2022-cv-60736

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. Filing fees $ 402.00 receipt number AFLSDC-15560218, filed by Louis Vuitton Malletier.

Civil Cover Sheet

(Exhibit 1 to Complaint - Certificates of Registration for the Louis Vuitton Trademarks)

Clerks Notice of Judge Assignment to Judge William P. Dimitrouleas and Magistrate Judge Lurana S. Snow. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Lurana S. Snow is available to handle any or all proceedings in this case. If agreed, parties should complete and file the Consent form found on our website. It is not necessary to file a document indicating lack of consent. Pro se (NON-PRISONER) litigants may receive Notices of Electronic Filings (NEFS) via email after filing a Consent by Pro Se Litigant (NON-PRISONER) to Receive Notices of Electronic Filing. The consent form is available under the forms section of our website.

FORM AO 120 SENT TO DIRECTOR OF U.S. PATENT AND TRADEMARK

(Exhibit Complaint) (bb)

Order Requiring Joint Scheduling Report. Signed by Judge William P. Dimitrouleas on 4/21/2022. See attached document for full details.

Plaintiff's Corporate Disclosure Statement by Louis Vuitton Malletier identifying Corporate Parent LVMH Moet Hennessy Louis Vuitton, SE for Louis Vuitton Malletier (Wiborg-Rodriguez, T.)

Plaintiff's MOTION to Seal per Local Rule 5.4 by Louis Vuitton Malletier.

Text of Proposed Order

ORDER granting [6] Motion to File Under Seal. Schedule "A" to Plaintiffs Complaint shall be filed under seal and shall remain under seal until further order from this Court. Signed by Judge William P. Dimitrouleas on 4/25/2022. See attached document for full details.

Order (Text entry; no document attached.)

Notice of Filing BOND in the amount of $10,000.00 posted by Louis Vuitton Malletier Approved by Judge William P. Dimitrouleas

Plaintiff's MOTION to Unseal by Louis Vuitton Malletier.

Text of Proposed Order

ORDER GRANTING PLAINTIFFS MOTION TO UNSEAL. ORDER granting [14] Motion to Unseal Document. Signed by Judge William P. Dimitrouleas on 5/4/2022. See attached document for full details.

NOTICE of Compliance re 15 Order on Motion to Unseal Document. (All Sealed Docket Entries Unsealed)

AMENDED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants, filed by Louis Vuitton Malletier.

Exhibit 1 to Amended Complaint - Certificates of Registration for the Louis Vuit

NOTICE of Filing Proposed Summons(es) by Louis Vuitton Malletier

Summon(s)

Summons Issued as to The Individuals, Business Entities, and Unincorporated Associations identified on Schedule A.

Joint MOTION to Continue Hearing and Deadlines by chrisshoes.com. Attorney Douglas J. Giuliano added to party chrisshoes.com(pty:dft). Responses due by 5/24/2022

Text of Proposed Order

NOTICE by Louis Vuitton Malletier re [4] Order Requiring Joint Scheduling Report, [7] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order, Preliminary Injunction, and Order Restraining Transfer of Assets Against Defendants and Memorandum of Law in Support Thereof, [1] Complaint, [9] Order on Motion to Seal, [10] Order on Ex Parte Motion, upon Defendants via Electronic Mail

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Louis Vuitton Malletier re [4] Order Requiring Joint Scheduling Report, [7] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order, Preliminary Injunction, and Order Restraining Transfer of Assets Against Defendants and Memorandum of Law in Support Thereof, [1] Complaint, [9] Order on Motion to Seal, [10] Order on Ex Parte Motion, [14] Motion to Unseal Document upon Defendants via Registrar

CERTIFICATE OF SERVICE by Louis Vuitton Malletier re [5] Certificate of Other Affiliates/Corporate Disclosure Statement, [6] Plaintiff's MOTION to Seal per Local Rule 5.4, [4] Order Requiring Joint Scheduling Report, [3] Form AO 120/121, [7] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order, Preliminary Injunction, and Order Restraining Transfer of Assets Against Defendants and Memorandum of Law in Support Thereof, [1] Complaint, [8] Plaintiff's EX PARTE MOTION for Order Authorizing Alternate Service of Process on Defendants Pursuant to Federal Rule of Civil Procedure 4(f)(3) and Memorandum of Law in Support Thereof, [9] Order on Motion to Seal, [10] Order on Ex Parte Motion, [2] Clerk's Notice of Judge Assignment, [14] Motion to Unseal Document, [13] Bond, [12] Sealed Document, [11] Order on Ex Parte Motion, upon Defendants via website posting

Set/Reset Response/Answer Due Deadline per DE [25] : chrisshoes.com response/answer due 6/28/2022. (Text entry; no document attached.)

SUMMONS (Affidavit) Returned Executed on [17] Amended Complaint/Amended Notice of Removal, [1] Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Louis Vuitton Malletier. bedclothesone.shop served on 5/5/2022, response/answer due 5/26/2022; bjik.shop served on 5/5/2022, response/answer due 5/26/2022; bobmore.shop served on 5/5/2022, response/answer due 5/26/2022; caosonline.shop served on 5/5/2022, response/answer due 5/26/2022; caukas.com served on 5/5/2022, response/answer due 5/26/2022; cchioes.shop served on 5/5/2022, response/answer due 5/26/2022; chrisshoes.com served on 5/5/2022, response/answer due 5/26/2022; clothesy.co served on 5/5/2022, response/answer due 5/26/2022; daisymary.com served on 5/5/2022, response/answer due 5/26/2022; dghluxury.com served on 5/5/2022, response/answer due 5/26/2022; fairiey.com served on 5/5/2022, response/answer due 5/26/2022; fashionstylemall.shop served on 5/5/2022, response/answer due 5/26/2022; freetopi.com served on 5/5/2022, response/answer due 5/26/2022; geatye.com served on 5/5/2022, response/answer due 5/26/2022; glohbo.com served on 5/5/2022, response/answer due 5/26/2022; gorgeosu.com served on 5/5/2022, response/answer due 5/26/2022; hfuyerg.shop served on 5/5/2022, response/answer due 5/26/2022; iofferdesign.com served on 5/5/2022, response/answer due 5/26/2022; jshudju.shop served on 5/5/2022, response/answer due 5/26/2022; jsiiqd.shop served on 5/5/2022, response/answer due 5/26/2022; lauraditulio.com served on 5/5/2022, response/answer due 5/26/2022; lbreai.com served on 5/5/2022, response/answer due 5/26/2022; louismmn.life served on 5/5/2022, response/answer due 5/26/2022; madgicxde.com served on 5/5/2022, response/answer due 5/26/2022; petcdplanet.com served on 5/5/2022, response/answer due 5/26/2022; restcoy.com served on 5/5/2022, response/answer due 5/26/2022; shijiaclothing.online served on 5/5/2022, response/answer due 5/26/2022; shop8.andrewss.com served on 5/5/2022, response/answer due 5/26/2022; shopluxebk.com served on 5/5/2022, response/answer due 5/26/2022; shoppalaza.store served on 5/5/2022, response/answer due 5/26/2022; sport9gift.us served on 5/5/2022, response/answer due 5/26/2022; squpstore.com served on 5/5/2022, response/answer due 5/26/2022; tixor.shop served on 5/5/2022, response/answer due 5/26/2022; wkdlbags.com served on 5/5/2022, response/answer due 5/26/2022; zanfelbagstore.com served on 5/5/2022, response/answer due 5/26/2022.

Affidavit of Service

Affidavit of Service

Affidavit of Service

ORDER granting [20] Motion to Continue. Per the agreement of the parties, the Preliminary Injunction hearing, as scheduled for May 13, 2022 at 11:00 A.M., is hereby CONTINUED as to Defendant Number 7 ONLY to June 10, 2022 at 11:15 A.M. The Preliminary Injunction hearing scheduled for May 13, 2022 at 11:00 A.M. will take place as to all Defendants except Defendant Number 7. Prelinjhrg Hearing set for 6/10/2022 11:15 AM before Judge William P. Dimitrouleas. Prelinjhrg Hearing set for 5/13/2022 11:00 AM before Judge William P. Dimitrouleas. chrisshoes.com response/answer due 6/28/2022. Signed by Judge William P. Dimitrouleas on 5/11/2022. See attached document for full details.

Set/Reset Deadlines/Hearings per DE [25] as to [7] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order, Preliminary Injunction, and Order Restraining Transfer of Assets Against Defendants and Memorandum of Law in Support Thereof. Responses due by 5/31/2022 Replies due by 6/7/2022. (Text entry; no document attached.)

NOTICE by Louis Vuitton Malletier of Identification of Additional PayPal Account Used By Defendant Number 25

Declaration of Kathleen Burns in Support Thereof

Exhibit 1 to the Declaration of Kathleen Burns

ORDER GRANTING APPLICATION FOR ENTRY OF PRELIMINARY INJUNCTION granting 7 Application for Preliminary Injunction. Signed by Judge William P. Dimitrouleas on 5/13/2022. See attached document for full details.

PAPERLESS Minute Entry for proceedings held before Judge William P. Dimitrouleas: Motion Hearing held on 5/13/2022 re 7 Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order, Preliminary Injunction, and Order Restraining Transfer of Assets Against Defendants and Memorandum of Law in Support Thereof filed by Louis Vuitton Malletier. This hearing was continued as to Defendant 7, who is not included in the motion hearing today. No Defendants appeared. Court will enter Order granting Preliminary Injunction. Total time in court: 15 minutes. Attorney Appearance(s): T. Raquel Wiborg-Rodriguez, Court Reporter: Sharon Velazco, 305-523-5636 / Sharon_PellVelazco@flsd.uscourts.gov.

NOTICE by Louis Vuitton Malletier of Identification of Additional PayPal Account Used By Defendant Number 25

Declaration of Kathleen Burns in Support Thereof

Exhibit 1 to the Declaration of Kathleen Burns

Joint MOTION to Continue Hearing and Deadlines as to Defendant Number 7 by Louis Vuitton Malletier. Responses due by 6/9/2022

Text of Proposed Order

ORDER granting [30] Motion to Continue. Prelinjhrg Hearing set for 6/10/2022 11:15 AM before Judge William P. Dimitrouleas CONTINUED to 7/1/2022 01:15 PM before Judge William P. Dimitrouleas as to Defendant Number 7 ONLY. Responses due by 6/14/2022 Replies due by 6/21/2022. chrisshoes.com response/answer due 7/12/2022. Signed by Judge William P. Dimitrouleas on 5/27/2022. See attached document for full details.

Set/Reset Response/Answer Due Deadline per DE [31]: chrisshoes.com response/answer due 7/12/2022. (Text entry; no document attached.)

Case Reassignment of Paired Magistrate Judge to Magistrate Judge Patrick M. Hunt. Magistrate Judge Lurana S. Snow no longer assigned to case.

ORDER TO SHOW CAUSE FOR LACK OF PROSECUTION Show Cause Response due by 6/9/2022. Signed by Judge William P. Dimitrouleas on 6/2/2022. See attached document for full details.

Case Reassignment of Paired Magistrate Judge pursuant to Administrative Order(s) - 2022-47 to Magistrate Judge Alicia O. Valle. Magistrate Judge Patrick M. Hunt no longer assigned to case.

RESPONSE TO ORDER TO SHOW CAUSE re [33] Order to Show Cause by Louis Vuitton Malletier. (Wiborg-Rodriguez, T.)

Plaintiff's MOTION for Clerks Entry of Default as to The Individuals, Business Entities, and Unincorporated Associations identified on Schedule A, bedclothesone.shop, bjik.shop, bobmore.shop, caosonline.shop, caukas.com, cchioes.shop, clothesy.co, daisymary.com, dghluxury.com, fairiey.com, fashionstylemall.shop, freetopi.com, geatye.com, glohbo.com, gorgeosu.com, hfuyerg.shop, iofferdesign.com, jshudju.shop, jsiiqd.shop, lauraditulio.com, lbreai.com, louismmn.life, madgicxde.com, petcdplanet.com, restcoy.com, shijiaclothing.online, shop8.andrewss.com, shopluxebk.com, shoppalaza.store, squpstore.com, tixor.shop, wkdlbags.com, zanfelbagstore.com by Louis Vuitton Malletier.

Exhibit Declaration of Stephen M. Gaffigan in Support of Request for Clerk'

Text of Proposed Order

Clerks Entry of Default as to The Individuals, Business Entities, and Unincorporated Associations identified on Schedule A - Granting 36 Motion for Clerks Entry of Default. Signed by DEPUTY CLERK on 6/10/2022.

STIPULATION Motion for Entry of Preliminary Injunction as to Defendant Number 7 by Louis Vuitton Malletier

Exhibit 1 - proposed Stipulated Entry of Preliminary Injunction as to Defendant

Clerks Notice to Filer re 38 Motion for Preliminary Injunction. Wrong Event Selected - Document is a Motion; ERROR - The Filer selected the wrong event. A motion event must always be selected when filing a motion. The correction was made by the Clerk. It is not necessary to refile this document.

ORDER granting [38] Stipulated Motion for Preliminary Injunction as to Defendant Number 7. Signed by Judge William P. Dimitrouleas on 6/15/2022. See attached document for full details.

Plaintiff's MOTION for Clerks Entry of Default as to sport9gift.us by Louis Vuitton Malletier.

Exhibit Declaration of Stephen M. Gaffigan in Support of Request for Clerk'

Text of Proposed Order

Clerks Entry of Default as to sport9gift.us Granting 41 Motion for Clerks Entry of Default. Signed by DEPUTY CLERK on 6/17/2022.

NOTICE by Louis Vuitton Malletier of Identification of Additional Financial Accounts Used by Defendant Number 25

Declaration of Kathleen Burns in Support Thereof

Exhibit 1 to the Declaration of Kathleen Burns

ORDER TO SHOW CAUSE re 24 Summons Returned Executed filed by Louis Vuitton Malletier. Show Cause Response due by 7/5/2022. Signed by Judge William P. Dimitrouleas on 6/27/2022. See attached document for full details.

NOTICE of Voluntary Dismissal Without Prejudice, of Defendant Numbers 5 and 13 by Louis Vuitton Malletier

Text of Proposed Order

NOTICE by Louis Vuitton Malletier of Identification of Additional PayPal Account Used by Defendant Number 35

Declaration of Kathleen Burns in Support Thereof

Exhibit 1 to the Declaration of Kathleen Burns

Plaintiff's MOTION for Default Judgment Against Defendants and Memorandum of Law in Support Thereof by Louis Vuitton Malletier.

Declaration of T. Raquel Wiborg-Rodriguez in Support Thereof

Text of Proposed Order Granting Motion for Final Default Judgment

Text of Proposed Order Final Default Judgment and Permanent Injunction

ORDER Dismissing Case as to Defendant Numbers 5 and 13 - case remains open. Signed by Judge William P. Dimitrouleas on 7/6/2022. See attached document for full details.

ORDER TO SHOW CAUSE WHY COURT SHOULD NOT GRANT MOTION FOR FINAL DEFAULT JUDGMENT. Show Cause Response due by 7/19/2022. Signed by Judge William P. Dimitrouleas on 7/6/2022. See attached document for full details.

Joint MOTION for Extension of Time to Extend Answer Deadline as to Defendant Number 7, by Louis Vuitton Malletier. Responses due by 7/25/2022

Text of Proposed Order

ORDER: Granting [50] Joint MOTION for Extension of Time to Extend Answer Deadline as to Defendant Number 7, filed by Louis Vuitton Malletier. Per the agreement of the parties, the deadline for Defendant 7 only to file a response to the Amended Complaint is continued to August 11, 2022. Signed by Judge William P. Dimitrouleas on 7/12/2022. See attached document for full details.

CERTIFICATE OF SERVICE by Louis Vuitton Malletier re [49] Order to Show Cause upon Defendants via Electronic Mail and via Website Posting

FINAL DEFAULT JUDGMENT AND PERMANENT INJUNCTION: GRANTING [47] Plaintiff's MOTION for Default Judgment Against Defendants and Memorandum of Law in Support Thereof filed by Louis Vuitton Malletier. This case remains open as to Defendant Number 7 ONLY, until further Order of the Court. Signed by Judge William P. Dimitrouleas on 7/22/2022. See attached document for full details.

ORDER GRANTING MOTION FOR FINAL DEFAULT JUDGMENT: Plaintiff's Motion [DE 47] is hereby GRANTED. In accordance with Federal Rule of Civil Procedure 58, a separate final judgment will be entered. Signed by Judge William P. Dimitrouleas on 7/22/2022. See attached document for full details.

Joint MOTION for Extension of Time to File Response/Reply/Answer as to [17] Amended Complaint/Amended Notice of Removal, by chrisshoes.com.

Text of Proposed Order

ORDER granting [55] Motion for Extension of Time to File Response/Answer to Amended Complaint. Response/Answer due 9/1/2022. Signed by Judge William P. Dimitrouleas on 8/10/2022. See attached document for full details.

Joint MOTION for Extension of Time to File Response/Reply/Answer as to [17] Amended Complaint/Amended Notice of Removal, by Louis Vuitton Malletier.

Text of Proposed Order

ORDER granting in part and denying in part [57] Motion for Extension of Time to File Response/Answer to a Amended Complaint or Other Case Initiating Document. chrisshoes.com Response/Answer due 9/8/2022. Signed by Judge William P. Dimitrouleas on 9/1/2022. See attached document for full details.

Agreed MOTION to Approve Consent Judgment as to Defendant Number 7 (Responses due by 9/22/2022), Agreed MOTION for Permanent Injunction as to Defendant Number 7 by Louis Vuitton Malletier.

Text of Proposed Order

CONSENT FINAL JUDGMENT AND PERMANENT INJUNCTION AS TO DEFENDANT NUMBER 7: The Clerk is directed to CLOSE this case and DENY AS MOOT any pending motions. Closing Case. Signed by Judge William P. Dimitrouleas on 9/8/2022. See attached document for full details.

FORM AO 120 SENT TO DIRECTOR OF U.S. PATENT AND TRADEMARK.

Judgment