Formerly Known As Lady Antebellum Complaint

IN THE UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF TENNESSEE

NASHVILLE DIVISION
HILLARY SCOTT, CHARLES )

KELLEY, DAVID HAYWOOD, AND )
LADY A ENTERTAINMENT LLC, )
)
PLAINTIFFS, )
) NO. ___________________
VS )
) JUDGE ________________
ANITA WHITE, )
)
DEFENDANT. )
PLAINTIFFS’ ORIGINAL COMPLAINT
Plaintiffs Hillary Scott, Charles Kelley, David Haywood, and Lady A Entertainment LLC
file this Original Complaint and allege as follows:
I. PARTIES
1. Plaintiff Hillary Scott (“Scott”) is an individual who is a citizen and resident of
Brentwood, Tennessee.
2. Plaintiff Charles Kelley (“Kelley”) is an individual who is a citizen and resident of
Nashville, Tennessee.
3. Plaintiff David Haywood (“Haywood”) is an individual who is a citizen and
resident of Nashville, Tennessee.
4. Plaintiff Lady A Entertainment LLC (“LAE,” and collectively with Scott, Kelley,
and Haywood, “Plaintiffs”) is a Tennessee limited liability company with its principal place of
business located at 2300 Charlotte Avenue, Suite 103, Nashville, Tennessee 37203.
5. Defendant Anita White (“White”) is an individual who is a citizen and resident of
Seattle, Washington. White is a blues, soul, and funk musician who—according to publicly-
available information—has performed live music in the Pacific Northwest, particularly Seattle,
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Case 3:20-cv-00585 Document 1 Filed 07/08/20 Page 1 of 13 PageID #: 1
and in various locations throughout the United States, including a recent performance in January
of 2020 at the “Her Majesty Presents 2020 Showcase” in Tennessee. White markets herself as
frequently performing in Memphis.
II. NATURE OF THE ACTION
6. This case arises from White’s attempt to enforce purported trademark rights in a
mark that Plaintiffs have held for more than a decade. Plaintiffs seek a declaratory judgment that,
among other things, their use of their trademarks incorporating “Lady A” do not infringe any of
White’s alleged trademark rights in “Lady A.” Plaintiffs do not seek monetary damages through
this action.
III. JURISDICTION AND VENUE
7. This Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and
1338(a), involving alleged violations of the Lanham Act. The Court further has subject matter
jurisdiction pursuant to 28 U.S.C. §§ 2201 and 2202 over actions for declaratory judgment.
8. This Court has specific personal jurisdiction over White because White has
purposefully availed herself of doing business in Tennessee. Upon information and belief, White
performs concerts in Tennessee and directs to Tennessee advertising for such musical
performances. Most recently, White performed at the “Her Majesty Presents 2020 Showcase” in
Memphis, Tennessee, in January, 2020. In addition, White directed contacts to the State of
Tennessee during the parties’ attempted negotiation of a coexistence agreement, including
retaining for the purposes of the negotiations an attorney located in Memphis, Tennessee, directing
written correspondence to Plaintiffs, and participating in telephone conferences and a Zoom
videoconference with Plaintiffs while White was aware that Plaintiffs were located in Tennessee.
Page 2 of 13
9. Venue is proper in this district pursuant to 28 U.S.C. § 1391(b) because White is
subject to personal jurisdiction in this judicial district and because a substantial part of the events
giving rise to this action occurred in this judicial district.
IV. FACTUAL ALLEGATIONS
10. Scott, Kelley, and Haywood (collectively, the “Musical Group”) are members of a
band that, until June 11, 2020, used the federally-registered brand names “Lady Antebellum” and
“Lady A” to promote their goods and services. However, in recognition of the hurtful connotations
of the word “antebellum,” the Musical Group announced on June 11, 2020 that they would
discontinue using their “Lady Antebellum” brand and use only the federally-registered “Lady A”
brand moving forward. Notably, the Musical Group started using “Lady A” as a source indicator
for their goods and services as early as 2006-2007, adopting as an official brand a name their fans
began associating with the Musical Group as they rose to popularity. The Musical Group has used
“Lady A” interchangeably with “Lady Antebellum” since the 2006-2007 timeframe.
11. Indeed, as early as 2008, the Musical Group’s own website referred to the band as
simply “Lady A.”
Page 3 of 13
See https://web.archive.org/web/20080201172701/http://ladyantebellum.musiccitynetworks.com/
(last accessed on July 7, 2020).
12. Since the band’s formation, the Musical Group has formed multiple legal entities,
the first of which, Lady A’D Productions, Inc., was formed in Tennessee in 2007. See Exhibit A.
They subsequently formed LAE in Tennessee in 2010. See Exhibit B. LAE is the successor in
interest (as of August 30, 2010) to trademark rights initially established by Lady A’D Productions,
Inc.
13. Also in 2010, the band’s website provided the ability for fans to “buy all of [their]
favorite Lady A songs through the online store,” advertised the “Official Lady A Merch Store,”
and invited users to view behind the scenes video footage that included a “Lady A” watermark on
the bottom corner of the video.
Page 4 of 13
14. On May 18, 2010, Lady A’D Productions, Inc. applied to register “Lady A” in
International Class 41 for entertainment services, including live musical performances and
streaming musical programming. The first use date was identified as 2006, and the first-use-in-
commerce date was identified as 2008. See Exhibit C. The application was assigned to Plaintiff
LAE on August 30, 2010. See Exhibit D. The application was published for opposition on October
19, 2010, and registered on July 26, 2011 (U.S. Reg. No. 4004006) after no oppositions were filed
by any person or entity, including White. See Exhibit E. On May 1, 2017, Plaintiff LAE filed its
Combined Declaration of Use and Incontestability under Sections 8 & 15 with the United States
Page 5 of 13
Patent and Trademark Office (“USPTO”), which was accepted by the USPTO on June 28, 2017,
acknowledging the registration’s incontestability. See Exhibit F.
15. On May 18, 2010, Lady A’D Productions, Inc. also applied to register “Lady A” in
International Class 9 for musical recordings, which was assigned to Plaintiff LAE on August 30,
2010 and published for public opposition on October 19, 2010. See Exhibit C, D. Again, no
oppositions were filed by any person or entity, including White, and the USPTO issued U.S.
Registration Number 4292685. See Exhibit G. Plaintiff LAE filed its Combined Declaration of
Use and Incontestability under Section 9 with the USPTO, which was accepted on September 5,
2019, acknowledging the registration’s incontestability. See Exhibit H.
16. On July 21, 2010, Lady A’D Productions, Inc. applied to register “Lady A” in
International Class 25 for clothing. See Exhibit I. That application, which was assigned to Plaintiff
LAE on August 30, 2010, was published for public opposition on July 12, 2011, and after no
oppositions were filed, the USPTO issued U.S. Registration Number 4030752 on September 27,
2011. See Exhibit D, J. Plaintiff LAE filed its Combined Declaration of Use and Incontestability
under Sections 8 & 15 on December 4, 2017, acknowledging the registration’s incontestability.
See Exhibit K. U.S. Trademark Registration Nos. 4004006, 4030752, and 4292685 are
collectively, the “LADY A Registrations.”
17. White did not oppose any of LAE’s applications for the LADY A mark.
18. White has not sought to cancel any of the LADY A Registrations.
19. Prior to 2020, White did not challenge, in any way, Plaintiffs’ open, obvious, and
widespread nationwide and international use of the LADY A mark as a source indicator for
Plaintiffs’ recorded, downloadable, and streaming music and videos, Plaintiffs’ live musical
performances, or Plaintiffs’ sale of souvenir merchandise.
Page 6 of 13
20. The Musical Group’s use of “Lady A” as a brand was not minor or insignificant.
Indeed, the media and the Musical Group’s fans strongly associated the “Lady A” brand with the
Musical Group in highly-visible ways.
21. Over the course of their decade-plus career, Lady A has become one of the twenty-
first century’s premier vocal groups, blending deeply-felt emotions with classic Country sounds.
As a Country-radio staple, the trio has amassed record-breaking success, ushering in ten No. 1 hits
with more than 18 million album units, 34 million tracks sold, and nearly five billion digital
streams. Known for their 9X Platinum hit “Need You Now” which is the highest certified song by
a Country group, they have earned ACM and CMA “Vocal Group of the Year” trophies three years
in a row and countless other honors including seven GRAMMY awards, Billboard Music Awards,
People’s Choice Awards, Teen Choice Awards, and a Tony Award nod.
22. The Musical Group recently learned that White, a blues, soul, and funk artist
located in Seattle, Washington, performs under the stage name “Lady ‘A’” in the Pacific
Northwest, Louisiana, Mississippi, and Tennessee. According to publicly-available information,
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White used “Lady ‘A’” to identify herself as the performer on recorded music originally released
in 2010, 2013, 2016, and 2018. Although White’s recorded music and the Musical Group’s
recorded music both appear on Spotify, each party’s music is immediately distinguishable. For
example, the Musical Group has a unique Lady A artist page with over 7 million monthly listeners
featuring only the Musical Group’s music (including its album artwork) beneath a prominent photo
of the Musical Group, while White has a separate unique Lady “A” artist page with (as of filing)
166 monthly listeners featuring three of her four albums (including her album artwork) beneath a
prominent photo of White. In addition, there is another Lady A artist page with White’s photo at
the top, but the page combines at least four musical artists performing recorded music under the
name Lady A (one of which is White, but none of which are the Musical Group).
23. Based on information and belief, White has never used “Lady ‘A’” as a trademark
to identify her goods or as a service mark to identify her entertainment services. If, at any point,
White’s use of “Lady ‘A’” to identify herself as a musical performer became a trademark use, such
trademark use began after Plaintiffs established their trademark and service mark rights in the
LADY A mark.
24. Based on information and belief, White has never applied to register “Lady ‘A’” as
a trademark or service mark.
25. Upon information and belief, no consumers have been confused with the source of
Plaintiffs’ music and the source of White’s music.
26. Plaintiffs contacted White, seeking to reach agreement on continuing to share the
use of “Lady A” as they had for 14 years (Plaintiffs as a trademark and service mark for their
Musical Group and its goods/services, and White as the name of a musical performer) and set up
a videoconference with White. On June 15, 2020, White posted on her Instagram account, under
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username @ladya_bluesdiva, a photo from the parties’ Zoom videoconference. The photo included
the following caption: “Today, we connected privately with the artist Lady A. Transparent, honest,
and authentic conversations were had. We are excited to share we are moving forward with positive
solutions and common ground. The hurt is turning into hope. More to come.”
See https://www.instagram.com/p/CBeiDpAHN6z/ (last accessed on July 7, 2020).
27. Plaintiffs and White – and later Plaintiffs’ counsel and White’s counsel – discussed
various forms of cooperation through which not only would the Plaintiffs and White continue to
peacefully coexist, but Plaintiffs would support White’s musical career. During their Zoom
conference, Plaintiffs and White discussed co-writing and jointly recording a new song that would
be promoted and commercialized by the parties, and soon afterward, began collaborating on the
writing process.
Page 9 of 13
28. After Plaintiffs’ counsel prepared and delivered a draft agreement memorializing
the discussions between Plaintiffs and White, White provided a quote to Newsday that “I received
a draft agreement from the Antebellum camp. I’m not happy about [it] yet again after talking in
good faith . . . Their camp is trying to erase me and I’ll have more to say tomorrow. Trust is
important and I no longer trust them.” See https://www.newsday.com/entertainment/music/lady-
antebellum-lady-a-1.45795425 (last accessed on July 8, 2020).
29. Notwithstanding White’s comments, her counsel continued to negotiate a draft
agreement with Plaintiffs’ counsel. Other than a nominal reimbursement of attorneys’ fees, a
monetary payment was never offered or demanded.
30. The next day (June 25th), at 10:27 PM EST, White’s new counsel contacted
Plaintiffs’ counsel, stating, in pertinent part, that “Cooley LLP represents Ms. White in connection
with trademark litigation matters. Please direct all future communications concerning the dispute
between Lady Antebellum and Ms. White to us” and “We possess what we believe is the latest
proposed settlement agreement. We are reviewing the agreement now. We will respond in due
course.” (emphasis added).
31. Eleven days later (July 7th), without any discussion or context (notwithstanding
Plaintiffs’ attempts to contact White’s new counsel) and notwithstanding White’s Instagram post
21 days prior extolling the Musical Group’s and White’s join goal of turning “hurt into hope,”
White’s new counsel delivered a draft settlement agreement that included an exorbitant monetary
demand, while maintaining the cooperation and collaboration obligations. See Exhibit L, filed
under seal. Paired with White’s public statements, White’s demand for an exorbitant payment in
exchange for continued coexistence, notwithstanding the previous absence of discussion of any
payment (other than reimbursement of nominal attorneys’ fees), gives rise to imminent
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controversy, demonstrating a course of action from which a threat of suit could be inferred based
on White’s charge of infringement, and giving rise to this Court’s jurisdiction under 28 U.S.C. §§
2201 and 2202.
32. Plaintiffs do not wish to prohibit White from performing under the name “Lady A”
or otherwise identifying herself as a musical performer named “Lady A,” nor do Plaintiffs seek
any monetary damages whatsoever. Rather, Plaintiffs simply wish that the parties continue to
coexist, and that Musical Group be permitted to continue using the LADY A mark, for which LAE
holds the incontestable LADY A Registrations and for which the Musical Group’s goods and
services have been identified for over a decade around the world.
33. Through this action, Plaintiffs further seek a declaration that their continued use of
the LADY A mark does not infringe on any of White’s alleged trademark rights or her non-
trademark use of “Lady A” to identify herself as a musical performer.
V. CAUSE OF ACTION
(Declaratory Judgment Under 28 U.S.C. § 2201)
34. Plaintiffs incorporate the allegations set forth in each of the preceding paragraphs
as if fully set forth herein.
35. An actual case or controversy exists between Plaintiffs and White as to Plaintiffs’
continued use of the LADY A mark in connection with, among other things, musical recordings,
performances, and merchandise.
36. White has asserted that Plaintiffs do not have the right to use the LADY A mark
due to her use of “Lady A”.
37. Plaintiffs seek a declaration from this Court that they are lawfully using the LADY
A mark and that their use of the mark and intent to continue using the mark do not infringe any
Page 11 of 13
rights White may have under state or federal law, including any rights under the Lanham Act, 15
U.S.C. § 1501, et seq.
38. This Court has jurisdiction over the claim asserted in this Complaint.
39. This controversy is ripe for adjudication.
VI. PRAYER FOR RELIEF
40. WHEREFORE, Plaintiffs respectfully request that the Court enter judgment in
their favor and:
a. Enter a declaratory judgment that Plaintiffs’ use of the LADY A mark does not and
would not infringe upon or otherwise violate any of White’s claimed rights in “Lady
A,” including any trade names or common law rights;
b. Enter a declaratory judgment confirming that LAE’s LADY A Registrations are
valid, subsisting, and incontestable; and
c. Grant other such further relief, in law or at equity, to which Plaintiffs may be
entitled.
Page 12 of 13
DATED: July 8, 2020 Respectfully Submitted,
GREENBERG TRAURIG LLP
By: /s/ Mary-Olga Lovett

Mary-Olga Lovett (TX SBN: 00789289)
Pro Hac Vice forthcoming
lovettm@gtlaw.com
1000 Louisiana Street, Suite 1700
Houston, Texas 77002
Telephone: 713.374.3570
NEAL & HARWELL, PLC
By: /s/ William T. Ramsey _________

William T. Ramsey (BPR #9245)
Mozianio S. Reliford, III (BPR #36170)
1201 Demonbreun St., Suite 1000
Nashville, TN 37203
(615) 244-1713
wtr@nealharwell.com
treliford@nealharwell.com
Attorneys for Plaintiffs Hillary Scott,

Charles Kelley, David Haywood, and Lady
A Entertainment LLC
Page 13 of 13
Exhibit “A”
Case 3:20-cv-00585 Document 1-1 Filed 07/08/20 Page 1 of 3 PageID #: 14

Division of Business Services
Department of State
State of Tennessee
312 Rosa L. Parks AVE, 6th FL
Nashville, TN 37243-1102
Tre Hargett
Secretary of State
Filing Information
Name: LADY A'D PRODUCTIONS, INC.

General Information
SOS Control # 000545967 Formation Locale: TENNESSEE
Filing Type: For-profit Corporation - Domestic Date Formed: 04/10/2007
04/10/2007 2:57 PM Fiscal Year Close 4
Status: Active
Duration Term: Perpetual
Registered Agent Address Principal Address

JULIE BOOS STE 103
STE 103 2300 CHARLOTTE AVE
2300 CHARLOTTE AVE NASHVILLE, TN 37203-1877
NASHVILLE, TN 37203-1877
The following document(s) was/were filed in this office on the date(s) indicated below:
Date Filed Filing Description Image #
09/28/2019 2019 Annual Report B0761-8166
04/09/2018 2018 Annual Report B0534-0777
04/04/2017 2017 Annual Report B0376-5150
04/20/2016 2016 Annual Report B0239-4572
03/08/2016 Assumed Name Renewal B0205-5926
Assumed Name Changed From: Ragtop Productions To: Ragtop Productions
Expiration Date Changed From: 04/27/2016 To: 03/08/2021
04/06/2015 2015 Annual Report B0083-6896
04/02/2014 2014 Annual Report A0233-0810
04/01/2013 2013 Annual Report A0171-3132
04/03/2012 2012 Annual Report A0117-2281
Principal Address 2 Changed From: SUITE 103 To: STE 103
Principal Postal Code Changed From: 37203 To: 37203-1877
Principal County Changed From: No value To: DAVIDSON COUNTY
04/27/2011 Assumed Name 6885-1919
New Assumed Name Changed From: No Value To: Ragtop Productions
04/04/2011 2011 Annual Report A0069-0288
7/7/2020 11:02:37 PM Page 1 of 2
Filing Information
Name: LADY A'D PRODUCTIONS, INC.

09/02/2010 2010 Annual Report 6765-1584
07/22/2009 2009 Annual Report 6574-0461
Principal Address Changed
Registered Agent Physical Address Changed
08/01/2008 2008 Annual Report 6358-1628
Mail Address Changed
04/18/2007 Administrative Amendment 6039-0848
Mail Address Changed
04/10/2007 Initial Filing 6018-1483
Active Assumed Names (if any) Date Expires

Ragtop Productions 05/03/2011 03/08/2021
7/7/2020 11:02:37 PM Page 2 of 2

Exhibit “B”

Division of Business Services
Department of State
State of Tennessee
312 Rosa L. Parks AVE, 6th FL
Nashville, TN 37243-1102
Tre Hargett
Secretary of State
Filing Information
Name: Lady A Entertainment LLC

General Information
SOS Control # 000639005 Formation Locale: TENNESSEE
Filing Type: Limited Liability Company - Domestic Date Formed: 08/30/2010
08/30/2010 3:56 PM Fiscal Year Close 12
Status: Active Member Count: 3
Duration Term: Perpetual
Managed By: Member Managed
Registered Agent Address Principal Address

JULIE BOOS STE 103
STE 103 2300 CHARLOTTE AVE
2300 CHARLOTTE AVE NASHVILLE, TN 37203-1877
NASHVILLE, TN 37203-1877
The following document(s) was/were filed in this office on the date(s) indicated below:
Date Filed Filing Description Image #
02/07/2020 2019 Annual Report B0815-1029
02/08/2019 2018 Annual Report B0652-0570
02/09/2018 2017 Annual Report B0496-1267
03/28/2017 2016 Annual Report B0372-1503
04/01/2016 2015 Annual Report B0229-0960
04/07/2015 2014 Annual Report B0083-7494
03/24/2014 2013 Annual Report A0225-1323
04/01/2013 2012 Annual Report A0171-3231
04/03/2012 2011 Annual Report A0117-2276
Principal Address 1 Changed From: 2300 CHARLOTTE AVENUE To: 2300 CHARLOTTE AVE
Principal Address 2 Changed From: SUITE 103 To: STE 103
Principal Postal Code Changed From: 37203 To: 37203-1877
Principal County Changed From: No value To: DAVIDSON COUNTY
04/04/2011 2010 Annual Report A0069-0192
Member Count Changed From: 1 To: 3
08/30/2010 Initial Filing 6763-0705
7/7/2020 11:05:00 PM Page 1 of 2

Filing Information
Name: Lady A Entertainment LLC
Active Assumed Names (if any) Date Expires
7/7/2020 11:05:00 PM Page 2 of 2

Exhibit “C”

PTO Form 1478 (Rev 9/2006)
OMB No. 0651-0009 (Exp 12/31/2011)
Trademark/Service Mark Application, Principal Register

Serial Number: 85042047
Filing Date: 05/18/2010
The table below presents the data as entered.
Input Field Entered

SERIAL NUMBER 85042047
MARK INFORMATION
*MARK LADY A
STANDARD CHARACTERS YES
USPTO-GENERATED IMAGE YES
LITERAL ELEMENT LADY A
The mark consists of standard characters, without claim to any
MARK STATEMENT
particular font, style, size, or color.
REGISTER Principal
APPLICANT INFORMATION
*OWNER OF MARK Lady A'd Productions, Inc.
INTERNAL ADDRESS Suite 103
*STREET 2300 Charlotte Avenue
*CITY Nashville
*STATE
(Required for U.S. applicants)
Tennessee
*COUNTRY United States

*ZIP/POSTAL CODE
37203
(Required for U.S. applicants only)
PHONE (615) 259-1450

FAX (615) 259-1470
EMAIL ADDRESS XXXX
LEGAL ENTITY INFORMATION
TYPE corporation
STATE/COUNTRY OF INCORPORATION Tennessee
GOODS AND/OR SERVICES AND BASIS INFORMATION
INTERNATIONAL CLASS 009
Series of musical sound recordings; pre-recorded compact
discs and DVD's; digital media, namely, downloadable audio
files and downloadable audio and video recordings featuring
*IDENTIFICATION musical entertainment; downloadable musical sound
recordings; downloadable video recordings featuring musical
entertainment; musical video recordings; video recordings
featuring musical entertainment

FILING BASIS SECTION 1(b)
Entertainment services in the nature of live performances, live
music concerts, and personal appearances all by a musical
group; entertainment services in the nature of audio and visual
performances by a musical group; audio and video recording
services; entertainment, namely, production of live theatrical
*IDENTIFICATION
shows, live musical shows, concerts, and videos; entertainment
services, namely, providing a Web site featuring musical
performances, musical videos, related film clips, photographs,
and other multimedia materials; entertainment services, namely
broadcasting an ongoing series in the field of music
FILING BASIS SECTION 1(b)
ATTORNEY INFORMATION
NAME Edward Playfair
ATTORNEY DOCKET NUMBER 014977-000004
FIRM NAME Adams and Reese LLP
STREET 424 Church Street
CITY Nashville
STATE Tennessee
COUNTRY United States
ZIP/POSTAL CODE 37219
PHONE (615) 259-1450
FAX (615) 259-1470
EMAIL ADDRESS trademarks@arlaw.com
AUTHORIZED TO COMMUNICATE VIA EMAIL Yes
OTHER APPOINTED ATTORNEY Reber M. Boult, Haverly Rauen MacArthur
CORRESPONDENCE INFORMATION
CITY Nashville
STATE Tennessee
PHONE (615) 259-1450
FAX (615) 259-1470

FEE INFORMATION
NUMBER OF CLASSES 2
FEE PER CLASS 325
*TOTAL FEE DUE 650
*TOTAL FEE PAID 650
SIGNATURE INFORMATION
SIGNATURE /Edward Playfair/
SIGNATORY'S NAME Edward Playfair
SIGNATORY'S POSITION Attorney of record, Tennessee bar member.
DATE SIGNED 05/18/2010

PTO Form 1478 (Rev 9/2006)
OMB No. 0651-0009 (Exp 12/31/2011)

To the Commissioner for Trademarks:
MARK: LADY A (Standard Characters, see mark)

The literal element of the mark consists of LADY A.
The mark consists of standard characters, without claim to any particular font, style, size, or color.
The applicant, Lady A'd Productions, Inc., a corporation of Tennessee, having an address of
Suite 103,
2300 Charlotte Avenue
Nashville, Tennessee 37203
United States
requests registration of the trademark/service mark identified above in the United States Patent and Trademark Office on the Principal Register
established by the Act of July 5, 1946 (15 U.S.C. Section 1051 et seq.), as amended, for the following:
International Class 009: Series of musical sound recordings; pre-recorded compact discs and DVD's; digital media, namely, downloadable
audio files and downloadable audio and video recordings featuring musical entertainment; downloadable musical sound recordings;
downloadable video recordings featuring musical entertainment; musical video recordings; video recordings featuring musical entertainment
Intent to Use: The applicant has a bona fide intention to use or use through the applicant's related company or licensee the mark in commerce on
or in connection with the identified goods and/or services. (15 U.S.C. Section 1051(b)).
International Class 041: Entertainment services in the nature of live performances, live music concerts, and personal appearances all by a
musical group; entertainment services in the nature of audio and visual performances by a musical group; audio and video recording services;
entertainment, namely, production of live theatrical shows, live musical shows, concerts, and videos; entertainment services, namely, providing a
Web site featuring musical performances, musical videos, related film clips, photographs, and other multimedia materials; entertainment services,
namely broadcasting an ongoing series in the field of music
Intent to Use: The applicant has a bona fide intention to use or use through the applicant's related company or licensee the mark in commerce on
or in connection with the identified goods and/or services. (15 U.S.C. Section 1051(b)).
The applicant's current Attorney Information:

Edward Playfair and Reber M. Boult, Haverly Rauen MacArthur of Adams and Reese LLP
Suite 2800
424 Church Street
United States
The attorney docket/reference number is 014977-000004.
The applicant's current Correspondence Information:
Edward Playfair
Adams and Reese LLP
Suite 2800
424 Church Street
(615) 259-1450(phone)
(615) 259-1470(fax)
trademarks@arlaw.com (authorized)
A fee payment in the amount of $650 has been submitted with the application, representing payment for 2 class(es).
Declaration

The undersigned, being hereby warned that willful false statements and the like so made are punishable by fine or imprisonment, or both, under
18 U.S.C. Section 1001, and that such willful false statements, and the like, may jeopardize the validity of the application or any resulting
registration, declares that he/she is properly authorized to execute this application on behalf of the applicant; he/she believes the applicant to be
the owner of the trademark/service mark sought to be registered, or, if the application is being filed under 15 U.S.C. Section 1051(b), he/she
believes applicant to be entitled to use such mark in commerce; to the best of his/her knowledge and belief no other person, firm, corporation, or
association has the right to use the mark in commerce, either in the identical form thereof or in such near resemblance thereto as to be likely,
when used on or in connection with the goods/services of such other person, to cause confusion, or to cause mistake, or to deceive; and that all
statements made of his/her own knowledge are true; and that all statements made on information and belief are believed to be true.
Signature: /Edward Playfair/ Date Signed: 05/18/2010

Signatory's Name: Edward Playfair
Signatory's Position: Attorney of record, Tennessee bar member.
RAM Sale Number: 16948

RAM Accounting Date: 05/19/2010

Internet Transmission Date: Tue May 18 20:55:01 EDT 2010
TEAS Stamp: USPTO/BAS-XXX.XXX.XX.XX-2010051820550186
5543-85042047-4605aa65387d2c2b5cf4babb4b
f4433e-DA-16948-20100518203910534930

Exhibit “D”

Exhibit “E”

Exhibit “F”

From: TMOfficialNotices@USPTO.GOV
Sent: Wednesday, June 28, 2017 11:02 PM
To: trademarks@arlaw.com
Subject: Official USPTO Notice of Acceptance/Acknowledgement Sections 8 and 15: U.S. Trademark RN 4004006: LADY A: Docket/Reference No. 014977-4
U.S. Serial Number: 85975356

U.S. Registration Number: 4004006
U.S. Registration Date: Jul 26, 2011
Mark: LADY A
Owner: Lady A Entertainment LLC
Jun 28, 2017
NOTICE OF ACCEPTANCE UNDER SECTION 8

The declaration of use or excusable nonuse filed for the above-identified registration meets the requirements of Section 8 of the Trademark Act, 15 U.S.C. §1058. The Section
8 declaration is accepted.
NOTICE OF ACKNOWLEDGEMENT UNDER SECTION 15

The declaration of incontestability filed for the above-identified registration meets the requirements of Section 15 of the Trademark Act, 15 U.S.C. §1065. The Section 15
declaration is acknowledged.
The registration will remain in force for the class(es) listed below, unless canceled by an order of the Commissioner for Trademarks or a Federal Court, as long as
the requirements for maintaining the registration are fulfilled as they become due.
Class(es):
041
TRADEMARK SPECIALIST
POST-REGISTRATION DIVISION
571-272-9500
REQUIREMENTS FOR MAINTAINING REGISTRATION
WARNING: Your registration will be canceled if you do not file the documents below during the specified statutory time periods.
Requirements in the First Ten Years
What and When to File: You must file a declaration of use (or excusable nonuse) and an application for renewal between the 9th and 10th years after the registration date.
See 15 U.S.C. §§1058, 1059.
Requirements in Successive Ten-Year Periods
What and When to File: You must file a declaration of use (or excusable nonuse) and an application for renewal between every 9th and 10th-year period, calculated from the
registration date. See 15 U.S.C. §§1058, 1059.
Grace Period Filings
The above documents will be considered as timely if filed within six months after the deadlines listed above with the payment of an additional fee.
***THE USPTO IS NOT REQUIRED TO SEND ANY FURTHER NOTICE OR REMINDER OF THESE REQUIREMENTS. THE OWNER SHOULD CONTACT THE USPTO
ONE YEAR BEFORE THE EXPIRATION OF THE TIME PERIODS SHOWN ABOVE TO DETERMINE APPROPRIATE REQUIREMENTS AND FEES.***
To check the status of this registration, go to

https://tsdr.uspto.gov/#caseNumber=85975356&caseSearchType=US_APPLICATION&caseType=DEFAULT&searchType=statusSearch or contact the Trademark Assistance
Center at 1-800-786-9199.
To view this notice and other documents for this registration on-line, go to
https://tsdr.uspto.gov/#caseNumber=85975356&caseSearchType=US_APPLICATION&caseType=DEFAULT&searchType=documentSearch NOTE: This notice will only be
available on-line the next business day after receipt of this e-mail.
* For further information, including information on filing and maintenance requirements for U.S. trademark applications and registrations and required fees,
please consult the USPTO website at https://www.uspto.gov/trademark/ or contact the Trademark Assistance Center at 1-800-786-9199.

Exhibit “G”

Exhibit “H”

Sent: Thursday, September 5, 2019 11:00 PM
To: atltrademark@gtlaw.com
Subject: Official USPTO Notice of Acceptance/Acknowledgement Sections 8 and 15: U.S. Trademark RN 4292685: LADY A: Docket/Reference No.
174940010200

U.S. Registration Date: Feb 19, 2013
Mark: LADY A
Owner: Lady A Entertainment LLC
Sep 5, 2019


Class(es):
009
571-272-9500
See 15 U.S.C. §§1058, 1059.

Center at 1-800-786-9199.

Exhibit “I”

PTO Form 1478 (Rev 9/2006)
OMB No. 0651-0009 (Exp 12/31/2011)

The table below presents the data as entered.
Input Field Entered

SERIAL NUMBER 85089816
MARK INFORMATION
*MARK LADY A
STANDARD CHARACTERS YES
USPTO-GENERATED IMAGE YES
LITERAL ELEMENT LADY A
The mark consists of standard characters, without claim to any particular font,
MARK STATEMENT
style, size, or color.
REGISTER Principal
APPLICANT INFORMATION
*OWNER OF MARK Lady A'd Productions, Inc.
*STREET 2300 Charlotte Avenue
*CITY Nashville
*STATE
(Required for U.S. applicants)
Tennessee
*COUNTRY United States

*ZIP/POSTAL CODE
37203
(Required for U.S. applicants only)
PHONE (615) 259-1450

FAX (615) 259-1470
EMAIL ADDRESS XXXX
LEGAL ENTITY INFORMATION
TYPE corporation
STATE/COUNTRY OF INCORPORATION Tennessee
GOODS AND/OR SERVICES AND BASIS INFORMATION
*IDENTIFICATION Clothing, namely, T-shirts
FILING BASIS SECTION 1(a)
FIRST USE ANYWHERE DATE At least as early as 02/00/2010
FIRST USE IN COMMERCE DATE At least as early as 02/00/2010
SPECIMEN FILE NAME(S)

spec-2091496098-164734228_._LADY_A_-_specimen_of_use_-
ORIGINAL PDF FILE
_class_25.pdf
CONVERTED PDF FILE(S)
\\TICRS\EXPORT11\IMAGEOUT11\850\898\85089816\xml1\APP0003.JPG
(2 pages)
\\TICRS\EXPORT11\IMAGEOUT11\850\898\85089816\xml1\APP0004.JPG
screen shot of point of purchase display, incorporating digital photographed

SPECIMEN DESCRIPTION
product
ATTORNEY INFORMATION
ATTORNEY DOCKET NUMBER 014977-000004
CITY Nashville
STATE Tennessee
PHONE (615) 259-1450
FAX (615) 259-1470
OTHER APPOINTED ATTORNEY Reber M. Boult, Haverly Rauen MacArthur
CORRESPONDENCE INFORMATION
CITY Nashville
STATE Tennessee
PHONE (615) 259-1450
FAX (615) 259-1470
FEE INFORMATION
NUMBER OF CLASSES 1
FEE PER CLASS 325
*TOTAL FEE DUE 325

*TOTAL FEE PAID 325
SIGNATURE INFORMATION
SIGNATURE /Edward Playfair/
SIGNATORY'S NAME Edward Playfair
SIGNATORY'S POSITION Attorney of record, Tennessee bar member.
DATE SIGNED 07/21/2010

PTO Form 1478 (Rev 9/2006)
OMB No. 0651-0009 (Exp 12/31/2011)

To the Commissioner for Trademarks:
MARK: LADY A (Standard Characters, see mark)

The literal element of the mark consists of LADY A.
The mark consists of standard characters, without claim to any particular font, style, size, or color.
The applicant, Lady A'd Productions, Inc., a corporation of Tennessee, having an address of
Suite 103,
2300 Charlotte Avenue
United States
requests registration of the trademark/service mark identified above in the United States Patent and Trademark Office on the Principal Register
established by the Act of July 5, 1946 (15 U.S.C. Section 1051 et seq.), as amended, for the following:
International Class 025: Clothing, namely, T-shirts
In International Class 025, the mark was first used at least as early as 02/00/2010, and first used in commerce at least as early as 02/00/2010, and
is now in use in such commerce. The applicant is submitting one specimen(s) showing the mark as used in commerce on or in connection with
any item in the class of listed goods and/or services, consisting of a(n) screen shot of point of purchase display, incorporating digital
photographed product.
Original PDF file:

spec-2091496098-164734228_._LADY_A_-_specimen_of_use_-_class_25.pdf
Converted PDF file(s) (2 pages)
Specimen File1
Specimen File2
The applicant's current Attorney Information:

Edward Playfair and Reber M. Boult, Haverly Rauen MacArthur of Adams and Reese LLP
Suite 2800
424 Church Street
United States
The attorney docket/reference number is 014977-000004.
The applicant's current Correspondence Information:
Edward Playfair
Adams and Reese LLP
Suite 2800
424 Church Street
(615) 259-1450(phone)
(615) 259-1470(fax)
trademarks@arlaw.com (authorized)
A fee payment in the amount of $325 has been submitted with the application, representing payment for 1 class(es).
Declaration
The undersigned, being hereby warned that willful false statements and the like so made are punishable by fine or imprisonment, or both, under

18 U.S.C. Section 1001, and that such willful false statements, and the like, may jeopardize the validity of the application or any resulting
registration, declares that he/she is properly authorized to execute this application on behalf of the applicant; he/she believes the applicant to be
the owner of the trademark/service mark sought to be registered, or, if the application is being filed under 15 U.S.C. Section 1051(b), he/she
believes applicant to be entitled to use such mark in commerce; to the best of his/her knowledge and belief no other person, firm, corporation, or
association has the right to use the mark in commerce, either in the identical form thereof or in such near resemblance thereto as to be likely,
when used on or in connection with the goods/services of such other person, to cause confusion, or to cause mistake, or to deceive; and that all
statements made of his/her own knowledge are true; and that all statements made on information and belief are believed to be true.
Signature: /Edward Playfair/ Date Signed: 07/21/2010

Signatory's Name: Edward Playfair
Signatory's Position: Attorney of record, Tennessee bar member.
RAM Sale Number: 3321

RAM Accounting Date: 07/22/2010

Internet Transmission Date: Wed Jul 21 16:56:54 EDT 2010
TEAS Stamp: USPTO/BAS-XXX.XXX.XX.XX-2010072116565439
5436-85089816-470fcb4547caa346bdf0b6c836
9fa2853d-DA-3321-20100721164734228679

Exhibit “J”

Exhibit “K”

Sent: Monday, December 4, 2017 11:01 PM
To: atltrademark@gtlaw.com
Subject: Official USPTO Notice of Acceptance/Acknowledgement Sections 8 and 15: U.S. Trademark RN 4030752: LADY A

U.S. Registration Date: Sep 27, 2011
Mark: LADY A
Owner: LADY A ENTERTAINMENT LLC
Dec 4, 2017


Class(es):
025
571-272-9500
See 15 U.S.C. §§1058, 1059.

Center at 1-800-786-9199.

JS 44 (Rev. 0/16) CIVIL COVER SHEET
The JS 44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or other papers as required by law, except as
provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of Court for the
purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON NEXT PAGE OF THIS FORM.)
I. (a) PLAINTIFFS DEFENDANTS

Hillary Scott, Charles Kelley, David Haywood, and Lady A Entertainment Anita White
LLC
(b) County of Residence of First Listed Plaintiff Williamson County, Tenn. County of Residence of First Listed Defendant King County, Wash.
(EXCEPT IN U.S. PLAINTIFF CASES) (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.
(c) Attorneys (Firm Name, Address, and Telephone Number) Attorneys (If Known)
Greenberg Traurig Cooley LLP
1000 Louisiana, Suite 1700 1700 Seventh Avenue, Suite 1900
Houston, TX 77002 Seattle, WA 98101
II. BASIS OF JURISDICTION (Place an “X” in One Box Only) III. CITIZENSHIP OF PRINCIPAL PARTIES (Place an “X” in One Box for Plaintiff
(For Diversity Cases Only) and One Box for Defendant)
u 1 U.S. Government u 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.S. Government Not a Party) Citizen of This State u 1 u 1 Incorporated or Principal Place u 4 u 4
of Business In This State
u 2 U.S. Government u 4 Diversity Citizen of Another State u 2 u 2 Incorporated and Principal Place u 5 u 5
Defendant (Indicate Citizenship of Parties in Item III) of Business In Another State
Citizen or Subject of a u 3 u 3 Foreign Nation u 6 u 6

Foreign Country
IV. NATURE OF SUIT (Place an “X” in One Box Only)
CONTRACT TORTS FORFEITURE/PENALTY BANKRUPTCY OTHER STATUTES
u 110 Insurance PERSONAL INJURY PERSONAL INJURY u 625 Drug Related Seizure u 422 Appeal 28 USC 158 u 375 False Claims Act
u 120 Marine u 310 Airplane u 365 Personal Injury - of Property 21 USC 881 u 423 Withdrawal u 376 Qui Tam (31 USC
u 130 Miller Act u 315 Airplane Product Product Liability u 690 Other 28 USC 157 3729(a))
u 140 Negotiable Instrument Liability u 367 Health Care/ u 400 State Reapportionment
u 150 Recovery of Overpayment u 320 Assault, Libel & Pharmaceutical PROPERTY RIGHTS u 410 Antitrust
& Enforcement of Judgment Slander Personal Injury u 820 Copyrights u 430 Banks and Banking
u 151 Medicare Act u 330 Federal Employers’ Product Liability u 830 Patent u 450 Commerce
u 152 Recovery of Defaulted Liability u 368 Asbestos Personal u 840 Trademark u 460 Deportation
Student Loans u 340 Marine Injury Product u 470 Racketeer Influenced and
(Excludes Veterans) u 345 Marine Product Liability LABOR SOCIAL SECURITY Corrupt Organizations
u 153 Recovery of Overpayment Liability PERSONAL PROPERTY u 710 Fair Labor Standards u 861 HIA (1395ff) u 480 Consumer Credit
of Veteran’s Benefits u 350 Motor Vehicle u 370 Other Fraud Act u 862 Black Lung (923) u 490 Cable/Sat TV
u 160 Stockholders’ Suits u 355 Motor Vehicle u 371 Truth in Lending u 720 Labor/Management u 863 DIWC/DIWW (405(g)) u 850 Securities/Commodities/
u 190 Other Contract Product Liability u 380 Other Personal Relations u 864 SSID Title XVI Exchange
u 195 Contract Product Liability u 360 Other Personal Property Damage u 740 Railway Labor Act u 865 RSI (405(g)) u 890 Other Statutory Actions
u 196 Franchise Injury u 385 Property Damage u 751 Family and Medical u 891 Agricultural Acts
u 362 Personal Injury - Product Liability Leave Act u 893 Environmental Matters
Medical Malpractice u 790 Other Labor Litigation u 895 Freedom of Information
REAL PROPERTY CIVIL RIGHTS PRISONER PETITIONS u 791 Employee Retirement FEDERAL TAX SUITS Act
u 210 Land Condemnation u 440 Other Civil Rights Habeas Corpus: Income Security Act u 870 Taxes (U.S. Plaintiff u 896 Arbitration
u 220 Foreclosure u 441 Voting u 463 Alien Detainee or Defendant) u 899 Administrative Procedure
u 230 Rent Lease & Ejectment u 442 Employment u 510 Motions to Vacate u 871 IRS—Third Party Act/Review or Appeal of
u 240 Torts to Land u 443 Housing/ Sentence 26 USC 7609 Agency Decision
u 245 Tort Product Liability Accommodations u 530 General u 950 Constitutionality of
u 290 All Other Real Property u 445 Amer. w/Disabilities - u 535 Death Penalty IMMIGRATION State Statutes
Employment Other: u 462 Naturalization Application
u 446 Amer. w/Disabilities - u 540 Mandamus & Other u 465 Other Immigration
Other u 550 Civil Rights Actions
u 448 Education u 555 Prison Condition
u 560 Civil Detainee -
Conditions of
Confinement
V. ORIGIN (Place an “X” in One Box Only)
u 1 Original u 2 Removed from u 3 Remanded from u 4 Reinstated or u 5 Transferred from u 6 Multidistrict u 8 Multidistrict
Proceeding State Court Appellate Court Reopened Another District Litigation - Litigation -
(specify) Transfer Direct File
Cite the U.S. Civil Statute under which you are filing (Do not cite jurisdictional statutes unless diversity):
28 U.S.C. §§ 2201 and 2202
VI. CAUSE OF ACTION Brief description of cause:
Declaratory judgment for validity of existing, incontestable mark and non-infringement of alleged trademark.
VII. REQUESTED IN u CHECK IF THIS IS A CLASS ACTION DEMAND $ CHECK YES only if demanded in complaint:
COMPLAINT: UNDER RULE 23, F.R.Cv.P. 0.00 JURY DEMAND: u Yes u No
VIII. RELATED CASE(S)
(See instructions):
IF ANY JUDGE DOCKET NUMBER
DATE SIGNATURE OF ATTORNEY OF RECORD
07/08/2020 /s/ Mary-Olga Lovett
FOR OFFICE USE ONLY
RECEIPT # Case 3:20-cv-00585 Document

AMOUNT APPLYING 1-12
IFP Filed 07/08/20
JUDGE Page 1 of 2 PageID #: 52
MAG. JUDGE
JS 44 Reverse (Rev. 0/16)
INSTRUCTIONS FOR ATTORNEYS COMPLETING CIVIL COVER SHEET FORM JS 44

Authority For Civil Cover Sheet
The JS 44 civil cover sheet and the information contained herein neither replaces nor supplements the filings and service of pleading or other papers as
required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is
required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. Consequently, a civil cover sheet is submitted to the Clerk of
Court for each civil complaint filed. The attorney filing a case should complete the form as follows:
I.(a) Plaintiffs-Defendants. Enter names (last, first, middle initial) of plaintiff and defendant. If the plaintiff or defendant is a government agency, use
only the full name or standard abbreviations. If the plaintiff or defendant is an official within a government agency, identify first the agency and
then the official, giving both name and title.
(b) County of Residence. For each civil case filed, except U.S. plaintiff cases, enter the name of the county where the first listed plaintiff resides at the
time of filing. In U.S. plaintiff cases, enter the name of the county in which the first listed defendant resides at the time of filing. (NOTE: In land
condemnation cases, the county of residence of the "defendant" is the location of the tract of land involved.)
(c) Attorneys. Enter the firm name, address, telephone number, and attorney of record. If there are several attorneys, list them on an attachment, noting
in this section "(see attachment)".
II. Jurisdiction. The basis of jurisdiction is set forth under Rule 8(a), F.R.Cv.P., which requires that jurisdictions be shown in pleadings. Place an "X"
in one of the boxes. If there is more than one basis of jurisdiction, precedence is given in the order shown below.
United States plaintiff. (1) Jurisdiction based on 28 U.S.C. 1345 and 1348. Suits by agencies and officers of the United States are included here.
United States defendant. (2) When the plaintiff is suing the United States, its officers or agencies, place an "X" in this box.
Federal question. (3) This refers to suits under 28 U.S.C. 1331, where jurisdiction arises under the Constitution of the United States, an amendment
to the Constitution, an act of Congress or a treaty of the United States. In cases where the U.S. is a party, the U.S. plaintiff or defendant code takes
precedence, and box 1 or 2 should be marked.
Diversity of citizenship. (4) This refers to suits under 28 U.S.C. 1332, where parties are citizens of different states. When Box 4 is checked, the
citizenship of the different parties must be checked. (See Section III below; NOTE: federal question actions take precedence over diversity
cases.)
III. Residence (citizenship) of Principal Parties. This section of the JS 44 is to be completed if diversity of citizenship was indicated above. Mark this
section for each principal party.
IV. Nature of Suit. Place an "X" in the appropriate box. If the nature of suit cannot be determined, be sure the cause of action, in Section VI below, is
sufficient to enable the deputy clerk or the statistical clerk(s) in the Administrative Office to determine the nature of suit. If the cause fits more than
one nature of suit, select the most definitive.
V. Origin. Place an "X" in one of the seven boxes.

Original Proceedings. (1) Cases which originate in the United States district courts.
Removed from State Court. (2) Proceedings initiated in state courts may be removed to the district courts under Title 28 U.S.C., Section 1441.
When the petition for removal is granted, check this box.
Remanded from Appellate Court. (3) Check this box for cases remanded to the district court for further action. Use the date of remand as the filing
date.
Reinstated or Reopened. (4) Check this box for cases reinstated or reopened in the district court. Use the reopening date as the filing date.
Transferred from Another District. (5) For cases transferred under Title 28 U.S.C. Section 1404(a). Do not use this for within district transfers or
multidistrict litigation transfers.
Multidistrict Litigation – Transfer. (6) Check this box when a multidistrict case is transferred into the district under authority of Title 28 U.S.C.
Section 1407.
Multidistrict Litigation – Direct File. (8) Check this box when a multidistrict case is filed in the same district as the Master MDL docket.
PLEASE NOTE THAT THERE IS NOT AN ORIGIN CODE 7. Origin Code 7 was used for historical records and is no longer relevant due to
changes in statue.
VI. Cause of Action. Report the civil statute directly related to the cause of action and give a brief description of the cause. Do not cite jurisdictional
statutes unless diversity. Example: U.S. Civil Statute: 47 USC 553 Brief Description: Unauthorized reception of cable service
VII. Requested in Complaint. Class Action. Place an "X" in this box if you are filing a class action under Rule 23, F.R.Cv.P.
Demand. In this space enter the actual dollar amount being demanded or indicate other demand, such as a preliminary injunction.
Jury Demand. Check the appropriate box to indicate whether or not a jury is being demanded.
VIII. Related Cases. This section of the JS 44 is used to reference related pending cases, if any. If there are related pending cases, insert the docket
numbers and the corresponding judge names for such cases.
Date and Attorney Signature. Date and sign the civil cover sheet.

Formerly Known As Lady Antebellum Complaint

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Formerly Known As Lady Antebellum Complaint

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IN THE UNITED STATES DISTRICT COURT

MIDDLE DISTRICT OF TENNESSEE

HILLARY SCOTT, CHARLES )

PLAINTIFFS’ ORIGINAL COMPLAINT

file this Original Complaint and allege as follows:

1. Plaintiff Hillary Scott (“Scott”) is an individual who is a citizen and resident of

2. Plaintiff Charles Kelley (“Kelley”) is an individual who is a citizen and resident of

3. Plaintiff David Haywood (“Haywood”) is an individual who is a citizen and

resident of Nashville, Tennessee.

5. Defendant Anita White (“White”) is an individual who is a citizen and resident of

frequently performing in Memphis.

II. NATURE OF THE ACTION

III. JURISDICTION AND VENUE

Tennessee during the parties’ attempted negotiation of a coexistence agreement, including

written correspondence to Plaintiffs, and participating in telephone conferences and a Zoom

giving rise to this action occurred in this judicial district.

IV. FACTUAL ALLEGATIONS

“Lady A” interchangeably with “Lady Antebellum” since the 2006-2007 timeframe.

simply “Lady A.”

(last accessed on July 7, 2020).

the bottom corner of the video.

acknowledging the registration’s incontestability. See Exhibit F.

2019, acknowledging the registration’s incontestability. See Exhibit H.

under Sections 8 & 15 on December 4, 2017, acknowledging the registration’s incontestability.

collectively, the “LADY A Registrations.”

performances, or Plaintiffs’ sale of souvenir merchandise.

Musical Group in highly-visible ways.

Northwest, Louisiana, Mississippi, and Tennessee. According to publicly-available information,

a trademark or service mark.

Plaintiffs’ music and the source of White’s music.

See https://www.instagram.com/p/CBeiDpAHN6z/ (last accessed on July 7, 2020).

important and I no longer trust them.” See https://www.newsday.com/entertainment/music/lady-

antebellum-lady-a-1.45795425 (last accessed on July 8, 2020).

29. Notwithstanding White’s comments, her counsel continued to negotiate a draft

monetary payment was never offered or demanded.

course.” (emphasis added).

2201 and 2202.

trademark use of “Lady A” to identify herself as a musical performer.

(Declaratory Judgment Under 28 U.S.C. § 2201)

as if fully set forth herein.

performances, and merchandise.

due to her use of “Lady A”.

U.S.C. § 1501, et seq.

39. This controversy is ripe for adjudication.

VI. PRAYER FOR RELIEF

their favor and:

A,” including any trade names or common law rights;

b. Enter a declaratory judgment confirming that LAE’s LADY A Registrations are

valid, subsisting, and incontestable; and

GREENBERG TRAURIG LLP

By: /s/ Mary-Olga Lovett

NEAL & HARWELL, PLC

By: /s/ William T. Ramsey _________

Attorneys for Plaintiffs Hillary Scott,

Case 3:20-cv-00585 Document 1-1 Filed 07/08/20 Page 1 of 3 PageID #: 14

Name: LADY A'D PRODUCTIONS, INC.

Registered Agent Address Principal Address

Name: LADY A'D PRODUCTIONS, INC.

Active Assumed Names (if any) Date Expires

7/7/2020 11:02:37 PM Page 2 of 2

Case 3:20-cv-00585 Document 1-2 Filed 07/08/20 Page 1 of 3 PageID #: 17

Name: Lady A Entertainment LLC