2022-cv-61659

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. Filing fees $ 402.00 receipt number AFLSDC-15926848, filed by Apple Corps Limited, Subafilms Limited.

Civil Cover Sheet

Exhibit 1 to Complaint Certificates of Registration for the Beatles Trademarks

(Exhibit 2 to Complaint Certificate of Registration for the Yellow Submarine Trademark)

Clerks Notice of Judge Assignment to Judge Raag Singhal. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Melissa Damian 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

Complaint and Exhibits

Plaintiff's Corporate Disclosure Statement by Apple Corps Limited, Subafilms Limited (Wiborg-Rodriguez, T.)

Plaintiff's MOTION to Seal per Local Rule 5.4 by Apple Corps Limited, Subafilms Limited.

Text of Proposed Order

Clerk's Notice to Filer re 4 Certificate of Other Affiliates/Corporate Disclosure Statement. Parties Not Added; ERROR - The Filer failed to add all parties from the Notice Filer is instructed to file a Notice of Entry of Parties Listed into CM/ECF and add the additional parties. Re: Apple Corps Limited. Apple Corps Limited owns 10% or more of the stock of Plaintiff, Subafilms Limited.

NOTICE OF COURT PRACTICE Unless otherwise specified by the Court, every motion, legal memorandum, brief, and otherwise shall: be double-spaced, in justified alignment, in 12-point font, using either Times New Roman or Arial typeface. This Notice does not supplant the requirements and provisions of Local Rule 7.1(c). The Court cautions parties against excessive use of footnotes. Multiple Plaintiffs or Defendants shall file joint motions with co-parties unless there are clear conflicts of position. If conflicts of position exist, parties shall explain the conflicts in their separate motions. Parties are encouraged to seek extensions of time in a timely fashion. "A motion for extension of time is not self-executing; no motion is, unless expressly provided for by the applicable rule. Yet, by filing these motions on or near the last day, and then sitting idle pending the Court's disposition of the motion, parties essentially grant their own motion. The Court will not condone this." Compere v. Nusret Miami, LLC, 2020 WL 2844888, at *2 (S.D. Fla. May 7, 2020) (internal citations omitted). Exhibits to pleadings and motions shall be docketed in accordance with the Courts CM/ECF procedures, Rule 3L.(2): (2) Describing an Attachment to a Docket Entry A party filing an attachment to a document shall select one of the prescribed attachment categories from the drop-down menu (e.g., affidavit, transcript), provide an alphabetical or numerical designation (e.g., Exhibit A, Exhibit 1), and descriptively name each attachment (e.g., Exhibit 1 - Affidavit of Boo Radley) in a manner that enables the Court to easily locate and distinguish attachments. (Emphasis added.) Local Rule 16.4, Local Rules for the United States District Court for the Southern District of Florida, requires that a Notice of Settlement "shall be filed and served jointly by counsel for all parties to the settlement." A unilateral notice of settlement will not stay pre-trial deadlines or hearings. Failure to comply with any of these procedures may result in the imposition of appropriate sanctions. Signed by Judge Raag Singhal on 9/12/2022.

PAPERLESS ORDER TO FILE CERTIFICATE OF INTERESTED PERSONS Within SEVEN (7) DAYS of entry of an appearance, each party, including governmental parties, must file certificates of interested parties and corporate disclosure statements that contain a complete list of persons, associated persons, firms, partnerships, or corporations that have a financial interest in the outcome of this case, including subsidiaries, conglomerates, affiliates, parent corporations, and other identifiable legal entities related to a party. The parties shall not include Judge Singhal or the paired magistrate judges as interested parties unless they have an interest in the litigation. Throughout the pendency of the action, the parties are under a continuing obligation to amend, correct, and update the certificates. Signed by Judge Raag Singhal on 9/12/2022.

PAPERLESS ORDER granting 5 Motion to Seal. Schedule "A" to the Plaintiffs' Complaint shall be filed under seal and shall remain under seal until further Court order. Signed by Judge Raag Singhal on 9/12/2022.

SYSTEM ENTRY - Docket Entry 10 [motion] restricted/sealed until further notice. (1336528) (Text entry; no document attached.)

SYSTEM ENTRY - Docket Entry 11 [motion] restricted/sealed until further notice. (1336528) (Text entry; no document attached.)

SYSTEM ENTRY - Docket Entry 12 [misc] restricted/sealed until further notice. (1336528) (Text entry; no document attached.)

Certificate of Other Affiliates by Apple Corps Limited, Subafilms Limited (Wiborg-Rodriguez, T.)

SYSTEM ENTRY - Docket Entry 14 [order] restricted/sealed until further notice. (Text entry; no document attached.)

SYSTEM ENTRY - Docket Entry 15 [order] restricted/sealed until further notice. (Text entry; no document attached.)

Surety Bond posted by Apple Corps Limited, Subafilms Limited Approved by Judge Raag Singhal

Plaintiff's MOTION To Unseal by Apple Corps Limited, Subafilms Limited.

Text of Proposed Order

Clerk's Notice to Filer re 17 Miscellaneous Relief. Wrong Motion Relief(s) Selected; ERROR - The Filer selected the wrong motion relief(s) when docketing the motion. The correction was made by the Clerk. It is not necessary to refile this document but future motions filed must include applicable reliefs.

AMENDED COMPLAINT against All Defendants, filed by Apple Corps Limited, Subafilms Limited.

Exhibit 1 to Amended Complaint Certificates of Registration for the Beatles Tra

Exhibit 2 to Amended Complaint Certificate of Registration for the Yellow Subma

NOTICE of Filing Proposed Summons(es) by Apple Corps Limited, Subafilms Limited

Proposed Summonses

Summons Issued as to 2020trendingtees.com, altracases.com, alvashirt.com, beddingwix.com, bestteestore.net, bezttee.com, casecov.com, casefamouse.com, caselone.com, caseshunter.com, chickteelye.com, donutpaw.com, dreamstees.com, enjoyraces.com, flowermoonz.com, gochildhood.com, gooluv.com, grinsha.com, hulktee.com, iphonefyy.com, kitchendecor.shop, koppsic.top, kteestore.com, lilycustom.com, matecolor.store, maydistore.com, nhalahome.com, nowbestshirt.com, nvoart.com, rainateeshirt.com, shinoprint.co, teepigz.com, teepital.com, teeskafi.com, winterprinting.com, zibbot.com.

NOTICE by Apple Corps Limited, Subafilms Limited re [1] Complaint, [19] Amended Complaint/Amended Notice of Removal, [17] Motion to Unseal Document upon Defendants via Electronic Mail

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Apple Corps Limited, Subafilms Limited re [2] Clerk's Notice of Judge Assignment, [16] Bond, [20] Notice of Filing Proposed Summons(es), [1] Complaint, [19] Amended Complaint/Amended Notice of Removal, [7] Notice of Court Practice/to Appear/Other, [5] Plaintiff's MOTION to Seal per Local Rule 5.4, [13] Certificate of Other Affiliates/Corporate Disclosure Statement, [17] Motion to Unseal Document, [3] Form AO 120/121, [8] Order, [9] Order on Motion to Seal, [4] Certificate of Other Affiliates/Corporate Disclosure Statement upon Defendants via website posting

PAPERLESS ORDER granting 17 Motion to Unseal Document. Signed by Judge Raag Singhal on 9/26/2022.

Clerk's NOTICE of Compliance re 24 Order on Motion to Unseal Document. All documents unsealed.

NOTICE of Striking [23] Certificate of Service, filed by Subafilms Limited, Apple Corps Limited by Apple Corps Limited, Subafilms Limited

CERTIFICATE OF SERVICE by Apple Corps Limited, Subafilms Limited re [2] Clerk's Notice of Judge Assignment, [16] Bond, [1] Complaint, [7] Notice of Court Practice/to Appear/Other, [15] Order on Ex Parte Motion, [5] Plaintiff's MOTION to Seal per Local Rule 5.4, [13] Certificate of Other Affiliates/Corporate Disclosure Statement, [17] Motion to Unseal Document, [11] 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, [3] Form AO 120/121, [8] Order, [9] Order on Motion to Seal, [14] Order on Ex Parte Motion, [12] Sealed Document, [4] Certificate of Other Affiliates/Corporate Disclosure Statement, [10] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order, Preliminary Injunction and Order Restraining Transfer of Assets and Memorandum of Law in Support Thereof upon Defendants via website posting

PAPERLESS Minute Entry for proceedings held before Judge Raag Singhal: Motion Hearing held on 9/27/2022 re 10 Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order, Preliminary Injunction and Order Restraining Transfer of Assets and Memorandum of Law in Support Thereof filed by Subafilms Limited, Apple Corps Limited. Total time in court: 15 minutes. Attorney Appearance(s): T. Raquel Wiborg-Rodriguez, Court Reporter: Karl Shires, 954-769-5496 / Karl_Shires@flsd.uscourts.gov.

ORDER GRANTING APPLICATION FOR ENTRY OF PRELIMINARY INJUNCTION Signed by Judge Raag Singhal on 9/28/2022. See attached document for full details.

ORDER ON DEFAULT PROCEDURE, (Motions due by 11/3/2022.) Signed by Judge Raag Singhal on 10/27/2022. See attached document for full details.

SUMMONS (Affidavit) Returned Executed on [1] Complaint, [19] Amended Complaint/Amended Notice of Removal, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Subafilms Limited, Apple Corps Limited. 2020trendingtees.com served on 9/26/2022, response/answer due 10/17/2022; altracases.com served on 9/26/2022, response/answer due 10/17/2022; alvashirt.com served on 9/26/2022, response/answer due 10/17/2022; beddingwix.com served on 9/26/2022, response/answer due 10/17/2022; bestteestore.net served on 9/26/2022, response/answer due 10/17/2022; bezttee.com served on 9/26/2022, response/answer due 10/17/2022; casecov.com served on 9/26/2022, response/answer due 10/17/2022; casefamouse.com served on 9/26/2022, response/answer due 10/17/2022; caselone.com served on 9/26/2022, response/answer due 10/17/2022; caseshunter.com served on 9/26/2022, response/answer due 10/17/2022; chickteelye.com served on 9/26/2022, response/answer due 10/17/2022; donutpaw.com served on 9/26/2022, response/answer due 10/17/2022; dreamstees.com served on 9/26/2022, response/answer due 10/17/2022; enjoyraces.com served on 9/26/2022, response/answer due 10/17/2022; flowermoonz.com served on 9/26/2022, response/answer due 10/17/2022; gochildhood.com served on 9/26/2022, response/answer due 10/17/2022; gooluv.com served on 9/26/2022, response/answer due 10/17/2022; grinsha.com served on 9/26/2022, response/answer due 10/17/2022; hulktee.com served on 9/26/2022, response/answer due 10/17/2022; iphonefyy.com served on 9/26/2022, response/answer due 10/17/2022; kitchendecor.shop served on 9/26/2022, response/answer due 10/17/2022; koppsic.top served on 9/26/2022, response/answer due 10/17/2022; kteestore.com served on 9/26/2022, response/answer due 10/17/2022; lilycustom.com served on 9/26/2022, response/answer due 10/17/2022; matecolor.store served on 9/26/2022, response/answer due 10/17/2022; maydistore.com served on 9/26/2022, response/answer due 10/17/2022; nhalahome.com served on 9/26/2022, response/answer due 10/17/2022; nowbestshirt.com served on 9/26/2022, response/answer due 10/17/2022; nvoart.com served on 9/26/2022, response/answer due 10/17/2022; rainateeshirt.com served on 9/26/2022, response/answer due 10/17/2022; shinoprint.co served on 9/26/2022, response/answer due 10/17/2022; teepigz.com served on 9/26/2022, response/answer due 10/17/2022; teepital.com served on 9/26/2022, response/answer due 10/17/2022; teeskafi.com served on 9/26/2022, response/answer due 10/17/2022; winterprinting.com served on 9/26/2022, response/answer due 10/17/2022; zibbot.com served on 9/26/2022, response/answer due 10/17/2022.

Affidavit of Service

Affidavit of Service

NOTICE by Apple Corps Limited, Subafilms Limited re [29] Preliminary Injunction upon Defendants via Electronic Mail

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Apple Corps Limited, Subafilms Limited re [29] Preliminary Injunction upon Defendant via Registrar

CERTIFICATE OF SERVICE by Apple Corps Limited, Subafilms Limited re [29] Preliminary Injunction upon Defendants via website posting

Plaintiff's MOTION for Clerk's Entry of Default as to 2020trendingtees.com, The Individuals, Business Entities, and Unincorporated Associations, altracases.com, alvashirt.com, beddingwix.com, bestteestore.net, bezttee.com, casecov.com, casefamouse.com, caselone.com, caseshunter.com, chickteelye.com, donutpaw.com, dreamstees.com, enjoyraces.com, flowermoonz.com, gochildhood.com, gooluv.com, grinsha.com, hulktee.com, iphonefyy.com, kitchendecor.shop, koppsic.top, kteestore.com, lilycustom.com, matecolor.store, maydistore.com, nhalahome.com, nowbestshirt.com, nvoart.com, rainateeshirt.com, shinoprint.co, teepigz.com, teepital.com, teeskafi.com, winterprinting.com, zibbot.com by Subafilms Limited, Apple Corps Limited.

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

Text of Proposed Order

Clerk's Entry of Default as to The Individuals, Business Entities, and Unincorporated Associations Listed on Schedule "A" of DE# 35 Motion for Clerk's Entry of Default, Signed by DEPUTY CLERK on 11/4/2022.

ORDER ON DEFAULT FINAL JUDGMENT PROCEDURE Signed by Judge Raag Singhal on 11/7/2022. See attached document for full details.

Plaintiff's MOTION for Default Judgment Against Defendants and Memorandum of Law in Support Thereof by Apple Corps Limited, Subafilms Limited.

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)(Wiborg-Rodriguez, T.)

ORDER granting [38] Motion for Final Default Judgment. Signed by Judge Raag Singhal on 1/13/2023. See attached document for full details.

DEFAULT JUDGMENT AND PERMANENT INJUNCTION in favor of Apple Corps Limited, Subafilms Limited against The Individuals, Business Entities, and Unincorporated Associations Closing Case. Signed by Judge Raag Singhal on 1/13/2023. See attached document for full details.

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