UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
THE TAUBMAN COMPANY LIMITED
PARTNERSHIP, Plaintiff,
v. WEBFEATS and HENRY MISHKOFF,
Defendants.
Civil Action No. 01-72987
Honorable Lawrence P. Zatkoff
Magistrate Judge Komives
EXPEDITED MOTION TO AMEND PRELIMINARY INJUNCTION
ON OCTOBER 11, 2001, this Court granted Plaintiff's motion for preliminary injunction
with the order attached hereto as Exhibit A, prohibiting Defendants from continuing to operate the
website www.shopsatwillowbend.com. At the time the injunction was entered, Defendants'
numerous additional websites incorporating various of Plaintiffs marks were not operational.
These websites are:
- willowbendsucks.com
- willowbendmallsucks.com
- theshopsatwillowbendsucks.com
- taubmansucks.com
- shopsatwillowbendsucks.com
Since the entry of the injunction, Defendants have made these numerous sites operational,
and, as promised in its previously filed brief, the sites are used to defame Plaintiff, its malls, its
lawyers, and to publicize the settlement discussions that were undertaken by the parties in an
attempt to resolve the dispute in this case. The first page (only) of the website is attached to this
motion as Exhibit B. The full printout from the website is not attached hereto in an effort to
minimize the distribution of Defendants' defamatory and confidential material, but can be
accessed by the Court at any of Defendants' listed websites.
Plaintiff respectfully submits that these sites are all based on domain names incorporating
Plaintiff's marks, and their use constitutes continued, unauthorized use by Defendants of the
marks at issue in this case. In order to prevent this ongoing use by Defendants of Plaintiff's
marks, Plaintiff requests this Court to modify the relevant language of its previously entered
injunction to read all "Defendants are hereby RESTRAINED and ENJOINED from using any
Internet domain name which incorporates the marks "THE SHOPS AT WILLOW BEND" or
"TAUBMAN" or any other domain name incorporating elements of these marks, and to remove
any related websites which use these domain names from the Internet. This order expressly
applies to the following domain names:
- www.shopsatwillowbend.com
- www.shopsatwillowbendsucks.com
- www.willowbendsucks.com
- www.theshopsatwillowbendsucks.com
- www.taubmansucks.com
- www.willowbendmallsucks.com
In further support of this motion, Plaintiff relies on the accompanying brief.
Respectfully submitted,
Julie A. Greenberg (P38299)
GIFFORD, KRASS, GROH, SPRINKLE,
ANDERSON & CITKOWSKI, P.C.
280 N. Old Woodward Ave., Suite 400
Birmingham, Michigan 48009
(248)647-6000
Attorneys for Plaintiff
Dated: October 15, 2001
