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Home , XV (rapper)

Electronically FILED by Superior Court of California, County of Los Angeles on 06/24/2021 11:56 AM Sherri R. Carter, Executive Officer/Clerk of Court, by D. Williams,Deputy Clerk 21STCV23514 Assigned for all purposes to: Stanley Mosk Courthouse, Judicial Officer: Kevin Brazile

1 BIRD, MARELLA, BOXER, WOLPERT, NESSIM, DROOKS, LINCENBERG & RHOW, P.C. 2 Ekwan E. Rhow (State Bar No. 174604) [email protected] 3 1875 Century Park East, 23rd Floor Los Angeles, California 90067-2561 4 Telephone: (310) 201-2100 Facsimile: (310) 201-2110 5 PRYOR CASHMAN LLP 6 Michael J. Niborski (State Bar No. 192111) [email protected] 7 1801 Century Park East, 24th Floor Los Angeles, California 90067 8 Telephone: 310-683-6900 Facsimile: 310-943-3397 9 Brad D. Rose (pro hac vice application forthcoming) 10 [email protected] Dyan Finguerra-DuCharme (pro hac vice application forthcoming) 11 [email protected] 7 Times Square

12 New York, New York 10706

Telephone: 212-421-4100

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- Attorneys for Plaintiffs

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683 14 KANYE WEST and YEEZY LLC

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(310) (310) 15 SUPERIOR COURT OF THE STATE OF CALIFORNIA : : eles,California 90067 16 FOR THE COUNTY OF LOS ANGELES, CENTRAL DISTRICT

Pryor Cashman Facsimile Telephone: (310) 17 Case No.

Los AngLos )

1801 Century Floor Park24th East, ) 18 KANYE WEST, an individual, and YEEZY ) COMPLAINT FOR: LLC, a Delaware limited liability company, ) 19 ) (1) UNFAIR COMPETITION – VIOLATION OF CAL. BUS. & PROF. Plaintiffs, ) 20 ) CODE §§17200 ET. SEQ.; ) 21 vs. ) AND ) 22 WALMART INC., a Delaware corporation, and ) (2) QUANTUM MERUIT DOES 1-10, inclusive, ) 23 ) Defendants. ) JURY DEMAND 24 ) ) 25 ) ) 26 ) ) 27

2 COMPLAINT

1 Plaintiffs Kanye West (“West”) and Yeezy LLC (“Yeezy,” and together with West,

2 “Plaintiffs”), by and through their undersigned counsel of record, as and for their Complaint 3 against defendant Walmart Inc. (“Walmart” or “Defendant”) hereby allege as follows: 4 PRELIMINARY STATEMENT 5 1. This is an action for violation of California Business & Professions Code § 17200 6 and unjust enrichment based upon Walmart’s willfully trading off the renown of Kanye West and 7 his iconic YEEZY brand. ® 8 2. West, the Grammy Award-winning recording artist, fashion designer and

9 entrepreneur, introduced the distinctive YEEZY FOAM RUNNER footwear in 2019. Debuted by 10 West’s daughter, the YEEZY FOAM RUNNER immediately garnered significant attention in the 11 footwear industry, becoming synonymous in the minds of consumers with West and the YEEZY

12 brand.

3. Walmart is flagrantly trading off of West’s and the YEEZY brand’s popularity by

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offering for sale an imitation version of the YEEZY FOAM RUNNER:

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eles,California 90067 16

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Telephone: (310) 17

Los AngLos 1801 Century Floor Park24th East, 18 19 20

21 YEEZY FOAM RUNNER Walmart Imitation Shoe 22

23 4. Consumers are purchasing the imitation YEEZY FOAM RUNNER footwear from 24 Walmart on the mistaken belief that the shoes are associated with West and the YEEZY brand, as 25 evidenced by comments on the Walmart website and on social media. 26 5. Walmart’s conduct is harming, and will continue to harm, West and Yeezy, leaving 27 Plaintiffs no choice but to commence the instant action to stop Walmart’s unfair competition and 28 profiting from the popularity and success of West and the YEEZY brand. The YEEZY brand is a 1 1 2 COMPLAINT

1 multi-billion dollar brand, and the harm caused to Plaintiffs on account of Walmart’s illegal

2 activities is, upon information and belief, potentially valued in the hundreds of millions of dollars. 3 PARTIES 4 6. Kanye West is a resident of Wyoming as well as the managing member of Yeezy 5 LLC. 6 7. Yeezy LLC is a Delaware limited liability company with a principal place of 7 business in La Palma, California. 8 8. Upon information and belief, Walmart Inc. is a Delaware corporation with a

9 principal place of business in Bentonville, Arkansas. 10 9. Plaintiffs are ignorant of the true names and capacities of defendants sued herein as 11 Does 1 through 10, inclusive, and therefore sues these defendants by these fictitious names.

12 Plaintiffs will amend this Complaint to allege their true names and capacities when ascertained.

13 Upon information and belief, each of the fictitiously named defendants is responsible in some

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683 14 manner for the occurrences herein alleged, and Plaintiffs’ damages as herein alleged were

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eles,California 90067 16 10. All references to “Defendants” hereafter shall be deemed to include Walmart and

Pryor Cashman Facsimile

Telephone: (310) 17 Does 1-10, and each of them, unless otherwise specifically alleged.

Los AngLos 1801 Century Floor Park24th East, 18 11. At all times mentioned herein, Defendants are and were the alter egos of each other, 19 in that a unity of interest exists between Defendants such that the maintenance of the separate 20 existence between Defendants would constitute a sham and perpetration of a fraud upon the public

21 and creditors of Defendants. As evidence of the lack of separateness of Defendants, Plaintiffs 22 allege the following on information and belief: Defendants failed to adequately capitalize for their

23 intended purpose or in light of their anticipated debts and obligations; Defendants failed to 24 maintain or conduct annual meetings as required by contract or applicable law; and Defendants 25 co-mingled funds. In light of the absence of any separate existence, Defendants are jointly and 26 severally liable for the wrongdoing alleged herein. 27 12. At all times mentioned herein, Defendants, and each of them, were the agents, joint 28 venturers, partners, representatives, or employees of each other and, in doing (or failing to do) the

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1 things alleged herein, were acting within the course, purpose, and scope of their agency, joint

2 ventures, partnerships, representations, or employment. The acts, omissions, conduct, and 3 relationships alleged herein of each of Defendants were known to, authorized and ratified by each 4 and every other of Defendants. It is further alleged, in the alternative, that some or each of 5 Defendants acted at times independently of all other of Defendants to cause damage and injury to 6 Plaintiffs. 7 VENUE AND JURISDICTION 8 13. This Court has personal jurisdiction over Walmart because, upon information and

9 belief, Walmart is doing business in California, the claims at issue arise out of Walmart’s acts that 10 took place in California or were directed to consumers residing in California, and/or Walmart 11 engaged in acts of unfair competition outside of California that caused injury to Plaintiffs in

12 California.

13 14. Venue is proper in this Court pursuant to Cal. Civ. Proc. Code § 395(a).

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683 14 STATEMENT OF FACTS 943

A. Mr. Kanye West

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eles,California 90067 16 15. Kanye West is an internationally renowned Grammy® Award-winning musical

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Telephone: (310) 17 artist, performer, media company owner, inventor, songwriter, producer, and fashion designer.

Los AngLos 1801 Century Floor Park24th East, 18 West has been described by multiple sources as one of the most acclaimed artists of the 21st 19 century. 20 16. To date, West has released nine full-length studio albums, and has sold over 21

21 million albums and 100 million digital songs in the United States, making him one of the best- 22 selling artists of all-time. West’s first seven albums, all of which have gone platinum, have

23 received numerous awards, including 21 Grammy Awards. West was ranked by Billboard 24 magazine as one of the top 10 music producers of the decade and was ranked third in BET’s “Top 25 Ten Rappers of the 21st Century” list. These are just a few of the industry awards and accolades 26 that West has earned. 27 28

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1 17. West’s talent and notoriety is recognized around the world. He has been named

2 one of the 100 most influential people by Time magazine, and Forbes routinely lists West as one 3 of the most successful people in the world. 4 18. West operates a Twitter social media account using the “@KanyeWest” handle that 5 is immensely popular with over 29 million followers. West commonly posts about his YEEZY 6 products and those tweets are routinely retweeted by his followers. 7 19. West’s notoriety expands well beyond music as he sets trends for everything he 8 touches. He has launched his own clothing lines, including his highly-coveted YEEZY fashion

9 line. West has also designed and/or developed footwear with major footwear and sneaker 10 companies, and even designed a shoe collection for high-end fashion designer Giuseppe Zanotti. 11 20. West’s massive following knows him as “YEEZY,” a pseudonym that West

12 adopted in 2009. The YEEZY name functions as a source-identifying trademark for goods and

13 services emanating from Plaintiffs.

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683 14 21. Few people have attained the fame achieved by West. Simply put, Kanye West is

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(310) (310) 15 a household name, and the YEEZY brand, which has become synonymous with West, has become : :

eles,California 90067 16 one of the most influential and successful brands in fashion.

Pryor Cashman Facsimile

Telephone: (310) 17 B. The YEEZY Brand

Los AngLos 1801 Century Floor Park24th East, 18 22. Plaintiffs created the YEEZY fashion brand (a/k/a YZY) and offer footwear, 19 apparel and bags for all genders. The YEEZY brand has been labeled one of the most influential 20 brands in fashion, including by Business Insider.

21 23. Plaintiffs have sold bags, footwear and apparel bearing the YEEZY and YZY 22 marks since at least as early as 2015.

23 24. The YEEZY brand has been credited with paving the way for some major trends in 24 the fashion industry. The YEEZY BOOST 750 sneakers set-off a global consumer sensation, 25 serving as the first product drop born of the collaboration between Adidas and Plaintiffs. Designed 26 with Adidas BOOST cushioning technology, the model combines the ultimate in comfort and 27 performance with high-end style. The YEEZY BOOST 750 was an unprecedented alliance that 28 made history as the most significant partnership ever created between a non-athlete and an athletic

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1 brand. The product redefined the future by uniting Adidas’ technical, innovative expertise and

2 capabilities with the visionary imagination of West. 3 25. As a follow-up, Plaintiffs and Adidas launched the YEEZY BOOST 350 sneaker, 4 which went on to become one of the most sought-after and fastest-selling footwear models in 5 history. The low-top model unites a BOOST cushioning sole and Adidas’ Primeknit material with 6 West’s pioneering aesthetic. The resulting design led to a consumer frenzy, followed by 7 unprecedented sales. The CEO of Adidas explained that “[t]he Yeezy brand has a fundamental 8 impact on our overall brand position.” In 2015, Forbes wrote that the YEEZY sneakers have

9 arguably become “the most sought-after sneakers in pop culture next to the Jordan Brand.” 10 26. GQ deemed the YEEZY Boost 350 shoes, which were first released in 2015, as the 11 most influential sneakers of 2016. In 2015, Footwear News, the renowned fashion news source,

12 honored West with the “Shoe of the Year” Award, acknowledging the success and cultural imprint

13 of the YEEZY brand. In explaining its decision, Footwear News stated that “The [YEEZY]

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683 14 sneaker releases dominated the market in 2015, as demand for the product crashed servers, sparked

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(310) (310) 15 extraordinary resale value, and created a need for mob control in stores.” Plaintiff’s YEEZY Boost : :

eles,California 90067 16 350 sneakers, priced at around $200, sell out in just minutes, and pairs of his sneakers have resold

Pryor Cashman Facsimile

Telephone: (310) 17 for more than $10,000 dollars on eBay. Forbes has praised the success of the YEEZY brand,

Los AngLos 1801 Century Floor Park24th East, 18 stating the “[YEEZY] shoes have transcended the role of style accessory and shifted into the role 19 of cultural necessity.” 20 27. To offer some context in which to evaluate the relative positioning of the YEEZY

21 brand within the fashion industry and the success of its promotional efforts, as reported by the 22 Hollywood Reporter in 2017, according to Lyst and Business of Fashion’s “Hot Brand Index,” a

23 new quarterly report compiled by the two companies that takes into account “search, page views 24 (across devices), engagement, intent rate and conversion,” GUCCI and YEEZY are the “hottest 25 brands in the world” in luxury fashion. The Hollywood Reporter explained that “Yeezy’s fire 26 power is to be expected too, as the brand combines two of fashion’s biggest trends — luxury 27 streetwear and a celebrity creative director.” According to Lyst’s 2018 rankings, the YEEZY 28 Boost 350 V2 sneakers were ranked in top 5 of the “hottest sneakers” based on “search, sales, and

1 5 2 COMPLAINT

1 page views combined” and YEEZY ranked in the top 5 of “hottest brands” in Q3 of 2018.

2 According to a February 2019 article by GQ magazine, YEEZY sneakers are a “top-ten selling 3 shoe” and have been considered “the most desirable shoe in the world.” The YEEZY brand has 4 had continuous, unprecedented success in the fashion industry since it launched. 5 28. Yeezy and its licensees have expended substantial amounts of time and have 6 invested substantial sums in marketing and promoting YEEZY and YZY branded goods, including 7 footwear. 8 29. Each year, the YEEZY and YZY products receive billions of impressions through

9 its marketing campaigns and through unsolicited media attention. 10 30. Based on Plaintiffs’ significant and extensive marketing campaigns, and West’s 11 worldwide marketplace success in both the entertainment industry and fashion world, the YEEZY

12 brand has become well-known for its high quality, style, and authenticity and its close association

13 with West.

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683 14 31. The YEEZY brand is often the subject of widespread media attention and has been

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(310) (310) 15 featured in prominent magazines and newspapers, including, but not limited to, The New York : :

eles,California 90067 16 Times, Vogue, and GQ. Celebrities are regularly photographed wearing YEEZY clothing and

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Telephone: (310) 17 footwear and using YEEZY products, which enhances the brand’s popularity and appeal to the

Los AngLos 1801 Century Floor Park24th East, 18 general public. Celebrities that have been photographed by the press wearing and using YEEZY 19 products include Kim Kardashian West, Justin Bieber, Ariana Grande, Jay Z, Calvin Harris, 20 Pharrell Williams, Snoop Dogg, Nick Jonas, Joe Jonas, Gigi Hadid, Bella Hadid, Hailey Baldwin,

21 Karlie Kloss, Jada Pinkett Smith, Kylie Jenner and Kendall Jenner. 22 32. In 2019, Plaintiffs raised money for one of America’s leading mental health

23 charities, America’s National Alliance on Mental Illness, via a series of pop-up YEEZY “lemonade 24 stands” throughout the United States. Partnering with Adidas, Plaintiffs’ ‘Yeezy Stands’ had 25 people selling limited pairs of Plaintiffs’ unreleased sneakers – the YEEZY Boost 700 V2 ‘Geode’. 26 C. The YEEZY FOAM RUNNER 27 Building on the success of the previous collaboration between West and Adidas, West and 28 Adidas developed the unique and distinctive YEEZY FOAM RUNNER. The YEEZY FOAM

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1 RUNNER is a slip-on shoe that employs a flexible one-piece build constructed from algae – a

2 decision stemmed from West’s commitment to producing a more sustainable product – as well as 3 EVA Foam. It features a clog-like silhouette punctuated with cutouts of varying sizes and shapes 4 along the sides and top of the shoe (the “YEEZY FOAM RUNNER Trade Dress”), as illustrated 5 by the images below, depicting the YEEZY FOAM RUNNER in an array of colors:

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: : eles,California 90067

16 33. The YEEZY FOAM RUNNER footwear made its official public debut on June 26,

Pryor Cashman Facsimile Telephone: (310) 17

Los AngLos 2020, through a surprise drop exclusively on Plaintiffs’ Yeezy Supply website. It retailed at $75.00 1801 Century Floor Park24th East, 18 USD and sold out instantly, and, upon information and belief, now sits at three times its initial 19 price on the resell market. 20 D. Walmart’s Knock-Off Foam Runner 21 34. Walmart is currently selling an imitation of the original and distinctive YEEZY

22 FOAM RUNNER (the “Imitation Shoe”), which is an unauthorized exact copy of the YEEZY 23 FOAM RUNNER in every respect, including the clog-silhouette, foam slip-on body, and 24 25 26 27 28

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1 characteristic varying-sized cutouts on the sides and top of the shoe. A comparison of the YEEZY

2 FOAM RUNNER and Walmart’s Imitation Shoe illustrate that they are virtually indistinguishable: 3 4 5 6 7

8 YEEZY FOAM RUNNER Walmart Imitation Shoe 9

10 35. In particular, both shoes feature three teardrop-shaped cutouts in decreasing size 11 from back to front, from the heel to the middle of the shoe, with three stacked curved lines

comprised of wide, short ovals over the smallest teardrop-shaped cutout along the side of the shoe,

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LLP with two eye-shaped cutouts on the side of the toe, a diamond-shaped pattern of undulating lines

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with oval cutouts on the top of the shoe, and identically textured bottoms, as further illustrated by

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eles,California 90067 the below side-by-side comparison of the parties’ products: 16

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Telephone: (310) 17 Los AngLos

1801 Century Floor Park24th East, 18

22 YEEZY FOAM RUNNER YEEZY FOAM RUNNER 23 24 25 26 27 28

1 8 2 COMPLAINT

2 3 4 5 6

7 Walmart Imitation Shoe Walmart Imitation Shoe 8

9 36. The fact that Walmart is trading off of West’s and the YEEZY brand’s popularity 10 is evident from the many consumer comments on Walmart’s website referencing West, the 11 YEEZY FOAM RUNNER, and the YEEZY brand in connection with the Imitation Shoe.

12 Representative examples are shown below:1

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eles,California 90067 16

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Los AngLos 1801 Century Floor Park24th East, 18 19

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26 1 See https://www.walmart.com/ip/Daeful-Mens-Womens-Kids-Summer-Beach-Shoes-Foam- Runner-Anti-Slipper-Sandals-Casual-Beige/226875605; https://www.walmart.com/ip/Daeful- 27 Adult-Children-Summer-Beach-Shoes-Foam-Runner-Anti-Slipper-Sandals-Casual- Color/416297212?selected=true and https://www.walmart.com/ip/Daeful-Adult-Children- 28 Summer-Beach-Shoes-Foam-Runner-Anti-Slipper-Sandals-Casual-Color/655015613 1 9 2 COMPLAINT

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Telephone: (310) 17 Los AngLos

1801 Century Floor Park24th East, 18 19 True and correct copies of consumer comments from the Walmart website associating the Imitation 20 Shoe with Kanye West and the YEEZY brand are attached hereto as Exhibit A.

21 37. In fact, these consumer comments make clear that many consumers purchased the 22 Imitation Shoe only because of its association with West and the YEEZY brand, and further, that

23 consumers likely would have purchased the YEEZY FOAM RUNNER were it not for the cheaper 24 knock-off Imitation Shoe. Thus, Walmart’s unfair competition has caused Plaintiffs to lose market 25 share they otherwise would have had. 26 38. The consumer comments on Walmart’s own website should have alerted Walmart 27 to the presence of an imitation good being sold on its website. 28

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1 39. Numerous posts on social media sites also indicate that many consumers

2 mistakenly believe that the Imitation Shoe in fact emanates from West or the YEEZY brand, or 3 that they are purchasing the Imitation Shoe solely because it is a cheap knock-off of the popular 4 YEEZY FOAM RUNNER. Examples of such posts from Twitter are shown below: 5 6 7 8

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Los AngLos 1801 Century Floor Park24th East, 18 19 20

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24 25 True and correct copies of additional social media posts associating the Imitation Shoe with Kanye 26 West and the YEEZY brand are attached as Exhibit B. 27 40. Not only are Plaintiffs losing market share for their authentic YEEZY FOAM 28 RUNNER, but also their reputation and the goodwill of the YEEZY brand is being harmed by the

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1 association with the Imitation Shoe given its subpar quality, as evidenced by the consumer

2 comments shown below from the Walmart website:2 3 4 5 6

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Los AngLos 1801 Century Floor Park24th East, 18 19

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23 True and correct copies of additional negative consumer reviews of the Imitation Shoe from the 24 Walmart website are attached hereto as Exhibit C. 25

26 2 See https://www.walmart.com/ip/Daeful-Mens-Womens-Kids-Summer-Beach-Shoes-Foam- 27 Runner-Anti-Slipper-Sandals-Casual-Beige/226875605; https://www.walmart.com/ip/Daeful- Adult-Children-Summer-Beach-Shoes-Foam-Runner-Anti-Slipper-Sandals-Casual- 28 Color/416297212?selected=true and https://www.walmart.com/ip/Daeful-Adult-Children- Summer-Beach-Shoes-Foam-Runner-Anti-Slipper-Sandals-Casual-Color/655015613 1 12 2 COMPLAINT

1 41. In sum, Walmart’s unfair competition is causing Plaintiffs economic harm in the

2 form of diminished sales of the YEEZY FOAM RUNNER as well as harm to Plaintiffs’ reputation 3 and its property in the form of the YEEZY brand. The YEEZY brand is a multi-billion dollar 4 brand, and the harm caused to Plaintiffs on account of Walmart’s illegal activities is, upon 5 information and belief, potentially valued in the hundreds of millions of dollars. 6 42. On June 23, 2021, counsel for Plaintiffs transmitted to Walmart a Notice of Claimed 7 Infringement (“NOCI”) demanding that Walmart immediately remove from walmart.com all of 8 the YEEZY FOAN RUNNER Imitation Shoes available on the walmart.com platform. To date,

9 Walmart has either failed or refused to comply with Plaintiffs’ NOCI demand, constraining 10 Plaintiffs to commence the instant action to vindicate their rights in this Court. 11 FIRST CAUSE OF ACTION

12 (Unfair Competition under California Business & Professions §§17200, et. seq.)

13 43. Plaintiffs repeat and reallege paragraphs 1 through 42 and incorporate them as

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683 14 though fully set forth herein. 943

44. Defendants have committed acts of unfair competition as defined by the California

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eles,California 90067 16 Business and Professions Code Sections 17200 et seq. (the “Unfair Competition Law”) in

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Telephone: (310) 17 performing the acts described herein because these practices and acts were unfair, unlawful, or

Los AngLos 1801 Century Floor Park24th East, 18 fraudulent. 19 45. Defendants sold an imitation version of the popular and distinctive YEEZY FOAM 20 RUNNER, notwithstanding comments by consumers that were or should have been sufficient to

21 alert Walmart to the presence of imitation goods on its website. Further, Walmart traded off of 22 the popularity and goodwill of West and the YEEZY brand in marketing, selling, and profiting

23 from the sale of the Imitation Shoe. 24 46. In particular, but not exclusively, Defendants’ conduct as set forth above was unfair 25 within the scope of the Unfair Competition Law because it was immoral, unethical, oppressive, 26 and/or unscrupulous in that it was designed to confuse consumers and profit off of the YEEZY 27 brand’s and Kanye West’s popularity and fame. 28

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1 47. Moreover, and also not exclusively, Defendants’ conduct as set forth above was

2 unlawful in that it was in violation of applicable federal and state law, including the Lanham Act 3 and California’s False Advertising Laws (Business and Professions Code Section 17500 et seq.). 4 48. Additionally, Defendants’ conduct as set forth above also constitutes unfair, 5 deceptive, untrue or misleading advertising in that it intentionally confuses consumers as to the 6 origins of the Imitation Shoe and its (non-existent) relationship to West and the YEEZY brand. In 7 that same regard Defendants’ conduct further constitutes a violation of California’s “False 8 Advertising Law,” which prohibits public dissemination of any untrue or misleading advertising

9 in connection with the sale of goods. 10 49. Defendants’ unfair and unlawful conduct has directly caused economic harm to 11 Plaintiffs, including by depriving them of market share for their authentic YEEZY FOAM

12 RUNNER, harming the goodwill of the YEEZY brand, and otherwise diminishing the value of

13 West’s and Yeezy’s present or future intellectual property interests.

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683 14 50. In addition, California consumers have been harmed as a direct, foreseeable and

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(310) (310) 15 proximate result of Defendants’ unfair, unlawful, or fraudulent conduct, and are threatened with : :

eles,California 90067 16 continued harm in the nature of, among other things, further consumer confusion.

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Telephone: (310) 17 51. As a consequence of Defendants’ violations of California’s Unfair Competition

Los AngLos 1801 Century Floor Park24th East, 18 Law, Plaintiffs have been harmed and damaged in an amount to be determined at trial. 19 52. Plaintiffs seek restitution or disgorgement of Defendants’ profits as well as 20 injunctive relief enjoining Defendants, their officers, agents, and employees, and all persons acting

21 in concert with them, from sale of the Imitation Shoe or any substantially similar product. 22 SECOND CAUSE OF ACTION

23 (Quantum Meruit) 24 53. Plaintiffs repeat and reallege paragraphs 1 through 52 and incorporate said 25 paragraphs as though fully set forth herein. 26 54. By trading off of West’s and the YEEZY brand’s popularity and goodwill to 27 increase sales of the Imitation Shoe, without authorization or compensation to Plaintiffs, 28 Defendants have unjustly enriched themselves to the detriment of Plaintiffs.

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EXHIBIT A Comments from https://www.walmart.com/ip/Daeful-Mens-Womens-Kids-Summer-Beach- Shoes-Foam-Runner-Anti-Slipper-Sandals-Casual-Beige/226875605:

C Iwalmart.comiip/Daeful-Mens-Womens-Kids-Summer-Beach-Shoes-Foarn-Runner-Anti-Slipper-Sandals-Casual-Beige/226875605 011

Customer Comments

What others said when purchasing this item

Nice looking Yeezy look

Jimmie, purchased on June 22, 2021 Report Pattrice, purchased on June 22, 2021 &Pc, -.t

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Customer Comments What others said when purchasing this item

Son wanted them to mow lawn. Kayne West designed these.

Mariane, purchased on June 20, 2021 Rt= effie. purchased on June 17. 2021 Bcpv

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Pickup & delivery Walmart_com Walmart;:: 41111=111113 8 Account (-0 My Items

Customer Comments What others said when purchasing this item

Because they are fire! Yezzy inspired

priscilla, purchased on June 9,2021 Boned nynesha. purchased on June 8.2021 Bono

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Customer Comments

What others said when purchasing this item

Cuz of Tik Tok Well they look like the yeezy wich cost alot more and i just want a nice comfrotable shoe and it look like it will do the job so why not Joel. purchased on June 4, 2021 Carlos, purchased on June 4.2021

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Customer Comments What others said when purchasing this item

Bc I like it They look like the Yeezy ones

Daisy. purchased on June 1,2021 Esea ashley, purchased on June 1,2021 Wnuc

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e walmart.com/ip/Daeful-Mens-Womens-Kids-Summer-Beach-Shoes-Foam-Runner-Anti-Stipper-Sandals-Casual-Beige/226875605 :;;; ( )

Customer Comments What others said when purchasing this item

Cause they yeezy Bc there cool kid shoes

Adrian, purchased on May 29,2021 alma eli, purchased on May 28.2021 h'PS't

< 1 ... 12 13 14 15 16 Customer comments from https://www.walmart.com/ip/Daeful-Adult-Children-Summer-Beach- Shoes-Foam-Runner-Anti-Slipp_er-Sandals-Casual-Color/416297212:

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Customer Comments What others said when purchasing this item

Bc they are dope as fack Because I LOVE YEEZY

chelsie, purchased on June 22. 2021 Pima Jair, purchased on June 19.2021 6t129.a

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<- C 121. Iwalmart.com/ip/Daeful-Adult-Children-Summer-Beach-Shoes-Foam-Runner-Anti-Slipper-Sandals-Casual-Color/416297212 123 0 311.

Customer Comments What others said when purchasing this item

My son has been wanting the yeezy slides but these look similar and are much idk tbh im just broke more affordable. Loren, purchased on June 19.2021 latz.Lt. Cynthia, purchased on June19, 2021 3f.1).ct

< 1 2 3 4 5 ... 10 >

-) C Iwalmart.com/ip/Daeful-Adult-Children-Summer-Beach-Shoes-Foam-Runner-Anti-Slipper-Sandals-Casual-Color/416297212

Customer Comments

What others said when purchasing this item

They're budget Yeezy Foam Runners Kanye vibez

Edgar. purchased on May 27. 2021 F -t. Amanda, purchased on May 26.2021

< 1 ... 6 7 8 9 10 > EXHIBIT B 5:56 I' al SI.'

walmart yeezy -0-

Top Latest People Photos Videos

J. Hall Ahallthedon .1,-, ••• • Y000 what's the link for the Walmart Ikii...... 410 Yeezy slides??

(2x5)ACIes euhGODherself • 1d Boutta cop the Walmart yeezy's

Amir I Clippers In 7 eCE00f... • 3d --- Deku went from shopping at Walmart to Yeezy

Alan S @RealisticSK • 3d Deku's hero costume

Chapter 8 vs chapter 317 Show this thread

Ian Curtis (ianthealienbb • 6d Yeezy foam runners at Walmart 33 5:56

walmart yeezy

Top Latest People Photiv, video,

Ian Curtis _ianthealienbb • 6d Yeezy foam runners at Walmart 11 rbaeful Mens Womens Kids Summer Beach Shoes Foam Runner Anti Slipper Sandals Casual Beige * (2.8) 33 ratings Z comment

neriah nunez @NeriahN • 6/16/21 .1\ Damn they selling yeezy on Walmart?! ali What a cope m A rbaeful Mens Womens Kids Summer Beach Shoes Foam Runner Anti Slipper Sandals Casual Beige ** I (2,5) arilkagi 21 corrtment

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walmart yeezy —0-

Top Latest People Photos Videos

410 @aerijuel • 17h Not Walmart selling the yeezy slidesss 4. omg

Suge Hefner 4 @RolledAmbitio... • 2h Walmart got the yeezy slides. Judge ya momma but not me when you see me in my new wallies

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100% GOONERY @tonemoral • 2d Replying to @imc_x3 Na cuh, i rather wear some Walmart kicks before i step foot in a yeezy, its an overrated shoe period

Slap.I0 ,IH New Site coming this week 3

• Can you guess what it is?

First 2 to guess get an invite to the private beta, we will reveal when this post gets 100 comments. Good luck!

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walmart yeezy

Top Latest People Photos Videos

YeezyMafia @Yeezy Mafia • 4d Walmart •T•

Xavier 'xavier_boldon • 2d Not Walmart sells the yeezy foam runners fp I)

MoBetta @Mo_Betta206 • 23h Walmart got all the Yeezy's for THE nia...,•• LOW!!! Real shit tho...these look soo damn close hahaha

Kenny Jones arelientkenny • 5d i love my walmart yeezy foam runners i bought another pair in another color 4 QtJi

LouTm @ALIFEstyle57- 2d @FullCourtPUMPS y000 did you ever order those Walmart Yeezy slides? Lol

Fine'2 @Fine2_• 22h I'm paying 24.00 for mine only difference in the shoes one is from Walmart 4a) other is yeezy A +110 cpi 5:571 sil

—0- walmart yeezy -0—

Top Latest People Photos Videos

Fines2 @Fine2_•2211 I'm paying 24.00 for mine only difference It1 in the shoes one is from Walmart the other is yeezy

* WheezeKlan Meecs 4- • 6/15/21 Them Walmart foam runners are way better than yeezy Fa.

Angie @Angie1979va • 22h fr: The Walmart knockoff Yeezy's look nice 000. And $20 A Q

*.+ LaChapis ',+ WajiaMexicana • 5d Replying to Qiurelientkenny Walmart low key has some really ea clothes and shoes

Kenny Jones (a relientkenny • 5(1 walmart has the knockoff yeezy foam tc) runners only on their site and i HAD to cop

Sir B. Terrell PitsBTerrell.1(: man... i'm bout to mess around and me some of these. lol tiff 5:57-i

walmart yeezy -0-

Top Latest People Photos Videos

walmart.com Yeezy Inspired Slides - Walmart.com 1

Javi @JaviCoronado_• 20h Walmart got yeezy foams •

LG Bobby Solez @BobbySolez • 5h • 43 Yeezy Foam Runners At Walmart?! •

228 views

cig 1 iKegoEggo @KegoEggo • 2d 4. Just witness a guy buy out a Walma battle style, homie. It was like watchin

, • 5:571

walmart yeezy

Top Latest People Photos Videos

Kenny Jones @relientkenny • 5d f.,13 • i bought the knockoff walmart yeezy foam runners for $23 + free shipping cause i ain't paying $200+ for shoes these things comfortable AF and shoutout to @FullCourtPUMPS for putting me on 5 ee #NoShame #Seel hei hing Is 1

4 U14 C) 28

Show this thread

Costner raAmanciaCost . • 2d VIAmanda You may be cool. But are you enflamed, 401 orange, Walmart-sandals called yeezy, cool?

16 5:58 sol

walmart yeezy -0

Top Latest People Photos Videos

AMBERELLA (aamberellaa • al Since i couldn't get the yeezy slides let ilito me go on Walmart and get the Walmart version 8:52

Desmond's Post • • •

Desmond Reid

If Yall want them new Yeezy Foam Runners Walmart gotem for the Low Low Low can't even tell the difference

daeful mens foam runner [m] aimarr.com Nearesr TO re

4,525 results Sort & filter

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Daeful

Daeful Mens Womens Kids .0. tr.-177i- Summer Beach Shoes Foam * $23.99

- • - Sold and shipped by Anyue Group Inc Free shipping

Colisha

Colisha Mens Womens Kids

Write a comment... 8:51

walmart foam runners

Posts People Groups Photos Videos

Lolor beige

400 17 3 Comments

Eb Like (:) Comment r;› Share

Roman Grimsley ••• 40 Jun 9 • 0 Walmart got knockoff yeezy foam runners for $23 C)4 1 Comment

e) Like Li Comment Share

DizzoDice McElroy ••• Apr 27 • 0 I PRESENT TO U THE NEW AND IMPROVED 2021 STRAINER. AVAILABLE AT A WALMART NEAR U.

* Justin Esmonds Apr 27 • 0

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emorial day sayings I up to 50% off clothing & accessories iaeful )aeful Adult Children Summer Beach Shoes Foar !unner Anti Slipper Sandals Casual Color **** (5.0) 1 rating 1 comment

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Add comment... @ 0 >aeful Adult Children Summer Beach Shoes Foam 'unner Anti Slipper Sandals Casual Color WALMART IS SELLING YEEZY'S? • •

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@wolfyneyda

$20 yeezy s from Walmart ,111,• I bought them! Come back for a review. #shoeto #yeezy #foamrunner #kanyewest #replicasneakers #vir ,4111.)A . • 14 U )0b - @Dante9k Spong(

Add comment... @ 0 8'49 .1 ••••••

THESE ARE SOLID REPLICA FOAM RUNNERS

11P 17.1K

409

#10 @stratussco 6-3 531 Don't Support The Resell Community! • • • Kanye Wanted These To Be $20 Either Way #foamrunner #yezzy #crocs #walmart #hypebeast #replicasneakers

JJ s Incredible - @Kart Life

Add comment... @ 0 8:49 .1 (I= < Search "daeful adult" jcip, Walmart if you want S'ptii?

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66 @tillyksg • • • Walmart foam RNNR vs real foam rnnr quick review #kanye #kanyewest #yeezy 13 id - tillyksg original sou

Add comment... 8:49 00'.4411111

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@revolttully • • • Shoutout Kanye East #TubiTaughtMe #kanyewest #yeezy #shoes #walmart • 13 ind - revolttully original

Add comment... 8:49 SIEN

I bought the Walmart yeezy foam runners

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010 @Iifeofcuzzi #yeezy #kanyetok #kanyewest #walmart #PrimeDayShowPJParty • • • #fyp #fy #foryou #kanyewest #kanye #tiktokmademebuyit #foamrunners n - @Kanye West All Min(

Add comment... Twimet

IDOOPAI @riocuchi am, @kanyewest Walmart stealing ur foam runners, get these mfs outta here

2:02 PM Jun 17, 2021 Twitter Web App we ex race black. :,,juKeboyace 10h tuck designer slides, these the most comfortable

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4.51 AM Jun 24, 2021 Twitter for !Phone Thread

•Daniel 111 DanieIII May 26 Walmart sued Ka nye over a design that just looked "close to the Wal ma rt logo but then they go ahead and sell this. 2 lc) Daeful Adult Children Summer Beach Shoes Foam Runner Anti... $19.99 - $20.99 Sold & shipped by Sansix Inc Free delivery

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Daniel I I Daniell! • May 26 Follow me for more Kanye/music content!

Replies

i'rileyedisonquin - May 26 zorqReplying to 6,1) Da nielll That's literally the exact same shoe lol 4- Tweet

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Kanye should sue the shit out of Walmart for this. TI!

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LaChapis i',MajiaMexicana • Jun 18 • • •

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Kenny Jones • • • relientkenny

Replying to (.4e. Majia Mexicana walmart has the knockoff yeezy foam runners only on their site and i HAD to cop

±59 PM • Jun 18.2021 Twitter for i Phone

1 Like LG Bobby Solez ••• @Bob bySo lez

Yeezy Foam Runners At Walmart?!

138 PM Jun 23, 2021 Twitter for i Phone

1 Retweet 20 Likes 1khirs. gamborab b td re clownl ribs, ttoVr• a. nal WO tore 90

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Walmart Vs Kanye West YZY LLC continues with take Yeezy foam runners now being sold on Walmart website

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Yeezy Foam Runner Reps Sold Or Walmart Site O Thoughts On This Dripveloprnent?

13:32 5i25/21 Twitter tor !Phone 3.* lowlifejoe_

Walmart cauaht biting off of Kanye's Yeezy Foam Runners n

1248 AM May 27, 2021 Twitter for iPhoge

1 Quote Tweet 3 Likes EXHIBIT C 6/24/2021 Product review - Walmart.com

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Customer reviews & ratings

Daeful Mens Womens Kids Summer Beach Shoes Foam Runner Anti Slipper -4;1113 Sandals Casual Beige

2.6 94% **9 ** Recommended 22 ratings (17 of 18)

5 stars 7 4 stars 1 3 stars 1 2 stars 2 1 star 11

Write a review

Most helpful positive review ***** Amazing replica for the foam runners! Sizes are accurate, material is so comfortable, looks exactly like the real deal I definitely recommend if %/nit rInnt want tn rnrI 4ÛÛ fnr th ia roal nair

See more v

https://www.walmaricom/reviews/product/226875605?sort=submissiori-desc 1/7 6/24/2021 Product review - Walmart.corn

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Terrible do not buy quality is terrible sizing is bad idc about 20$ this is worth 20 cents

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22 reviews Sort by: newest to oldest

****w Sizing is to big June 20, 2021 Verified purchase Sizing is to big, order a size down

Tisha

Helpful? Yes (0) No (1) IIReport

,T Slight purple on the inside June 19, 2021 They look very close to the Yeezy Foam Rnners and arre a very god alternative to them they are comft etc My only complaint and its a big one is that after 1 whole day they inside (where my foot was) is turn purple so idk if its the quality or a defect in my pair but if u wanna take the risk go ahead. Now i will be buying another pair just to see if its the same and I will update you!

Likes Appearance, Fit, As a gift, Softness Dislikes Quality

See less ^

billyrocc

Helpful? Yes (0) No (0) I Report

https://i.vww.walmart.com/reviews/product/226875605?sort=submission-desc 2/7 6/24/2021 Product review - Walmart.com

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INIPPRInvrrems- Xv.• X X • X1.11,1.11 Ir. X

Fit is bad and foam broke while wearing. They come off as you step and lean forward. The real ones are so worth it for retail. Don't buy this garbage.

Sam

Helpful? Yes (0) N() Report

***** Amazing replica for the foam runners!

June 15, 2021 Varnasall V'u Sizes are accurate, material is so comfortable, looks exactly like the real deal I definitely recommend if you dont want to spend $400 for the real pair.

Nathan

Helpful? Yes (0) No (0) Report

*****

June 12, 2021 Had purchase Terrible do not buy quality is terrible sizing is bad idc about 20$ this is worth 20 cents

ear

Francisco

Helpful? Yes (0) No (0) Report

***** Worth the price! June 8, 2021 'V/70 Hars;11 lassaahasaa Super comfortable and stylish! Who cares about the pricier version.

christopher

Helpful? Yes (0) No (0) Report

https://www.walmart.com/reviews/product/226875605?sort=submission-desc 3/7 6/24/2021 Product review - Walmart.com

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INIFFRIPireirrr— V VOX • • •••••••1 rgo•I•

Look amazing u can go a half size down but it was about half and inch bigger then expected but still fit

janet

Helpful? Yes (1) No (1) Report

***** Horrible June 2, 2021 Ripped after 20 minutes of wear

David

Helpful? Yes (0) No (0) Report

*****

June 22, 2021 'ierified purchase

chase

Helpful? Yes (0) No (0) Report

*****

June 21, 2021 v(g{fified varchEse

Cristina

Helpful? Yes (0) No (0) Report

*7"--747,+*-

June 19, 2021 V®. filFINd {-112r&11 irc h a as

Brooke

Helpful? Yes (0) No (0) Report

https://www.walmart.com/reviews/product/226875605?sort=submission-desc 417 6/24/2021 Product review - Walmart.com

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raillir11114114,•••1101 r•il• • •••• •1•••••••

Tyler Helpful? Yes (0) NQ() Report

*****

June 17, 2021 '';:.fai,rtEirsdl prgrchgno

Mazen

Helpful? Yes (0) No() Report

*****

June 16, 2021 VorMed pfLilrghESG

Shaina

Helpful? Yes (1) No (0) Report

*****

June 16, 2021 VorMad purchaza

Miriam

Helpful? Yes() No (0) Report

*****

June 15, 2021 '":-/cDeffrodl purchaso

Joshua

Helpful? Yes (0) No (0) Report

*****

June 15, 2021 '::::!/%,Affrazil pugpa...f;„

Landon

Helpful? Yes (0) N2() Report

https://www.walmart.com/reviews/product/226875605?sort=submission-desc 5/7 6/24/2021 Product review - Walmart.com

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IRIFFHPwrimerm-, V V • • v. r • • v .P

Michael Helpful? Yes (0) NQ() Report

****-

June 12, 2021 Verified purchase

Elaine

Helpful? Yes (0) No (0) Report

*****

June 11, 2021

Joseph Helpful? Yes (0) NQ() Report

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Customer reviews & ratings

Daeful Adult Children Summer Beach Shoes Foam Runner Anti Slipper Sandals Casual Color

2.9 91% -A-* ** Recommended 28 ratings (21 of 23)

5 stars 11 4 stars 3 3 stars 2 stars 1 star 14

Write a review

Most helpful positive review ***** Overall Review Honestly pretty good for 20 bucks, really comfortable in hand look identical to the actual foam runner

LtiO07•0

See more \/

https://www.walmart.com/reviews/product/416297212 1/7 6/24/2021 Product review - Walmart.com

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gmealia.l.N.SPIPPOISIMEmen. ***** Legendarily bad sizing. Don't buy. Ordered a US men's size 13... what I got wasn't even close to a men's size 10. Don't buy these, especially if vnit hava a frint larnor than tic mon't in

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28 reviews Sort by: most relevant

***** Overall Review June 17, 2021 Verified purchase Honestly pretty good for 20 bucks, really comfortable in hand look identical to the actual foam runner yeezy

Ivan Helpful? Yes (0) No (0) I Report

***** Hottest Item On Tik Tok June 4, 2021 Verified purchase COMFORTABLE

Jovanny Helpful? Yes (2) No (1) I Report

https://www.walmart.com/reviews/product/416297212 2/7 6/24/2021 Product review - Walmart.com

< Back rena I bought this without reading the reviews, so I was nervous that they would show up super small. Not only did they come before the expected time, but they were the correct size. I've been wearing them most of the day. They feel pretty good. Just ensure that you choose the correct size for adults, and I don't think you should have a problem.

Brycen

Helpful? Yes (0) No (0) Report

**** Nice but not perfect. June 12, 2021 Verified purchase Solid, color could more closely emulate the real shoes if it wanted it to.

Amritpal

Helpful? Q) &(2) Report

**** Yeezy Foam Runner Knock Offs June 19, 2021 Verified purchase I liked them. Not the best replicas lye seen, but its the best you're gonna get for 25 bucks.

Nate

Helpful? Yes (0) No (0) Report

***** Legendarily bad sizing. Don't buy. June 4, 2021 Verified purchase Ordered a US men's size 13... what I got wasn't even close to a men's size 10. Don't buy these, especially if you have a foot larger than US men's 10.

Ben

Helpful? Yes (1) &(i) Report

https://www.walmart.com/reviews/product/416297212 3R 6/24/2021 Product review - Walmart.com

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OURIENiumen6-7 lin, • • • Iro •4101411,,b0

Bought a US men's size 13 and it was easily a shoe for a small child. Returned and Refunded.

William

Helpful? Yes (0) No (0) Report

****1 DO NOT BUY June 12, 2021 Verified purchase Do not buy!! I am begging you please do not buy. I was sent a packet of balloons.

amber

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*****

June 8, 2021 Verified purchase Careful when buying this !!!

Edward

Helpful? Yes (0) No (0) Report

*****

June 10, 2021 Order a size 12 and got like a size 2 in kids

eddie

Helpful? `tj_(Q) Na(Q) Report

***** Read before you buy lol June 15, 2021 Lol everyone whos saying I bought a 13 and doesn't fit cant read cause it clearly says 13Y

Khuram

Helpful? Yes (0) No (0) Report

httpsi/www.walmart.com/reviews/product/416297212 4R 6/24/2021 Product review- Walmart.com

< Back trenamemm: Order like a size 10 men but is a 111 too big but they ok

Francisco

Helpful? Yes (0) No (0) I Report

*****

June 16, 2021 Verified purchase

Christina

Helpful? Yes (0) No (0) I Report

*****

June 18, 2021 Verified purchase

Brayan

Helpful? Yes (0) No (0) I Report

*****

June 16, 2021 Verified purchase

Reiss

Helpful? Yes (0) No (0) I Report

*****

May 28, 2021

Christian

Helpful? Yes (0) No (0) I Report

*****

May 27, 2021

woroud

Helpful? Yes (0) No (0) Report

https://www.walmart.com/reviews/product/416297212 517 6/24/2021 Product review - Walmart.com

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diego

Helpful? Yes (0) No (0) Report

*****

May 22, 2021

Pinkk

Helpful? Yes (3) No (10) Report

June 12, 2021 Verified purchase

amber

Helpful? Yes (0) No (0) Report

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Customer reviews & ratings

Daeful Adult Children Summer Beach Shoes Foam Runner Anti Slipper Sandals Casual Color

2.9 91% -A-* ** Recommended 28 ratings (21 of 23)

5 stars 11 4 stars 3 3 stars 2 stars 1 star 14

Write a review

Most helpful positive review ***** Overall Review Honestly pretty good for 20 bucks, really comfortable in hand look identical to the actual foam runner

LtiO07•0

See more \/

https://www.walmart.com/reviews/product/416297212?page=26sort=submission-desc 1/4 6/24/2021 Product review - Walmart.com

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INIPOPOIMININIPIRINPIL — . .41111•11111.- . — . ***** Legendarily bad sizing. Don't buy. Ordered a US men's size 13... what I got wasn't even close to a men's size 10. Don't buy these, especially if %/Ai i hzva z fnni- larnor thzn I lc manic in

See more v

28 reviews Sort by: newest to oldest

*****

May 28, 2021 Verified purchase

Jazzi

Helpful? Yes (0) i2() Report

*****

May 28, 2021

Christian

Helpful? Yes (0) No (0) Report

*****

May 28, 2021

diego

Helpful? Yes (0) No (0) I Report

*****

May 27, 2021

woroud

Helpful? YAL(Q) Niz a I Report

https://www.walmart.com/reviews/product/416297212?page=26sort=submission-desc 214 6/24/2021 Product review - Walmart.corn

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*****

May 27, 2021

Ish

Helpful? Yes (0) No (1) II Report

*****

May 27, 2021

Mohammad

Helpful? Yes (0) No (1) I Report

*****

May 22, 2021

Pinkk

Helpful? Yes (3) No (10) I Report

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