Citadel Lawsuit

Case: 1:18-cv-02330 Document #: 1 Filed: 03/30/18 Page 1 of 16 PageID #:1
IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
Citadel Enterprise Americas LLC and )

KCG IP Holdings LLC, )
) Civil Action No. _____________
1:18-cv-2330
Plaintiffs, )
)
v. )
)
Citadel Tax Consulting, )
)
Defendant. )
COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF
Plaintiffs Citadel Enterprise Americas LLC (“Citadel”) and KCG IP Holdings LLC
(“KCG,” and collectively with Citadel, “Plaintiffs”), by and through their undersigned counsel,
bring this Complaint against Defendant for trademark infringement and unfair competition under
the Lanham Act, common law trademark infringement and unfair competition, and
cybersquatting under the Anticybersquatting Consumer Protection Act. Defendant Citadel Tax
Consulting (“CTC” or “Defendant”) registered the domain <citadel-consult.com> (the
“Offending Domain”). The Offending Domain infringes Plaintiff KCG’s registered trademarks
(for which Plaintiff Citadel is a licensee). Defendant operates a website associated with the
Offending Domain name purporting to offer a variety of financial services, including credit and
banking services, to the public.

SUMMARY OF ACTION
1. This action involves Defendants’ misappropriation and infringement of KCG’s
federally registered trademarks for investment and financial goods and services, of which Citadel
is a licensee and user in interstate commerce.
2. Specifically, this is an action for trademark infringement under the Lanham Act,
15 U.S.C. § 1114, unfair competition under the Lanham Act, 15 U.S.C. § 1125(a), trademark
infringement and unfair competition under the common law of the State of Illinois, and
cybersquatting under the Anticybersquatting Consumer Protection Act, 15 U.S.C. § 1125(d) (the
“ACPA”). As set forth more fully herein, Plaintiffs seek actual and punitive damages, statutory
damages, permanent injunctive relief, and the attorneys’ fees, costs, and expenses related to this
lawsuit.
THE PARTIES
3. Plaintiff Citadel is a Delaware limited liability company with its principal place of
business located at 131 South Dearborn Street, Chicago, Illinois 60603. Founded in 1990,
Citadel has become one of the world’s largest and most sophisticated investment institutions.
Citadel employs more than one thousand professionals worldwide and has offices around the
world, including, among others, New York, Chicago, San Francisco, London, Hong Kong, and
Dublin. Its investors include endowments, pension funds, foundations and other institutional
investors, as well as high-net-worth individuals.
4. Plaintiff KCG is a Delaware limited liability company with its principal place of
business located at 131 South Dearborn Street, Chicago, Illinois 60603.
5. On information and belief, and according to the website at the Offending Domain,
Defendant is domiciled in the country of Estonia. Attached hereto as Exhibit 1 is a printout of a
2
translation of the website at <citadel-consult.com> showing Defendant’s address at Str.
Tornimäe 5, Tornimäe Business Center, Tallinn, Estonia 10145. Defendants’ email address is
listed on Exhibit 1 as legal@citadel-consult.com.
JURISDICTION AND VENUE
6. This Court has personal jurisdiction over Defendant under 735 ILCS 5/2-
209(a)(2) and (c) because Defendant has intentionally directed tortious and intentional acts to
Plaintiffs in Illinois with knowledge that Plaintiffs are located in and operate their businesses in
Illinois. Such tortious and intentional acts by Defendant include but are not limited to
(1) advertising and promoting of goods and services using the Offending Domain in Illinois and
(2) engaging in infringing and otherwise unlawful conduct within Illinois and the United States,
as further detailed herein.
7. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and
1338(a), and 15 U.S.C. § 1121, because the action involves federal questions, including causes of
action under the Lanham Act (15 U.S.C. §§ 1114 and 1125(a)) and a cause of action under the
ACPA (15 U.S.C. § 1125(d)). This Court has subject matter jurisdiction over the remaining state
law claims pursuant to 28 U.S.C. § 1367.
8. Venue is proper in this Court pursuant to 28 U.S.C. § 1391(b)(2) because a
substantial part of the events or omissions giving rise to Plaintiffs’ claims occurred in this
judicial district.
ALLEGATIONS COMMON TO ALL COUNTS
Plaintiffs’ Trademarks and Domain Names
9. Citadel was founded in 1990 and has since grown into one of the world’s largest
and most sophisticated investment institutions. Citadel employs more than one thousand
3
professionals worldwide and has offices around the world, including, among others, in New
York, Chicago, San Francisco, London, Hong Kong, and Dublin. Its investors include
endowments, pension funds, foundations, and other institutional investors, as well as high-net-
worth individuals. Currently, Citadel manages billions of dollars in investment capital.
10. Citadel has sought to protect its investment in its brand by, among other things,
registering certain trademarks with the United States Patent and Trademark Office (“USPTO”).
KCG, Citadel’s affiliated company, has obtained federal registrations for the marks CITADEL
and Design (Reg. No. 2,812,459); CITADEL (Reg. No. 3,213,943); CITADEL TECHNOLOGY
and Design (Reg. No. 4,360,258 and Reg. No. 4,720,553); CITADEL TECHNOLOGY (Reg.
No. 4,360,189 and Reg. No. 4,506,273); and CITADEL SECURITIES, among numerous others
(collectively, the “CITADEL Trademarks”). These federal trademark registrations are
summarized in the following table:
Trademark Registration No. Services

CITADEL and Design 2,812,459 Providing investment management services,
investment consultation and advice, investment
portfolio management services, investment
brokerage services, mutual fund investment
services, and investment of funds for others.
(Int’l Class 36)
CITADEL 3,213,943 Providing investment management services,
investment consultation and advice, investment
portfolio management services, investment
brokerage services, mutual fund investment
services, and investment of funds for others.
(Int’l Class 36)
CITADEL 4,360,258 Providing temporary use of non-downloadable
TECHNOLOGY and software for use in providing financial services,
Design namely, order management and execution, risk
management, research and middle and back office
services; providing temporary use of non-
downloadable computer software for the
administration and management of funds.
(Int’l Class 42)
4
CITADEL 4,720,553 Software for use in providing financial services,

TECHNOLOGY and namely, order management and execution, risk
Design management, research and middle and back office
services; computer software for the administration
and management of funds. (Int’l Class 9)
CITADEL 4,360,189 Providing temporary use of non-downloadable
TECHNOLOGY software for use in providing financial services,
namely, order management and execution, risk
services; providing temporary use of non-
downloadable computer software for the
administration and management of funds.
(Int’l Class 42)
CITADEL 4,506,273 Software for use in providing financial services,
TECHNOLOGY namely, order management and execution, risk
services; computer software for the administration
and management of funds. (Int’l Class 9)
CITADEL 4,523,732 Financial Services, namely, institutional sales and
SECURITIES trading in the nature of the selling, purchasing and
trading of securities on behalf of institutional
clients, securities trade execution services,
principal trading in the nature of trading in
securities, multi-asset class market making
services in the nature of stock exchange quotations
and selling, purchasing, and trading of securities
otherwise than on an exchange, principal strategic
investments in the nature of investing in exchanges
for securities, derivatives and other financial
instruments, broker-dealers, and other service
providers operating in the financial services
industry (Int’l Class 36)
11. True and correct copies of the registration certificates for the CITADEL
Trademarks are collectively attached hereto as Exhibit 2.
12. Citadel has used and continues to use the CITADEL Trademarks in interstate
commerce under license from KCG in association with the goods and services listed in the
above-identified registrations.
5
13. The CITADEL Trademarks, which all incorporate the “CITADEL” element, are
highly distinctive and arbitrary trademarks used in connection with Citadel’s financial and
investment goods and services on a global scale.
14. Citadel is also the Registry Operator for the top level domain name <.citadel> (the
“Citadel TLD”).
15. Citadel has provided investment management, consultation and brokerage fund
services since 1990 and has been using the CITADEL Trademarks in connection with such
services since at least 1994. Citadel spends substantial sums promoting its CITADEL brand and
incorporates the CITADEL Trademarks into its website at <citadel.com>, client mailings, and
investor materials, all of which prominently associate the CITADEL Trademarks with Citadel’s
financial and investment goods and services. Plaintiffs have invested heavily in the CITADEL
Trademarks, including expending resources on enforcement actions, as well as investment in
building a reputation for high-quality financial and investment goods and services. As a result,
the CITADEL Trademarks are valuable assets of Plaintiffs and represent Plaintiffs’ substantial
goodwill and good reputation.
16. In addition to their rights in the CITADEL Trademarks based on federal
registration, Plaintiffs own significant common law rights in and to the CITADEL Trademarks
based on many years of use of those trademarks throughout the United States, in association with
Plaintiffs’ financial and investment goods and services.
17. As a result of Citadel’s substantial expenditures over many years in promoting the
goods and services offered under the CITADEL Trademarks, members of the trade and public in
the United States, including members of the U.S. financial and investment markets, recognize the
CITADEL Trademarks represent Citadel and its financial and investment goods and services.
6
18. Defendant registered the Offending Domain on April 2, 2015. At that time, the
website at the Offending Domain appeared to be a default page from the domain host.
19. In May 2015, Plaintiffs learned that the Offending Domain was being used in
conjunction with the website for a business calling itself Citadel Tax Consulting.
20. Due to the vague nature of the website in May 2015, Plaintiffs placed the
Offending Domain on a quarterly watch to monitor changes in use or ownership of the Offending
Domain.
21. After further investigation into CTC and its business, and due to what appeared to
be increased activity on its website directed at commerce within the United States, Plaintiffs
contacted Defendant on July 21, 2017.
22. On July 25, 2017, Defendant responded to Plaintiffs’ initial contact and asserted
that it owned trademark rights in CITADEL in the Ukraine, and that it limited its business to the
Ukraine alone. Notwithstanding this assertion, Defendant also stated “The jurisdictions listed on
our website and referred to in your letter, namely the US, UK, Panama, Hong Kong, etc. do not
imply that our company conducts business activities in those countries. We act in the capacity of
clients of the professional service providers located in those jurisdictions.”
23. On that same day, counsel for Plaintiffs requested clarification of the statement
“We act in the capacity of clients of the professional service providers located in those
jurisdictions.”
24. On July 26, 2017, Defendant responded:
The reason we are advertising several jurisdictions on our website is that we can
help our Ukrainian clients incorporate companies worldwide. This is because we
have direct contacts with service providers located in those jurisdictions, for
whom we serve as clients of record. In turn, for our Ukrainian clients, we act in
the capacity of professional intermediaries between them and the actual service
provider located overseas.
7
25. Defendant’s foregoing statements confirm that Defendant gathers work from
within the Ukraine and then performs services by acting as an intermediary for its clients outside
of the Ukraine, including in the U.S. and other jurisdictions where Plaintiff has trademark rights.
26. Plaintiffs have not been contacted by Defendant since July 26, 2017, and the
infringing content remains at the Offending Domain.
Defendants’ Bad-Faith Use of Plaintiffs’

CITADEL Trademarks and the Offending Domain
27. Defendant registered the Offending Domain, <citadel-consult.com>, on April 2,
2015. In approximately May 2015, the Offending Domain began to be used in conjunction with
a website for the purported financial services business, Citadel Tax Consulting. A true and
correct copy of translated portions of the website at the Offending Domain ranging from
September 2015 through June 2017 are attached as Exhibit 3. As shown in Exhibits 1 and 3, the
Offending Domain contains the identical “citadel” element of the CITADEL Trademarks,
combined with the generic, industry-relevant term “consult” and the generic top-level domain
“.com”.
28. Upon information and belief, without any intellectual property rights in any mark
containing the element “citadel” outside of the Ukraine, Defendants used the CITADEL
Trademarks in the Offending Domain with the bad-faith intent to cause consumer confusion and
to profit from the goodwill and value associated with the CITADEL Trademarks generally, and
especially within the world of financial services.
29. Defendants’ conduct as described herein has caused and is likely to cause
confusion or mistake or both, and to deceive consumers by leading them to falsely believe that
the Offending Domain (and any goods and services offered on a past, present, or future website
8
at the Offending Domain) is affiliated with, related to, sponsored by or connected with Plaintiffs.
Defendants’ conduct described herein is also likely to cause confusion regarding the existence of
an affiliation or connection between the Offending Domain and Plaintiffs. Upon information and
belief, the registration and use of the Offending Domain was in bad faith so as to confuse
consumers as to the sponsorship, ownership, affiliation, or connection of Defendant’s business
with that of Plaintiffs.
30. Defendant used the exact CITADEL Trademarks within the Offending Domain
while having at least constructive notice, and, upon information and belief, actual knowledge of
Plaintiffs’ rights in the CITADEL Trademarks.
31. Defendant has had constructive notice of Plaintiffs’ rights in a CITADEL
Trademark since at least February 10, 2004, based on KCG’s federal registration of the
CITADEL and Design mark. Further, all other registrations of the CITADEL Trademarks, and
the constructive notice that each provides to Defendants, long predate the first known registration
of the Offending Domain.
32. Unless Defendant is enjoined from further infringement of the CITADEL
Trademarks and use of the Offending Domain, Defendant will continue to trade on the goodwill
that Plaintiffs have developed in the CITADEL Trademarks, thereby causing irreparable harm,
damage and injury to Plaintiffs for which they have no adequate remedy at law.
COUNT I
Trademark Infringement Under the Lanham Act
(15 U.S.C. § 1114)
33. Plaintiffs reallege and incorporate by reference paragraphs 1‒32 as if fully set
forth herein.
34. This is a claim for infringement of the CITADEL Trademarks.
9
35. KCG is the owner of all right, title, and interest in and to the CITADEL
Trademarks, of which Citadel is a licensee.
36. Defendant’s use in commerce of the CITADEL Trademarks in the Offending
Domain, as described herein, constitutes a reproduction, copying, and colorable imitation of the
registered CITADEL Trademarks, in connection with the offering for sale and advertising of
Defendants’ services, in a manner that is likely to cause confusion or mistake, or is likely to
deceive consumers.
37. Defendants’ conduct as described herein is likely to cause confusion or mistake,
or is likely to deceive the purchasing public and others, whereby purchasers and others would be
led to believe, incorrectly, that Defendants are affiliated with, related to, sponsored by, or
connected with Plaintiffs in violation of 15 U.S.C. § 1114(1).
38. Despite their actual and constructive knowledge of KCG’s ownership of the
CITADEL Trademarks and Citadel’s prior use of the CITADEL Trademarks, Defendant has
willfully adopted and used the confusingly similar designations without Plaintiffs’ authorization
or consent.
39. Defendant’s conduct has caused and, unless restrained and enjoined by this Court,
will continue to cause irreparable harm, damage, and injury to Plaintiffs.
40. Plaintiffs have no adequate remedy at law.
COUNT II
Unfair Competition Under the Lanham Act
(15 U.S.C. § 1125(a))
forth herein.
42. Plaintiffs have spent substantial sums in promotion and generated substantial
revenues in association with their investment services provided under the CITADEL
10
Trademarks. The distinctive CITADEL Trademarks are impressed in the minds of members of
the trade, press, and public as identifying Plaintiffs’ financial and investment goods and services,
and indicate the source of origin of such services provided in association with the CITADEL
Trademarks as emanating from Plaintiffs. Plaintiffs have built a large and valuable business in
the use of the CITADEL Trademarks, and Plaintiffs value greatly the reputation and goodwill in
those marks.
43. Defendant’s conduct as described herein constitutes use of a false designation of
origin, or a false or misleading description or representation of fact on or in connection with their
services that is likely to cause confusion, mistake, or deception as to the affiliation, connection,
or association of Defendant with Plaintiffs, or as to the origin, sponsorship, or approval of
Defendant’s services in violation of Section 43(a) of the Lanham Act, 15 U.S.C. § 1125(a).
Defendant’s conduct as described herein also constitutes an attempt to trade on the goodwill that
Plaintiffs have developed in the CITADEL Trademarks, all to the damage of Plaintiffs.
44. Defendant’s use in commerce of designations that are substantially identical to the
CITADEL Trademarks, despite having constructive notice of Plaintiffs’ prior rights in and to the
CITADEL Trademarks, constitutes intentional conduct by Defendant to make false designations
of origin and false descriptions about their services and commercial activities.
45. Defendant has caused and, unless restrained and enjoined by this Court, will
continue to cause irreparable harm, damage, and injury to Plaintiffs.
COUNT III
Trademark Infringement Under Common Law
forth herein.
11
48. Defendant’s conduct complained of herein has caused and is likely to cause
confusion, mistake, or deception as to the affiliation, connection, or association of Defendant
with Plaintiffs, and as to the origin, sponsorship, or approval of Defendant’s services, in violation
of the common law of the State of Illinois.
COUNT IV
Unfair Competition Under Common Law
forth herein.
52. Defendant’s conduct complained of herein constitutes misappropriation of
Plaintiffs’ valuable property rights and trades on the goodwill symbolized by the distinctive
CITADEL Trademarks, and is likely to confuse and deceive members of the purchasing public.
53. By virtue of such conduct, Defendant has engaged in unfair competition in
violation of the common law of the State of Illinois.
COUNT V
Cybersquatting Under the Anticybersquatting Consumer Protection Act
(15 U.S.C. § 1125(d)(1))
forth herein.
12
57. The Offending Domain is confusingly similar to Plaintiffs’ CITADEL
Trademarks.
58. The CITADEL Trademarks were distinctive at the time Defendant registered the
Offending Domain.
59. Defendant registered, trafficked in, or used the Offending Domain with a bad-
faith intent to profit from Plaintiffs’ CITADEL Trademarks.
60. Defendant’s activities as alleged herein violate the federal Anticybersquatting
Consumer Protection Act, 15 U.S.C. § 1125(d).
61. As a result of Defendant’s willful and intentional actions, Plaintiffs have been
damaged in an amount to be proven at trial.
62. Defendant’s registration, trafficking in, or use of the Offending Domain has
caused and, unless restrained and enjoined by this Court, will continue to cause irreparable harm,
damage, and injury to Plaintiffs.
RELIEF REQUESTED
WHEREFORE, Plaintiffs Citadel Enterprise Americas LLC and KCG IP Holdings LLC
respectfully request that this Court enter an order for Plaintiffs and against Defendant, granting
Plaintiffs the following relief:
(a) A permanent injunction restraining and enjoining Defendant, its principals,
officers, directors, agents, servants, and employees, as well as any successors or assigns of
Defendant and all those acting in privity, concert, or participation with Defendant, from:
i. imitating, copying, duplicating, or otherwise making any use of the CITADEL

Trademarks or any mark confusingly similar to the CITADEL Trademarks;
13
ii. manufacturing, producing, distributing, circulating, selling, or otherwise

disposing of any product or material that bears any copy or colorable imitation
of the CITADEL Trademarks;
iii. using any false designation of origin or false description that can or is likely to
lead the trade or public, or individual members thereof, to mistakenly believe
that any product or service advertised, promoted, offered, or sold by
Defendant is sponsored, endorsed, connected with, approved, or authorized by
Plaintiffs;
iv. causing likelihood of confusion or injury to Plaintiffs’ business reputation and

to the distinctiveness of the CITADEL Trademarks by unauthorized use of the
same;
v. operating any website associated with, using, linking to, transferring, selling,
exercising control over, or otherwise owning the Offending Domain or any
other domain name or trademark or service mark that incorporates, in whole
or in part, any of the CITADEL Trademarks or any marks confusingly similar
thereto;
vi. permitting access in the United States to any website operated by Defendants
that displays or uses Citadel’s name or the CITADEL Trademarks;
vii. engaging in any other activity constituting unfair competition or infringement

of the CITADEL Trademarks or Plaintiffs’ rights therein, or to use, or to
exploit the same; or
viii. assisting, aiding, or abetting another person or business entity in engaging in

or performing any of the activities enumerated in subparagraphs (i) through
(vii) above.
(b) An injunction requiring Defendant to remove any social media postings, videos,
or other media linking to the Offending Domain or using any CITADEL formative marks;
(c) A finding that Defendant’s actions constitute trademark infringement in violation
of 15 U.S.C. § 1114(1);
(d) A finding that Defendant’s actions constitute false designation of origin in
violation of 15 U.S.C. § 1125(a);
(e) A finding that Defendant’s actions constitute trademark infringement in violation
of the common law of the State of Illinois;
14
(f) A finding that Defendant’s actions constitute unfair competition in violation of
the common law of the State of Illinois;
(g) A finding that Defendant’s actions constitute illegal cybersquatting in violation of
15 U.S.C. § 1125(d)(1)(A);
(h) A finding that Defendant’s violations of Plaintiffs’ trademark rights, under
15 U.S.C. §§ 1114 and 1125(a) and (d), are willful as a result of the actions complained of
herein, and that this is an exceptional case pursuant to 15 U.S.C. § 1117(a);
(i) An award to Plaintiffs of monetary damages in an amount to be fixed by the Court
in its discretion as just, including all of Defendant’s profits or gains of any kind resulting from
the actions complained of herein, said amount to be trebled, and exemplary damages in view of
the intentional nature of the acts complained of herein, pursuant to 15 U.S.C. § 1117(a) and (b),
and the common law of the State of Illinois;
(j) An award to Plaintiffs of their attorneys’ fees and their costs and expenses of
litigation, pursuant to 15 U.S.C. § 1117(a) and (b);
(k) An award to Plaintiffs of statutory damages pursuant to 15 U.S.C. § 1117(d), in
the amount of $100,000 per domain name, for Defendant’s willful violation of 15 U.S.C.
§ 1125(d)(1)(A);
(l) An order requiring the domain name registry for the Offending Domain to transfer
the Offending Domain from the current registrar of record to a registrar of Plaintiffs’ selection,
which shall then register such domain names in Plaintiffs’ name;
(m) An order requiring the domain name registry for the Offending Domain, upon
notice by Plaintiffs, to transfer any future domain names registered by Defendants that consist, in
whole or in part, of any of the CITADEL Trademarks or any marks confusingly similar thereto,
15
from the current registrar of record to a registrar of Plaintiffs’ selection, which shall then register
such domain names in Plaintiff’s name;
(n) An order requiring Defendant and any principals, agents, servants, employees,
successors, and assigns of and all those in privity or concert with Defendant who receive actual
notice of said order, to deliver up for destruction all infringing products and all promotional,
advertising, and any other printed materials and items of any kind bearing (i) the designations
“Citadel” or “Citadel Tax Consulting” or (ii) any other mark or design that is confusingly similar
to the CITADEL Trademarks; and,
(o) Such other and further relief as the Court may deem just, proper, and equitable
under the circumstances.
Jury Demand
Plaintiffs demand a trial by jury on all issues so triable.
Respectfully submitted,
CITADEL ENTERPRISE AMERICAS

LLC and KCG IP HOLDINGS LLC
Date: March 30, 2018 /s/ Daniel D. Rubinstein

Daniel D. Rubinstein
drubinstein@winston.com
Steven Grimes
SGrimes@winston.com
Paul D. McGrady, Jr.
pmcgrady@winston.com
Liz Brodzinski
ebrodzinski@winston.com
WINSTON & STRAWN LLP
35 West Wacker Drive
Chicago, Illinois 60601
Telephone: (312) 558-5600
Facsimile: (312) 558-5700
16

Citadel Lawsuit

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Case: 1:18-cv-02330 Document #: 1 Filed: 03/30/18 Page 1 of 16 PageID #:1

IN THE UNITED STATES DISTRICT COURT

Citadel Enterprise Americas LLC and )

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF

Consulting (“CTC” or “Defendant”) registered the domain <citadel-consult.com> (the

banking services, to the public.

1. This action involves Defendants’ misappropriation and infringement of KCG’s

is a licensee and user in interstate commerce.

investors, as well as high-net-worth individuals.

business located at 131 South Dearborn Street, Chicago, Illinois 60603.

Defendant is domiciled in the country of Estonia. Attached hereto as Exhibit 1 is a printout of a

translation of the website at <citadel-consult.com> showing Defendant’s address at Str.

listed on Exhibit 1 as legal@citadel-consult.com.

JURISDICTION AND VENUE

as further detailed herein.

law claims pursuant to 28 U.S.C. § 1367.

8. Venue is proper in this Court pursuant to 28 U.S.C. § 1391(b)(2) because a

ALLEGATIONS COMMON TO ALL COUNTS

Plaintiffs’ Trademarks and Domain Names

worth individuals. Currently, Citadel manages billions of dollars in investment capital.

(collectively, the “CITADEL Trademarks”). These federal trademark registrations are

summarized in the following table:

Trademark Registration No. Services

CITADEL 4,720,553 Software for use in providing financial services,

Trademarks are collectively attached hereto as Exhibit 2.

investment goods and services on a global scale.

Trademarks, including expending resources on enforcement actions, as well as investment in

goodwill and good reputation.

16. In addition to their rights in the CITADEL Trademarks based on federal

Plaintiffs’ financial and investment goods and services.

contacted Defendant on July 21, 2017.

clients of the professional service providers located in those jurisdictions.”

24. On July 26, 2017, Defendant responded:

infringing content remains at the Offending Domain.

Defendants’ Bad-Faith Use of Plaintiffs’

27. Defendant registered the Offending Domain, <citadel-consult.com>, on April 2,

especially within the world of financial services.

consumers as to the sponsorship, ownership, affiliation, or connection of Defendant’s business

with that of Plaintiffs.

Plaintiffs’ rights in the CITADEL Trademarks.

31. Defendant has had constructive notice of Plaintiffs’ rights in a CITADEL

of the Offending Domain.

32. Unless Defendant is enjoined from further infringement of the CITADEL

34. This is a claim for infringement of the CITADEL Trademarks.

Trademarks, of which Citadel is a licensee.

36. Defendant’s use in commerce of the CITADEL Trademarks in the Offending

Defendants’ services, in a manner that is likely to cause confusion or mistake, or is likely to

37. Defendants’ conduct as described herein is likely to cause confusion or mistake,

connected with Plaintiffs in violation of 15 U.S.C. § 1114(1).

will continue to cause irreparable harm, damage, and injury to Plaintiffs.

40. Plaintiffs have no adequate remedy at law.

43. Defendant’s conduct as described herein constitutes use of a false designation of

origin, or a false or misleading description or representation of fact on or in connection with their

or association of Defendant with Plaintiffs, or as to the origin, sponsorship, or approval of

CITADEL Trademarks, constitutes intentional conduct by Defendant to make false designations

continue to cause irreparable harm, damage, and injury to Plaintiffs.

46. Plaintiffs have no adequate remedy at law.

confusion, mistake, or deception as to the affiliation, connection, or association of Defendant

of the common law of the State of Illinois.

will continue to cause irreparable harm, damage, and injury to Plaintiffs.

50. Plaintiffs have no adequate remedy at law.

52. Defendant’s conduct complained of herein constitutes misappropriation of

53. By virtue of such conduct, Defendant has engaged in unfair competition in