,956

Reg. NO. 4 373 956 FOR: LAMP BASES OF GLASS, PORCELAIN AND EARTHENWARE; LAMPS, INCLUDING,
' ' TABLE LAMPS MADE FROM PORCELAIN, GLASS, EARTHENWARE, PLASTER, PLASTIC,
WOOD, WAX, RESIN, CORK, REED, CANE, WICKER, HORN, BONE, IVORY, WHALEBONE,
SHELL, AMBER, MOTHER OF PEARL, MEERSCHAUM AND SUBSTITUTES FOR THESE
MATERIALS; DECORATIVE WATER FOUNTAINS MADE FROM PORCELAIN, GLASS,
EARTHENWARE, PLASTER, PLASTIC, WOOD, WAX, RESIN, CORK, REED, CANE,
WICKER, HORN, BONE, IVORY, WHALEBONE, SHELL, AMBER, MOTHER OF PEARL,
MEERSCHAUM AND SUBSTITUTES FOR THESE MATERIALS , IN CLASS 11 (U.S. CLS.
13, 21, 23, 31AND34).
FOR: JEWELRY BOXES NOT OF METAL, INCLUDING CERAMIC AND PORCELAIN

JEWELRY BOXES FOR TRINKETS; JEWELRY; HOROLOGICAL AND CHRONOMETRIC
INSTRUMENTS, NAMELY, WATCHES AND CLOCKS; WATCH STRAPS, CUFF LINKS,
BROOCHES, BRACELETS, BANGLES, EARRINGS, PENDANTS, MEDALLIONS, TRINKETS
BEING JEWELRY, CHARMS BEING JEWELRY, RINGS BEING JEWELRY, TIE PINS, JEW-
ELERS ORNAMENTAL TIE PINS, LAPEL PINS, TIE CLIPS, COLLECTIBLE NON-MONETARY
COINS, ORNAMENTAL PINS; ARTICLES OF PRECIOUS METAL AND THEIR ALLOYS,
AND ARTICLES COATED WITH PRECIOUS METAL AND THEIR ALLOYS, NAMELY,
BELT BUCKLES FOR CLOTHING, COASTERS, JEWELRY BOXES, KEY RINGS, KEY
CHAINS; HAT AND SHOE ORNAMENTS AND KEY FOBS ALL OF PRECIOUS METAL;
RINGS BEING JEWELRY; ORNAMENTAL PINS; CIGARETTE AND CIGAR CASES; PRE-
CIOUS STONES; SEMI-PRECIOUS STONES; STATUETTES AND FIGURINES OF PRECIOUS
METAL OR PRECIOUS STONE OR COATED THEREWITH; SCALE MODEL VEHICLES,
SHIPS OR SUBMARINES ALL MADE FROM, OR COATED WITH PRECIOUS METAL OR
PRECIOUS STONE, IN CLASS 14 (U.S. CLS. 2, 27, 28 AND 50).
FOR: MUSICAL INSTRUMENTS, MUSICAL BOXES, BARREL ORGANS, PERFORATED

MUSIC ROLLS FOR PLAYER PIANOS, IN CLASS 15 (U.S. CLS. 2, 21 AND 36).
FOR: ARTICLES OF PRECIOUS METAL AND THEIR ALLOYS, AND ARTICLES COATED
WITH PRECIOUS METAL AND THEIR ALLOYS, NAMELY, MONEY CLIPS; NON-METAL
MONEY CLIPS; BOOKENDS, INCLUDING BOOKENDS MADE FROM GLASS, PORCELAIN,
EARTHENWARE, PLASTER, PLASTIC, WOOD, WAX, RESIN, CORK, REED, CANE,
WICKER, HORN, BONE, IVORY, WHALEBONE, SHELL, AMBER, MOTHER OF PEARL,
MEERSCHAUM AND SUBSTITUTES FOR THESE MATERIALS; BOND, CARBON, COPY,
PRINTING AND WRITING PAPER; CARDBOARD; PRINTED MATTER, NAMELY, PRINTED
AWARDS, PRINTED AWARD CERTIFICATES, AND REPRODUCTIONS OF PRINTED
AWARD CERTIFICATES, AND PRINTED EMBLEMS AND FORMS; BOOK BINDING MA-
TERIALS, NAMELY, COATED PAPER FOR USE AS BOOK BINDING AND BOOK BINDING
CLOTH; MOUNTED AND UNMOUNTED PHOTOGRAPHS; STATIONERY; ADHESIVE
TAPES FOR STATIONERY OR HOUSEHOLD PURPOSES; ARTIST MATERIALS, NAMELY,
PAINT BRUSHES, ARTISTS' SKETCH PADS, DRAWING AND PAINTING PAPERS AND
CHARCOAL PENCILS; ELECTRIC AND NON-ELECTRIC TYPEWRITERS; OFFICE REQUIS-
ITES, NAMELY, PAPER SHREDDERS AND EMBOSSERS; PRINTED INSTRUCTIONAL
AND TEACHING MATERIALS ON THE SUBJECT OF MUSIC; PLASTIC BUBBLE PACKS
FOR PACKAGING; PRINTING TYPE; PRINTING BLOCKS; POSTERS; BOOKS, NAMELY,
EDUCATIONAL BOOKS ON THE SUBJECT OF MUSICAL GROUPS, BOOKS ON THE
SUBJECT OF THE ENTERTAINMENT INDUSTRY, BOOKS ON THE SUBJECT OF MODERN
HISTORY, AND BIOGRAPHIES; ADDRESS BOOKS; SONG BOOKS; BUSINESS CARDS;
PAPER GIFT CARDS, POSTCARDS; PRINTED INVITATIONS; GREETING CARDS; CALEN-
DARS; PHOTOGRAPH ALBUMS; PRINTS, NAMELY, PHOTOGRAPH PRINTS AND
PICTORIAL PRINTS; PAPER GIFT BAGS; PAPER GIFT BOXES; NOTE PADS, NOTE BOOKS;
ADHESIVE BACKED PAPER FOR STATIONERY PURPOSES; PENS, PENCILS AND
CRAYONS; STATIONERY PUSH PINS AND THUMBTACKS; DIARIES; BLANK CHECKS
AND BLANK CHECK BOOKS; CHECK BOOK COVERS; COASTERS OF CARDBOARD OR
PAPER; GIFT TAGS OF PAPER AND CARDBOARD; DECORATIVE PENCIL TIP ORNA-
MENTS MADE FROM PAPER, CARDBOARD AND PAPER MACHE; STICKERS; DECAL-
COMANIA; RING BINDERS INTHE NATURE OF DOCUMENTFILES; FOLDERS; PERSONAL
Page: 3 I RN# 4,373,956

Reg. NO. 4 373 956 ORGANIZERS; COVERS FOR BOOKS AND FOR PERSONAL ORGANIZERS; PAPER TABLE
' ' CLOTHS; PRINTED SHEET MUSIC; PRINTED PAPER PUBLICATIONS IN THE NATURE
OFMAGAZINES,ACTIVITYBOOKS,ANDCOLORINGBOOKSONTHESUBJECTMATTER
OF MUSICIANS, ANIMATION, CARICATURES, CARTOONS, FICTION AND MOTION
PICTURE FILMS; BOOKS, BOOKLETS, PAMPHLETS, PRINTED GUIDES, COMIC BOOKS
AND MAGAZINES ON THE SUBJECT OF MUSIC, MUSICIANS, CARICATURES, ANIMA-
TION, CARTOONS, FICTION AND MOTION PICTURE FILMS; COMIC BOOKS; GENERAL
FEATURE MAGAZINES; CHILDREN'S ACTIVITY BOOKS; SCRAPBOOK ALBUMS;
CROSSWORD PUZZLE BOOKS; EDUCATIONAL ACTIVITY BOOKS ON THE SUBJECT
OF MUSIC; WRITING PAPER; ENVELOPES; SMALL NOTE PADS; TRADING CARDS;
PICTURES; ART PRINTS AND FRAMED ART PRINTS; FRAMED AND UNFRAMED
PICTORIAL PRINTS, CARTOON PRINTS, LITHOGRAPHIC PRINTS, COLOR PRINTS, CA-
RICATURE PRINTS, COMPUTER GENERATED PICTORIAL PRINTS, AND BLACK AND
WHITE, AND COLOR PRINTS FEATURING HIDDEN OR THREE DIMENSIONAL IMAGES;
GRAPHIC ART ETCHINGS; CARDBOARD GIFT BOXES; PAPER GIFT WRAP; MEMO PADS;
STATIONERY PAPER; BOOK COVERS; FIGURINES OF PAPER, CARDBOARD OR PAPER
MACHE; PARTY DECORATIONS OF PAPER, CARDBOARD OR PAPER MACHE FOR
CHRISTMAS USE; KITS COMPOSED OF PAPER OR CARDBOARD FOR MAKING PAPER
FIGURINES; COLLECTABLE NON-POSTAGE COMMEMORATIVE STAMPS; RUBBER
STAMPS; PROTECTIVE COVERS FOR BOOKS AND PERSONAL ORGANIZERS FOR
STATIONERY USE; TELEPHONE DIRECTORIES; PAPER DESK MATS; PEN AND PENCIL
CASES; PEN AND PENCIL BOXES; PEN AND PENCIL HOLDERS; DRAWING RULERS;
ERASERS; PRINTED PAPER EMBROIDERY DESIGN PATTERNS; SEWING PATTERNS
FOR MAKING CLOTHES, KNITTING PATTERNS; IRON-ON TRANSFERS FOR DECORAT-
ING TEXTILES; PRINTED WALL CHARTS; PAPERWEIGHTS, NOT OF PRECIOUS METAL;
BABIES' BIBS OF PAPER; BOOKMARKS; PASSPORT HOLDERS ALL MADE FROM
LEATHER OR IMITATION LEATHER; PENCIL CASES, NOTELETS AND AUTOGRAPH
BOOKS; REUSABLE TEXTILE LUNCH BAGS; REUSABLE PLASTIC SHOPPING BAGS, IN
CLASS 16 (U.S. CLS. 2, 5, 22, 23, 29, 37, 38 AND 50).
FOR: GOODS MADE FROM LEATHER OR IMITATION LEATHER, NAMELY, WAIST

POUCHES FOR CARRYING PURSES AND WALLETS; LUGGAGE, CARRY ON TRAVELING
BAGS, CLUTCH BAGS, TRUNKS, BUSINESS CARD CASES, RUCKSACKS, BACKPACKS,
PURSES, WALLETS, KEY CASES, LUGGAGE TAGS; BILLFOLDS, LEATHER KEY FOBS,
KEY CASES, UMBRELLAS; BAGS, NAMELY, HANDBAGS, SHOULDER BAGS, ALL
PURPOSE SPORTS BAGS, BARREL BAGS, CARRY-ON FLIGHT BAGS AND DUFFEL BAGS,
SUITCASES, ATTACHE CASES, SCHOOL BAGS, SATCHELS, GYM BAGS, BEACH BAGS
AND CREDIT CARD CASES; HAND CARRY OVERNIGHT CASES OF METAL, PLASTIC
OR RESIN; TOTE BAGS, INCLUDING METAL TOTES; TEXTILE SHOPPING BAGS; IDEN-
TITY CARD HOLDERS OF LEATHERAND IMITATIONS OF LEATHER, IN CLASS 18 (U.S.
CLS. 1, 2, 3, 22AND 41).
FOR: FRAMES FOR PHOTOGRAPHIC SLIDE TRANSPARENCIES; PICTURE FRAMES AND

PHOTOGRAPH FRAMES MADE OF, OR COATED WITH, PRECIOUS METAL OR PRECIOUS
STONE; NON-METAL TRAIN AND BUS TRAVEL TICKET HOLDERS OF LEATHER AND
IMITATIONLEATHER;PORCELAINDOORKNOBS;EARTHENWAREDOORKNOBS;WALL
PLAQUES OF PLASTIC AND WOOD; WIND CHIMES; MONEY BOXES NOT OF METAL;
WOOD, PLASTIC OR RESIN CONTAINERS FOR COMMERCIAL USE; FURNITURE; FUR-
NITURE MIRRORS, NAMELY, MIRRORS FOR HANGING, PROP-UP MIRRORS AND FULL-
LENGTH MIRRORS; HAND-HELD MIRRORS, INCLUDING SHAVING MIRRORS AND
POCKET MIRRORS; MIRROR TILES; PICTURE FRAMES; PHOTOGRAPH FRAMES;
CUSHIONS; PILLOWS; ORNAMENTS, STATUETTES, FIGURINES, TRINKET BOXES AND
LAMPS BASES MADE FROM PLASTIC, WOOD, WAX, RESIN, CORK, REED, CANE,
WICKER, HORN, IVORY, WHALEBONE, SHELL, AMBER, MOTHER-OF-PEARL, MEER-
SCHAUM AND SUBSTITUTES FOR THESE MATERIALS; PLAQUES OF BONE, IVORY,
PLASTIC, RESIN, WAX AND WOOD; STORAGE RACKS; KEY RINGS, KEY FOBS AND
KEY CHAINS, NOT OF METAL; WOOD BOXES; SIGNBOARDS MADE OF WOOD, PLASTIC
OR RESIN; NAME PLATES NOT OF METAL; NON-METAL KEY HOLDERS; BOTTLE
Page: 4 I RN# 4,373,956

Reg. No. 4 373 956 cLosuREsNmoFMETAL;coATHooKsNmoFMETAL;INDooRBLINDsoFwooD,

' ' REED, BAMBOO, BEADS OR PLASTIC; NON-ELECTRIC FANS FOR PERSONAL USE; FIRE
SCREENS FOR DOMESTIC USE; FOOTSTOOLS; INFLATABLE FURNITURE; INFLATABLE
CHAIRS; LETTER BOXES NOT OF METAL; INTERIOR WINDOW BLINDS OF TEXTILE;
DISPLAY BOARDS, IN CLASS 20 (U.S. CLS. 2, 13, 22, 25, 32 AND 50).
FOR: LEATHER OR IMITATION LEATHER COASTERS; ARTICLES OF PRECIOUS METAL

AND THEIR ALLOYS, AND ARTICLES COATED WITH PRECIOUS METAL AND THEIR
ALLOYS, NAMELY, SERVING TRAYS; DECORATIVE PLATES AND DISHES, COMMEM-
ORATIVE PLATES, GOBLETS, AND NAPKIN RINGS; DRINKING STRAWS; ALL PURPOSE
PORTABLE HOUSEHOLD CONTAINERS MADE OF WOOD, PLASTIC OR RESIN; NON-
METAL HOUSEHOLD OR KITCHEN CONTAINERS; SMALL DOMESTIC CONTAINERS,
NAMELY, ALL PURPOSE PORTABLE HOUSEHOLD CONTAINERS; CLEANING COMBS
AND SCOURING SPONGES; DUSTING BRUSHES; BEVERAGE GLASSWARE; PORCELAIN
EGGS AND SCULPTURES; EARTHENWARE FIGURINES, MUGS, SCULPTURES, AND
STATUES; ORNAMENTS, EXCEPT CHRISTMAS ORNAMENTS, STATUETTES AND FIG-
URINES OF CERAMIC, CHINA, CRYSTAL, GLASS, EARTHENWARE AND PORCELAIN;
PLATES; ORNAMENTAL AND COMMEMORATIVE PLATES; WALL PLAQUES OF CHINA,
CRYSTAL, EARTHENWARE, GLASS, PORCELAIN, AND TERRA COTTA; DRINKING
VESSELS, NAMELY, GLASSES, MUGS, JUGS, AND TANKARDS NOT OF PRECIOUS
METAL; BOTTLES, NAMELY, SELTZER BOTTLES FOR USE AS BARWARE, SPORT
BOTTLES SOLD EMPTY, AND VACUUM BOTTLES; INSULATED BOTTLES, NAMELY,
THERMAL INSULATED BOTTLES AND FLASKS FOR BEVERAGES; GLASS BELL JARS
USED TO DISPLAY FRAGILE ORNAMENTAL OBJECTS; GLASS BELL JARS FOR ORNA-
MENTAL PURPOSES; PLASTIC BELL JARS USED TO DISPLAY FRAGILE OBJECTS;
PLASTIC BELL JARS FOR ORNAMENTAL PURPOSES; NON-METAL JARS FOR JAMS
AND JELLIES MADE FROM EARTHENWARE, GLASS, PORCELAIN AND PLASTIC;
COOKIE JARS; COASTERS OTHER THAN OF PAPER OR OF TABLE LINEN; SERVING
TRAYS NOT OF PRECIOUS METAL; HAIR COMBS; HAIR BRUSHES; SPONGES FOR
HOUSEHOLD PURPOSES; ORNAMENTS, EXCEPT CHRISTMAS TREE ORNAMENTS,
STATUETTES AND FIGURINES ALL OF TERRA COTTA; DRINKING GOBLETS, NOT OF
PRECIOUS METAL; DRINKING GLASSES; STEMMED DRINKING GLASSES; CHAMPAGNE
GLASSES; BOTTLES, SOLD EMPTY; BOTTLE OPENERS; CORK SCREWS; HOUSEHOLD
FOOD STORAGE JARS AND FOOD STORAGE CONTAINERS MADE OF PLASTIC, GLASS,
EARTHENWARE, TERRA COTTA OR PORCELAIN; GLASS BELL JARS FOR COVERING
ORNAMENTS AND FOODS; EGG CUPS; LUNCH BOXES; COOKERY MOLDS; CAKE
MOLDS; ICE-CUBE MOLDS FOR REFRIGERATORS; SHAPED COOKIE CUTTERS; BREAD
BOARDS; BREAD BOXES; CANDLESTICKS NOT OF PRECIOUS METAL; SHAPED IRONING
BOARD COVERS; NAPKIN RINGS NOT OF PRECIOUS METAL; NAPKIN HOLDERS; SOAP
BOXES; SOAP DISHES; TOOTH BRUSH HOLDERS; TOOTH BRUSHES; GARBAGE CANS;
SMALL DOMESTIC CONTAINERS, NAMELY, PIGGY BANKS NOT OF METAL, FLOWER
POTS, SALT AND PEPPER SHAKERS, SALT AND PEPPER POTS NOT OF PRECIOUS
METAL, AND HAND OPERATED SALT AND PEPPER MILLS; NON-ELECTRIC TEA AND
COFFEE POTS NOT OF PRECIOUS METAL; TEA SETS OF CHINA, CERAMIC OR PORCEL-
AIN; TEA CUPS AND SAUCERS; DOMESTIC BOWLS; DISH AND POT STANDS MADE OF
CERAMIC TILES FOR HOT FOOD; COASTERS NOT OF PAPER AND OTHER THAN TABLE
LINEN, NAMELY, COASTERS MADE OF CERAMIC TILES FOR BEVERAGES; VASES OF
CHINA, CRYSTAL, GLASS AND PORCELAIN; PORCELAIN BOXES; TABLEWARE NOT
OF PRECIOUS METAL, NAMELY, SERVING DISHES, SERVING PLATES, CHARGERS IN
THE NATURE OF PLATTERS, SOUP TUREENS AND GRAVY BOATS; DECORATIVE
DISHES, PLATES AND CHARGERS IN THE NATURE OF PLATTERS; CERAMIC AND
PORCELAIN TRINKET BOXES; SALT AND PEPPER POTS OF PRECIOUS METAL; INDOOR
TERRARIUMS FOR PLANT CULTIVATION OR TERRESTRIAL ANIMALS, IN CLASS 21
(U.S. CLS. 2, 13, 23, 29, 30, 33, 40 AND 50).
FOR: DECORATIVE WINDOW CURTAINS OF WOOD, REED, BAMBOO, BEADS OR

PLASTIC; HOUSEHOLD LINEN; BED LINEN; BEDSPREADS; TABLE LINEN; TABLE
CLOTHS NOT OF PAPER; TABLE MATS NOT OF PAPER; TEXTILE TABLE NAPKINS;
Page: 5 I RN# 4,373,956

Reg. No. 4 373 956 COASTERS MADE OF TABLE LINEN OR TEXTILE; UNFITTED FABRIC FURNITURE
' ' COVERS; BED SHEETS, PILLOW CASES, DUVET COVERS; TOWELS; FACE TOWELS;
FACE WASHING CLOTHS; CURTAINS; WALL HANGING OF TEXTILE; CLOTH BANNERS;
CLOTH BUNTING; CLOTH FLAGS; HANDKERCHIEFS; CUSHION COVERS; PRE-CUT
TEXTILES FOR MAKING INTO CUSHIONS AND CUSHION COVERS; TRACED CLOTHS
FOR EMBROIDERY, IN CLASS 24 (U.S. CLS. 42 AND 50).
FOR: FOOTWEAR AND HEADGEAR, NAMELY, HATS AND CAPS; CLOTHING, NAMELY,
SHIRTS, POLO SHIRTS, T-SHIRTS, SWEATSHIRTS; SWEATPANTS; JACKETS, COATS;
PULLOVERS; VESTS; ARTICLES OF UNDERCLOTHING, NAMELY, UNDERWEAR;
SHORTS; SCARVES; SILK POCKET SQUARES; NECK-TIES; BRACES IN THE NATURE
OF SUSPENDERS; BELTS; SOCKS; LONG-SLEEVED SHIRTS AND LONG SLEEVED T-
SHIRTS; SILK SCARVES; SILK SCARVES IN THE SHAPE OF SQUARES FOR WEARING
OVER THE HEAD OR AROUND THE NECK; PANTS; FLEECE TOPS; THERMAL TOPS;
JERSEYS; BASEBALL JERSEYS; HOCKEY JERSEYS; SWEATERS; TANK TOPS; WAIST-
COATS; TROUSERS; GOLF SHIRTS; GOLF PANTS; GOLF SHOES; SWIM WEAR; BEACH-
WEAR; NIGHT GOWNS; PAJAMAS; DRESSING GOWNS; BATHROBES; BATHING CAPS;
HEAD BANDS; SLIPPERS; BEACH SHOES; SANDALS; CLOTHING FOR TODDLERS, IN-
FANTS AND BABIES, NAMELY, ROMPERS, SHORTALLS, BABIES' SLEEP SUITS; CLOTH
BABIES' BIBS, IN CLASS 25 (U.S. CLS. 22 AND 39).
FOR: CARPETS; RUGS; LINOLEUM FOR USE ON FLOORS; WALL HANGINGS NOT OF
TEXTILE; REED MATS; RUBBER AND PLASTIC BATH MATS; DOOR MATS; TEXTILE
FLOOR MATS FOR USE IN THE HOME, IN CLASS 27 (U.S. CLS. 19, 20, 37, 42 AND 50).
FOR: MUSICAL SNOW GLOBES; SNOW GLOBES; COMPUTER GAME JOYSTICKS; VIDEO
GAME MACHINES FOR USE WITH TELEVISIONS OR COMPUTERS; YO YOS; PLAYING
CARDS; PLAYING CARD CASES; TOY MODEL VEHICLES OF PAPER, CARDBOARD OR
PAPER MACHE; CHRISTMAS TREE DECORATIONS OF PAPER, CARDBOARD OR PAPER
MACHE; KITS COMPOSED OF PAPER, CARDBOARD OR PAPER MACHE FOR USE IN
MAKING TOY MODEL VEHICLES; INFLATABLE PUBLICITY OBJECTS, NAMELY, BAL-
LOONS; STAND ALONE VIDEO GAME MACHINES; COIN OR TOKEN OPERATED VIDEO
GAMES; COIN OR TOKEN OPERATED PINBALL MACHINES; COIN OR TOKEN OPERATED
ARCADE GAMES; COIN OR TOKEN OPERATED ELECTRICAL OR ELECTRONIC
AMUSEMENT GAME MACHINES IN THE NATURE OF QUIZ GAME MACHINES; VIRTUAL
REALITY DISPLAY APPARATUS, NAMELY, VIRTUAL REALITY HEADSETS, VIRTUAL
REALITY HELMETS AND VIRTUAL REALITY VISORS ADAPTED FOR USE IN PLAYING
VIDEO GAMES AND PROVIDING INTERACTIVE ENTERTAINMENT EXPERIENCES IN
THIS REGARD; VIRTUAL REALITY DISPLAY APPARATUS, NAMELY, ELECTRONIC
DISPLAY SCREENS FOR DISPLAYING IMAGES IN VIRTUAL REALITY SPECIALLY AD-
APTED FOR USE IN PLAYING VIDEO GAMES, AND PROVIDING INTERACTIVE ENTER-
TAINMENT EXPERIENCES AND VIRTUAL REALITY THEATER, ALL ENCLOSED
WITHIN AN ELECTRONICALLY ENABLED SPECIALLY ADAPTED BOOTH; VIRTUAL
REALITY DISPLAY APPARATUS, NAMELY, AMUSEMENT PARK RIDES AND RIDE-ON
TOYS, ALL OF WHICH DISPLAY IMAGES IN VIRTUAL REALITY; COIN OR TOKEN OP-
ERATED ELECTRICAL AMUSEMENT APPARATUS, NAMELY, VIRTUAL REALITY
HEADSETS, VIRTUAL REALITY HELMETS, VIRTUAL REALITY VISORS AND VIRTUAL
REALITY ELECTRONIC DISPLAY SCREENS ENCLOSED WITHIN AN ELECTRONICALLY
ENABLED SPECIALLY ADAPTED BOOTH, ALL SPECIALLY ADAPTED FOR USE IN
PLAYING VIDEO GAMES AND PROVIDING VIRTUAL REALITY THEATER OR INTER-
ACTIVE ENTERTAINMENT EXPERIENCES IN THIS REGARD FEATURING CARTOONS,
ANIMATION, VIRTUAL REALITY IMAGES, AND MUSIC; COIN OR TOKEN OPERATED
ELECTRICAL OR ELECTRONIC AMUSEMENT PARK RIDES AND RIDE-ON TOYS,
NAMELY, SIT-AND RIDE-ON MOTION SIMULATOR RIDE MACHINES WHICH SIMULATE
THE MOTION OF A VEHICLE, SHIP OR SUBMARINE; AMUSEMENT PARK RIDES AND
RIDE-ON TOYS, NAMELY, MOTION SIMULATORS FOR SIMULATING THE MOTION OF
A VEHICLE, SHIP OR SUBMARINE; RECREATIONAL FLOATS FOR SWIMMING;
AMUSEMENT PARK RIDES, NAMELY, MOTION SIMULATORS FOR ENTERTAINMENT
Page: 6 I RN# 4,373,956

Reg. No. 4 373 956 PURPOSESINTHENATUREOFVIRTUALREALITYAMUSEMENTPARKRIDES;MOTION

' ' SIMULATORS FOR ENTERTAINMENT PURPOSES IN THE NATURE OF AMUSEMENT
PARK RIDES AND RIDE-ON TOYS, ALL FOR SIMULATING THE MOTION OF A VEHICLE,
SHIP OR SUBMARINE;CRIB MOBILES OF PAPER OR CARDBOARD; VIDEO GAME MA-
CHINES FOR USE WITH EXTERNAL TELEVISION OR VIDEO DISPLAY SCREENS;
AMUSEMENT APPARATUS INCORPORATING A VIDEO MONITOR FOR INTERACTIVE
VIDEO GAMES OF VIRTUAL REALITY; AN APPARATUS FOR ELECTRONIC GAMES
OTHER THAN THOSE ADAPTED FOR USE WITH AN EXTERNAL DISPLAY SCREEN OR
MONITOR, NAMELY, AN APPARATUS FOR INTERACTIVE VIDEO GAMES OF VIRTUAL
REALITY; COMPUTER GAME CONSOLES FOR USE WITH AN EXTERNAL DISPLAY
SCREEN OR MONITOR FOR INTERACTIVE VIDEO GAMES OF VIRTUAL REALITY, IN
CLASS 28 (U.S. CLS. 22, 23, 38 AND 50).
FOR: SMOKER'S ARTICLES, NAMELY, ASHTRAYS NOT OF PRECIOUS METAL, LIGHTERS

FOR SMOKERS NOT OF PRECIOUS METAL, INCLUDING CIGARETTE, CI GARAND PIPE
LIGHTERS, AND CIGARETTE AND CIGAR CASES NOT OF PRECIOUS METAL, IN CLASS
34 (U.S. CLS. 2, 8, 9 AND 17).
FOR: ENTERTAINMENT, NAMELY, PROVISION OF INFORMATION RELATING TO MO-

TION PICTURES AND MUSIC, LIVE ENTERTAINMENT IN THE NATURE OF MUSICAL
SHOWS, MUSICAL ROAD SHOWS, MUSICAL CONCERT PERFORMANCES, ORCHESTRA
PERFORMANCES AND THEATRICAL STAGE PLAYS; ENTERTAINMENT, NAMELY, LIVE
PERFORMANCES BY A MUSICAL BAND; ENTERTAINMENT IN THE NATURE OF
THEATRE PRODUCTIONS; ENTERTAINMENT, NAMELY, PRESENTATION OF LIVE
VIRTUAL REALITY SHOWS FEATURING MUSIC; ENTERTAINMENT IN THE NATURE
OF LASER SHOWS AND LIGHT SHOWS; ENTERTAINMENT, NAMELY, AMUSEMENT
PARK RIDES; ENTERTAINMENT, NAMELY, PROVIDING VIRTUAL REALITY AMUSE-
MENT PARK AND ARCADE RIDES; ENTERTAINMENT, NAMELY, RENTAL OF ELEC-
TRONIC, COMPUTER AND VIDEO GAME EQUIPMENT; PROVIDING FACILITIES FOR
RECREATIONAL ACTIVITIES, NAMELY, FACILITIES FOR RIDING HYDRAULICALLY,
MECHANICALLY OR ELECTRICALLY OPERATED AMUSEMENT PARK AND ARCADE
RIDES THAT SIMULATE THE MOTION OF A VEHICLE, SHIP OR SUBMARINE; ENTER-
TAINMENT IN THE NATURE OF RENTAL OF VIDEO EQUIPMENT FOR DISPLAYING
IMAGES OF VIRTUAL REALITY; PROVIDING FACILITIES FOR RECREATIONAL
ACTIVITIES FOR USE BY THE PUBLIC, NAMELY, FOR DISPLAYING IMAGES OF VIRTUAL
REALITYVIA ELECTRONIC, COMPUTER, VIDEO GAMEAND OTHER VIDEO EQUIPMENT
FOR ENTERTAINMENT PURPOSES; ENTERTAINMENT SERVICES, NAMELY, DISPLAYING
IMAGES OF VIRTUAL REALITY TO THE PUBLIC VIA ELECTRONIC, COMPUTER, VIDEO
GAME AND OTHER VIDEO EQUIPMENT; ENTERTAINMENT, NAMELY, DISPLAYING
VIRTUAL REALITY IMAGES OF MUSICAL PERFORMANCES, ANIMATION AND MOTION
PICTURE FILMS VIA VIDEO EQUIPMENT; ENTERTAINMENT IN THE NATURE OF DIS-
PLAYING VIRTUAL REALITY IMAGES OF SHOWS VIA TELEVISION SETS, MOTION
PICTURE PROJECTION SCREENS, ELECTRONIC DISPLAY EQUIPMENT, VIDEO EQUIP-
MENT, COMPUTER IMAGE GENERATION EQUIPMENT; ENTERTAINMENT AND EDU-
CATION IN THE NATURE OF ON-GOING TELEVISION AND RADIO PROGRAMS IN THE
FIELD OF MUSIC, MUSICIANS, MOTION PICTURES, ANIMATION, CARICATURES AND
CARTOONS; INTERACTIVE ENTERTAINMENT, NAMELY, PROVIDING AN ON-LINE
INTERACTIVE COMPUTER GAME; PRODUCTION AND DISTRIBUTION OF RADIO AND
TELEVISION PROGRAMS AND MOTION PICTURE FILMS; PRODUCTION OF AUDIO-
VISUAL CONTENT FOR INTERACTIVE COMPACT DISCS AND CD-ROMS; ENTERTAIN-
MENT SERVICES, NAMELY, PLANNING AND CONDUCTING A SERIES OF MUSIC AND
FILM FESTIVALS; CONDUCTING ENTERTAINMENT EXHIBITIONS FEATURING MUSIC
MEMORABILIA; RENTAL OF MOTION PICTURE FILMS, SOUND RECORDINGS, AND
MUSIC RECORDINGS ON INTERACTIVE COMPACT DISCS AND CD-ROMS; RENTAL OF
VIDEOTAPE RECORDINGS TO OTHERS FOR PUBLIC EXHIBITION; AMUSEMENT ARCADE
SERVICES; AMUSEMENT PARK SERVICES; PRESENTATION OF LIVE AND PRE-RECOR-
DED SHOWS IN THE NATURE OF MUSIC SHOWS, ANIMATED FILM, AND VIRTUAL
REALITY SHOWS IN URBAN ENVIRONMENTS FOR OTHERS; ENTERTAINMENT IN THE
Page: 7 I RN# 4,373,956

Reg. No. 4 373 956 NATURE OF CIRCUSES; THEME PARK SERVICES, NAMELY, PROVISION OF LIVE MU-
' ' SI CAL SHOWS AND AMUSEMENT RIDES RELATING TO MUSIC, MUSICIANS, MOTION
PICTURES, ANIMATION, CARICATURES AND CARTOONS; ORGANIZING AND CON-
DUCTING COMPETITIONS IN THE NATURE OF QUIZ SHOWS AND ONLINE QUIZ
COMPETITIONS IN THE FIELD OF MOTION PICTURE FILMS, MUSIC, MUSICIANS AND
ENTERTAINERS; CINEMA SERVICES, NAMELY, RENTAL OF CINEMA FILMS, CINEMA
PROJECTION APPARATUS AND ACCESSORIES; CINEMA THEATRES, INCLUDING MO-
BILE CINEMA THEATRES; DISCOTHEQUE SERVICES; ORGANIZING AND CONDUCTING
ENTERTAINMENT EXHIBITIONS INTHEFIELD OF MUSIC, INCLUDING PRE-RECORDED
MUSIC; ENTERTAINMENT, NAMELY, QUIZ SHOWS AND COMPETITIONS IN THE FIELD
OF MUSIC AND MOTION PICTURE FILMS; ENTERTAINMENT, NAMELY, PROVIDING
A WEBSITE VIA A COMPUTER GLOBAL NETWORK FEATURING NON-DOWNLOADABLE
MUSIC-BASED QUIZZES, MUSIC-BASED COMPETITIONS, PUZZLES, ARCADE-STYLE
GAMES, VIDEO AND SOUND CLIPS, ANIMATION, INTERACTIVE ENTERTAINMENT
FEATURING MUSIC AND IMAGES, MUSIC-BASED ROLE PLAYING GAMES, ENTERTAIN-
MENT INFORMATION, PHOTOGRAPHS, AND PERSONAL DIGITAL POSTCARDS IN THE
FIELDS OF MUSIC AND MUSICAL ENTERTAINMENT, IN CLASS 41 (U.S. CLS. 100, 101
AND 107).
FOR: PROVIDING ON-LINE, NON-DOWNLOADABLE COMPUTER SOFTWARE FOR DIS-

PLAYING AND PLAYING MUSICAL SOUND AND VIDEO RECORDINGS, AND FOR
MANAGING ACCESS TO AND DOWNLOADING THE SAME VIA THE WORLD WIDE WEB;
PROVIDING ONLINE, NON-DOWNLOADABLE COMPUTER SOFTWARE FOR GENERATING
INTERACTIVE ENTERTAINMENT FEATURES ON AN ENTERTAINMENT WEBSITE IN
THE FIELD OF MUSICAL SOUND AND VIDEO RECORDINGS, IN CLASS 42 (U.S. CLS. 100
AND 101).
OWNER OF ERPN CMNTY TM OFC REG. NO. 000219048, DATED 1-26-1999, EXPIRES 4-
1-2016.
SER. NO. 75-921,156, FILED 2-16-2000.
ZHALEH DELANEY, EXAMINING ATTORNEY
Page: 8 I RN# 4,373,956

REQUIREMENTS TO MAINTAIN YOUR FEDERAL

TRADEMARK REGISTRATION
WARNING: YOUR REGISTRATION WILL BE CANCELLED IF YOU DO NOT FILE THE

DOCUMENTS BELOW DURING THE SPECIFIED TIME PERIODS.
Requirements in the First Ten Years*

What and When to File:
First Filing Deadline: You must file a Declaration of Use (or Excusable Nonuse) between the
5th and 6th years after the registration date. See 15 U.S.C. §§1058, l 14lk. If the declaration is
accepted, the registration will continue in force for the remainder of the ten-year period, calculated
from the registration date, unless cancelled by an order of the Commissioner for Trademarks or a
federal court.
Second Filing Deadline: You must file a Declaration of Use (or Excusable Nonuse) and an
Application for Renewal between the 9th and 10th years after the registration date.*
See 15 U.S.C. §1059.
Requirements in Successive Ten-Year Periods*

What and When to File:
You must file a Declaration ofU se (or Excusable Nonuse) and an Application for Renewal between
every 9th and 10th-year period, calculated from the registration date.*
Grace Period Filings*
The above documents will be accepted as timely if filed within six months after the deadlines listed above
with the payment of an additional fee.
The United States Patent and Trademark Office (USPTO) will NOT send you any future notice or
reminder of these filing requirements.
*ATTENTION MADRID PROTOCOL REGISTRANTS: The holder of an international registration with

an extension of protection to the United States under the Madrid Protocol must timely file the Declarations
of Use (or Excusable Nonuse) referenced above directly with the USPTO. The time periods for filing are
based on the U.S. registration date (not the international registration date). The deadlines and grace periods
for the Declarations of Use (or Excusable Nonuse) are identical to those for nationally issued registrations.
See 15 U .S.C. §§ 1058, 114 lk. However, owners of international registrations do not file renewal applications
at the USPTO. Instead, the holder must file a renewal of the underlying international registration at the
International Bureau of the World Intellectual Property Organization, under Article 7 of the Madrid Protocol,
before the expiration of each ten-year term of protection, calculated from the date of the international
registration. See 15 U.S. C. § 1141j. For more information and renewal forms for the international registration,
see http://www.wipo.int/madrid/en/.
NOTE: Fees and requirements for maintaining registrations are subject to change. Please check the
USPTO website for further information. With the exception of renewal applications for registered
extensions of protection, you can file the registration maintenance documents referenced above online
at http ://www.uspto.gov.
Page: 9 I RN# 4,373,956

Composite Exhibit 2
Case 0:18-cv-60221-RNS Document
O JS 44 (R ev. 2/08) CIVIL1-3 Entered
COVER on FLSD Docket 02/01/2018 Page 1 of 2
SHEET
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as provided
by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the purpose of initiating
the civil docket sheet. (SEE IN STR U C TIO N S O N THE R EV ER SE O F T HE FO R M .) NOTICE: Attorneys MUST Indicate All Re-filed Cases Below.
I. (a) PLAINTIFFS DEFENDANTS
APPLE CORPS LIMITED and SUBAFILMS LIMITED SHIRTSFORYOU.NET, et al.
(b) County of Residence of First Listed Plaintiff
County of Residence of First Listed Defendant
(EX C EPT IN U .S. PLAIN TIFF C ASES) (IN U .S. PLAIN TIFF C ASES O N LY )
(c) Attorney’s (Firm N ame, Address, and Telephone N umber) N O TE: IN LAN D C O N D EM N ATIO N C ASES, U SE THE LO C ATIO N O F THE TR AC T
LAN D IN V O LV ED .
Stephen M. Gaffigan/STEPHEN M. GAFFIGAN, P.A.
401 East Las Olas Blvd., Suite 130-453, Ft. Lauderdale, Florida 33301 Attorneys (If Know n)
(954) 767-4819
(d) Check County Where Action Arose: M IAM I- D AD E MONROE ✔

BR O W AR D PALM BEA CH M AR TIN ST. LU C IE IN D IAN R IV ER O KEEC HO BEE
HIG HLAN D S
II. BASIS OF JURISDICTION (Place an “ X ” in O ne Box O nly) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X ” in O ne Box for Plaintiff
(For D iversity C ases O nly) and O ne Box for D efendant)
1 U .S. G overnment ✔ 3 Federal Q uestion PTF DEF PTF DEF
Plaintiff (U .S. G overnment N ot a Party) C itizen of This State 1 1 Incorporated or Principal Place 4 4
of Business In This State
2 U .S. G overnment 4 D iversity C itizen of Another State 2 2 Incorporated and Principal Place 5 5
D efendant of Business In A nother State
(Indicate C itizenship of Parties in Item III)
C itizen or Subject of a 3 3 Foreign N ation 6 6

Foreign C ountry
IV. NATURE OF SUIT (Place an “X ” in O ne B ox O nly)
CONTRACT TORTS F O R FE IT U R E /P E N A L T Y B A N K R U PT C Y O T H E R ST A T U T E S
110 Insurance P E R SO N A L IN JU R Y P E R SO N A L IN JU R Y 610 Agriculture 422 Appeal 28 U SC 158 400 State R eapportionment
120 M arine 310 Airplane 362 Personal Injury - 620 O ther Food & D rug 423 W ithdraw al 410 Antitrust
130 M iller Act 315 Airplane Product M ed. M alpractice 625 D rug R elated Seizure 28 U SC 157 430 Banks and Banking
140 N egotiable Instrument Liability 365 Personal Injury - of Property 21 U SC 881 450 C ommerce
150 R ecovery of O verpayment 320 Assault, Libel & Product Liability 630 Liquor Law s P R O PE R T Y R IG H T S 460 D eportation
& Enforcement of Judgment Slander 368 Asbestos Personal 640 R .R . & Truck 820 C opyrights 470 R acketeer Influenced and
151 M edicare Act 330 Federal Employers’ Injury P roduct 650 Airline R egs. 830 Patent C orrupt O rganizations
152 R ecovery of D efaulted Liability Liability 660 O ccupational ✘
840 Trademark 480 C onsumer C redit
Student Loans 340 M arine P E R SO N A L P R O P E R T Y Safety/Health 490 Cable/Sat TV
(Excl. V eterans) 345 M arine Product 370 O ther Fraud 690 O ther 810 Selective Service
153 R ecovery of O verpayment Liability 371 Truth in Lending LABOR SO C IA L SE C U R IT Y 850 Securities/C ommodities/
of V eteran’s Benefits 350 M otor V ehicle 380 O ther Personal 710 Fair Labor Standards 861 HIA (1395ff) Exchange
160 Stockholders’ Suits 355 M otor V ehicle Property D amage Act 862 Black Lung (923) 875 C ustomer C hallenge
190 O ther C ontract Product Liability 385 Property D amage 720 Labor/M gmt. R elations 863 D IW C /D IW W (405(g)) 12 U SC 3410
195 C ontract Product Liability 360 O ther Personal Product Liability 730 Labor/M gmt.R eporting 864 SSID Title X V I 890 O ther Statutory Actions
196 Franchise Injury & D isclosure Act 865 R SI (405(g)) 891 Agricultural Acts
R E A L P R O PE R T Y C IV IL R IG H T S P R ISO N E R P E T IT IO N S 740 R ailw ay Labor Act F E D E R A L T A X SU IT S 892 Economic Stabilization Act
210 Land C ondemnation 441 V oting 510 M otions to V acate 790 O ther Labor Litigation 870 Taxes (U .S. Plaintiff 893 Environmental M atters
220 Foreclosure 442 Employment Sentence 791 E m pl. R et. Inc . Security or D efendant) 894 Energy Allocation Act
230 R ent Lease & Ejectment 443 Housing/ H abeas C orpus: Act 871 IRS— Third Party
895 Freedom of Information Act
240 Torts to Land Accommodations 530 G eneral 26 U SC 7609
245 Tort Product Liability 444 W elfare 535 D eath Penalty IM M IG R A T IO N 900 Appeal of Fee D etermination
445 Amer. w /D isabilities - 462 N aturalization U nder Equal Access to Justice
290 All O ther R eal Property 540 M andamus & O ther
Employment Application
446 Amer. w /D isabilities - 463 Habeas C orpus-Alien
550 C ivil R ights
O ther D etainee
465 O ther Immigration 950 C onstitutionality of State
440 O ther C ivil R ights 555 Prison C ondition
Actions Statutes
V. ORIGIN (Place an “X ” in O ne B ox O nly) Appeal to District

Transferred from
✔
1 Original 2 Removed from 3 Re-filed- 4 Reinstated or 5 another district 6 Multidistrict 7 Judge from
Magistrate
Proceeding State Court (see VI below) Reopened (specify) Litigation
Judgment
a) Re-filed Case YES ✔
NO b) Related Cases YES
✔ NO
VI. RELATED/RE-FILED (See instructions
CASE(S). second page): JUDGE DOCKET NUMBER
Cite the U.S. Civil Statute under which you are filing and Write a Brief Statement of Cause (Do not cite jurisdictional statutes unless
diversity):
VII. CAUSE OF ACTION Trademark infringement and counterfeiting pursuant to 15 USC 1114
LENGTH OF TRIAL via ______

5 days estimated (for both sides to try entire case)
VIII. REQUESTED IN CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint:
COM PLAINT: UNDER F.R.C.P. 23 JURY DEMAND: Yes ✔ No
ABOVE INFORMATION IS TRUE & CORRECT TO SIG N ATU R E O F ATTO R N EY O F R EC O R D D ATE
THE BEST OF MY KNOWLEDGE
February 1, 2018
F O R O F F IC E U SE O N L Y
AM O U N T R EC EIPT # IFP
JS 44 R everse (R ev. 02/08)
INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44
Authority For Civil Cover Sheet

The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as required
by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use
of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of Court for each civil complaint
filed. The attorney filing a case should complete the form as follows:
I. (a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use only
the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and then the official, giving
both name and title.
(b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the time
of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land condemnation cases,
the county of residence of the “defendant” is the location of the tract of land involved.)
(c) Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, noting
in this section “(see attachment)”.
(d) Choose one County where Action Arose.
II. Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.C.P., which requires that jurisdictions be shown in pleadings. Place an “X” in one
of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.
United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.
United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an “X” in this box.
Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment to the
Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes precedence, and box
1 or 2 should be marked.
Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the citizenship of the
different parties must be checked. (See Section III below; federal question actions take precedence over diversity cases.)
III. Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark this section
for each principal party.
IV. Nature of Suit. Place an “X” in the appropriate box. If the nature of suit cannot be determined, be sure the cause of action, in Section VI below, is sufficient
to enable the deputy clerk or the statistical clerks in the Administrative Office to determine the nature of suit. If the cause fits more than one nature of suit, select
the most definitive.
V. Origin. Place an “X” in one of the seven boxes.
Original Proceedings. (1) Cases which originate in the United States District Courts.
Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441. When the petition
for removal is granted, check this box.
Refiled (3) Attach copy of Order for Dismissal of Previous case. Also complete VI.
Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date.
Transferred from Another District. (5) For cases transferred under Title 28 U.S.C. Section 1404(a). Do not use this for within district transfers or multidistrict
litigation transfers.
Multidistrict Litigation. (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C. Section 1407. When this box
is checked, do not check (5) above.
Appeal to District Judge from Magistrate Judgment. (7) Check this box for an appeal from a magistrate judge’s decision.
VI. Related/Refiled Cases. This section of the JS 44 is used to reference related pending cases or re-filed cases. Insert the docket numbers and the corresponding
judges name for such cases.
VII. Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. Do not cite jurisdictional statutes
unless diversity. Example: U.S. Civil Statute: 47 USC 553
Brief Description: Unauthorized reception of cable service
VIII. Requested in Complaint. Class Action. Place an “X” in this box if you are filing a class action under Rule 23, F.R.Cv.P.
Demand. In this space enter the dollar amount (in thousands of dollars) being demanded or indicate other demand such as a preliminary injunction.
Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.
Date and Attorney Signature. Date and sign the civil cover sheet.

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Case 0:18-cv-60221-RNS Document 1 Entered on FLSD Docket 02/01/2018 Page 1 of 31

UNITED STATES DISTRICT COURT

APPLE CORPS LIMITED and SUBAFILMS

SHIRTSFORYOU.NET, B..F STORE, GOOD

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF

Plaintiffs, APPLE CORPS LIMITED and SUBAFILMS LIMITED (“Plaintiffs”) hereby

IDs”). In support of their claims, Plaintiffs allege as follows:

JURISDICTION AND VENUE

1. This is an action for federal trademark counterfeiting and infringement, false

Subject Domain Name and Seller IDs.

4. Plaintiff, Apple Corps Limited (“Apple Corps”) is an incorporated limited company

5. Plaintiff, Subafilms Limited (“Subafilms”) is an associated company of Apple

called “Yellow Submarine.”

6. Plaintiffs are engaged in the development, manufacture, promotion, distribution,

9. In order to combat the indivisible harm caused by the combined actions of

Defendants, Plaintiffs expend significant resources in connection with trademark enforcement

Internet based marketplace websites, AliEpress.com, Amazon.com, Bonanza.com, eBay.com, and

Etsy.com, under the Seller IDs.

Number on Schedule “A” hereto.

bearing counterfeits and infringements of Plaintiffs’ individual trademarks as described herein

using at least the Subject Domain Name and Seller IDs.

purpose of engaging in illegal counterfeiting activities.

bearing counterfeit and confusingly similar imitations of Plaintiffs’ trademarks unless

preliminarily and permanently enjoined.

COMMON FACTUAL ALLEGATIONS

Apple Corp’s Business and Trademark Rights

BEATLES Marks are attached hereto as Composite Exhibit “1.”

enormous goodwill and have never been abandoned.

term is used in 15 U.S.C. §1125(c)(1).

as identifiers of quality goods.

goods sold thereunder.

Subafilms’ Trademark Rights

counterfeits of the YELLOW SUBMARINE Mark.

29. The YELLOW SUBMARINE Mark is a symbol of Subafilms’ quality, reputation

and enormous goodwill and has never been abandoned.

mark as that term is used in 15 U.S.C. §1125(c)(1).

experienced substantial sales of its high quality goods.

merchandise sponsored and approved by Subafilms.

meaning as an identifier of high quality goods.

of the Defendants in this matter.

goods sold thereunder.

Defendants’ Infringing Activities

using counterfeit and confusingly similar imitations of Plaintiffs’ merchandise.

37. Defendants’ Counterfeit Goods are of a quality substantially and materially

and approved by Plaintiffs.

form of Plaintiffs’ Marks is the proximate cause of damage to Plaintiffs.

associated with Plaintiffs’ Marks.

consuming public for Defendants’ own benefit.

Plaintiffs’ consent or authorization.

43. Defendants are engaging in the above-described illegal counterfeiting and

which there is not.

used and/or controlled by them.

their assets to avoid payment of any monetary judgment awarded to Plaintiffs.

47. Plaintiffs have no adequate remedy at law.

sale of their Counterfeit Goods.

COUNT I - TRADEMARK COUNTERFEITING AND INFRINGEMENT

of the Counterfeit Goods.

them to advertise, promote and sell counterfeit and infringing goods.

55. Defendants’ above-described illegal actions constitute counterfeiting and

infringement of Plaintiffs’ Marks in violation of Plaintiffs’ respective rights under § 32 of the

Lanham Act, 15 U.S.C. § 1114.

COUNT II - FALSE DESIGNATION OF ORIGIN

representations, all to Plaintiffs’ detriment.