02 Amended Complaint 20-Cv-04335 (Pdf)

IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

VIACOM INTERNATIONAL INC, CASE NO.: 1:20-CV-04335 PLAINTIFF,

V. JUDGE VIRGINIA M. KENDALL

THE PARTNERSHIPS AND UNINCORPORATED ASSOCIATIONS IDENTIFIED ON SCHEDULE A, MAGISTRATE JUDGE JEFFREY CUMMINGS

DEFENDANTS. FILED UNDER SEAL

AMENDED COMPLAINT

Plaintiff, Viacom International Inc (“Viacom” or “Plaintiff”), by its undersigned counsel, hereby complains ofe th Partnerships and Unincorporated Associations identified on Schedule A attached hereto (collectively, “Defendants”), and using the identified online marketplace accounts

(collectively, the “Seller Aliases”), and for its Complaint hereby alleges as follows:

JURISDICTION AND VENUE

1. This Court has original subject matter jurisdiction over the claims in this action pursuant to the provisions of the Lanham Act, 15 U.S.C. § 1051 et seq., the Federal Copyright Act,

17 U.S.C. § 101, et seq., 28 U.S.C. § 1338(a)–(b), and 28 U.S.C. § 1331. This Court has jurisdiction over the claims in this action that arise under the laws of the State of Illinois pursuant to 28 U.S.C. §

1367(a), because the state law claims are so related to the federal claims that they form part of the same case or controversy and derive from a common nucleus of operative facts.

2. This Court has personal jurisdiction over each Defendant, in that each Defendant conducts significant business in Illinois and in this Judicial District, and the acts and events giving

0 rise to this lawsuit, of which each Defendant stands accused, were undertaken in Illinois and within this Judicial District.

3. Venue is proper in this Court pursuant to 28 U.S.C. § 1391, since each Defendant directly targets consumers in the United States, including Illinois, through the fully interactive, commercial Internet stores operating under the Defendant Seller Aliases and/or the Online

Marketplace Accounts identified in Schedule A. Each of the Defendants has targeted sales from

Illinois residents by operating online stores that offer shipping to the United States, including Illinois, accept payment in U.S. dollars and, on information and belief, has sold, and continues to sell counterfeit products that infringe Plaintiff’s trademarks and/or copyrights. Each Defendant is committing tortious acts, is engaging in interstate commerce, and has wrongfully caused substantial injury in the State of Illinois.

INTRODUCTION

4. This action has been filed to combat the online trademark and copyright infringement and counterfeiting of Defendants, who trade upon Plaintiff’s valuable trademarks and copyrights by selling, and/or offering for sale, unauthorized, unauthentic, and counterfeit products in connection with

Plaintiff’s federally registered trademarks, as well as to stop and prevent Defendants’ selling of unauthorized products that use, are based on, and/or are derived from, copyrighted subject matter created by Viacom.

5. Plaintiff,Viacom International Inc, is the owner of the federally registered Teenage

Mutant Ninja Turtles (“TMNT”) Trademarks, United States Trademark Registration Nos. 1,465,387,

1,469,195, 1,533,399, 1,534,724, 1,535,255, 1,535,416, 1,571,013, 2,818,181, 2,826,075, 2,832,801,

2,843,654, 2,875,370, 2,860,969, 2,875,371, 2,882,475, 2,887,154, 2,921,165, 2,971,494, 2,989,983,

3,112,463, 3,112,464, 3,237,389, 5,591,449, 5,746,310, 5,746,311, 3,112,465, 3,112,469, 3,279,830,

1 3,532,640, 3,532,641, 3,360,904, 3,370,778, 3,370,779, 3,360,905, and, 3,360,906 (collectively referred to as the “TMNT Trademarks”) which cover a variety of TMNT products (hereinafter referred to as “TMNT Products”). The Registrations are valid, subsisting, and in full force and effect. True and correct copies of the registration certificates for the aforementioned TMNT Trademarks are attached hereto as Exhibit 1. Additionally, Plaintiff is the owner of numerous copyright registrations, which have effective registration dates as early as 2010, and are attached hereto as Exhibit 2 (hereinafter referred to as “TMNT Copyrights”).

6. In an effort to illegally and deceptively profit from the TMNT Trademarks and TMNT

Copyrights, Defendants created numerous Seller Aliases and online stores (referred to as “Defendant

Internet Stores”), intentionally designed in look, feeling, and suggestion to give the impression to consumers that they are legitimate websites selling authorized TMNT Products, with Defendants’ ultimate intention being to deceive unknowing consumers into purchasing counterfeit TMNT Products.

7. Defendant Internet Stores share numerous unique identifiers, such as design elements and similarities of the unauthorized products offered for sale, establishing a logical relationship between Defendants, and suggesting that Defendants’ illegal operations arise out of the same transaction, occurrence, or series of transactions or occurrences. Defendants attempt to avoid liability by going to great lengths to conceal both their identities and the full scope and interworking of their illegal operation.

8. Plaintiff is forced to file this action to combat Defendants’ ongoing infringement of

Plaintiff’s TMNT Trademarks and TMNT Copyrights (collectively referred to as “TMNT Intellectual

Property” or “TMNT IP”). Plaintiff has been, and continues to be, irreparably damaged through consumer confusion, dilution, loss of control over the creative content, and tarnishment of its valuable trademarks and copyrights, as a result of Defendants’ actions; thus, Plaintiff is seeking injunctive and monetary relief.

2 THE PLAINTIFF

9. Viacom International Inc is a Delaware corporation, which has a principal place of business at 1515 Broadway, New York, NY. Viacom owns world-famous properties such as Dora the Explorer, SpongeBob SquarePants, and Teenage Mutant Ninja Turtles, among others. In addition to creating media content based on these properties that is distributed through linear cable television networks, streaming services, online and theatrical releases, Viacom offers a line of consumer products and services for each property including toys, clothing, food items, decorative items, wall stickers, personal care products, and, experiences marketed towards fans of the properties. The following are examples of genuine TMNT intellectual property and products:

10. The TMNT Trademarks have been used exclusively by Viacom International Inc and its licensees since their acquisition in 2009, and have never been abandoned. The TMNT registrations are valid, subsisting, and in full force and effect. The registrations of the TMNT Trademarks constitute prima facie evidence of their validity and ofViacom International Inc’s exclusive right to use the

TMNT Trademarks pursuant to 15 U.S.C. § 1057(b).

11. Viacom’s TMNT Trademarks and Copyrighted Works are, and have been, continuously used, and are, and have been, the subject of continuous marketing and promotion by

Plaintiff in the industry and to consumers.

12. The success of the TMNT Products and TMNT brand is due in large part to the marketing, promotional, and distribution efforts of Viacom. Viacom has invested substantial time, money, and effort in building up and developing consumer recognition, awareness, and goodwill in the

TMNT Products.

13. The success of the TMNT brand is also due to the use of high-quality materials and processes in making the TMNT Products.

14. Additionally, Viacom owes a substantial amount of the success of the TMNT products to its licensees, consumers, and interest that its consumers have generated.

15. As a result of the efforts of Viacom, the quality of its TMNT products, the promotional efforts for its products and designs, press and media coverage, members of the public have become familiar with the TMNT Products, TMNT Copyrights, and TMNT Trademarks, and associate them exclusively with Viacom.

16. Viacom International Inc has made efforts to protect its interests in and to the TMNT

Intellectual Property. Viacom International Inc and its licensees are the only businesses and/or individuals authorized to manufacture, import, export, advertise, offer for sale, or sell any toy action figures utilizing the TMNT Copyrights and/or TMNT Trademarks, without the express written

permission of Viacom International Inc. Plaintiff has not licensed or authorized Defendants to use the

TMNT Trademarks and Copyrights.

THE DEFENDANTS

17. Defendants are individuals and business entities who, upon information and belief, reside in the People’s Republic of China or other foreign jurisdictions. Defendants conduct business throughout the United States, including Illinois, and within this Judicial District, through the operation of fully interactive commercial websites and online marketplaces operating under the Defendant

Internet Stores. Each Defendant targets the United States, including Illinois, and has offered to sell and, on information and belief, has sold and continues to sell unauthorized and/or counterfeit TMNT

Products to consumers within the United States, Illinois, and this Judicial District.

THE DEFENDANTS’ UNLAWFUL CONDUCT

18. The success and widespread popularity and recognition of the TMNT brand and TMNT

Products has resulted in significant counterfeiting and intentional copying. Plaintiff has identified numerous Seller Aliases linked to fully interactive websites and marketplace listings on platforms such as eBay, Amazon, Wish, and AliExpress, including the Defendant Internet Stores, which are offering for sale, selling, and importing counterfeit TMNT Products to consumers in this Judicial District and throughout the United States. Internet websites like the Defendant Internet Stores are estimated to receive tens of millions of visits per year and to generate over $135 billion in annual online sales.

According to an intellectual property rights seizures statistics report issued by Homeland Security, the manufacturer’s suggested retail price (MSRP) of goods seized by the U.S. government in the fiscal year

2013 was over $1.74 billion, up from $1.26 billion in 2012. Internet websites like the Defendant Internet

Stores are also estimated to contribute to tens of thousands of lost jobs for legitimate businesses and broader economic damages such as lost tax revenue every year.

19. As recently addressed in the Wall Street Journal, Fortune, and the New York Times, and as reflected in the federal lawsuits filed against sellers offering for sale and selling infringing and/or counterfeit products on the above mentioned digital marketplaces, an astronomical number of counterfeit and infringing products are offered for sale and sold on these digital marketplaces at a rampant rate. See Kathy Chu, Luxury brands get tougher with counterfeiters – and Alibaba,

MARKETWATCH (Aug. 16, 2016), http://www.marketwatch.com/story/luxury-brands-get-tough- with-counterfeiters-2016-08-16-91031611; Gilian Wong, Alibaba Sued Over Alleged Counterfeits,

WALL STREET JOURNAL (May 17, 2015), http://www.wsj.com/articles/alibaba-sued-over- alleged-counterfeits-1431877734; Scott Cendrowski, There’s no end in sight for Alibaba’s counterfeit problem, FORTUNE (May 18, 2015), http://fortune.com/2015/05/18/theres-no-end- in- sight-for-alibabas-counterfeit-problem/.

20. Upon information and belief, Defendants facilitate sales by designing the Defendant

Internet Stores to appear to unknowing consumers to be authorized online retailers, outlet stores, or wholesalers selling genuine TMNT Products through the use of TMNT Intellectual Property.

Defendant Internet Stores look sophisticated and perpetuate an illusion of legitimacy – they accept payment in U.S. dollars via credit cards, Western Union, and PayPal; they often include images and design elements that make it difficult for consumers to distinguish these unauthorized sites from an authorized website; they offer “live 24/7” customer service; and, they use indicia of authenticity and security that consumers have come to associate with authorized retailers, including the McAfee®

Security, VeriSign®, Visa®, MasterCard®, and PayPal® logos.

21. Upon information and belief, Defendants also deceive unknowing consumers by using the TMNT Trademarks without authorization within the content, text, and/or meta tags of their websites, in order to attract and manipulate search engines into identifying Defendants’ Online Stores as legitimate websites for TMNT Products. Defendants also employ other unauthorized search engine

optimization (“SEO”) tactics and social media spamming so that Defendant Internet Stores show up at or near the top of relevant search results, including tactics to propel new domain names to the top of search results after others are shut down. These tactics are meant to, and are successful in, misdirecting consumers who are searching for genuine TMNT Products.

22. There is a substantial evidentiary overlap in Defendants’ acts of infringement, thus constituting a collective enterprise.

23. On information and belief, Defendants go to great lengths to conceal their identities and often use multiple fictitious names and addresses to register and operate their massive network of

Defendant Internet Stores. For example, many of Defendants’ names and physical addresses used to register the Defendant domain names are incomplete, contain randomly typed letters, or fail to include cities or states. Other Defendant domain names use privacy services that conceal the owners’ identity and contact information. Upon information and belief, Defendants regularly create new websites and online marketplace accounts on various platforms using the identities listed in Schedule

A of the Complaint, as well as other unknown fictitious names and addresses. Such Defendant Internet

Store registration patterns are one of many common tactics used by Defendants to conceal their identities, the full scope and interworking of their massive infringing operation, and to avoid being shut down.

24. On information and belief, even though Defendants operate under multiple fictitious names, there are numerous similarities among the Defendant Internet Stores, including, but by no means limited to: (1) virtually identical layouts, even though different aliases were used to register the respective domain names; (2) similarities of the unauthorized and/or counterfeit TMNT Products, and indicia of being related to one another, suggesting that the illegal products were manufactured by and come from a common source and that Defendants are interrelated; and (3) other notable common features such as use of the same domain name registration patterns, unique shopping cart platforms,

accepted payment methods, check-out methods, meta data, illegitimate SEO tactics, HTML user- defined variables, domain redirection, lack of contact information, identically or similarly priced items and volume sales discounts, similar hosting services, similar name servers, and the use of the same text and images.

25. Further, illegal operators, like Defendants, typically operate multiple credit card merchant accounts and third-party payment processor accounts, such as PayPal accounts, behind layers of payment gateways so they can continue operation in spite of any enforcement efforts. Upon information and belief, and as PayPal transaction logs in previous similar cases have shown, Defendants maintain off-shore bank accounts and regularly move funds from their PayPal accounts to off-shore bank accounts outside the jurisdiction of this Court.

26. Defendants, without any authorization or license, have knowingly and willfully infringed the TMNT Trademarks and Copyrights in connection with the advertisement, distribution, offering for sale, and sale of illegal, infringing, and counterfeit products into the United States and

Illinois. Each Defendant Internet Store offers to ship to the United States, including Illinois, and, on information and belief, each Defendant has offered to sell, or has already sold, infringing products therein.

27. In committing these acts, Defendants have, among other things, willfully and in bad faith committed the following, all of which have and will continue to cause irreparable harm to the

TMNT brand: infringed upon and counterfeited the TMNT Trademarks and TMNT Copyrights; created, manufactured, sold, and/or offered to sell counterfeit products and/or products which infringe upon the TMNT Intellectual Property; used the TMNT IP in an unauthorized manner in order to sell, advertise, describe, mislead, disceive, and trade upon the TMNT brand; engaged in unfair competition; and unfairly and unjustly profited from such activities at the expenses of Viacom International Inc.

28. Unless enjoined, Defendants will continue to cause irreparable harm toViacom

International Inc.

COUNT I TRADEMARK INFRINGEMENT AND COUNTERFEITING (15 U.S.C. § 1114)

29. Plaintiff repleads and incorporates by reference each and every allegation set forth in the preceding paragraphs as if fully set forth herein.

30. This is a trademark infringement action against Defendants, based on their unauthorized use in commerce of counterfeit imitations of the federally registered Plaintiff’s

Trademarks in connection with the sale, offering for sale, distribution, and/or advertising of infringing goods.

31. Without the authorization or consent of Viacom, and with knowledge of Viacom’s well-known ownership rights in its TMNT Trademarks, and with knowledge that Defendants’ counterfeit products bear counterfeit marks, Defendants intentionally reproduced, copied, and/or colorably imitated the TMNT Trademarks and/or used spurious designations that are identical with, or substantially indistinguishable from, the TMNT Trademarks on or in connection with the manufacturing, import, export, advertising, marketing, promotion, distribution, display, offering for sale, and/or sale of counterfeit products.

32. Defendants have manufactured, imported, exported, advertised, marketed, promoted, distributed, displayed, offered for sale, and/or sold their counterfeit products to the purchasing public in direct competition with Viacom and the TMNT Products, in or affecting interstate commerce, and/or have acted with reckless disregard of Plaintiff’s rights in and to the TMNT Trademarks through their participation in such activities.

33. Defendants have applied their reproductions, counterfeits, copies, and colorable imitations of the TMNT Trademarks to packaging, point-of-purchase materials, promotions, and/or

advertisements intended to be used in commerce upon, or in connection with, the manufacturing, importing, exporting, advertising, marketing, promoting, distributing, displaying, offering for sale, and/or selling of Defendants’ counterfeit products, which is likely to cause confusion, mistake, and deception among the general purchasing public as to the origin of the counterfeit products, and is likely to deceive consumers, the public, and the trade into believing that the counterfeit products sold by Defendants originate from, are associated with, or are otherwise authorized by Viacom

International Inc, through which Defendants make substantial profits and gains to which they are not entitled in law or equity.

34. Defendants’ unauthorized use of the TMNT Trademarks on or in connection with the counterfeit products was done with notice and full knowledge that such use was not authorized or licensed by Viacom International Inc, and with deliberate intent to unfairly benefit from the incalculable goodwill inherent in the TMNT Trademarks.

35. Defendants’ actions constitute willful counterfeiting of the TMNT Trademarks in violation of 15 U.S.C. §§ 1114(1)(a)-(b), 1116(d), and 1117(b)-(c).

36. Defendants’ continued intentional use of the TMNT Trademarks without the consent or authorization of Viacom International Inc, constitutes intentional infringement of

Viacom International Inc’s federally registered TMNT Trademarks in violation of § 32 of the

Lanham Act, 15 U.S.C. § 1114.

37. As a direct and proximate result of Defendants’ illegal actions alleged herein,

Defendants have caused substantial monetary loss, irreparable injury, and damage to Viacom

International Inc, its business, its reputation, and its valuable rights in and to the TMNT Trademarks and the goodwill associated therewith, in an amount as yet unknown. Viacom International Inc has no adequate remedy at law for this injury, and unless immediately enjoined, Defendants will continue

11 to cause such substantial and irreparable injury, loss, and damage to Viacom International Inc and its valuable TMNT Trademarks.

38. Based on Defendants’ actions as alleged herein, Viacom International Inc is entitled to injunctive relief, damages for the irreparable harm that Viacom International Inc has sustained, and will sustain, as a result of Defendants’ unlawful and infringing actions, as well as all gains, profits, and advantages obtained by Defendants as a result thereof, enhanced discretionary damages, treble damages, and/or statutory damages of up to $2,000,000 per-counterfeit mark per-type of goods sold, offered for sale, or distributed, and reasonable attorneys’ fees and costs.

COUNT II FALSE DESIGNATION OF ORIGIN, PASSING OFF, & UNFAIR COMPETITION (15 U.S.C. § 1125(a)/LANHAM ACT § 43(a))

39. Plaintiff repleads and incorporates by reference each and every allegation set forth in the preceding paragraphs as if fully set forth herein.

40. Plaintiff, as the owner of all right, title, and interest in and to the TMNT Trademarks has standing to maintain an action for false designation of origin and unfair competition under the

Federal Trademark Statute, Lanham Act § 43(a) (15 U.S.C. § 1125).

41. Plaintiff’s TMNT Trademarks are inherently distinctive and are registered with the

United States Patent and Trademark Office on the Principal Register; the TMNT Trademarks have been continuously used and have never been abandoned; the registrations for the TMNT Trademarks are valid, subsisting, and in full force and effect; and many are incontestable pursuant to 15 U.S.C. §

1065.

42. Defendants’ promotion, marketing, offering for sale, and sale of infringing TMNT

Products has created and continues to create a likelihood of confusion, mistake, and deception among the public as to the affiliation, connection, or association with Plaintiff or as to the origin, sponsorship, or approval of Defendants’ infringing products by Plaintiff.

43. By using the TMNT Trademarks in connection with the sale of counterfeit products,

Defendants create a false designation of origin and a misleading representation of fact as to the origin and sponsorship of the unauthorized products.

44. Defendants’ false designation of origin and misrepresentation of fact as to the origin and/or sponsorship of the counterfeit products to the general public is a willful violation of Section

43 of the Lanham Act, 15 U.S.C. § 1125.

45. Upon information and belief, Defendants’ aforementioned wrongful actions have been knowing, deliberate, willful, and intended to cause confusion, to cause mistake, and to deceive the purchasing public, with the intent to trade on the goodwill and reputation of Viacom International

Inc, its TMNT Products, and TMNT Trademarks.

46. As a direct and proximate result of Defendants’ aforementioned actions, Defendants have caused irreparable injury to Viacom International Inc by depriving Plaintiff of sales of its TMNT

Products and by depriving Viacom International Inc of the value of its TMNT Trademarks as commercial assets in an amount as yet unknown.

47. Plaintiff has no adequate remedy at law and, if Defendants’ actions are not enjoined,

Plaintiff will continue to suffer irreparable harm to its reputation and the goodwill of its brand.

COUNT III VIOLATION OF ILLINOIS UNIFORM DECEPTIVE TRADE PRACTICES ACT (815 ILCS § 510, et seq.)

48. Plaintiff repleads and incorporates by reference each and every allegation set forth in the preceding paragraphs as if fully set forth herein.

49. Defendants have engaged in acts violating Illinois law, including, but not limited to, passing off their unauthorized products as those of Plaintiff, causing a likelihood of confusion and/or misunderstanding as to the source of Defendants’ goods, thus causing a likelihood of confusion and/or misunderstanding as to an affiliation, connection, or association with genuine TMNT

Products, through Defendants’ representation that Defendants’ counterfeit products have Plaintiff’s approval, when they do not.

50. The foregoing Defendants’ acts constitute a willful violation of the Illinois Uniform

Deceptive Trade Practices Act, 815 ILCS § 510, et seq..

51. Plaintiff has no adequate remedy at law, and Defendants’ conduct has caused Plaintiff to suffer damage to its reputation and goodwill. Unless enjoined by the Court, Plaintiff will suffer future irreparable harm as a direct result of Defendants’ unlawful activities.

COUNT IV COPYRIGHT INFRINGEMENT (17 U.S.C. § 501(a))

52. Plaintiff repleads and incorporates by reference each and every allegation set forth in the preceding paragraphs as if fully set forth herein.

53. The TMNT Copyrights are the subject of multiple valid copyright registrations.

54. Plaintiff, at all relevant times, has been the holder of the copyright registrations and exclusive rights of and belonging to Viacom International Inc, including but not limited to the TMNT

Copyrights and derivative works.

55. The TMNT Copyrights have significant value and have been produced and created at considerable expense.

56. The trademarked and copyrighted products include a copyright notice advising the general public that the TMNT Products are protected by the Copyright Laws of the United States.

57. Upon information and belief, Defendants had access to the copyrighted works through

Plaintiff’s normal business activities. After accessing Plaintiff’s works, Defendants wrongfully created copies of the copyrighted works without Plaintiff’s consent, and engaged in, and continue to engage in acts of widespread infringement.

58. Viacom International Inc is informed, and thereon alleges, that Defendants further infringed TMNT Copyrights by making, or causing to be made, derivative works by producing and distributing unauthorized reproductions of the TMNT Copyrights, without permission of Viacom

International Inc.

59. Each Defendant, without the permission or consent of the Plaintiff, has sold, and continues to sell, online infringing derivative works of Plaintiff’s Copyrights. Each Defendant has violated Plaintiff’s exclusive rights of reproduction and distribution. Each Defendant’s actions constitute an infringement of Plaintiff’s exclusive rights protected under the Copyright Act (17

U.S.C. §101 et seq.).

60. Further, as a direct result of the Defendants’ acts of copyright infringement,

Defendants have obtained profits they would not have otherwise realized but for their infringement of Plaintiff’s Copyrights. Viacom International Inc is entitled to disgorgement of Defendants’ profits, directly and indirectly, attributable to said infringement.

61. As a result of each Defendant’s infringement of Plaintiff’s exclusive rights under U.S.

62. The conduct of each Defendant is causing and, unless enjoined and restrained by this

Court, will continue to cause Plaintiff great and irreparable injury that cannot fully be compensated or measured monetarily. Plaintiff has no adequate remedy at law. As such, pursuant to 17 U.S.C. §§

502 and 503, Plaintiff is entitled to injunctive relief prohibiting each Defendant from further infringing Plaintiff’s Copyrights, and ordering that each Defendant destroy all unauthorized and/or infringing copies and reproductions of Plaintiff’s Copyrighted works. Defendants’ copies, plates, and other embodiments of the copyrighted work from which copies can be reproduced should be impounded and forfeited to Viacom International Inc as instruments of infringement, under 17 U.S.C

§503.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff requests judgment against Defendants as follows:

1) That Defendants, their affiliates, officers, agents, servants, employees, attorneys, confederates, and all persons acting for, with, by, through, under, or in active concert with them be temporarily, preliminarily, and permanently enjoined and restrained from:

a. using the TMNT Trademarks or any reproductions, copies, or colorable imitations

thereof, in any manner in connection with the distribution, marketing, advertising,

offering for sale, or sale of any product that is not an authorized TMNT Product, or is

not authorized by Plaintiff to be sold in connection with the TMNT Trademarks or

TMNT Copyrights;

b. passing off, inducing, or enabling others to sell or pass off any product not produced

under the authorization, control, or supervision of Plaintiff and approved by Plaintiff

for sale under the TMNT Trademarks or TMNT Copyrights;

c. shipping, delivering, holding for sale, transferring, or otherwise moving, storing,

distributing, returning, or otherwise disposing of, in any manner, products or inventory

not authorized by Plaintiff to be sold or offered for sale, and which bear the TMNT

Trademarks, or which are derived from the TMNT Copyrights;

d. further infringing the TMNT Trademarks and damaging Plaintiff’s goodwill;

e. using, linking to, transferring, selling, exercising control over, or otherwise owning the

Online Marketplace Accounts, the Defendant Internet Stores, Defendant product

listings, or any other domain name or online marketplace account that is being used to

sell products or inventory not authorized by Plaintiff which bear the TMNT

Trademarks or which are derived from Plaintiff’s TMNT Copyrights;

f. operating and/or hosting websites at the Defendant Internet Stores, and any other

domain names registered to or operated by Defendants that are involved with the

distribution, marketing, advertising, offering for sale, or sale of products or inventory

not authorized by Plaintiff which bear the TMNT Trademarks, or which are derived

from Plaintiff’s TMNT Copyrights;

2) Entry of an Order that, upon Plaintiff’s request, those in privity with Defendants and those with notice of the injunction, including any online marketplaces and payment processors, such as eBay, Amazon, Wish, iOffer, and Alibaba Group Holding Ltd., Alipay.com Co., Ltd., and any related

Alibaba entities (collectively, “Alibaba”), social media platforms, Facebook, YouTube, LinkedIn,

Twitter, Internet search engines such as Google, Bing, and Yahoo, web hosts for the Defendant domain names, and domain name registrars, shall:

a. disable and cease providing services for any accounts through which Defendants

engage in the sale of products not authorized by Plaintiff which bear the TMNT

Trademarks, including any accounts associated with Defendants listed on Schedule A;

b. disable and cease displaying any advertisements used by or associated with Defendants

in connection with the sale of products not authorized by Plaintiff which bear the

TMNT Trademarks, or which are derived from Plaintiff’s copyrights in the TMNT

Copyrights; and,

c. take all steps necessary to prevent links to the Seller Aliases identified on Schedule A

from displaying in search results, including, but not limited to, removing links to the

Seller Aliases from any search index.

3) That Defendants account for, and pay to Plaintiff, all profits realized by Defendants by reason of Defendants’ unlawful acts herein alleged;

4) For Judgment in favor of Plaintiff against Defendants that they have willfully infringed

Plaintiff’s rights in its federally registered TMNT Trademarks, pursuant to 15 U.S.C. § 1114;

5) That Plaintiff be awarded actual damages, statutory damages, and/or other available damages, at the election of Plaintiff; and that the amount of damages for infringement are increased by a sum not to exceed three times the amount thereof as provided by 15 U.S.C. § 1117;

6) For Judgment in favor of Plaintiff against Defendants that they have: a) willfully infringed

Plaintiff’s rights in its federally registered TMNT Copyrights pursuant to 17 U.S.C. §501; and, b) otherwise injured the business reputation and business of Plaintiff by Defendants’ acts and conduct set forth in this Complaint;

7) That Plaintiff be awarded actual damages, statutory damages, and/or other available damages pursuant to 17 U.S.C. § 504, at the election of Plaintiff;

8) That Plaintiff be awarded its reasonable attorneys’ fees and costs; and,

9) Any and all other relief that this Court deems just and proper.

DATED: July 23, 2020 Respectfully submitted,

/s/ Ann Marie Sullivan Ann Marie Sullivan Alison Carter Raymond Lang AM Sullivan Law, LLC 1440 W. Taylor St., Suite 515 Chicago, Illinois 60607 Telephone: 224-258-9378 E-mail: [email protected]

ATTORNEYS FOR PLAINTIFF

18 IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

VIACOM INTERNATIONAL INC, CASE NO.: 1:20-CV-04335

PLAINTIFF, JUDGE VIRGINIA M. KENDALL V.

THE PARTNERSHIPS AND UNINCORPORATED MAGISTRATE JUDGE JEFFREY CUMMINGS ASSOCIATIONS IDENTIFIED ON SCHEDULE A,

DEFENDANTS. FILED UNDER SEAL

EXHIBIT 1 TO THE COMPLAINT

Reg. No. 5,591,449 VIACOM INTERNATIONAL INC. (DELAWARE CORPORATION) 1515 Broadway Registered Oct. 23, 2018 New York, NEW YORK 10036 CLASS 41: Entertainment services in the nature of continuing program series, featuring live Int. Cl.: 41 action, comedy and drama provided through cable television, broadcast television, internet, video-on-demand, and through other forms of transmission media; providing online Service Mark information in the field of entertainment concerning television programs

Principal Register FIRST USE 7-20-2018; IN COMMERCE 7-20-2018

THE MARK CONSISTS OF STANDARD CHARACTERS WITHOUT CLAIM TO ANY PARTICULAR FONT STYLE, SIZE OR COLOR

OWNER OF U.S. REG. NO. 2843654, 1534724, 1469195

SER. NO. 87-563,783, FILED 08-10-2017 REQUIREMENTS TO MAINTAIN YOUR FEDERAL TRADEMARK REGISTRATION WARNING: YOUR REGISTRATION WILL BE CANCELLED IF YOU DO NOT FILE THE DOCUMENTS BELOW DURING THE SPECIFIED TIME PERIODS.

Requirements in the First Ten Years* What and When to File:

First Filing Deadline: You must file a Declaration of Use (or Excusable Nonuse) between the 5th and 6th years after the registration date. See 15 U.S.C. §§1058, 1141k. If the declaration is accepted, the registration will continue in force for the remainder of the ten-year period, calculated from the registration date, unless cancelled by an order of the Commissioner for Trademarks or a federal court.

Second Filing Deadline: You must file a Declaration of Use (or Excusable Nonuse) and an Application for Renewal between the 9th and 10th years after the registration date.* See 15 U.S.C. §1059.

Requirements in Successive Ten-Year Periods* What and When to File:

You must file a Declaration of Use (or Excusable Nonuse) and an Application for Renewal between every 9th and 10th-year period, calculated from the registration date.*

Grace Period Filings*

The above documents will be accepted as timely if filed within six months after the deadlines listed above with the payment of an additional fee.

*ATTENTION MADRID PROTOCOL REGISTRANTS: The holder of an international registration with an extension of protection to the United States under the Madrid Protocol must timely file the Declarations of Use (or Excusable Nonuse) referenced above directly with the United States Patent and Trademark Office (USPTO). The time periods for filing are based on the U.S. registration date (not the international registration date). The deadlines and grace periods for the Declarations of Use (or Excusable Nonuse) are identical to those for nationally issued registrations. See 15 U.S.C. §§1058, 1141k. However, owners of international registrations do not file renewal applications at the USPTO. Instead, the holder must file a renewal of the underlying international registration at the International Bureau of the World Intellectual Property Organization, under Article 7 of the Madrid Protocol, before the expiration of each ten-year term of protection, calculated from the date of the international registration. See 15 U.S.C. §1141j. For more information and renewal forms for the international registration, see http://www.wipo.int/madrid/en/.

NOTE: Fees and requirements for maintaining registrations are subject to change. Please check the USPTO website for further information. With the exception of renewal applications for registered extensions of protection, you can file the registration maintenance documents referenced above online at h ttp://www.uspto.gov.

NOTE: A courtesy e-mail reminder of USPTO maintenance filing deadlines will be sent to trademark owners/holders who authorize e-mail communication and maintain a current e-mail address with the USPTO. To ensure that e-mail is authorized and your address is current, please use the Trademark Electronic Application System (TEAS) Correspondence Address and Change of Owner Address Forms available at http://www.uspto.gov.

Page: 2 of 2 / RN # 5591449 Reg. No. 5,746,310 VIACOM INTERNATIONAL INC. (DELAWARE CORPORATION) 1515 Broadway, 33rd Floor Registered May 07, 2019 New York, NEW YORK 10036 CLASS 28: Toys and games, namely, toy figures, sets of miniature figures for game playing, Int. Cl.: 28 board games, puzzles, balloons; plastic inflated balls; inflatable pounding bags; toy boxes, toy swim goggles; kites; halloween costume masks; Christmas tree ornaments; elbow pads for Trademark athletic use; knee pads for athletic use; inflatable swimming rings; inflatable wading pools; ride-on toys; roller skates; play ground equipment, namely, sandboxes; playground slides; Principal Register skateboards; snow skis and ski poles; snow sleds for recreational use; snow boards; action type target games; role-playing game toy play sets; miniature toy vehicles; bubble making activity toys; stuffed plush toys; miniature motorized toy vans; toy whistles; decorative wind socks; coin operated pinball games; coin operated arcade type video games; yo-yo's, basketball game set containing basketball hoop, net, and basketball, play shaving kits with play shaver, shave cream and brush; children's fishing kits, consisting of plastic box, plastic worms, hooks and string for fishing

FIRST USE 9-9-2018; IN COMMERCE 9-9-2018

THE MARK CONSISTS OF STANDARD CHARACTERS WITHOUT CLAIM TO ANY PARTICULAR FONT STYLE, SIZE OR COLOR

OWNER OF U.S. REG. NO. 1534724, 2843654, 1469195

SER. NO. 87-563,760, FILED 08-10-2017 REQUIREMENTS TO MAINTAIN YOUR FEDERAL TRADEMARK REGISTRATION WARNING: YOUR REGISTRATION WILL BE CANCELLED IF YOU DO NOT FILE THE DOCUMENTS BELOW DURING THE SPECIFIED TIME PERIODS.

Requirements in the First Ten Years* What and When to File:

Second Filing Deadline: You must file a Declaration of Use (or Excusable Nonuse) and an Application for Renewal between the 9th and 10th years after the registration date.* See 15 U.S.C. §1059.

Requirements in Successive Ten-Year Periods* What and When to File:

You must file a Declaration of Use (or Excusable Nonuse) and an Application for Renewal between every 9th and 10th-year period, calculated from the registration date.*

Grace Period Filings*

The above documents will be accepted as timely if filed within six months after the deadlines listed above with the payment of an additional fee.

Page: 2 of 2 / RN # 5746310 Reg. No. 5,746,311 VIACOM INTERNATIONAL INC. (DELAWARE CORPORATION) 1515 Broadway, 33rd Floor Registered May 07, 2019 New York, NEW YORK 10036 CLASS 25: Clothing, footwear and headgear, namely, cloth aprons, bandanas, bathing suits, Int. Cl.: 25 clothing belts, children's sleepwear; boxer shorts, clothing caps; halloween costumes; children's footwear; gloves; hats; ski hats; headbands; outwear jackets; jumpsuits; mittens; Trademark neckwarmers; children's raincoats; robes; socks; stockings; suspenders; sweaters; sweatshirts; Principal Register t-shirts; tops; underwear and visors FIRST USE 10-1-2018; IN COMMERCE 10-1-2018

THE MARK CONSISTS OF STANDARD CHARACTERS WITHOUT CLAIM TO ANY PARTICULAR FONT STYLE, SIZE OR COLOR

OWNER OF U.S. REG. NO. 1534724, 2843654, 1469195

SER. NO. 87-563,769, FILED 08-10-2017 REQUIREMENTS TO MAINTAIN YOUR FEDERAL TRADEMARK REGISTRATION WARNING: YOUR REGISTRATION WILL BE CANCELLED IF YOU DO NOT FILE THE DOCUMENTS BELOW DURING THE SPECIFIED TIME PERIODS.

Requirements in the First Ten Years* What and When to File:

Second Filing Deadline: You must file a Declaration of Use (or Excusable Nonuse) and an Application for Renewal between the 9th and 10th years after the registration date.* See 15 U.S.C. §1059.

Requirements in Successive Ten-Year Periods* What and When to File:

You must file a Declaration of Use (or Excusable Nonuse) and an Application for Renewal between every 9th and 10th-year period, calculated from the registration date.*

Grace Period Filings*

The above documents will be accepted as timely if filed within six months after the deadlines listed above with the payment of an additional fee.

Page: 2 of 2 / RN # 5746311

IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

VIACOM INTERNATIONAL INC, CASE NO.: 1:20-CV-04335

PLAINTIFF, JUDGE VIRGINIA M. KENDALL V.

THE PARTNERSHIPS AND UNINCORPORATED MAGISTRATE JUDGE JEFFREY CUMMINGS ASSOCIATIONS IDENTIFIED ON SCHEDULE A,

DEFENDANTS. FILED UNDER SEAL

EXHIBIT 2 TO THE COMPLAINT TMNT Copyright Registrations

Full Title Copyright Number Date BATMAN/TEENAGE MUTANT NINJA TURTLES #2, July 2016 (line TX0008305624 2016 sketch variant cover) Batman/Teenage Mutant Ninja Turtles #2, March 2016 (1:50) / by DC TX0006250164 2016 Comics. Batman/Teenage Mutant Ninja Turtles #2, March 2016 / by DC Comics. TX0006250165 2016 BATMAN/TEENAGE MUTANT NINJA TURTLES #3, April 2016 . TX0008299957 2016 Batman/Teenage Mutant Ninja Turtles #3, April 2016 (1:25 variant cover) / TX0005795262 2016 by DC Comics. BATMAN/TEENAGE MUTANT NINJA TURTLES #3, April 2016 TX0008299966 2016 (Batman, sword & turtles) Batman/Teenage Mutant Ninja Turtles #3, May 2016 (second printing black TX0006250419 2016 & white) / by DC Comics. BATMAN/TEENAGE MUTANT NINJA TURTLES #4, May 2016 . TX0008304932 2016 Batman/Teenage Mutant Ninja Turtles #5, June 2016 / by DC Comics. TX0006250420 2016 BATMAN/TEENAGE MUTANT NINJA TURTLES #6, July 2016 . TX0008322861 2016 BATMAN/TEENAGE MUTANT NINJA TURTLES #6, July 2016 (1:50 TX0008322850 2016 variant cover) Batman/Teenage Mutant Ninja Turtles Adventures #1. VA0002112331 2016 Batman/Teenage Mutant Ninja Turtles Adventures #1: Director's Cut. VA0002111701 2017 Batman/Teenage Mutant Ninja Turtles Adventures #2 (with 6 cover VA0002112310 2016 editions) Batman/Teenage Mutant Ninja Turtles Adventures #3 (with 4 cover VA0002112328 2017 editions) Batman/Teenage Mutant Ninja Turtles Adventures #4 (with 3 cover VA0002112276 2017 editions) Batman/Teenage Mutant Ninja Turtles Adventures #5 (with 4 cover VA0002112292 2017 editions) Batman/Teenage Mutant Ninja Turtles Adventures #6 (with 7 cover VA0002114027 2017 editions) BATMAN/TEENAGE MUTANT NINJA TURTLES : February 2016 : 1. TX0008224356 2015

BATMAN/TEENAGE MUTANT NINJA TURTLES II #1, February 2018 . TX0008519225 2017 BATMAN/TEENAGE MUTANT NINJA TURTLES II #1, February 2018 TX0008519229 2017 (open order) BATMAN/TEENAGE MUTANT NINJA TURTLES II #2, February 2018 . TX0008519242 2017 BATMAN/TEENAGE MUTANT NINJA TURTLES II #2, February 2018 TX0008519220 2017 (open order) BATMAN/TEENAGE MUTANT NINJA TURTLES II #3, March 2018 . TX0008519237 2018 BATMAN/TEENAGE MUTANT NINJA TURTLES II #3, March 2018 TX0008519241 2018 (open order) BATMAN/TEENAGE MUTANT NINJA TURTLES II #4, April 2018 . TX0008546339 2018 BATMAN/TEENAGE MUTANT NINJA TURTLES II #4, April 2018 TX0008546346 2018 (open order) BATMAN/TEENAGE MUTANT NINJA TURTLES II #5, May 2018 . TX0008526191 2018 BATMAN/TEENAGE MUTANT NINJA TURTLES II #5, May 2018 TX0008518917 2018 (open order) BATMAN/TEENAGE MUTANT NINJA TURTLES II #6, June 2018 . TX0008545218 2018 BATMAN/TEENAGE MUTANT NINJA TURTLES II #6, June 2018 TX0008545215 2018 (open order) BATMAN/TEENAGE MUTANT NINJA TURTLES III #1 Variant Cover. TX0008748186 2019

BATMAN/TEENAGE MUTANT NINJA TURTLES III #2 Variant Cover. TX0008748193 2019

BATMAN/TEENAGE MUTANT NINJA TURTLES III #3 Variant Cover. TX0008750795 2019

BATMAN/TEENAGE MUTANT NINJA TURTLES III #4 Variant Cover. TX0008775369 2019

BATMAN/TEENAGE MUTANT NINJA TURTLES III #5 Variant Cover. TX0008785434 2019

BATMAN/TEENAGE MUTANT NINJA TURTLES III #6 Variant Cover. TX0008806791 2019 BATMAN/TEENAGE MUTANT NINJA TURTLES III 1 of 6. TX0008748219 2019 BATMAN/TEENAGE MUTANT NINJA TURTLES III 2 of 6. TX0008748215 2019 BATMAN/TEENAGE MUTANT NINJA TURTLES III 3 of 6. TX0008750291 2019 BATMAN/TEENAGE MUTANT NINJA TURTLES III 4. TX0008775372 2019 BATMAN/TEENAGE MUTANT NINJA TURTLES III 5 of 6. TX0008785432 2019 BATMAN/TEENAGE MUTANT NINJA TURTLES III 6 of 6. TX0008806790 2019 BATMAN/TEENAGE MUTANT NINJA TURTLES, June 2016 (1:50 TX0008246789 2016 variant) Batman/Teenage Mutant Ninja Turtles, June 2016 (1:50 variant) / by DC TX0006250418 2016 Comics, Viacom International Inc. BATMAN/TEENAGE MUTANT NINJA TURTLES: THE DELUXE VA0002123764 2018 EDITION. BATMAN/TEENAGE MUTANT NINJA TURTLES: THE DELUXE TX0008592327 2018 EDITION (hard cover book) BATMAN VS TEENAGE MUTANT NINJA TURTLES. PA0002196740 2019 Rise of the Teenage Mutant Ninja Turtles. PA0002212999 2019 Rise of the Teenage Mutant Ninja Turtles : 101. PA0002143767 2018 Rise of the Teenage Mutant Ninja Turtles : 102, Origami Tsunami. PA0002145523 2018 Rise of the Teenage Mutant Ninja Turtles : 103, War and Pizza; PA0002152002 2018 Newsworthy. Rise of the Teenage Mutant Ninja Turtles : 104, RED MANTIS; DOWN PA0002149186 2018 WITH THE SICKNESS. Rise of the Teenage Mutant Ninja Turtles : 105, The Fast and the Furiest; PA0002149193 2018 Mascot Melee. Rise of the Teenage Mutant Ninja Turtles : 106. PA0002145588 2018 Rise of the Teenage Mutant Ninja Turtles : 107. PA0002145636 2018 Rise of the Teenage Mutant Ninja Turtles : 108. PA0002145633 2018 Rise of the Teenage Mutant Ninja Turtles : 109. PA0002145537 2018 Rise of the Teenage Mutant Ninja Turtles: 2017 Core Styleguide. VAu001334964 2018 Rise of the Teenage Mutant Ninja Turtles: 2018 Initial Launch Kit. VAu001327005 2018 Rise of the Teenage Mutant Ninja Turtles: 2018 Packaging Guide. VAu001328902 2018 Tales of the Teenage Mutant Ninja Turtles: The Final Chapters. PA0002108037 2017 Teenage mutant ninja turtles. V3607D652 2011 Teenage mutant ninja turtles. V3607D212 2011 Teenage Mutant Ninja Turtles. V3595D361 2010 Teenage Mutant Ninja Turtles. V3595D358 2010 Teenage Mutant Ninja Turtles. V3595D355 2010 Teenage Mutant Ninja Turtles. V3595D360 2010 Teenage Mutant Ninja Turtles. V3595D354 2010 Teenage Mutant Ninja Turtles. V3595D359 2010 Teenage Mutant Ninja Turtles. V3595D356 2010 Teenage Mutant Ninja Turtles. V3595D363 2010 Teenage Mutant Ninja Turtles. V3595D362 2010 Teenage Mutant Ninja Turtles. V3595D357 2010 Teenage Mutant Ninja Turtles #66 (with 4 cover editions) VA0002111690 2017 Teenage Mutant Ninja Turtles #67 (with 5 cover editions) VA0002112284 2017 Teenage Mutant Ninja Turtles #68 (with 6 cover editions) VA0002111801 2017 Teenage Mutant Ninja Turtles #69 (with 7 cover editions) VA0002111684 2017 Teenage Mutant Ninja Turtles #70 (with 7 cover editions) VA0002114025 2017 Teenage Mutant Ninja Turtles & 17 other titles. V3595D556 2010 Teenage Mutant Ninja Turtles & 17 other titles. V3595D557 2010 Teenage Mutant Ninja Turtles: 001, Things Change & 153 other titles. V3595D559 2010 Teenage Mutant Ninja Turtles: 001, Things Change & 155 other titles. V3595D558 2010 Teenage Mutant Ninja Turtles : 101, Rise of the Turtles, Part 1. PA0001824457 2012 Teenage Mutant Ninja Turtles : 102, Rise of the Turties Part 2. PA0001813811 2012 Teenage Mutant Ninja Turtles : 103. PAu003628954 2012 Teenage Mutant Ninja Turtles : 104, New Friend, Old Enemy. PA0001813810 2012 Teenage Mutant Ninja Turtles : 105, I Think His Name is Baxter Stockman. PA0001824467 2012 Teenage Mutant Ninja Turtles : 106, Metalhead. PAu003642557 2012 Teenage Mutant Ninja Turtles : 107, Monkey Brains. PAu003642559 2012 Teenage Mutant Ninja Turtles : 108, Never Say Xever. PAu003643167 2012 Teenage Mutant Ninja Turtles : 109. PAu003647116 2012 Teenage Mutant Ninja Turtles : 110. PAu003647632 2012 Teenage Mutant Ninja Turtles : 111. PAu003654415 2012 Teenage Mutant Ninja Turtles : 112. PAu003660844 2012 Teenage Mutant Ninja Turtles : 113. PAu003663055 2013 Teenage Mutant Ninja Turtles : 114, I, Monster. PAu003744418 2013 Teenage Mutant Ninja Turtles : 115. PAu003688906 2013 Teenage Mutant Ninja Turtles : 116. PA0001853472 2013 Teenage Mutant Ninja Turtles : 117. PA0001853479 2013 Teenage Mutant Ninja Turtles : 118, Cockroach Terminator. PA0001853476 2013 Teenage Mutant Ninja Turtles : 119, Baxter's Gambit. PA0001853481 2013 Teenage Mutant Ninja Turtles : 120, Enemy of My Enemy. PA0001853474 2013 Teenage Mutant Ninja Turtles : 121, Karal's Vendetta. PA0001853478 2013 Teenage Mutant Ninja Turtles : 122, THE PULVERIZER RETURNS! PA0001870202 2013 Teenage Mutant Ninja Turtles : 123, PARASITICA. PA0001870230 2013 Teenage Mutant Ninja Turtles : 124, OPERATION: BREAK OUT. PA0001870233 2013 Teenage Mutant Ninja Turtles : 125, SHOWDOWN PART 1. PAu003699010 2013 Teenage Mutant Ninja Turtles : 126, SHOWDOWN PART 2. PAu003699009 2013 Teenage Mutant Ninja Turtles : 201, The Mutation Situation. PA0001886722 2013 Teenage Mutant Ninja Turtles - 2011 Retro Guide Addendum. VAu001111391 2012 Teenage Mutant Ninja Turtles - 2012 Packaging Guide. VAu001111392 2012 Teenage Mutant Ninja Turtles - 2012 Retro Guide Addendum. VAu001111403 2012 Teenage Mutant Ninja Turtles - 2012 Styleguide. VAu001118386 2012 Teenage Mutant Ninja Turtles: 2015 Fall/Winter 16 Techniques. VAu001230759 2015 Teenage Mutant Ninja Turtles : 202, Follow the Leader. PAu003716235 2013 Teenage Mutant Ninja Turtles : 203, Invasion Of The Squirrelanoids. PA0001882090 2013 Teenage Mutant Ninja Turtles : 204, Mutagen Man Unleashed. PAu003711568 2013 Teenage Mutant Ninja Turtles : 205, Mikey Gets Shellacne. PAu003713772 2013 Teenage Mutant Ninja Turtles : 206, Target: April O'Nell. PA0001890939 2013 Teenage Mutant Ninja Turtles : 207, Slash and Destroy. PA0001890933 2013 Teenage Mutant Ninja Turtles : 208, The Kraang Conspiracy. PAu003720274 2014 Teenage Mutant Ninja Turtles : 209, The Good, the Bad, and Casey Jones. PAu003720178 2014 Teenage Mutant Ninja Turtles : 210, Fungus Humungous. PAu003720196 2014 Teenage Mutant Ninja Turtles : 211, Metalhead Rewired. PA0001933307 2014 Teenage Mutant Ninja Turtles : 212, Of Rats and Men. PA0001933315 2014 Teenage Mutant Ninja Turtles : 213, The Manhattan Project: Part 1. PAu003759463 2014 Teenage Mutant Ninja Turtles : 214, The Manhattan Project: Part 2. PAu003759466 2014 Teenage Mutant Ninja Turtles : 215, Mazes & Mutants. PA0001933300 2014 Teenage Mutant Ninja Turtles : 215, The Wrath of Tiger Claw. PA0001933302 2014 Teenage Mutant Ninja Turtles : 216, The Lonely Mutation of Baxter PA0001933313 2014 Stockman. Teenage Mutant Ninja Turtles : 217, Newtralized! PA0001933305 2014 Teenage Mutant Ninja Turtles : 219, Pizza Face. PA0001933317 2014 Teenage Mutant Ninja Turtles : 220, The Legend of Kuro Kabuto. PA0001933309 2014 Teenage Mutant Ninja Turtles : 221, Plan 10. PA0001933314 2014 Teenage Mutant Ninja Turtles : 222, Vengeance is Mine. PA0001933319 2014 Teenage Mutant Ninja Turtles : 223, A Chinatown Ghost Story. PA0001933303 2014 Teenage Mutant Ninja Turtles : 224, Into Dimension X! PA0001933316 2014 Teenage Mutant Ninja Turtles : 225, The Invasion: Part 1. PA0001933310 2014 Teenage Mutant Ninja Turtles : 226, The Invasion: Part 2. PA0001933312 2014 Teenage Mutant Ninja Turtles : 301. PA0001932533 2014 Teenage Mutant Ninja Turtles : 302. PA0001932534 2014 Teenage Mutant Ninja Turtles : 303. PA0001932495 2014 Teenage Mutant Ninja Turtles : 304, The Croaking. PA0001948507 2014 Teenage Mutant Ninja Turtles : 305, In Dreams. PA0001948509 2014 Teenage Mutant Ninja Turtles : 306, Race with the Demon. PA0001948510 2014 Teenage Mutant Ninja Turtles : 307, Eyes of the Chimera. PA0001948506 2015 Teenage Mutant Ninja Turtles : 308, Vision Quest. PA0001948501 2015 Teenage Mutant Ninja Turtles : 309, Return to New York. PA0001948505 2015 Teenage Mutant Ninja Turtles : 310, Serpent Hunt. PA0001948504 2015 Teenage Mutant Ninja Turtles : 311. PA0001956438 2015 Teenage Mutant Ninja Turtles : 312. PA0001956442 2015 Teenage Mutant Ninja Turtles : 313. PA0001956441 2015 Teenage Mutant Ninja Turtles : 314. PA0001956437 2015 Teenage Mutant Ninja Turtles : 315. PAu003776027 2015 Teenage Mutant Ninja Turtles : 316. PAu003777722 2015 Teenage Mutant Ninja Turtles : 317. PAu003777093 2015 Teenage Mutant Ninja Turtles : 318, THE DEADLEY VENOM. PA0001958995 2015 Teenage Mutant Ninja Turtles : 319. PAu003779210 2015 Teenage Mutant Ninja Turtles : 320. PAu003780328 2015 Teenage Mutant Ninja Turtles : 321. PAu003783359 2015 Teenage Mutant Ninja Turtles : 322, The Creeping Doom. PAu003782665 2015 Teenage Mutant Ninja Turtles : 323. PAu003782573 2015 Teenage Mutant Ninja Turtles : 325. PA0001979533 2015 Teenage Mutant Ninja Turtles : 326. PA0001979531 2015 Teenage Mutant Ninja Turtles: 35 Years of TMNT Toolkit. VAu001373751 2019 Teenage Mutant Ninja Turtles : 401. PA0001971691 2015 Teenage Mutant Ninja Turtles : 402. PA0001971701 2015 Teenage Mutant Ninja Turtles : 403. PA0001971698 2015 Teenage Mutant Ninja Turtles : 404, The Outlaw Armaggon. PA0001977321 2015 Teenage Mutant Ninja Turtles : 405, Riddle of the Ancient Aeons. PA0002046454 2016 Teenage Mutant Ninja Turtles : 406, Journey to the Center of Mikey's PA0001977328 2016 Mind. Teenage Mutant Ninja Turtles : 407. PA0001979534 2016 Teenage Mutant Ninja Turtles : 408. PA0001979536 2016 Teenage Mutant Ninja Turtles : 415. PA0002039057 2016 Teenage Mutant Ninja Turtles : 416. PA0002039060 2016 Teenage Mutant Ninja Turtles : 417. PA0002038625 2016 Teenage Mutant Ninja Turtles : 418. PA0002038626 2016 Teenage Mutant Ninja Turtles : 419. PA0002038635 2016 Teenage Mutant Ninja Turtles : 420. PA0002038640 2016 Teenage Mutant Ninja Turtles : 421. PA0002038647 2016 Teenage Mutant Ninja Turtles : 422. PA0002038650 2016 Teenage Mutant Ninja Turtles : 423. PA0002038660 2017 Teenage Mutant Ninja Turtles : 424. PA0002039046 2017 Teenage Mutant Ninja Turtles : 425. PAu003838606 2017 Teenage Mutant Ninja Turtles : 426. PAu003838607 2017 Teenage Mutant Ninja Turtles : 501. PAu003836340 2017 Teenage Mutant Ninja Turtles : 502. PAu003836334 2017 Teenage Mutant Ninja Turtles : 503. PAu003836302 2017 Teenage Mutant Ninja Turtles : 504. PAu003836303 2017 Teenage Mutant Ninja Turtles: A Green Christmas - Fall/Winter 2014 VAu001188363 2014 Seasonal Guide. Teenage Mutant Ninja Turtles: Bebop & Rocksteady Styleguide. VAu001257397 2016 Teenage Mutant Ninja Turtles: Beyond The Known Universe. PA0002042377 2016 Teenage Mutant Ninja Turtles Branding Guide. VAu001188355 2014 Teenage Mutant Ninja Turtles - Character Art Style: Comic Origins. VAu001194673 2013 Teenage Mutant Ninja Turtles: Classic Turtles - Turtles in Training: 2014 VAu001187653 2014 Girls' & Juniors' Fast Fashion Pack. Teenage Mutant Ninja Turtles, Cowabunga Christmas. PA0002009161 2015 Teenage Mutant Ninja Turtles: DimensionX Spring/Summer 2016 Seasonal VAu001230757 2015 Guide. Teenage Mutant Ninja Turtles : Earth's Last Stand. PA0002100400 2016 Teenage Mutant Ninja Turtles : Enter Shredder. PA0001867812 2013 Teenage Mutant Ninja Turtles - Fall/Winter 2013 Hook Book. VAu001118391 2012 Teenage Mutant Ninja Turtles: Fall/Winter 2016 Back to the Sewer. VAu001230758 2015 Teenage Mutant Ninja Turtles: Fast Fashion 2014 Baby/Toddler - Tiny VAu001188225 2014 Mutant Ninja Turtles. Teenage Mutant Ninja Turtles: Fast Fashion 2014 Girls/Juniors Skater Girl. VAu001188238 2014 Teenage Mutant Ninja Turtles: Fast Fashion 2014 Kids - Turtles Comic. VAu001188121 2014 Teenage Mutant Ninja Turtles - For The Fans! Spring/Summer 2014 VAu001194666 2013 Seasonal Guide. Teenage Mutant Ninja Turtles Free Comic Book Day 2017. VA0002112282 2017 Teenage Mutant Ninja Turtles Funko Universe (with 3 cover editions) VA0002112339 2017 Teenage Mutant Ninja Turtles: Half-Shell Heroes 2015 Packaging Guide. VAu001230632 2015

Teenage Mutant Ninja Turtles: Half-Shell Heroes 2016 Supplement Guide. VAu001230652 2015 Teenage Mutant Ninja Turtles: Half-Shell Heroes - Blast To The Past. PA0002024875 2016 Teenage Mutant Ninja Turtles: Half-Shell Heroes - Blast to the Past 2016 VAu001257394 2016 Supplement Guide. Teenage Mutant Ninja Turtles: Half-Shell Heroes Little Dudes VAu001257403 2016 Spring/Summer 2017 Seasonal Guide . Teenage Mutant Ninja Turtles - Holiday 2013 Supplement Guide. VAu001118390 2012 Teenage Mutant Ninja Turtles Holiday Heroes - Fall/Winter 2015 Seasonal VAu001188345 2014 Guide. Teenage Mutant Ninja Turtles: Hypersport Spring/Summer 2016 Seasonal VAu001230622 2015 Guide. Teenage Mutant Ninja Turtles: Maxin' and Shellaxin' - Fall/Winter 2014 VAu001188361 2014 Seasonal Guide. Teenage Mutant Ninja Turtles: Mini Pizza Spring/Summer 2017 Seasonal VAu001257399 2016 Guide. Teenage Mutant Ninja Turtles, Mutagen Mayhem. PA0001904038 2014 Teenage Mutant Ninja Turtles: Ninja Moves - Fall/Winter 2016 Seasonal VAu001230653 2015 Guide. Teenage Mutant Ninja Turtles: NYC Showdown. PA0001967482 2015 Teenage Mutant Ninja Turtles: Ooze Control - 2015 Fall/Winter Seasonal VAu001187277 2014 Guide. Teenage Mutant Ninja Turtles: Out of the Shadows Styleguide. VAu001373746 2019 Teenage Mutant Ninja Turtles Packaging Guide. VAu001188362 2014 Teenage Mutant Ninja Turtles: Property Universe Mythology (2nd Edition) VAu001188866 2014

Teenage Mutant Ninja Turtles - Property Universe Mythology Styleguide. VAu001211984 2013 Teenage Mutant Ninja Turtles: Pulverizer Power. PA0001967487 2015 Teenage Mutant Ninja Turtles: Retreat! PA0001974640 2015 Teenage Mutant Ninja Turtles: Return to NYC! PA0002066893 2015 Teenage Mutant Ninja Turtles, Revenge! PA0002065673 2015 Teenage Mutant Ninja Turtles, Rise Of The Turtles. PA0001841106 2013 Teenage Mutant Ninja Turtles: Sewer Surfin' - 2015 Spring/Summer VAu001188223 2014 Seasonal Guide. Teenage Mutant Ninja Turtles: Shell Skater - 2015 Spring/Summer VAu001188278 2014 Seasonal Guide. Teenage Mutant Ninja Turtles: Shell Skater - 2015 Spring/Summer VAu001188134 2014 Seasonal Guide. Teenage Mutant Ninja Turtles: Shellin' Out Justice - 2015 Fall/Winter VAu001188132 2014 Seasonal Guide. Teenage Mutant Ninja Turtles : Showdown in Dimension X. PA0001954698 2014 Teenage Mutant Ninja Turtles: Space Ninjas Spring/Summer 2017 Seasonal VAu001257351 2016 Guide. Teenage Mutant Ninja Turtles style guide supplement. VAu001188337 2014 Teenage Mutant Ninja Turtles: Tales of the Turtles 400 Tool Kit. VAu001330232 2018 Teenage Mutant Ninja Turtles: Techniques Supplement. VAu001188100 2014 Teenage Mutant Ninja Turtles: The Beginning - The Complete 1st Season. PA0001931807 2014 Teenage Mutant Ninja Turtles, The Good, The Bad & Casey Jones. PA0001925048 2014 Teenage Mutant Ninja Turtles: The IDW Collection, Volume 4. VA0002112909 2017 Teenage Mutant Ninja Turtles: The Search For Splinter. PA0001967486 2015 Teenage Mutant Ninja Turtles: Totally Turtles 2 Pack! PA0001886780 2013 Teenage Mutant Ninja Turtles Trickster Treats - Fall/Winter 2015 Seasonal VAu001188343 2014 Guide. Teenage Mutant Ninja Turtles: Turtle Power Reading. TX0008234885 2016 Teenage Mutant Ninja Turtles Turtle Power! Styleguide. VAu001188358 2014 Teenage Mutant Ninja Turtles - Ultimate Showdown. PA0001868532 2013 Teenage Mutant Ninja Turtles Universe #10 (with 3 cover editions) VA0002111702 2017 Teenage Mutant Ninja Turtles: Varsity Grunge. VAu001187667 2014 Teenage Mutant Ninja Turtles: XMELO Styleguide. VAu001257343 2016 Teenage Mutant Ninja Turtles: Xtreme Green Spring/Summer 2017 VAu001257333 2016 Seasonal Guide. X-FILES/ TEENAGE MUTANT NINJA TURTLES: CONSPIRACY - #1 VA0001923453 2014 (TV - COMIC BOOK)