UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 22-61695-CIV-SINGHAL/VALLE

ADIDAS AG, et al.,

Plaintiffs,
vs.

THE INDIVIDUALS, BUSINESS ENTITIES,

AND UNINCORPORATED ASSOCIATIONS
IDENTIFIED ON SCHEDULE “A,”

Defendants.
/

PLAINTIFFS’ EX PARTE APPLICATION FOR

ENTRY OF TEMPORARY RESTRAINING ORDER,
PRELIMINARY INJUNCTION, AND ORDER
RESTRAINING TRANSFER OF ASSETS AND
MEMORANDUM OF LAW IN SUPPORT THEREOF

Stephen M. Gaffigan, P.A.

401 East Las Olas Blvd., Suite 130-453
Ft. Lauderdale, Florida 33301
Telephone: (954) 767-4819
 Plaintiffs, adidas AG, adidas International Marketing B.V., and adidas America, Inc.

(“Plaintiffs”), hereby do apply, on an ex parte basis, for entry of a temporary restraining order and

an order restraining transfer of assets, and upon expiration of the temporary restraining order, a

preliminary injunction against Defendants, the Individuals, Business Entities, and Unincorporated

Associations identified on Schedule “A” hereto (“Defendants”) pursuant to 15 U.S.C. § 1116, Fed.

R. Civ. P. 65, The All Writs Act, 28 U.S.C. § 1651(a), and the Court’s inherent authority. In support

thereof, Plaintiffs submit the following memorandum of law.

I. INTRODUCTION

Defendants are knowingly and intentionally promoting, advertising, distributing, offering

for sale, and selling goods bearing and/or using counterfeits of Plaintiffs’ registered trademarks

within this district and throughout the United States (the “U.S.”) by operating fully interactive,

commercial Internet websites under the domain names identified on Schedule “A” hereto (the

“Subject Domain Names”). Plaintiffs obtained evidence clearly demonstrating that Defendants (a)

are engaged in the advertising, offering for sale, and sale of counterfeit and infringing versions of

Plaintiffs’ goods; and (b) accomplish their sales of counterfeit and infringing goods via the Internet

using, at least, the Subject Domain Names. Plaintiffs’ Complaint thus alleges claims for trademark

counterfeiting and infringement, false designation of origin, cybersquatting, common law unfair

competition, and common law trademark infringement.

Defendants’ unlawful activities deprive Plaintiffs of their rights to determine the way their

trademarks are presented to the public. Indeed, Defendants have and continue to wrongfully trade

and capitalize on Plaintiffs’ reputation and goodwill and the commercial value of Plaintiffs’

trademarks. Defendants are defrauding Plaintiffs and consumers for their own benefit. Defendants

should not be permitted to continue their unlawful activities, which are causing Plaintiffs ongoing

irreparable harm. Accordingly, Plaintiffs are seeking entry of a temporary restraining order
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prohibiting Defendants’ further wrongful use of Plaintiffs’ trademarks.

Plaintiffs also seek to restrain Defendants’ unlawful profits. Plaintiffs have obtained

evidence that Defendants use money transfer and retention services with PayPal, Inc. (“PayPal”)

in connection with the sale of their counterfeit products. The Lanham Act allows Plaintiffs to

recover the illegal profits gained through Defendants’ distribution and sales of counterfeit and

infringing goods. See 15 U.S.C. § 1117(a). Considering the inherently deceptive nature of the

counterfeiting business, Plaintiffs have good reason to believe Defendants will hide or transfer

their ill-gotten assets beyond the jurisdiction of this Court unless they are restrained. To preserve

that disgorgement remedy and all other equitable remedies available, Plaintiffs seek an ex parte

order restraining Defendants’ assets, including specifically, funds transmitted through PayPal.

II. STATEMENT OF FACTS

A. Plaintiffs’ Rights.

Plaintiffs’ own all rights in and to the federally registered trademarks listed in Paragraph 5

(the “adidas Marks”) of the Declaration of Mia Nidia Gutierrez in Support of Plaintiffs’

Application for TRO (“Gutierrez Decl.”), which are used in connection with the manufacture and

distribution of quality goods in the categories identified therein. (Gutierrez Decl. ¶¶ 4–5. The

adidas Marks are symbols of Plaintiffs’ quality, reputations, and goodwill and have never been

abandoned. (See Gutierrez Decl. ¶¶ 6–11.) Plaintiffs expend substantial resources developing,

advertising, and otherwise promoting the adidas Marks. (See id. ¶ 8.) Accordingly, the adidas

Marks are famous marks as the term is used in 15 U.S.C. § 1125(c)(1).

Furthermore, Plaintiffs extensively use, advertise, and promote the adidas Marks in the

U.S. in interstate commerce, and carefully monitor and police the use of their trademarks. (See id.

at ¶¶ 6–11.) As a result, members of the consuming public readily identify products sold under the

adidas Marks as being quality merchandise sponsored and approved by Plaintiffs, and the
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trademarks have achieved secondary meaning as identifiers of high-quality products. At all times

relevant hereto, Defendants have been aware of Plaintiffs’ (a) ownership of the adidas Marks; (b)

exclusive right to use the adidas Marks; and (c) substantial goodwill embodied in, and favorable

recognition for, the adidas Marks.

B. Defendants Wrongfully Use Plaintiffs’ Trademarks.

Defendants do not have, nor have they ever had, the right or authority to use the adidas

Marks for any purpose. (Gutierrez Decl. ¶¶ 13, 16.) Despite their known lack of authority to do so,

Defendants are concurrently promoting and otherwise advertising, distributing, selling and/or

offering for sale, through their Subject Domain Names, goods using counterfeit and infringing

trademarks that are exact copies of one or more of the adidas Marks, without authorization

(“Defendants’ Goods”). (Gutierrez Decl. ¶¶ 13–17; Declaration of Virgilio Gigante in Support of

Plaintiffs’ Application for TRO (“Gigante Decl.”) ¶ 2; Declaration of Kathleen Burns in Support

of Plaintiffs’ Application for TRO (“Burns Decl.”) ¶ 4; see also web page captures from

Defendants’ websites operating under the Subject Domain Names displaying Plaintiffs’ branded

items offered for sale attached as Comp. Ex. “1” to the Burns Decl.)

Given Defendants’ slavish copying of the adidas Marks, Defendants’ Goods offered for

sale and sold under identical marks are indistinguishable to consumers, both at the point of sale

and post-sale. By using the adidas Marks, Defendants have created a false association between

their counterfeit and infringing goods and websites and Plaintiffs in violation of 15 U.S.C. §

1125(a) and is causing and will continue to cause Plaintiffs irreparable harm. (Gutierrez Decl. ¶

24.) Additionally, Defendant Numbers 1–3’s registration of their domain names incorporating at

least one of the adidas Marks constitutes cybersquatting in violation of 15 U.S.C. § 1125(d).

Plaintiffs’ counsel retained Invisible Inc (“Invisible”), a licensed private investigation

firm, to investigate the promotion and sale of counterfeit versions of Plaintiffs’ branded products
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by Defendants and determine the available payment account data for receipt of funds paid to

Defendants for the sale of counterfeit versions of Plaintiffs’ branded merchandise. (Gutierrez Decl.

¶ 14; Gigante Decl. ¶ 2; Burns Decl. ¶ 3.) Invisible accessed the websites operating under

Defendants’ Subject Domain Names, placed an order from each website for the purchase of a

product using counterfeits of at least one of the adidas Marks, and requested the products be

shipped to addresses in the Southern District of Florida. (See Burns Decl. ¶ 4.) Each order was

processed entirely online, and following the submission of the orders, Invisible received

information for finalizing payment for the products ordered from Defendants to their respective

PayPal accounts identified on Schedule “A.” 1 (Id. and Comp. Ex. 1 thereto.) The detailed web

page captures and images of products ordered via Defendants’ Subject Domain Names were sent

to Plaintiffs for inspection. (Burns Decl. ¶ 4; Gigante Decl. ¶ 2; Gutierrez Decl. ¶ 15.) Plaintiffs’

representative reviewed and visually inspected the adidas-branded goods ordered by Invisible via

each of the Subject Domain Names by reviewing the websites, or the detailed web page captures

and images of the products using the adidas Marks, and determined the products were non-genuine,

unauthorized versions of Plaintiffs’ goods. (Gutierrez Decl. ¶¶ 16–17.)

Section 45 of the Lanham Act defines a “counterfeit” as “a spurious mark which is

identical with, or substantially indistinguishable from, a registered mark.” 15 U.S.C. § 1127. Also,

using the “ocular test” of direct comparison, courts have found that even marks that are slightly

modified from the registered marks copied are to be considered counterfeit marks. See Fimab-

Finanziaria Maglificio vs. Helio Import/Export, Inc., 601 F. Supp. 1 (S.D. Fla. 1983). Comparing

the adidas Marks to the marks used by Defendants in connection with their Goods reveals the

obvious counterfeit nature of such Goods. Defendants’ Goods are being promoted, advertised,

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Certain Defendants also provided contact e-mail addresses in connection with their Subject
Domain Names, which are included on Schedule “A” hereto. (See Burns Decl. ¶ 4 n.2.)
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offered for sale, and sold by Defendants within this district and throughout the U.S. (Burns Decl.

¶ 4.) Defendants are profiting by preying upon consumers, many of whom have no knowledge

Defendants are defrauding them. Defendants’ activities infringe on Plaintiffs’ rights. The Subject

Domain Names and associated payment accounts are a substantial part of how Defendants further

their scheme and cause Plaintiffs’ harm.

C. Defendants Unfairly Compete with and Cause Indivisible Harm to Plaintiffs.

Defendants are all using counterfeits and infringements of Plaintiffs’ famous names and

the adidas Marks to make their websites appear more relevant and attractive to consumers

shopping for genuine adidas branded products online. While each Defendant causes direct

individual harm to Plaintiffs, the combined effect of Defendants’ unlawful activities functions as

a force multiplier to cause Plaintiffs a single indivisible harm. (Gutierrez Decl. ¶¶ 20, 23.) In other

words, they are all logically part of the same occurrence. Defendants are therefore properly joined

in this action pursuant to Fed. R. Civ. P. 20. See Bose Corp. v. The P’ships and Unincorporated

Ass’ns Identified on Schedule “A,” 334 F.R.D. 511 (N.D. Ill. Feb. 19, 2020) (holding that the

combined effect of the individual harm suffered by a plaintiff from online counterfeiters creates

injuries to the plaintiff in the aggregate constituting an occurrence under Rule 20.)

Specifically, genuine adidas branded goods are widely legitimately advertised, promoted,

offered for sale, and discussed by Plaintiffs and unrelated third parties via the Internet. (Gutierrez

Decl. ¶ 18.) Visibility on the Internet, particularly via search engines and social media platforms,

is important to Plaintiffs’ overall marketing and consumer education efforts. (Id. at ¶ 19.) Plaintiffs

expend significant resources on Internet marketing and consumer education regarding their

products, including search engine optimization, search engine marketing, and social media

strategies, which allow Plaintiffs and others to fairly educate consumers about the value associated

with the adidas brand and the goods sold thereunder. (Id.; see also Compl. ¶ 25.)
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 Counterfeiters like Defendants embrace similar marketing strategies to Plaintiffs and are

concurrently leveraging them to cause greater, more significant harm to Plaintiffs. The

combination of all Defendants engaging in the same exact illegal activity for the same purpose

over the same time span causes Plaintiffs irreparable harm in a way that the individual actions

occurring alone might not. See, Bose Corp., 334 F.R.D. at 517 (“[Plaintiff] does not perceive any

one counterfeiter to be the problem. Each injury by itself is relatively inconsequential to [Plaintiff].

Rather, it is the injuries in the aggregate . . . that is harmful and from which [Plaintiff] seeks

shelter.”) Defendants are jointly and concertedly harming Plaintiffs’ marketing efforts on the

Internet by blocking and consistently increasing the cost of online visibility for Plaintiffs’

legitimate, authorized websites. (Gutierrez Decl. ¶ 22.) The combination of Defendants’ unlawful

activities increases Plaintiffs’ cost to market their genuine goods and educate consumers about

their brand. (Id.); see, Bose Corp., 334 F.R.D. at 517 (“Seeking relief against each member of the

swarm one by one defies common sense, because it is the swarm—the fact that all Defendants are

attacking at once—that is the defining aspect of the harm from which [Plaintiff] seeks relief.”).

Defendants, each of whom is likely aware of the existence of the illegal marketplace and

the activities of the others to perpetuate the same, are combining the force of their actions to cause

individual, concurrent, and indivisible harm to Plaintiffs and consumers. (Gutierrez Decl. ¶¶ 22–

23; Compl. ¶¶ 29, 42-43). See also Bose Corp., 334 F.R.D. at 517 (“Joinder of all defendants who

are part of the swarm attacking [Plaintiff’s] trademarks flows easily from conceptualizing the

swarm as the relevant Rule 20 ‘occurrence.’”) By engaging in market building strategies based

upon an illegal use of the adidas Marks, Defendants are obliterating the otherwise open and

available marketplace space in which Plaintiffs have the right to fairly market their goods and

associated message. (Gutierrez Decl. ¶ 21.) Through their combined concurrent actions,

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Defendants are causing individual, concurrent, and indivisible harm to Plaintiffs and the

consuming public by (i) depriving Plaintiffs and other third parties of the ability to fairly compete

for space within marketing results, (ii) causing an overall degradation of the value of the goodwill

associated with the adidas Marks, (iii) increasing Plaintiffs’ overall cost to market their goods and

educate consumers about their brand via the World Wide Web, and (iv) creating and maintaining

an illegal marketplace using the World Wide Web which perpetuates the ability of Defendants to

confuse consumers and harm Plaintiffs with impunity. (Gutierrez Decl. ¶ 16.) See, Bose Corp.,

334 F.R.D. at 517 (“From the plaintiff's perspective . . . it is irrelevant whether the swarm is

intentionally coordinated or simply a product of market forces enabled by the internet.”)

Meaningful space on the World Wide Web, including marketplace and social media

advertisement space, is akin to real estate – there is only so much of it available. Website operators,

including Plaintiffs and Defendants, spend substantial sums of money incorporating concepts and

popular search terms, such as the adidas Marks, into their on-site and off-site content and

advertising to promote visibility on the World Wide Web. (See Gutierrez Decl. ¶¶ 18–19.) A

significant part of relevant market targeting involves reaching a specific demographic or profile

based upon a user’s search terms. (See id.) Plaintiffs are doing so through the use of their

trademarks in which they have made a substantial economic investment, and Defendants are doing

so through subterfuge and unlawful use of the adidas Marks. Each Defendant is helping to create

and maintain the overall illicit marketplace where they market and sell their respective goods and

confuse consumers.

Plaintiffs, their trademark rights, and associated goodwill are suffering death by 1,000 cuts

caused by the combined force of all Defendants’ individual but concurrent unlawful activities.

The combined force and effect of all of Defendants’ actions are causing the single indivisible harm

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of the mass consumer confusion and the denial of Plaintiffs’ right to fairly compete for visibility

on the World Wide Web.

III. ARGUMENT

A. A Temporary Restraining Order is Essential to Prevent Immediate Injury.

Rule 65(b) of the Federal Rules of Civil Procedure provides, in part, that a temporary

restraining order may be granted without written or oral notice to the opposing party or that party’s

counsel where “specific facts in an affidavit . . . clearly show that immediate and irreparable injury,

loss, or damage will result to the movant before the adverse party can be heard in opposition.”

Fed. R. Civ. P. 65(b). This is such a case.

Defendants fraudulently promote, advertise, offer for sale, and sell goods using counterfeits

of the adidas Marks via their Subject Domain Names. Specifically, Defendants are wrongfully

using counterfeits and infringements of the adidas Marks to increase consumer traffic to their

illegal operations. By their actions, Defendants are creating a false association in the minds of

consumers between Defendants and Plaintiffs. The entry of a temporary restraining order will

serve to immediately stop Defendants from benefiting from their wrongful use of the adidas Marks

and preserve the status quo until such time as a hearing can be held. See Dell Inc. v.

BelgiumDomains, LLC, No. 07-22674 2007 WL 6862341, at *2 (S.D. Fla. Nov. 21, 2007) (finding

ex parte relief more compelling where Defendants’ scheme “is in electronic form and subject to

quick, easy, untraceable destruction by Defendants.”)

Absent a temporary restraining order without notice, Defendants can significantly alter the

status quo before the Court can determine the parties’ respective rights. In particular, the websites

at issue are under Defendants’ complete control. Thus, Defendants can change the ownership or

modify domain registration data and content, redirect consumer traffic to other domain names,

change payment accounts, and transfer assets and ownership of the Subject Domain Names.
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(Gigante Decl. ¶ 4.) Such modifications can happen in a short span of time after Defendants are

provided with notice of this action. (Id.) Thus Defendants can easily electronically transfer and

secret the funds sought to be restrained if they obtain advance notice of Plaintiffs’ Application for

TRO, thereby thwarting the Court’s ability to grant meaningful relief and can completely erase the

status quo. (Id.) As Defendants engage in illegal counterfeiting activities, Plaintiffs have no reason

to believe Defendants will make their assets available for recovery pursuant to an accounting of

profits and other equitable remedies or will adhere to the authority of this Court any more than

they have adhered to federal trademark law.

Moreover, federal courts have long recognized that civil actions against counterfeiters –

whose very businesses are built around the deliberate misappropriation of rights and property

belonging to others – present special challenges that justify proceeding on an ex parte basis.

Columbia Pictures Indus., Inc. v. Jasso, 927 F. Supp. 1075, 1077 (N.D. Ill. 1996) (observing that

“proceedings against those who deliberately traffic in infringing merchandise are often useless if

notice is given to the infringers”). This Court should prevent an injustice from occurring by issuing

an ex parte temporary restraining order which precludes Defendants from continuing to display

their infringing content or modifying or deleting any related content or data to prevent ongoing

irreparable harm and maintain the status quo.

B. Standard for Temporary Restraining Order and Preliminary Injunction.

In this Circuit, the standard for obtaining a temporary restraining order and the standard

for obtaining a preliminary injunction are the same. See Emerging Vision, Inc. v. Glachman, No.

10-cv-80734, 2010 WL 3293346, at *3 (S.D. Fla. June 29, 2010) (citing Siegel v. LePore, 120 F.

Supp. 2d 1041 (S.D. Fla. 2000) aff’d 234 F.3d 1163 (11th Cir. 2000)). To obtain a temporary

restraining order or a preliminary injunction, a party must establish (1) a substantial likelihood of

success on the merits; (2) that irreparable injury will be suffered if the relief is not granted; (3) that
9
the threatened injury outweighs the harm the relief would inflict on the non-movant; and (4) that

entry of the relief would serve the public interest. Schiavo ex rel. Schindler v. Schiavo, 403 F.3d

1223, 1225-26 (11th Cir. 2005). Plaintiffs’ evidence establishes all of the relevant factors.

1. Probability of Success on the Merits of Plaintiffs’ Claims.

Likelihood of Success on Counterfeiting Claim.

Title 15 U.S.C. §1114 provides liability for trademark infringement if, without the consent

of the registrant, a defendant uses “in commerce any reproduction, counterfeit, copy, or colorable

imitation of a registered mark in connection with the sale, offering for sale, distribution, or

advertising of any goods or services on or in connection with which such use is likely to cause

confusion, or to cause mistake, or to deceive.” 15 U.S.C. § 1114 (2022). Plaintiffs must

demonstrate (1) ownership of the trademarks at issue; (2) Defendants’ use of the trademarks is

without Plaintiffs’ authorization; and (3) Defendants’ use is likely to cause confusion, mistake, or

deception as to the source, affiliation, or sponsorship of Defendants’ Goods. See 15 U.S.C. §

1114(1). Plaintiffs’ evidence satisfies these requirements.

The first two elements of Plaintiffs’ trademark counterfeiting and infringement claims are

easily met. The adidas Marks are owned by Plaintiffs and registered on the Principal Register of

the United States Patent and Trademark Office, and all but one have become “incontestable” under

15 U.S.C. §§ 1058 and 1065. (See Comp. Ex. “1” to the Compl.) See Ocean Bio-Chem, Inc. v.

Turner Network Television, Inc., 741 F. Supp. 1546, 1554 (S.D. Fla. 1990) (“Incontestable status

provides conclusive evidence of the registrant’s exclusive right to use the registered mark, subject

to §§ 15 and 33(b) of the Lanham Act.”). Moreover, Defendants have never had the right or

authority to use the adidas Marks. (Gutierrez Decl. ¶¶ 13, 16.)

The Eleventh Circuit uses a seven-factor test in determining the third element, likelihood

of confusion. See Ross Bicycles, Inc. v. Cycles USA, Inc., 765 F.2d 1502, 1506 (11th Cir. 1985).

10
These factors, as outlined in Safeway Store, Inc. v. Safeway Discount Drugs, Inc., are: (1) the

strength of the mark; (2) the similarity of marks; (3) the similarity of the goods; (4) similarity of

the sales methods; (5) the similarity of advertising media; (6) defendant’s intent; and (7) evidence

of actual confusion. See 675 F.2d 1160, 1164 (11th Cir. 1982); see also Lipscher v. LRP Publ’ns,

Inc., 266 F.3d 1305, 1303 (11th Cir. 1997). The seven factors listed are to be weighed and balanced

and no single factor is dispositive. (Id.)

(1) Strength of the Marks.

The spectrum of protectability and strength for trademarks is divided into four primary

types of designations: (1) coined, fanciful or arbitrary; (2) suggestive; (3) descriptive; and (4)

generic. See Two Pesos, Inc. v. Taco Cabana, Inc., 505 U.S. 763, 768, 112 S. Ct. 2753, 120 L.Ed.2d

615 (1992). Arbitrary or fanciful marks are the strongest and deemed inherently distinctive and

entitled to protection. (See id.) It cannot be seriously disputed that the adidas Marks are strong,

arbitrary and fanciful marks. (See Comp. Ex. “1” to the Complaint.) The adidas Marks have also

acquired secondary meaning. Plaintiffs expend substantial resources in developing, advertising,

and promoting the adidas Marks. (Gutierrez Decl. ¶¶ 6–9.) The adidas Marks enjoy widespread

recognition in the U.S. and are prominent in the minds of consumers.

(2) Similarity of the Marks.

Likelihood of confusion is greater when an infringer uses the exact trademark. Turner

Greenberg Assocs. v. C & C Imps., 320 F. Supp. 2d 1317, 1332 (S.D. Fla. 2004). Defendants are

using marks that are identical to the adidas Marks. (Compare Comp. Ex. “1” to the Compl. with

Comp. Ex. “1” to the Burns Decl.)

(3) Similarity of the Goods.

“The greater the similarity between the products and services, the greater the likelihood of

confusion.” John H. Harland Co. v. Clarke Checks, Inc., 711 F.2d 966, 976 (11th Cir. 1983).

11
Defendants are selling the same types of goods Plaintiffs sell. (Gutierrez Decl. ¶¶ 4–5; see

generally Defendants’ Subject Domain Names, attached as Comp. Ex. “1” to the Burns Decl.)

Because they bear counterfeits of the adidas Marks, Defendants’ Goods appear virtually identical

to Plaintiffs’ genuine products. Standing alone, this similarity can be held sufficient to establish a

likelihood of confusion. See John H. Harland Co., 711 F.2d at 976.

(4) Similarity of Sales Method and (5) Advertising Method.

Convergent marketing channels increase the likelihood of confusion. See Turner

Greenberg Assocs., 320 F. Supp. 2d at 1332. Both Plaintiffs and Defendants sell and advertise

their products using at least one of the same marketing channels, the Internet, in the same

geographical distribution areas within the U.S., including the Southern District of Florida.

(Gutierrez Decl. ¶¶ 7, 18–19; Burns Decl. ¶ 4.) Moreover, both target the same general U.S.

consumers, and as such, Plaintiffs are directly competing with Defendants’ products.

(6) Defendants’ Intent.

This district has held that when an alleged infringer adopts a mark “with the intent of

obtaining benefit from the plaintiff’s business reputation, ‘this fact alone may be sufficient to

justify the inference that there is confusing similarity.’” Turner Greenberg Assocs., 320 F. Supp.

2d at 1333, citing Carnival Corp. v. Seaescape Casino Cruises, Inc., 74 F. Supp. 2d 1261, 1268

(S.D. Fla. 1999). In a case of clear-cut copying such as in this case, it is appropriate to infer

Defendants intended to benefit from Plaintiffs’ reputations, to Plaintiffs’ detriment. See Playboy

Ent., Inc. v. P.K. Sorren Export Co. Inc. of Fla., 546 F. Supp. 987, 996 (S.D. Fla. 1982).

(7) Evidence of Actual Confusion.

Actual confusion is unnecessary to establish infringement since the test is likelihood of

confusion. See Frehling Enters. v. Int’l Select Group, Inc., 192 F.3d 1330, 1340 (11th Cir. 1999).

In this case, however, it is reasonable to infer actual confusion exists in the marketplace because

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Defendants are advertising, offering to sell and selling counterfeit goods identical in appearance

to those sold by Plaintiffs. (Gutierrez Decl. ¶¶ 13–16; Burns Decl. ¶ 4 and Comp. Ex. “1” thereto.)

The seven factors weigh only in Plaintiffs’ favor. Plaintiffs have therefore shown a

probability of success on the merits of their trademark counterfeiting and infringement claim.

Likelihood of Success on False Designation of Origin, Common

Law Unfair Competition, and Common Law Trademark
Infringement Claims.

As with a trademark infringement claim, the test for liability for false designation of origin

under Section 43(a) of the Lanham Act, 15 U.S.C. § 1125(a), is also whether the public is likely

to be deceived or confused by the similarity of the marks at issue. Two Pesos, 505 U.S. at 780.

Additionally, whether a defendant’s use of a plaintiff’s trademarks creates a likelihood of

confusion between the plaintiff’s and the defendant’s products is also the determining factor in the

analysis of unfair competition under the common law of Florida and Florida common law

trademark infringement. See Planetary Motion, Inc. v. Techsplosion, Inc., 261 F.3d 1188, 1193

n.4 (11th Cir. 2001) (“Courts may use an analysis of federal infringement claims as a ‘measuring

stick’ in evaluating the merits of state law claims.”); PetMed Express, Inc. v. MedPets.com, Inc.,

336 F. Supp. 2d 1213, 1217–18 (S.D. Fla. 2004). Whether the violation is called infringement,

unfair competition, or false designation of origin, the test is identical – is there a “likelihood of

confusion?” Two Pesos, 505 U.S. at 763. Thus, because Plaintiffs have established the merits of

their trademark counterfeiting and infringement claims against Defendants, a likelihood of success

is also shown for Plaintiffs’ false designation of origin, as well as their common law unfair

competition and trademark infringement claims.

Likelihood of Success on Cybersquatting Claim.

The Anticybersquatting Consumer Protection Act (“ACPA”) protects an owner of a

distinctive or famous trademark from another’s bad faith intent to profit from that trademark by

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registering or using a domain name that is identical or confusingly similar to the trademark owner’s

mark without regard to the goods or services. 15 U.S.C. § 1125(d). Plaintiffs must prove (1) the

adidas Marks are distinctive or famous and entitled to protection; (2) Defendants’ domain names

are identical or confusingly similar to the adidas Marks; and (3) Defendants registered or used the

domain names with a bad faith intent to profit. Bavaro Palace, S.A. v. Vacation Tours, Inc., 203

Fed. Appx. 252, 256, 2006 WL 2847233, at *3 (11th Cir. 2006).

Defendant Numbers 1-3 have registered their respective domain names incorporating, at

least, one of the adidas Marks in its entirety rendering the domain names nearly identical to the

adidas’ Marks (the “Cybersquatted Subject Domain Names”). See Victoria’s Cyber Secret Ltd.

P’ship v. V Secret Catalogue, Inc., 161 F. Supp. 2d 1339, 1351 (S.D. Fla. 2001) (“The taking of

an identical copy of another’s famous and distinctive trademark for use as a domain name creates

a presumption of confusion among Internet users as a matter of law.”).

The ACPA lists nine nonexclusive factors for determining whether a domain name has

been registered or used in “bad faith” with an intent to profit from a mark in registering or using

the mark in a domain name. See 15 U.S.C. § 1125(d)(1)(B)(i); see also Victoria’s Cyber Secret

Ltd. P’ship, 161 F. Supp. 2d at 1346. The nine factors are not meant to be exclusive and the Court

may consider all relevant factors in making a determination of bad faith. Id. at 1347. An

examination of the bad faith factors compels the conclusion that Defendant Numbers 1–3’s

registration and use of the Cybersquatted Subject Domain Names violates 15 U.S.C. § 1125(d).

The first and third factors, § 1125(d)(1)(B)(I) and (III), are clearly present as Defendant

Numbers 1–3 have no rights in the adidas Marks and have never used the Marks in connection

with a bona fide offering of goods or services. Additionally, the fourth, fifth, and ninth factors, §

1125(d)(1)(B)(IV), (V), and (IX), weigh in Plaintiffs’ favor. As discussed above, Defendant

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Numbers 1–3 have clearly intentionally incorporated the adidas Marks in their Cybersquatted

Subject Domain Name(s) to divert consumers looking for Plaintiffs’ website to their own websites

for commercial gain. Such consumers are likely to be confused as to the source and sponsorship

of their websites and mistakenly believe the websites are endorsed by and/or affiliated with

Plaintiffs. Clearly, Defendant Numbers 1–3’s registration of the Cybersquatted Subject Domain

Names to sell and offer for sale counterfeit adidas branded goods, knowing the domain names are

identical or confusingly similar to Plaintiffs’ indisputably famous and distinctive marks, ensures a

likelihood of confusion among consumers. See House Judiciary Committee Report on H.R. 3028,

H.R. Rep. No. 106-412 p. 13 (October 25, 1999) (“The more distinctive or famous a mark has

become, the more likely the owner of that mark is deserving of the relief available under this act.”).

Thus, Plaintiffs have shown a likelihood of success on their cybersquatting claim.

2. Plaintiffs are Suffering Irreparable Injury.

As the Eleventh Circuit stated: “[A] sufficiently strong showing of likelihood of confusion

[caused by trademark infringement] may by itself constitute a showing of … [a] substantial threat

of irreparable harm.” Ferrellgas Ptnrs., L.P. v. Barrow, 143 Fed. Appx., 180, 191 (11th Cir. 2005)

(citing McDonald’s Corp. v. Robertson, 147 F.3d 1301, 1310 (11th Cir. 1998). Such a finding of

irreparable injury following a showing of likelihood of confusion is virtually always made cases

like this, where a plaintiff demonstrated it will lose control of its reputation due to a defendant’s

activities. Id. A likelihood of confusion exists herein as Defendants engaged in counterfeiting

activities using spurious designations indistinguishable from the adidas Marks.

3. The Balance of Hardship Tips Sharply in Plaintiffs’ Favor.

Plaintiffs expend substantial resources to develop the quality, reputation, and goodwill

associated with the adidas Marks. (Gutierrez Decl. ¶¶ 7–8.) Should Defendants be permitted to

continue their trade in counterfeit goods, Plaintiffs will suffer losses and damage to their

15
reputations. (Id. at ¶ 24.) However, Defendants will suffer no legitimate hardship in the event a

temporary restraining order is issued as they have no right to engage in their present activities.

4. The Relief Sought Serves the Public Interest.

Defendants are engaged in unlawful activities and are directly defrauding consumers by

palming off Defendants’ Goods as Plaintiffs’ genuine goods. The public has an interest in not

being misled as to the origin, source, or sponsorship of trademarked products. See Nailtiques

Cosmetic Corp. v. Salon Sciences, Corp., 1997 WL 244746, 5, 41 U.S.P.Q.2d 1995, 1999 (S.D.

Fla.1997) (“The interests of the public in not being victimized and misled are important

considerations in determining the propriety of granting injunctive relief.”).

C. The Equitable Relief Sought is Appropriate.

The Lanham Act authorizes courts to issue injunctive relief “according to principles of

equity and upon such terms as the court may deem reasonable, to prevent the violation of any right

of the registrant of a mark ….” 15 U.S.C. § 1116(a).

1. Entry of an Order Immediately Enjoining Defendants’ Unauthorized

and Unlawful Use of Plaintiffs’ Trademarks is Appropriate.

Plaintiffs request an order requiring Defendants immediately cease all use of the adidas

Marks, or substantially similar marks, including on or in connection with all websites and domain

names they own and operate, or control. Such relief is necessary to stop the ongoing harm to

Plaintiffs’ trademarks and goodwill and to prevent Defendants from continuing to benefit from the

increased consumer traffic to their illegal operations created by their unlawful use of the adidas

Marks. This Court and others have authorized immediate injunctive relief in similar cases

involving the unauthorized use of trademarks. 2

2
See Acushnet Company v. the Individuals, No. 22-cv-61501-AHS (S.D. Fla. June 27, 2022) (Order
granting Ex Parte Application for TRO); Taylor Made Golf Company, Inc. v. the Individuals, No.
22-cv-61038-AHS (S.D. Fla. June 8, 2022) (same); see also Yeti Coolers, LLC v. Individuals, No.
16
 2. An Ex Parte Order Restraining Transfer of Assets is Appropriate.

The Court should further enter an order limiting the transfer of Defendants’ unlawfully

gained assets. Plaintiffs have demonstrated above that they will likely succeed on the merits of

their claims. Under 15 U.S.C. § 1117, Plaintiffs will be entitled to an accounting and payment of

the profits earned by Defendants throughout the course of their counterfeiting scheme. 15 U.S.C.

§ 1117. Due to the deceptive nature of the counterfeiting business, and Defendants’ deliberate

violations of federal trademark laws, Plaintiffs respectfully request this Court grant additional ex

parte relief identifying payment accounts and restraining the transfer of all monies held or received

by PayPal, for the benefit of any one or more of the Defendants, and any other financial accounts

tied thereto. See Int’l Star Class Yacht Racing Ass’n v. Tommy Hilfiger USA, Inc., 80 F.3d 749

(2d Cir. 1996); SEC v. ETS Payphones, 408 F.3d 727, 735 (11th Cir. 2005) (restraining all of the

defendant’s assets to preserve sufficient funds for the potential disgorgement).

This Court has broad authority to grant such an order. The Supreme Court has provided

that district courts have the power to grant preliminary injunctions to prevent a defendant from

transferring assets in cases where an equitable interest is claimed. Grupo Mexicano de Desarrollo,

S.A. v. Alliance Bond Fund, Inc., 527 U.S. 308, 144 L. Ed. 2d 319, 119 S. Ct. 1961 (1999). Almost

every Circuit has interpreted Rule 65 of the Federal Rules of Civil Procedure to grant authority to

courts to restrain assets pendente lite. See Mason Tenders Dist. Council Pension Fund v. Messera,

1997 WL 223077 (S.D.N.Y. May 7, 1997) (acknowledging that “[a]lmost all the Circuit Courts

have held that Rule 65 is available to freeze assets pendente lite under some set of circumstances”).

Considering the illicit nature of the counterfeiting business and the ability of counterfeiters

21-cv-62008-BB, 2021 U.S. Dist. Lexis 197592 (S.D. Fla. Sept. 28, 2021) (Bloom, B.) (same);
adidas AG v. Individuals, No. 19-cv-60457-WPD, 2019 U.S. Dist. Lexis 78028 (S.D. Fla. Feb. 25,
2019) (Dimitrouleas, W.).
17
to practically eliminate evidentiary trails by conducting their business entirely over the Internet,

courts in the Eleventh Circuit, have particularly noted the significance of such asset restraints in

cases involving counterfeiting defendants. See, e.g. Levi Strauss & Co. v. Sunrise Int’l Trading,

51 F.3d 982 (11th Cir. 1995); Reebok Int’l Ltd. v. Marnatech Enter., 737 F. Supp. 1521 (S.D. Cal.

1989), aff’d, 970 F.2d 552 (9th Cir. 1992). In Levi Strauss, the Eleventh Circuit upheld an order

granting an asset restraint against an alleged counterfeiter where the complaint included a request

for a permanent injunction and the equitable remedy of disgorgement of the alleged counterfeiter’s

profits under 15 U.S.C. § 1117. Levi Strauss, 51 F.3d at 987. Distinguishing Levi Strauss from

two earlier cases not involving Lanham Act claims, the Court emphasized the necessity of the

restraint holding that a “request for equitable relief invokes the district court’s inherent equitable

powers to order preliminary relief, including an asset freeze, in order to assure the availability of

permanent relief.” Id. citing Federal Trade Commission v. U.S. Oil and Gas Corp., 748 F.2d 1431,

1433-34 (11th Cir.1984) (district court may exercise its full range of equitable powers, including

a preliminary asset restraint, to ensure that permanent equitable relief will be possible). Indeed,

Courts may issue broad asset restraints to preserve the availability of permanent relief, including

assets that are not directly traceable to the fraudulent activity that serves as a basis for the equitable

relief requested. See S. E. C. v. Lauer, 445 F. Supp. 2d 1362, 1370 (S.D. Fla. 2006) (noting that

there is no requirement for the restrained assets be traceable to the fraudulent activity underlying

a lawsuit); Levi Strauss, 51 F.3d at 987-88 (upholding asset restraint, including assets not linked

to the profits of the alleged illegal activity, noting the defendants may request the court exempt

any particular assets); Kemp v. Peterson, 940 F.2d 110, 113-14 (4th Cir. 1991) (court may restrain

assets not specifically traced to illegal activity). In substantially similar cases, this Court and others

18
have entered the precise relief sought herein. 3

In Reebok v. Marnatech, the District Court granted Reebok a limited restraint of the

defendants’ assets for the purpose of preserving those assets, ensuring availability of a meaningful

accounting after trial. Reebok Int’l Ltd., 737 F. Supp. at 1526. In affirming the decision, the Ninth

Circuit determined that the plaintiff met its burden of demonstrating: (1) a likelihood of success

on the merits; (2) immediate and irreparable harm because of defendants’ counterfeiting activities;

and (3) that defendants might hide their allegedly ill-gotten profits if their assets were not frozen.

Reebok Int’l Ltd., 970 F.2d 552, 563 (9th Cir. 1992). Moreover, the Court reasoned: “because the

Lanham Act authorizes the District Court to grant Reebok an accounting of [defendant’s] profits

as a form of final equitable relief, the District Court has the inherent power to freeze [defendant’s]

assets in order to ensure the availability of that final relief.” Reebok Int’l Ltd., 970 F.2d. at 559;

see also, Republic of Philippines v. Marcos, 862 F.2d 1355, 1364 (9th Cir. 1988), cert. denied, 490

U.S. 1035 (1989) (“[a] court has the power to issue a preliminary injunction in order to prevent a

defendant from dissipating assets in order to preserve the possibility of equitable remedies”).

Using the power to issue provisional remedies ancillary to their authority to provide final

equitable relief, numerous courts have granted orders restraining defendants from transferring their

assets under trademark infringement claims. See e.g. Levi Strauss, 51 F.3d at 987; Reebok Int’l

Ltd., 970 F.2d at 559. Moreover, to provide complete equitable relief, courts have granted such

orders without providing notice to the defendants. Federal courts have held that where advance

3
See e.g., Acushnet Company v. the Individuals, No. 22-cv-61501-AHS (S.D. Fla. June 27, 2022)
(Order granting TRO, inter alia, restraining funds held or received by financial institution to
preserve assets to satisfy Plaintiffs’ requested relief); Taylor Made Golf Company, Inc. v. the
Individuals, Case No. 22-cv-61038-AHS (S.D. Fla. June 8, 2022) (same); see also Richemont Int’l
SA v. Individuals, No. 20-cv-62624-JIC, 2020 U.S. Dist. Lexis 250702 (S.D. Fla. Dec. 23, 2020)
(Cohn, J.) (same); adidas AG v. Individuals, No. 19-cv-60457-WPD, 2019 U.S. Dist. Lexis 78028
(S.D. Fla. Feb. 25, 2019) (Dimitrouleas, W.) (same).
19
notice of an asset restraint is likely to cause a party to alienate the assets sought to be restrained, a

temporary restraining order may be issued ex parte. See F.T. Int’l Ltd v. Mason, 2000 WL 1514881

*3 (E.D. Pa. 2000) (granting ex parte TRO restraining defendants’ assets upon finding that advance

notice would have caused the defendants to alienate funds); CSC Holdings, Inc. v. Greenleaf Elec.,

Inc., 2000 WL 715601 (N.D. Ill. 2000) (granting ex parte TRO enjoining cable television pirates

and restraining pirates’ assets).

Defendants’ blatant violations of federal trademark laws warrant an ex parte order

restraining the transfer of their ill-gotten assets. Moreover, as Defendants’ businesses are

conducted anonymously over the Internet, Plaintiffs have additional cause for ex parte relief, as

Defendants may easily secret or transfer their assets without the Court’s or Plaintiffs’ knowledge.

D. A Bond Should Secure the Injunction.

Because of the strong and unequivocal nature of Plaintiffs’ evidence, Plaintiffs respectfully

request this Court require them to post a bond of no more than ten thousand dollars ($10,000.00),

subject to increase at the Court’s discretion should an application be made in the interest of justice.

The posting of security is vested in the Court’s sound discretion. Fed. R. Civ. P. 65(c).

IV. CONCLUSION

In view of the foregoing, Plaintiffs respectfully request this Court grant their ex parte

application and enter a temporary restraining order as to Defendants in the form submitted

herewith and schedule a hearing on Plaintiffs’ Motion for a Preliminary Injunction before the

expiration of the temporary restraining order. Furthermore, due to the time provisions of a

temporary restraining order, in the event the application is granted, Plaintiffs respectfully request

the Court provide a copy of the order to Plaintiffs’ counsel via e-mail at [email protected] so that

Plaintiffs may immediately effectuate any relief ordered therein and provide Defendants proper

notice of the order and any subsequent hearing date.

20
DATED: September 12, 2022. Respectfully submitted,

STEPHEN M. GAFFIGAN, P.A.

By: Virgilio Gigante__________________

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., #130-453
Ft. Lauderdale, Florida 33301
Telephone: (954) 767-4819
E-mail: [email protected]
E-mail: [email protected]
E-mail: [email protected]

Attorneys for Plaintiffs

21
 SCHEDULE “A”
DEFENDANTS BY NUMBER, SUBJECT DOMAIN NAME,
FINANCIAL ACCOUNT INFORMATION, AND E-MAIL ADDRESS

Account
Def. Defendant / Account Information:
Information: PayPal E-mail Address
No. Subject Domain Name PayPal Account / Payee
Merchant ID
1 2021yeezyboost.com [email protected] 6BY2QN3VDNS2N
2 adidasoutletstores.us.com [email protected] 4G8XKCK9TYQKY
2 adidasultra-boosts.us.com FUZHAO SHAO F7DZ6HBF6DKNY
2 officialyeezywebsite.us.com FUZHAO SHAO F7DZ6HBF6DKNY
cassidiecharnisejomara@gm
2 yeezyshoesadidas.us.com [email protected]
ail.com
2 yeezyshop.us.com [email protected] F7DZ6HBF6DKNY
3 adidasshoes-canada.ca [email protected] 5DE7HSVKHJMPJ
4 365yeezys.com [email protected] EPA52DJRHQM3L [email protected]
4 365yeezyshop.com EPA52DJRHQM3L [email protected]
[email protected]
5 abovebizsport.com [email protected] SZ9JD6JR8Q9GY [email protected]
[email protected]
[email protected]
5 departmentstoreblog.com [email protected] GPBDNYC7894SA [email protected]
[email protected]
[email protected]
[email protected] RNR7SDRDJHUTG
[email protected]
5 fsportshoe.com apolo.com
[email protected] TNELZL8GGZ87W globalpurchasing@shoeworl
dbusiness.com

[email protected]
[email protected]
5 mtsqualityshop.com [email protected] RHN8AW9KPPG28 [email protected]
[email protected]
apolo.com
[email protected]
6 artemisfashionsneaker.com [email protected] GNB5M69UTJVYE [email protected]
[email protected]
7 artemisoutlet.ru [email protected] UHTDFHTLF3N24
[email protected]

22
 artmisoutletsneaker@gmail.
com
cheapjordanshoes2021@gm
7 cheapjordan.ru [email protected] UHTDFHTLF3N24
ail.com
[email protected]
[email protected]
8 awekicks.com [email protected] 456XQ3BUTWYY6 [email protected]
[email protected]
om
9 bestshoesstore.net [email protected] MGLLEK5ER3S92
[email protected]
op.com
[email protected]
[email protected]
9 hotkicks.org [email protected] MGLLEK5ER3S92
[email protected]
op.com
DT7GM2R5MHYH
10 bisitry.com [email protected] [email protected]
W
Quanzhou Quangu Trading Co., DT7GM2R5MHYH [email protected]
10 breezesp.com
Ltd. W [email protected]
11 bittase.com Caryln Andrea LHWDPJQVVRRFA [email protected]
11 gabrielatony.com [email protected] LHWDPJQVVRRFA [email protected]
[email protected]
11 sadoplus.com Caryln Andrea LHWDPJQVVRRFA
[email protected]

[email protected] WH5DBKTH7GVTE [email protected]

12 bstsneakers.com [email protected]
[email protected] om
13 buyajshoes.com [email protected] GNKPW25F7MT3Q [email protected]
service@customerservicesfa
14 buythesole.com [email protected]
ce.com
[email protected]
15 cheapyeezy.net [email protected] YMP227Z6963GJ [email protected]
op.com
[email protected]
[email protected]
[email protected]
16 cheapyeezynow.com [email protected]
[email protected]
[email protected]
m
FUKARVGULQXA [email protected]
17 deluxerep.com [email protected]
G [email protected]
18 elevenkicks.com [email protected] [email protected]
customerservice@flamsneak
19 flamsneaker.com [email protected] VPB7NCSCWQRYJ er.com
[email protected]

23
 [email protected]
20 footballretrojersey.com [email protected] 43CZTKJCMWXJQ
om
[email protected]
m
21 hamptonathletics.com [email protected] YWXS74S5L7E46
[email protected]
om
22 hellopk.net [email protected] [email protected]
[email protected]
23 hottest-shoes.com [email protected] F38PPL2WMRBMY
m
24 incbbl.store [email protected] [email protected]
25 jordan1best.com [email protected] [email protected]
[email protected]
26 jordanplugs.com [email protected]
[email protected]
[email protected]
27 kickbulk.co [email protected]
[email protected]
[email protected]
28 kicki.co [email protected]
[email protected]
29 kickwho.asia [email protected] PW8SVSR577UZW [email protected]
[email protected] [email protected]
30 kisskick.ru [email protected]
[email protected] [email protected]
31 ljrsneakers.com [email protected] [email protected]
[email protected]
32 minejerseys.net [email protected] [email protected]
[email protected]
ogtonysneakers2012@gmail
.com
33 ogtonysneakers.com [email protected] T5PCH5VGSEHZ4 [email protected]
[email protected]
op.com
34 onebyonemall.com [email protected] Q6YZ4G6ZR2KLU [email protected]
34 sneakercome.com [email protected] Q6YZ4G6ZR2KLU [email protected]
outletsshoesservice@gmail.
SBRMVMSKBGVG
35 outletsshoes.cn [email protected] com
U
[email protected]
[email protected]
36 owowgoodshop.com [email protected] 4C8L3SM7FNHDJ
m
37 realkicks.vip [email protected] [email protected]
38 rockkick.ru [email protected] [email protected]
[email protected] FBY9PN2BS2QAU
39 serchluxury.com [email protected]
[email protected] 595QCLVBWMFUA

24
 [email protected]
40 sharesneaker.net [email protected]
[email protected]
41 shootjerseys.biz [email protected] [email protected]
41 shootjerseys.store [email protected] [email protected]
BX4QKKUMLHM2
42 sirsoccer.com [email protected] [email protected]
Y
[email protected]
43 sneakercrushes.co [email protected] 6YN3DV2GNXEWS
m
[email protected]
[email protected]
HTWFQCXCWUYS
44 kickswho.vip [email protected] [email protected]
S
[email protected]
[email protected]
HTWFQCXCWUYS
44 sneakermolds.com [email protected]
S
sneakershoeboxclub@gmail.
com
45 sneakershoeboxru.ru [email protected]
customercomplain18@gmai
l.com
[email protected] H5EGJHR2HV7NQ [email protected]
46 sneakerwell.com [email protected]
[email protected] TFZA3ENKRCSDL m
47 soccerpeter.com [email protected] 7UDV9R2EPGLRG [email protected]
48 stockxhouse.com [email protected] 7NGGXKBSXV7JJ [email protected]
[email protected] [email protected]
49 stockxpro.vip [email protected]
[email protected] [email protected]
50 songsneaker.com [email protected] LRJKDPX6EVSPE [email protected]
50 stockxsneaker.net [email protected] LRJKDPX6EVSPE
S7ZKYHSWEM2W
51 style4ug.com [email protected] [email protected]
N
[email protected]
52 taosneakers.com [email protected]
[email protected]
53 taxshoes.com [email protected] C44SDVNN2VSK2 [email protected]
[email protected] VKECYMW738RDY [email protected]
54 teeplano.com
[email protected] NXK2F75SA48KW [email protected]
[email protected] shop@customerservicesface
55 thechurchofsaintstephen.com .com
[email protected] [email protected]
betappayconsultingfinance@gmai
56 unclelin.net [email protected]
l.com
57 wavyword.shop [email protected] SFU3JU5VH36QU [email protected]

25
 [email protected] 2Q5VFB35PYMLE [email protected]
58 weststocks.ru [email protected]
[email protected] Z94VCAWGVAJFA apolo.com
[email protected]
59 wonderkicks.ru [email protected]
[email protected]
60 yeezyall.com [email protected] 9MFWU93AXBVHJ [email protected]
[email protected]
61 yeezywish.com [email protected] J9GVG3TA26SHE m
[email protected]
[email protected] 9DEG9RMY2AVQQ
62 yesyeezy.ru [email protected]
[email protected] H3H47QCLSKZFY
[email protected] [email protected]
63 yougoodha.gq
[email protected] [email protected]

26