Page 3 of 60form of, including but not limited to, apparel, CDs (compact discs), paper goods, advertisements,coffee, champagne, soft drinks, and snack foods, and 4) developing radio and television jinglesto promote the brand. In an effort to protect those marks Who Dat?, Inc. takes action to preventthe infringement, dilution, disparagement, and misappropriation of its marks.5.
Defendant New Orleans Louisiana Saints, L.L.C. (herein the Saints) are a Texaslimited liability company with its principal place of business at 5800 Airline Drive, Metairie, LA70003 which own and operates a professional football team, providing entertainment services tothe public in the form of competitive professional football games. The Saints are one of thethirty-two member clubs (herein the Member Clubs) of the National Football League (hereinthe NFL).6.
Defendant NFL Properties, LLC (herein the NFLP), is a limited liability companyorganized and existing under the laws of Delaware with its principal place of business at 280Park Avenue, New York, New York 10017, and has been authorized by the NFL and the Saintsto use their respective trademarks for commercial purposes, to promote the NFL and its MemberClubs and to protect their trademarks.7.
Defendant Secretary of State of Louisiana is responsible for the state trademark applications filed through the Louisiana Secretary of States office and is a necessary party to anaction to challenge the fraudulent filings made by the Saints for a WHO DAT trademark.8.
Defendant State of Louisiana (herein Louisiana) is through its elected officials(principally the Attorney General) is responsible for making false statements regarding thevalidity of the trademarks of Who, Dat?, Inc. and is a necessary party to an action to declare thatWHO DAT does not belong to the public domain.
Case 3:10-cv-00154-JVP-DLD Document 1 03/04/10 Page 3 of 93