Case: 3:11-cv-00586

Document

Filed: 08/19/11

Page

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UNITED STATED DISTRICT COURT WESTERN DISTRICT OF WISCONSIN

STATE BAR OF

WISCONSIN,

Plaintiff,
v.

Civil Action No. 11-CV-586 Jury Trial Demanded

LEXISNEXIS (a division of Reed

Elsevier, Inc.),

Defendant.

COMPLAINT FOR TRADEMARK INFRINGEMENT

GODFREY &

KAHN, S.C.

James D. Peterson Jennifer L. Gregor One East Main Street, Suite 500 Post Office Box 2719 Madison, WI 53701-2719 Phone: 608-257-3911 Fax: 608-257-0609 Email: jpeterson@gklaw.com

jgregor@gklaw.com

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The

plaintiff,

State Bar of Wisconsin,

by and through its attorneys, Godfrey & Kahn,

S.C., brings the following Complaint against the defendant, LexisNexis:

INTRODUCTION

This is below:

an

action for

infringement of the

State Bar's Pillar Icon trademark, shown

V.
The State Bar

adopted the Pillar Icon after a careful screening for conflicting marks,

and it

applied for and received federal registration of the

in connection with all its

Pillar Icon. The State Bar uses the Pillar Icon

services, which are provided to lawyers and members of the public for

the purnose of improving the justice system and

legal profession,

and to facilitate the

delivery of

legal

services and information to the

as

public.

A copy of the certificate of registration for the Pillar

Icon is attached 2.

Exhibit A.

LexisNexis has

recently adopted a mark strikingly similar to the

Pillar Icon,

shown below:

e
LexisNexis
uses

this mark in connection with its

Lawyers.com website,

which

provides lawyer

finding tools and legal resources to the public.

LexisNexis has not

sought or received

registration of its infringing pillar mark. Upon information and belief, LexisNexis conducted no
trademark

screening before adopting its infringing pillar mark.

Consumer confusion is inevitable. If LexisNexis'

infringement continues, thinkinginconectlythat

members of the

public and the legal profession will be

confused into

Case: 3:11-cv-00586

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there is

some

affiliation

or

relationship between the Lawyers.com services

own

and the services

offered by the State Bar. To protect its

investment in the Pillar Icon, and to protect the

State Bar seeks

public and the legal profession from this inevitable confusion, the
and

declaratory

injunctive relief preventing LexisNexis

from the continued

use

of its

infringing pillar mark.

THE PARTIES

4.

The plaintiff State Bar of Wisconsin is

Wisconsin

professional association,
Court. The State

constituted by and operating under the

Bars offices
are

auspices

of the Wisconsin

Supreme

located at 5302

Eastpark Blvd., Madison, Wisconsin 53718. provides legal

and public records information
more

5.

The defendant LexisNexis

databases, serving customers in more than

worldwide. The

100 countries with

are

than 15, 000

employees

principal offices

of LexisNexis

located at 9443

Springboro Pike,

Miamisburg,
6.

Ohio 45342.

Upon information and belief, LexisNexis

Delaware

is

division of Reed The

Elsevier, Inc.,

which is

corporation, registered to do business in Wisconsin.

are

principal offices

of Reed Elsevier, Inc.

located at 2 Newton Place, Suite 350, Newton, Massachusetts 02458.

JURISDICTION AND VENUE

7.

This matter arises under the laws of the United States,

specifically

15 U.S.C.

1114 and 1125. This Court therefore has

original jurisdiction over this

action pursuant to 28

U.S.C. U. S. C. 8.

1331 and 1338. The Court has the 2201 and 2202.

authority to grant declaratory relief pursuant to 28

This Court has

supplemental jurisdiction over the

so

State Bars state law claim

pursuant to 28 U.S.C. part of the

same case or

1367 because that claim is

related to the federal claims that

they form

controversy.

Case: 3:11-cv-00586

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11

9.

The Court has

personal jurisdiction over LexisNexis pursuant to Wis.

Stat.

801.05(1) because LexisNexis is engaged in substantial

and judicial
over

and not isolated activities in this state

district, including maintaining offices and employees here. Personal jurisdiction

LexisNexis is also proper under Wis. Stat.

801.05(4) because

the State Bar has suffered

on

injury within this

state and judicial district while LexisNexis has carried

solicitation and

service activities here. This Courts exercise of personal jurisdiction with the Due Process Clause of the United States Constitution.
10.

over

LexisNexis comports

Venue is proper in this judicial district pursuant to 28 U.S.C.

1391(b) because
a

the defendant LexisNexis is deemed to reside in this judicial

district, and because

substantial

part of the

events

giving rise to the

State Bars claims occurred in this judicial district.

FACTUAL BACKGROUND The State Bar and Its Trademarks 11.

The State Bar began

as a

voluntary association of Wisconsin lawyers

Supreme

in 1878. It

currently operates under the auspices

of the Wisconsin

Court. The State Bars

24, 000

members include all attorneys licensed to practice law in Wisconsin. The State Bars

membership includes 7, 600 non-resident attorneys located throughout the United States and beyond.
12.

The mission of the State Bar,

as

established in Wisconsin

Supreme

Court Rule

10.02(2),

includes

aiding the

courts in the administration of justice,

fostering high ideals

and

skills within the citizens

profession, representing the professional interests

of lawyers, and

serving

by facilitating the delivery of legal services

and providing education and informed

discussion of the law.

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13.

The activities of the State Bar

State Bars

are

supported,

in part,

by dues paid by

its members.

The

majority of the

budget, however, is provided by sales

of a broad range of

products and services, including its highly regarded books,

14.

seminars and publications.

The State Bar also services is the

provides a range of services to the public. Among the most LegalExplorer website,
available at

significant of these
The State Bars and other
as

www.legalexplorer.com.
information
on

LegalExplorer website provides lawyer-finding tools,

for the

legal topics

legal resources

public.

A copy of the home page of LegalExplorer is attached

Exhibit B.
15.

The State Bar maintains

portfolio

of trademarks that it uses to promote and

distinguish its goods and services.

The State Bars

currently used and federally registered or

registration-pending marks include:

STATE BAR OF WISCONSIN U. S. Registration No. 4005002 PINNACLE U.S. Registration No. 4013233
PILLAR ICON

U.S.

Registration No.

3945835

REACH NEW HEIGHTS IN YOUR PRACTICE U.S. Registration No. 3952559 YOUR PRACTICE. OUR PURPOSE. U.S. Registration No. 4013234 LEADERS IN THE LAW. ADVOCATES FOR JUSTICE. U. S. Registration approved; issue of certificate pending WISBAR U.S. Registration No. 3741623 WISCONSIN LAWYERS EXPERT ADVISERS. SERVING YOU. U. S. Registration No. 2764231

Case: 3:11-cv-00586

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16.

The Pillar Icon, at issue in this case,

was

selected and

adopted by the

State Bar

as

part of a the creation of a new brand image intended to facilitate the nationwide sales and
distribution of the State Bars conducted
17.
a

goods and services.

Before

adopting the Pillar Icon, the

State Bar

search for potentially The State Bar

2010
on an

conflicting marks.
of the Pillar Icon That
on

applied for federal trademark registration

use

February 18,
was

intent to

basis pursuant to 15 U. S.C.

1051(b).

application

duly examined and approved by the United States

18. 19.

Trademark Office.
as

The State Bar began

use

of the Pillar Icon at least

early as

June

1, 2010.

The State Bar submitted to the United States Trademark Office of the Pillar Icon
on

specimens

demonstrating its use

Office issued the
20.

February 7,
2011.

2011. The United States Trademark

registration on April 12,

The State Bars federal

registration of the Pillar Icon is prima facie evidence of ownership of it, pursuant to
15 U.S.C.

the

validity of the mark and the

State Bars

1115(a). right

The

registration is also prima facie evidence that the

State Bar has the nationwide exclusive

to use the Pillar Icon in connection with the

goods and services specified in the registration,

2010.

effective

as

of the date of its

application, February 18,

21.

The State Bar also has trademark rights under Wisconsin

law, dating from the

1, 2010.

State Bars first use of the Pillar

Icon, which was

at least

as

early as

June

LexisNexis and its 22.

Infringing Pillar Mark

of publications,

The defendant LexisNexis

provides databases

legal documents legal research

and public records. It is well known in the

legal profession for the

Lexis on-line

service, used by attorneys throughout the United States and the world.

Case: 3:11-cv-00586

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23.

LexisNexis also

owns

and operates

Lawyers.com,

website that provides

information about attached

as

lawyers

and the law to the

public.

A copy of the home page of Lawyers.com is

Exhibit C.

24.

Lawyers.com provides lawyer-finding tools which allow users to find lawyers by

the

geographic region or by area of law. Upon information and belief,

of Lawyers.com
are

lawyer-finding tools are

based

on

the data in the Martindale-Hubbell

directory, which like

LexisNexis, is also part of Reed Elsevier.

25.

Lawyers.com also provides legal research resources, legal

information by

topic,

and do it
26.

yourself legal forms.

LexisNexis has

only recently began use

of its

infringing pillar mark on

State

Lawyers.com.
Bar

LexisNexis first use of the

infringing pillar mark occurred well after the

State Bar began

applied for registration of the Pillar Icon, well after the

using the Pillar Icon, registration for

and upon information and belief, well after the U.S. Trademark Office issued the the Pillar Icon.
27.

Upon information and belief, LexisNexis conducted no

search for

potentially

conflicting marks before it adopted its infringing pillar mark.

Confusion Caused 28.

by LexisNexis Infringement

The services

provide by LexisNexis through Lawyers.com are highly related to

State Bar. Both LexisNexis and the State Bar direct many of their
some

the services

provide by the

services to attorneys.

Indeed,

of the services

are

identical to and

competitive with those

offered by the State Bar.

29.

The services

provided at Lawyers.com substantially overlap the

services

provided

by the

State Bar

through LegalExplorer.

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30.

The

lawyer-finding tools provided through Lawyers.com are highly related and

Service

potentially in competition with the Lawyer Referral and Information

State Bar
as a

provided by the

service to its members and the The

public. through Lawyers.com are similar to,

State Bar.

31.

legal research resources

available

and

competitive with, the legal research resources provided by the

32.

The information

on

legal topics

available

through Lawyers.com is highly related,

State Bar.

and may be
33.

competitive with, the legal publications of the

LexisNexis
use

of its

infringing pillar mark on Lawyers.com will inevitably

or

cause consumer

confusion

as

to the source, affiliation

sponsorship of the

services

provided

though Lawyers.com.
34.

The

Lawyers.com article on trademarks (available

at

http://intellectual-

property.lawyers.com/trademarks/Trademarks.html) explains the damage caused by the

unauthorized
use

of confusingly similar trademarks:

Trademarks also protect the investment the maker of a product has in the product. Part of this is goodwill. It's unfair for a rival or competing business to play off of the popularity of a particular product or service by using the same or similar mark. This rival or competitor could obtain business based on the quality or years you've spent building your brand name. What's more, your fine product's reputation could be damaged if consumers purchase an inferior product believing it to be yours because of a similar trademark. That's unfair, and trademark law makes it illegal.
35.
use

The State Bar, its

members, and the public have been damaged by LexisNexis

and the State Bar will be

of its

infringing pillar mark,

irreparably harmed unless LexisNexis

infringement is enjoined.
FIRST CAUSE OF ACTION Trademark Infringement 15 U.S.C. 1114 36.

Paragraphs

through 35

of this

Complaint are incorporated here by reference.

Case: 3:11-cv-00586

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37. 38.

The Pillar Icon is LexisNexis

uses

valid, federally registered trademark owned by the

commerce a

State Bar.

in

reproduction, counterfeit,

copy,

or

colorable

imitation of the Pillar Icon

39.

LexisNexis

uses

the

reproduction, counterfeit,

copy,

or

colorable imitation of the

or

Pillar Icon in connection with the

goods and services that are the same

closely related to those

specified in the
40.

State Bars

registration.
use

LexisNexis

of its

reproduction, counterfeit,
to cause

copy,

or

colorable imitation of

the Pillar Icon is

41.

likely to cause confusion,

use

mistake,

or

to deceive.

LexisNexis

of its

reproduction, counterfeit,

copy,

or

colorable imitation of the

Pillar Icon is without the State Bars consent.

42.

LexisNexis
cause

use

of its

reproduction, counterfeit,

copy,

or

colorable imitation of the

Pillar Icon will

43.

damage

and

irreparable harm to the

State Bar.

LexisNexis has violated 15 U.S.C.

1114, entitling the State Bar to judgment so

declaring and an injunction prohibiting LexisNexis from using its infringing pillar mark.
SECOND CAUSE OF ACTION False Designation of Origin 15 U.S.C. 1125 44. 45.

Paragraphs
LexisNexis
to deceive
as

through 43
in

of this

Complaint are incorporated here by reference. symbol that is likely to

cause

uses

commerce a

confusion,

to cause

mistake,

or

to the

origin, sponsorship or approval of its

services. of the

46.

The State Bar is

likely to be damaged by LexisNexis use

symbol and the

confusion that results.

47.

LexisNexis has violated 15 U.S.C.

1125, entitling the State Bar to judgment so

declaring and an injunction prohibiting LexisNexis from using its infringing pillar mark.

Case: 3:11-cv-00586

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THIRD CAUSE OF ACTION

Common Law Trademark 48. 49.

Infringement

Paragraphs

through 47

of this

Complaint are incorporated here by reference. goods and services provided

The Pillar Icon is distinctive trademark that identifies

by the

State Bar. 50.

LexisNexis

uses

in connection with its

own

goods and services a pillar mark that

is

striking similar to the

51.

State Bars Pillar Icon.

use

LexisNexis
as

of its

pillar mark is likely to cause confusion,

services.

to cause

mistake,

or

to deceive

to the

origin, sponsorship or approval of its

use

52. State Bar. 53.

LexisNexis

of its

pillar mark will cause damage and irreparable harm to the

LexisNexis has violated the State Bars

State Bar to judgment
so

rights under the common law of

Wisconsin, entitling the

LexisNexis from

declaring and an injunction prohibiting

using its infringing pillar mark.

WHEREFORE, Plaintiff State Bar of Wisconsin requests the following:

1. 2.
A declaration that LexisNexis An

pillar mark infringes the rights

of the State Bar;

injunction prohibiting LexisNexis from any further use confusingly similar to the Pillar Icon;

of its

infringing pillar

mark,

or

any other mark that is

3. 4.

Judgment against LexisNexis in favor of the Judgment against LexisNexis in favor of the

State Bar for the costs of this State Bar for the State Bars

action;

reasonable actual attorney fees pursuant to 15 U.S.C.

1117(a); and,

10

Case: 3:11-cv-00586

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5.

Any further relief to the

State Bar as this Court may deem

a

appropriate.

The State Bar of Wisconsin demands

jury on all issues

so

triable.

Dated:

August 19,

2011.

Respectfully submitted,

By:

s/James D. Peterson James D. Peterson Jennifer L. Gregor GODFREY & KAHN, S.C. One East Main Street, Suite 500 Post Office Box 2719 Madison, WI 53701-2719 Phone: 608-257-3911 Fax: 608-257-0609 Email: jpeterson@gklaw.com

jgregor@gklaw.com
A ttorneysfor Plaintiff, State Bar
6716518_2

of Wisconsin

11

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EXHIBIT A

Case: 3:11-cv-00586

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raint

:s)tate5 of

liniteb *tato Patent anb Trabetnarh Office

ame,

jIU
Reg. No. 3,945, 835 Registered Apr. 12,
Int. Cls.:
STATE BAR OF WISCONSIN PO BOX 7158

(WISCONSIN NON-PROFIT ASSOCIATION)

2011

MADISON, WI 53718
FOR: PUBLICATIONS AND PRACTICE MATERIALS, NAMELY, WOKS, MAGAZINES, NEWSLETTERS, PAMPHLETS, FILL-1N LEGAL FORMS, AND COURSE MATERIALS IN THE FIELD OF LAW, IN CLASS 16 (U.S. CLS. 2, 5, 22, 23, 29, 37, 38 AND 50).

16, 35,

and 41

TRADEMARK
FIRST USE

6-1-2010;

IN COMMERCE 6-1-2010.

SERVICE MARK
FOR: ASSOCIATION

PRINCIPAL REGISTER

ANT) IMPROVING THE DELIVERY OF LEGAL 101 AND

SERVICES, NAMELY, PROMOTING THE INTEREST OF LAWYERS SERVICES, IN CLASS 35 (IJ.S. CLS. 100,

102).
6-1-2010; IN COMMERCE 6-1-2010.

FIRST USE

FOR: EDUCATIONAL SERVICES AND PROGRAMS FOR LAWYERS, NAIV1ELY, PROVIDING CONTINUING LEGAL EDUCATION

COURSES, IN CLASS 41 (U.S. CLS. 100, 101AND 107).

FIRST USE 6-1-2010; IN COMMERCE 6-1-2010.

WE MARK CONSISTS OF A PORTION OF A COLUMN FORMED OF THREE VERTICAL

LINES WITH A CAPITAL FORMED OF TWO HORIZONTAL LINES TOGETHER FORMING A STYLIZED "W" REVERSED FROMA CIRCULAR

BACKGROUND, ALL SURROUNDED

(n
1+1.14NT FA"
oF

BY AN OUTER CIRCLE. SN 77-939.045, FILED 2-18-2010. KEVIN DINALID, EXAMINING ATTORNEY

pod;

.5-7.

Director of die United Stales Potent .d Oodemork Office

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EXHIBIT B

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2JS 44 (Rev. 12/07)

Case: 3:11-cv-00586 Document #: 1-4

Filed: CIVIL COVER SHEET 08/19/11 Page 1 of 1

The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.)

I. (a) PLAINTIFFS
STATE BAR OF WISCONSIN

DEFENDANTS
LEXISNEXIS (a division of Reed Elsevier, Inc.) Dane
County of Residence of First Listed Defendant
(IN U.S. PLAINTIFF CASES ONLY) NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF THE LAND INVOLVED.

(b) County of Residence of First Listed Plaintiff

(EXCEPT IN U.S. PLAINTIFF CASES)

James D. Peterson, Jennifer L. Gregor of Godfrey & Kahn, S.C., One East Main Street, PO Box 2719, Madison, WI 53701-2719, Tel. 608-257-3911

(c) Attorneys (Firm Name, Address, and Telephone Number)

Attorneys (If Known)

II. BASIS OF JURISDICTION

u 1
U.S. Government Plaintiff

(Place an X in One Box Only)

III. CITIZENSHIP OF PRINCIPAL PARTIES(Place an X in One Box for Plaintiff

(For Diversity Cases Only) PTF u 1 Citizen of This State Citizen of Another State DEF u 1 and One Box for Defendant) PTF DEF Incorporated or Principal Place u 4 u 4 of Business In This State Incorporated and Principal Place of Business In Another State Foreign Nation

u 3 Federal Question (U.S. Government Not a Party) u 4 Diversity

(Indicate Citizenship of Parties in Item III)

u 2

U.S. Government Defendant

u 2 u 3

u u

u 5 u 6

u 5 u 6

Citizen or Subject of a Foreign Country

IV. NATURE OF SUIT

CONTRACT

(Place an X in One Box Only) TORTS PERSONAL INJURY 310 Airplane 315 Airplane Product Liability 320 Assault, Libel & Slander 330 Federal Employers Liability 340 Marine 345 Marine Product Liability 350 Motor Vehicle 355 Motor Vehicle Product Liability 360 Other Personal Injury CIVIL RIGHTS 441 Voting 442 Employment 443 Housing/ Accommodations 444 Welfare 445 Amer. w/Disabilities Employment 446 Amer. w/Disabilities Other 440 Other Civil Rights PERSONAL INJURY u 362 Personal Injury Med. Malpractice u 365 Personal Injury Product Liability u 368 Asbestos Personal Injury Product Liability PERSONAL PROPERTY u 370 Other Fraud u 371 Truth in Lending u 380 Other Personal Property Damage u 385 Property Damage Product Liability PRISONER PETITIONS u 510 Motions to Vacate Sentence Habeas Corpus: u 530 General u 535 Death Penalty u 540 Mandamus & Other u 550 Civil Rights u 555 Prison Condition

FORFEITURE/PENALTY

BANKRUPTCY

OTHER STATUTES

u u u u u u u u u u u u u u u u u u

110 Insurance 120 Marine 130 Miller Act 140 Negotiable Instrument 150 Recovery of Overpayment & Enforcement of Judgment 151 Medicare Act 152 Recovery of Defaulted Student Loans (Excl. Veterans) 153 Recovery of Overpayment of Veterans Benefits 160 Stockholders Suits 190 Other Contract 195 Contract Product Liability 196 Franchise REAL PROPERTY 210 Land Condemnation 220 Foreclosure 230 Rent Lease & Ejectment 240 Torts to Land 245 Tort Product Liability 290 All Other Real Property

u u u u u u u u u u u u u u u u

u 610 Agriculture u 620 Other Food & Drug u 625 Drug Related Seizure of Property 21 USC 881 u 630 Liquor Laws u 640 R.R. & Truck u 650 Airline Regs. u 660 Occupational Safety/Health u 690 Other LABOR u 710 Fair Labor Standards Act u 720 Labor/Mgmt. Relations u 730 Labor/Mgmt.Reporting & Disclosure Act u 740 Railway Labor Act u 790 Other Labor Litigation u 791 Empl. Ret. Inc. Security Act
IMMIGRATION u 462 Naturalization Application u 463 Habeas Corpus Alien Detainee u 465 Other Immigration Actions

u 422 Appeal 28 USC 158 u 423 Withdrawal 28 USC 157

PROPERTY RIGHTS u 820 Copyrights u 830 Patent u 840 Trademark

u u u u u u u u u u u u u u u u u u u

SOCIAL SECURITY 861 HIA (1395ff) 862 Black Lung (923) 863 DIWC/DIWW (405(g)) 864 SSID Title XVI 865 RSI (405(g)) FEDERAL TAX SUITS u 870 Taxes (U.S. Plaintiff or Defendant) u 871 IRSThird Party 26 USC 7609

u u u u u

400 State Reapportionment 410 Antitrust 430 Banks and Banking 450 Commerce 460 Deportation 470 Racketeer Influenced and Corrupt Organizations 480 Consumer Credit 490 Cable/Sat TV 810 Selective Service 850 Securities/Commodities/ Exchange 875 Customer Challenge 12 USC 3410 890 Other Statutory Actions 891 Agricultural Acts 892 Economic Stabilization Act 893 Environmental Matters 894 Energy Allocation Act 895 Freedom of Information Act 900Appeal of Fee Determination Under Equal Access to Justice 950 Constitutionality of State Statutes

V. ORIGIN

u 1 Original Proceeding

u 2 Removed from
State Court

(Place an X in One Box Only)

Appeal to District Appellate Court

u 3 Remanded from

u 4 Reinstated or u 5 Transferred from u 6 Multidistrict another district Reopened Litigation (specify)

u 7 Judge from Magistrate

Judgment

Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):

VI. CAUSE OF ACTION Brief description of cause:

15 USC Sections 1114 & 1125

DEMAND $ CHECK YES only if demanded in complaint: Yes u u No JURY DEMAND: DOCKET NUMBER

u CHECK IF THIS IS A CLASS ACTION VII. REQUESTED IN UNDER F.R.C.P. 23 COMPLAINT: VIII. RELATED CASE(S) (See instructions): JUDGE IF ANY
DATE

Trademark infringement

SIGNATURE OF ATTORNEY OF RECORD

08/19/2011
FOR OFFICE USE ONLY RECEIPT # AMOUNT

s/James D. Peterson

APPLYING IFP

JUDGE

MAG. JUDGE

Case: 3:11-cv-00586
AO 120 (Rev. 3 04

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1-5

Filed: 08/19/11

Page

1 of 1

TO:

Mail Stop 8 Director of the U.S. Patent and Trademark Office

P.O. Box 1450

REPORT ON THE

FILING OR DETERMINATION OF AN ACTION REGARDING A PATENT OR

TRADEMARK
1116 you are hereby advised that
on

Alexandria, VA 22313-1450
In

Compliance with 35

U.S.C.

290 and/or 15 U.S.C.

court action has been

or

filed in the U.S. District Court

DOCKET

Western District of Wisconsin

U.S. DISTRICT

the

following

Patents

Q7

Trademarks:

V-9,V-586

DATE FI

i09/2011

COURWTestern

District of Wisconsin

PLAINTIFF

DEFENDANT

STATE BAR OF WISCONSIN

LEXISNEXIS

(a division of Reed Elsevier, Inc.)

PATENT OR TRADEMARK NO.

1 2

DATE OF PATENT OR TRADEMARK

HOLDER OF PATENT OR TRADEMARK

3, 945, 835

4/12/2011

State Bar of Wisconsin

3
4 5

In the aboveentitled case, the

following patent(s)/ trademark(s) have been included:

DATE INCLUDED

INCLUDED BY

G
PATENT OR TRADEMARK NO.
1 2

Amendment

Answer

Cross Bill

Other

Pleading

DATE OF PATENT OR TRADEMARK

HOLDER OF PATENT OR TRADEMARK

3
4 5

In the aboveentitled case, the

following decision has been rendered or judgement issued:

DECISION/JUDGEMENT

CLERK

(BY) DEPUTY CLERK

DATE

Copy 1Upon initiation of action, mail this copy to Director Copy 3Upon termination of action, mail this Copy 2Upon filing document adding patent(s), mail this copy to Director Copy 4Case file copy

copy to Director

Case: 3:11-cv-00586
AO 440

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(Rev. 12/09)

Summons in

Civil Action

UNITED STATES DISTRICT COURT

for the

Western District of Wisconsin

STATE BAR OF WISCONSIN

Plaintiff
v.

Civil Action No.

11-CV-586

LEXISNEXIS

(a

division of Reed Elsevier,

Inc.)

Defendant
SUMMONS IN A CIVIL ACTION
To: (Defendants
name

and address) LexisNexis

(a

division of Reed Elsevier,

Inc.)
Agent

c/o CT Corporation System, Registered 8040 Excelsior Drive, Ste. 200 Madison, WI 53717

A lawsuit has been filed

against you.

Within 21 days after service of this summons on you (not counting the day you received it) or 60 days if you the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ. P. 12 (a)(2) or (3) you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff s attorney, whose name and address are: Attorneys James D. Peterson and Jennifer L. Gregor Godfrey & Kahn, S.C. One East Main Street, Suite 500 P.O. Box 2719
are

Madison, WI 53701-2719

(608)

257-3911

If you fail to respond, judgment by default will be entered You also must file your answer or motion with the court.

against you for the relief demanded in the complaint.

CLERK OF COURT

Date:

Signature of Clerk or Deputy

Clerk

Case: 3:11-cv-00586
AO 440

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(Rev. 12/09)

Summons in

Civil Action

(Page 2)

Civil Action No. 11-CV-586

PROOF OF SERVICE

(This
This
was

section should not be filed with the court unless

required by Fed. R.

Civ. P.

4(l))

summons

for (name of individual and title, ifany)

received

by me

on

(date).
served the
summons on

Cl I

personally

the individual at (place)

on

(date);

or

Cl I left the

summons

at the individuals residence

a

or

usual

place

of abode with (name)

person of suitable age and discretion who resides there,

on

(date), and mailed

summons on

copy to the individuals last known

address;

or

Cl I served the

(name ofindividual
of process
on

who is behalf of (name oforganization)

on

designated by law to accept service

(date);

or

Cl I returned the Cl Other (specify):

summons

unexecuted because;

or

My fees

are

for travel and

for

services, for a total of

0.00

I declare under penalty of perjury that this information is true.

Date:
Servers

signature

Printed name and title

Servers address

Additional information regarding

attempted service, etc: