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UNITED STATES DISTRICT COURT


SOUTHERN DISTRICT OF FLORIDA

CASE NO. 17-60521-CIV- MOORE/MCALILEY

MEOWINGTONS LLC, a Florida limited liability


company,
Plaintiff,
v.

JOEL ZIMMERMAN p/k/a DEADMAU5,


an individual; PROF. MEOWINGTONS LTD.;
RONICA HOLDINGS LTD.,

Defendants.
/

PROF. MEOWINGTONS LTD.,

Counter-Plaintiff,
v.

EMMA BASSIRI, an individual;


SCOTT HUTCHISON, an individual; and
MEOWINGTONS LLC

Counter-Defendants.
/

PROF. MEOWINGTONS LTD.S COUNTERCLAIM COMPLAINT


Counter-Plaintiff, PROF. MEOWINGTONS LTD. (Counter-Plaintiff), hereby sues

Counter-Defendants, EMMA BASSIRI (Bassiri), SCOTT HUTCHISON (Hutchison), and

MEOWINGTONS LLC (Meowingtons LLC) (collectively referred to as Counter-Defendants

or Bassiri Parties), and alleges:

INTRODUCTION

1. This action arises out of Counter-Defendants blatant attempts to exploit for their

own commercial benefits the popular MEOWINGTONS mark of internationally-renowned and

respected progressive electronic music artist and producer, Joel Zimmerman, whose stage name is

deadmau5 (pronounced dead mouse). Over the course of his storied career, deadmau5 has

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released scores of critically acclaimed and chart-topping albums and singles, garnered millions of

fans, won multiple prestigious music industry awards, and given record-breaking performances at

some of the worlds most legendary venues, festivals, and award ceremonies. Indeed, deadmau5

has achieved national and international fame and had near ubiquity at all relevant times in his,

Bassiris, and Hutchisons home town of Toronto, Canada.

2. As a result of deadmau5s fame, his cat whom he named Prof. Meowingtons,

PhD, and is commonly referred to as Prof. Meowingtons, and Meowingtons has become

widely recognized in his own right and gained substantial fans and followers on social media.

3. Specifically, deadmau5 developed the MEOWINGTONS mark in 2010, and first

used MEOWINGTONS as a trademark in commerce in the United States in 2011 through his

wholly-owned entities, including Ronica Holdings Limited (Ronica) and then Counter-Plaintiff,

Prof. Meowingtons Ltd.1


4. In addition to using the MEOWINGTONS mark in connection with entertainment

performances and related services, deadmau5 has, through Prof. Meowingtons Ltd., used it on

consumer goods. As a result of this widespread and continuous use of the MEOWINGTONS mark

and public exposure and commercial success, valuable goodwill has accrued in the

MEOWINGTONS mark.

5. In the years between deadmau5s first use of the MEOWINGTONS mark in 2011

and Counter-Defendants first purported use of the same mark in April of 2014, deadmau5 sold

tens of thousands of units of MEOWINGTONS-branded apparel in commerce in the United States

alone. In those years, deadmau5 headlined a MEOWINGTONS-branded tour, the Meowington

Hax Tour, which played across the United States and Canada, released a Meowington Hax Tour

Trax album, and released a Meowington Hax video. During this period, deadmau5 also sold

MEOWINGTONS-branded headphones in interstate commerce.

1
Prof. Meowingtons Ltd. was formed on September 11, 2015 for the purpose of, among other
things, owning and commercializing the intellectual properties and business to which the
MEOWINGTONS mark pertains, which was done through Ronica Holdings Limited before.

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7. As admitted in the Complaint, Counter-Defendants operate an online cat-themed

retail store, www.meowingtons.com, in violation of deadmau5 and Counter-Plaintiffs rights in

the MEOWINGTONS mark. A true and correct screenshot of the www.meowingtons.com

homepage and logo is attached hereto as Exhibit 1.

8. Counter-Defendants unauthorized use of the MEOWINGTONS mark has already

caused actual confusion in the marketplace, with customers mistaken and confused into believing

that Counter-Defendants are affiliated with deadmau5. This is a point that is unequivocally

admitted and affirmatively asserted by Counter-Defendants in the Complaint (Dkt. No. 1 at 25,

69, 77).

9. Further, Counter-Defendants unauthorized use of the MEOWINGTONS mark has

already started to tarnish the reputation and goodwill associated with the mark. For example,

according to the Better Business Bureau, Counter-Defendants business activities under the

MEOWINGTONS mark are so untrustworthy and the products they offer so inferior that their

business was rated F.2 Given the perceived affiliation and admitted confusion between Counter-

Defendants on the one hand and Counter-Plaintiff and deadmau5 on the other, the goodwill and

reputation associated with the MEOWINGTONS mark are and continue to be irreparably

damaged.

10. Despite deadmau5 and Counter-Plaintiffs prior use of the MEOWINGTONS mark

in connection with headphones, music, musical performances, and apparels which Counter-

Defendants recognized and admitted in the Complaint (Dkt. No. 1 at 31) on information and

2
See copies of complaints submitted to the Better Business Bureau about Counter-Defendants
business activities attached hereto as Exhibit 13.

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belief, they fraudulently procured the registration of the MEOWINGTONS mark shown in

Registration No. 4,711,265 (the Subject Registration).

11. Even worse, they have sued deadmau5, Ronica, and Prof. Meowingtons Ltd. for

trademark infringement, asserting that deadmau5s conduct which predates Counter-Defendants

purported first use by several years somehow infringes their purported trademark rights in the

MEOWINGTONS mark.

12. Despite deadmau5 and Prof. Meowingtons Ltd.s repeated efforts to resolve the

dispute amicably with Counter-Defendants, they refuse to acknowledge and remedy their

wrongdoing. Instead, they brought this meritless trademark infringement action against deadmau5

Prof. Meowingtons Ltd., and Ronica, thereby necessitating this Counterclaim Complaint. Because

Prof. Meowingtons Ltd. has been harmed and will continue to be harmed unless Counter-

Defendants are enjoined from their infringing activities, Prof. Meowingtons Ltd. brings this

Counterclaim Complaint, seeking, among other things, actual damages, punitive damages, and

injunctive relief.

THE PARTIES
13. Counter-Plaintiff Prof. Meowingtons Ltd. is a Canadian corporation with its

principal place of business at 16000 Ventura Boulevard, Suite 600, Encino, California 91436.

Counter-Plaintiff is the current owner of the subject MEOWINGTONS mark. Counter-Plaintiff is

wholly-owned and controlled by Joel Zimmerman p/k/a deadmau5.3 It was formed on September

11, 2015 for the purpose of, among other things, owning and commercializing the intellectual

properties and business to which the MEOWINGTONS mark pertains. Along with its predecessor,

Ronica Holdings Limited, Counter-Plaintiff Prof. Meowingtons Ltd. is referred to herein as

Meowingtons Ltd.

14. Counter-Defendant Meowingtons, LLC is a Florida limited liability with an address

3
The MEOWINGTONS mark was always wholly owned by Mr. Zimmerman, first through his
wholly owned entity Ronica Holdings Limited, and then through Counter-Plaintiff. In the factual
summary, deadmau5 is meant to include all of Mr. Zimmermans wholly owned entities.

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at 20 John Street, Suite 318, Toronto M5V0G5, Canada, and with a registered agent for service of

process at 101 NW 5th Avenue, Fort Lauderdale, Florida 33311. Counter-Defendant

Meowingtons, LLC has marketed and offered, and continues to market and offer, services and

products under the MEOWINGTONS mark without Counter-Plaintiffs authorization or consent

throughout the United States.

15. On information and belief, Counter-Defendant Emma Bassiri is an individual who

is from Toronto, Canada, and currently resides in the Southern District of Florida. On information

and belief, Bassiri has been at all relevant times, and currently is, a Manager of Counter-Defendant

Meowingtons, LLC. Bassiri has marketed and offered, and continues to market and offer, services

and products under the MEOWINGTONS mark without Meowingtons Ltd.s authorization or

consent throughout the United States. According to the USPTO database, Bassiri submitted

Application 86/338,038 to register MEOWINGTONS and made the following statement under

penalty of perjury, which on information and belief is false:

The signatory believes that to the best of the signatorys knowledge and belief, no

other person has the right to use the mark in commerce, either in the identical

form or in such near resemblance as to be likely, when used on or in connection

with the goods/services of such other person, to cause confusion or mistake, or

to deceive. The signatory being warned that willful false statements and the like are

punishable by fine or imprisonment, or both, under 18 U.S.C. Section 1001, and

that such willful false statements and the like may jeopardize the validity of the

application or any registration resulting therefrom, declares that all statements

made of his/her own knowledge are true and all statements made on information

and belief are believed to be true.

16. On information and belief, Counter-Defendant Scott Hutchison is an individual

who is from Toronto, Canada,4 and currently resides in the Southern District of Florida. Hutchison

4
There is another Scott Hutchison, the frontman of Scottish indie rock band Frightened Rabbit;
that Scott Hutchison is not a Counter-Defendant. deadmau5 has no dispute with Frightened Rabbit.

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has been at all relevant times, and currently is, a Manager of Counter-Defendant Meowingtons

LLC. Hutchison has marketed and offered, and continues to market and offer, services and

products under the MEOWINGTONS mark without Meowingtons Ltd.s authorization or consent

throughout the United States. Prior to the alleged first use of the MEOWINGTONS mark by

Meowingtons, LLC on April 1, 2014, Hutchison was a DJ in the Toronto area under the name

Hutch. During that period, Hutchison posted photographs of himself playing deadmau5 tracks,

as shown below, as early as April 16, 2010. It is simply inconceivable that Hutchison, as a manager

of Meowingtons, LLC and a Toronto-area DJ, was unaware of the existence of MEOWINGTONS

as of April 1, 2014.

JURISDICTION AND VENUE

17. This is a counterclaim for trademark infringement and false association under the

Trademark Act of 1946, as amended, 15 U.S.C. 1051 et seq. (the Lanham Act), and for

trademark infringement under the common law of the State of Florida.

18. This Court has jurisdiction over the Lanham Act claims pursuant to 15 U.S.C.

1121 and 28 U.S.C. 1331 and 1338. Supplemental jurisdiction exists over the Florida common

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law claims pursuant to 28 U.S.C. 1367(a).

19. Venue lies in this district under 28 U.S.C. 1391(b) and (c) because the parties are

located in and/or transact their affairs in this judicial district, and/or a substantial part of the events

or omissions giving rise to the claim occurred in this judicial district, and all the parties are subject

to this Courts personal jurisdiction. Both individual Counter-Defendants have indicated to the

Florida Secretary of State that they reside in Fort Lauderdale, and the LLC Counter-Defendant

lists its address as within the District. Moreover, Plaintiff initiated this action in this judicial

district.

ALLEGATIONS COMMON TO ALL CLAIMS FOR RELIEF


I. deadmau5s5 Widespread Fame in the United States as well as in Toronto, Canada,

the Home Town of Bassiri, Hutchison, and deadmau5

20. deadmau5s prolific career as an artist, composer, performer, and producer has been

both ground- and record-breaking. Today, deadmau5 is universally recognized as one of the most

dominant figures in the electronic dance music (EDM) movement that has swept the United States

and the globe over the past decade and a half. deadmau5 has graced the cover of VIBE, Rolling

Stone, Inked and NME, among others. As noted by USA Today and Your EDM magazine, over

the past 14 years, deadmau5 has dominate[d] the EDM scene in large part due to his efforts to

painstakingly curat[e] and develop[] an iconic, recognizable brand. Attached as Exhibit 2 are

true and correct copies of the aforementioned USA Today and Your EDM articles.

21. Since 2002, deadmau5 has released over 100 solo and collaborative albums, EPs,

and singles, and has had his works featured in dozens more compilation albums. His album

while(1<2) debuted atop Billboard magazines Dance/Electronic Albums chart in the summer of

2014 as deadmau5s second consecutive No. 1 album following >album title goes here<.

while(1<2) also rose to number 9 in the top 20 of Billboards Top 200 and number 4 on Billboards

5
As used in this Counterclaim, deadmau5 refers to Mr. Zimmerman and his team in their
professional capacity. Where Mr. Zimmerman is being referred to in his personal capacity, he is
simply referred to by name.

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Digital Albums chart, and was nominated for a Grammy in the Best Dance/Electronic Album

category.

22. In addition to audio works, deadmau5 has released for sale DVDs containing

footage from two of his more momentous performances to date: deadmau5 live @ earls court,

and Meowingtons Hax 2k11 TORONTO, which he named after his cat, Meowingtons.

23. The second DVD Meowingtons Hax 2k11 TORONTO contains footage from

the final stop of deadmau5s record-setting Meowingtons Hax North American tour, which

launched on August 5, 2011 at Lollapalooza in Chicago and concluded on November 5, 2011 with

a show at Torontos Rogers Centre (about 500 yards from Bassiris home at the time). During this

tour, deadmau5 became the first electronic music artist to headline the Lollapalooza music festival

as well as the first Canadian musical artist (of any genre) to headline the stadium-sized Rogers

Centre (formerly known as the SkyDome, home of the Blue Jays). Attached hereto as Exhibit 3

are true and correct copies of the cover of the Meowingtons Hax 2k11 TORONTO DVD, a printout

of the iTunes product page for the DVD, and articles from the Toronto Star and Examiner.com

reviewing the Rogers Centre concert.

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24. On July 1, 2014, deadmau5 served as Grand Marshal in the Canada Day parade put

on by Niagara Falls, Ontario, and was given the key to the city.

25. deadmau5, through his wholly-owned and controlled holding companies, owns

several trademarks related to the deadmau5 name and brand, including MEOWINGTONS, and

has sought to exploit the reach of his brand through a highly successful and profitable licensing

and merchandising program using his music and intellectual properties in or on a wide range of

goods. deadmau5 is extremely selective in choosing licensees, and carefully controls and monitors

the quality of the licensed products and services produced by these licensees as they are a reflection

on deadmau5, his act, and his business activities.

26. Goods bearing deadmau5s marks have been offered through nationwide chains

such as Target, Hot Topic, Spencers Gifts, Forever 21, Party City, Tillys, and Torrid, as well as

through music merchandising companies that specialize in selling artists merchandise to fans and

novelty stores. For example, until very recently, major music merchandiser LiveNation and its

subsidiaries operated deadmau5s official online store, handled merchandise sales at deadmau5s

concerts, and were the largest sellers of deadmau5 merchandise through other outlets. deadmau5

now handles his merchandise in-house.

II. deadmau5s Prior Use of the MEOWINGTONS Mark and Senior Rights Thereto
A. Origin of the MEOWINGTONS Name and Its Introduction to the World

27. In January 2010, Mr. Zimmerman adopted a black and white cat from the Toronto

Humane Society. Because of the cats incessant meowing, he named the cat Prof. Meowingtons,

PhD, or Meowingtons for short.

28. Meowingtons instantly became an internet sensation. Several videos of

Meowingtons dating back to January 2010 are on YouTube, many of them with hundreds of

thousands of views.

29. In or about April 2010, deadmau5 created a separate Facebook account for

Meowingtons that has over 95,000 likes, and in June 2010, deadmau5 posted a photo album

titled me ow ing tons on his deadmau5 Facebook page, which has nearly 9 million likes,

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containing photos of Meowingtons. In November 2010, deadmau5 created a separate Twitter

account for Meowingtons under username @meowingtons_pHd. The Meowingtons Twitter

account has approximately 31,000 followers and is a verified account a status reserved only

for celebrities, public figures, and other accounts of public interest. Meowingtons also has a second

Twitter account, @meowingtons, as well as his own verified Instagram account, @meowingtons,

which has over 19,000 followers. Attached hereto as Exhibits 4, 5 and 6 are true and correct copies

of Meowingtons Facebook, Twitter, and Instagram account profiles, respectively. Attached hereto

as Exhibit 7 is a true and correct copy of the search results for Meowingtons on YouTube.

30. Meowingtons fame has been recognized by media outlets such as Toronto Life

magazine, who in November 2011 published an article about deadmau5, noting that Meowingtons

has become a starring character in Zimmermans online universe, and further noting that the cat

has his own Facebook page with tens of thousands of fans. A photo of deadmau5 wearing his

iconic mau5head and holding Meowingtons is featured prominently at the top of the article, a true

and correct copy of which is attached hereto as Exhibit 8.

31. Like deadmau5, Meowingtons has also gained his fair share of unsolicited media

and fan attention. For example, in 2012, photos of celebrity cat Meowingtons were featured on

poshpetsblog.com. Also in 2012, a fan created a tumblr fanblog dedicated to Meowingtons titled

Fuck Yeah Meowingtons, which features hundreds of photos of Meowingtons along with

deadmau5. True and correct copies of these blog posts are attached hereto as Exhibit 9.

B. Tens of Thousands of Units of MEOWINGTONS-Branded Merchandise Have

Been Sold in Commerce Beginning in 2011 and Continuously to the Present

32. Beginning in 2011, deadmau5 and his management team began taking steps to

convert Meowingtons (the cat)s rising fame into a commercial and artistic opportunity. This

transformation took a number of forms, all of which were aimed at turning the name of

Meowingtons6 into its own MEOWINGTONS brand.

6
As used in this Counterclaim, Meowingtons refers to the cat, and MEOWINGTONS refers to
the mark as used in commerce.

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33. First, in the fall of 2011, deadmau5 launched a groundbreaking North American

music tour utilizing the MEOWINGTONS mark the Meowingtons Hax Tour. As discussed

above, the Meowingtons Hax Tour began on August 5, 2011 at Lollapalooza in Chicago. During

this tour, deadmau5 became the first electronic music artist to headline Lollapalooza. Promotional

materials and merchandise (e.g., posters, t-shirts, etc.) for the tour, examples of which are depicted

below, bear the MEOWINGTONS mark as well as cartoon images of Meowingtons wearing a

mau5head, together with deadmau5 himself.

34. As part of the promotion for the Meowingtons Hax Tour, on August 25, 2011,

deadmau5 released a compilation album on his mau5trap label titled Meowingtons Hax Tour Trax,

which includes tracks from renowned music artists including himself, Skrillex, Tommy Lee, DJ

Aero, and Feed Me. The front and back cover of the album prominently bear the

MEOWINGTONS mark and images of Meowingtons and deadmau5 similar to the artwork used

on the tours promotional materials.

35. In connection with the Meowingtons Hax Tour and continuing to the present,

deadmau5 marketed extensive merchandise featuring the MEOWINGTONS mark, both on its own

and as a secondary source indicator in connection with Meowingtons and deadmau5. To date,

approximately 40,000 units of MEOWINGTONS merchandise have been sold or transported in

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commerce in the United States alone. A significant portion of those sales pre-date Plaintiffs

purported priority date of April 1, 2014.

36. For example, in November of 2011, deadmau5 began causing Meowington Hax t-

shirts to be shipped in interstate commerce to Hot Topic: ultimately, more than 16,000 units of

these shirts were sold throughout the United States. On information and belief, Hot Topic has more

than 500 stores across America.

37. The Meowingtons Hax tour ended on November 5, 2011, with a 20,000-strong

crowd at Torontos Rogers Centre (formerly known as the SkyDome, and home of the Blue Jays),

which is a mere mile away from OCAD (Ontario College of Arts and Design), where Bassiri was

then attending her third year of college. deadmau5 was the first Canadian musical artist of any

genre to headline a show at the Skydome.

38. Despite the tour ending in 2011, deadmau5 continued to promote the

MEOWINGTONS mark from 2012 to the present, independently of any particular event. Simply

by way of example:

a. In March of 2012, deadmau5 began causing F*** Yeah Meowingtons shirts to

be transported in interstate commerce to Spencers, another retailer that, on information and belief,

has more than 500 stores across America. More than 6,500 units of that shirt alone have been sold

in interstate commerce.

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b. In August 2012, deadmau5 collaborated with Sol Republic, an audio equipment

company, to design and sell limited edition high-end MEOWINGTONS branded headphones the

first ever headphones designed specifically for cats. The marketing materials bear the

MEOWINGTONS mark and an image of Meowingtons wearing the headphones as depicted

below.

Indeed, the headphones themselves bear the MEOWINGTONS mark as depicted below.

The commercial for the MEOWINGTONS headphones, in which Meowingtons appears (available

at https://www.youtube.com/watch?v=YEk-Gp2uojM and

https://www.youtube.com/watch?v=isie2VF3VGw), was published on YouTube on August 1,

2012 and has a total of over 477,000 views.

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e. Beginning in 2011, merchandise bearing the MEOWINGTONS mark was also sold

at deadmau5 tours. Thousands of units of MEOWINGTONS merchandise were sold under the

MEOWINGTONS mark through this channel.

f. deadmau5 featured an image of Meowingtons wearing a partial mau5head in his

2012 album >album title goes here<. This album debuted at number 6 on the Billboard 200 and

at number 1 on Billboard magazines Dance/Electronic Albums chart. The album also peaked at

number 1 on the UK Dance Albums chart.

g. On March 19, 2013, deadmau5, through Ultra Records, released for sale a DVD

titled Meowingtons Hax 2k11 TORONTO, which features live footage from the final stop of the

momentous Meowington Hax Tour at the Rogers Center. The DVD cover bearing the

MEOWINGTONS mark is depicted below.

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39. deadmau5 took other steps to commercialize the MEOWINGTONS mark. In

September of 2011, he had a MEOWINGTONS perfume bottle commissioned. Pictures of the

sample bottles are attached hereto as Exhibit 10.

40. On August 8, 2015, Counter-Plaintiffs predecessor, wholly-owned and controlled

by Mr. Zimmerman, filed U.S. Trademark Application Serial No. 86/719,048 for the mark PROF.

MEOWINGTONS, covering certain goods and services in International Classes 9, 16, 18, 21, 24,

25, 28, and 41. On May 19, 2016, the USPTO issued an Office action refusing registration because

of a likelihood of confusion with the mark shown in the Subject Registration for

MEOWINGTONS, issued on March 31, 2015 to Counter-Defendant Meowingtons, LLC. The

MEOWINGTONS mark had been hijacked by Counter-Defendants.

III. Counter-Defendants Willful Infringement of the MEOWINGTONS Mark


A. Counter-Defendants Knowledge of deadmau5s Use and Right to the Mark

41. On information and belief, Bassiri, the principal of Counter-Defendant

Meowingtons LLC, spent her teen years and early twenties in Toronto, Canada, before moving to

the Fort Lauderdale area in or about 2014. While in Toronto, Bassiri attended OCAD (Ontario

College of Arts and Design) in Toronto from 2009 to 2013.

42. Although deadmau5 has garnered extensive fame in the United States and

worldwide well beyond those knowledgeable of EDM, he cut his musical teeth in Toronto, and his

level of fame there is analogous to Bruce Springsteen in New Jersey or Gloria Estefan in Miami.

43. On information and belief, Hutchison, a manager of Meowingtons, LLC, was at all

relevant times a DJ based in Toronto, Canada, under the name Hutch, who played deadmau5

tracks in connection with his work at least as early as April 2010 (see 16, supra). It is not

conceivable that a Toronto-area DJ (particularly one who had featured deadmau5 in his work)

would not be aware of both deadmau5 and MEOWINGTONS as of April 2014.

44. On information and belief, on or about February 11, 2014, Counter-Defendants

registered the domain name, www.meowingtons.com.

45. On information and belief, on or about April 1, 2014, Counter-Defendants started

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using MEOWINGTONS mark on meowingtons.com as their online retail store featuring cat-

themed products.

46. Meowingtons, LLC claims in its Complaint in this matter (Dkt. No. 1 at 10) that

it took various diligent steps prior to, and upon launching her Meowingtons [sic] business such

as conducting trademark, domain name and corporate name searches. A cursory look at Google

indicates this is not true.

47. Google permits users to conduct date-limited searches, thus making it possible to

reproduce what a search looked like in 2013 or 2014, when Counter-Defendants purported

research took place.

48. Attached hereto as Exhibit 11 is a screenshot of a Google search for meowingtons

using the date range June 30, 2013 through March 31, 2014 (immediately before Counter-

Defendants purported first date of use). Of the ten links on the first page, six reference deadmau5,

and two more (the meowingtons corp site and the meowingtons theme) expressly reference

deadmau5 in context.

49. Attached hereto as Exhibit 12 is a screenshot of a Google Canada search for

meowingtons using the date range June 30, 2013 through March 31, 2014 (immediately before

the purported first date of use), but limited to Canadian results. The top 5 results all reference

deadmau5.

50. Thus, a simple Google search of Meowingtons at the time would have shown

both a link to deadmau5 and his use of MEOWINGTONS in commerce in connection with, at the

very least, deadmau5s music. If Counter-Defendants indeed engaged in diligence prior to

adopting the MEOWINGTONS mark, they would have promptly uncovered deadmau5s use of

the mark.

51. On information and belief, Counter-Defendants have been aware of both

MEOWINGTONS and deadmau5s use of the MEOWINGTONS mark since at least before using

the MEOWINGTONS mark in April 2014.

52. On information and belief, Counter-Defendants, having knowledge of deadmau5

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and of the valuable goodwill associated with deadmau5s brands and marks, including the

MEOWINGTONS mark, intentionally chose and adopted the MEOWINGTONS mark for their

business in order to trade on this valuable goodwill and have been using the MEOWINGTONS

mark without deadmau5 or Counter-Plaintiffs consent or authorization.

53. Counter-Defendant Meowingtons LLC has an F rating on the Better Business

Bureau website, with negative reviews and complaints about Counter-Defendant and

www.meowingtons.com, including complaints about poor customer service, false and misleading

advertising, and poor product quality. See Exhibit 13.

54. Indeed, Counter-Defendants appear to be using the very existence of this dispute in

an effort to draw attention to the meowingtons.com site. Promptly upon filing this lawsuit,

Counter-Defendants shopped stories about the fact that they had sued deadmau5 to numerous

publications including, without limitation, the New York Times, The Hollywood Reporter, and

several Village Voice Media publications, in an effort to draw further attention (and presumably

business) to the meowingtons.com site. Not content to simply trade on deadmau5s and Counter-

Plaintiffs goodwill in business, Counter-Defendants have initiated this lawsuit and concomitant

media strategy in an effort to use the very fact of this dispute to trade on deadmau5s fame and

Meowingtons popularity. Indeed, within three days of filing the Complaint, Counter-Defendants

posted on their website If theres any time for women entrepreneurs to prevail its now. I wont

be bullied into submission over something Ive worked so hard for, about the instant lawsuit they

instituted, seeking community support and inviting people to share the post and leave comments.

B. Counter-Defendants Fraudulent Declaration to the USPTO

55. On or about July 15, 2014, Counter-Defendants filed U.S. Trademark Application

Serial No. 86/338,038 (Application) for the standard character mark MEOWINGTONS,

covering the following services in International Class 35: Retail store and online retail store

services for men and women featuring cat themed accessories and clothing, namely, t-shirts, tank

tops, crop tops, sweatshirts, hooded sweatshirts, bathing suits, cardigans, blouses, dresses, pants,

pyjamas [sic], shorts, skirts, rompers, panties, bras, thongs, jumpers, leggings, sweatpants, knitted

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woven or knitted underwear, lingerie, jackets, scarves, baseball hats, five panel hats, caps, socks,

stockings, pantyhose, rings, necklaces, earrings, bracelets, purses, handbags, shoulder bags, clutch

bags, tote bags, wallets, slippers, shoes, sandals, flats, boots, running shoes, ties, bows, bandanas,

headbands, gloves, sunglasses, belts, watches.

56. According to the Application, Counter-Defendants first use of the

MEOWINGTONS mark in commerce was on April 1, 2014 years after deadmau5s first use of

the mark in commerce. Attached hereto as Exhibit 14 is a true and correct copy of the Application.

57. On or about July 15, 2014, Bassiri submitted a Declaration in support of said

Application purporting to declare under oath (emphasis added):

The signatory believes that to the best of the signatorys knowledge and belief, no

other person has the right to use the mark in commerce, either in the identical

form or in such near resemblance as to be likely, when used on or in connection

with the goods/services of such other person, to cause confusion or mistake, or

to deceive. The signatory being warned that willful false statements and the like are

punishable by fine or imprisonment, or both, under 18 U.S.C. Section 1001, and

that such willful false statements and the like may jeopardize the validity of the

application or any registration resulting therefrom, declares that all statements

made of his/her own knowledge are true and all statements made on information

and belief are believed to be true.

58. On information and belief, at the time Bassiri submitted the foregoing Declaration,

she was aware of deadmau5s right to use the MEOWINGTONS mark in commerce, and that

Counter-Defendants use of said mark in commerce in connection with the services covered in the

Subject Registration would be likely to cause confusion or mistake or to deceive. As such, Counter-

Defendants fraudulently procured Registration No. 4,711,265 by intentionally making knowingly

false and material statements to the USPTO. Attached hereto as Exhibit 15 is a true and correct

copy of Bassiris Declaration submitted to the USPTO.

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C. Actual Confusion and Tarnishment of the MEOWINGTONS Mark

59. Counter-Defendants use of the MEOWINGTONS mark in the manner described

above is likely to cause confusion, mistake, and/or deception as to the origin, sponsorship, or

approval of the goods marketed and sold by Counter-Defendants, their services, and commercial

activities in that the public, the trade, and others are likely to believe that Counter-Defendants

goods are provided, sponsored, approved, licensed, authorized or endorsed by, or affiliated with,

or in some other way legitimately connected to deadmau5 and Counter-Plaintiffs goods and

services that are promoted, offered, and/or sold in connection with the MEOWINGTONS mark.

60. Counter-Defendants have admitted as much in the Complaint in this matter, stating

in paragraphs 25, 69 and 77 that confusion is likely between Counter-Plaintiffs senior

MEOWINGTONS mark and Counter-Defendants use of the mark: Because of the similarity

between Plaintiffs Mark and Defendants Marks and the similar goods and/or services: (i)

prospective consumers are likely to be deceived, mistaken, or confused as to the source or origin

of the respective goods and/or services of the parties; (ii) the distinctiveness of Plaintiffs Mark is

being diluted; and/or (iii) Defendants have caused the likelihood of direct consumer confusion,

initial interest confusion, reverse confusion and/or forward looking confusion. Dkt. No. 1 at

25.

61. Thus, confusion is unequivocally admitted by Counter-Defendants.

62. Counter-Defendants unauthorized use of the MEOWINGTONS mark also falsely

designates the origin of their goods and services. Furthermore, their use of the mark prevents

deadmau5 and Counter-Plaintiff from controlling the nature and quality of goods and services

provided thereunder and places the valuable reputation and goodwill of deadmau5 and Counter-

Plaintiff in the hands of Counter-Defendants, over whom deadmau5 and Counter-Plaintiff have no

control.

63. Indeed, there are several incidents where consumers have actually confused

Counter-Defendants goods and services as having originated with deadmau5 and Counter-

Plaintiff:

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a. One consumer directed the following Twitter message to deadmau5 and

Meowingtons: @meowingtons @deadmau5 You have a store?! Wow! Except I dont see your

profile anywhere.. meowingtons.com.

b. Another consumer sent the following Twitter message to deadmau5, along with a

screenshot of a kitty purse for sale on www.meowingtons.com: @deadmau5 ummmm?? Are

you behind this meowingtons fashion site? Lol uh-oh I smell lawsuit.

c. Yet another consumer sent the following Twitter message to deadmau5 with a

screenshot of the www.meowingtons.com homepage: Does Meowingtons has [sic] an online

shop? @deadmau5 looks like someone has another legal battle to fight lol.

d. There are also several instances of consumers tagging Counter-Plaintiffs senior

Twitter account (@meowingtons) in connection with goods sold on www.meowingtons.com. For

example, one consumer posted: I <3 my new ring from @meowingtons! Another consumer

Tweeted: I got my kitty ring in from @meowingtons too. Attached hereto as Exhibit 16 are true

and correct copies of the aforementioned Twitter posts, or tweets, in addition to several other

examples of actual consumer confusion.

64. Further adding to the confusion, Counter-Defendants posted an image to their

Instagram account (@meowingtonsco) of the www.meowingtons.com logo on a photo of a cat that

looks identical to Meowingtons, and indeed one user tagged @deadmau5 in the comments.

Attached hereto as Exhibit 17 is a true and correct copy of this Instagram post and the

aforementioned comment.

65. On information and belief, Counter-Defendants actions were calculated and willful

from the outset and reflect an intent to confuse consumers and profit from the goodwill associated

with deadmau5 and his valuable intellectual property.

D. Counter-Defendants Refusal to Limit Their Use of the Mark

66. As part of its good faith efforts to resolve this dispute without litigation, Counter-

Plaintiff repeatedly requested that Counter-Defendants limit their use and registration of the

MEOWINGTONS mark. They refused.

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Case 0:17-cv-60521-KMM Document 16 Entered on FLSD Docket 05/12/2017 Page 25 of 33

67. As of the date of this Counterclaim, Counter-Defendants continue to use the

MEOWINGTONS mark without deadmau5s consent or authorization. Their bad faith denial and

refusal to comply with deadmau5s demands further underscores that Counter-Defendants

infringement of the MEOWINGTONS mark was and is willful. Indeed, Counter-Defendant

Meowingtons, LLC has sued deadmau5 and Meowingtons Ltd. in an effort to bar use that it

concedes pre-dates Counter-Defendants use.

68. Counter-Defendants actions as alleged herein constitute blatant and willful

trademark infringement and false association in violation of federal and state law.

COUNT I
(Trademark Infringement Under Section 43(a) of the Lanham Act)

69. Counter-Plaintiff refers to and incorporates the foregoing allegations as if fully set

forth herein.

70. Counter-Defendants use of deadmau5s prior common-law MEOWINGTONS

mark is likely to cause confusion, mistake, or deception as to the source, origin, sponsorship, or

approval of Counter-Defendants goods, services, and commercial activities in that consumers,

potential licensees, and others are likely to believe that Counter-Defendants are associated with or

related to deadmau5 and Counter-Plaintiff or that deadmau5 and Counter-Plaintiff authorized and

control the sale of Counter-Defendants goods, services, and commercial activities in the United

States.

71. Indeed, Counter-Defendant Meowingtons, LLC admits as much in its Complaint:

Because of the similarity between Plaintiffs Mark and Defendants Marks and the similar goods

and/or services: (i) prospective consumers are likely to be deceived, mistaken, or confused as to

the source or origin of the respective goods and/or services of the parties; (ii) the distinctiveness

of Plaintiffs Mark is being diluted; and/or (iii) Defendants have caused the likelihood of direct

consumer confusion, initial interest confusion, reverse confusion and/or forward looking

confusion. Dkt. No. 1 at 25.

72. Counter-Defendants unauthorized use of the MEOWINGTONS mark has also

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Case 0:17-cv-60521-KMM Document 16 Entered on FLSD Docket 05/12/2017 Page 26 of 33

caused actual confusion, mistake, or deception as to the source, origin, sponsorship, or approval

of Counter-Defendants goods, services, and commercial activities.

73. Counter-Defendants actions, as alleged herein, constitute infringement of Counter-

Plaintiffs valid and subsisting common law mark in violation of Section 43(a) of the Lanham Act,

15 U.S.C. 1125.

74. On information and belief, Counter-Defendants actions have chilled Counter-

Plaintiffs licensing program and injured the reputation and goodwill associated with the

MEOWINGTONS mark that deadmau5 and Counter-Plaintiff have built and their reputation with

customers and potential licensees by creating confusion about Counter-Defendants goods and

services and their association or affiliation with deadmau5 and Counter-Plaintiff.

75. Counter-Defendants have been unjustly enriched as a direct and proximate result

of the actions alleged herein, which have also greatly and irreparably damaged Counter-Plaintiff.

76. Accordingly, pursuant to 15 U.S.C. 1117(a), Counter-Plaintiff is entitled to and

should be awarded Counter-Defendants profits, any damages sustained by Counter-Plaintiff, and

the costs of this action, in amounts to be determined at trial.

77. Counter-Defendants actions have greatly and irreparably damaged Counter-

Plaintiff and will continue to so damage Counter-Plaintiff unless restrained by this Court;

wherefore, Counter-Plaintiff is without an adequate remedy at law. Accordingly, Counter-Plaintiff

is entitled to an order preliminarily and permanently enjoining and restraining Counter-Defendants

from using the MEOWINGTONS mark.

COUNT II

(False Association Under Section 43(a) of the Lanham Act)

78. Counter-Plaintiff refers to and incorporates the foregoing allegations as if fully set

forth herein.

79. Counter-Defendants unauthorized use of Counter-Plaintiffs MEOWINGTONS

mark is likely to cause confusion, mistake, or deception as to the source, origin, sponsorship, or

approval of Counter-Defendants goods, services, and commercial activities in that consumers,

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Case 0:17-cv-60521-KMM Document 16 Entered on FLSD Docket 05/12/2017 Page 27 of 33

potential licensees, and others are likely to believe that Counter-Defendants are associated with or

related to deadmau5 and Counter-Plaintiff or that deadmau5 and Counter-Plaintiff authorized and

control the sale of Counter-Defendants goods, services, and commercial activities in the United

States.

80. Counter-Defendants actions, as alleged herein, falsely suggest a connection with

deadmau5 and/or Counter-Plaintiff and constitute false association in violation of Section 43(a) of

the Lanham Act, 15 U.S.C. 1125(a).

81. On information and belief, Counter-Defendants actions have chilled Counter-

Plaintiffs licensing program and injured deadmau5 and Counter-Plaintiffs reputation and

goodwill with consumers and potential licensees by creating confusion about Counter-Defendants

goods and their association or affiliation with deadmau5 and Counter-Plaintiff.

82. Counter-Defendants have been unjustly enriched as a direct and proximate result

of the actions alleged herein, which have also greatly and irreparably damaged Counter-Plaintiff.

83. Accordingly, pursuant to 15 U.S.C. 1117(a), Counter-Plaintiff is entitled to and

should be awarded Counter-Defendants profits, any damages sustained by Counter-Plaintiff, and

the costs of this action, in amounts to be determined at trial.

84. Counter-Defendants actions have greatly and irreparably damaged Counter-

Plaintiff and will continue to so damage Counter-Plaintiff unless restrained by this Court;

wherefore, Counter-Plaintiff is without an adequate remedy at law. Accordingly, Counter-Plaintiff

is entitled to an order preliminarily and permanently enjoining and restraining Counter-Defendants

from using the MEOWINGTONS mark.

COUNT III

(Cancellation of Trademark Registration No. 4,711,265 on Account of Fraud)

85. Counter-Plaintiff refers to and incorporates the foregoing allegations as if fully set

forth herein.

86. Counter-Plaintiff is the prior user, and has nationwide priority of right over the

mark MEOWINGTONS in connection with Counter-Defendants goods and services.

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Case 0:17-cv-60521-KMM Document 16 Entered on FLSD Docket 05/12/2017 Page 28 of 33

87. To the extent Counter-Defendants have used or are using the MEOWINGTONS

mark, such use is without Counter-Plaintiffs authorization and as such Counter-Defendants are

misrepresenting the source of the goods and services.

88. Notwithstanding Counter-Plaintiffs senior use and priority, Counter-Defendant

Meowingtons, LLC obtained Registration No. 4,711,265.

89. As set forth in detail above, that registration was obtained by fraud. Upon

information and belief, the declaration alleging, among other things, that Counter-Defendants

believed no other person has the right to use the mark in commerce, either in the identical form

or in such near resemblance as to be likely, when used on or in connection with the goods/services

of such other person, to cause confusion or mistake, or to deceive was made in bad faith and in

an attempt to perpetrate a fraud upon the USPTO because Counter-Defendants knew or acted in

reckless disregard of the truth that deadmau5 and Meowingtons Ltd. had the right to use the

MEOWINGTONS mark in commerce at the time Application No. 86/338,038 was filed.

90. Reasonably relying on the truth of such materially false statement, the USPTO

approved Application No. 86/338,038 for registration, issuing into Registration No. 4,711,265 on

March 31, 2015.

91. Upon information and belief, the conduct of Counter-Defendants constitutes fraud

on the USPTO and therefore Registration No. 4,711,265 should be cancelled on this ground alone.

COUNT IV

(Cancellation of Trademark Registration No. 4,711,265 as Void Ab Initio)

92. Counter-Plaintiff refers to and incorporates the foregoing allegations as if fully set

forth herein.

93. Section 1(a) of the Lanham Act, 15 U.S.C. 1051(a), allows registration of

trademarks used in commerce and requires that an applicant make a verified statement that the

mark is in use in commerce before the filing of the application. Section 45 of the Act, 15 U.S.C.

1127, defines use in commerce of a mark in connection with services when it is used or

displayed in the sale or advertising of services and the services are rendered in commerce, or the

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Case 0:17-cv-60521-KMM Document 16 Entered on FLSD Docket 05/12/2017 Page 29 of 33

services are rendered in more than one State or in the United States and a foreign country and the

person rendering the services is engaged in commerce in connection with the services.

94. Upon information and belief, Counter-Defendants had not used the mark

MEOWINGTONS in commerce on or in connection with some or all of the services identified in

Application No. 86/338,038, and resulting Registration No. 4,711,265, as of April 1, 2014 as

declared under oath in the Application and required under Sections 1(a) and 45 of the Lanham Act,

15 U.S.C. 1051(a) and 1127.

95. Accordingly, Application No. 86/338,038, and resulting Registration No.

4,711,265, are void ab initio, and Registration No. 4,711,265 should be cancelled on this ground

alone.

COUNT V
(Cancellation of Trademark Registration No. 4,711,265 for Likelihood of Confusion)

96. Counter-Plaintiff refers to and incorporates the foregoing allegations as if fully set

forth herein.

97. As set forth in detail above, Meowingtons Ltd. has continuously and exclusively

used the MEOWINGTONS mark in connection with its sale of consumer goods and its provision

of related services prior to Counter-Defendants claimed April 1, 2014 date of first use in

commerce of the identical mark MEOWINGTONS. As such, Meowingtons Ltd. has priority.

98. The MEOWINGTONS mark is recognized and relied upon by the relevant

consumers and public as identifying Meowingtons Ltd.s goods and services, and as distinguishing

them from the goods and services of others, and has come to represent and symbolize extremely

valuable goodwill belonging exclusively to Counter-Plaintiff.

99. As admitted by Counter-Defendants in the Complaint, the MEOWINGTONS mark

as registered in Registration No. 4,711,265 and as admittedly used in connection with Counter-

Defendants goods and services causes confusion, mistake, and/or deception and falsely designates

and suggests a connection with deadmau5 and/or Counter-Plaintiff.

100. Accordingly, Registration No. 4,711,265 should be cancelled on this ground alone.

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Case 0:17-cv-60521-KMM Document 16 Entered on FLSD Docket 05/12/2017 Page 30 of 33

COUNT VI

(Violation of the Anti-Cybersquatting Consumer Protection Act, 15 U.S.C. 1125(d))

101. Counter-Plaintiff refers to and incorporates the foregoing allegations as if fully set

forth herein.

102. Counter-Defendants unauthorized use of the domain name

www.meowingtons.com is identical and confusingly similar to Counter-Plaintiffs

MEOWINGTONS mark.

103. On information and belief, Counter-Defendants registered the domain name in bad

faith with an intent to profit from the use of the MEOWINGTONS mark, in violation of 15 U.S.C.

1125(d), because Counter-Defendants knew or acted in a reckless disregard of the truth that

deadmau5 and Meowingtons Ltd. had the right to use the MEOWINGTONS mark in commerce

at the time they registered the domain name.

104. Accordingly, pursuant to 15 U.S.C. 1125(d)(1)(C), Counter-Plaintiff is entitled to

cancellation and/or forfeiture of the www.meowingtons.com domain. Additionally, Counter-

Plaintiff is entitled to all other remedies available under the Lanham Act, including but not limited

to, compensatory damages and disgorgement of profits, or alternatively, statutory damages as

permitted by 15 U.S.C. 1117(d), treble damages, and costs and attorneys fees.

COUNT VII

(Unfair Competition Under Florida Common Law)

105. Counter-Plaintiff refers to and incorporates the foregoing allegations as if fully set

forth herein.

106. Counter-Plaintiff has adopted and used the MEOWINGTONS mark throughout

Florida since at least as early as 2011 in connection with headphones, music, musical

performances, and apparels, and in marketing, advertising, and sales to identify Counter-Plaintiff

as the source of high quality headphones, music, musical performances, and apparels.

107. Counter-Defendants subsequent unauthorized use of the MEOWINGTONS mark

is actually causing and continues to cause customer confusion as to the source or the origin of their

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Case 0:17-cv-60521-KMM Document 16 Entered on FLSD Docket 05/12/2017 Page 31 of 33

goods and services.

108. Upon information and belief, Counter-Defendants also use the MEOWINGTONS

mark in the domain name, www.meowingtons.com, to either intentionally divert and drive internet

traffic and potential consumers to their website and/or to appear related to or affiliated with

Counter-Plaintiff, when such is not the case.

109. Counter-Defendants are engaging in unfair acts of competition in violation of

Florida law and have infringed Counter-Plaintiffs common law rights in the MEOWINGTONS

mark.

110. Counter-Defendants unauthorized use of the MEOWINGTONS mark is causing

and will continue to cause damage to Counter-Plaintiff including, but not limited to, irreparable

harm. Counter-Plaintiff has no adequate remedy at law.

111. Counter-Plaintiff is entitled to a temporary and permanent injunction against

Counter-Defendants as well as all other remedies available including, but not limited to,

compensatory damages, disgorgement of profits, costs, and attorneys fees.

WHEREFORE, Counter-Plaintiff prays for judgment against Counter-Defendants as

follows:
1. For a temporary and permanent injunction prohibiting Counter-Defendants from:

a. using the MEOWINGTONS mark, whether alone or in combination with

other words or elements, or any other mark confusingly similar to the MEOWINGTONS mark, in

marketing and selling any of Counter-Defendants products or to otherwise create a false

association with deadmau5 or Counter-Plaintiff; and

b. registering, attempting to register, or maintaining any trademark

registration, trademark, service mark, trade name, domain name, trade designation, or other indicia

of origin or source containing the MEOWINGTONS mark, whether alone or in combination with

other words or elements, or any other mark confusingly similar to the MEOWINGTONS mark,

including through the maintenance of Registration No. 4,711,265;

2. For an accounting to be directed to determine Counter-Defendants profits from the

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Case 0:17-cv-60521-KMM Document 16 Entered on FLSD Docket 05/12/2017 Page 32 of 33

actions complained of;

3. For an award against and in favor of Counter-Plaintiff of all damages sustained by

Counter-Plaintiff and all profits realized by Counter-Defendants by reason of their infringement

of the MEOWINGTONS mark or false association therewith and cybersquatting, and all costs of

this action, attorneys fees, and treble damages as provided by 15 U.S.C. 1117;

4. For cancellation or forfeiture of the www.meowingtons.com domain name;

5. For an order cancelling United States Trademark Registration No. 4,711,265;

6. For prejudgment and post-judgment interest; and


7. For such other and further relief as the Court may deem just and equitable.

Dated: May 12, 2017 Respectfully submitted,

/s/ Joshua D. Martin


Joshua D. Martin, Esq.
Florida Bar No.: 028100
E-Mail: josh.martin@johnsonmartinlaw.com
JOHNSON & MARTIN, P.A.
500 W. Cypress Creek Rd.
Suite 430
Fort Lauderdale, Florida 33309
Telephone: (954) 790-6699
Facsimile: (954) 206-0017

Irene Y. Lee (admitted pro hac vice)


E-mail: ilee@raklaw.com
Nathan D. Meyer (admitted pro hac vice)
E-mail: nmeyer@raklaw.com
Shani Williams (admitted pro hac vice)
E-mail: swilliams@raklaw.com
RUSS, AUGUST & KABAT
12424 Wilshire Boulevard, 12th Floor
Los Angeles, CA 90025
Telephone: (310) 826-7474
Facsimile: (310) 826-6991

Attorney for Defendants and Counter-


Plaintiff Prof. Meowingtons LTD.

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Case 0:17-cv-60521-KMM Document 16 Entered on FLSD Docket 05/12/2017 Page 33 of 33

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that, on this 12th day of May 2017, I electronically filed the

foregoing document with the Clerk of the Court using CM/ECF. I also certify that the foregoing

document is being served this day on all counsel of record on the attached service list via

transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized

manner for those counsel or parties who are not authorized to receive electronically Notices of

Electronic Filing.

By: /s/ Joshua D. Martin


Joshua D. Martin

SERVICE LIST

MEOWINGTONS, LLC v. JOEL ZIMMERMAN p/k/a DEADMAU5, ET. AL.


CASE NO. 17-60521-CIV- MOORE/MCALILEY

Joshua D. Martin Michael I. Santucci


E-Mail: josh.martin@johnsonmartinlaw.com E-Mail: mis@500law.com
JOHNSON & MARTIN, P.A. SANTUCCI PRIORE, P.L.
500 W. Cypress Creek Rd. 200 South Andrews Avenue, Suite 100
Suite 430 Fort Lauderdale, FL 33301
Fort Lauderdale, Florida 33309 Telephone: (954) 351-7474
Telephone: (954) 790-6699 Facsimile: (954) 351-7475
Facsimile: (954) 206-0017

Irene Y. Lee (admitted pro hac vice)


E-mail: ilee@raklaw.com
Nathan D. Meyer (admitted pro hac vice)
E-mail: nmeyer@raklaw.com
Shani Williams (admitted pro hac vice)
E-mail: swilliams@raklaw.com
RUSS, AUGUST & KABAT
12424 Wilshire Boulevard, 12th Floor
Los Angeles, CA 90025
Telephone: (310) 826-7474
Facsimile: (310) 826-6991

33