2022-cv-61677

COMPLAINT for Damages and Injunctive Relief against All Defendants. Filing fees $ 402.00 receipt number AFLSDC-15933618, filed by Gianni Versace S.r.l., J. Choo Limited.

Civil Cover Sheet

Exhibit 1 to the Complaint

Exhibit 2 to the Complaint

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.

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

Complaint and Exhibits

Plaintiff's MOTION to Seal per Local Rule 5.4 by Gianni Versace S.r.l., J. Choo Limited.

Text of Proposed Order to File Under Seal

Plaintiff's Corporate Disclosure Statement by Gianni Versace S.r.l., J. Choo Limited identifying Corporate Parent Capri Holdings Limited for Gianni Versace S.r.l., J. Choo 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 9/9/2022.

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 9/9/2022.

PAPERLESS ORDER granting 4 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 9/9/2022.

Order (Text entry; no document attached.)

Plaintiff's Notice of Filing Bond. Seizure Bond BOND in the amount of $10,000.00 posted by Gianni Versace S.r.l., J. Choo Limited Approved by Judge Raag Singhal

Plaintiff's Certificate of Other Affiliates by Gianni Versace S.r.l., J. Choo Limited

Corrected Certificate of Other Affiliates by Gianni Versace S.r.l., J. Choo Limited

Order (Text entry; no document attached.)

Plaintiff's MOTION to Unseal by Gianni Versace S.r.l., J. Choo Limited.

Text of Proposed Order Granting Plaintiffs' Motion to Unseal

Plaintiff's AMENDED COMPLAINT for Damages and Injunctive Relief against All Defendants, filed by Gianni Versace S.r.l., J. Choo Limited.

Exhibit 1 to the Amended Complaint

Exhibit 2 to the Amended Complaint

NOTICE of Filing Proposed Summons(es) by Gianni Versace S.r.l., J. Choo Limited

Summon(s) Proposed Summons

Summons Issued as to 9alaxies.com and all other defendants identified in Schedule "A" hereto.

NOTICE of Striking [21] Notice of Filing Proposed Summons(es) filed by Gianni Versace S.r.l., J. Choo Limited by Gianni Versace S.r.l., J. Choo Limited

NOTICE of Filing Proposed Summons(es) by Gianni Versace S.r.l., J. Choo Limited

Summon(s) Corrected Proposed Summons

PAPERLESS ORDER granting 19 Motion to Unseal. Signed by Judge Raag Singhal on 9/26/2022.

PAPERLESS SCHEDULING ORDER: re 18 Order on Ex Parte Motion. The Telephonic Preliminary Injunction Hearing is rescheduled for 9/30/2022 at 1:30 PM in Fort Lauderdale Division before Judge Raag Singhal. (TIME CHANGE ONLY). Signed by Judge Raag Singhal on 9/26/2022.

Corrected Summons Issued as to 9alaxies.com. and all other defendants identified in Schedule "A" hereto.

NOTICE of Compliance by Unsealing documents 9, 10, 11, 12, 13, 17 & 18 pursuant to DE 25 Order.

NOTICE of Voluntary Dismissal Without Prejudice of Defendant Numbers 99, 106, and 111 by Gianni Versace S.r.l., J. Choo Limited

Text of Proposed Order of Dismissal

NOTICE by Gianni Versace S.r.l., J. Choo Limited of E-mail Inquiries Received from Certain Defendants in Connection with Asset Restraint and Service

Exhibit 1 to the Notice of E-mail Inquiries Received from Certain Defendants in

NOTICE by Gianni Versace S.r.l., J. Choo Limited re [20] Amended Complaint/Amended Notice of Removal, [12] Order on Ex Parte Motion, [8] Order on Motion to Seal, [1] Complaint, [6] Notice of Court Practice/to Appear/Other, [18] Order on Ex Parte Motion, upon Defendants via Electronic Mail

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Gianni Versace S.r.l., J. Choo Limited re [9] Sealed Document, [19] Plaintiff's MOTION to Unseal, [17] Plaintiff's EX PARTE MOTION to Extend Temporary Restraining Order, Associated Deadlines, and to Continue Hearing Scheduled for September 23, 2022 in Connection with Motion for Preliminary Injunction, [15] Bond, [13] Order on Ex Parte Motion, [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), [20] Amended Complaint/Amended Notice of Removal, [7] Order, [2] Clerk's Notice of Judge Assignment, [12] Order on Ex Parte Motion, [24] Notice of Filing Proposed Summons(es), [8] Order on Motion to Seal, [1] Complaint, [3] Form AO 120/121, [14] Certificate of Other Affiliates/Corporate Disclosure Statement, [6] Notice of Court Practice/to Appear/Other, [5] Certificate of Other Affiliates/Corporate Disclosure Statement, [18] Order on Ex Parte Motion, [4] Plaintiff's MOTION to Seal per Local Rule 5.4, [10] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order, Preliminary Injunction, and Order Restraining Transfer of Assets upon Defendants via website posting

NOTICE by Gianni Versace S.r.l., J. Choo Limited re [26] Scheduling Order, upon Defendants via Electronic Mail

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Gianni Versace S.r.l., J. Choo Limited re [26] Scheduling Order, upon Defendants via website posting

PAPERLESS Minute Entry for proceedings held before Judge Raag Singhal: Motion Hearing held on 9/30/2022 re 10 Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order, Preliminary Injunction, and Order Restraining Transfer of Assets filed by Gianni Versace S.r.l., J. Choo Limited. Total time in court: 15 minutes. Attorney Appearance(s): Christine Ann Daley, Court Reporter: Karl Shires, 954-769-5496 / Karl_Shires@flsd.uscourts.gov.

ORDER GRANTING DE [10] APPLICATION FOR ENTRY OF PRELIMINARY INJUNCTION- Signed by Judge Raag Singhal on 9/30/2022. See attached document for full details.

Plaintiff's MOTION to Approve Consent Judgment and Permanent Injunction as to Defendant Number 97 by Gianni Versace S.r.l., J. Choo Limited. Responses due by 10/20/2022

Exhibit 1: Proposed Consent Final Judgment and Permanent Injunction as to Defendant Number 97

(Exhibit 2: Statement of Consent)

ORDER ON DEFAULT PROCEDURE: Plaintiffs shall submit a motion for entry of Clerk's default no later than 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, [20] Amended Complaint/Amended Notice of Removal, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by J. Choo Limited, Gianni Versace S.r.l. 3 Peter rabbit Store served on 9/27/2022, response/answer due 10/18/2022; 9alaxies.com served on 9/27/2022, response/answer due 10/18/2022; AREQW WENLING Store served on 9/27/2022, response/answer due 10/18/2022; Charles shoes served on 9/27/2022, response/answer due 10/18/2022; DODOAI Store served on 9/27/2022, response/answer due 10/18/2022; Deposittl served on 9/27/2022, response/answer due 10/18/2022; FREEHAOO Fashion Store Store served on 9/27/2022, response/answer due 10/18/2022; FRM Trade served on 9/27/2022, response/answer due 10/18/2022; Faith-866 served on 9/27/2022, response/answer due 10/18/2022; Fiklyc Pajamas Store served on 9/27/2022, response/answer due 10/18/2022; Guuuuu served on 9/27/2022, response/answer due 10/18/2022; Hello2022World served on 9/27/2022, response/answer due 10/18/2022; High quality clothing 366 served on 9/27/2022, response/answer due 10/18/2022; JARYCORN JARYCORN Store served on 9/27/2022, response/answer due 10/18/2022; JARYCORN Store served on 9/27/2022, response/answer due 10/18/2022; Jan-Jan Store served on 9/27/2022, response/answer due 10/18/2022; Jeans3 served on 9/27/2022, response/answer due 10/18/2022; Jiawang103 served on 9/27/2022, response/answer due 10/18/2022; LINCICI Store served on 9/27/2022, response/answer due 10/18/2022; LVHUACUN Store served on 9/27/2022, response/answer due 10/18/2022; LingQing Store served on 9/27/2022, response/answer due 10/18/2022; Lkc88 served on 9/27/2022, response/answer due 10/18/2022; Mangota served on 9/27/2022, response/answer due 10/18/2022; Men Business Formal Store served on 9/27/2022, response/answer due 10/18/2022; Mens Boutique Clothes Store served on 9/27/2022, response/answer due 10/18/2022; Shop1100024026 Store served on 9/27/2022, response/answer due 10/18/2022; Shop1100049184 Store served on 9/27/2022, response/answer due 10/18/2022; Shop1100187053 Store served on 9/27/2022, response/answer due 10/18/2022; Shop5792224 Store served on 9/27/2022, response/answer due 10/18/2022; Shop910980027 Store served on 9/27/2022, response/answer due 10/18/2022; Star sports shoes store served on 9/27/2022, response/answer due 10/18/2022; TIANJ served on 9/27/2022, response/answer due 10/18/2022; TTXI Mens Trend Clothes Store served on 9/27/2022, response/answer due 10/18/2022; UFOA Store served on 9/27/2022, response/answer due 10/18/2022; VAZN Factory 2 Store served on 9/27/2022, response/answer due 10/18/2022; WANANSN welcome Store served on 9/27/2022, response/answer due 10/18/2022; WENWENLINLIN Store served on 9/27/2022, response/answer due 10/18/2022; Youpin Bag Store served on 9/27/2022, response/answer due 10/18/2022; ZONWAY Store served on 9/27/2022, response/answer due 10/18/2022; aa201319 served on 9/27/2022, response/answer due 10/18/2022; arttishoe.com served on 9/27/2022, response/answer due 10/18/2022; beltsactive.com served on 9/27/2022, response/answer due 10/18/2022; brilliashop.com served on 9/27/2022, response/answer due 10/18/2022; business cloth Store served on 9/27/2022, response/answer due 10/18/2022; californialuxury60.com served on 9/27/2022, response/answer due 10/18/2022; carters1 served on 9/27/2022, response/answer due 10/18/2022; casemall.jp served on 9/27/2022, response/answer due 10/18/2022; ccfg 199201 Store served on 9/27/2022, response/answer due 10/18/2022; clubhao.com served on 9/27/2022, response/answer due 10/18/2022; coolclothingz.co served on 9/27/2022, response/answer due 10/18/2022; darhgens6 served on 9/27/2022, response/answer due 10/18/2022; dellsion.com served on 9/27/2022, response/answer due 10/18/2022; dviock.com served on 9/27/2022, response/answer due 10/18/2022; fashionbeast.ru served on 9/27/2022, response/answer due 10/18/2022; fashionlad.co served on 9/27/2022, response/answer due 10/18/2022; fashline.co served on 9/27/2022, response/answer due 10/18/2022; finessethings.com served on 9/27/2022, response/answer due 10/18/2022; frieow.shop served on 9/27/2022, response/answer due 10/18/2022; gloriaeulalia.com served on 9/27/2022, response/answer due 10/18/2022; hoogday.com served on 9/27/2022, response/answer due 10/18/2022; hotjewelry11 served on 9/27/2022, response/answer due 10/18/2022; jewelry1588 served on 9/27/2022, response/answer due 10/18/2022; jingfadianshang158 served on 9/27/2022, response/answer due 10/18/2022; jinyuanjersey served on 9/27/2022, response/answer due 10/18/2022; lanipsipjxq served on 9/27/2022, response/answer due 10/18/2022; lcghome.com served on 9/27/2022, response/answer due 10/18/2022; lengcomg168 Store served on 9/27/2022, response/answer due 10/18/2022; letheaufdxf served on 9/27/2022, response/answer due 10/18/2022; lg1314 served on 9/27/2022, response/answer due 10/18/2022; llp004 served on 9/27/2022, response/answer due 10/18/2022; loawoaezmckff served on 9/27/2022, response/answer due 10/18/2022; luxrubyhowell.com served on 9/27/2022, response/answer due 10/18/2022; luxshirt.co served on 9/27/2022, response/answer due 10/18/2022; lvcase.com served on 9/27/2022, response/answer due 10/18/2022; lvpeng2593 served on 9/27/2022, response/answer due 10/18/2022; ly811 served on 9/27/2022, response/answer due 10/18/2022; mcsammemgtr served on 9/27/2022, response/answer due 10/18/2022; mikepromi.com served on 9/27/2022, response/answer due 10/18/2022; miumiu678 served on 9/27/2022, response/answer due 10/18/2022; monvanti.com served on 9/27/2022, response/answer due 10/18/2022; muciity.com served on 9/27/2022, response/answer due 10/18/2022; original66 served on 9/27/2022, response/answer due 10/18/2022; original88 served on 9/27/2022, response/answer due 10/18/2022; penereqauut served on 9/27/2022, response/answer due 10/18/2022; qiang98 served on 9/27/2022, response/answer due 10/18/2022; qqbj123 served on 9/27/2022, response/answer due 10/18/2022; ravici.com served on 9/27/2022, response/answer due 10/18/2022; repgod.org served on 9/27/2022, response/answer due 10/18/2022; senaykyfhhtp served on 9/27/2022, response/answer due 10/18/2022; sheytayogl served on 9/27/2022, response/answer due 10/18/2022; shiyuan68 served on 9/27/2022, response/answer due 10/18/2022; shoeseve.com served on 9/27/2022, response/answer due 10/18/2022; shoplongbeachclothing.com served on 9/27/2022, response/answer due 10/18/2022; shouzhi served on 9/27/2022, response/answer due 10/18/2022; sletatqyrts served on 9/27/2022, response/answer due 10/18/2022; summeroutfit.co served on 9/27/2022, response/answer due 10/18/2022; superjackets served on 9/27/2022, response/answer due 10/18/2022; susieruby.com served on 9/27/2022, response/answer due 10/18/2022; tchic.gift served on 9/27/2022, response/answer due 10/18/2022; veshey.shop served on 9/27/2022, response/answer due 10/18/2022; vverssasce served on 9/27/2022, response/answer due 10/18/2022; weighezjjwq served on 9/27/2022, response/answer due 10/18/2022; wereplica.ru served on 9/27/2022, response/answer due 10/18/2022; whitic.shop served on 9/27/2022, response/answer due 10/18/2022; wholesale.pshare001.com served on 9/27/2022, response/answer due 10/18/2022; womensjewelry served on 9/27/2022, response/answer due 10/18/2022; wpokfd served on 9/27/2022, response/answer due 10/18/2022; xiaobingbing08 served on 9/27/2022, response/answer due 10/18/2022; yuyaojing888 served on 9/27/2022, response/answer due 10/18/2022; zhengfeier888 served on 9/27/2022, response/answer due 10/18/2022; zhenzhen773 served on 9/27/2022, response/answer due 10/18/2022.

Affidavit of Service

Affidavit of Service

NOTICE by Gianni Versace S.r.l., J. Choo Limited re [36] Preliminary Injunction upon Defendants via Electronic Mail

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Gianni Versace S.r.l., J. Choo Limited re [36] Preliminary Injunction upon Defendants via website posting

Plaintiff's MOTION for Clerk's Entry of Default as to 3 Peter rabbit Store, 9alaxies.com, AREQW WENLING Store, Charles shoes, DODOAI Store, Deposittl, FREEHAOO Fashion Store Store, Faith-866, Fiklyc Pajamas Store, Guuuuu, Hello2022World, High quality clothing 366, JARYCORN JARYCORN Store, JARYCORN Store, Jan-Jan Store, Jeans3, Jiawang103, LINCICI Store, LVHUACUN Store, LingQing Store, Lkc88, Mangota, Men Business Formal Store, Mens Boutique Clothes Store, Shop1100024026 Store, Shop1100049184 Store, Shop1100187053 Store, Shop5792224 Store, Shop910980027 Store, Star sports shoes store, TIANJ, TTXI Mens Trend Clothes Store, The Individuals, Business Entities, and Unincorporated Associations Identified on Schedule "A", UFOA Store, VAZN Factory 2 Store, WANANSN welcome Store, WENWENLINLIN Store, Youpin Bag Store, ZONWAY Store, aa201319, arttishoe.com, beltsactive.com, brilliashop.com, business cloth Store, californialuxury60.com, carters1, casemall.jp, ccfg 199201 Store, clubhao.com, coolclothingz.co, darhgens6, dellsion.com, dviock.com, fashionbeast.ru, fashionlad.co, fashline.co, finessethings.com, frieow.shop, gloriaeulalia.com, hoogday.com, hotjewelry11, jewelry1588, jingfadianshang158, jinyuanjersey, lanipsipjxq, lcghome.com, lengcomg168 Store, letheaufdxf, lg1314, llp004, loawoaezmckff, luxrubyhowell.com, luxshirt.co, lvcase.com, lvpeng2593, ly811, mcsammemgtr, mikepromi.com, miumiu678, monvanti.com, muciity.com, original66, original88, penereqauut, qiang98, qqbj123, ravici.com, repgod.org, senaykyfhhtp, sheytayogl, shiyuan68, shoeseve.com, shoplongbeachclothing.com, shouzhi, sletatqyrts, summeroutfit.co, superjackets, susieruby.com, tchic.gift, veshey.shop, vverssasce, weighezjjwq, wereplica.ru, whitic.shop, wholesale.pshare001.com, womensjewelry, wpokfd, xiaobingbing08, yuyaojing888, zhengfeier888, zhenzhen773 by J. Choo Limited, Gianni Versace S.r.l.

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

Text of Proposed Order

Clerk's Entry of Default as to Defendants listed in Schedule A re 42. Signed by DEPUTY CLERK on 11/4/2022.

ORDER ON DEFAULT FINAL JUDGMENT PROCEDURE: Plaintiff shall file a motion for default final judgment OR notice of joint liability by 11/18/2022. Signed by Judge Raag Singhal on 11/7/2022. See attached document for full details.

CONSENT FINAL JUDGMENT AND PERMANENT INJUNCTION AS TO DEFENDANT NUMBER 97: 37 Plaintiff's MOTION to Approve Consent Judgment and Permanent Injunction as to Defendant Number 97, FRM Trade, is GRANTED. Signed by Judge Raag Singhal on 11/7/2022. See attached document for full details.

Plaintiff's MOTION for Default Judgment Against Defendants by Gianni Versace S.r.l., J. Choo Limited.

Declaration of Christine Ann Daley in Support of Plaintiffs' Motion for Entry of Final Default Judgment

Text of Proposed Order Granting Motion for Final Default Judgment

(Text of Proposed Order Proposed Default Final Judgment and Permanent Injunction)

ORDER GRANTING MOTION FOR FINAL DEFAULT JUDGMENT granting [46] Motion for Default Judgment. Signed by Judge Raag Singhal on 1/13/2023. See attached document for full details.

DEFAULT FINAL JUDGMENT AND PERMANENT INJUNCTION in favor of Gianni Versace S.r.l., J. Choo Limited against The Individuals, Business Entities, and Unincorporated Associations Identified on Schedule "A", 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