1:25-cv-25442•Sega Corporation et al v. The Partnerships and Unincorporated Associations Identified On Schedule A
Sega Corporation et al v. The Partnerships and Unincorporated Associations Identified On Schedule A
1:25-cv-25442Flsd27 gen 2026
Testo completo
1
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 1:25-cv-25442-JB
SEGA CORPORATION and
SEGA OF AMERICA, INC.,
Plaintiffs,
v.
THE PARTNERSHIPS and
UNINCORPORATED ASSOCIATIONS
IDENTIFIED ON SCHEDULE "A,"
Defendants.
ORDER GRANTING PLAINTIFFS’ MOTION
FOR PRELIMINARY INJUNCTION ORDER
THIS CAUSE comes before the Court upon Plaintiffs Sega Corporation’s and
Sega of America, Inc.'s ("Plaintiffs" or "Sega") Motion for Entry of a Preliminary
Injunction. ECF No. [21]. In the Motion, Sega seeks entry of a preliminary injunction
order against the Partnerships and Unincorporated Associations Identified on
Schedule A hereto (collectively, "Defendants"), and entry of an order restraining the
financial accounts used by Defendants, pursuant to the Lanham Act, 15 U.S.C. §§
1116 et seq.; Federal Rule of Civil Procedure 65; the Copyright Act, 17 U.S.C. §§ 101
et seq.; and the All Writs Act, 28 U.S.C. § 1651(a).
On December 30, 2025, the Court entered an order granting Plaintiffs' ex parte
Motion for Entry of Temporary Restraining Order ("TRO"). ECF No. [14]. Upon
Plaintiffs' showing of good cause, the Court extended the TRO to expire on January
27, 2026. ECF No. [19]. The Court convened a public hearing on January 26, 2026.
_____________________________________/
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 1 of 1112 ECF No. [29]. Plaintiffs certified that they served Defendants notice of this hearing on January 22, 2026, on the Defendants identified on Schedule “A” hereto by (1) emailing Defendants the Complaint, Motion, and TRO issued in this action; and (2) posting copies of the Complaint, Motion, TRO, and all other documents filed in this action at https://www.tme-law.com/case/25-cv-25442, where such documents are available to view and download in compliance with this Court’s TRO. ECF Nos. [14] at 100; [26]. Only counsel for Plaintiffs appeared through counsel at the hearing on the Motion. As represented by Plaintiffs’ counsel at the hearing and reflected on the docket of this case, no Defendants have made any appearance, indicated an intention to challenge the TRO, or otherwise answered and/or defended against the Complaint. The Court heard argument from Plaintiffs and reviewed the evidence that Plaintiffs’ counsel presented to the Court. Upon due consideration of the Motion, the pertinent portions of the record, the relevant authorities, and for the reasons set forth herein, the Motion is hereby GRANTED in its entirety. I. FACTUAL BACKGROUND The following background is taken from Plaintiffs' Complaint, ECF No. [1], the Motion, and supporting evidentiary submissions and exhibits. Sega is the owner of various copyright registrations related to its Sonic the Hedgehog franchise (the "Sega Copyrighted Works"). A list of the Sega Copyrighted Works is below. See Declaration of Andrew Masterson (the "Masterson Decl.") ECF Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 2 of 111
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 3 of 111
4 TX0007617970 Sonic the Hedgehog Buddy "Tail's". [Published: 1995-10-31. Issue: no. 3, Feb 1996] September 25, 2012 TX0007609679 Sonic the Hedgehog Presents "Princess Sally". [Published: 1995-04-12. Issue: no. 1, April, 1995] September 25, 2012 TX0007609635 Sonic the Hedgehog Presents "Princess Sally". [Published: 1995-05-23. Issue: no. 2, May 1995] September 25, 2012 TX0007609608 Sonic the Hedgehog Presents "Princess Sally". [Published: 1995-06-25. Issue: no. 3, June 1995] September 25, 2012 TX0007604909 SONIC X. [Published: 2008-03-10. Issue: no. 30, 03/10/2008] September 24, 2012 TX0007604907 SONIC X. [Published: 2008-03-26. Issue: no. 31, 03/26/2008] September 24, 2012 TX0007604905 SONIC X. [Published: 2008-04-23. Issue: no. 32, 04/23/2008] September 24, 2012 TX0007604904 SONIC X. [Published: 2008-05-28. Issue: no. 33, 05/28/2008] September 24, 2012 TX0007604903 SONIC X. [Published: 2008-06-25. Issue: no. 34, 06/25/2008] September 24, 2012 TX0007604877 SONIC X. [Published: 2008-07-23. Issue: no. 35, 07/23/2008] September 24, 2012 TX0007604398 SONIC X. [Published: 2008-08-27. Issue: no. 36, 08/27/2008] September 24, 2012 TX0007604138 SONIC X. [Published: 2008-09-24. Issue: no. 37, 09/24/2008] September 24, 2012 TX0007604076 SONIC X. [Published: 2008-10-22. Issue: no. 38, 10/22/2008] September 24, 2012 TX0007603702 SONIC X. [Published: 2008-11-26. Issue: no. 39, 11/26/2008] September 24, 2012 TX0007602871 SONIC X. [Published: 2008-12-24. Issue: no. 40, 12/24/08] September 24, 2012 TX0007604911 SONIC X. [Published: 2005-09-07. Issue: no. 1, Nov 2005] September 19, 2012 TX0007604912 SONIC X. [Published: 2007-02-09. Issue: no. 16, Mar 2007] September 19, 2012 TX0007605207 SONIC X. [Published: 2007-03-16. Issue: no. 17, April 2007] September 19, 2012 TX0007605212 SONIC X. [Published: 2007-04-13. Issue: no. 18, May 2007] September 19, 2012 TX0007605218 SONIC X. [Published: 2007-05-03. Issue: no. 19, June 2007] September 19, 2012 Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 4 of 111
5 TX0007617976 SONIC X. [Published: 2007-05-31. Issue: no. 20, July 2007] September 19, 2012 TX0007605216 SONIC X. [Published: 2007-07-02. Issue: no. 21, Aug 2007] September 19, 2012 TX0007605214 SONIC X. [Published: 2007-07-30. Issue: no. 22, Sept 2007] September 19, 2012 TX0007605119 SONIC X. [Published: 2007-08-27. Issue: no. 23, Oct 2007] September 19, 2012 TX0007605116 SONIC X. [Published: 2007-09-24. Issue: no. 24, Nov 2007] September 19, 2012 TX0007604938 SONIC X. [Published: 2007-10-22. Issue: no. 25, Dec 2007] September 19, 2012 TX0007604930 SONIC X. [Published: 2007-11-07. Issue: no. 26, Jan 2008] September 19, 2012 TX0007604928 SONIC X. [Published: 2007-12-17. Issue: no. 27, Feb 2008] September 19, 2012 TX0007604925 SONIC X. [Published: 2008-01-14. Issue: no. 28, Mar 2008] September 19, 2012 TX0007604921 SONIC X. [Published: 2008-02-11. Issue: no. 29, Mar 2008] September 19, 2012 TX0007617978 SONIC X. [Published: 2005-10-05. Issue: no. 2, Dec 2005] September 17, 2012 TX0007605205 SONIC X. [Published: 2005-11-02. Issue: no. 3, Jan 2006] September 17, 2012 TX0007605203 SONIC X. [Published: 2005-11-30. Issue: no. 4, Feb 2006] September 17, 2012 TX0007605201 SONIC X. [Published: 2006-01-25. Issue: no. 5, April 2006] September 17, 2012 TX0007605184 SONIC X. [Published: 2006-02-22. Issue: no. 6, May 2006] September 17, 2012 TX0007605180 SONIC X. [Published: 2006-03-22. Issue: no. 7, June 2006] September 17, 2012 TX0007605172 SONIC X. [Published: 2006-04-19. Issue: no. 8, July 2006] September 17, 2012 TX0007605168 SONIC X. [Published: 2006-06-28. Issue: no. 10, Aug 2006] September 17, 2012 TX0007604931 SONIC X. [Published: 2006-06-28. Issue: no. 9, July 2006] September 17, 2012 TX0007604940 SONIC X. [Published: 2006-07-22. Issue: no. 12, Nov 2006] September 17, 2012 TX0007605164 SONIC X. [Published: 2006-07-26. Issue: no. 11, Sept 2006] September 17, 2012 TX0007605175 SONIC X. [Published: 2006-10-25. Issue: no. 13, Dec 2006] September 17, 2012 Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 5 of 111
6 TX0007604935 SONIC X. [Published: 2006-11-01. Issue: no. 14, Jan 2006] September 17, 2012 TX0007604933 SONIC X. [Published: 2006-12-13. Issue: no. 15, Feb 2007] September 17, 2012 TX0007563319 SONIC SUPER SPECIAL. [Published: 1997- 04-29. Issue: no. 1, 4/29/1997] July 13, 2012 TX0007563317 SONIC SUPER SPECIAL. [Published: 1997- 08-19. Issue: no. 2, 8/19/1997] July 13, 2012 TX0007563313 SONIC SUPER SPECIAL. [Published: 1997- 10-21. Issue: no. 3, 10/21/1997] July 13, 2012 TX0007563302 SONIC SUPER SPECIAL. [Published: 1997- 12-30. Issue: no. 4, 1998] July 13, 2012 TX0007563180 SONIC SUPER SPECIAL. [Published: 1998- 03-17. Issue: no. 5, 3/17/1998] July 13, 2012 TX0007563178 SONIC SUPER SPECIAL. [Published: 1998- 06-16. Issue: no. 6, 6/16/1998] July 13, 2012 TX0007563175 SONIC SUPER SPECIAL. [Published: 1998- 09-29. Issue: no. 7, 9/29/1998] July 13, 2012 TX0007562833 SONIC SUPER SPECIAL. [Published: 1999- 03-16. Issue: no. 9, 3-16-99] July 13, 2012 TX0007562829 SONIC SUPER SPECIAL. [Published: 1999- 06-15. Issue: no. 10, 6/15/1999] July 13, 2012 TX0007562822 SONIC SUPER SPECIAL. [Published: 1999- 09-21. Issue: no. 11, 9/21/1999] July 13, 2012 TX0007562838 SONIC SUPER SPECIAL. [Published: 1999- 12-29. Issue: no. 8, 12/29/1999] July 13, 2012 TX0007562818 SONIC SUPER SPECIAL. [Published: 2000- 01-04. Issue: no. 12, 1/4/00] July 13, 2012 TX0007562815 SONIC SUPER SPECIAL. [Published: 2000- 01-04. Issue: no. 13, 01/04/2000] July 13, 2012 TX0007562811 SONIC SUPER SPECIAL. [Published: 2000- 06-01. Issue: no. 14, 06/01/2000] July 13, 2012 TX0007562780 SONIC SUPER SPECIAL. [Published: 2000- 11-01. Issue: no. 15, Feb 2001] July 13, 2012 PAu003353780 Sonic Unleashed Video Excerpts and Screenshots. August 20, 2008 PA0000783698 The adventures of Sonic the Hedgehog : no. 238-101. February 8, 1996 PA0000783697 The adventures of Sonic the Hedgehog : no. 238-102. February 8, 1996 PA0000783696 The adventures of Sonic the Hedgehog : no. 238-103 February 8, 1996 PA0000783767 The adventures of Sonic the Hedgehog : no. 238-104, Sloww going. February 8, 1996 Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 6 of 111
7 PA0000783769 The adventures of Sonic the Hedgehog : no. 238-105, High stakes Sonic. February 8, 1996 PA0000783766 The adventures of Sonic the Hedgehog : no. 238-106, Sonic breakout. February 8, 1996 PA0000783765 The adventures of Sonic the Hedgehog : no. 238-107, Trail of the missing... February 8, 1996 PA0000783740 The adventures of Sonic the Hedgehog : no. 238-108. February 8, 1996 PA0000783739 The adventures of Sonic the Hedgehog : no. 238-109. February 8, 1996 PA0000783760 The adventures of Sonic the Hedgehog : no. 238-110, King Coconuts. February 8, 1996 PA0000791347 The adventures of Sonic the Hedgehog : no. 238-111. February 8, 1996 PA0000791349 The adventures of Sonic the Hedgehog : no. 238-112. February 8, 1996 PA0000791345 The adventures of Sonic the Hedgehog : no. 238-113. February 8, 1996 PA0000791344 The adventures of Sonic the Hedgehog : no. 238-114. February 8, 1996 PA0000791340 The adventures of Sonic the Hedgehog : no. 238-115. February 8, 1996 PA0000791339 The adventures of Sonic the Hedgehog : no. 238-116. February 8, 1996 PA0000791341 The adventures of Sonic the Hedgehog : no. 238-117. February 8, 1996 PA0000791342 The adventures of Sonic the Hedgehog : no. 238-118. February 8, 1996 PA0000777971 The adventures of Sonic, the hedgehog : no. 238-137. February 8, 1996 PA0000777973 The adventures of Sonic, the hedgehog : no. 238-138. February 8, 1996 PA0000777970 The adventures of Sonic, the hedgehog : no. 238-139. February 8, 1996 PA0000778054 The adventures of Sonic the Hedgehog : no. 238-140. February 8, 1996 PA0000778058 The adventures of Sonic the Hedgehog : no. 238-141. February 8, 1996 PA0000778060 The adventures of Sonic the Hedgehog : no. 238-142. February 8, 1996 PA0000778056 The adventures of Sonic the Hedgehog : no. 238-143. February 8, 1996 PA0000777968 The adventures of Sonic, the hedgehog : no. 238-144. February 8, 1996 Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 7 of 111
8 PA0000777967 The adventures of Sonic, the hedgehog : no. 238-145. February 8, 1996 PA0000778055 The adventures of Sonic the Hedgehog : no. 238-146. February 8, 1996 PA0000778061 The adventures of Sonic the Hedgehog : no. 238-147. February 8, 1996 PA0000777966 The adventures of Sonic, the hedgehog : no. 238-148. February 8, 1996 PA0000777965 The adventures of Sonic, the hedgehog : no. 238-149. February 8, 1996 PA0000778053 The adventures of Sonic the Hedgehog : no. 238-150. February 8, 1996 PA0000777972 The adventures of Sonic, the hedgehog : no. 238-151. February 8, 1996 PA0000778062 The adventures of Sonic the Hedgehog : no. 238-152. February 8, 1996 PA0000778059 The adventures of Sonic the Hedgehog : no. 238-153. February 8, 1996 PA0000778057 The adventures of Sonic the Hedgehog : no. 238-154. February 8, 1996 PA0000783699 The adventures of Sonic the Hedgehog : no. 238-155. February 8, 1996 PA0000783700 The adventures of Sonic the Hedgehog : no. 238-156. February 8, 1996 PA0000783706 The adventures of Sonic the Hedgehog : no. 238-157. February 8, 1996 PA0000783702 The adventures of Sonic the Hedgehog : no. 238-158. February 8, 1996 PA0000783701 The adventures of Sonic the Hedgehog : no. 238-159. February 8, 1996 PA0000783705 The adventures of Sonic the Hedgehog : no. 238-160. February 8, 1996 PA0000783761 The adventures of Sonic the Hedgehog : no. 238-161, 48 hour sonic : a.k.a. Fat & easy. February 8, 1996 PA0000783764 The adventures of Sonic the Hedgehog : no. 238-162, Lifestyles of the sick and twisted. February 8, 1996 PA0000783763 The adventures of Sonic the Hedgehog : no. 238-163, Sonic is running. February 8, 1996 PA0000783762 The adventures of Sonic the Hedgehog : no. 238-164, Roboninjas. February 8, 1996 PA0000791361 The adventures of Sonic, the hedgehog : no. 238-165. February 8, 1996 PA0000791242 The adventures of Sonic the Hedgehog : no. 238-119, Mystery of the missing... February 7, 1996 Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 8 of 111
9 PA0000791233 The adventures of Sonic the Hedgehog : no. 238-120, Goodbye sucker. February 7, 1996 PA0000791232 The adventures of Sonic the Hedgehog : no. 238-121, Sonic getstrashed. February 7, 1996 PA0000791231 The adventures of Sonic the Hedgehog : no. 238-122, Pseudo Sonic. February 7, 1996 PA0000777969 The adventures of Sonic, the hedgehog : no. 238-123. February 7, 1996 PA0000791230 The adventures of Sonic the Hedgehog : no. 238-124, Tails in charge. February 7, 1996 PA0000791229 The adventures of Sonic the Hedgehog : no. 238-125, Sno problem. February 7, 1996 PA0000777963 The adventures of Sonic, the hedgehog : no. 238-126. February 7, 1996 PA0000791228 The adventures of Sonic the Hedgehog : no. 238-127, Dream on. February 7, 1996 PA0000791234 The adventures of Sonic the Hedgehog : no. 238-128, Musta ... beautiful baby. February 7, 1996 PA0000772425 The adventures of Sonic, the hedgehog : no. 238-129. February 7, 1996 PA0000791243 The adventures of Sonic the Hedgehog : no. 238-130, Full tilt tails. February 7, 1996 PA0000791244 The adventures of Sonic the Hedgehog : no. 238-131, MacHopper. February 7, 1996 PA0000772426 The adventures of Sonic the Hedgehog : no. 238-132. February 7, 1996 PA0000777964 The adventures of Sonic, the hedgehog : no. 238-133. February 7, 1996 PA0000772423 The adventures of Sonic, the hedgehog : no. 238-134. February 7, 1996 PA0000772427 The adventures of Sonic the Hedgehog : no. 238-135. February 7, 1996 PA0000791227 The adventures of Sonic the Hedgehog : no. 238-136, Robotnik's rival. February 7, 1996 PA0000659981 Sonic the hedgehog 3 June 22, 1994 PA0000659929 Sonic the hedgehog March 7, 1994 TXu000593150 Sonic spinball. November 3, 1993 PA0000602981 Sonic the hedgehog 2 November 12, 1992 Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 9 of 111
10 Sega also owns the following federally registered trademarks, which are valid and registered on the Principal Register of the United States Patent and Trademark Office (the "Sega Trademarks"). See id.ECF No. [11-1]. Registrati on Number Trademark Registrati on Date Goods and Services 3,009,472 SONIC THE HEDGEHOG Oct. 25, 2005 For: Video game software in class 009. 4,673,369 SONIC THE HEDGEHOG Jan. 20, 2015 For: Key rings of precious metals; badges of precious metal; wristwatches; watches; clocks in class 014. For: Printed matter, namely, books, magazines and newsletters featuring animation, video games, computer games, arcade games, posters; comic books; note books in class 016. For: Bags, namely, backpacks, shoulder bags in class 018. For: Picture frames in class 020. For: Cups; bottles, sold empty in class 021. For: Quilts; quilt covers; pillowcases; bed blankets in class 024. For: Clothing, namely, t- Shirts, shirts, socks, Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 10 of 111
11 underwear, sweaters, parkas, head wear, pajamas; shoes in class 025. For: Amusement game machines and coin-operated amusement machines for use in amusement parks; toys, namely, electronic action toys, inflatable toys, mechanical action toys puzzles, toy building blocks, board games; action figures; electronic action toys; dolls; stuffed toys; playing cards; sports equipment, namely, skateboards in class 028. For: Confectionery made of sugar; ice cream in class 030. For: Carbonated soft drinks; non-alcoholic beverages, namely, fruit-flavored soft drinks and soda water in class 032. 6,358,553 SONIC THE HEDGEHOG May 25, 2021 For: Recorded videotapes and videodiscs featuring animation, action, adventure and comedy films; downloadable films and movies featuring animation, action, adventure and comedy provided via a video-on- demand service; motion picture films featuring animation, action, adventure and comedy; downloadable graphics for Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 11 of 111
12 computers, video game machines and mobile phones featuring scenes and characters based on animated cartoons, computer games and video games; electronic publications, namely, downloadable electronic books and magazines in the field of motion pictures, cartoons, music, computer games and video games; phonograph records featuring music; downloadable music files via a global computer network and wireless devices; recorded compact discs featuring music, video game sounds and dialogues; compact discs, prerecorded audio tapes, and downloadable files featuring musical sound recordings; mobile phone straps; protective cases for cell phones; downloadable computer game programs; recorded computer game programs; downloadable computer game software; recorded computer game software; downloadable video game software; recorded video game software; downloadable video game programs; recorded video game programs; video game discs and cartridges; downloadable computer game software for use on mobile and cellular phones in class 009. Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 12 of 111
13 3,584,384 SONIC UNLEASHED Mar. 03, 2008 For: Video game software in class 009. 5,024,565 SONIC RUNNERS Aug. 23, 2016 For: Computer game programs; computer game software; computer game software for use on mobile and cellular phones; mobile phone straps; protective cases for cell phones in class 009. For: Entertainment services, namely, providing on-line video games and on-line computer games; providing information on on-line games; providing amusement facilities in class 041. 5,268,608 SONIC MANIA Aug. 22, 2017 For: Computer game programs; computer game software; video game software; video game programs; video game discs and video game cartridges; computer game software for use on mobile and cellular phones; protective cases for cell phones; downloadable graphics, images and moving images for computers, video game machines or mobile phones featuring scenes and characters based on computer and video games; downloadable computer and video game software; downloadable music files via a global computer network and wireless devices; musical sound recordings; prerecorded Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 13 of 111
14 video discs and tapes featuring music, comedy, drama, action, adventure and animation in class 009. For: Entertainment services, namely, providing on-line video games and on-line computer games in class 041. 5,619,845 SONIC BOOM Dec. 4, 2018 For: Computer game programs for home video consoles; electronic circuits, magnetic computer tapes and disks, optical disks, ROM cartridges and other recording media, namely, computer cartridges and computer cassettes, all containing video game programs for use with home video game consoles; electronic circuits, magnetic computer tapes and disks, optical disks, ROM cartridges and other recording media, namely, computer cartridges and computer cassettes, all containing video game programs for use with hand- held games with liquid crystal displays; video game software for home video game consoles; telecommunication machines and apparatus, namely, cellular phones and mobile phones; straps for mobile phones; computers; computer game programs; electronic circuits, magnetic computer Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 14 of 111
15 tapes and disks, optical disks, ROM cartridges containing computer game programs; computer software for children's education; computer application software for mobile phones, namely, game software; computer game software; computer software for computer system management; computer programs for arcade video game machines; electronic circuits, magnetic computer tapes and disks, optical disks, ROM cartridges and other recording media, namely, computer cartridges and cassettes, all containing video game programs for use with arcade video game machines; game software for arcade video game machines; video game program; video game software; phonograph records featuring music; downloadable music files; downloadable music files for mobile telephones and tablet computers; recorded compact discs featuring music, animated cartoons; downloadable image files in the field of computer games, video games and animated cartoons; downloadable image files, namely, downloadable moving image files for mobile terminals, in the field of computer games, video games Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 15 of 111
16 and animated cartoons; recorded video discs and video tapes featuring movies, cartoons, video games; videotapes and videodiscs recorded with animation; downloadable electronic publications, namely, books, comic books, magazines and manuals featuring computer games, video games and animated cartoons in class 009. For: Pastes and other adhesives for stationery or household purposes; hygienic hand towels of paper, namely, wet tissue; paper towels; table napkins of paper; hand towels of paper; handkerchiefs of paper; stationery; seals; stickers; printed matter, namely, comic books, video game instruction manuals, children's books, children's activity books, songbooks, children's magazines, magazines and pamphlets featuring information and articles about fashion and games; pictorial prints; picture books; catalogues in the field of computer games, video games and animated cartoons; calendars; trading cards; paintings and calligraphic works; printed photographs; photograph stands in class Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 16 of 111
17 016. For: Clothing for domestic pets; bags, namely, athletic bags, all-purpose sports bags and beach bags; pouches, namely, felt pouches, leather pouches and key pouches; Boston bags; rucksacks; card cases, namely, credit card cases, name card cases and game card cases; key cases; purses; commutation-ticket holders, namely, wallets, document cases, ticket pouches; business card cases; unfitted vanity cases sold empty; umbrellas and their parts; walking sticks; canes; metal parts of canes and walking-sticks; walking cane handles and walking stick handles; saddlery in class 018. For: Non-metal locks; cushions; Japanese floor cushions (zabuton); pillows; mattresses; nameplates and door nameplates, not of metal; hand-held flat fans; hand-held folding fans; furniture; wind chimes; plastic keychains with a small doll attached; plastic key tags with a small doll attached in class 020. For: Plastic handheld shopping baskets; cosmetic and toilet utensils; toothbrushes; hair Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 17 of 111
18 brushes; toilet cases, namely, toilet brush holder; kitchen utensils, namely, batter dispenser, grill covers, barbeque branders and grates; kitchen containers, namely, kitchen containers, containers for household or kitchen user of precious metal and non- electric kitchen containers not made of precious metal; non- electric cooking pots and pans; non-electric coffee-pots; Japanese cast iron kettles, non-electric (tetsubin); non- electric kettles; tableware, other than knives, forks and spoons, namely, coffee services, tea services; drinking cups; dishes; Japanese rice bowls (chawan); lunch boxes; Japanese style tea cups (yunomi); Japanese style soup serving bowls (wan); non- electric portable coldboxes; rice chests; food preserving jars of glass; drinking flasks; vacuum bottles; piggy banks in class 021. For: Towels; Japanese cotton towels (tenugui); handkerchiefs; mosquito nets; bedsheets; futon quilts; fitted futon covers not of paper, unfitted futon covers not of paper; quilt covers; futon ticksticks, namely, unstuffed futon covers not of paper; Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 18 of 111
19 pillowcases; blankets, namely, lap blankets, bed blankets and baby blankets; table napkins of textile; dish cloths; shower curtains; banners and flags of textile; seat covers of textile, namely, fitted toilet seat covers of textile, unfitted seat covers of textile; wall hangings of textile; curtains; table cloths not of paper; draperies in the nature of thick drop curtains in class 024. For: Lottery tickets; amusement game machines and apparatus, namely, coin- operated amusement machines for use in amusement parks; arcade video game machines other than for use with television receivers; coin, card or counter operated electronic arcade-type video games and amusement apparatus adapted for use with an external display screen or monitor, amusement apparatus incorporating a video monitor; arcade medal redemption game machines, namely, arcade redemption game machines which dispenses tickets or the like to successful players; arcade ticket redemption game machines, namely, arcade redemption game machines which dispenses tickets or the like to Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 19 of 111
20 successful players; arcade game machines other than for use with television receivers; coin, card or counter operated electronic arcade-type video games and amusement apparatus, namely, amusement apparatus adapted for use with an external display screen or monitor; fairground ride apparatus, namely, amusement park rides; home video game machines; hand-held games with liquid crystal displays; toys, namely, rubber character toys, plastic character toys, wooden character toys, electronic character toys, educational character toys, party favors in the nature of small toys; squeeze toys; dolls; stuffed toys; action figures; puzzles; jigsaw puzzles; cards, namely, game cards; trading card games; go games; Japanese playing cards, namely, utagaruta; Japanese chess (shogi games); dice; Japanese dice games (sugoroku); dice cups; Chinese checkers as games; chess games; checkers; checker sets; conjuring apparatus, namely, magic tricks; dominoes; playing cards; Japanese playing cards (hanafuda); mah- jong; game machines and apparatus, namely, coin- Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 20 of 111
21 operated video games; billiard equipment; darts equipment, namely, darts, dart shafts, dart boards; digital darts equipment, namely, electronic dart game; slot machines; sports equipment, namely, baseball bats, baseball gloves and baseball batting helmets, soccer balls, basketballs, hockey skates, skis in class 028. For: Tea; coffee; cocoa; confectionery, namely, confectionery made of sugar, confectionery, namely, pastilles, fondants, fruit jellies candy, chocolate, popcorn and chewing gum; bread and buns; sandwiches; steamed buns stuffed with minced meat (niku-manjuh); hamburger sandwiches; pizzas; hot dog sandwiches; meat pies; ice cream; pasta, macaroni, oatmeal, flakes, namely, corn flakes, oat flakes, maize flakes; pastry; bread; Chinese stuffed dumplings (gyoza, cooked); Chinese steamed dumplings (shumai, cooked); sushi; fried balls of batter mix with small pieces of octopus, namely, takoyaki; boxed lunches consisting primarily of rice, with added meat, fish or vegetables; ravioli; instant confectionery mixes, namely, Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 21 of 111
22 instant pudding mix, cake mixes, sherbet mixes and ice cream mixes; crepes; pasta sauce; biscuits; cookies in class 030. For: Carbonated drinks, namely, carbonated soft drinks; fruit juices; vegetable juices; whey beverages in class 032. For: Providing non- downloadable electronic publications in the nature of magazines, newsletters, picture books and comic books in the field of computer games, video games and animated cartoons; services of reference libraries for literature and documentary records; book rental; providing on-line electronic publications via internet or database including websites in the nature of magazines, news letters, picture books and comic books in the field of computer games, video games and animated cartoons; planning or arrangement of showing movies, live show performances, plays or musical performances; movie showing, movie film production, or movie film distribution; providing on-line images, movies, moving images and Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 22 of 111
23 graphics in the field of computer games, video games and animated cartoons; providing on-line images, movies, moving images and graphics by computer terminals or mobile phones; entertainment in the form of non-downloadable images relating to fictional characters from books, animation, toys and games; direction or presentation of plays; providing on-line music, not downloadable, via computer terminals or mobile phones; organization of game tournaments; entertainment services, namely, providing amusement park rides in the nature of bumper car ride and roller coaster ride; providing amusement facilities; providing amusement arcade services; providing amusement parks; providing on-line video games; providing on-line board games; providing on-line quizzes; providing information relating to on-line computer games; providing on-line computer games; providing information relating to providing on-line computer games; providing information, in websites offering on-line video games, consisting of the game scores achieved by players of the games on the Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 23 of 111
24 website and the rankings of such players based on those scores; production of radio or television programs; television entertainment, namely, a continuing animated cartoons, variety, news, comedy show broadcast over television; production of radio and television programs; radio entertainment, namely, a continuing animated cartoons, variety, news, comedy show broadcast over the radio, radio entertainment production in class 041. 2,892,207 Oct. 12, 2004 For: Video game software; computer game programs; computer game discs video computer game programs; home video computer game discs game discs containing game programs for use with hand-held video game machines with built-in screens; musical sound recordings; in class 009. 4,366,529 Jul. 16, 2013 For: Computer game programs; computer game software; video game software; video game programs; video game discs and cartridges; computer game software for use on mobile and cellular phones; downloadable graphics and images featuring fictional characters or video games, and music via a global computer network; Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 24 of 111
25 downloadable graphics and moving images for mobile phones featuring fictional characters or video games in class 009. 3,972,721 Jun. 7, 2011 For: Computer game programs; video game software; video game programs in class 009. 6,187,305 SONIC RACING Nov. 3, 2020 For: Downloadable computer game programs; recorded computer game programs; downloadable computer game software; recorded computer game software; downloadable video game software; recorded video game software; downloadable video game programs; recorded video game programs; video game discs and cartridges; downloadable computer game software for use on mobile and cellular phones; mobile phone straps; protective cases for cell phones; downloadable graphics, images and moving images for computers, video game machines or mobile phones featuring scenes and characters based on computer and video games; downloadable computer game and video game software; downloadable music files via a Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 25 of 111
26 global computer network and wireless devices; sound recorded compact discs featuring music, video game sounds and dialogues; compact discs, magnetic tapes, and downloadable files featuring musical sound recordings; prerecorded video discs and tapes featuring music, comedy, drama, action, adventure and animation; electronic publications, namely, downloadable books and magazines in the field of computer games, video games, cartoons and music; phonograph records featuring music in class 009. For: Entertainment services, namely, providing on-line video games and on-line computer games; providing entertainment information on on-line games; providing non- downloadable on-line computer graphics, moving images and images featuring scenes and characters based on computer and video games by computer networks, video game machines or mobile phones; providing amusement facilities; providing amusement arcade services; providing amusement parks; organization, production and presentation of video and Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 26 of 111
27 computer game contests and tournaments; providing entertainment information about amusement facilities; providing on-line music, not downloadable in class 041. 6,263,485 TEAM SONIC RACING Feb. 9, 2021 For: Downloadable computer game programs; recorded computer game programs; downloadable computer game software; recorded computer game software; downloadable video game software; recorded video game software; downloadable video game programs; recorded video game programs; video game discs and cartridges; downloadable computer game software for use on mobile and cellular phones; downloadable computer game and video game software in class 009. For: Pastes and other adhesives for stationery or household purposes; hygienic hand towels of paper; table napkins of paper; hand towels of paper; handkerchiefs of paper; stationery; stickers; printed matter, namely, comic books, instruction manuals in the field of computer games and video games, children's books, children's activity books, songbooks, children's magazines and magazines in Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 27 of 111
28 the field of computer games, video games, cartoons and music; picture books, reference books in the field of computer games, video games, cartoons and music; catalogues in the field of computer games, video games, cartoons and music; calendars; general feature magazines in the field of computer games, video games, cartoons and music; books, namely, coloring books, date books; pamphlets in the field of computer games, video games, cartoons and music; trading cards other than for games; printed instructional and teaching material in the field of computer games, video games, cartoons and music; photographs; photograph stands in class 016. For: Clothing, namely, t-shirts, shirts, sweaters, sweatshirts, jackets, pajamas, coats, swimwear, mufflers as neck scarves, gloves, scarves, neck ties, socks, underwear, pants, jeans, shorts, skirts, underpants, robes; shoes; boots; footwear; beach shoes; galoshes; half-boots; lace boots; sandals; sneaker; sports shoes; wooden shoes; heels, namely, high-heel shoes; masquerade costumes; play costumes, namely, costumes for use in Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 28 of 111
29 children's dress up play, costumes for use in role- playing games; clothes for sports, namely, sports jerseys and breeches for sports; boots for sports; headwear, namely, hats and caps in class 025. For: Coin-operated video games; arcade game machines; arcade video game machines; amusement game machines with built-in screens; toy vehicles; dolls; stuffed toys; toy action figures; trading card games; playing cards; arcade redemption game machines which dispense tickets or tokens to successful players; arcade crane game machines which dispense tickets or tokens to successful players; gaming machines, namely, slot machines in class 028. For: Tea; prepared coffee and coffee-based beverages; prepared cocoa and cocoa- based beverages; almond confectionery, namely, almond cookies, chocolate confectionery, namely, chocolate mousses, chocolate cakes and chocolate chips, confectionery fondants, namely, rolled fondant, confectionery fruits jellies, namely, fruit jelly candy, confectionery fruits pastes, Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 29 of 111
30 namely, fruit paste for flavoring of food, peanut confectionery, namely, peanut brittle and peanut butter confectionery chips, fruits- based confectionery, namely, fruit coulis, fruit turnovers and fruit cobblers; bread and buns; sandwiches; hamburgers sandwiches; pizzas; hot dog sandwiches; meat pies; ice cream; preparations made from cereals, namely, cereal- based snack bars; sushi; ravioli; instant confectionery mixes, namely, cappuccino mixes, hot chocolate mixes and biscuit mixes; crepes; pasta sauce; biscuits; cookies in class 030. For: Beer; fruit-flavored carbonated drinks; fruit juices; vegetable juices; extracts of hops for making beer; whey beverages in class 032. For: Entertainment services, namely, providing on-line video games and on-line computer games; organization, production and presentation of video and computer game contests and tournaments in class 041. 7,002,602 SONIC PRIME Mar. 21, 2023 For: Downloadable computer game programs; recorded computer game programs; Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 30 of 111
31 downloadable computer game software; recorded computer game software; downloadable video game software; recorded video game software; downloadable video game programs; recorded video game programs; video game discs and cartridges; downloadable computer game software for use on mobile and cellular phones; mobile phone straps; protective cases for cell phones; downloadable graphics, images, and video recordings for computers, video game machines and mobile phones featuring scenes and characters based on computer and video games; downloadable computer game and video game software; downloadable music files via a global computer network and wireless devices; sound recordings recorded on compact discs featuring music, video game sounds and dialogues; prerecorded compact discs, magnetic audio tapes, and downloadable files featuring music; prerecorded video discs and magnetic audio tapes featuring music, comedy, drama, action, adventure and animation; electronic publications, namely, downloadable books and magazines in the field of Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 31 of 111
32 computer games, video games, cartoons and music; phonograph records featuring music; animated cartoons, namely, videotapes and videodiscs recorded with animation; downloadable electronic publications in the nature of books, manuals, catalogs, pamphlets, and magazines in the field of computer games, video games, cartoons and music; pedometers; scales; bathroom scales in class 009. For: Pastes and other adhesives for stationery or household purposes; hygienic hand towels of paper; towels of paper; table napkins of paper; hand towels of paper; handkerchiefs of paper; stationery; seals being stationery; stickers being stationery; blank notepads; decorative stickers for portable game machines; printed instruction manuals in the field of computer games, video games, cartoons and music; printed picture books; printed reference books in the field of computer games, video games, cartoons and music; printed catalogues in the field of computer games, video games, cartoons and music; printed calendars; printed magazine Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 32 of 111
33 publications in the field of computer games, video games, cartoons and music; printed books in the field of computer games, video games, cartoons and music; printed pamphlets in the field of computer games, video games, cartoons and music; printed trading cards, other than for games; printed game hint books and manuals; printed photographs; photograph stands in class 016. For: Clothing for domestic pets; bags, namely, carry-on bags; shoulder bags; school bags; traveling bags; pouches of leather; boston bags; rucksacks; key cases; wallets; credit card cases; vanity cases, not fitted; umbrellas and their parts; walking sticks; canes; metal parts of canes and walking-sticks; handles for canes and walking-sticks; saddlery in class 018. For: Clothing, namely, t-shirts, shirts, sweaters, sweatshirts, jackets, pajamas, coats, swimwear, mufflers, gloves, scarves, neck ties, socks, underwear, pants, jeans, shorts, skirts, underpants, robes; footwear; beach shoes; boots; galoshes; half-boots; lace boots; sandals; sneakers; Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 33 of 111
34 shoes; sports shoes; wooden shoes; high-heeled shoes; masquerade costumes; play costumes, namely, costumes for use in children's dress up play, costumes for use in role- playing games; clothes for sports namely, sports jerseys and breeches for sports; boots for sports; headwear, namely hats and caps in class 025. For: Toy vehicles; dolls; plush dolls; stuffed toys; toy action figures; toy for pets; toy jewelry; bath toys; electronic action toys; plastic character toys; children's educational toys for developing cognitive skills; construction toys; puzzles; children's multiple activity toys; toy building sets comprised of toy building blocks; novelty toy face masks; trading card games; playing cards; coin-operated video games; arcade game machines; arcade video game machines; amusement game machines with built-in screens; arcade redemption game machines which dispense tickets or tokens to successful players; arcade crane game machines which dispense tickets or tokens to successful players in class 028. For: Tea; prepared coffee and Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 34 of 111
35 coffee-based beverages; prepared cocoa and cocoa- based beverages; almond confectionery, namely, cookies; chocolate confectionery; confectionery fondants; confectionery fruit jellies, namely, fruit jelly candy; confectionery fruit pastes for flavouring of food; peanut confectionery, namely, peanut brittle and peanut butter confectionery chips; fruit-based confectionery, namely, hollow candy forms filled with fruit; bread and buns; steamed buns stuffed with minced meat; meat pies; ice cream; cereal preparations¸, namely, cereal- based snack bars; Chinese stuffed dumplings; Chinese steamed dumplings; sushi; pre- packaged boxed lunches consisting of rice, with added meat, fish or vegetables; ravioli; instant confectionery mixes¸, namely, cappuccino mixes, hot chocolate mixes, cocoa mixes, cake mixes, cookie mixes, pastry mixes, crepe mixes, mixes for bakery goods, biscuit mixes, instant pudding mixes, mixes for candy making, frosting mixes, frozen yogurt mixes, pre-processed mixes for making non-dairy frozen confections; crepes; pasta sauce; biscuits; cookies in class 030. Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 35 of 111
36 For: Entertainment services, namely, providing on-line video games and on-line computer games; providing information on on-line games; providing non-downloadable on-line computer graphics, videos and images featuring scenes and characters based on computer and video games by computer networks, video game machines or mobile phones; providing amusement facilities; organization, production and presentation of video and computer game events; arranging and conducting of video game and computer game events for entertainment purposes; organization or arrangement of game tournaments; providing information about amusement facilities; providing on-line music, not downloadable; providing electronic publications in the nature of books, manuals, catalogs, pamphlets, and magazines in the field of computer games, video games, cartoons and music; services of reference libraries for literature and documentary records; book rental; planning, management or arrangement of showing movies, theatrical shows, plays or musical performances; Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 36 of 111
37 providing information relating to planning, management or arrangement of showing movies, theatrical shows, plays or musical performances; movie showing, movie film production, or movie film distribution; providing information relating to providing on-line graphics, movies showing, moving images, images, music and publishing of electronic publications; providing on-line graphics, movies showing, moving images, images, music and text information by computer terminals or mobile phones; providing information relating to providing on-line graphics, movies showing, moving images, images, music and publishing of electronic publications by computer terminals or mobile phones; providing on-line graphic novels, not downloadable, relating to characters of books, animated cartoons, toys, games; images showing; presentation of live show performances; direction or presentation of theatrical plays; presentation of musical performances; on-line presentation of shows, theatrical plays or musical performances; providing information relating to on-line Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 37 of 111
38 presentation of shows, theatrical plays or musical performances; provision of shows, theatrical plays or musical performances by computer terminals or mobile phones; providing information relating to provision of shows, theatrical plays or musical performances by computer terminals or mobile phones; production of theatrical shows; production of live theatrical and musical shows; presentation of musical performances, direction or presentation of theatrical plays and presentation of musical performances provided on-line from a computer network; production of moving images and music using the internet via streaming; production of moving images and music relating to animated cartoons using the internet via streaming; on-line production of radio or television programs; production of radio or television programs and production of broadcast programs, using computer graphics; directing of radio and television programs; providing information relating to direction of radio and television programs; organization of sporting events; providing sports Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 38 of 111
39 information; organization and provision of games and competitions via the internet; organization, arranging and conducting of computer game and video game tournaments; organization, arranging and conducting of photo sessions; providing information relating to sports and sporting events; organizing and conducting of sporting and cultural events; rental of game machines and apparatus; providing exercise facilities; rental of sports equipment; photography in class 041. 1,566,116 Nov. 14, 1989 For: Video game attachments for television sets, namely, video game control sticks, video game programs recorded on integrated circuits in the form of cartridges and cards in class 028. 5,808,893 Jul. 23, 2019 For: Apparatus and instruments for conducting, switching, transforming, accumulating, regulating or controlling electricity; apparatus for recording, transmission or reproduction of sound or images; prerecorded magnetic data carriers, recording discs, compact discs, DVDs and computer media featuring scenes and characters from computer and video games; Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 39 of 111
40 mechanisms for coin-operated apparatus; cash registers, calculating machines, data processing equipment, computers; computer software for playing video games; computer software for database management; computer software for controlling and managing business data; fire- extinguishing apparatus; computer software development tools; downloadable computer file sharing software to enable uploading, downloading, accessing, posting, displaying, tagging, blogging, streaming, linking, sharing or otherwise providing electronic media or information via computer and communication networks; computer programs, namely, downloadable software for playing video games; programs for cell phones, namely, downloadable software for playing video games; game programs for smartphones, namely, downloadable computer game software; programs for smartphones, namely, downloadable software for playing video games; downloadable computer game programs for handheld terminals; coils, electric; particle accelerators; reflecting Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 40 of 111
41 discs for wear, for the prevention of traffic accidents; clothing for protection against accidents, irradiation and fire; accumulator jars; battery boxes; acidimeters for batteries; hydrometers; plates for batteries; whistle alarms; acoustic sound alarms; acoustic conduits; speaking tubes; actinometers; adding machines; aerometers; enlarging apparatus for photography; electro-dynamic apparatus for the remote control of railway points; magnets; electromagnetic coils; air analysis apparatus; alcoholmeters; alidades; igniting apparatus, electric, for igniting at a distance, namely, remote control starters for vehicles; batteries for lighting; altimeters; asbestos gloves for protection against accidents; asbestos clothing for protection against fire; ammeters; amplifiers; amplifying tubes for amplifiers; anemometers; fire extinguishers; anodes; anode batteries; electrical transformers; optical apertometers; money counting and sorting machines; surveying instruments; surveying chains; lenses for astrophotography; mechanisms for coin-operated apparatus; comparators; fire alarms; Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 41 of 111
42 automatic indicators of low pressure in vehicle tires; protective suits for aviators; alarm bells, electric for use with burglar alarms; rods for water diviners; life-saving rafts; scales; meteorological balloons; demagnetizing apparatus for magnetic tapes; tape recorders; blank magnetic computer tapes; barometers; weighing machines; weighbridges; fire beaters; chargers for electric batteries; betatrons; ticket dispensers, namely, video lottery ticket terminals, electronic parking lot ticket dispensers; cabinets for loudspeakers; close-up lenses; electricity terminals; pressure indicator plugs for valves; galvanometers; electrical push buttons for door bells; electrical branch distribution boxes; tone arms for record players; spirit levels; punched card machines for offices; sheaths for electric cables; frames for photographic transparencies; circular slide rules; slide-rules; slide calipers; blueprinting machines; cinematographic cameras; capillary tubes for laboratory research use; protective helmets; respiratory masks, other than for artificial respiration or medical purposes; solderers' helmets; Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 42 of 111
43 eyeglass chains; photography darkroom equipment, namely, lamps; boiler control instruments; drying racks for photography; editing appliances for cinematographic films; printed circuits; blinkers being traffic light signaling lights; signal bells; containers for microscope slides; electric installations for the remote control of industrial operations; switchboxes for electricity; commutators; marine compasses; eyepieces, namely, spectacles; thread counters; pedometers; metronomes; condensers; conductors, electric; electricity conduits; circuit closers; electrical connectors; junction boxes; contacts, electric; regulating apparatus, electric; speed checking apparatus for vehicles, namely, laser speed detectors; converters, electric; photographic, electrostatic, and thermic photocopiers; eyeglass cords; correcting lenses; objectives lenses; diving suits; electric apparatus for commutation, namely, commutators; switches, electric; electricity limiters; electrical connections, namely, sockets, plugs and other contacts; current rectifiers; cell switches for electricity; dressmakers' tape measures; Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 43 of 111
44 crucibles for laboratory use; appliances for measuring the thickness of leather; cyclotrons; counterfeit false coin detectors; shutter release; densimeters; video disks and tapes with recorded animated cartoons; laboratory trays; metal detectors for industrial or military purposes; sonars; shutters for cameras; acoustics diaphragms for use in sound recording; centering apparatus for photographic transparencies; cameras; photographic transparencies; slide projectors; dictating machines; diffraction apparatus for use in microscopy; loudspeakers; circuit breakers; record players; microscopes; distance recording apparatus; range finders; distribution boards for use with electricity; distribution consoles for use with electricity; compasses being measuring instruments; tape measures; dynamometers; water level indicators; fire escapes, namely, ladders; flash-bulbs for photography; telephone receivers; fluorescent screens; projection screens; workmen's protective face-shields; screens for photography; drainers for use in photography; electric loss indicators; cables, electric; Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 44 of 111
45 electricity ducts; control panels for use in electricity; connections for electric lines; couplings, electric; relays, electric; electrolysers; transmitters of electronic signals; transmitting sets comprising transmitters for use in telecommunication; blank sound recording magnetic strips; spools for cameras; mechanical signs; epidiascopes; test tubes for laboratory use; balancing apparatus namely, balances; thermostats; egg-candlers; fuel gauges; gasoline gauges; spark-guards for protection against injury; cases especially made for photographic apparatus and instruments, namely, video cameras; refractometers; exposure meters being light meters; invoicing machines, namely, printers; apparatus for fermentation being laboratory apparatus; wires, electric; magnetic wires; plumb bobs; plumb lines; nets for protection against accidents; safety nets; safety tarpaulins; film cutting apparatus; filters for respiratory masks for laboratory use; camera filters for use in photography; battery chargers; frequency meters; fuses; radios; galena crystals detectors for use in electronics; Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 45 of 111
46 galvanic batteries; gloves for protection against accidents; gloves for divers; gloves for protection against X-rays for industrial purposes; gas testing instruments; gasometers being measuring instruments; surveying apparatus and instruments; leveling staffs being surveying instruments; drying apparatus for photographic prints; glazing apparatus for photographic prints; rulers being measuring instruments; measuring glassware; screens for photoengraving; grids for batteries; clothing for protection against fire; audio- and video-receivers; heliographic apparatus; hygrometers; identification threads for electric wires; identification sheaths for electric wires; life saving apparatus and equipment, namely, flotation vests; fire hose nozzles; fire engines; fire trucks; slope indicators; taximeters; quantity indicators; vacuum gauges; speed indicators; electricity inductors; armatures for use in electricity apparatus; data processing apparatus; mirrors for inspecting work; carriers for dark plates in photography; electricity inverters; ionizers for scientific or laboratory use; Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 46 of 111
47 peepholes, namely, magnifying lenses for doors; furniture especially made for laboratories; lactodensimeters; lactometers; darkroom lamps for photography; magic lanterns; signal lanterns for safety purposes; lasers, not for medical purposes; optical lenses; letter scales; magnifying glasses; signs, luminous; neon signs; spectacles; surveyors' levels; spectacle lenses; pressure gauges; periscopes; coin- operated mechanisms for television sets; megaphones; computer memory devices; carpenters' rules; mercury levels; speed measuring apparatus for use in photography; microphones; microtomes; time switches, automatic; optical mirrors; breathing apparatus for underwater swimming; electric navigational instruments; spectacle frames; batteries, electric; accumulators, electric; optical prisms for scientific purposes; octants; ohmmeters; wavemeters; optical glass for use with spectacles; computers; oscillographs; oxygen transvasing apparatus; ozonisers; micrometers; signaling panels, luminous or mechanical for traffic purposes; lightning conductors Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 47 of 111
48 being rods; parking meters; apparatus for measuring the thickness of skins for laboratory use; acid hydrometers; weighing apparatus and instruments; salinometers; washing trays for use in photography; stands for photographic apparatus; viewfinders, photographic; photometers; phototelegraphy apparatus; pince-nez; pipettes; plane tables being surveying instruments; planimeters; ear plugs for divers; bells for use as warning devices; test weights; polarimeters; radiotelephony sets; radiotelegraphy sets; pressure measuring apparatus; pressure indicators; mouth guards for athletic use; pyrometers; radar apparatus; vehicle radios; protractors being measuring instruments; apparatus and installations for the production of X-rays, not for medical purposes; X-ray tubes not for medical purposes; protection devices against X-rays, not for medical purposes; telephone apparatus; refractors for laboratory use; X-ray apparatus not for medical purposes; spectroscopes; resistances, electric; thermometers, not for medical purposes; respirators for filtering air other than for Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 48 of 111
49 artificial respiration; breathing apparatus, except for artificial respiration for underwater use; rheostats; balances for use in steelyards; emergency signals, luminous or mechanical; saccharometers; electrical probes for scientific purposes; satellites for scientific purposes; choking coils for electrical impedance; electricity wire connectors; locks, electric; sextants; signaling whistles; vehicle breakdown warning triangles; electro-dynamic apparatus for the remote control of signals; simulators for the steering and control of vehicles; sirens; sound transmitting apparatus; sound recording apparatus; sound reproduction apparatus; spherometers; stereoscopes; needles for record players; sulfitometers; teleprinters; tachometers; screw-tapping gauges; telegraph transmitting apparatus; television apparatus for projection purposes; telegraph wires; masts for wireless aerials; teleprompters; telephone transmitters; teleruptors; binoculars; telescopes; temperature indicators; time recording apparatus; theodolites; thermostats for vehicles; revolution counters; speed regulators for record Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 49 of 111
50 players; television transmitters; radio transmitters; precision balances; marking gauges for joinery; vacuum tubes for radios; urinometers; variometers; verniers; blank videotapes; viscosimeters; voltage regulators for vehicles; voting machines; voltmeters; apparatus for changing record player needles; stills for laboratory experiments; fuse wire; anticathodes; dog whistles; electrical anti-theft warning apparatus for personal use; beacons, luminous; holders for electric coils; photographic films, exposed; road signs, luminous or mechanical; life buoys; signaling buoys; electric buzzers; directional compasses; fog signals, non-explosive; cash registers; radiology screens for industrial purposes; identity cards, magnetic; photovoltaic cells; densitometers not for medical use; blank disks, magnetic; blank floppy disks; head cleaning tapes for use in recording sound and video; video recorders; computer keyboards; integrated circuits; semi-conductors; integrated circuit chips; cathodes; life jackets; life belts; cinematographic film, exposed; materials for electricity mains, Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 50 of 111
51 namely, wires, cables; contact lenses; containers for contact lenses; incubators for bacteria culture; solar batteries; copper wire, insulated; discharge tubes, electric, other than for lighting; diaphragms for use in photography; distillation apparatus for scientific purposes; dosage dispensers, namely, machines for dispensing pre-determined dosages of medication; electric door bells; spectacle cases; furnaces for laboratory use; optical fibers, namely, fibers being light conducting filaments; telephone wires; x- ray films, exposed; filters for ultraviolet rays, for photography; horns for loudspeakers; tripods for cameras; bar code readers; bullet-proof waistcoats and vests; marking buoys; wafers for integrated circuits; chromatography apparatus for laboratory use; chronographs being time recording apparatus; blank compact discs for audio-video; blank compact discs for read-only memory; computer peripheral devices; optical condensers; acoustic couplers; couplers being data processing equipment; decompression chambers; plotters; divers' masks; electronic pens with Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 51 of 111
52 visual display units; encoded magnetic cards, namely, charge cards, debit cards, identify cards; facsimile machines; fire boats; interfaces for computers; juke boxes for computers; knee-pads for workers; light dimmers being electric regulators; magnetic encoders; magnetic tape units for computers; microprocessors; modems; monitors being computer hardware; computer monitors; mouse being a computer peripheral; optical character readers; printers for use with computers; processors being central processing units; readers being data processing equipment; scanners being data processing equipment; smoke detectors; electronic transistors; x-ray photographs, other than for medical purposes; junction sleeves for electric cables; abacuses; electronic agendas; answering machines; camcorders; cassette players; compact disc players; disk drives for computers; electrified rails for mounting spot lights for emergency use; electronic pocket translators; electronic tags for goods; fire blankets; flashlights for use in photography; integrated circuit cards, namely, blank smart cards; measuring spoons; Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 52 of 111
53 notebook computers; electronic notice boards; pocket calculators; shoes for protection against accidents, irradiation and fire; sprinkler systems for fire protection; battery starter cables for motors; sunglasses; time clocks being time recording devices; blank video cassettes; video game cartridges; video screens; video telephones; goggles for sports; nose clips for divers and swimmers; protective helmets for sports; downloadable electronic publications, namely, books featuring scenes and characters from computer and video games; navigation apparatus for vehicles being on-board computers; decorative magnets; cordless telephones; mouse pads; personal stereos; wrist rests for use with computers; coaxial cables; fiber optic cables; covers for electric outlets; marine depth finders; electrified fences; computer game software; headphones; lighting ballasts; radio pagers; satellite navigational apparatus, namely, GPS; solenoid valves being electromagnetic switches; voltage surge protectors; walkie-talkies; wind socks for indicating wind direction; light-emitting electronic Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 53 of 111
54 pointers; resuscitation mannequins being teaching apparatus; stage lighting electrical regulators; egg timers, namely, sandglasses; DNA chips; DVD players; automated teller machines (ATM); traffic-light apparatus being signaling devices; hands free kits for phones; asbestos screens for firemen; riding helmets; clothing especially made for laboratories; encoded identification bracelets, magnetic; transponders; downloadable ring tones for mobile phones; downloadable music files; downloadable image files; crash test dummies; laboratory centrifuges; printed circuit boards; blank USB flash drives; global positioning system (GPS) apparatus; portable media players; cell phone straps; light emitting diodes (LEDs); triodes; step-up transformers; laptop computers; fire hose; bags adapted for laptops; sleeves for laptops; digital photo frames; petri dishes; pitot tubes; stroboscopes; safety traffic cones; temperature indicator labels, not for medical purposes; electronic book readers; smartphones; toner cartridges, unfilled, for printers and photocopiers; Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 54 of 111
55 baby monitors; video baby monitors; lens hoods; tablet computers; encoded key cards; 3D spectacles; memory cards for video game machines; bullet-proof clothing; accelerometers; electrical adapters; life-saving capsules for natural disasters; computer hardware; solar panels for the production of electricity; telescopic sights for artillery; digital signs; electronic sports training simulators; computer game cartridges; computer game programs; computer game software downloadable from a global computer network; computer programs for video and computer games; interactive multimedia computer game programs; computer game discs; downloadable computer game programs; electronic game programs; electronic game software; interactive video game programs; recorded computer game programs; video game discs; video game programs; video games software; virtual reality game software; audio tapes featuring music; cases for telephones; cellular phones; compact discs featuring music; prerecorded audio tapes featuring music; prerecorded video cassettes featuring music in class 009. Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 55 of 111
56 For: Printed matter namely, comic books, video game instruction manuals, children's books, children's activity books, songbooks, children's magazines, magazines and pamphlets featuring information and articles about fashion and games; bookbinding material; photographs; stationery; adhesives for stationery or household purposes; paint brushes; printers' type; printing blocks; steel letters for use in printing; steel pens; adhesive tape dispensers being office requisites; address stamps; addressing machines; paper; posters; printed advertisement boards of paper or cardboard; franking machines for office use; clips for letters; paper clips; binder clips; clips for name badge holders; pen clips; stapling presses; photo albums; pictures; print engravings; cigar bands; pencil sharpening machines, electric or non- electric; bookends; hand-rests for painters; aquarelles; architects' models; document files being stationery; writing slates; slate pencils; silver paper; modelling clay; printed arithmetical tables; print engravings; lithographic works Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 56 of 111
57 of art; paintings and pictures, framed or unframed; pencils; newspapers; atlases; loose-leaf binders; gummed tape; place mats of paper for beer glasses; printed tickets; printing blocks; drawing pads; pads for writing being stationery; spools for inking ribbons; wristbands for the retention of writing instruments; pamphlets in the field of computer games, video games, animated films and animated cartoons; embroidery designs being printed patterns; drawing pins; moisteners being office requisites; painters' brushes; blotters; stamps seals; sealing stamps; inking pads; sealing wax; envelope sealing machines for offices; sealing compounds for stationery purposes; writing or drawing books; trays for sorting and counting money; tracing patterns; tracing paper; tracing cloth; finger-stalls being office requisites; printing type; carbon paper; paper for recording machines; note books; square rulers for drawing; greeting cards; index cards; paper sheets for note taking; cardboard; hat boxes of cardboard; perforated cards for jacquard looms; cardboard tubes; catalogs in the field of computer games, video games, Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 57 of 111
58 animated films and animated cartoons; tags for index cards; song books; composing frames for printing; folders for papers; painters' easels; numbers for printing type; Indian inks; chromolithographs; modelling wax, not for dental purposes; paper files; office perforators; toilet paper; books in the field of computer games, video games, animated films and animated cartoons; compasses for drawing; printers' type numerals and letters; letter trays; conical paper bags; correcting fluids for type; correcting ink for use in heliography; pencil leads; histological sections for teaching purposes; French curves; book covers; writing chalk; chalk for lithography; tailors' chalk; writing chalk and marking chalk holders; pencil holders; pencil lead holders; cream containers of paper, namely, paper boxes for use as food packaging; paper clasps; rollers for typewriters; transfers being decalcomanias; graphic prints; graining combs; drawing boards; drawing instruments; diagrams for building computer circuits; envelopes for use as stationery; duplicators, namely, duplicating paper, machines, ink; etchings; packing paper; Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 58 of 111
59 pen nibs; typewriters, electric or non-electric; pen cases; nibs of gold for pens; erasing products, namely, erasers; drawing shields; erasing shields; rubber erasers; electrocardiograph paper; hand-operated and electric hole punches being office requisites; writing and drawing ink; inking ribbons; inkwells; envelope sealing machines for offices; printed, photographs; pen wipers; sealing stamps; fabrics for bookbinding; ledger books; telephone indexes; figurines being statuettes of papier mâché; filter paper; filtering materials in the nature of paper; forms, printed; charcoal pencils; stencils; galley racks for printing; electrotypes; geographical maps; terrestrial globes; artists' watercolor saucers; graphic art reproductions; graphic representations; scrapers being erasers for offices; engraving plates; hectographs; printed timetables; moisteners for gummed surfaces being office requisites; postcards; hand labeling appliances, namely, label printing machines; printers' blankets, not of textile; manuals being handbooks in the field of computer games, video games, Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 59 of 111
60 animated films and animated cartoons; writing paper; paperweights; tracing needles for drawing purposes; drawing pens; table linen of paper; lithographs; lithographic stones; booklets in the field of computer games, video games, animated films and animated cartoons; luminous paper; papier mâché; manifold paper; marking chalk; plastics for modeling, namely, polymer modelling clay; modelling compounds; modelling paste; handkerchiefs of paper; inking sheets for duplicators; tablecloths of paper; blackboards; paper-clips; oleographs; binding strips for use in bookbinding; sealing wafers for stationery purposes; palettes for painters; pantographs being drawing instruments; stationery; parchment paper; pastels being crayons; printed sewing patterns; stencil cases; house painters' rollers; canvas for painting; paint boxes being articles for use in school; plastic film for wrapping; apparatus for mounting photographs, namely, photograph mounts; photograph stands; photo- engravings; blueprints; stationery folders; fountain pens; stencil plates; stencils; Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 60 of 111
61 portraits; flower-pot covers of paper; mimeograph apparatus and machines; paper tapes and cards for the recordal of computer programs; printed prospectuses in the field of computer games, video games, animated films and animated cartoons; paper for radiograms; drawing rulers; printers' reglets; bookbinding material; bookbindings; cloth for bookbinding; cords for bookbinding; inking sheets for document reproducing machines; pens being office requisites; magazines in the field of computer games, video games, animated films and animated cartoons; paper ribbons; typewriter ribbons; bags of paper or plastics, for merchandise packaging; stamp pads; school supplies, namely, stationery; bookmarkers; greeting cards; steatite tailor's chalk; balls for ball-point pens; tablemats of paper; desk mats; typewriter keys; holders for stamping seals; cases for stamping seals; postage stamps; stamp stands; paper transparencies; gluten glue for stationery or household purposes; adhesives glues for stationery or household purposes; adhesive tapes for stationery or household purposes; adhesive bands for Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 61 of 111
62 stationery or household purposes; address plates for addressing machines; almanacs; calendars; starch paste adhesive for stationery or household purposes; paintbrushes; self-adhesive tapes for stationery or household purposes; elastic bands for offices; bibs of paper; wood pulp paper board for stationery purposes; wood pulp paper; boxes of cardboard or paper; stands for pens and pencils; bottle envelopes of cardboard or paper; coasters of paper; announcement cards; plastic bubble packs for wrapping or packaging; flags of paper; paper shredders for office use; sheets of reclaimed cellulose for wrapping; desktop cabinets for stationery; glue for stationery or household purposes; paper knives being letter openers; garbage bags of paper or of plastics; pencil sharpeners, electric or non- electric; tissues of paper for removing make-up; table napkins of paper; place mats of paper; drawing squares; drawing t-squares; penholders; inkstands; writing cases, namely, sets of pencils; bottle wrappers of cardboard or paper; placards of paper or cardboard; towels of paper; face towels of paper; labels of Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 62 of 111
63 paper, cardboard; etching needles; viscose sheets for wrapping; gums being adhesives for stationery or household purposes; gummed cloth for stationery purposes, namely, bookbinding; isinglass for making glue for stationery or household purposes; bags for microwave cooking; paper coffee filters; plastic cling film, extensible, for palletization; inking ribbons for computer printers; signboards of paper or cardboard; stickers; bookbinding apparatus in the nature of machines being office equipment; comic books; copying paper; holders for checkbooks; ink sticks; ink stones; musical greeting cards; newsletters in the field of computer games, video games, animated films and animated cartoons; packaging material made of paper based starches; waxed paper; passport holders; writing brushes; writing instruments; drawer liners of paper, perfumed or not; credit card imprinters, non-electric; document laminators for office use; Xuan paper for Chinese painting and calligraphy; writing board erasers; clipboards; chart pointers, non- electronic; paper bows for gift wrapping; moulds for modeling clays being artists' materials; Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 63 of 111
64 money clips; trading cards other than for games; absorbent sheets of paper or plastic for foodstuff packaging; humidity control sheets of paper or plastic for foodstuff packaging; correcting tapes being office requisites; paint trays; marking pens; informational flyers in the field of computer games, video games, animated films and animated cartoons; document holders; page holders; polymer modelling clay; packing, cushioning, and stuffing materials of paper or cardboard; stuffing of paper or cardboard; paper tags; printed lottery tickets other than toys; computer game instruction manuals; computer user manuals in class 016. For: Clothing, namely, tops, bottoms, shirts; footwear other than special footwear for sports; headwear; non-slipping devices for footwear, namely, soles; motorists' clothing, namely, tops, bottoms, shirts; bath sandals; bath slippers; stockings; sweat-absorbent stockings; heelpieces for stockings; berets; overalls; boas being necklets; caps being headwear; hosiery; half-boots; tips for footwear; dress shields; lace boots; collars as clothing; Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 64 of 111
65 camisoles; boxer shorts; skull caps; bodices being lingerie; underwear; hoods as clothing; hat frames; cap peaks; belts; shawls; dressing gowns; sweaters; chasubles; socks; sock suspenders; garters; stocking suspenders; boot uppers; inner soles; shirts; shirt fronts; short-sleeve shirts; hats; head wear; fittings of metal for footwear; furs being clothing; detachable collars; tights; wet suits for water-skiing; combinations; corselets; suits; ready-made clothing, namely, tops, bottoms, shirts; babies' pants; ear muffs; neckties; footwear uppers; breeches for wear; trousers; cyclists' clothing, namely, tops, bottoms, shirts; outer clothing, namely, tops, bottoms, shirts; gloves; ready- made linings being parts of clothing; sashes for wear; knitwear clothing, namely, shirts, dresses, sweaters; shirt yokes; esparto shoes or sandals; fur stoles; top hats; gabardines; corsets being clothing; corsets being foundation clothing; girdles; galoshes; wimples; gymnastic shoes; coats; waterproof clothing, namely, tops, bottoms, shirts; leggings, namely, leg warmers; jerseys; skirts; clothing layettes; Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 65 of 111
66 liveries; sports jerseys not for athletic purposes; cuffs; aprons being clothing; muffs; maniples; mittens; slippers; pelerines; pelisses; beach clothes, namely, tops, bottoms, shirts; beach shoes; pockets for clothing; dresses; wooden shoes; sandals; underpants; brassieres; overcoats; heelpieces for footwear; togas; welts for footwear; uniforms; stuff jackets; jackets; paper clothing, namely, tops, bottoms, shirts; veils; bathing caps; bathing trunks; bathing suits; bath robes; bibs, not of paper; soles for footwear; heels; footmuffs, not electrically heated, for use as clothing; studs for football boots; headbands; parkas; petticoats; ski boots; slips as undergarments; teddies as undergarments; bandanas being neckerchiefs; clothing for gymnastics, namely, tops, bottoms, shirts; clothing of imitations of leather, namely, tops, bottoms, shirts; clothing of leather, namely, tops, bottoms, shirts; mantillas; masquerade costumes; saris; tee-shirts; turbans; ascots; shower caps; fishing vests; money belts as clothing; pocket squares; paper hats as clothing; sleep masks; skorts; ponchos; sarongs; ski gloves; Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 66 of 111
67 leggings in the nature of trousers; jumper dresses; visors being headwear; sports singlets; valenki being felted boots; albs in class 025. For: Decorations for Christmas trees; bladders of balls for games; artificial fishing bait; caps for toy pistols; toys for domestic pets; ring games; Christmas trees of synthetic material; bows for archery; archery implements; edges of skis; swings; balls for games; play balloons; billiard table cushions; rocking horses; batting gloves; dolls' feeding bottles; stationary exercise bicycles; billiard balls; chalk for billiard cues; billiard markers; skittles; marbles for games; building blocks as toys; bob-sleighs; explosive bonbons, namely, Christmas crackers; skating boots with skates attached; candle holders for Christmas trees; balls for playing games and sports; bowling apparatus and machinery; boxing gloves; gut for rackets; golf clubs; rods for fishing; kites; kite reels; targets; bells for Christmas trees; counters being discs for games; building games; strings for rackets; machines for physical exercises; body- building apparatus; novelties Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 67 of 111
68 for parties and dances in the nature of paper party favors; shin guards being sports articles; cricket bags, namely, bags specially designed to hold cricket equipment; hockey sticks; dice; chest expanders being exercisers; discuses for sports; dominoes; chess games; chessboards; toy pistols; rollers for stationary exercise bicycles; landing nets for anglers; golf bags, with or without wheels; nets for sports; tennis nets; ski bindings; darts; floats for fishing; foosball tables; harpoon guns; gloves for games; cups for dice; bar-bells; fish hooks; baby rattles; clay pigeon traps; rackets; decoys for hunting or fishing; fishing tackle; lines for fishing; dolls' beds; dolls' houses; puppets; dolls; theatrical masks; carnival masks; scale model vehicles; reels for fishing; flippers for swimming; creels as fishing traps; swimming pools being play articles; artificial snow for Christmas trees; quoits; roller skates; ice skates; seal skins being coverings especially adapted for skis; clay pigeons as targets; surfboards; dolls' clothes; dolls' rooms; Playing cards for use in magic tricks; skittles games; gut for fishing; sole coverings for skis; skis; Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 68 of 111
69 tables for table tennis; spinning tops as toys; sleds being sports articles; backgammon games; scooters as toys; shuttlecocks; air pistols being toys; percussion caps being toys; ornaments for Christmas trees, except illumination articles and confectionery; Christmas tree stands; billiard cues; billiard cue tips; billiard tables; coin- operated billiard tables; surf skis; sailboards; hang gliders; appliances for gymnastics; fencing weapons; fencing masks; fencing gauntlets; baseball gloves; climbers' harness; elbow guards being sports articles for athletic use; knee guards being sports articles for athletic use; mobiles as toys; paragliders; protective paddings being parts of sports suits for athletic use; skateboards; toy slides; spring boards; teddy bears; water skis; golf gloves; bite indicators as fishing tackle; bite sensors as fishing tackle; board games; fairground ride apparatus; flying discs toys; horseshoe games; mah-jong; plush toys; soap bubble making wand and solution sets; toy vehicles; twirling batons; butterfly nets; bags especially designed for skis and surfboards; harness Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 69 of 111
70 for sailboards; jigsaw puzzles; masts for sailboards; paintball guns; paintballs ammunition for paintball guns; surfboard leashes; tennis ball throwing apparatus; starting blocks for sports; snow globes; weight lifting belts; bodyboards; bingo cards; divot repair tools as golf accessories; hunting game calls; roulette wheels; in-line roller skates; pinatas; punching bags; radio- controlled toy vehicles; rosin used by athletes; snowshoes; sling shots being sports articles; amusement machines, automatic and coin-operated; kaleidoscopes; playing cards; confetti; electronic targets for sports; scent lures for hunting or fishing; camouflage screens; men's athletic supporters; snowboards; scale model kits as toys; pachinkos; ascenders being mountaineering equipment; slot machines being gaming machines; paper party hats; swimming kick boards; chips for gambling; scratch cards for playing lottery games; stuffed toys; trampolines; poles for pole vaulting; water wings; swimming belts; swimming jackets; video game machines; portable games with liquid crystal displays; arcade video game machines; controllers for Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 70 of 111
71 game consoles; toy models; toy figures; ball pitching machines; dumb-bells; masks as playthings; matryoshka dolls being wooden nested Russian dolls; controllers for toys, namely, cars, robots, and planes; action figure toys; electronic action toys; mechanical and electronic action toys; amusement park rides in class 028. For: Advertising services; business management; business administration; providing office functions; business management assistance; business inquiries; bill-posting; import-export agencies; commercial information agencies; cost price analysis; dissemination of advertising matter; photocopying services; employment agencies; book- keeping; drawing up of statements of accounts, namely, administration, billing and reconciliation of accounts on behalf of others; business auditing; business management and organization consultancy; personnel management consultancy; business management consultancy; typing; demonstration of goods; direct mail advertising services; Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 71 of 111
72 commercial and industrial management assistance; document reproduction; updating of advertising material; distribution of samples; business efficiency expert services; auctioneering; conducting marketing studies; business appraisals; business investigations; publicity material rental; business organization consultancy; publication of publicity texts; radio advertising; business research; public relations; shorthand services; television advertising; transcription of communications; shop window dressing; services of advertising agencies; advisory services for business management; modelling for advertising or sales promotion; marketing research; computerized file management; professional business consultancy; economic forecasting services; organization of exhibitions for commercial or advertising purposes; business information; public opinion polling; payroll preparation; personnel recruitment; relocation services for businesses; rental of advertising space; sales promotion for others; secretarial services; tax Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 72 of 111
73 preparation; telephone answering for unavailable subscribers; word processing; arranging newspaper subscriptions for others; advertising by mail order; business management of hotels; business management of performing artists; compilation of information into computer databases; systemization of information into computer databases; organization of trade fairs for commercial or advertising purposes; rental of photocopying machines; on-line advertising on a computer network; rental of advertising time on communication media; news clipping services; rental of vending machines; psychological testing for the selection of personnel; price comparison services; presentation of goods on communication media, for retail purposes, namely, television home shopping services; commercial information and advice for consumers in the nature of a consumer advice shop; arranging subscriptions to telecommunication services for others; administrative processing of purchase orders; commercial administration of the licensing of the goods and Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 73 of 111
74 services of others; outsourcing services, namely, business management, administration and consultancy; invoicing; writing of publicity texts; compilation of statistics; layout services for advertising purposes; sponsorship search; organization of fashion shows for promotional purposes; production of advertising films; business management of sports people; marketing services; telemarketing services; retail store and wholesale store services featuring pharmaceutical, veterinary and sanitary preparations and medical supplies; rental of sales stands; provision of commercial and business contact information; search engine optimization for sales promotion; web site traffic optimization; pay per click advertising; business management for freelance service providers; negotiation and conclusion of commercial transactions for third parties; updating and maintenance of data in computer databases; business project management services for construction projects; providing business information via a web site; provision of an on-line marketplace for buyers and sellers of goods and services; Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 74 of 111
75 design of advertising materials; outsourced administrative management for companies; tax filing services; rental of billboards; career planning services; presentation of companies and their goods and services on the Internet for promotional purposes; presentation of companies on the Internet and other media for promotional purposes; providing employment information; providing employment information via a global computer network in class 035. For: Accident insurance underwriting services; issue of tokens of value; processing electronic payments made through prepaid cards; issue of tokens of value for payment of transportation expenses; electronic payment, namely, providing electronic processing and transmission of credit card transaction wireless wallets, mobile wallets, electronic wallets, debit and prepaid card transactions; charge card and stored value prepaid card services, namely, processing electronic payments; pre-paid purchase card services namely, processing electronic payments made through prepaid cards; accident insurance Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 75 of 111
76 underwriting; instalment loans; actuarial services; leasing of real estate; credit bureaus; real estate agency services; real estate brokerage; debt collection agency services; insurance brokerage; financial customs brokerage services; insurance underwriting for all types of insurance; banking; real estate appraisal; charitable fund raising; mutual funds investment, distribution and advisory services; capital investment; exchanging money; financial clearing-houses; safe deposit box services; loans financing; fiscal assessments; financial evaluation for insurance, banking, and real estate purposes; factoring agency services; trusteeship representatives; financing services; financial management; pawn brokerage; real estate management services; apartment house management; fire insurance underwriting; rental of apartments; leasing of farms; health insurance underwriting; marine insurance underwriting; mortgage banking; savings bank services; securities brokerage; life insurance underwriting; financial analysis; antique appraisal; art appraisal; check Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 76 of 111
77 verification; financial consultancy; insurance consultancy; credit card transaction processing services; debit card transaction processing services; electronic funds transfer; financial information; insurance information; jewelry appraisal; numismatic appraisal; rent collection; stamp appraisal; issuance of tokens of value; deposits of valuables, namely, safety deposit box services; stock exchange quotations; issuance of credit cards; real estate services, namely, rental of offices; financial sponsorship of sports competitions and special events related thereto; online banking; business liquidation services, financial; repair costs evaluation; brokerage of carbon credits; financial evaluation of standing timber; financial evaluation of wool; stock brokerage services; debt advisory services; arranging finance for construction projects; providing financial information via a web site; financial management of reimbursement payments for others; investment of funds; stocks and bonds brokerage; agencies for trading of commodity futures; brokerage of futures; futures commission Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 77 of 111
78 merchant services, namely, clearing trades for commodities, futures and foreign exchange; financial services, namely, gold trading; providing information on options markets via a web site; providing information relating to the trading of commodity futures; securities arbitrage services; appraisal of second- hand automobiles; automobile appraisal; consultancy relating to the appraisal of goods; providing information relating to the appraisal of second-hand automobiles in class 036. For: Radio broadcasting; electronic message sending; television broadcasting; transmission of telegrams; telegraph services; communications by telegrams; telephone communication services; communications by telephone; communications through an international system of telegraphy with printed messages transmitted and received by teleprinters using the public telecommunications network; news agencies, namely, the transmission of news items to news reporting organizations; cable television broadcasting; communications by cellular phones; communications by Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 78 of 111
79 computer terminals; computer aided transmission of messages and images; electronic transmission of e- mail; facsimile transmission; information about telecommunication; paging services for radio, telephone or other means of electronic communication; rental of message sending apparatus for communications purposes; rental of facsimile apparatus; rental of modems; rental of telecommunication equipment; rental of telephones; satellite transmission; electronic bulletin board services; providing telecommunications connections to a global computer network; telecommunications routing and junction services; teleconferencing services; providing user access to global computer networks; rental of access time to global computer networks; providing telecommunication channels for teleshopping services; providing Internet chatrooms; providing access to databases; voice mail services; transmission of greeting cards online; transmission of digital files; wireless broadcasting; videoconferencing services; providing online forums for transmission of messages Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 79 of 111
80 among computer users; streaming of data; radio communications in class 038. For: Education services, namely, providing classes of instruction in the field of video games; organizing community sporting activities; providing online non-downloadable software for playing games, namely, providing on-line computer games; game cafe services, namely, providing facilities for playing computer games with installed video game machines in an Internet cafe environment; providing on-line journals, namely, blogs featuring user-defined content in the field of social- networking; providing information about computer games using communication by an electronic computer terminal; providing information about computer games via a cellular phone; providing information via the Internet about computer games using communication by hand-held games with liquid crystal displays; providing games using communication by an electronic computer terminal, namely, providing on-line computer games; providing on-line computer games using communication by Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 80 of 111
81 a cellular phone; providing on- line computer games using communication by hand-held games with liquid crystal displays; providing on-line non-downloadable consumer video games; providing non- downloadable music, sound and image data using Internet; computer game services provided on-line from a computer network; amusement park services; animal training; rental of movie projectors and accessories; movie studios services; circuses; Providing education in the field of computers, music, art rendered through correspondence courses; physical education; rental of show scenery; providing recreation facilities; radio entertainment production; publication of texts, other than publicity texts; rental of sound recordings; rental of cine-films; film production, other than advertising films; gymnastic instruction; lending libraries; publication of books; rental of radio and television sets; production of radio and television programmes; music- halls; orchestra services; entertainment in the nature of theatre productions; production of television shows; television entertainment, Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 81 of 111
82 namely, ongoing television programs in the field of computer games, video games, animated films and animated cartoons; rental of stage scenery; zoological garden services; providing sports facilities; modelling for artists; mobile library services; providing casino facilities for gambling; entertainment and education club services, namely, after-hours night club services; arranging and conducting of educational conferences; arranging and conducting of educational congresses in the field of business; discotheque services; information about education; educational examination services; entertainment information; organization of exhibitions for cultural or educational purposes; gambling services; providing golf facilities; health club services, namely, providing health and fitness training; holiday camp services; presentation of live show performances; cinema theater presentations; nursery schools; organization of sports competitions; party planning; providing museum facilities presentation and exhibitions; recording studio services; recreation information; rental Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 82 of 111
83 of skin diving equipment; rental of sports equipment, except vehicles; rental of stadium facilities; rental of video cassette recorders; rental of videotapes; sport camp services; timing of sports events; boarding school education; arranging of beauty contests; booking of seats for shows; dubbing; providing classes of instruction in the field of religious education; operating lotteries; organization of balls; organization of live music shows, namely, impresario services; providing amusement arcade services; rental of audio equipment; rental of lighting apparatus for theatrical sets or television studios; rental of tennis courts; rental of video cameras; scriptwriting services for non-advertising purposes; videotape editing; publication of electronic books and journals on-line; electronic desktop publishing; subtitling; electronic game services provided on-line from a computer network; providing karaoke facility services; music composition services; night clubs; providing on-line non- downloadable electronic publications in the nature of books and journals in the field of business; publication of Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 83 of 111
84 electronic books and journals in the field of business; photographic reporting; photography; vocational guidance; news reporters services; translation; sign language interpretation; videotaping; microfilming; ticket agency services for entertainment events; writing of texts, other than publicity texts, namely, writing of articles for professional journals other than for advertising or publicity; arranging and conducting of concerts; calligraphy services; layout services, other than for advertising purposes; organization of fashion shows for entertainment purposes; coaching in the field of sports; rental of sports grounds; disc jockey services; language interpreter services; personal trainer services fitness training; conducting fitness classes; production of music; toy rental; games equipment rental; providing on-line music, not downloadable; providing on-line videos, namely, providing a web site featuring non-downloadable instructional videos in the field of computer games, video games, animated films and animated cartoons; rental of cameras; rental of musical Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 84 of 111
85 instruments; rental of paintings and calligraphic works; rental of film negatives; operation of audio equipment for production of radio programs; operation of video and audio equipment for production of television programs; providing information on-line relating to computer games and computer enhancements for games; providing on-line computer games; providing on-line information and news in the field of employment training; providing zip line rides for recreational purposes; amusement arcade services; amusement park and theme park services; entertainment in the nature of a water park and amusement center; entertainment in the nature of an amusement park ride; providing amusement facilities in class 041. For: Design and development of computer hardware and software; Software as a service, namely, providing non- downloadable operating system software with regard to infrastructures on the Internet, intranet and extranet in the fields gaming and wagering; providing temporary use of non-downloadable Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 85 of 111
86 software for the operation of gaming and wagering websites on the Internet; design, development and maintenance of computer software and online game websites for others; design, development and maintenance of computer software and online game sites; chemical analysis; analysis for oil-field exploitation; architectural services; bacteriological research; chemistry services, namely, research in the field of chemistry; chemical research; architectural consultation; construction drafting; oil-well testing; cosmetics research; design of interior decor; industrial design; packaging design; material testing; geological surveys; oil-field surveys; engineering; meteorological information; land surveying; computer rental; computer programming; oil prospecting; physics research; mechanical research; textile testing; geological prospecting; geological research; authenticating works of art; calibration; computer software design; updating of computer software; consultancy in the design and development of computer hardware; dress designing; graphic arts design; Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 86 of 111
87 quality control for others; rental of computer software; research and development of new products for others; styling, namely, industrial design; underwater exploration; recovery of computer data; maintenance of computer software; computer system analysis; biological research; urban planning; surveying; computer system design services; vehicle roadworthiness testing; duplication of computer programs; conversion of data or documents from physical to electronic media; creating and maintaining web sites for others; hosting the computer sites on a computer server for a global computer network; installation of computer software; cloud seeding; data conversion of computer programs and data not physical conversion; computer software consultancy; rental of web servers; computer virus protection services; consultancy in the field of energy-saving for scientific research purposes; research in the field of environmental protection; providing search engines for the Internet; digitization of documents; handwriting analysis, namely, graphology; provision of Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 87 of 111
88 scientific information, advice and consultancy in relation to carbon offsetting; quality evaluation of standing timber; quality evaluation of wool; monitoring of computer systems by remote access for detecting unauthorized access or data breach; water analysis; scientific laboratory services; energy auditing; web site design consultancy; consulting services in the field of software as a service (SaaS); information technology consultancy; scientific research; server hosting; conducting clinical trials for others; off-site data backup; electronic data storage; providing information on computer technology and programming via a web site; cartography services; cloud computing consultancy; technological consultancy in the field of computer systems; telecommunications technology consultancy; weather forecasting; technical advice relating to operation of computers; rental of measuring apparatus; rental of laboratory apparatus and instruments; rental of technical drawing instruments; development of computer game software; development of computer hardware; development of Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 88 of 111
89 computer software; development of computer software application solutions; development of computer systems in class 042. For: Services for providing food and drink in restaurants; providing temporary accommodation; accommodation bureau, namely, providing services of hotels and boarding houses; food and drink catering; retirement home services; cafes; cafeterias; providing campground facilities; canteen services; rental of temporary accommodation; boarding house services; tourist home services; hotels; day-nurseries in the nature of creches; restaurants; boarding house bookings; making hotel reservations for others; self- service restaurants; snack- bars; boarding for animals; bar services; providing temporary lodging for holiday camp services; temporary accommodation reservations; motel services; rental of chairs, tables, table linen, glassware; rental of meeting rooms; rental of tents; rental of cooking apparatus; rental of drinking water dispensers; food sculpting; rental of futon and quilts for hotels; rental of Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 89 of 111
90 towels for hotels in class 043. For: Legal services; security services for the protection of property and individuals, namely, surveillance services; personal body guarding; detective agency services; dating services; night guard services; locksmithing, namely, opening of security locks; evening dress rental; crematorium services; missing person investigations; funeral arrangement services; funerary service undertaking; clothing rental; guard services; marriage agencies, namely, conducting civil marriage ceremony services; physical security consultancy; horoscope casting; fire- fighting; organization of religious prayer meetings; adoption agency services; monitoring of burglar and security alarms; babysitting; baggage handling inspections for airlines; house sitting; pet sitting; personal background investigations; lost property return; mediation; inspection of factories for safety purposes; rental of fire alarms; rental of fire extinguishers; arbitration services; intellectual property consultancy; copyright management; licensing of intellectual property; Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 90 of 111
91 monitoring intellectual property rights for legal advisory purposes; legal research; litigation services; licensing of computer software; registration of domain names; alternative dispute resolution services; rental of safes; genealogical research; planning and arranging of wedding ceremonies; on-line social networking services; releasing doves for special occasions; embalming services; legal document preparation services; tracking of stolen property; legal administration of licenses; consultancy services in the field of personal fashion; information about personal wardrobe styling services; information relating to fashion coordination services for individuals; personal styling services consisting of bra measuring and fitting services; personal styling services consisting of measuring and fitting services for ladies' lingerie; personal wardrobe styling services; providing grave spaces or charnel houses; legal services relating to social insurance claims; rental of altars; rental of jewelry; licensing of computer software via networks in class 045. Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 91 of 111
92 6,039,333 Apr. 28, 2020 For: Coin-operated video games; arcade game machines; arcade video game machines; amusement game machines with built-in screens; toy vehicles; dolls; stuffed toys; toy action figures; trading card games; playing cards; arcade redemption game machines which dispense tickets or tokens to successful players; arcade crane game machines which dispense tickets or tokens to successful players; slot machines in class 028. 2,315,166 SEGA Feb. 8, 2000 For: Video game machines for use with televisions; electronic gaming machines; video game software; computer game software in class 009. 3,245,697 SEGA May 29, 2007 For: T-shirts; shirts in class 025. 3,491,509 DREAMCAST Aug. 26, 2008 For: Video game software, computer game programs in class 009. 1,690,329 GENESIS June 2, 1992 For: Video output game machines; software for video output game machines; attachments for video output game machines; namely, joystick controllers and joypad controllers; and carrying cases and storage containers for the foregoing in class 028. 3,358,022 SEGA GENESIS COLLECTION Dec. 18, 2007 For: Home video game software, video game software for hand- held game machines in class 009. Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 92 of 111
93
3,713,204
SONIC'S
ULTIMATE
GENESIS
COLLECTION
Nov. 17,
2009
For: Video game software in
class 009.
3,013,830 Nov. 08,
2005
For: Video game software in
class 009.
Sega alleges that Defendants, through fully interactive, e-commerce stores1,
operating under the seller aliases identified on Schedule A to the Complaint and
attached hereto (the "Seller Aliases"), have advertised, promoted, offered for sale,
sold, or imported goods bearing and/or embodying what Sega has determined to be
counterfeits, infringements, reproductions, or colorable imitations of the Sega
Trademarks and/or unauthorized copies of the Sega Copyrighted Works. ECF No.
[1].
Sega alleges that it has not licensed or authorized Defendants to use any of the
Sega Trademarks or Sega Copyrighted Works, and none of the Defendants are
authorized retailers of genuine Sega Products. ECF No. [11-1].
Sega attests that it investigated the promotion and sale of infringing and
counterfeit versions of its branded products by Defendants ("Unauthorized
Products"). See id. at ¶ 21. Sega alleges that it analyzed each each of the e-commerce
stores operating under the Seller Aliases and determined that Unauthorized
Products were being offered for sale to residents of the United States, including
1 The e-commerce store URLs are listed on Schedule A to the Complaint and attached hereto.
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 93 of 11194 Florida. Id. In addition, each e-commerce store offered shipping to the United States. Id. Sega attests that it conducted a review and visually inspected the Unauthorized Products listed for sale on each Defendants’ e-commerce store and and determined said products were non-genuine and unauthorized by Sega. Id. II. LEGAL STANDARD To obtain a preliminary injunction, a party must demonstrate: (1) a substantial likelihood of success on the merits; (2) that irreparable injury will be suffered if the relief is not granted; (3) that the threatened injury outweighs the harm the relief would inflict on the non- movant; and (4) that the entry of the relief would serve the public interest. Schiavo ex. rel Schindler v. Schiavo, 403 F.3d 1223, 1225-26 (11th Cir. 2005); see also Levi Strauss & Co. v. Sunrise Int'l Trading Inc., 51 F.3d 982, 985 (11th Cir. 1995) (applying the test to a preliminary injunction in a Lanham Act case). III. DISCUSSION The declarations Sega submitted in support of the Motion support the following conclusions of law: A. Sega has a strong probability of proving at trial that: a. Consumers are likely to be confused by Defendants' advertisement, promotion, sale, offer for sale, and/or distribution of Unauthorized Products, and that Defendants' Unauthorized Products use infringing and counterfeit versions of the Sega Trademarks and/or unauthorized copies of the Sega Copyrighted Works. Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 94 of 111
95 b. Defendants are offering for sale and selling Unauthorized Sega Products which include reproductions of the Sega Copyrighted Works or works derived from the Sega Copyrighted Works, and the Unauthorized Sega Products bear copies of works that are substantially similar to the Sega Copyrighted Work. B. This Court has personal jurisdiction over Defendants because Defendants directly target their business activities toward consumers in the United States, including Florida. Specifically, Defendants have targeted sales to Florida residents by setting up and operating e-commerce stores that target United States consumers using the Seller Aliases, offer shipping to Florida, and/or have sold Unauthorized Products to residents of Florida. C. Because of the infringement of the Sega Trademarks and/or Sega Copyrighted Works, Sega is likely to suffer immediate and irreparable injury if a preliminary injunction order is not granted. The following specific facts, as set forth in Sega's Complaint, Sega's Motion, and accompanying declarations, demonstrate that immediate and irreparable loss, damage, and injury will result to Sega and to consumers before Defendants can be heard in opposition unless Sega's request for preliminary relief is granted: a. Defendants own, operate, and/or control fully interactive, e- commerce stores operating under the Seller Aliases which advertise, offer for sale, sell, and ship Unauthorized Products to customers in Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 95 of 111
96 the Florida that bear infringing and/or counterfeit versions of the Sega Trademarks and/or bear unauthorized copies of the Sega Copyrighted Works; and b. There is good cause to believe that more counterfeit and infringing products bearing the Sega Trademarks and/or unauthorized copies of the Sega Copyrighted Works will appear in the marketplace; that consumers are likely to be misled, confused, and disappointed by the quality of the Unauthorized Products; and that Sega may suffer loss of sales for its genuine products and an unnatural erosion of the legitimate marketplace in which it operates; and D. The potential harm to Defendants in restraining their trade in counterfeit and infringing goods through their e-commerce stores and freezing ill- gotten profits if a preliminary injunction order is granted is far outweighed by the irreparable harm Sega, its reputation, and its goodwill has suffered and will continue to suffer if a preliminary injunction order is not issued. E. The public interest favors issuance of the preliminary injunction order to prevent consumer confusion and dispel the false impression that Defendants are operating their e-commerce stores with Sega's approval and endorsement, as well as protect Sega's legitimate intellectual property interests. Further, the public will be protected from being defrauded by the illegal sale of Unauthorized Products. Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 96 of 111
97
F. Under 15 U.S.C. § 1117(a), Sega may be entitled to recover, as an equitable
remedy, the illegal profits gained through Defendants' distribution and
sales of goods bearing infringing and/or counterfeit versions of the Sega
Trademarks. See Reebok Int'l, Ltd. v. Marnatech Enters., Inc., 970 F.2d
552, 559 (9th Cir. 1992) (quoting Fuller Brush Prods. Co. v. Fuller Brush
Co., 299 F.2d 772, 777 (7th Cir. 1962) ("An accounting of profits under §
1117(a) is not synonymous with an award of monetary damages: '[a]n
accounting for profits . . . is an equitable remedy subject to the principles of
equity'").
G. Under 17 U.S.C. § 504(b) and 17 U.S.C. § 502(a), Sega may be entitled to
recover, as an equitable remedy, the illegal profits gained through
Defendants' distribution and sales of goods bearing unauthorized copies of
the Sega Copyrighted Works. See Antsy Labs, LLC v. Individuals, 24-cv-
61436-WPD, 2024 WL 4472009, at *6 (S.D. Fla. Sept. 16, 2024) ("Under 17
U.S. Code § 504(b) and 17 U.S. Code § 502(a), Plaintiff may be entitled to
recover, as an equitable remedy, the illegal profits gained through
Defendants' distribution and sales of goods infringing Plaintiff’s
Copyrights.").
H. Requesting 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." Levi Strauss & Co., 51 F.3d at
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 97 of 11198 987 (citing Federal Trade Commission v. United States Oil & Gas Corp., 748 F.2d 1431, 143334 (11th Cir. 1984)). I. In light of the inherently deceptive nature of the intellectual property infringement business, and the likelihood that Defendants have violated federal trademark and copyright laws, Sega has good reason to believe Defendants will hide or transfer their ill-gotten assets beyond the jurisdiction of this Court unless those assets are restrained. Accordingly, upon due consideration of Sega’s Complaint, the Motion, the supporting evidentiary submissions, the relevant authorities, and for the reasons et forth on the record at the hearing on the Motion, which are incorporated herein, it is hereby ORDERED AND ADJUDGED that the Motion, ECF No. [21], is GRANTED, under the terms set forth below: 1. Defendants, their affiliates, officers, agents, servants, employees, attorneys, confederates, and all persons acting for, with, by, through, under, or in active concert with Defendants be preliminary enjoined and restrained from: a. using the Sega Trademarks or any reproductions, counterfeit copies, or colorable imitations thereof in any manner in connection with the distribution, marketing, advertising, offering for sale, or sale of any product that is not a genuine Sega product or not authorized by Sega to be sold in connection with the Sega Trademarks; Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 98 of 111
99 b. reproducing, distributing copies of, making derivative works of, or publicly displaying the Sega Copyrighted Works in any manner without the express authorization of Sega; c. passing off, inducing, or enabling others to sell or pass off any product as a genuine Sega product or any other product produced by Sega, that is not Sega's or not produced under the authorization, control, or supervision of Sega and approved by Sega for sale under the Sega Trademarks and/or Sega Copyrighted Works; d. committing any acts calculated to cause consumers to believe that Defendants' products are those sold under the authorization, control, or supervision of Sega, or are sponsored by, approved by, or otherwise connected with Sega; e. further infringing the Sega Trademarks and Sega Copyrighted Works and damaging Sega's goodwill; and f. manufacturing, shipping, delivering, holding for sale, transferring or otherwise moving, storing, distributing, returning, or otherwise disposing of, in any manner, products or inventory not manufactured by or for Sega, nor authorized by Sega to be sold or offered for sale, and which bear any of Sega's trademarks, including the Sega Trademarks, or any reproductions, counterfeit copies, or colorable imitations and/or which bear the Sega Copyrighted Works. Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 99 of 111
100 2. Upon Sega's request, any third party with actual notice of this Order who is providing services for any of the Defendants, or in connection with any of Defendants' Seller Aliases, including, without limitation, any online platforms such as Amazon.com, Inc. (“Amazon”), Dhgate.com (“DHGate”), eBay, Inc. (“eBay”), Etsy, Inc. (“Etsy”), Payoneer Global Inc. (“Payoneer”), PayPal, Inc. (“PayPal”), Stripe, Inc. (“Stripe”), Roadget Business PTE Ltd. (“SHEIN”), and Context Logic, Inc. d/b/a Wish.com (“Wish”) (collectively, the "Third Party Providers") shall, within seven (7) calendar days after receipt of such notice, provide to Sega expedited discovery, including copies of all documents and records in such person's or entity's possession or control relating to: a. the identities and locations of Defendants, their affiliates, officers, agents, servants, employees, confederates, attorneys, and any persons acting in concert or participation with them, including all known contact information and all associated e-mail addresses; b. the nature of Defendants' operations and all associated sales, methods of payment for services, and financial information, including, without limitation, identifying information associated with the Seller Aliases and Defendants' financial accounts, as well as providing a full accounting of Defendants' sales and listing history related to their respective Seller Aliases; and c. any financial accounts owned or controlled by Defendants, including their agents, servants, employees, confederates, attorneys, and any persons Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 100 of 111
101 acting in concert or participation with them, including such accounts residing with or under the control of any banks, savings and loan associations, payment processors or other financial institutions, including, without limitation, the Third Party Providers, or other merchant account providers, payment providers, third party processors, and credit card associations (e.g., MasterCard and VISA). 3. Upon Sega's request, those with notice of this Order, including the Third Party Providers as defined in Paragraph 2, shall within seven (7) calendar days after receipt of such notice, disable and cease displaying any advertisements used by or associated with Defendants in connection with the sale of counterfeit and infringing goods using the Sega Trademarks and/or which bear the Sega Copyrighted Works. 4. Defendants shall be temporarily and preliminarily restrained and enjoined from transferring or disposing of any money or other of Defendants' assets until further ordered by this Court. 5. The Third Party Providers shall, within seven (7) calendar days of receipt of this Order: a. locate all accounts and funds connected to Defendants' Seller Aliases, including, but not limited to, any financial accounts connected to the information listed in Schedule A hereto, the e-mail addresses identified in Exhibit 3 to the Declaration of Andrew Masterson, and any e-mail addresses provided for Defendants by third parties; and Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 101 of 111
102 b. restrain and enjoin any such accounts or funds from transferring or disposing of any money or other of Defendants' assets until further order by this Court. 6. Sega is authorized to issue expedited written discovery to Defendants, pursuant to Federal Rules of Civil Procedure 33, 34, and 36, related to: a. the identities and locations of Defendants, their affiliates, officers, agents, servants, employees, confederates, attorneys, and any persons acting in active concert or participation with them, including all known contact information, including any and all associated e-mail addresses; and b. the nature of Defendants' operations and all associated sales, methods of payment for services, and financial information, including, without limitation, identifying information associated with the Seller Aliases and Defendants' financial accounts, as well as providing full accounting of Defendants' sales and listing history related to their respective Seller Aliases. 7. Sega is authorized to issue the expedited discovery requests authorized in Paragraph 6 via e-mail. Defendants shall respond to any such discovery requests within three (3) business days of being served via e-mail. 8. Any Defendants that are subject to this Order may appear and move to dissolve or modify the Order as permitted by and in compliance with the Federal Rules of Civil Procedure and Southern District of Florida Local Rules. Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 102 of 111
103 9. The ten-thousand-dollar ($10,000) bond posted by Plaintiffs shall remain with the Court until a final disposition of this case or until the Preliminary Injunction is terminated. 10. As a matter of law, this Preliminary Injunction shall no longer apply to any Defendant or associated e-commerce store dismissed from this action or as to which Plaintiff has withdrawn its request for a preliminary injunction. 11. This Order shall remain in effect during the pendency of this action, or until further Order of this Court. DONE AND ORDERED in Miami, Florida, on this 27th day of January, 2026. __________________________________________ JACQUELINE BECERRA UNITED STATES DISTRICT JUDGE Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 103 of 111
104 Sega Corporation and Sega of America, Inc. v. The Partnerships and Unincorporated Associations Identified on Schedule "A" – Case No. 25-cv- 25442-JB Schedule A DOE No. Defendants Infringement Type Seller URL 1 chufangxiaodian Copyright only https://www.amazon.com/sp?ie= UTF8&seller=AF7Z2SI6KHXOF 2 dongzide Copyright only https://www.amazon.com/sp?ie= UTF8&seller=A196AMINXCJ2F G 3 GuiYuAnFenMaoYi Copyright only https://www.amazon.com/sp?ie= UTF8&seller=A38ML5FWNVJ8I E 4 JFneonsios Copyright only https://www.amazon.com/sp?ie= UTF8&seller=AWI263UNSTI4G 5 K2HOARD Copyright only https://www.amazon.com/sp?ie= UTF8&seller=AGYWJGWGAMR D7 6 kailin Copyright only https://www.amazon.com/sp?ie= UTF8&seller=A2T6Y7OV0RYW Q7 7 shawncraft Copyright only https://www.amazon.com/sp?ie= UTF8&seller=A179C6MGV2CK W0 8 ShenYangMingQiangTu ShiFangGongChengYou XianGongSi Copyright only https://www.amazon.com/sp?ie= UTF8&seller=A1F7Q587D3W9L R 9 SNHPARTY Copyright only https://www.amazon.com/sp?ie= UTF8&seller=A1F7Q587D3W9L R 10 TheLittleHeroes Copyright only https://www.amazon.com/sp?ie= UTF8&seller=A1FH617ITDALZ L 11 XianRuLian Copyright only https://www.amazon.com/sp?ie= UTF8&seller=A38CC3RN64MRI V 12 cartonn Copyright only https://www.dhgate.com/store/to p-selling/21929384.html 13 chiccharm Copyright only https://www.dhgate.com/store/to p-selling/22057112.html Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 104 of 111
105 14 dboos Copyright only https://www.dhgate.com/store/to p-selling/22011545.html 15 ddmyapr Copyright only https://www.dhgate.com/store/to p-selling/21997318.html 16 dhpetdd Copyright only https://www.dhgate.com/store/to p-selling/22019574.html 17 difnik Copyright only https://www.dhgate.com/store/to p-selling/21946498.html 18 factorytoyss Copyright only https://www.dhgate.com/store/to p-selling/22233956.html 19 fashion_official01 Copyright only https://www.dhgate.com/store/to p-selling/21908286.html 20 glamgears Copyright only https://www.dhgate.com/store/to p-selling/22055888.html 21 glamor111 Copyright only https://www.dhgate.com/store/to p-selling/22059134.html 22 happy__every_day Copyright only https://www.dhgate.com/store/to p-selling/22054864.html 23 henio Copyright only https://www.dhgate.com/store/to p-selling/22041223.html 24 jiaomengmeng8 Copyright only https://www.dhgate.com/store/to p-selling/22204866.html 25 liancheng05 Copyright only https://www.dhgate.com/store/21 733799 26 limionou Copyright only https://www.dhgate.com/store/to p-selling/21931893.html 27 louis_vh_store Copyright only https://www.dhgate.com/store/21 888431 28 lucky_tree777 Copyright only https://www.dhgate.com/store/to p-selling/22056961.html 29 manilabest Copyright only https://www.dhgate.com/store/to p-selling/21555942.html 30 olgariner Copyright only https://www.dhgate.com/store/to p-selling/21810466.html 31 pinerw Copyright only https://www.dhgate.com/store/21 942835 32 postland Copyright only https://www.dhgate.com/store/to p-selling/22033768.html 33 quality_life_hall Copyright only https://www.dhgate.com/store/22 002290 34 refulgence898 Copyright only https://www.dhgate.com/store/to p-selling/22048987.html 35 stylespo Copyright only https://www.dhgate.com/store/to p-selling/22055881.html Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 105 of 111
106 36 that_person Copyright only https://www.dhgate.com/store/to p-selling/21997755.html 37 tie08 Copyright only https://www.dhgate.com/store/21 836704 38 tonethiny Copyright only https://www.dhgate.com/store/to p-selling/21060778.html 39 toyshopcn Copyright only https://www.dhgate.com/store/to p-selling/22242686.html 40 usseller518 Copyright only https://www.dhgate.com/store/to p-selling/21791966.html 41 xgx009 Copyright only https://www.dhgate.com/store/to p-selling/22044687.html 42 xpreal Copyright only https://www.dhgate.com/store/to p-selling/21946530.html 43 yaowak Copyright only https://www.dhgate.com/store/to p-selling/21947263.html 44 yiwang01 Copyright only https://www.dhgate.com/store/to p-selling/21269253.html 45 yuancao Copyright only https://www.dhgate.com/store/to p-selling/20061363.html 46 z00010 Copyright only https://www.dhgate.com/store/21 963226 47 WorldofstarsHome Copyright only https://www.etsy.com/shop/World ofstarsHome?ref=shop-header- name&listing_id=4320144358&f rom_page=listing 48 1tees.com Copyright only https://1tees.com 49 Animal Kingdom Copyright only https://animalkingdomdesigns.co m/ 50 Boo Haul, Co. Copyright only https://boohaul.com 51 Drinkwears Copyright only https://drinkwears.com/ 52 goofyahhproduction Copyright only https://goofyahhtees.com 53 minomog Copyright only https://minomog.com 54 Oscarsitosroom Copyright only https://oscarsitosroom.com 55 TeleTeeShirt Copyright only https://teleteeshirt.com/ 56 VUITINO LLC Copyright only https://vuitino.com/ 57 wexhome Copyright only https://www.wexhome.com/ 58 Zalivora Copyright only https://www.zalivora.com 59 ZANIAZ Copyright only https://www.zaniaz.com/ 60 asvdsfv Copyright only https://us.shein.com/store/home? store_code=2177703847 61 baiyangshop Copyright only https://us.shein.com/store/home? store_code=1591306652 Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 106 of 111
107 62 Box Key Copyright only https://us.shein.com/store/home? store_code=8318751172 63 caefe Copyright only https://us.shein.com/store/home? store_code=7870752566 64 Canvas Elegance STORE Copyright only https://us.shein.com/store/home? store_code=5062436050 65 ChillWear Copyright only https://us.shein.com/store/home? store_code=1974176592 66 Diamond5 Copyright only https://us.shein.com/store/home? store_code=8699315752 67 dsggs Copyright only https://us.shein.com/store/home? store_code=5723887930 68 fdhbdfhnd Copyright only https://us.shein.com/store/home? store_code=7657367586&ici=Pag eGoodsDetail&main_cate_id=17 38&main_goods_id=151541653 69 fuxianbin34 Copyright only https://us.shein.com/store/home? store_code=5904600892& 70 gzsxgbzxb Copyright only https://us.shein.com/store/home? store_code=9354692152 71 hankemu Copyright only https://us.shein.com/store/home? store_code=1194302054 72 HOUGVPJKOI Copyright only https://us.shein.com/store/home? store_code=1848025638 73 JORVALEN DUNE Copyright only https://us.shein.com/store/home? store_code=6835786239 74 kdhuufjnhfjn Copyright only https://us.shein.com/store/home? store_code=6288606871 75 km mmnh Copyright only https://us.shein.com/store/home? store_code=3913843995 76 lijianlang11 Copyright only https://us.shein.com/store/home? store_code=6294993300 77 liuxing0203 Copyright only https://us.shein.com/store/home? store_code=2227813064 78 longpipi Copyright only https://us.shein.com/store/home? store_code=1525649112 79 NSEDFTHY Copyright only https://us.shein.com/store/home? store_code=5182456220 80 pengchao0203 Copyright only https://us.shein.com/store/home? store_code=8869730071 81 qingqingfushi Copyright only https://us.shein.com/store/home? store_code=1752039235 82 RosemaryRise4 Copyright only https://us.shein.com/store/home? store_code=9336993033 Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 107 of 111
108 83 tanminghuanvzhuang Copyright only https://us.shein.com/store/home? store_code=7543363027 84 ufq1vauxuirq Copyright only https://us.shein.com/store/home? store_code=6670111514 85 vl5zb42zp2bf Copyright only https://us.shein.com/store/home? store_code=5661608798 86 wanglan0203 Copyright only https://us.shein.com/store/home? store_code=1190894475 87 wangwenxiangshop Copyright only https://us.shein.com/store/home? store_code=4103744397 88 weimengdashop Copyright only https://us.shein.com/store/home? store_code=6920606412 89 YJYF RTYE Copyright only https://us.shein.com/store/home? store_code=4580631930 90 Clothes LQ Store Copyright only https://www.wish.com/merchant/ 5defa67429e7867bac094c0f 91 erl5965shop Copyright only https://www.wish.com/merchant/ 5e8bf70a0a83cbe0b6000738 92 Durcoo Trademark only https://www.amazon.com/sp?ie= UTF8&seller=A8AM0HT6MG7R S 93 taste76but Trademark only https://www.ebay.com/str/taste76 but 94 LIAOMEIXIAus01 shop Trademark only https://us.shein.com/store/home? store_code=8267462125 95 shiyso2u1 d shop Trademark only https://us.shein.com/store/home? store_code=3518447261 96 alezae Trademark and Copyright https://www.dhgate.com/store/to p-selling/22042462.html 97 amazing8888 Trademark and Copyright https://www.dhgate.com/store/21 780107 98 dh1102729193 Trademark and Copyright https://www.dhgate.com/store/to p-selling/22019561.html 99 freakhouse Trademark and Copyright https://www.dhgate.com/store/22 002450 100 lizhenbaby0517 Trademark and Copyright https://www.dhgate.com/store/to p-selling/22124944.html 101 merrydecorations97 Trademark and Copyright https://www.dhgate.com/store/to p-selling/22244339.html 102 minifight Trademark and Copyright https://www.dhgate.com/store/21 678707 103 sihuai04 Trademark and Copyright https://www.dhgate.com/store/to p-selling/21614050.html Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 108 of 111
109 104 terratread Trademark and Copyright https://www.dhgate.com/store/to p-selling/22240777.html 105 the_medallion1 Trademark and Copyright https://www.dhgate.com/store/pr oducts/22012251 106 zyggood Trademark and Copyright https://www.dhgate.com/store/pr oducts/20994126 107 gitrin22 Trademark and Copyright https://www.ebay.com/str/gitrin2 2 108 nguye-6542 Trademark and Copyright https://www.ebay.com/str/anhsto re?_tab=about 109 snapbackhighquality Trademark and Copyright https://www.ebay.com/usr/snapb ackhighquality 110 MihnCraftStore Trademark and Copyright https://www.etsy.com/shop/Mihn CraftStore 111 Anime Printz Trademark and Copyright https://www.animeprintz.com 112 AWAZOME Trademark and Copyright https://www.awazome.com 113 beyburst Trademark and Copyright https://beyburst.com 114 EBeddingSets Trademark and Copyright https://www.ebeddingsets.com/ 115 Fanaticity Fashion LLC Trademark and Copyright https://fanaticity.com 116 Fuzeprint Trademark and Copyright https://fuzeprint.com 117 Growkoc Trademark and Copyright https://growkoc.com 118 Huystyle Trademark and Copyright https://huystyle.com/ 119 Personality Fashion Trademark and Copyright https://supportpersonality.com 120 Shopzinia Trademark and Copyright https://shopzinia.com 121 T-shirt At Low Price Trademark and Copyright https://tshirtatlowprice.com 122 Teewiin Store Trademark and Copyright https://www.teewiin.com/ 123 62e5iib7 Trademark and Copyright https://us.shein.com/store/home? store_code=8873021824 124 A+Novelty US Trademark and Copyright https://us.shein.com/store/home? store_code=2540761022 125 ADFG BNHJ Trademark and Copyright https://us.shein.com/store/home? store_code=1934317007 Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 109 of 111
110 126 AuraCanvas Trademark and Copyright https://us.shein.com/store/home? store_code=5639737805 127 AYG VDXEDGB Trademark and Copyright https://us.shein.com/store/home? store_code=2631269484 128 CCOYTR ART SHOP Trademark and Copyright https://us.shein.com/store/home? store_code=6742538152 129 dfjyrhffg Trademark and Copyright https://us.shein.com/store/home? store_code=4025050660 130 dgsgsdsadgfsd Trademark and Copyright https://us.shein.com/store/home? store_code=6036088703 131 dsddss Trademark and Copyright https://us.shein.com/store/home? store_code=5491333814 132 dsgsdhdfsh Trademark and Copyright https://us.shein.com/store/home? store_code=8939706714 133 dsvdsds Trademark and Copyright https://us.shein.com/store/home? store_code=7912427471 134 FDSF HT Trademark and Copyright https://us.shein.com/store/home? store_code=4264638258 135 ffgjkffgh Trademark and Copyright https://us.shein.com/store/home? store_code=7628625622 136 FGHJKQ Trademark and Copyright https://us.shein.com/store/home? store_code=1351992659 137 HBHDH Trademark and Copyright https://us.shein.com/store/home? store_code=2337883547 138 hi derj Trademark and Copyright https://us.shein.com/store/home? store_code=8321717751 139 Junction5 Trademark and Copyright https://us.shein.com/store/home? store_code=2483591527 140 szsxcf vhgjh Trademark and Copyright https://us.shein.com/store/home? store_code=8526691531 141 xiexibing025 stus Trademark and Copyright https://us.shein.com/store/home? store_code=3028794077 142 yangwusheng0203 Trademark and Copyright https://us.shein.com/store/home? store_code=3519647535 143 zhanggushng Trademark and Copyright https://us.shein.com/store/home? store_code=7985210506&ici=Pag eGoodsDetail&main_cate_id=17 38&main_goods_id=140411712 144 zhoutao0203 Trademark and Copyright https://us.shein.com/store/home? store_code=8176948403 145 adsad23 Trademark and Copyright https://www.wish.com/merchant/ 5d5a53b5560eca4252f2a778 Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 110 of 111
111 Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 111 of 111
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OCR transcription for search; preserved printed pages are authoritative
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 1 of 111
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA
CASE NO .: 1:25-cv-25442-JB
SEGA CORPORATION and SEGA OF AMERICA, INC.,
Plaintiffs,
V.
THE PARTNERSHIPS and UNINCORPORATED ASSOCIATIONS IDENTIFIED ON SCHEDULE "A,"
Defendants. /
ORDER GRANTING PLAINTIFFS' MOTION FOR PRELIMINARY INJUNCTION ORDER
THIS CAUSE comes before the Court upon Plaintiffs Sega Corporation's and Sega of America, Inc.'s ("Plaintiffs" or "Sega") Motion for Entry of a Preliminary Injunction. ECF No. [21]. In the Motion, Sega seeks entry of a preliminary injunction order against the Partnerships and Unincorporated Associations Identified on Schedule A hereto (collectively, "Defendants"), and entry of an order restraining the financial accounts used by Defendants, pursuant to the Lanham Act, 15 U.S.C. §§ 1116 et seq .; Federal Rule of Civil Procedure 65; the Copyright Act, 17 U.S.C. §§ 101 et seq .; and the All Writs Act, 28 U.S.C. § 1651(a).
On December 30, 2025, the Court entered an order granting Plaintiffs' ex parte Motion for Entry of Temporary Restraining Order ("TRO"). ECF No. [14]. Upon Plaintiffs' showing of good cause, the Court extended the TRO to expire on January 27, 2026. ECF No. [19]. The Court convened a public hearing on January 26, 2026.
1
AUTHENTICATED U.S. GOVERNMENT INFORMATION GPO
2
ECF No. [29]. Plaintiffs certified that they served Defendants notice of this hearing
on January 22, 2026, on the Defendants identified on Schedule “A” hereto by (1)
emailing Defendants the Complaint, Motion, and TRO issued in this action; and (2)
posting copies of the Complaint, Motion, TRO, and all other documents filed in this
action at https://www.tme-law.com/case/25-cv-25442, where such documents are
available to view and download in compliance with this Court’s TRO. ECF Nos. [14]
at 100; [26].
Only counsel for Plaintiffs appeared through counsel at the hearing on the
Motion. As represented by Plaintiffs’ counsel at the hearing and reflected on the
docket of this case, no Defendants have made any appearance, indicated an intention
to challenge the TRO, or otherwise answered and/or defended against the Complaint.
The Court heard argument from Plaintiffs and reviewed the evidence that Plaintiffs’
counsel presented to the Court.
Upon due consideration of the Motion, the pertinent portions of the record, the
relevant authorities, and for the reasons set forth herein, the Motion is hereby
GRANTED in its entirety.
I. FACTUAL BACKGROUND
The following background is taken from Plaintiffs' Complaint, ECF No. [1], the
Motion, and supporting evidentiary submissions and exhibits.
Sega is the owner of various copyright registrations related to its Sonic the
Hedgehog franchise (the "Sega Copyrighted Works"). A list of the Sega Copyrighted
Works is below. See Declaration of Andrew Masterson (the "Masterson Decl.") ECF
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 2 of 111
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 3 of 111
No. [11-1].
U.S. Copyright Reg. No.
Work Title
Issue Date
PA0002344266
Sonic the Hedgehog 2
April 8, 2022
PRE00001179 8
Sonic the Hedgehog 2
April 9, 2021
PA0002228951
Sonic the Hedgehog
February 18, 2020
PRE00001094 8
Sonic the Hedgehog
July 22, 2019
TX0008029049
Sonic Boom.
January 22, 2015
TX0007606111
Sonic & Knuckles "Mecha Madness Special"
October 8, 2012
TX0007609228
Sonic & Knuckles
October 8, 2012
TX0007609248
Sonic Adventures "Nights Into Dreams"
October 8, 2012
TX0007609603
Sonic Adventures "Nights Into Dreams"
October 8, 2012
TX0007609483
Sonic Adventures "Nights Into Dreams"
October 8, 2012
TX0007609242
Sonic Adventures "Nights Into Dreams"
October 8, 2012
TX0007609194
Sonic Blast
October 8, 2012
TX0007609230
Sonic Live
October 8, 2012
TX0007609187
Sonic the Hedgehog "In Your Face". [Published: 1997-01-15. Issue: no. 1, 01/15/1997]
October 8, 2012
TX0007609198
Sonic Triple Trouble. [Published: 1995-06-28. Issue: no. 1, 06/28/1995]
October 8, 2012
TX0007609235
Sonic vs. Knuckles. [Published: 1995-04-17. Issue: no. 1, 04/17/1995]
October 8, 2012
TX0007606123
Sonic Quest: Death Egg Saga. [Published: 1996-08-26. Issue: no. 1, Dec 1996]
September 25, 2012
TX0007606128
Sonic Quest: Death Egg Saga. [Published: 1996-09-15. Issue: no. 2, Jan 1997]
September 25, 2012
TX0007606137
Sonic Quest: Death Egg Saga. [Published: 1996-11-16. Issue: no. 3, Feb 1997]
September 25,
2012
TX0007617975
Sonic the Hedgehog Buddy "Tail's". [Published: 1995-08-17. Issue: no. 1, Dec 1995]
September 25, 2012
TX0007617973
Sonic the Hedgehog Buddy "Tail's". [Published: 1995-09-26. Issue: no. 2, Jan 1996]
September 25, 2012
3
4
TX0007617970
Sonic the Hedgehog Buddy "Tail's".
[Published: 1995-10-31. Issue: no. 3, Feb
1996]
September 25,
2012
TX0007609679
Sonic the Hedgehog Presents "Princess
Sally". [Published: 1995-04-12. Issue: no. 1,
April, 1995]
September 25,
2012
TX0007609635
Sonic the Hedgehog Presents "Princess
Sally". [Published: 1995-05-23. Issue: no. 2,
May 1995]
September 25,
2012
TX0007609608
Sonic the Hedgehog Presents "Princess
Sally". [Published: 1995-06-25. Issue: no. 3,
June 1995]
September 25,
2012
TX0007604909
SONIC X. [Published: 2008-03-10. Issue: no.
30, 03/10/2008]
September 24,
2012
TX0007604907
SONIC X. [Published: 2008-03-26. Issue: no.
31, 03/26/2008]
September 24,
2012
TX0007604905
SONIC X. [Published: 2008-04-23. Issue: no.
32, 04/23/2008]
September 24,
2012
TX0007604904
SONIC X. [Published: 2008-05-28. Issue: no.
33, 05/28/2008]
September 24,
2012
TX0007604903
SONIC X. [Published: 2008-06-25. Issue: no.
34, 06/25/2008]
September 24,
2012
TX0007604877
SONIC X. [Published: 2008-07-23. Issue: no.
35, 07/23/2008]
September 24,
2012
TX0007604398
SONIC X. [Published: 2008-08-27. Issue: no.
36, 08/27/2008]
September 24,
2012
TX0007604138
SONIC X. [Published: 2008-09-24. Issue: no.
37, 09/24/2008]
September 24,
2012
TX0007604076
SONIC X. [Published: 2008-10-22. Issue: no.
38, 10/22/2008]
September 24,
2012
TX0007603702
SONIC X. [Published: 2008-11-26. Issue: no.
39, 11/26/2008]
September 24,
2012
TX0007602871
SONIC X. [Published: 2008-12-24. Issue: no.
40, 12/24/08]
September 24,
2012
TX0007604911
SONIC X. [Published: 2005-09-07. Issue: no.
1, Nov 2005]
September 19,
2012
TX0007604912
SONIC X. [Published: 2007-02-09. Issue: no.
16, Mar 2007]
September 19,
2012
TX0007605207
SONIC X. [Published: 2007-03-16. Issue: no.
17, April 2007]
September 19,
2012
TX0007605212
SONIC X. [Published: 2007-04-13. Issue: no.
18, May 2007]
September 19,
2012
TX0007605218
SONIC X. [Published: 2007-05-03. Issue: no.
19, June 2007]
September 19,
2012
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 4 of 111
5
TX0007617976
SONIC X. [Published: 2007-05-31. Issue: no.
20, July 2007]
September 19,
2012
TX0007605216
SONIC X. [Published: 2007-07-02. Issue: no.
21, Aug 2007]
September 19,
2012
TX0007605214
SONIC X. [Published: 2007-07-30. Issue: no.
22, Sept 2007]
September 19,
2012
TX0007605119
SONIC X. [Published: 2007-08-27. Issue: no.
23, Oct 2007]
September 19,
2012
TX0007605116
SONIC X. [Published: 2007-09-24. Issue: no.
24, Nov 2007]
September 19,
2012
TX0007604938
SONIC X. [Published: 2007-10-22. Issue: no.
25, Dec 2007]
September 19,
2012
TX0007604930
SONIC X. [Published: 2007-11-07. Issue: no.
26, Jan 2008]
September 19,
2012
TX0007604928
SONIC X. [Published: 2007-12-17. Issue: no.
27, Feb 2008]
September 19,
2012
TX0007604925
SONIC X. [Published: 2008-01-14. Issue: no.
28, Mar 2008]
September 19,
2012
TX0007604921
SONIC X. [Published: 2008-02-11. Issue: no.
29, Mar 2008]
September 19,
2012
TX0007617978
SONIC X. [Published: 2005-10-05. Issue: no.
2, Dec 2005]
September 17,
2012
TX0007605205
SONIC X. [Published: 2005-11-02. Issue: no.
3, Jan 2006]
September 17,
2012
TX0007605203
SONIC X. [Published: 2005-11-30. Issue: no.
4, Feb 2006]
September 17,
2012
TX0007605201
SONIC X. [Published: 2006-01-25. Issue: no.
5, April 2006]
September 17,
2012
TX0007605184
SONIC X. [Published: 2006-02-22. Issue: no.
6, May 2006]
September 17,
2012
TX0007605180
SONIC X. [Published: 2006-03-22. Issue: no.
7, June 2006]
September 17,
2012
TX0007605172
SONIC X. [Published: 2006-04-19. Issue: no.
8, July 2006]
September 17,
2012
TX0007605168
SONIC X. [Published: 2006-06-28. Issue: no.
10, Aug 2006]
September 17,
2012
TX0007604931
SONIC X. [Published: 2006-06-28. Issue: no.
9, July 2006]
September 17,
2012
TX0007604940
SONIC X. [Published: 2006-07-22. Issue: no.
12, Nov 2006]
September 17,
2012
TX0007605164
SONIC X. [Published: 2006-07-26. Issue: no.
11, Sept 2006]
September 17,
2012
TX0007605175
SONIC X. [Published: 2006-10-25. Issue: no.
13, Dec 2006]
September 17,
2012
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 5 of 111
6
TX0007604935
SONIC X. [Published: 2006-11-01. Issue: no.
14, Jan 2006]
September 17,
2012
TX0007604933
SONIC X. [Published: 2006-12-13. Issue: no.
15, Feb 2007]
September 17,
2012
TX0007563319
SONIC SUPER SPECIAL. [Published: 1997-
04-29. Issue: no. 1, 4/29/1997] July 13, 2012
TX0007563317
SONIC SUPER SPECIAL. [Published: 1997-
08-19. Issue: no. 2, 8/19/1997] July 13, 2012
TX0007563313
SONIC SUPER SPECIAL. [Published: 1997-
10-21. Issue: no. 3, 10/21/1997] July 13, 2012
TX0007563302
SONIC SUPER SPECIAL. [Published: 1997-
12-30. Issue: no. 4, 1998] July 13, 2012
TX0007563180
SONIC SUPER SPECIAL. [Published: 1998-
03-17. Issue: no. 5, 3/17/1998] July 13, 2012
TX0007563178
SONIC SUPER SPECIAL. [Published: 1998-
06-16. Issue: no. 6, 6/16/1998] July 13, 2012
TX0007563175
SONIC SUPER SPECIAL. [Published: 1998-
09-29. Issue: no. 7, 9/29/1998] July 13, 2012
TX0007562833
SONIC SUPER SPECIAL. [Published: 1999-
03-16. Issue: no. 9, 3-16-99] July 13, 2012
TX0007562829
SONIC SUPER SPECIAL. [Published: 1999-
06-15. Issue: no. 10, 6/15/1999] July 13, 2012
TX0007562822
SONIC SUPER SPECIAL. [Published: 1999-
09-21. Issue: no. 11, 9/21/1999] July 13, 2012
TX0007562838
SONIC SUPER SPECIAL. [Published: 1999-
12-29. Issue: no. 8, 12/29/1999] July 13, 2012
TX0007562818
SONIC SUPER SPECIAL. [Published: 2000-
01-04. Issue: no. 12, 1/4/00] July 13, 2012
TX0007562815
SONIC SUPER SPECIAL. [Published: 2000-
01-04. Issue: no. 13, 01/04/2000] July 13, 2012
TX0007562811
SONIC SUPER SPECIAL. [Published: 2000-
06-01. Issue: no. 14, 06/01/2000] July 13, 2012
TX0007562780
SONIC SUPER SPECIAL. [Published: 2000-
11-01. Issue: no. 15, Feb 2001] July 13, 2012
PAu003353780
Sonic Unleashed Video Excerpts and
Screenshots. August 20, 2008
PA0000783698
The adventures of Sonic the Hedgehog : no.
238-101. February 8, 1996
PA0000783697
The adventures of Sonic the Hedgehog : no.
238-102. February 8, 1996
PA0000783696
The adventures of Sonic the Hedgehog : no.
238-103 February 8, 1996
PA0000783767
The adventures of Sonic the Hedgehog : no.
238-104, Sloww going. February 8, 1996
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 6 of 111
7
PA0000783769
The adventures of Sonic the Hedgehog : no.
238-105, High stakes Sonic. February 8, 1996
PA0000783766
The adventures of Sonic the Hedgehog : no.
238-106, Sonic breakout. February 8, 1996
PA0000783765
The adventures of Sonic the Hedgehog : no.
238-107, Trail of the missing... February 8, 1996
PA0000783740
The adventures of Sonic the Hedgehog : no.
238-108. February 8, 1996
PA0000783739
The adventures of Sonic the Hedgehog : no.
238-109. February 8, 1996
PA0000783760
The adventures of Sonic the Hedgehog : no.
238-110, King Coconuts. February 8, 1996
PA0000791347
The adventures of Sonic the Hedgehog : no.
238-111. February 8, 1996
PA0000791349
The adventures of Sonic the Hedgehog : no.
238-112. February 8, 1996
PA0000791345
The adventures of Sonic the Hedgehog : no.
238-113. February 8, 1996
PA0000791344
The adventures of Sonic the Hedgehog : no.
238-114. February 8, 1996
PA0000791340
The adventures of Sonic the Hedgehog : no.
238-115. February 8, 1996
PA0000791339
The adventures of Sonic the Hedgehog : no.
238-116. February 8, 1996
PA0000791341
The adventures of Sonic the Hedgehog : no.
238-117. February 8, 1996
PA0000791342
The adventures of Sonic the Hedgehog : no.
238-118. February 8, 1996
PA0000777971
The adventures of Sonic, the hedgehog : no.
238-137. February 8, 1996
PA0000777973
The adventures of Sonic, the hedgehog : no.
238-138. February 8, 1996
PA0000777970
The adventures of Sonic, the hedgehog : no.
238-139. February 8, 1996
PA0000778054
The adventures of Sonic the Hedgehog : no.
238-140. February 8, 1996
PA0000778058
The adventures of Sonic the Hedgehog : no.
238-141. February 8, 1996
PA0000778060
The adventures of Sonic the Hedgehog : no.
238-142. February 8, 1996
PA0000778056
The adventures of Sonic the Hedgehog : no.
238-143. February 8, 1996
PA0000777968
The adventures of Sonic, the hedgehog : no.
238-144. February 8, 1996
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 7 of 111
8
PA0000777967
The adventures of Sonic, the hedgehog : no.
238-145. February 8, 1996
PA0000778055
The adventures of Sonic the Hedgehog : no.
238-146. February 8, 1996
PA0000778061
The adventures of Sonic the Hedgehog : no.
238-147. February 8, 1996
PA0000777966
The adventures of Sonic, the hedgehog : no.
238-148. February 8, 1996
PA0000777965
The adventures of Sonic, the hedgehog : no.
238-149. February 8, 1996
PA0000778053
The adventures of Sonic the Hedgehog : no.
238-150. February 8, 1996
PA0000777972
The adventures of Sonic, the hedgehog : no.
238-151. February 8, 1996
PA0000778062
The adventures of Sonic the Hedgehog : no.
238-152. February 8, 1996
PA0000778059
The adventures of Sonic the Hedgehog : no.
238-153. February 8, 1996
PA0000778057
The adventures of Sonic the Hedgehog : no.
238-154. February 8, 1996
PA0000783699
The adventures of Sonic the Hedgehog : no.
238-155. February 8, 1996
PA0000783700
The adventures of Sonic the Hedgehog : no.
238-156. February 8, 1996
PA0000783706
The adventures of Sonic the Hedgehog : no.
238-157. February 8, 1996
PA0000783702
The adventures of Sonic the Hedgehog : no.
238-158. February 8, 1996
PA0000783701
The adventures of Sonic the Hedgehog : no.
238-159. February 8, 1996
PA0000783705
The adventures of Sonic the Hedgehog : no.
238-160. February 8, 1996
PA0000783761
The adventures of Sonic the Hedgehog : no.
238-161, 48 hour sonic : a.k.a. Fat & easy. February 8, 1996
PA0000783764
The adventures of Sonic the Hedgehog : no.
238-162, Lifestyles of the sick and twisted. February 8, 1996
PA0000783763
The adventures of Sonic the Hedgehog : no.
238-163, Sonic is running. February 8, 1996
PA0000783762
The adventures of Sonic the Hedgehog : no.
238-164, Roboninjas. February 8, 1996
PA0000791361
The adventures of Sonic, the hedgehog : no.
238-165. February 8, 1996
PA0000791242
The adventures of Sonic the Hedgehog : no.
238-119, Mystery of the missing... February 7, 1996
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 8 of 111
9
PA0000791233
The adventures of Sonic the Hedgehog : no.
238-120, Goodbye sucker. February 7, 1996
PA0000791232
The adventures of Sonic the Hedgehog : no.
238-121, Sonic getstrashed. February 7, 1996
PA0000791231
The adventures of Sonic the Hedgehog : no.
238-122, Pseudo Sonic. February 7, 1996
PA0000777969
The adventures of Sonic, the hedgehog : no.
238-123. February 7, 1996
PA0000791230
The adventures of Sonic the Hedgehog : no.
238-124, Tails in charge. February 7, 1996
PA0000791229
The adventures of Sonic the Hedgehog : no.
238-125, Sno problem. February 7, 1996
PA0000777963
The adventures of Sonic, the hedgehog : no.
238-126. February 7, 1996
PA0000791228
The adventures of Sonic the Hedgehog : no.
238-127, Dream on. February 7, 1996
PA0000791234
The adventures of Sonic the Hedgehog : no.
238-128, Musta ... beautiful baby. February 7, 1996
PA0000772425
The adventures of Sonic, the hedgehog : no.
238-129. February 7, 1996
PA0000791243
The adventures of Sonic the Hedgehog : no.
238-130, Full tilt tails. February 7, 1996
PA0000791244
The adventures of Sonic the Hedgehog : no.
238-131, MacHopper. February 7, 1996
PA0000772426
The adventures of Sonic the Hedgehog : no.
238-132. February 7, 1996
PA0000777964
The adventures of Sonic, the hedgehog : no.
238-133. February 7, 1996
PA0000772423
The adventures of Sonic, the hedgehog : no.
238-134. February 7, 1996
PA0000772427
The adventures of Sonic the Hedgehog : no.
238-135. February 7, 1996
PA0000791227
The adventures of Sonic the Hedgehog : no.
238-136, Robotnik's rival. February 7, 1996
PA0000659981 Sonic the hedgehog 3 June 22, 1994
PA0000659929 Sonic the hedgehog March 7, 1994
TXu000593150 Sonic spinball.
November 3,
1993
PA0000602981 Sonic the hedgehog 2
November 12,
1992
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 9 of 111
10
Sega also owns the following federally registered trademarks, which are valid
and registered on the Principal Register of the United States Patent and Trademark
Office (the "Sega Trademarks"). See id.ECF No. [11-1].
Registrati
on
Number Trademark
Registrati
on
Date
Goods and Services
3,009,472 SONIC THE
HEDGEHOG Oct. 25, 2005 For: Video game software in
class 009.
4,673,369 SONIC THE
HEDGEHOG
Jan. 20,
2015
For: Key rings of precious
metals; badges of precious
metal; wristwatches; watches;
clocks in class 014.
For: Printed matter, namely,
books, magazines and
newsletters featuring
animation, video games,
computer games, arcade
games, posters; comic books;
note books in class 016.
For: Bags, namely, backpacks,
shoulder bags in class 018.
For: Picture frames in class
020.
For: Cups; bottles, sold empty
in class 021.
For: Quilts; quilt covers;
pillowcases; bed blankets in
class 024.
For: Clothing, namely, t-
Shirts, shirts, socks,
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 10 of 111
11
underwear, sweaters, parkas,
head wear, pajamas; shoes in
class 025.
For: Amusement game
machines and coin-operated
amusement machines for use
in amusement parks; toys,
namely, electronic action toys,
inflatable toys, mechanical
action toys puzzles, toy
building blocks, board games;
action figures; electronic action
toys; dolls; stuffed toys;
playing cards; sports
equipment, namely,
skateboards in class 028.
For: Confectionery made of
sugar; ice cream in class 030.
For: Carbonated soft drinks;
non-alcoholic beverages,
namely, fruit-flavored soft
drinks and soda water in class
032.
6,358,553 SONIC THE
HEDGEHOG
May 25,
2021
For: Recorded videotapes and
videodiscs featuring
animation, action, adventure
and comedy films;
downloadable films and movies
featuring animation, action,
adventure and comedy
provided via a video-on-
demand service; motion picture
films featuring animation,
action, adventure and comedy;
downloadable graphics for
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 11 of 111
12
computers, video game
machines and mobile phones
featuring scenes and
characters based on animated
cartoons, computer games and
video games; electronic
publications, namely,
downloadable electronic books
and magazines in the field of
motion pictures, cartoons,
music, computer games and
video games; phonograph
records featuring music;
downloadable music files via a
global computer network and
wireless devices; recorded
compact discs featuring music,
video game sounds and
dialogues; compact discs,
prerecorded audio tapes, and
downloadable files featuring
musical sound recordings;
mobile phone straps; protective
cases for cell phones;
downloadable computer game
programs; recorded computer
game programs; downloadable
computer game software;
recorded computer game
software; downloadable video
game software; recorded video
game software; downloadable
video game programs; recorded
video game programs; video
game discs and cartridges;
downloadable computer game
software for use on mobile and
cellular phones in class 009.
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 12 of 111
13
3,584,384 SONIC
UNLEASHED
Mar. 03,
2008
For: Video game software in
class 009.
5,024,565 SONIC
RUNNERS
Aug. 23,
2016
For: Computer game programs;
computer game software;
computer game software for
use on mobile and cellular
phones; mobile phone straps;
protective cases for cell phones
in class 009.
For: Entertainment services,
namely, providing on-line
video games and on-line
computer games; providing
information on on-line games;
providing amusement facilities
in class 041.
5,268,608 SONIC MANIA Aug. 22,
2017
For: Computer game programs;
computer game software; video
game software; video game
programs; video game discs
and video game cartridges;
computer game software for
use on mobile and cellular
phones; protective cases for
cell phones; downloadable
graphics, images and moving
images for computers, video
game machines or mobile
phones featuring scenes and
characters based on computer
and video games;
downloadable computer and
video game software;
downloadable music files via a
global computer network and
wireless devices; musical
sound recordings; prerecorded
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 13 of 111
14
video discs and tapes featuring
music, comedy, drama, action,
adventure and animation in
class 009.
For: Entertainment services,
namely, providing on-line
video games and on-line
computer games in class 041.
5,619,845 SONIC BOOM Dec. 4, 2018
For: Computer game programs
for home video consoles;
electronic circuits, magnetic
computer tapes and disks,
optical disks, ROM cartridges
and other recording media,
namely, computer cartridges
and computer cassettes, all
containing video game
programs for use with home
video game consoles; electronic
circuits, magnetic computer
tapes and disks, optical disks,
ROM cartridges and other
recording media, namely,
computer cartridges and
computer cassettes, all
containing video game
programs for use with hand-
held games with liquid crystal
displays; video game software
for home video game consoles;
telecommunication machines
and apparatus, namely,
cellular phones and mobile
phones; straps for mobile
phones; computers; computer
game programs; electronic
circuits, magnetic computer
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 14 of 111
15
tapes and disks, optical disks,
ROM cartridges containing
computer game programs;
computer software for
children's education; computer
application software for mobile
phones, namely, game
software; computer game
software; computer software
for computer system
management; computer
programs for arcade video
game machines; electronic
circuits, magnetic computer
tapes and disks, optical disks,
ROM cartridges and other
recording media, namely,
computer cartridges and
cassettes, all containing video
game programs for use with
arcade video game machines;
game software for arcade video
game machines; video game
program; video game software;
phonograph records featuring
music; downloadable music
files; downloadable music files
for mobile telephones and
tablet computers; recorded
compact discs featuring music,
animated cartoons;
downloadable image files in
the field of computer games,
video games and animated
cartoons; downloadable image
files, namely, downloadable
moving image files for mobile
terminals, in the field of
computer games, video games
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 15 of 111
16
and animated cartoons;
recorded video discs and video
tapes featuring movies,
cartoons, video games;
videotapes and videodiscs
recorded with animation;
downloadable electronic
publications, namely, books,
comic books, magazines and
manuals featuring computer
games, video games and
animated cartoons in class
009.
For: Pastes and other
adhesives for stationery or
household purposes; hygienic
hand towels of paper, namely,
wet tissue; paper towels; table
napkins of paper; hand towels
of paper; handkerchiefs of
paper; stationery; seals;
stickers; printed matter,
namely, comic books, video
game instruction manuals,
children's books, children's
activity books, songbooks,
children's magazines,
magazines and pamphlets
featuring information and
articles about fashion and
games; pictorial prints; picture
books; catalogues in the field of
computer games, video games
and animated cartoons;
calendars; trading cards;
paintings and calligraphic
works; printed photographs;
photograph stands in class
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 16 of 111
17
016.
For: Clothing for domestic
pets; bags, namely, athletic
bags, all-purpose sports bags
and beach bags; pouches,
namely, felt pouches, leather
pouches and key pouches;
Boston bags; rucksacks; card
cases, namely, credit card
cases, name card cases and
game card cases; key cases;
purses; commutation-ticket
holders, namely, wallets,
document cases, ticket
pouches; business card cases;
unfitted vanity cases sold
empty; umbrellas and their
parts; walking sticks; canes;
metal parts of canes and
walking-sticks; walking cane
handles and walking stick
handles; saddlery in class 018.
For: Non-metal locks; cushions;
Japanese floor cushions
(zabuton); pillows; mattresses;
nameplates and door
nameplates, not of metal;
hand-held flat fans; hand-held
folding fans; furniture; wind
chimes; plastic keychains with
a small doll attached; plastic
key tags with a small doll
attached in class 020.
For: Plastic handheld shopping
baskets; cosmetic and toilet
utensils; toothbrushes; hair
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 17 of 111
18
brushes; toilet cases, namely,
toilet brush holder; kitchen
utensils, namely, batter
dispenser, grill covers,
barbeque branders and grates;
kitchen containers, namely,
kitchen containers, containers
for household or kitchen user
of precious metal and non-
electric kitchen containers not
made of precious metal; non-
electric cooking pots and pans;
non-electric coffee-pots;
Japanese cast iron kettles,
non-electric (tetsubin); non-
electric kettles; tableware,
other than knives, forks and
spoons, namely, coffee services,
tea services; drinking cups;
dishes; Japanese rice bowls
(chawan); lunch boxes;
Japanese style tea cups
(yunomi); Japanese style soup
serving bowls (wan); non-
electric portable coldboxes; rice
chests; food preserving jars of
glass; drinking flasks; vacuum
bottles; piggy banks in class
021.
For: Towels; Japanese cotton
towels (tenugui);
handkerchiefs; mosquito nets;
bedsheets; futon quilts; fitted
futon covers not of paper,
unfitted futon covers not of
paper; quilt covers; futon
ticksticks, namely, unstuffed
futon covers not of paper;
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 18 of 111
19
pillowcases; blankets, namely,
lap blankets, bed blankets and
baby blankets; table napkins of
textile; dish cloths; shower
curtains; banners and flags of
textile; seat covers of textile,
namely, fitted toilet seat covers
of textile, unfitted seat covers
of textile; wall hangings of
textile; curtains; table cloths
not of paper; draperies in the
nature of thick drop curtains
in class 024.
For: Lottery tickets;
amusement game machines
and apparatus, namely, coin-
operated amusement machines
for use in amusement parks;
arcade video game machines
other than for use with
television receivers; coin, card
or counter operated electronic
arcade-type video games and
amusement apparatus adapted
for use with an external
display screen or monitor,
amusement apparatus
incorporating a video monitor;
arcade medal redemption
game machines, namely,
arcade redemption game
machines which dispenses
tickets or the like to successful
players; arcade ticket
redemption game machines,
namely, arcade redemption
game machines which
dispenses tickets or the like to
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 19 of 111
20
successful players; arcade
game machines other than for
use with television receivers;
coin, card or counter operated
electronic arcade-type video
games and amusement
apparatus, namely,
amusement apparatus adapted
for use with an external
display screen or monitor;
fairground ride apparatus,
namely, amusement park
rides; home video game
machines; hand-held games
with liquid crystal displays;
toys, namely, rubber character
toys, plastic character toys,
wooden character toys,
electronic character toys,
educational character toys,
party favors in the nature of
small toys; squeeze toys; dolls;
stuffed toys; action figures;
puzzles; jigsaw puzzles; cards,
namely, game cards; trading
card games; go games;
Japanese playing cards,
namely, utagaruta; Japanese
chess (shogi games); dice;
Japanese dice games
(sugoroku); dice cups; Chinese
checkers as games; chess
games; checkers; checker sets;
conjuring apparatus, namely,
magic tricks; dominoes;
playing cards; Japanese
playing cards (hanafuda); mah-
jong; game machines and
apparatus, namely, coin-
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 20 of 111
21
operated video games; billiard
equipment; darts equipment,
namely, darts, dart shafts,
dart boards; digital darts
equipment, namely, electronic
dart game; slot machines;
sports equipment, namely,
baseball bats, baseball gloves
and baseball batting helmets,
soccer balls, basketballs,
hockey skates, skis in class
028.
For: Tea; coffee; cocoa;
confectionery, namely,
confectionery made of sugar,
confectionery, namely,
pastilles, fondants, fruit jellies
candy, chocolate, popcorn and
chewing gum; bread and buns;
sandwiches; steamed buns
stuffed with minced meat
(niku-manjuh); hamburger
sandwiches; pizzas; hot dog
sandwiches; meat pies; ice
cream; pasta, macaroni,
oatmeal, flakes, namely, corn
flakes, oat flakes, maize flakes;
pastry; bread; Chinese stuffed
dumplings (gyoza, cooked);
Chinese steamed dumplings
(shumai, cooked); sushi; fried
balls of batter mix with small
pieces of octopus, namely,
takoyaki; boxed lunches
consisting primarily of rice,
with added meat, fish or
vegetables; ravioli; instant
confectionery mixes, namely,
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 21 of 111
22
instant pudding mix, cake
mixes, sherbet mixes and ice
cream mixes; crepes; pasta
sauce; biscuits; cookies in class
030.
For: Carbonated drinks,
namely, carbonated soft
drinks; fruit juices; vegetable
juices; whey beverages in class
032.
For: Providing non-
downloadable electronic
publications in the nature of
magazines, newsletters,
picture books and comic books
in the field of computer games,
video games and animated
cartoons; services of reference
libraries for literature and
documentary records; book
rental; providing on-line
electronic publications via
internet or database including
websites in the nature of
magazines, news letters,
picture books and comic books
in the field of computer games,
video games and animated
cartoons; planning or
arrangement of showing
movies, live show
performances, plays or musical
performances; movie showing,
movie film production, or
movie film distribution;
providing on-line images,
movies, moving images and
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 22 of 111
23
graphics in the field of
computer games, video games
and animated cartoons;
providing on-line images,
movies, moving images and
graphics by computer
terminals or mobile phones;
entertainment in the form of
non-downloadable images
relating to fictional characters
from books, animation, toys
and games; direction or
presentation of plays;
providing on-line music, not
downloadable, via computer
terminals or mobile phones;
organization of game
tournaments; entertainment
services, namely, providing
amusement park rides in the
nature of bumper car ride and
roller coaster ride; providing
amusement facilities;
providing amusement arcade
services; providing amusement
parks; providing on-line video
games; providing on-line board
games; providing on-line
quizzes; providing information
relating to on-line computer
games; providing on-line
computer games; providing
information relating to
providing on-line computer
games; providing information,
in websites offering on-line
video games, consisting of the
game scores achieved by
players of the games on the
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 23 of 111
24
website and the rankings of
such players based on those
scores; production of radio or
television programs; television
entertainment, namely, a
continuing animated cartoons,
variety, news, comedy show
broadcast over television;
production of radio and
television programs; radio
entertainment, namely, a
continuing animated cartoons,
variety, news, comedy show
broadcast over the radio, radio
entertainment production in
class 041.
2,892,207 Oct. 12, 2004
For: Video game software;
computer game programs;
computer game discs video
computer game programs;
home video computer game
discs game discs containing
game programs for use with
hand-held video game
machines with built-in screens;
musical sound recordings; in
class 009.
4,366,529 Jul. 16, 2013
For: Computer game programs;
computer game software; video
game software; video game
programs; video game discs
and cartridges; computer game
software for use on mobile and
cellular phones; downloadable
graphics and images featuring
fictional characters or video
games, and music via a global
computer network;
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 24 of 111
25
downloadable graphics and
moving images for mobile
phones featuring fictional
characters or video games in
class 009.
3,972,721 Jun. 7, 2011
For: Computer game programs;
video game software; video
game programs in class 009.
6,187,305 SONIC
RACING Nov. 3, 2020
For: Downloadable computer
game programs; recorded
computer game programs;
downloadable computer game
software; recorded computer
game software; downloadable
video game software; recorded
video game software;
downloadable video game
programs; recorded video game
programs; video game discs
and cartridges; downloadable
computer game software for
use on mobile and cellular
phones; mobile phone straps;
protective cases for cell
phones; downloadable
graphics, images and moving
images for computers, video
game machines or mobile
phones featuring scenes and
characters based on computer
and video games;
downloadable computer game
and video game software;
downloadable music files via a
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 25 of 111
26
global computer network and
wireless devices; sound
recorded compact discs
featuring music, video game
sounds and dialogues; compact
discs, magnetic tapes, and
downloadable files featuring
musical sound recordings;
prerecorded video discs and
tapes featuring music, comedy,
drama, action, adventure and
animation; electronic
publications, namely,
downloadable books and
magazines in the field of
computer games, video games,
cartoons and music;
phonograph records featuring
music in class 009.
For: Entertainment services,
namely, providing on-line
video games and on-line
computer games; providing
entertainment information on
on-line games; providing non-
downloadable on-line computer
graphics, moving images and
images featuring scenes and
characters based on computer
and video games by computer
networks, video game
machines or mobile phones;
providing amusement
facilities; providing
amusement arcade services;
providing amusement parks;
organization, production and
presentation of video and
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 26 of 111
27
computer game contests and
tournaments; providing
entertainment information
about amusement facilities;
providing on-line music, not
downloadable in class 041.
6,263,485 TEAM SONIC
RACING Feb. 9, 2021
For: Downloadable computer
game programs; recorded
computer game programs;
downloadable computer game
software; recorded computer
game software; downloadable
video game software; recorded
video game software;
downloadable video game
programs; recorded video game
programs; video game discs
and cartridges; downloadable
computer game software for
use on mobile and cellular
phones; downloadable
computer game and video
game software in class 009.
For: Pastes and other
adhesives for stationery or
household purposes; hygienic
hand towels of paper; table
napkins of paper; hand towels
of paper; handkerchiefs of
paper; stationery; stickers;
printed matter, namely, comic
books, instruction manuals in
the field of computer games
and video games, children's
books, children's activity
books, songbooks, children's
magazines and magazines in
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the field of computer games,
video games, cartoons and
music; picture books, reference
books in the field of computer
games, video games, cartoons
and music; catalogues in the
field of computer games, video
games, cartoons and music;
calendars; general feature
magazines in the field of
computer games, video games,
cartoons and music; books,
namely, coloring books, date
books; pamphlets in the field of
computer games, video games,
cartoons and music; trading
cards other than for games;
printed instructional and
teaching material in the field
of computer games, video
games, cartoons and music;
photographs; photograph
stands in class 016.
For: Clothing, namely, t-shirts,
shirts, sweaters, sweatshirts,
jackets, pajamas, coats,
swimwear, mufflers as neck
scarves, gloves, scarves, neck
ties, socks, underwear, pants,
jeans, shorts, skirts,
underpants, robes; shoes;
boots; footwear; beach shoes;
galoshes; half-boots; lace boots;
sandals; sneaker; sports shoes;
wooden shoes; heels, namely,
high-heel shoes; masquerade
costumes; play costumes,
namely, costumes for use in
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children's dress up play,
costumes for use in role-
playing games; clothes for
sports, namely, sports jerseys
and breeches for sports; boots
for sports; headwear, namely,
hats and caps in class 025.
For: Coin-operated video
games; arcade game machines;
arcade video game machines;
amusement game machines
with built-in screens; toy
vehicles; dolls; stuffed toys; toy
action figures; trading card
games; playing cards; arcade
redemption game machines
which dispense tickets or
tokens to successful players;
arcade crane game machines
which dispense tickets or
tokens to successful players;
gaming machines, namely, slot
machines in class 028.
For: Tea; prepared coffee and
coffee-based beverages;
prepared cocoa and cocoa-
based beverages; almond
confectionery, namely, almond
cookies, chocolate
confectionery, namely,
chocolate mousses, chocolate
cakes and chocolate chips,
confectionery fondants,
namely, rolled fondant,
confectionery fruits jellies,
namely, fruit jelly candy,
confectionery fruits pastes,
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namely, fruit paste for
flavoring of food, peanut
confectionery, namely, peanut
brittle and peanut butter
confectionery chips, fruits-
based confectionery, namely,
fruit coulis, fruit turnovers and
fruit cobblers; bread and buns;
sandwiches; hamburgers
sandwiches; pizzas; hot dog
sandwiches; meat pies; ice
cream; preparations made
from cereals, namely, cereal-
based snack bars; sushi;
ravioli; instant confectionery
mixes, namely, cappuccino
mixes, hot chocolate mixes and
biscuit mixes; crepes; pasta
sauce; biscuits; cookies in class
030.
For: Beer; fruit-flavored
carbonated drinks; fruit juices;
vegetable juices; extracts of
hops for making beer; whey
beverages in class 032.
For: Entertainment services,
namely, providing on-line
video games and on-line
computer games; organization,
production and presentation of
video and computer game
contests and tournaments in
class 041.
7,002,602 SONIC PRIME Mar. 21,
2023
For: Downloadable computer
game programs; recorded
computer game programs;
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downloadable computer game
software; recorded computer
game software; downloadable
video game software; recorded
video game software;
downloadable video game
programs; recorded video game
programs; video game discs
and cartridges; downloadable
computer game software for
use on mobile and cellular
phones; mobile phone straps;
protective cases for cell
phones; downloadable
graphics, images, and video
recordings for computers, video
game machines and mobile
phones featuring scenes and
characters based on computer
and video games;
downloadable computer game
and video game software;
downloadable music files via a
global computer network and
wireless devices; sound
recordings recorded on
compact discs featuring music,
video game sounds and
dialogues; prerecorded compact
discs, magnetic audio tapes,
and downloadable files
featuring music; prerecorded
video discs and magnetic audio
tapes featuring music, comedy,
drama, action, adventure and
animation; electronic
publications, namely,
downloadable books and
magazines in the field of
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computer games, video games,
cartoons and music;
phonograph records featuring
music; animated cartoons,
namely, videotapes and
videodiscs recorded with
animation; downloadable
electronic publications in the
nature of books, manuals,
catalogs, pamphlets, and
magazines in the field of
computer games, video games,
cartoons and music;
pedometers; scales; bathroom
scales in class 009.
For: Pastes and other
adhesives for stationery or
household purposes; hygienic
hand towels of paper; towels of
paper; table napkins of paper;
hand towels of paper;
handkerchiefs of paper;
stationery; seals being
stationery; stickers being
stationery; blank notepads;
decorative stickers for portable
game machines; printed
instruction manuals in the
field of computer games, video
games, cartoons and music;
printed picture books; printed
reference books in the field of
computer games, video games,
cartoons and music; printed
catalogues in the field of
computer games, video games,
cartoons and music; printed
calendars; printed magazine
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publications in the field of
computer games, video games,
cartoons and music; printed
books in the field of computer
games, video games, cartoons
and music; printed pamphlets
in the field of computer games,
video games, cartoons and
music; printed trading cards,
other than for games; printed
game hint books and manuals;
printed photographs;
photograph stands in class
016.
For: Clothing for domestic
pets; bags, namely, carry-on
bags; shoulder bags; school
bags; traveling bags; pouches
of leather; boston bags;
rucksacks; key cases; wallets;
credit card cases; vanity cases,
not fitted; umbrellas and their
parts; walking sticks; canes;
metal parts of canes and
walking-sticks; handles for
canes and walking-sticks;
saddlery in class 018.
For: Clothing, namely, t-shirts,
shirts, sweaters, sweatshirts,
jackets, pajamas, coats,
swimwear, mufflers, gloves,
scarves, neck ties, socks,
underwear, pants, jeans,
shorts, skirts, underpants,
robes; footwear; beach shoes;
boots; galoshes; half-boots; lace
boots; sandals; sneakers;
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shoes; sports shoes; wooden
shoes; high-heeled shoes;
masquerade costumes; play
costumes, namely, costumes
for use in children's dress up
play, costumes for use in role-
playing games; clothes for
sports namely, sports jerseys
and breeches for sports; boots
for sports; headwear, namely
hats and caps in class 025.
For: Toy vehicles; dolls; plush
dolls; stuffed toys; toy action
figures; toy for pets; toy
jewelry; bath toys; electronic
action toys; plastic character
toys; children's educational
toys for developing cognitive
skills; construction toys;
puzzles; children's multiple
activity toys; toy building sets
comprised of toy building
blocks; novelty toy face masks;
trading card games; playing
cards; coin-operated video
games; arcade game machines;
arcade video game machines;
amusement game machines
with built-in screens; arcade
redemption game machines
which dispense tickets or
tokens to successful players;
arcade crane game machines
which dispense tickets or
tokens to successful players in
class 028.
For: Tea; prepared coffee and
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coffee-based beverages;
prepared cocoa and cocoa-
based beverages; almond
confectionery, namely, cookies;
chocolate confectionery;
confectionery fondants;
confectionery fruit jellies,
namely, fruit jelly candy;
confectionery fruit pastes for
flavouring of food; peanut
confectionery, namely, peanut
brittle and peanut butter
confectionery chips; fruit-based
confectionery, namely, hollow
candy forms filled with fruit;
bread and buns; steamed buns
stuffed with minced meat;
meat pies; ice cream; cereal
preparations¸, namely, cereal-
based snack bars; Chinese
stuffed dumplings; Chinese
steamed dumplings; sushi; pre-
packaged boxed lunches
consisting of rice, with added
meat, fish or vegetables;
ravioli; instant confectionery
mixes¸, namely, cappuccino
mixes, hot chocolate mixes,
cocoa mixes, cake mixes, cookie
mixes, pastry mixes, crepe
mixes, mixes for bakery goods,
biscuit mixes, instant pudding
mixes, mixes for candy
making, frosting mixes, frozen
yogurt mixes, pre-processed
mixes for making non-dairy
frozen confections; crepes;
pasta sauce; biscuits; cookies
in class 030.
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For: Entertainment services,
namely, providing on-line
video games and on-line
computer games; providing
information on on-line games;
providing non-downloadable
on-line computer graphics,
videos and images featuring
scenes and characters based on
computer and video games by
computer networks, video
game machines or mobile
phones; providing amusement
facilities; organization,
production and presentation of
video and computer game
events; arranging and
conducting of video game and
computer game events for
entertainment purposes;
organization or arrangement of
game tournaments; providing
information about amusement
facilities; providing on-line
music, not downloadable;
providing electronic
publications in the nature of
books, manuals, catalogs,
pamphlets, and magazines in
the field of computer games,
video games, cartoons and
music; services of reference
libraries for literature and
documentary records; book
rental; planning, management
or arrangement of showing
movies, theatrical shows, plays
or musical performances;
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providing information relating
to planning, management or
arrangement of showing
movies, theatrical shows, plays
or musical performances;
movie showing, movie film
production, or movie film
distribution; providing
information relating to
providing on-line graphics,
movies showing, moving
images, images, music and
publishing of electronic
publications; providing on-line
graphics, movies showing,
moving images, images, music
and text information by
computer terminals or mobile
phones; providing information
relating to providing on-line
graphics, movies showing,
moving images, images, music
and publishing of electronic
publications by computer
terminals or mobile phones;
providing on-line graphic
novels, not downloadable,
relating to characters of books,
animated cartoons, toys,
games; images showing;
presentation of live show
performances; direction or
presentation of theatrical
plays; presentation of musical
performances; on-line
presentation of shows,
theatrical plays or musical
performances; providing
information relating to on-line
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presentation of shows,
theatrical plays or musical
performances; provision of
shows, theatrical plays or
musical performances by
computer terminals or mobile
phones; providing information
relating to provision of shows,
theatrical plays or musical
performances by computer
terminals or mobile phones;
production of theatrical shows;
production of live theatrical
and musical shows;
presentation of musical
performances, direction or
presentation of theatrical plays
and presentation of musical
performances provided on-line
from a computer network;
production of moving images
and music using the internet
via streaming; production of
moving images and music
relating to animated cartoons
using the internet via
streaming; on-line production
of radio or television programs;
production of radio or
television programs and
production of broadcast
programs, using computer
graphics; directing of radio and
television programs; providing
information relating to
direction of radio and
television programs;
organization of sporting
events; providing sports
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information; organization and
provision of games and
competitions via the internet;
organization, arranging and
conducting of computer game
and video game tournaments;
organization, arranging and
conducting of photo sessions;
providing information relating
to sports and sporting events;
organizing and conducting of
sporting and cultural events;
rental of game machines and
apparatus; providing exercise
facilities; rental of sports
equipment; photography in
class 041.
1,566,116 Nov. 14,
1989
For: Video game attachments
for television sets, namely,
video game control sticks,
video game programs recorded
on integrated circuits in the
form of cartridges and cards in
class 028.
5,808,893 Jul. 23, 2019
For: Apparatus and
instruments for conducting,
switching, transforming,
accumulating, regulating or
controlling electricity;
apparatus for recording,
transmission or reproduction
of sound or images;
prerecorded magnetic data
carriers, recording discs,
compact discs, DVDs and
computer media featuring
scenes and characters from
computer and video games;
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mechanisms for coin-operated
apparatus; cash registers,
calculating machines, data
processing equipment,
computers; computer software
for playing video games;
computer software for
database management;
computer software for
controlling and managing
business data; fire-
extinguishing apparatus;
computer software
development tools;
downloadable computer file
sharing software to enable
uploading, downloading,
accessing, posting, displaying,
tagging, blogging, streaming,
linking, sharing or otherwise
providing electronic media or
information via computer and
communication networks;
computer programs, namely,
downloadable software for
playing video games; programs
for cell phones, namely,
downloadable software for
playing video games; game
programs for smartphones,
namely, downloadable
computer game software;
programs for smartphones,
namely, downloadable
software for playing video
games; downloadable computer
game programs for handheld
terminals; coils, electric;
particle accelerators; reflecting
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discs for wear, for the
prevention of traffic accidents;
clothing for protection against
accidents, irradiation and fire;
accumulator jars; battery
boxes; acidimeters for
batteries; hydrometers; plates
for batteries; whistle alarms;
acoustic sound alarms;
acoustic conduits; speaking
tubes; actinometers; adding
machines; aerometers;
enlarging apparatus for
photography; electro-dynamic
apparatus for the remote
control of railway points;
magnets; electromagnetic coils;
air analysis apparatus;
alcoholmeters; alidades;
igniting apparatus, electric, for
igniting at a distance, namely,
remote control starters for
vehicles; batteries for lighting;
altimeters; asbestos gloves for
protection against accidents;
asbestos clothing for protection
against fire; ammeters;
amplifiers; amplifying tubes
for amplifiers; anemometers;
fire extinguishers; anodes;
anode batteries; electrical
transformers; optical
apertometers; money counting
and sorting machines;
surveying instruments;
surveying chains; lenses for
astrophotography; mechanisms
for coin-operated apparatus;
comparators; fire alarms;
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automatic indicators of low
pressure in vehicle tires;
protective suits for aviators;
alarm bells, electric for use
with burglar alarms; rods for
water diviners; life-saving
rafts; scales; meteorological
balloons; demagnetizing
apparatus for magnetic tapes;
tape recorders; blank magnetic
computer tapes; barometers;
weighing machines;
weighbridges; fire beaters;
chargers for electric batteries;
betatrons; ticket dispensers,
namely, video lottery ticket
terminals, electronic parking
lot ticket dispensers; cabinets
for loudspeakers; close-up
lenses; electricity terminals;
pressure indicator plugs for
valves; galvanometers;
electrical push buttons for door
bells; electrical branch
distribution boxes; tone arms
for record players; spirit levels;
punched card machines for
offices; sheaths for electric
cables; frames for photographic
transparencies; circular slide
rules; slide-rules; slide
calipers; blueprinting
machines; cinematographic
cameras; capillary tubes for
laboratory research use;
protective helmets; respiratory
masks, other than for artificial
respiration or medical
purposes; solderers' helmets;
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eyeglass chains; photography
darkroom equipment, namely,
lamps; boiler control
instruments; drying racks for
photography; editing
appliances for cinematographic
films; printed circuits; blinkers
being traffic light signaling
lights; signal bells; containers
for microscope slides; electric
installations for the remote
control of industrial
operations; switchboxes for
electricity; commutators;
marine compasses; eyepieces,
namely, spectacles; thread
counters; pedometers;
metronomes; condensers;
conductors, electric; electricity
conduits; circuit closers;
electrical connectors; junction
boxes; contacts, electric;
regulating apparatus, electric;
speed checking apparatus for
vehicles, namely, laser speed
detectors; converters, electric;
photographic, electrostatic,
and thermic photocopiers;
eyeglass cords; correcting
lenses; objectives lenses; diving
suits; electric apparatus for
commutation, namely,
commutators; switches,
electric; electricity limiters;
electrical connections, namely,
sockets, plugs and other
contacts; current rectifiers; cell
switches for electricity;
dressmakers' tape measures;
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crucibles for laboratory use;
appliances for measuring the
thickness of leather;
cyclotrons; counterfeit false
coin detectors; shutter release;
densimeters; video disks and
tapes with recorded animated
cartoons; laboratory trays;
metal detectors for industrial
or military purposes; sonars;
shutters for cameras; acoustics
diaphragms for use in sound
recording; centering apparatus
for photographic
transparencies; cameras;
photographic transparencies;
slide projectors; dictating
machines; diffraction
apparatus for use in
microscopy; loudspeakers;
circuit breakers; record
players; microscopes; distance
recording apparatus; range
finders; distribution boards for
use with electricity;
distribution consoles for use
with electricity; compasses
being measuring instruments;
tape measures; dynamometers;
water level indicators; fire
escapes, namely, ladders;
flash-bulbs for photography;
telephone receivers;
fluorescent screens; projection
screens; workmen's protective
face-shields; screens for
photography; drainers for use
in photography; electric loss
indicators; cables, electric;
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electricity ducts; control panels
for use in electricity;
connections for electric lines;
couplings, electric; relays,
electric; electrolysers;
transmitters of electronic
signals; transmitting sets
comprising transmitters for
use in telecommunication;
blank sound recording
magnetic strips; spools for
cameras; mechanical signs;
epidiascopes; test tubes for
laboratory use; balancing
apparatus namely, balances;
thermostats; egg-candlers; fuel
gauges; gasoline gauges;
spark-guards for protection
against injury; cases especially
made for photographic
apparatus and instruments,
namely, video cameras;
refractometers; exposure
meters being light meters;
invoicing machines, namely,
printers; apparatus for
fermentation being laboratory
apparatus; wires, electric;
magnetic wires; plumb bobs;
plumb lines; nets for protection
against accidents; safety nets;
safety tarpaulins; film cutting
apparatus; filters for
respiratory masks for
laboratory use; camera filters
for use in photography; battery
chargers; frequency meters;
fuses; radios; galena crystals
detectors for use in electronics;
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galvanic batteries; gloves for
protection against accidents;
gloves for divers; gloves for
protection against X-rays for
industrial purposes; gas
testing instruments;
gasometers being measuring
instruments; surveying
apparatus and instruments;
leveling staffs being surveying
instruments; drying apparatus
for photographic prints;
glazing apparatus for
photographic prints; rulers
being measuring instruments;
measuring glassware; screens
for photoengraving; grids for
batteries; clothing for
protection against fire; audio-
and video-receivers;
heliographic apparatus;
hygrometers; identification
threads for electric wires;
identification sheaths for
electric wires; life saving
apparatus and equipment,
namely, flotation vests; fire
hose nozzles; fire engines; fire
trucks; slope indicators;
taximeters; quantity
indicators; vacuum gauges;
speed indicators; electricity
inductors; armatures for use in
electricity apparatus; data
processing apparatus; mirrors
for inspecting work; carriers
for dark plates in photography;
electricity inverters; ionizers
for scientific or laboratory use;
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peepholes, namely, magnifying
lenses for doors; furniture
especially made for
laboratories; lactodensimeters;
lactometers; darkroom lamps
for photography; magic
lanterns; signal lanterns for
safety purposes; lasers, not for
medical purposes; optical
lenses; letter scales;
magnifying glasses; signs,
luminous; neon signs;
spectacles; surveyors' levels;
spectacle lenses; pressure
gauges; periscopes; coin-
operated mechanisms for
television sets; megaphones;
computer memory devices;
carpenters' rules; mercury
levels; speed measuring
apparatus for use in
photography; microphones;
microtomes; time switches,
automatic; optical mirrors;
breathing apparatus for
underwater swimming; electric
navigational instruments;
spectacle frames; batteries,
electric; accumulators, electric;
optical prisms for scientific
purposes; octants; ohmmeters;
wavemeters; optical glass for
use with spectacles;
computers; oscillographs;
oxygen transvasing apparatus;
ozonisers; micrometers;
signaling panels, luminous or
mechanical for traffic
purposes; lightning conductors
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being rods; parking meters;
apparatus for measuring the
thickness of skins for
laboratory use; acid
hydrometers; weighing
apparatus and instruments;
salinometers; washing trays
for use in photography; stands
for photographic apparatus;
viewfinders, photographic;
photometers; phototelegraphy
apparatus; pince-nez; pipettes;
plane tables being surveying
instruments; planimeters; ear
plugs for divers; bells for use
as warning devices; test
weights; polarimeters;
radiotelephony sets;
radiotelegraphy sets; pressure
measuring apparatus; pressure
indicators; mouth guards for
athletic use; pyrometers; radar
apparatus; vehicle radios;
protractors being measuring
instruments; apparatus and
installations for the production
of X-rays, not for medical
purposes; X-ray tubes not for
medical purposes; protection
devices against X-rays, not for
medical purposes; telephone
apparatus; refractors for
laboratory use; X-ray
apparatus not for medical
purposes; spectroscopes;
resistances, electric;
thermometers, not for medical
purposes; respirators for
filtering air other than for
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artificial respiration; breathing
apparatus, except for artificial
respiration for underwater use;
rheostats; balances for use in
steelyards; emergency signals,
luminous or mechanical;
saccharometers; electrical
probes for scientific purposes;
satellites for scientific
purposes; choking coils for
electrical impedance;
electricity wire connectors;
locks, electric; sextants;
signaling whistles; vehicle
breakdown warning triangles;
electro-dynamic apparatus for
the remote control of signals;
simulators for the steering and
control of vehicles; sirens;
sound transmitting apparatus;
sound recording apparatus;
sound reproduction apparatus;
spherometers; stereoscopes;
needles for record players;
sulfitometers; teleprinters;
tachometers; screw-tapping
gauges; telegraph transmitting
apparatus; television
apparatus for projection
purposes; telegraph wires;
masts for wireless aerials;
teleprompters; telephone
transmitters; teleruptors;
binoculars; telescopes;
temperature indicators; time
recording apparatus;
theodolites; thermostats for
vehicles; revolution counters;
speed regulators for record
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players; television
transmitters; radio
transmitters; precision
balances; marking gauges for
joinery; vacuum tubes for
radios; urinometers;
variometers; verniers; blank
videotapes; viscosimeters;
voltage regulators for vehicles;
voting machines; voltmeters;
apparatus for changing record
player needles; stills for
laboratory experiments; fuse
wire; anticathodes; dog
whistles; electrical anti-theft
warning apparatus for
personal use; beacons,
luminous; holders for electric
coils; photographic films,
exposed; road signs, luminous
or mechanical; life buoys;
signaling buoys; electric
buzzers; directional compasses;
fog signals, non-explosive; cash
registers; radiology screens for
industrial purposes; identity
cards, magnetic; photovoltaic
cells; densitometers not for
medical use; blank disks,
magnetic; blank floppy disks;
head cleaning tapes for use in
recording sound and video;
video recorders; computer
keyboards; integrated circuits;
semi-conductors; integrated
circuit chips; cathodes; life
jackets; life belts;
cinematographic film, exposed;
materials for electricity mains,
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namely, wires, cables; contact
lenses; containers for contact
lenses; incubators for bacteria
culture; solar batteries; copper
wire, insulated; discharge
tubes, electric, other than for
lighting; diaphragms for use in
photography; distillation
apparatus for scientific
purposes; dosage dispensers,
namely, machines for
dispensing pre-determined
dosages of medication; electric
door bells; spectacle cases;
furnaces for laboratory use;
optical fibers, namely, fibers
being light conducting
filaments; telephone wires; x-
ray films, exposed; filters for
ultraviolet rays, for
photography; horns for
loudspeakers; tripods for
cameras; bar code readers;
bullet-proof waistcoats and
vests; marking buoys; wafers
for integrated circuits;
chromatography apparatus for
laboratory use; chronographs
being time recording
apparatus; blank compact
discs for audio-video; blank
compact discs for read-only
memory; computer peripheral
devices; optical condensers;
acoustic couplers; couplers
being data processing
equipment; decompression
chambers; plotters; divers'
masks; electronic pens with
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visual display units; encoded
magnetic cards, namely,
charge cards, debit cards,
identify cards; facsimile
machines; fire boats; interfaces
for computers; juke boxes for
computers; knee-pads for
workers; light dimmers being
electric regulators; magnetic
encoders; magnetic tape units
for computers;
microprocessors; modems;
monitors being computer
hardware; computer monitors;
mouse being a computer
peripheral; optical character
readers; printers for use with
computers; processors being
central processing units;
readers being data processing
equipment; scanners being
data processing equipment;
smoke detectors; electronic
transistors; x-ray photographs,
other than for medical
purposes; junction sleeves for
electric cables; abacuses;
electronic agendas; answering
machines; camcorders; cassette
players; compact disc players;
disk drives for computers;
electrified rails for mounting
spot lights for emergency use;
electronic pocket translators;
electronic tags for goods; fire
blankets; flashlights for use in
photography; integrated circuit
cards, namely, blank smart
cards; measuring spoons;
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notebook computers; electronic
notice boards; pocket
calculators; shoes for
protection against accidents,
irradiation and fire; sprinkler
systems for fire protection;
battery starter cables for
motors; sunglasses; time clocks
being time recording devices;
blank video cassettes; video
game cartridges; video screens;
video telephones; goggles for
sports; nose clips for divers
and swimmers; protective
helmets for sports;
downloadable electronic
publications, namely, books
featuring scenes and
characters from computer and
video games; navigation
apparatus for vehicles being
on-board computers; decorative
magnets; cordless telephones;
mouse pads; personal stereos;
wrist rests for use with
computers; coaxial cables; fiber
optic cables; covers for electric
outlets; marine depth finders;
electrified fences; computer
game software; headphones;
lighting ballasts; radio pagers;
satellite navigational
apparatus, namely, GPS;
solenoid valves being
electromagnetic switches;
voltage surge protectors;
walkie-talkies; wind socks for
indicating wind direction;
light-emitting electronic
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pointers; resuscitation
mannequins being teaching
apparatus; stage lighting
electrical regulators; egg
timers, namely, sandglasses;
DNA chips; DVD players;
automated teller machines
(ATM); traffic-light apparatus
being signaling devices; hands
free kits for phones; asbestos
screens for firemen; riding
helmets; clothing especially
made for laboratories; encoded
identification bracelets,
magnetic; transponders;
downloadable ring tones for
mobile phones; downloadable
music files; downloadable
image files; crash test
dummies; laboratory
centrifuges; printed circuit
boards; blank USB flash
drives; global positioning
system (GPS) apparatus;
portable media players; cell
phone straps; light emitting
diodes (LEDs); triodes; step-up
transformers; laptop
computers; fire hose; bags
adapted for laptops; sleeves for
laptops; digital photo frames;
petri dishes; pitot tubes;
stroboscopes; safety traffic
cones; temperature indicator
labels, not for medical
purposes; electronic book
readers; smartphones; toner
cartridges, unfilled, for
printers and photocopiers;
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baby monitors; video baby
monitors; lens hoods; tablet
computers; encoded key cards;
3D spectacles; memory cards
for video game machines;
bullet-proof clothing;
accelerometers; electrical
adapters; life-saving capsules
for natural disasters; computer
hardware; solar panels for the
production of electricity;
telescopic sights for artillery;
digital signs; electronic sports
training simulators; computer
game cartridges; computer
game programs; computer
game software downloadable
from a global computer
network; computer programs
for video and computer games;
interactive multimedia
computer game programs;
computer game discs;
downloadable computer game
programs; electronic game
programs; electronic game
software; interactive video
game programs; recorded
computer game programs;
video game discs; video game
programs; video games
software; virtual reality game
software; audio tapes featuring
music; cases for telephones;
cellular phones; compact discs
featuring music; prerecorded
audio tapes featuring music;
prerecorded video cassettes
featuring music in class 009.
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For: Printed matter namely,
comic books, video game
instruction manuals, children's
books, children's activity
books, songbooks, children's
magazines, magazines and
pamphlets featuring
information and articles about
fashion and games;
bookbinding material;
photographs; stationery;
adhesives for stationery or
household purposes; paint
brushes; printers' type;
printing blocks; steel letters for
use in printing; steel pens;
adhesive tape dispensers being
office requisites; address
stamps; addressing machines;
paper; posters; printed
advertisement boards of paper
or cardboard; franking
machines for office use; clips
for letters; paper clips; binder
clips; clips for name badge
holders; pen clips; stapling
presses; photo albums;
pictures; print engravings;
cigar bands; pencil sharpening
machines, electric or non-
electric; bookends; hand-rests
for painters; aquarelles;
architects' models; document
files being stationery; writing
slates; slate pencils; silver
paper; modelling clay; printed
arithmetical tables; print
engravings; lithographic works
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of art; paintings and pictures,
framed or unframed; pencils;
newspapers; atlases; loose-leaf
binders; gummed tape; place
mats of paper for beer glasses;
printed tickets; printing
blocks; drawing pads; pads for
writing being stationery;
spools for inking ribbons;
wristbands for the retention of
writing instruments;
pamphlets in the field of
computer games, video games,
animated films and animated
cartoons; embroidery designs
being printed patterns;
drawing pins; moisteners being
office requisites; painters'
brushes; blotters; stamps seals;
sealing stamps; inking pads;
sealing wax; envelope sealing
machines for offices; sealing
compounds for stationery
purposes; writing or drawing
books; trays for sorting and
counting money; tracing
patterns; tracing paper;
tracing cloth; finger-stalls
being office requisites; printing
type; carbon paper; paper for
recording machines; note
books; square rulers for
drawing; greeting cards; index
cards; paper sheets for note
taking; cardboard; hat boxes of
cardboard; perforated cards for
jacquard looms; cardboard
tubes; catalogs in the field of
computer games, video games,
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animated films and animated
cartoons; tags for index cards;
song books; composing frames
for printing; folders for papers;
painters' easels; numbers for
printing type; Indian inks;
chromolithographs; modelling
wax, not for dental purposes;
paper files; office perforators;
toilet paper; books in the field
of computer games, video
games, animated films and
animated cartoons; compasses
for drawing; printers' type
numerals and letters; letter
trays; conical paper bags;
correcting fluids for type;
correcting ink for use in
heliography; pencil leads;
histological sections for
teaching purposes; French
curves; book covers; writing
chalk; chalk for lithography;
tailors' chalk; writing chalk
and marking chalk holders;
pencil holders; pencil lead
holders; cream containers of
paper, namely, paper boxes for
use as food packaging; paper
clasps; rollers for typewriters;
transfers being decalcomanias;
graphic prints; graining combs;
drawing boards; drawing
instruments; diagrams for
building computer circuits;
envelopes for use as stationery;
duplicators, namely,
duplicating paper, machines,
ink; etchings; packing paper;
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pen nibs; typewriters, electric
or non-electric; pen cases; nibs
of gold for pens; erasing
products, namely, erasers;
drawing shields; erasing
shields; rubber erasers;
electrocardiograph paper;
hand-operated and electric
hole punches being office
requisites; writing and
drawing ink; inking ribbons;
inkwells; envelope sealing
machines for offices; printed,
photographs; pen wipers;
sealing stamps; fabrics for
bookbinding; ledger books;
telephone indexes; figurines
being statuettes of papier
mâché; filter paper; filtering
materials in the nature of
paper; forms, printed; charcoal
pencils; stencils; galley racks
for printing; electrotypes;
geographical maps; terrestrial
globes; artists' watercolor
saucers; graphic art
reproductions; graphic
representations; scrapers being
erasers for offices; engraving
plates; hectographs; printed
timetables; moisteners for
gummed surfaces being office
requisites; postcards; hand
labeling appliances, namely,
label printing machines;
printers' blankets, not of
textile; manuals being
handbooks in the field of
computer games, video games,
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animated films and animated
cartoons; writing paper;
paperweights; tracing needles
for drawing purposes; drawing
pens; table linen of paper;
lithographs; lithographic
stones; booklets in the field of
computer games, video games,
animated films and animated
cartoons; luminous paper;
papier mâché; manifold paper;
marking chalk; plastics for
modeling, namely, polymer
modelling clay; modelling
compounds; modelling paste;
handkerchiefs of paper; inking
sheets for duplicators;
tablecloths of paper;
blackboards; paper-clips;
oleographs; binding strips for
use in bookbinding; sealing
wafers for stationery purposes;
palettes for painters;
pantographs being drawing
instruments; stationery;
parchment paper; pastels
being crayons; printed sewing
patterns; stencil cases; house
painters' rollers; canvas for
painting; paint boxes being
articles for use in school;
plastic film for wrapping;
apparatus for mounting
photographs, namely,
photograph mounts;
photograph stands; photo-
engravings; blueprints;
stationery folders; fountain
pens; stencil plates; stencils;
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portraits; flower-pot covers of
paper; mimeograph apparatus
and machines; paper tapes and
cards for the recordal of
computer programs; printed
prospectuses in the field of
computer games, video games,
animated films and animated
cartoons; paper for radiograms;
drawing rulers; printers'
reglets; bookbinding material;
bookbindings; cloth for
bookbinding; cords for
bookbinding; inking sheets for
document reproducing
machines; pens being office
requisites; magazines in the
field of computer games, video
games, animated films and
animated cartoons; paper
ribbons; typewriter ribbons;
bags of paper or plastics, for
merchandise packaging; stamp
pads; school supplies, namely,
stationery; bookmarkers;
greeting cards; steatite tailor's
chalk; balls for ball-point pens;
tablemats of paper; desk mats;
typewriter keys; holders for
stamping seals; cases for
stamping seals; postage
stamps; stamp stands; paper
transparencies; gluten glue for
stationery or household
purposes; adhesives glues for
stationery or household
purposes; adhesive tapes for
stationery or household
purposes; adhesive bands for
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stationery or household
purposes; address plates for
addressing machines;
almanacs; calendars; starch
paste adhesive for stationery
or household purposes;
paintbrushes; self-adhesive
tapes for stationery or
household purposes; elastic
bands for offices; bibs of paper;
wood pulp paper board for
stationery purposes; wood pulp
paper; boxes of cardboard or
paper; stands for pens and
pencils; bottle envelopes of
cardboard or paper; coasters of
paper; announcement cards;
plastic bubble packs for
wrapping or packaging; flags of
paper; paper shredders for
office use; sheets of reclaimed
cellulose for wrapping; desktop
cabinets for stationery; glue for
stationery or household
purposes; paper knives being
letter openers; garbage bags of
paper or of plastics; pencil
sharpeners, electric or non-
electric; tissues of paper for
removing make-up; table
napkins of paper; place mats of
paper; drawing squares;
drawing t-squares; penholders;
inkstands; writing cases,
namely, sets of pencils; bottle
wrappers of cardboard or
paper; placards of paper or
cardboard; towels of paper;
face towels of paper; labels of
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paper, cardboard; etching
needles; viscose sheets for
wrapping; gums being
adhesives for stationery or
household purposes; gummed
cloth for stationery purposes,
namely, bookbinding; isinglass
for making glue for stationery
or household purposes; bags
for microwave cooking; paper
coffee filters; plastic cling film,
extensible, for palletization;
inking ribbons for computer
printers; signboards of paper
or cardboard; stickers;
bookbinding apparatus in the
nature of machines being office
equipment; comic books;
copying paper; holders for
checkbooks; ink sticks; ink
stones; musical greeting cards;
newsletters in the field of
computer games, video games,
animated films and animated
cartoons; packaging material
made of paper based starches;
waxed paper; passport holders;
writing brushes; writing
instruments; drawer liners of
paper, perfumed or not; credit
card imprinters, non-electric;
document laminators for office
use; Xuan paper for Chinese
painting and calligraphy;
writing board erasers;
clipboards; chart pointers, non-
electronic; paper bows for gift
wrapping; moulds for modeling
clays being artists' materials;
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money clips; trading cards
other than for games;
absorbent sheets of paper or
plastic for foodstuff packaging;
humidity control sheets of
paper or plastic for foodstuff
packaging; correcting tapes
being office requisites; paint
trays; marking pens;
informational flyers in the field
of computer games, video
games, animated films and
animated cartoons; document
holders; page holders; polymer
modelling clay; packing,
cushioning, and stuffing
materials of paper or
cardboard; stuffing of paper or
cardboard; paper tags; printed
lottery tickets other than toys;
computer game instruction
manuals; computer user
manuals in class 016.
For: Clothing, namely, tops,
bottoms, shirts; footwear other
than special footwear for
sports; headwear; non-slipping
devices for footwear, namely,
soles; motorists' clothing,
namely, tops, bottoms, shirts;
bath sandals; bath slippers;
stockings; sweat-absorbent
stockings; heelpieces for
stockings; berets; overalls;
boas being necklets; caps being
headwear; hosiery; half-boots;
tips for footwear; dress shields;
lace boots; collars as clothing;
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camisoles; boxer shorts; skull
caps; bodices being lingerie;
underwear; hoods as clothing;
hat frames; cap peaks; belts;
shawls; dressing gowns;
sweaters; chasubles; socks;
sock suspenders; garters;
stocking suspenders; boot
uppers; inner soles; shirts;
shirt fronts; short-sleeve
shirts; hats; head wear;
fittings of metal for footwear;
furs being clothing; detachable
collars; tights; wet suits for
water-skiing; combinations;
corselets; suits; ready-made
clothing, namely, tops,
bottoms, shirts; babies' pants;
ear muffs; neckties; footwear
uppers; breeches for wear;
trousers; cyclists' clothing,
namely, tops, bottoms, shirts;
outer clothing, namely, tops,
bottoms, shirts; gloves; ready-
made linings being parts of
clothing; sashes for wear;
knitwear clothing, namely,
shirts, dresses, sweaters; shirt
yokes; esparto shoes or
sandals; fur stoles; top hats;
gabardines; corsets being
clothing; corsets being
foundation clothing; girdles;
galoshes; wimples; gymnastic
shoes; coats; waterproof
clothing, namely, tops,
bottoms, shirts; leggings,
namely, leg warmers; jerseys;
skirts; clothing layettes;
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liveries; sports jerseys not for
athletic purposes; cuffs; aprons
being clothing; muffs;
maniples; mittens; slippers;
pelerines; pelisses; beach
clothes, namely, tops, bottoms,
shirts; beach shoes; pockets for
clothing; dresses; wooden
shoes; sandals; underpants;
brassieres; overcoats;
heelpieces for footwear; togas;
welts for footwear; uniforms;
stuff jackets; jackets; paper
clothing, namely, tops,
bottoms, shirts; veils; bathing
caps; bathing trunks; bathing
suits; bath robes; bibs, not of
paper; soles for footwear; heels;
footmuffs, not electrically
heated, for use as clothing;
studs for football boots;
headbands; parkas; petticoats;
ski boots; slips as
undergarments; teddies as
undergarments; bandanas
being neckerchiefs; clothing for
gymnastics, namely, tops,
bottoms, shirts; clothing of
imitations of leather, namely,
tops, bottoms, shirts; clothing
of leather, namely, tops,
bottoms, shirts; mantillas;
masquerade costumes; saris;
tee-shirts; turbans; ascots;
shower caps; fishing vests;
money belts as clothing; pocket
squares; paper hats as
clothing; sleep masks; skorts;
ponchos; sarongs; ski gloves;
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leggings in the nature of
trousers; jumper dresses;
visors being headwear; sports
singlets; valenki being felted
boots; albs in class 025.
For: Decorations for Christmas
trees; bladders of balls for
games; artificial fishing bait;
caps for toy pistols; toys for
domestic pets; ring games;
Christmas trees of synthetic
material; bows for archery;
archery implements; edges of
skis; swings; balls for games;
play balloons; billiard table
cushions; rocking horses;
batting gloves; dolls' feeding
bottles; stationary exercise
bicycles; billiard balls; chalk
for billiard cues; billiard
markers; skittles; marbles for
games; building blocks as toys;
bob-sleighs; explosive bonbons,
namely, Christmas crackers;
skating boots with skates
attached; candle holders for
Christmas trees; balls for
playing games and sports;
bowling apparatus and
machinery; boxing gloves; gut
for rackets; golf clubs; rods for
fishing; kites; kite reels;
targets; bells for Christmas
trees; counters being discs for
games; building games; strings
for rackets; machines for
physical exercises; body-
building apparatus; novelties
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for parties and dances in the
nature of paper party favors;
shin guards being sports
articles; cricket bags, namely,
bags specially designed to hold
cricket equipment; hockey
sticks; dice; chest expanders
being exercisers; discuses for
sports; dominoes; chess games;
chessboards; toy pistols; rollers
for stationary exercise bicycles;
landing nets for anglers; golf
bags, with or without wheels;
nets for sports; tennis nets; ski
bindings; darts; floats for
fishing; foosball tables;
harpoon guns; gloves for
games; cups for dice; bar-bells;
fish hooks; baby rattles; clay
pigeon traps; rackets; decoys
for hunting or fishing; fishing
tackle; lines for fishing; dolls'
beds; dolls' houses; puppets;
dolls; theatrical masks;
carnival masks; scale model
vehicles; reels for fishing;
flippers for swimming; creels
as fishing traps; swimming
pools being play articles;
artificial snow for Christmas
trees; quoits; roller skates; ice
skates; seal skins being
coverings especially adapted
for skis; clay pigeons as
targets; surfboards; dolls'
clothes; dolls' rooms; Playing
cards for use in magic tricks;
skittles games; gut for fishing;
sole coverings for skis; skis;
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tables for table tennis;
spinning tops as toys; sleds
being sports articles;
backgammon games; scooters
as toys; shuttlecocks; air
pistols being toys; percussion
caps being toys; ornaments for
Christmas trees, except
illumination articles and
confectionery; Christmas tree
stands; billiard cues; billiard
cue tips; billiard tables; coin-
operated billiard tables; surf
skis; sailboards; hang gliders;
appliances for gymnastics;
fencing weapons; fencing
masks; fencing gauntlets;
baseball gloves; climbers'
harness; elbow guards being
sports articles for athletic use;
knee guards being sports
articles for athletic use;
mobiles as toys; paragliders;
protective paddings being
parts of sports suits for
athletic use; skateboards; toy
slides; spring boards; teddy
bears; water skis; golf gloves;
bite indicators as fishing
tackle; bite sensors as fishing
tackle; board games;
fairground ride apparatus;
flying discs toys; horseshoe
games; mah-jong; plush toys;
soap bubble making wand and
solution sets; toy vehicles;
twirling batons; butterfly nets;
bags especially designed for
skis and surfboards; harness
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70
for sailboards; jigsaw puzzles;
masts for sailboards; paintball
guns; paintballs ammunition
for paintball guns; surfboard
leashes; tennis ball throwing
apparatus; starting blocks for
sports; snow globes; weight
lifting belts; bodyboards; bingo
cards; divot repair tools as golf
accessories; hunting game
calls; roulette wheels; in-line
roller skates; pinatas;
punching bags; radio-
controlled toy vehicles; rosin
used by athletes; snowshoes;
sling shots being sports
articles; amusement machines,
automatic and coin-operated;
kaleidoscopes; playing cards;
confetti; electronic targets for
sports; scent lures for hunting
or fishing; camouflage screens;
men's athletic supporters;
snowboards; scale model kits
as toys; pachinkos; ascenders
being mountaineering
equipment; slot machines
being gaming machines; paper
party hats; swimming kick
boards; chips for gambling;
scratch cards for playing
lottery games; stuffed toys;
trampolines; poles for pole
vaulting; water wings;
swimming belts; swimming
jackets; video game machines;
portable games with liquid
crystal displays; arcade video
game machines; controllers for
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game consoles; toy models; toy
figures; ball pitching
machines; dumb-bells; masks
as playthings; matryoshka
dolls being wooden nested
Russian dolls; controllers for
toys, namely, cars, robots, and
planes; action figure toys;
electronic action toys;
mechanical and electronic
action toys; amusement park
rides in class 028.
For: Advertising services;
business management;
business administration;
providing office functions;
business management
assistance; business inquiries;
bill-posting; import-export
agencies; commercial
information agencies; cost
price analysis; dissemination
of advertising matter;
photocopying services;
employment agencies; book-
keeping; drawing up of
statements of accounts,
namely, administration, billing
and reconciliation of accounts
on behalf of others; business
auditing; business
management and organization
consultancy; personnel
management consultancy;
business management
consultancy; typing;
demonstration of goods; direct
mail advertising services;
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commercial and industrial
management assistance;
document reproduction;
updating of advertising
material; distribution of
samples; business efficiency
expert services; auctioneering;
conducting marketing studies;
business appraisals; business
investigations; publicity
material rental; business
organization consultancy;
publication of publicity texts;
radio advertising; business
research; public relations;
shorthand services; television
advertising; transcription of
communications; shop window
dressing; services of
advertising agencies; advisory
services for business
management; modelling for
advertising or sales promotion;
marketing research;
computerized file
management; professional
business consultancy; economic
forecasting services;
organization of exhibitions for
commercial or advertising
purposes; business
information; public opinion
polling; payroll preparation;
personnel recruitment;
relocation services for
businesses; rental of
advertising space; sales
promotion for others;
secretarial services; tax
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preparation; telephone
answering for unavailable
subscribers; word processing;
arranging newspaper
subscriptions for others;
advertising by mail order;
business management of
hotels; business management
of performing artists;
compilation of information into
computer databases;
systemization of information
into computer databases;
organization of trade fairs for
commercial or advertising
purposes; rental of
photocopying machines; on-line
advertising on a computer
network; rental of advertising
time on communication media;
news clipping services; rental
of vending machines;
psychological testing for the
selection of personnel; price
comparison services;
presentation of goods on
communication media, for
retail purposes, namely,
television home shopping
services; commercial
information and advice for
consumers in the nature of a
consumer advice shop;
arranging subscriptions to
telecommunication services for
others; administrative
processing of purchase orders;
commercial administration of
the licensing of the goods and
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74
services of others; outsourcing
services, namely, business
management, administration
and consultancy; invoicing;
writing of publicity texts;
compilation of statistics; layout
services for advertising
purposes; sponsorship search;
organization of fashion shows
for promotional purposes;
production of advertising films;
business management of
sports people; marketing
services; telemarketing
services; retail store and
wholesale store services
featuring pharmaceutical,
veterinary and sanitary
preparations and medical
supplies; rental of sales stands;
provision of commercial and
business contact information;
search engine optimization for
sales promotion; web site
traffic optimization; pay per
click advertising; business
management for freelance
service providers; negotiation
and conclusion of commercial
transactions for third parties;
updating and maintenance of
data in computer databases;
business project management
services for construction
projects; providing business
information via a web site;
provision of an on-line
marketplace for buyers and
sellers of goods and services;
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design of advertising
materials; outsourced
administrative management
for companies; tax filing
services; rental of billboards;
career planning services;
presentation of companies and
their goods and services on the
Internet for promotional
purposes; presentation of
companies on the Internet and
other media for promotional
purposes; providing
employment information;
providing employment
information via a global
computer network in class 035.
For: Accident insurance
underwriting services; issue of
tokens of value; processing
electronic payments made
through prepaid cards; issue of
tokens of value for payment of
transportation expenses;
electronic payment, namely,
providing electronic processing
and transmission of credit card
transaction wireless wallets,
mobile wallets, electronic
wallets, debit and prepaid card
transactions; charge card and
stored value prepaid card
services, namely, processing
electronic payments; pre-paid
purchase card services namely,
processing electronic payments
made through prepaid cards;
accident insurance
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underwriting; instalment
loans; actuarial services;
leasing of real estate; credit
bureaus; real estate agency
services; real estate brokerage;
debt collection agency services;
insurance brokerage; financial
customs brokerage services;
insurance underwriting for all
types of insurance; banking;
real estate appraisal;
charitable fund raising;
mutual funds investment,
distribution and advisory
services; capital investment;
exchanging money; financial
clearing-houses; safe deposit
box services; loans financing;
fiscal assessments; financial
evaluation for insurance,
banking, and real estate
purposes; factoring agency
services; trusteeship
representatives; financing
services; financial
management; pawn brokerage;
real estate management
services; apartment house
management; fire insurance
underwriting; rental of
apartments; leasing of farms;
health insurance underwriting;
marine insurance
underwriting; mortgage
banking; savings bank
services; securities brokerage;
life insurance underwriting;
financial analysis; antique
appraisal; art appraisal; check
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verification; financial
consultancy; insurance
consultancy; credit card
transaction processing
services; debit card transaction
processing services; electronic
funds transfer; financial
information; insurance
information; jewelry appraisal;
numismatic appraisal; rent
collection; stamp appraisal;
issuance of tokens of value;
deposits of valuables, namely,
safety deposit box services;
stock exchange quotations;
issuance of credit cards; real
estate services, namely, rental
of offices; financial sponsorship
of sports competitions and
special events related thereto;
online banking; business
liquidation services, financial;
repair costs evaluation;
brokerage of carbon credits;
financial evaluation of
standing timber; financial
evaluation of wool; stock
brokerage services; debt
advisory services; arranging
finance for construction
projects; providing financial
information via a web site;
financial management of
reimbursement payments for
others; investment of funds;
stocks and bonds brokerage;
agencies for trading of
commodity futures; brokerage
of futures; futures commission
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merchant services, namely,
clearing trades for
commodities, futures and
foreign exchange; financial
services, namely, gold trading;
providing information on
options markets via a web site;
providing information relating
to the trading of commodity
futures; securities arbitrage
services; appraisal of second-
hand automobiles; automobile
appraisal; consultancy relating
to the appraisal of goods;
providing information relating
to the appraisal of second-hand
automobiles in class 036.
For: Radio broadcasting;
electronic message sending;
television broadcasting;
transmission of telegrams;
telegraph services;
communications by telegrams;
telephone communication
services; communications by
telephone; communications
through an international
system of telegraphy with
printed messages transmitted
and received by teleprinters
using the public
telecommunications network;
news agencies, namely, the
transmission of news items to
news reporting organizations;
cable television broadcasting;
communications by cellular
phones; communications by
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79
computer terminals; computer
aided transmission of
messages and images;
electronic transmission of e-
mail; facsimile transmission;
information about
telecommunication; paging
services for radio, telephone or
other means of electronic
communication; rental of
message sending apparatus for
communications purposes;
rental of facsimile apparatus;
rental of modems; rental of
telecommunication equipment;
rental of telephones; satellite
transmission; electronic
bulletin board services;
providing telecommunications
connections to a global
computer network;
telecommunications routing
and junction services;
teleconferencing services;
providing user access to global
computer networks; rental of
access time to global computer
networks; providing
telecommunication channels
for teleshopping services;
providing Internet chatrooms;
providing access to databases;
voice mail services;
transmission of greeting cards
online; transmission of digital
files; wireless broadcasting;
videoconferencing services;
providing online forums for
transmission of messages
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among computer users;
streaming of data; radio
communications in class 038.
For: Education services,
namely, providing classes of
instruction in the field of video
games; organizing community
sporting activities; providing
online non-downloadable
software for playing games,
namely, providing on-line
computer games; game cafe
services, namely, providing
facilities for playing computer
games with installed video
game machines in an Internet
cafe environment; providing
on-line journals, namely, blogs
featuring user-defined content
in the field of social-
networking; providing
information about computer
games using communication by
an electronic computer
terminal; providing
information about computer
games via a cellular phone;
providing information via the
Internet about computer
games using communication by
hand-held games with liquid
crystal displays; providing
games using communication by
an electronic computer
terminal, namely, providing
on-line computer games;
providing on-line computer
games using communication by
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81
a cellular phone; providing on-
line computer games using
communication by hand-held
games with liquid crystal
displays; providing on-line
non-downloadable consumer
video games; providing non-
downloadable music, sound
and image data using Internet;
computer game services
provided on-line from a
computer network; amusement
park services; animal training;
rental of movie projectors and
accessories; movie studios
services; circuses; Providing
education in the field of
computers, music, art rendered
through correspondence
courses; physical education;
rental of show scenery;
providing recreation facilities;
radio entertainment
production; publication of
texts, other than publicity
texts; rental of sound
recordings; rental of cine-films;
film production, other than
advertising films; gymnastic
instruction; lending libraries;
publication of books; rental of
radio and television sets;
production of radio and
television programmes; music-
halls; orchestra services;
entertainment in the nature of
theatre productions;
production of television shows;
television entertainment,
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82
namely, ongoing television
programs in the field of
computer games, video games,
animated films and animated
cartoons; rental of stage
scenery; zoological garden
services; providing sports
facilities; modelling for artists;
mobile library services;
providing casino facilities for
gambling; entertainment and
education club services,
namely, after-hours night club
services; arranging and
conducting of educational
conferences; arranging and
conducting of educational
congresses in the field of
business; discotheque services;
information about education;
educational examination
services; entertainment
information; organization of
exhibitions for cultural or
educational purposes;
gambling services; providing
golf facilities; health club
services, namely, providing
health and fitness training;
holiday camp services;
presentation of live show
performances; cinema theater
presentations; nursery schools;
organization of sports
competitions; party planning;
providing museum facilities
presentation and exhibitions;
recording studio services;
recreation information; rental
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83
of skin diving equipment;
rental of sports equipment,
except vehicles; rental of
stadium facilities; rental of
video cassette recorders; rental
of videotapes; sport camp
services; timing of sports
events; boarding school
education; arranging of beauty
contests; booking of seats for
shows; dubbing; providing
classes of instruction in the
field of religious education;
operating lotteries;
organization of balls;
organization of live music
shows, namely, impresario
services; providing amusement
arcade services; rental of audio
equipment; rental of lighting
apparatus for theatrical sets or
television studios; rental of
tennis courts; rental of video
cameras; scriptwriting services
for non-advertising purposes;
videotape editing; publication
of electronic books and
journals on-line; electronic
desktop publishing; subtitling;
electronic game services
provided on-line from a
computer network; providing
karaoke facility services; music
composition services; night
clubs; providing on-line non-
downloadable electronic
publications in the nature of
books and journals in the field
of business; publication of
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84
electronic books and journals
in the field of business;
photographic reporting;
photography; vocational
guidance; news reporters
services; translation; sign
language interpretation;
videotaping; microfilming;
ticket agency services for
entertainment events; writing
of texts, other than publicity
texts, namely, writing of
articles for professional
journals other than for
advertising or publicity;
arranging and conducting of
concerts; calligraphy services;
layout services, other than for
advertising purposes;
organization of fashion shows
for entertainment purposes;
coaching in the field of sports;
rental of sports grounds; disc
jockey services; language
interpreter services; personal
trainer services fitness
training; conducting fitness
classes; production of music;
toy rental; games equipment
rental; providing on-line
music, not downloadable;
providing on-line videos,
namely, providing a web site
featuring non-downloadable
instructional videos in the field
of computer games, video
games, animated films and
animated cartoons; rental of
cameras; rental of musical
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85
instruments; rental of
paintings and calligraphic
works; rental of film negatives;
operation of audio equipment
for production of radio
programs; operation of video
and audio equipment for
production of television
programs; providing
information on-line relating to
computer games and computer
enhancements for games;
providing on-line computer
games; providing on-line
information and news in the
field of employment training;
providing zip line rides for
recreational purposes;
amusement arcade services;
amusement park and theme
park services; entertainment
in the nature of a water park
and amusement center;
entertainment in the nature of
an amusement park ride;
providing amusement facilities
in class 041.
For: Design and development
of computer hardware and
software; Software as a
service, namely, providing non-
downloadable operating
system software with regard to
infrastructures on the
Internet, intranet and extranet
in the fields gaming and
wagering; providing temporary
use of non-downloadable
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software for the operation of
gaming and wagering websites
on the Internet; design,
development and maintenance
of computer software and
online game websites for
others; design, development
and maintenance of computer
software and online game
sites; chemical analysis;
analysis for oil-field
exploitation; architectural
services; bacteriological
research; chemistry services,
namely, research in the field of
chemistry; chemical research;
architectural consultation;
construction drafting; oil-well
testing; cosmetics research;
design of interior decor;
industrial design; packaging
design; material testing;
geological surveys; oil-field
surveys; engineering;
meteorological information;
land surveying; computer
rental; computer
programming; oil prospecting;
physics research; mechanical
research; textile testing;
geological prospecting;
geological research;
authenticating works of art;
calibration; computer software
design; updating of computer
software; consultancy in the
design and development of
computer hardware; dress
designing; graphic arts design;
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87
quality control for others;
rental of computer software;
research and development of
new products for others;
styling, namely, industrial
design; underwater
exploration; recovery of
computer data; maintenance of
computer software; computer
system analysis; biological
research; urban planning;
surveying; computer system
design services; vehicle
roadworthiness testing;
duplication of computer
programs; conversion of data
or documents from physical to
electronic media; creating and
maintaining web sites for
others; hosting the computer
sites on a computer server for
a global computer network;
installation of computer
software; cloud seeding; data
conversion of computer
programs and data not
physical conversion; computer
software consultancy; rental of
web servers; computer virus
protection services;
consultancy in the field of
energy-saving for scientific
research purposes; research in
the field of environmental
protection; providing search
engines for the Internet;
digitization of documents;
handwriting analysis, namely,
graphology; provision of
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88
scientific information, advice
and consultancy in relation to
carbon offsetting; quality
evaluation of standing timber;
quality evaluation of wool;
monitoring of computer
systems by remote access for
detecting unauthorized access
or data breach; water analysis;
scientific laboratory services;
energy auditing; web site
design consultancy; consulting
services in the field of software
as a service (SaaS);
information technology
consultancy; scientific
research; server hosting;
conducting clinical trials for
others; off-site data backup;
electronic data storage;
providing information on
computer technology and
programming via a web site;
cartography services; cloud
computing consultancy;
technological consultancy in
the field of computer systems;
telecommunications technology
consultancy; weather
forecasting; technical advice
relating to operation of
computers; rental of measuring
apparatus; rental of laboratory
apparatus and instruments;
rental of technical drawing
instruments; development of
computer game software;
development of computer
hardware; development of
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computer software;
development of computer
software application solutions;
development of computer
systems in class 042.
For: Services for providing food
and drink in restaurants;
providing temporary
accommodation;
accommodation bureau,
namely, providing services of
hotels and boarding houses;
food and drink catering;
retirement home services;
cafes; cafeterias; providing
campground facilities; canteen
services; rental of temporary
accommodation; boarding
house services; tourist home
services; hotels; day-nurseries
in the nature of creches;
restaurants; boarding house
bookings; making hotel
reservations for others; self-
service restaurants; snack-
bars; boarding for animals; bar
services; providing temporary
lodging for holiday camp
services; temporary
accommodation reservations;
motel services; rental of chairs,
tables, table linen, glassware;
rental of meeting rooms; rental
of tents; rental of cooking
apparatus; rental of drinking
water dispensers; food
sculpting; rental of futon and
quilts for hotels; rental of
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90
towels for hotels in class 043.
For: Legal services; security
services for the protection of
property and individuals,
namely, surveillance services;
personal body guarding;
detective agency services;
dating services; night guard
services; locksmithing, namely,
opening of security locks;
evening dress rental;
crematorium services; missing
person investigations; funeral
arrangement services;
funerary service undertaking;
clothing rental; guard services;
marriage agencies, namely,
conducting civil marriage
ceremony services; physical
security consultancy;
horoscope casting; fire-
fighting; organization of
religious prayer meetings;
adoption agency services;
monitoring of burglar and
security alarms; babysitting;
baggage handling inspections
for airlines; house sitting; pet
sitting; personal background
investigations; lost property
return; mediation; inspection
of factories for safety purposes;
rental of fire alarms; rental of
fire extinguishers; arbitration
services; intellectual property
consultancy; copyright
management; licensing of
intellectual property;
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monitoring intellectual
property rights for legal
advisory purposes; legal
research; litigation services;
licensing of computer software;
registration of domain names;
alternative dispute resolution
services; rental of safes;
genealogical research;
planning and arranging of
wedding ceremonies; on-line
social networking services;
releasing doves for special
occasions; embalming services;
legal document preparation
services; tracking of stolen
property; legal administration
of licenses; consultancy
services in the field of personal
fashion; information about
personal wardrobe styling
services; information relating
to fashion coordination
services for individuals;
personal styling services
consisting of bra measuring
and fitting services; personal
styling services consisting of
measuring and fitting services
for ladies' lingerie; personal
wardrobe styling services;
providing grave spaces or
charnel houses; legal services
relating to social insurance
claims; rental of altars; rental
of jewelry; licensing of
computer software via
networks in class 045.
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6,039,333 Apr. 28,
2020
For: Coin-operated video
games; arcade game machines;
arcade video game machines;
amusement game machines
with built-in screens; toy
vehicles; dolls; stuffed toys; toy
action figures; trading card
games; playing cards; arcade
redemption game machines
which dispense tickets or
tokens to successful players;
arcade crane game machines
which dispense tickets or
tokens to successful players;
slot machines in class 028.
2,315,166 SEGA Feb. 8, 2000
For: Video game machines for
use with televisions; electronic
gaming machines; video game
software; computer game
software in class 009.
3,245,697 SEGA May 29,
2007
For: T-shirts; shirts in class
025.
3,491,509 DREAMCAST Aug. 26,
2008
For: Video game software,
computer game programs in
class 009.
1,690,329 GENESIS June 2, 1992
For: Video output game
machines; software for video
output game machines;
attachments for video output
game machines; namely,
joystick controllers and joypad
controllers; and carrying cases
and storage containers for the
foregoing in class 028.
3,358,022
SEGA
GENESIS
COLLECTION
Dec. 18,
2007
For: Home video game software,
video game software for hand-
held game machines in class
009.
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3,713,204
SONIC'S
ULTIMATE
GENESIS
COLLECTION
Nov. 17,
2009
For: Video game software in
class 009.
3,013,830 Nov. 08,
2005
For: Video game software in
class 009.
Sega alleges that Defendants, through fully interactive, e-commerce stores1,
operating under the seller aliases identified on Schedule A to the Complaint and
attached hereto (the "Seller Aliases"), have advertised, promoted, offered for sale,
sold, or imported goods bearing and/or embodying what Sega has determined to be
counterfeits, infringements, reproductions, or colorable imitations of the Sega
Trademarks and/or unauthorized copies of the Sega Copyrighted Works. ECF No.
[1].
Sega alleges that it has not licensed or authorized Defendants to use any of the
Sega Trademarks or Sega Copyrighted Works, and none of the Defendants are
authorized retailers of genuine Sega Products. ECF No. [11-1].
Sega attests that it investigated the promotion and sale of infringing and
counterfeit versions of its branded products by Defendants ("Unauthorized
Products"). See id. at ¶ 21. Sega alleges that it analyzed each each of the e-commerce
stores operating under the Seller Aliases and determined that Unauthorized
Products were being offered for sale to residents of the United States, including
1 The e-commerce store URLs are listed on Schedule A to the Complaint and attached hereto.
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Florida. Id. In addition, each e-commerce store offered shipping to the United States.
Id. Sega attests that it conducted a review and visually inspected the Unauthorized
Products listed for sale on each Defendants’ e-commerce store and and determined
said products were non-genuine and unauthorized by Sega. Id.
II. LEGAL STANDARD
To obtain a preliminary injunction, a party must demonstrate: (1) a substantial
likelihood of success on the merits; (2) that irreparable injury will be suffered if the
relief is not granted; (3) that the threatened injury outweighs the harm the relief
would inflict on the non- movant; and (4) that the entry of the relief would serve the
public interest. Schiavo ex. rel Schindler v. Schiavo, 403 F.3d 1223, 1225-26 (11th
Cir. 2005); see also Levi Strauss & Co. v. Sunrise Int'l Trading Inc., 51 F.3d 982, 985
(11th Cir. 1995) (applying the test to a preliminary injunction in a Lanham Act case).
III. DISCUSSION
The declarations Sega submitted in support of the Motion support the following
conclusions of law:
A. Sega has a strong probability of proving at trial that:
a. Consumers are likely to be confused by Defendants' advertisement,
promotion, sale, offer for sale, and/or distribution of Unauthorized
Products, and that Defendants' Unauthorized Products use
infringing and counterfeit versions of the Sega Trademarks and/or
unauthorized copies of the Sega Copyrighted Works.
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b. Defendants are offering for sale and selling Unauthorized Sega
Products which include reproductions of the Sega Copyrighted Works
or works derived from the Sega Copyrighted Works, and the
Unauthorized Sega Products bear copies of works that are
substantially similar to the Sega Copyrighted Work.
B. This Court has personal jurisdiction over Defendants because Defendants
directly target their business activities toward consumers in the United
States, including Florida. Specifically, Defendants have targeted sales to
Florida residents by setting up and operating e-commerce stores that target
United States consumers using the Seller Aliases, offer shipping to Florida,
and/or have sold Unauthorized Products to residents of Florida.
C. Because of the infringement of the Sega Trademarks and/or Sega
Copyrighted Works, Sega is likely to suffer immediate and irreparable
injury if a preliminary injunction order is not granted. The following
specific facts, as set forth in Sega's Complaint, Sega's Motion, and
accompanying declarations, demonstrate that immediate and irreparable
loss, damage, and injury will result to Sega and to consumers before
Defendants can be heard in opposition unless Sega's request for
preliminary relief is granted:
a. Defendants own, operate, and/or control fully interactive, e-
commerce stores operating under the Seller Aliases which advertise,
offer for sale, sell, and ship Unauthorized Products to customers in
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the Florida that bear infringing and/or counterfeit versions of the
Sega Trademarks and/or bear unauthorized copies of the Sega
Copyrighted Works; and
b. There is good cause to believe that more counterfeit and infringing
products bearing the Sega Trademarks and/or unauthorized copies
of the Sega Copyrighted Works will appear in the marketplace; that
consumers are likely to be misled, confused, and disappointed by the
quality of the Unauthorized Products; and that Sega may suffer loss
of sales for its genuine products and an unnatural erosion of the
legitimate marketplace in which it operates; and
D. The potential harm to Defendants in restraining their trade in counterfeit
and infringing goods through their e-commerce stores and freezing ill-
gotten profits if a preliminary injunction order is granted is far outweighed
by the irreparable harm Sega, its reputation, and its goodwill has suffered
and will continue to suffer if a preliminary injunction order is not issued.
E. The public interest favors issuance of the preliminary injunction order to
prevent consumer confusion and dispel the false impression that
Defendants are operating their e-commerce stores with Sega's approval and
endorsement, as well as protect Sega's legitimate intellectual property
interests. Further, the public will be protected from being defrauded by the
illegal sale of Unauthorized Products.
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F. Under 15 U.S.C. § 1117(a), Sega may be entitled to recover, as an equitable
remedy, the illegal profits gained through Defendants' distribution and
sales of goods bearing infringing and/or counterfeit versions of the Sega
Trademarks. See Reebok Int'l, Ltd. v. Marnatech Enters., Inc., 970 F.2d
552, 559 (9th Cir. 1992) (quoting Fuller Brush Prods. Co. v. Fuller Brush
Co., 299 F.2d 772, 777 (7th Cir. 1962) ("An accounting of profits under §
1117(a) is not synonymous with an award of monetary damages: '[a]n
accounting for profits . . . is an equitable remedy subject to the principles of
equity'").
G. Under 17 U.S.C. § 504(b) and 17 U.S.C. § 502(a), Sega may be entitled to
recover, as an equitable remedy, the illegal profits gained through
Defendants' distribution and sales of goods bearing unauthorized copies of
the Sega Copyrighted Works. See Antsy Labs, LLC v. Individuals, 24-cv-
61436-WPD, 2024 WL 4472009, at *6 (S.D. Fla. Sept. 16, 2024) ("Under 17
U.S. Code § 504(b) and 17 U.S. Code § 502(a), Plaintiff may be entitled to
recover, as an equitable remedy, the illegal profits gained through
Defendants' distribution and sales of goods infringing Plaintiff’s
Copyrights.").
H. Requesting 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." Levi Strauss & Co., 51 F.3d at
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987 (citing Federal Trade Commission v. United States Oil & Gas Corp.,
748 F.2d 1431, 143334 (11th Cir. 1984)).
I. In light of the inherently deceptive nature of the intellectual property
infringement business, and the likelihood that Defendants have violated
federal trademark and copyright laws, Sega has good reason to believe
Defendants will hide or transfer their ill-gotten assets beyond the
jurisdiction of this Court unless those assets are restrained.
Accordingly, upon due consideration of Sega’s Complaint, the Motion, the
supporting evidentiary submissions, the relevant authorities, and for the reasons
et forth on the record at the hearing on the Motion, which are incorporated herein,
it is hereby ORDERED AND ADJUDGED that the Motion, ECF No. [21], is
GRANTED, under the terms set forth below:
1. Defendants, their affiliates, officers, agents, servants, employees, attorneys,
confederates, and all persons acting for, with, by, through, under, or in active
concert with Defendants be preliminary enjoined and restrained from:
a. using the Sega Trademarks or any reproductions, counterfeit copies, or
colorable imitations thereof in any manner in connection with the
distribution, marketing, advertising, offering for sale, or sale of any product
that is not a genuine Sega product or not authorized by Sega to be sold in
connection with the Sega Trademarks;
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 98 of 111
99
b. reproducing, distributing copies of, making derivative works of, or publicly
displaying the Sega Copyrighted Works in any manner without the express
authorization of Sega;
c. passing off, inducing, or enabling others to sell or pass off any product as a
genuine Sega product or any other product produced by Sega, that is not
Sega's or not produced under the authorization, control, or supervision of
Sega and approved by Sega for sale under the Sega Trademarks and/or Sega
Copyrighted Works;
d. committing any acts calculated to cause consumers to believe that
Defendants' products are those sold under the authorization, control, or
supervision of Sega, or are sponsored by, approved by, or otherwise
connected with Sega;
e. further infringing the Sega Trademarks and Sega Copyrighted Works and
damaging Sega's goodwill; and
f. manufacturing, shipping, delivering, holding for sale, transferring or
otherwise moving, storing, distributing, returning, or otherwise disposing
of, in any manner, products or inventory not manufactured by or for Sega,
nor authorized by Sega to be sold or offered for sale, and which bear any of
Sega's trademarks, including the Sega Trademarks, or any reproductions,
counterfeit copies, or colorable imitations and/or which bear the Sega
Copyrighted Works.
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 99 of 111
100
2. Upon Sega's request, any third party with actual notice of this Order who is
providing services for any of the Defendants, or in connection with any of
Defendants' Seller Aliases, including, without limitation, any online platforms
such as Amazon.com, Inc. (“Amazon”), Dhgate.com (“DHGate”), eBay, Inc.
(“eBay”), Etsy, Inc. (“Etsy”), Payoneer Global Inc. (“Payoneer”), PayPal, Inc.
(“PayPal”), Stripe, Inc. (“Stripe”), Roadget Business PTE Ltd. (“SHEIN”), and
Context Logic, Inc. d/b/a Wish.com (“Wish”) (collectively, the "Third Party
Providers") shall, within seven (7) calendar days after receipt of such notice,
provide to Sega expedited discovery, including copies of all documents and
records in such person's or entity's possession or control relating to:
a. the identities and locations of Defendants, their affiliates, officers, agents,
servants, employees, confederates, attorneys, and any persons acting in
concert or participation with them, including all known contact information
and all associated e-mail addresses;
b. the nature of Defendants' operations and all associated sales, methods of
payment for services, and financial information, including, without
limitation, identifying information associated with the Seller Aliases and
Defendants' financial accounts, as well as providing a full accounting of
Defendants' sales and listing history related to their respective Seller
Aliases; and
c. any financial accounts owned or controlled by Defendants, including their
agents, servants, employees, confederates, attorneys, and any persons
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 100 of 111
101
acting in concert or participation with them, including such accounts
residing with or under the control of any banks, savings and loan
associations, payment processors or other financial institutions, including,
without limitation, the Third Party Providers, or other merchant account
providers, payment providers, third party processors, and credit card
associations (e.g., MasterCard and VISA).
3. Upon Sega's request, those with notice of this Order, including the Third Party
Providers as defined in Paragraph 2, shall within seven (7) calendar days after
receipt of such notice, disable and cease displaying any advertisements used
by or associated with Defendants in connection with the sale of counterfeit and
infringing goods using the Sega Trademarks and/or which bear the Sega
Copyrighted Works.
4. Defendants shall be temporarily and preliminarily restrained and enjoined
from transferring or disposing of any money or other of Defendants' assets until
further ordered by this Court.
5. The Third Party Providers shall, within seven (7) calendar days of receipt of
this Order:
a. locate all accounts and funds connected to Defendants' Seller Aliases,
including, but not limited to, any financial accounts connected to the
information listed in Schedule A hereto, the e-mail addresses identified in
Exhibit 3 to the Declaration of Andrew Masterson, and any e-mail
addresses provided for Defendants by third parties; and
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 101 of 111
102
b. restrain and enjoin any such accounts or funds from transferring or
disposing of any money or other of Defendants' assets until further order by
this Court.
6. Sega is authorized to issue expedited written discovery to Defendants,
pursuant to Federal Rules of Civil Procedure 33, 34, and 36, related to:
a. the identities and locations of Defendants, their affiliates, officers, agents,
servants, employees, confederates, attorneys, and any persons acting in
active concert or participation with them, including all known contact
information, including any and all associated e-mail addresses; and
b. the nature of Defendants' operations and all associated sales, methods of
payment for services, and financial information, including, without
limitation, identifying information associated with the Seller Aliases and
Defendants' financial accounts, as well as providing full accounting of
Defendants' sales and listing history related to their respective Seller
Aliases.
7. Sega is authorized to issue the expedited discovery requests authorized in
Paragraph 6 via e-mail. Defendants shall respond to any such discovery
requests within three (3) business days of being served via e-mail.
8. Any Defendants that are subject to this Order may appear and move to dissolve
or modify the Order as permitted by and in compliance with the Federal Rules
of Civil Procedure and Southern District of Florida Local Rules.
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 102 of 111
103
9. The ten-thousand-dollar ($10,000) bond posted by Plaintiffs shall remain with
the Court until a final disposition of this case or until the Preliminary
Injunction is terminated.
10. As a matter of law, this Preliminary Injunction shall no longer apply to any
Defendant or associated e-commerce store dismissed from this action or as to
which Plaintiff has withdrawn its request for a preliminary injunction.
11. This Order shall remain in effect during the pendency of this action, or until
further Order of this Court.
DONE AND ORDERED in Miami, Florida, on this 27th day of January, 2026.
__________________________________________
JACQUELINE BECERRA
UNITED STATES DISTRICT JUDGE
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 103 of 111
104
Sega Corporation and Sega of America, Inc. v. The Partnerships and
Unincorporated Associations Identified on Schedule "A" – Case No. 25-cv-
25442-JB
Schedule A
DOE
No.
Defendants Infringement
Type
Seller URL
1 chufangxiaodian Copyright only
https://www.amazon.com/sp?ie=
UTF8&seller=AF7Z2SI6KHXOF
2 dongzide Copyright only
https://www.amazon.com/sp?ie=
UTF8&seller=A196AMINXCJ2F
G
3 GuiYuAnFenMaoYi Copyright only
https://www.amazon.com/sp?ie=
UTF8&seller=A38ML5FWNVJ8I
E
4 JFneonsios Copyright only
https://www.amazon.com/sp?ie=
UTF8&seller=AWI263UNSTI4G
5 K2HOARD Copyright only
https://www.amazon.com/sp?ie=
UTF8&seller=AGYWJGWGAMR
D7
6 kailin Copyright only
https://www.amazon.com/sp?ie=
UTF8&seller=A2T6Y7OV0RYW
Q7
7 shawncraft Copyright only
https://www.amazon.com/sp?ie=
UTF8&seller=A179C6MGV2CK
W0
8
ShenYangMingQiangTu
ShiFangGongChengYou
XianGongSi Copyright only
https://www.amazon.com/sp?ie=
UTF8&seller=A1F7Q587D3W9L
R
9 SNHPARTY Copyright only
https://www.amazon.com/sp?ie=
UTF8&seller=A1F7Q587D3W9L
R
10 TheLittleHeroes Copyright only
https://www.amazon.com/sp?ie=
UTF8&seller=A1FH617ITDALZ
L
11 XianRuLian Copyright only
https://www.amazon.com/sp?ie=
UTF8&seller=A38CC3RN64MRI
V
12 cartonn Copyright only
https://www.dhgate.com/store/to
p-selling/21929384.html
13 chiccharm Copyright only
https://www.dhgate.com/store/to
p-selling/22057112.html
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 104 of 111
105
14 dboos Copyright only
https://www.dhgate.com/store/to
p-selling/22011545.html
15 ddmyapr Copyright only
https://www.dhgate.com/store/to
p-selling/21997318.html
16 dhpetdd Copyright only
https://www.dhgate.com/store/to
p-selling/22019574.html
17 difnik Copyright only
https://www.dhgate.com/store/to
p-selling/21946498.html
18 factorytoyss Copyright only
https://www.dhgate.com/store/to
p-selling/22233956.html
19 fashion_official01 Copyright only
https://www.dhgate.com/store/to
p-selling/21908286.html
20 glamgears Copyright only
https://www.dhgate.com/store/to
p-selling/22055888.html
21 glamor111 Copyright only
https://www.dhgate.com/store/to
p-selling/22059134.html
22 happy__every_day Copyright only
https://www.dhgate.com/store/to
p-selling/22054864.html
23 henio Copyright only
https://www.dhgate.com/store/to
p-selling/22041223.html
24 jiaomengmeng8 Copyright only
https://www.dhgate.com/store/to
p-selling/22204866.html
25 liancheng05 Copyright only
https://www.dhgate.com/store/21
733799
26 limionou Copyright only
https://www.dhgate.com/store/to
p-selling/21931893.html
27 louis_vh_store Copyright only
https://www.dhgate.com/store/21
888431
28 lucky_tree777 Copyright only
https://www.dhgate.com/store/to
p-selling/22056961.html
29 manilabest Copyright only
https://www.dhgate.com/store/to
p-selling/21555942.html
30 olgariner Copyright only
https://www.dhgate.com/store/to
p-selling/21810466.html
31 pinerw Copyright only
https://www.dhgate.com/store/21
942835
32 postland Copyright only
https://www.dhgate.com/store/to
p-selling/22033768.html
33 quality_life_hall Copyright only
https://www.dhgate.com/store/22
002290
34 refulgence898 Copyright only
https://www.dhgate.com/store/to
p-selling/22048987.html
35 stylespo Copyright only
https://www.dhgate.com/store/to
p-selling/22055881.html
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 105 of 111
106
36 that_person Copyright only
https://www.dhgate.com/store/to
p-selling/21997755.html
37 tie08 Copyright only
https://www.dhgate.com/store/21
836704
38 tonethiny Copyright only
https://www.dhgate.com/store/to
p-selling/21060778.html
39 toyshopcn Copyright only
https://www.dhgate.com/store/to
p-selling/22242686.html
40 usseller518 Copyright only
https://www.dhgate.com/store/to
p-selling/21791966.html
41 xgx009 Copyright only
https://www.dhgate.com/store/to
p-selling/22044687.html
42 xpreal Copyright only
https://www.dhgate.com/store/to
p-selling/21946530.html
43 yaowak Copyright only
https://www.dhgate.com/store/to
p-selling/21947263.html
44 yiwang01 Copyright only
https://www.dhgate.com/store/to
p-selling/21269253.html
45 yuancao Copyright only
https://www.dhgate.com/store/to
p-selling/20061363.html
46 z00010 Copyright only
https://www.dhgate.com/store/21
963226
47 WorldofstarsHome Copyright only
https://www.etsy.com/shop/World
ofstarsHome?ref=shop-header-
name&listing_id=4320144358&f
rom_page=listing
48 1tees.com Copyright only https://1tees.com
49 Animal Kingdom Copyright only
https://animalkingdomdesigns.co
m/
50 Boo Haul, Co. Copyright only https://boohaul.com
51 Drinkwears Copyright only https://drinkwears.com/
52 goofyahhproduction Copyright only https://goofyahhtees.com
53 minomog Copyright only https://minomog.com
54 Oscarsitosroom Copyright only https://oscarsitosroom.com
55 TeleTeeShirt Copyright only https://teleteeshirt.com/
56 VUITINO LLC Copyright only https://vuitino.com/
57 wexhome Copyright only https://www.wexhome.com/
58 Zalivora Copyright only https://www.zalivora.com
59 ZANIAZ Copyright only https://www.zaniaz.com/
60 asvdsfv Copyright only
https://us.shein.com/store/home?
store_code=2177703847
61 baiyangshop Copyright only
https://us.shein.com/store/home?
store_code=1591306652
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 106 of 111
107
62 Box Key Copyright only
https://us.shein.com/store/home?
store_code=8318751172
63 caefe Copyright only
https://us.shein.com/store/home?
store_code=7870752566
64 Canvas Elegance STORE Copyright only
https://us.shein.com/store/home?
store_code=5062436050
65 ChillWear Copyright only
https://us.shein.com/store/home?
store_code=1974176592
66 Diamond5 Copyright only
https://us.shein.com/store/home?
store_code=8699315752
67 dsggs Copyright only
https://us.shein.com/store/home?
store_code=5723887930
68 fdhbdfhnd Copyright only
https://us.shein.com/store/home?
store_code=7657367586&ici=Pag
eGoodsDetail&main_cate_id=17
38&main_goods_id=151541653
69 fuxianbin34 Copyright only
https://us.shein.com/store/home?
store_code=5904600892&
70 gzsxgbzxb Copyright only
https://us.shein.com/store/home?
store_code=9354692152
71 hankemu Copyright only
https://us.shein.com/store/home?
store_code=1194302054
72 HOUGVPJKOI Copyright only
https://us.shein.com/store/home?
store_code=1848025638
73 JORVALEN DUNE Copyright only
https://us.shein.com/store/home?
store_code=6835786239
74 kdhuufjnhfjn Copyright only
https://us.shein.com/store/home?
store_code=6288606871
75 km mmnh Copyright only
https://us.shein.com/store/home?
store_code=3913843995
76 lijianlang11 Copyright only
https://us.shein.com/store/home?
store_code=6294993300
77 liuxing0203 Copyright only
https://us.shein.com/store/home?
store_code=2227813064
78 longpipi Copyright only
https://us.shein.com/store/home?
store_code=1525649112
79 NSEDFTHY Copyright only
https://us.shein.com/store/home?
store_code=5182456220
80 pengchao0203 Copyright only
https://us.shein.com/store/home?
store_code=8869730071
81 qingqingfushi Copyright only
https://us.shein.com/store/home?
store_code=1752039235
82 RosemaryRise4 Copyright only
https://us.shein.com/store/home?
store_code=9336993033
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 107 of 111
108
83 tanminghuanvzhuang Copyright only
https://us.shein.com/store/home?
store_code=7543363027
84 ufq1vauxuirq Copyright only
https://us.shein.com/store/home?
store_code=6670111514
85 vl5zb42zp2bf Copyright only
https://us.shein.com/store/home?
store_code=5661608798
86 wanglan0203 Copyright only
https://us.shein.com/store/home?
store_code=1190894475
87 wangwenxiangshop Copyright only
https://us.shein.com/store/home?
store_code=4103744397
88 weimengdashop Copyright only
https://us.shein.com/store/home?
store_code=6920606412
89 YJYF RTYE Copyright only
https://us.shein.com/store/home?
store_code=4580631930
90 Clothes LQ Store Copyright only
https://www.wish.com/merchant/
5defa67429e7867bac094c0f
91 erl5965shop Copyright only
https://www.wish.com/merchant/
5e8bf70a0a83cbe0b6000738
92 Durcoo Trademark only
https://www.amazon.com/sp?ie=
UTF8&seller=A8AM0HT6MG7R
S
93 taste76but Trademark only
https://www.ebay.com/str/taste76
but
94 LIAOMEIXIAus01 shop Trademark only
https://us.shein.com/store/home?
store_code=8267462125
95 shiyso2u1 d shop Trademark only
https://us.shein.com/store/home?
store_code=3518447261
96 alezae
Trademark and
Copyright
https://www.dhgate.com/store/to
p-selling/22042462.html
97 amazing8888
Trademark and
Copyright
https://www.dhgate.com/store/21
780107
98 dh1102729193
Trademark and
Copyright
https://www.dhgate.com/store/to
p-selling/22019561.html
99 freakhouse
Trademark and
Copyright
https://www.dhgate.com/store/22
002450
100 lizhenbaby0517
Trademark and
Copyright
https://www.dhgate.com/store/to
p-selling/22124944.html
101 merrydecorations97
Trademark and
Copyright
https://www.dhgate.com/store/to
p-selling/22244339.html
102 minifight
Trademark and
Copyright
https://www.dhgate.com/store/21
678707
103 sihuai04
Trademark and
Copyright
https://www.dhgate.com/store/to
p-selling/21614050.html
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 108 of 111
109
104 terratread
Trademark and
Copyright
https://www.dhgate.com/store/to
p-selling/22240777.html
105 the_medallion1
Trademark and
Copyright
https://www.dhgate.com/store/pr
oducts/22012251
106 zyggood
Trademark and
Copyright
https://www.dhgate.com/store/pr
oducts/20994126
107 gitrin22
Trademark and
Copyright
https://www.ebay.com/str/gitrin2
2
108 nguye-6542
Trademark and
Copyright
https://www.ebay.com/str/anhsto
re?_tab=about
109 snapbackhighquality
Trademark and
Copyright
https://www.ebay.com/usr/snapb
ackhighquality
110 MihnCraftStore
Trademark and
Copyright
https://www.etsy.com/shop/Mihn
CraftStore
111 Anime Printz
Trademark and
Copyright https://www.animeprintz.com
112 AWAZOME
Trademark and
Copyright https://www.awazome.com
113 beyburst
Trademark and
Copyright https://beyburst.com
114 EBeddingSets
Trademark and
Copyright https://www.ebeddingsets.com/
115 Fanaticity Fashion LLC
Trademark and
Copyright https://fanaticity.com
116 Fuzeprint
Trademark and
Copyright https://fuzeprint.com
117 Growkoc
Trademark and
Copyright https://growkoc.com
118 Huystyle
Trademark and
Copyright https://huystyle.com/
119 Personality Fashion
Trademark and
Copyright https://supportpersonality.com
120 Shopzinia
Trademark and
Copyright https://shopzinia.com
121 T-shirt At Low Price
Trademark and
Copyright https://tshirtatlowprice.com
122 Teewiin Store
Trademark and
Copyright https://www.teewiin.com/
123 62e5iib7
Trademark and
Copyright
https://us.shein.com/store/home?
store_code=8873021824
124 A+Novelty US
Trademark and
Copyright
https://us.shein.com/store/home?
store_code=2540761022
125 ADFG BNHJ
Trademark and
Copyright
https://us.shein.com/store/home?
store_code=1934317007
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 109 of 111
110
126 AuraCanvas
Trademark and
Copyright
https://us.shein.com/store/home?
store_code=5639737805
127 AYG VDXEDGB
Trademark and
Copyright
https://us.shein.com/store/home?
store_code=2631269484
128 CCOYTR ART SHOP
Trademark and
Copyright
https://us.shein.com/store/home?
store_code=6742538152
129 dfjyrhffg
Trademark and
Copyright
https://us.shein.com/store/home?
store_code=4025050660
130 dgsgsdsadgfsd
Trademark and
Copyright
https://us.shein.com/store/home?
store_code=6036088703
131 dsddss
Trademark and
Copyright
https://us.shein.com/store/home?
store_code=5491333814
132 dsgsdhdfsh
Trademark and
Copyright
https://us.shein.com/store/home?
store_code=8939706714
133 dsvdsds
Trademark and
Copyright
https://us.shein.com/store/home?
store_code=7912427471
134 FDSF HT
Trademark and
Copyright
https://us.shein.com/store/home?
store_code=4264638258
135 ffgjkffgh
Trademark and
Copyright
https://us.shein.com/store/home?
store_code=7628625622
136 FGHJKQ
Trademark and
Copyright
https://us.shein.com/store/home?
store_code=1351992659
137 HBHDH
Trademark and
Copyright
https://us.shein.com/store/home?
store_code=2337883547
138 hi derj
Trademark and
Copyright
https://us.shein.com/store/home?
store_code=8321717751
139 Junction5
Trademark and
Copyright
https://us.shein.com/store/home?
store_code=2483591527
140 szsxcf vhgjh
Trademark and
Copyright
https://us.shein.com/store/home?
store_code=8526691531
141 xiexibing025 stus
Trademark and
Copyright
https://us.shein.com/store/home?
store_code=3028794077
142 yangwusheng0203
Trademark and
Copyright
https://us.shein.com/store/home?
store_code=3519647535
143 zhanggushng
Trademark and
Copyright
https://us.shein.com/store/home?
store_code=7985210506&ici=Pag
eGoodsDetail&main_cate_id=17
38&main_goods_id=140411712
144 zhoutao0203
Trademark and
Copyright
https://us.shein.com/store/home?
store_code=8176948403
145 adsad23
Trademark and
Copyright
https://www.wish.com/merchant/
5d5a53b5560eca4252f2a778
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 110 of 111
Case 1:25-cv-25442-JB Document 31 Entered on FLSD Docket 01/27/2026 Page 111 of 111
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