Plaintiffs adidas America, Inc. and adidas
(collectively, "adidas") state the foHowingfor their Complaint against Defendants Shoe Shoe Express, Inc., doing business as SquadraUSA, and Luis A. Gonzalez, individually and doing business as Squadra USA (collectively,"Defendants").
This is an action at law and in equity for counterfeiting, trademark infringementand dilution, unfair competition, and unfair business practices, arising under the Trademark Act
(2009) ("Lanham Act"); the anti-dilution laws
severalstates; the unfair business practices and unfair and deceptive trade practices acts
several states;and the conunon law.2. For decades, adidas has manufactured,sold, and promoted apparel bearing itsfamous and distinctive Three-Stripe trademark (the "Three-Stripe Mark"). As identified below,adidas owns numerous incontestable federal trademark registrations for its Three-Stripe Mark forapparel, and adidas has invested millions
dollars building its brand in connection with theThree-Stripe Mark.3. adidas also has for many years manufactured,sold, and promoted apparel bearingits famous and distinctive "3-Bars Logo," which is a design mark that was inspired
the ThreeStripe Mark. As identified below, adidas owns numerous incontestable federal trademarkregistrations for its 3-Bars Logo for apparel,
has invested millions
dollars buildingits brand in connection with the 3-Bars Logo.
4. Despite Defendants' knowledge
adidas's rights in the famous Three-StripeMark and 3-Bars Logo, Defendants are designing, sourcing,manufacturing, importing,distributing, marketing,promoting,offering for sale, and/or selling apparel bearing counterfeit
and/or confusingly similar imitations
adidas's federally registered Three-Stripe Mark and 3Bars Logo, including the apparel depicted below:2-COMPLAINT
1120 N.W. Couch Street, Tenth Floor Portland, OR 97209-4128 Phone: 503.727.2000 Fax:503.727.2222
Case 3:11-cv-01501-AC Document 1 Filed 12/12/11 Page 2 of 26 Page ID#: 2