Certification of Counsel — 3M Company v. TAC2 Global LLC (Middle District of Florida)

Summary

A certification by counsel for 3M Company, filed May 8, 2020 as Document 13 in 3M Company v. TAC2 Global LLC, Case No. 8:20-cv-1003-T-35CPT, in the U.S. District Court for the Middle District of Florida, Tampa Division, under the court's order of May 7, 2020. Counsel certifies that TAC2 Global was formally served with the summons and complaint on May 6, 2020, and that counsel emailed it, on May 8, 2020, copies of the orders entered, 3M's motion for a temporary restraining order and preliminary injunction, two supporting declarations and the order on that motion. It states that TAC2 Global has known of the suit since at least May 1, 2020, when it commented for a Bloomberg Law article, and that it has not said whether it has counsel. Signed by Joseph M. Wasserkrug of McDermott Will & Emery LLP.

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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.
Case 8:20-cv-01003-MSS-CPT     Document 13     Filed 05/08/20     Page 1 of 3 PageID 319

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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

Case 8:20-cv-01003-MSS-CPT     Document 13     Filed 05/08/20     Page 2 of 3 PageID 320

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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
Case 8:20-cv-01003-MSS-CPT     Document 13     Filed 05/08/20     Page 3 of 3 PageID 321

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