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this Court’s Order dated May 7, 2020, hereby certifies as follows
Date
2020-05-07
Full text
1
UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
TAMPA DIVISION
3M COMPANY,
Plaintiff,
v.
Case No.: 8:20-cv-1003-T-35CPT
TAC2 GLOBAL LLC,
Defendant.
______________________/
CERTIFICATION
Undersigned counsel for Plaintiff 3M Company (“Plaintiff” or “3M”), pursuant to
this Court’s Order dated May 7, 2020, hereby certifies as follows:
1.
Notice of the above-captioned litigation has been provided to Defendant
TAC2 Global LLC (“Defendant”).
2.
Formal service of process of the Summons and Complaint was effected on
May 6, 2020 at 11:21 am. A copy of the executed Return of Service is attached hereto as
Exhibit A.
3.
Undersigned counsel sent copies of the following documents to Defendants
via email to derek@tac2global.com and chris.d@tac2global.com on May 8, 2020 at 2:23
pm: (i) Related Case Order and Track Two Notice [ECF No. 6]; (ii) Interested Persons
Order for Civil Cases [ECF No. 7]; (iii) Motion for Temporary Restraining Order and
Preliminary Injunction and Supporting Memorandum of Law [ECF No. 8]; (iv) Declaration
of Charles Stobbie in Support of Plaintiff 3M Company’s Motion for Temporary
Restraining Order and Preliminary Injunction [ECF No. 9]; (v) Declaration of David A.
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Crist in Support of Plaintiff 3M Company’s Motion for Temporary Restraining Order and
Preliminary Injunction [ECF No. 10]; and (vi) Order on Motion for Temporary Restraining
Order [ECF No. 12]. A copy of the May 8, 2020 email to Defendant and confirmation of
delivery of the same is attached hereto as Exhibit B.
4.
Upon information and belief, Defendant has had actual knowledge of the
above-captioned litigation since at least May 1, 2020 because Defendant provided
comments in connection with an article published by Bloomberg Law on May 1, 2020. See
Brittain, New 3M N95 Trademark Suit Targets Include Florida Lawyer (1), BLOOMBERG
LAW, available at https://news.bloomberglaw.com/ip-law/new-3m-n95-trademark-suit-
targets-include-florida-lawyer (May 1, 2020). A copy of New 3M N95 Trademark Suit
Targets Include Florida Lawyer (1) is attached hereto as Exhibit C.
5.
Plaintiff has no knowledge regarding whether Defendant has retained
counsel in this matter. Plaintiff has requested that Defendant advise whether it has retained
counsel, and, if so, to provide Plaintiff with the name(s) of the attorney(s) and law firm(s)
representing Defendant. See Ex. B.
6.
Plaintiff has not received a response to undersigned counsel’s email
attached hereto as Exhibit B.
Dated: May 8, 2020
MCDERMOTT WILL & EMERY LLP
By:
/s/ Joseph M. Wasserkrug
Joseph M. Wasserkrug
Florida Bar No.: 112274
jwasserkrug@mwe.com
333 SE 2nd Avenue, Suite 4500
Miami, FL 33131-4336
T: 305.347.6501 | F: 305.675.8403
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CERTIFICATE OF SERVICE
I hereby certify that on May 8, 2020 a copy of the foregoing was filed using the
Court’s CM/ECF filing system, and was served on Defendant via email at
derek@tac2global.com and chris.d@tac2global.com.
By:
/s/ Joseph M. Wasserkrug
Joseph M. Wasserkrug
DM_US 168531434-2.099922.0012
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