Case 1:11-cv-01069-KAM -SMG Document 1 Filed 03/07/11 Page 1 of 2

ORIGINAL
UNITED STATES DISTRICT COURT 11- 1069 J
EASTERN DISTRICT OF NEW YORK Complaint

-----------------------------------------------------)( Plaintiff Demands Trial By Jury

Gotham Dating Partners Inc. Plaintiffs,

Lebron Jordan Inc. {).Cllrrnm-f-lA M~TSlJMOTPJ4·~,
(l·O·
-Against-
Lebron James, Michael Jordan, Nike Inc., Jump D.C. Inc.,Live Nation, Converse Inc.

-----------------------------------------------------)(
1: At all Times Hereinafter mentioned, Plaintiffs was and still is a resident of 690 Gates
Ave, Ste SF, Brooklyn, NY 11221
2: Defendants are Individuals and Corporations Respectively with offices and or
representation at the following addresses: Nike Inc.! Converse Inc, One Bowerman Drive,
DF4, Beaverton, Oregon, 97005-6453. Lebron James, Represented by Grubman, Indursky
th
& Shire, P.c., Carnegie Hall Tower, 152 West 57 Street, New York, NY 10019-3301.
Michael Jordan, Jump D.C. and Live Nation, 5335 Wisconsin Avenue, NW, Suite 720,
Washington DC, 20015. Michael Jordan, Jump D.C. and Live Nation share the same
address.
3: Plaintiffs are seeking relief in the amount of $150 million dollars from Each Defendant
Respectively.
4: We believe this court to have jurisdiction because Defendants have violated the
intellectual Property Rights of Plaintiffs by claiming ownership of their Legally Protected
brand. Plaintiffs offices are in the vicinity of the Eastern District.
5: Statement of Facts: On January 7th we received a letter from Nike Inc.! Converse Inc
stating that we had infringed upon their trademark rights by doing Business as Lebron
Jordan Inc .. The reason, they claimed the combination Lebron Jordan was an
Infringement because they own the rights to the last name Jordan and the first name
Lebron; in any combination. This assumes that only one person can trademark a product
with a name once it has been used, in any form. Lebron Jordan is not Michael Jordan, or
Lebron James. It is neither Lebron or Jordan. The company is not a single name company
but rather Lebron Jordan. We were not only the first to secure the name Lebron Jordan,
but prior to us, you could not even find that name combination on Google and any other
search engine.
6: On January 13th we received a similar letter from Jump D.C., and Live nation,
representing Michael Jordan. The letter also claimed infringement violations and asked
that we cease and Desist from not only using the brand, but return all monies for past
orders.
 Case 1:11-cv-01069-KAM -SMG Document 1 Filed 03/07/11 Page 2 of 2

7: The negative press surrounding the threatened action against us has caused us to lose a
multimillion dollar deal in addition to declining sales because of the assumption that we
have infringed on their respective trademarks.
8: For the following reasons we ask the court to hear this matter and consider relief for the
stated amount above.

w~
Dl/hl
wro Gttcs ft-uL- #- 5F
15I1J'o ( c..J~11;;J I Ny I (;)- P- I
5~( ~ 1/ (l( - S ~ 1/