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Battle on the Midway... Let justice prevail!!
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Coach P
56 posts
Jun 21, 2018
8:25 AM
June 20, 2018
FOR IMMEDIATE ATTENTION




Re: Court Order: Left Coast Wrestling, LLC v. Dearborn International LLC et al.
Dear Sir/Madam:
This office represents Plaintiff, Left Coast Wrestling, LLC (“Plaintiff”), in a case against Defendants Dearborn International LLC and Duke Minh Le (collectively, “Defendants”), in an action filed in the United States District Court, Southern District of California, Case No. 3:17-cv-00466-LAB-NLS.

On May 23, 2018, the Honorable Nita L. Stormes, United States Magistrate Judge, entered a Report and Recommendation for Order Granting Default Judgment, and on June 12, 2018, a Supplemental Recommendation for Order Granting Default Judgment (collectively, the “Default Judgment Recommendation”). Defendants did not file an objection to the Default Judgment Recommendation before the Court’s June 15, 2018 deadline. On June 19, 2018, the Honorable Larry A. Burns, United States District Court Judge, entered the Court’s Order Adopting Report and Recommendation, and Granting Default Judgment Against Defendants Duke Minh Le and Dearborn International LLC. The enclosed Court Orders and Default Judgment contains bookmarked copies of these recommendations and orders.

We write because we are informed and believe that Defendants will take destructive measures to prevent the return of the below to Plaintiff. We respectfully request that you preserve all content related to the below such that it is not altered or destroyed. We will need it to transition the information to the true owner, Plaintiff, pursuant to the Court’s order. It is worth noting the Court found this to be an “exceptional” case warranting an award of Plaintiff’s attorneys fees.

To provide a brief background of this case for context, the “Battle on the Midway” is a youth wrestling tournament put on by Plaintiff that takes places in San Diego, California. After the 2016 tournament concluded, one of Plaintiff’s members, Duke Le, stole Plaintiff’s idea, trademark, tournament, social media accounts, website and other items, and began promoting a “Battle on the Midway” tournament on behalf of his own separate business “Tri Titans,” instead of Plaintiff. Tri Titans



2 DOCS 124952-000001/3336515.1
is the d/b/a of Defendant Dearborn International LLC. Since filing this lawsuit and registering numerous participants for the 2017 “Battle on the Midway” tournament, Defendants changed the name of the tournament to the “Ultimate Summer Series.” All searches for the Battle on the Midway tournament currently direct consumers to the Ultimate Summer Series website and social media accounts, and Defendants are continuing to profit from their unlawful conduct.

The Court has ordered the following, among other items:

1. A permanent injunction issue with the following terms: Defendants, its officers, directors, owners, employees, agents, and all those working in concert with Defendants shall be ordered to and permanently enjoined from the following: … c. Defendants shall immediately return to Plaintiff by facilitating the transfer of the rights with the host company or otherwise, any and all media related intellectual property of Plaintiff, including without limitation, … iii. Any and all web hosting accounts associated with the Battle on the Midway together with all codes, passwords, credentials or other information necessary to fully access, implement and operate the same; iv. Any and all URL hostings and URL listings associated with the Battle on the Midway together with all codes, passwords, credentials or other information necessary to fully access, implement and operate the same; vi. Any and all Battle on the Midway tournament registration databases in any form, together with all codes, passwords, credentials or other information necessary to fully access, implement and operate the same; … d. Defendants shall immediately cease, desist and disable any cross links from the Battle on the Midway website or search terms to Defendants’ websites or social media portals and locations; e. Defendants shall post a copy of this Order and Permanent Injunction on the Ultimate Summer Series Website; f. Defendants shall provide a copy of this Order and Permanent Injunction to all distributors, wholesalers, retailers or other agents participating in the marketing and distribution of infringing products; g. Defendants shall immediately return to Plaintiff via electronic format and thereafter permanently delete and cease the use any and all databases that include contact information for attendees or spectators for the 2016 or 2017 wrestling event together with all codes, passwords, credentials or information necessary to fully access, implement and operate the same; … i. Defendants shall immediately cease from coordinating, promoting, or hosting wresting tournaments at or near the U.S.S. Midway Museum and/or the Broadway Pier and shall be enjoined from directly or indirectly performing wresting tournaments at that finite location for a period of three years.




3 DOCS 124952-000001/3336515.1
At this time we respectfully request you take any and all immediate measures to assure this content is preserved and not destroyed. Given the high likelihood that Defendants will destroy this information in order to prevent Plaintiff from gaining access to its rightful property, we request a freeze be placed over the same so that Defendants are not allowed to access, harm or destroy the content. We also respectfully request that you transfer this information to us directly, including database management or downloads, membership downloads, web address of page redirects such as Domain Masking, redirects, CNAMES, hyperlinks, URL redirection or forwarding, user profiles, CMR database, DNS rights, marketing “ad word” accounts, revenues or account balances due to you, and any other relevant data and property falling within the above categories as defined by the Court’s order.

We thank you in advance for assisting in this preservation and transfer. Please let us know if you have any questions.

Truly,
Coach P
57 posts
Jun 21, 2018
8:30 AM
The legal ruling is 45 pages long, a very long read. If you would like to read the court ruling let me know and I will forward it to you. Basically Left Coast Wrestling,(Perry and Aaron) won everything they ask for against USS (Ultimate Summer Series), Duke Le. Let the truth be brought to the light.
member165
206 posts
Jun 21, 2018
8:59 AM
Amen.

tri-titans should be ashamed of themselves. Wrestling (Incase tri-titans didn’t know) is a very truthful sport. In the end of every match the truth is revealed. In wrestling you can not hide, you can’t cheat, you can’t deceive your way to a win. That’s why we love it, that’s why it must be kept pure and free of cancers, free of poison, free of people who are willing to sacrifice the good and growth of the sport for a few dollars to shove in people’s faces.

Money is not important to wrestlers, we have all the best of what money can’t buy. Truth, strength, pride, humility, passion, love, character, spirit, relationships, respect, self respect, sportsmanship, work ethic, mental toughness, the ability to endure pain (physical and mental) and push farther and dig deeper than most.

You can’t build a brand off lies, and deceit, some were promised the world and were seduced by the prospect of monetary compensation in exchange for loyalty. Those learned a valuable lesson in life, Don’t compromise the value of your character.

Now the growth of our sport can begin. Our section (San Diego) will catapult to the forefront of the wrestling community.

A lot of people were fooled by the tri-titans, it’s ok, it happens. IT WILL NOT HAPPEN ANY LONGER.

Last Edited by member165 on Jun 22, 2018 5:05 PM
Poway Wrestling Camp
227 posts
Jun 22, 2018
6:56 AM
Poway Summer Slam wrestling tournament July 21 still be up and running! All ages for this one. We already have kids signed up from Ohio, CT, Mass, NY, and AZ! Register on trackwrestling.com

This tournament is always run well with CIF referees.

Last Edited by Poway Wrestling Camp on Jun 22, 2018 6:57 AM
Marc Smith
947 posts
Jun 25, 2018
9:52 AM
I assume the event still exist with same schedule . Just different folks running it?


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