Ceremony of Roses Acquisition LLC v. Various John Does, Various Jane Does, and ABC Company

CourtDistrict Court, E.D. Missouri
DecidedMarch 5, 2026
Docket4:26-cv-00285
StatusUnknown

This text of Ceremony of Roses Acquisition LLC v. Various John Does, Various Jane Does, and ABC Company (Ceremony of Roses Acquisition LLC v. Various John Does, Various Jane Does, and ABC Company) is published on Counsel Stack Legal Research, covering District Court, E.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ceremony of Roses Acquisition LLC v. Various John Does, Various Jane Does, and ABC Company, (E.D. Mo. 2026).

Opinion

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

CEREMONY OF ROSES ACQUISI- TION LLC,

Plaintiff,

v. No. 4:26-cv-285 MAL

VARIOUS JOHN DOES, VARIOUS JANE DOES, and ABC COMPANY,

Defendants.

MEMORANDUM AND ORDER Plaintiff Ceremony of Roses Acquisition LLC—the company licensed to sell country music artist Zach Bryan’s merchandise—seeks an emergency temporary re- straining order, preliminary injunction, and an ex parte seizure order barring defend- ants identified only as “Various John Does, Various Jane Does, and ABC Company” from selling bootleg merchandise outside Zach Bryan’s thirty-nine-city international stadium tour. Doc. 6. The court GRANTS Ceremony of Roses’s request—with some modifications. Background Zach Bryan is kicking off his next tour in St. Louis this weekend. (Doc. 1 at ¶ 13). His tour merchandise is made and sold by Ceremony of Roses, who has the exclusive right to sell Zach Bryan’s official tour merchandise with trademarked de- signs using his name. (Id. at ¶¶ 6, 9.) But Ceremony of Roses knows from prior concerts that bootleggers will inevitably flock to the tour to sell unauthorized knock- off apparel that infringes on Zach Bryan’s trademarks. (Doc. 9 at ¶¶ 8–12.) But the names of the bootleggers are unknown, and Ceremony of Roses doubts they will iden- tify themselves at the concert, much less show up in court if identified and sued. (Doc. 8 at ¶¶ 13–14). So Ceremony of Roses sues the bootleggers as “Various John Does, Various Jane Does, and ABC Company” for trademark infringement, asking this Court for an emergency injunction barring the bootleggers from selling unauthorized merchandise during Zach Bryan’s “Heaven on Tour” concerts and an order sanction- ing the seizure of the bootlegger’s counterfeit goods. (Doc. 1.) Analysis The Trademark Counterfeiting Act of 1984 amended the Lanham Act to ex- pressly authorize ex parte injunctions to combat fly-by-night counterfeiters, which some courts had begun to impose under their inherent equitable authority anyway. See, e.g., Steven N. Baker, The Never-Ending Seizure Order: How Courts Have Granted Immortality to Congress's Mayfly, 26 Cardozo Arts & Ent. L.J. 369, 374 (2008); Rakoff & Wolff, Commercial Counterfeiting and the Proposed Trademark Counterfeiting Act, 20 Am. Crim. L. Rev. 145, 209–224 (1982); Joel v. Various John Does, 499 F. Supp. 791, 792 (E.D. Wis. 1980). While the Lanham Act had always authorized courts to enjoin infringements of licensed trademarks “according to the principles of equity[,]” 15 U.S.C. § 1116(a); Pub. L. 93–596, § 34 (1946) (original Lan- ham Act), the amended Act allows for ex parte orders to seize goods, records, counter- feit marks, and the means of making such marks. 15 U.S.C. § 1116(d)(1)(A); Pub. L. 100–667, § 1503 (1984 amendment). Ex parte seizure orders are not automatic. The Act imposes several require- ments on an applicant. Ceremony of Roses appears to have satisfied those require- ments. It has notified the acting U.S Attorney for the Eastern District of Missouri, see id. § 1116(d)(2), (Doc. 8 at ¶ 26); submitted an affidavit from Alan Sitchon, Vice President of Tour for Ceremony of Roses, see id. § 1116(d)(3)(A), (Doc. 9 at ¶ 2); sub- mitted a proposed order containing the information the Court needs to issue a seizure order under § 1116(d)(5), see id. § 1116(d)(3)(B), (Doc. 6-1); will provide security to compensate any wrongful seizures, see id. § 1116(d)(4)(A), (Doc. 6-1) (proposing an order requiring a bond); and presented “specific facts” allowing the Court to clearly find, at this early stage, that: (i) “an order other than an ex parte seizure order is not adequate to achieve the purposes of section 1114 of this title” because Ceremony of Roses has no other legal remedy that would prevent unauthorized sales without allowing bootleggers to conceal infringing goods and sell them later or otherwise seize the goods sold by unknown bootleggers who intention- ally and in bad faith keep their identities secret; (ii) “the applicant has not publicized the requested seizure”; (iii) “the applicant is likely to succeed in showing that the person against whom seizure would be ordered used a counterfeit mark in connection with the sale, offering for sale, or distribution of goods or services” be- cause Ceremony of Roses possesses an exclusive right to use Zach Bryan’s marks, (Doc. 9 at ¶¶ 3, 10), and bootleggers are likely to sell unauthorized Zach Bryan merchandise at the St. Louis concert; (iv) “an immediate and irreparable injury will occur if such seizure is not ordered” because unauthorized sales of lower-quality goods harms the reputation and value of Zach-Bryan-branded marks and because of the unique nature of how bootleggers do business, which is to sell merchan- dise but not identify themselves or show up in court if they are caught. Having an ex-parte order that allows Ceremony of Roses to seize the bootlegged goods is the most Ceremony of Roses expects to recover from these unknown entities, (id. at ¶ 15) (when confronted, bootleggers “re- fuse to identify themselves or provide aliases, or simply flee the area only to resume sales elsewhere”), (id. at ¶ 20) (bootleggers also do not show up in court); (v) “the matter to be seized will be located at the place identified in the ap- plication,” which is the 3-mile radius surrounding The Dome at Amer- ica’s Center in St. Louis (excluding any brick-and-mortar retailers), as this is would be where bootleggers would logically operate to benefit from attendance at, and association with, the concert in that venue, (Doc. 6-1 and Doc. 9 at ¶ 8, 14); (vi) “the harm to the applicant of denying the application outweighs the harm to the legitimate interests of the person against whom seizure would be ordered of granting the application” because bootleggers have no right to sell infringing merchandize, which they could move to an- other location and offer for sale again if not confiscated, and because any inadvertent seizure of merchandise that is not infringing may be reme- died in a subsequent hearing in this case; and (vii) “the person against whom seizure would be ordered, or persons acting in concert with such person, would destroy, move, hide, or otherwise make such matter inaccessible to the court, if the applicant were to pro- ceed on notice to such person” because, again, bootleggers in similar cir- cumstances have relocated or “disappeared” when approached and are difficult to identify at subsequent shows. (Doc. 8 at ¶ 14). 15 U.S.C. § 1116(d)(4)(B). Based on Ceremony of Roses’ briefing and the ex parte hearing, the Court will grant Ceremony of Roses’ ex parte request for a seizure order under 15 U.S.C. § 1116. * * * Ceremony of Roses also asks for a temporary restraining order (TRO) and that the TRO be issued without notice to Defendants on account of their unidentifiability. As Federal Rule of Civil Procedure 65 recognizes, district courts have equitable power to issue TROs. See also Dataphase Sys., Inc. v. C L Sys., Inc., 640 F.2d 109, 113 n.5 (8th Cir. 1981) (en banc).

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Dataphase Systems, Inc. v. C L Systems, Inc.
640 F.2d 109 (Eighth Circuit, 1981)
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Joel v. Various John Does
499 F. Supp. 791 (E.D. Wisconsin, 1980)
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Ceremony of Roses Acquisition LLC v. Various John Does, Various Jane Does, and ABC Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ceremony-of-roses-acquisition-llc-v-various-john-does-various-jane-does-moed-2026.