TimesLines, Inc v. Facebook, Inc.

Filing 7

MOTION by Plaintiff TimesLines, Inc for temporary restraining order (Hultquist, James)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
TIMELINES, INC.
)
)
Plaintiff,
)
)
v.
)
Civil Action No.:_______________
)
FACEBOOK, INC.
)
Jury Trial Demanded
)
Defendant.
)
PLAINTIFF’S MOTION FOR A TEMPORARY RESTRAINING ORDER
For the reasons set forth in its accompanying memorandum of law, Plaintiff Timelines,
Inc. respectfully moves the Court to grant it a temporary restraining order enjoining the
Defendant Facebook, Inc. from:
(a)

using Timelines’ federally registered trademarks, or any confusingly similar derivation

thereof, in the provision of goods and services;
(b)

commencing Facebook’s “Timeline” offering using Timelines’ federally registered

trademarks, or any confusingly similar derivation thereof;
(c)

The court should further order Facebook to publish corrective advertising to dispel the

false and misleading impressions created by its promotional materials; and
(d)

The court should grant all such other relief as the Court deems just and appropriate.

US_ACTIVE-107408211.1

Dated: September 30, 2011

TIMELINES, INC.

By:

/s/ James T. Hultquist
One of its Attorneys

James T. Hultquist (#6204320)
Douglas Alan Albritton (#6228734)
REED SMITH LLP
10 South Wacker Drive, 40th Floor
Chicago, Illinois 60606-7507
[phone]
[phone] (facsimile)
[e-mail]
[e-mail]

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CERTIFICATE OF SERVICE
I hereby certify that on September 30, 2011, I electronically transmitted the attached
document to the Clerk’s Office using the CM/ECF System for filing and for transmittal of a
Notice of Electronic Filing to the following, who was served via electronic mail:
Steven D. McCormick
Kirkland & Ellis LLP
300 North LaSalle Street
Chicago, IL 60654
s/ James T. Hultquist______________________

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