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.
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Civil Action No.:_______________
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FACEBOOK, INC.
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Jury Trial Demanded
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Defendant.
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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
(312) 207-1000
(312) 207-6400 (facsimile)
jhultquist@reedsmith.com
dalbritton@reedsmith.com
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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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