2022-cv-61967

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. Filing fees $ 402.00 receipt number AFLSDC-16046562, filed by David Yurman Enterprises LLC, David Yurman IP LLC.

Civil Cover Sheet

Exhibit 1 to Complaint Certificates of Registration for the David Yurman Tradem

Clerks Notice of Judge Assignment to Judge William P. Dimitrouleas. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Panayotta Augustin-Birch 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

Corporate Disclosure Statement by David Yurman Enterprises LLC, David Yurman IP LLC (Wiborg-Rodriguez, T.)

Plaintiff's MOTION to Seal per Local Rule 5.4 by David Yurman Enterprises LLC, David Yurman IP LLC.

Text of Proposed Order

ORDER granting [5] Motion to Seal. Signed by Judge William P. Dimitrouleas on 10/24/2022. See attached document for full details.

ORDER REQUIRING COUNSEL TO MEET, FILE JOINT SCHEDULING REPORT AND JOINT DISCOVERY REPORT: Signed by Judge William P. Dimitrouleas on 10/25/2022. See attached document for full details.

Set/Reset Deadlines/Hearings per DE [11] Order. Preliminary Injunction Hearing set for 11/16/2022 01:10 PM in Fort Lauderdale Division before Judge William P. Dimitrouleas. (Text entry; no document attached.)

Order (Text entry; no document attached.)

Set/Reset Deadlines/Hearings per DE [11] Order. Preliminary Injunction Hearing set for 11/16/2022 01:10 PM in Fort Lauderdale Division before Judge William P. Dimitrouleas. (Text entry; no document attached.)

Order (Text entry; no document attached.)

Plaintiffs' Notice of Filing Bond. Seizure Bond BOND in the amount of $100,000.00 posted by David Yurman Enterprises LLC, David Yurman IP LLC Approved by Judge William P. Dimitrouleas

SYSTEM ENTRY - Docket Entry 13 [misc] restricted/sealed until further notice. (1336528) (Text entry; no document attached.)

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

Plaintiff's MOTION To Unseal by David Yurman Enterprises LLC, David Yurman IP LLC.

Text of Proposed Order

AMENDED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants, filed by David Yurman Enterprises LLC, David Yurman IP LLC.

Exhibit 1 to Amended Complaint Certificates of Registration for the David Yurm

ORDER granting [16] Motion to Unseal. Signed by Judge William P. Dimitrouleas on 11/10/2022. See attached document for full details.

NOTICE of Compliance re 23 Order on Motion for Miscellaneous Relief (Documents Unsealed)

NOTICE by David Yurman Enterprises LLC, David Yurman IP LLC re [16] Plaintiff's MOTION To Unseal, [1] Complaint, [7] Order Requiring Joint Scheduling Report, [6] Order on Motion to Seal upon Defendants via Electronic Mail

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by David Yurman Enterprises LLC, David Yurman IP LLC re [1] Complaint, [7] Order Requiring Joint Scheduling Report upon Defendant via Registrar

CERTIFICATE OF SERVICE by David Yurman Enterprises LLC, David Yurman IP LLC re [4] Certificate of Other Affiliates/Corporate Disclosure Statement, [3] Form AO 120/121, [16] Plaintiff's MOTION To Unseal, [15] Bond, [5] Plaintiff's MOTION to Seal per Local Rule 5.4, [1] Complaint, [7] Order Requiring Joint Scheduling Report, [6] Order on Motion to Seal, [2] Clerk's Notice of Judge Assignment, upon Defendants via website posting

NOTICE by David Yurman Enterprises LLC, David Yurman IP LLC of Identification of Additional PayPal Accounts for Defendant Numbers 111 and 114

Declaration of Kathleen Burns in Support Thereof

Exhibit 1 to the Declaration of Kathleen Burns

NOTICE by David Yurman Enterprises LLC, David Yurman IP LLC of E-mail Inquiries Received from Certain Defendants in Connection with Asset Restraint and Service

Exhibit 1 to the Notice of E-mail Inquiries

PAPERLESS Minute Entry for proceedings held before Judge William P. Dimitrouleas: Motion Hearing held on 11/16/2022 re 8 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 David Yurman IP LLC, David Yurman Enterprises LLC. Defendants failed to appear. The Court will grant Plaintiff's motion for preliminary injunction. Total time in court: 5 minutes. Attorney Appearance(s): T. Raquel Wiborg-Rodriguez, Court Reporter: Francine Salopek, 305-301-3276 / mjsfcs@aol.com. (rs00)

ORDER GRANTING APPLICATION FOR ENTRY OF PRELIMINARY INJUNCTION: Plaintiffs' Application for Preliminary Injunction DE 8 is GRANTED. Signed by Judge William P. Dimitrouleas on 11/16/2022. See attached document for full details.

ORDER TO SHOW CAUSE FOR LACK OF PROSECUTION: Show Cause Response due by 12/16/2022. Signed by Judge William P. Dimitrouleas on 12/9/2022. See attached document for full details.

Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to [1] Complaint, by COOLSTEELANDBEYOND. Attorney Darren Adam Heitner added to party COOLSTEELANDBEYOND(pty:dft).

Text of Proposed Order Proposed Order

ORDER GRANTING UNOPPOSED MOTION FOR EXTENSION OF TIME:GRANTING 28 Motion for Extension of Time to File Response to a Complaint or Other Case Initiating Document COOLSTEELANDBEYOND. Response due 1/6/2023. Signed by Judge William P. Dimitrouleas on 12/14/2022. See attached document for full details.

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 David Yurman IP LLC, David Yurman Enterprises LLC. AsWell served on 11/10/2022, response/answer due 12/1/2022; Boys Jewellery served on 11/10/2022, response/answer due 12/1/2022; Brillian Store served on 11/10/2022, response/answer due 12/1/2022; COOLSTEELANDBEYOND served on 11/10/2022, response/answer due 1/6/2023; Idas Shop served on 11/10/2022, response/answer due 12/1/2022; Msiena Smnuer Official Store served on 11/10/2022, response/answer due 12/1/2022; Shop911052112 Store served on 11/10/2022, response/answer due 12/1/2022; Sunny Jewelry Store served on 11/10/2022, response/answer due 12/1/2022; Taklu served on 11/10/2022, response/answer due 12/1/2022; Winhime served on 11/10/2022, response/answer due 12/1/2022; Zalman Jewelry Official Store served on 11/10/2022, response/answer due 12/1/2022; Zdjynyq served on 11/10/2022, response/answer due 12/1/2022; Zocivan Official Store served on 11/10/2022, response/answer due 12/1/2022; aiyue2020 served on 11/10/2022, response/answer due 12/1/2022; babygod666 served on 11/10/2022, response/answer due 12/1/2022; beautgirl served on 11/10/2022, response/answer due 12/1/2022; beauty_li served on 11/10/2022, response/answer due 12/1/2022; beautysaloon served on 11/10/2022, response/answer due 12/1/2022; benana served on 11/10/2022, response/answer due 12/1/2022; boyun2021 served on 11/10/2022, response/answer due 12/1/2022; buyancangate served on 11/10/2022, response/answer due 12/1/2022; cgstea.com served on 11/10/2022, response/answer due 12/1/2022; chromeheartsstore served on 11/10/2022, response/answer due 12/1/2022; cycinternational served on 11/10/2022, response/answer due 12/1/2022; czjyczjya served on 11/10/2022, response/answer due 12/1/2022; d8jd served on 11/10/2022, response/answer due 12/1/2022; dbft served on 11/10/2022, response/answer due 12/1/2022; dhfumubuyit served on 11/10/2022, response/answer due 12/1/2022; diorstores88 served on 11/10/2022, response/answer due 12/1/2022; directlyoperatedstor served on 11/10/2022, response/answer due 12/1/2022; djyg served on 11/10/2022, response/answer due 12/1/2022; dwyp served on 11/10/2022, response/answer due 12/1/2022; earringdesigner served on 11/10/2022, response/answer due 12/1/2022; economic8 served on 11/10/2022, response/answer due 12/1/2022; fashion198507 served on 11/10/2022, response/answer due 12/1/2022; fgyo served on 11/10/2022, response/answer due 12/1/2022; fitr served on 11/10/2022, response/answer due 12/1/2022; fuu2 served on 11/10/2022, response/answer due 12/1/2022; fzctb1 served on 11/10/2022, response/answer due 12/1/2022; fzctc3 served on 11/10/2022, response/answer due 12/1/2022; fzctd2 served on 11/10/2022, response/answer due 12/1/2022; fzcti6 served on 11/10/2022, response/answer due 12/1/2022; fzctl2 served on 11/10/2022, response/answer due 12/1/2022; fzcto6 served on 11/10/2022, response/answer due 12/1/2022; geland served on 11/10/2022, response/answer due 12/1/2022; gesv served on 11/10/2022, response/answer due 12/1/2022; godengaimen served on 11/10/2022, response/answer due 12/1/2022; godisomnipotent served on 11/10/2022, response/answer due 12/1/2022; h9en served on 11/10/2022, response/answer due 12/1/2022; haiyigood served on 11/10/2022, response/answer due 12/1/2022; haomingrui served on 11/10/2022, response/answer due 12/1/2022; hdoe served on 11/10/2022, response/answer due 12/1/2022; heheda1 served on 11/10/2022, response/answer due 12/1/2022; helay2021 served on 11/10/2022, response/answer due 12/1/2022; hh3e served on 11/10/2022, response/answer due 12/1/2022; hkmo served on 11/10/2022, response/answer due 12/1/2022; hmmo served on 11/10/2022, response/answer due 12/1/2022; hookah14 served on 11/10/2022, response/answer due 12/1/2022; hzma served on 11/10/2022, response/answer due 12/1/2022; jauh served on 11/10/2022, response/answer due 12/1/2022; jesses4315 served on 11/10/2022, response/answer due 12/1/2022; jessup served on 11/10/2022, response/answer due 12/1/2022; jizc served on 11/10/2022, response/answer due 12/1/2022; jjhp served on 11/10/2022, response/answer due 12/1/2022; jtkb served on 11/10/2022, response/answer due 12/1/2022; judydoll served on 11/10/2022, response/answer due 12/1/2022; knab served on 11/10/2022, response/answer due 12/1/2022; kour served on 11/10/2022, response/answer due 12/1/2022; likegrace served on 11/10/2022, response/answer due 12/1/2022; mavns503zn served on 11/10/2022, response/answer due 12/1/2022; melvinassa served on 11/10/2022, response/answer due 12/1/2022; misihan04 served on 11/10/2022, response/answer due 12/1/2022; mlmt served on 11/10/2022, response/answer due 12/1/2022; ninn served on 11/10/2022, response/answer due 12/1/2022; nrd5 served on 11/10/2022, response/answer due 12/1/2022; nyfly served on 11/10/2022, response/answer due 12/1/2022; o7zw served on 11/10/2022, response/answer due 12/1/2022; ocf8 served on 11/10/2022, response/answer due 12/1/2022; ogcct97tt served on 11/10/2022, response/answer due 12/1/2022; outstandingquality04 served on 11/10/2022, response/answer due 12/1/2022; pg24 served on 11/10/2022, response/answer due 12/1/2022; pickled_peppers served on 11/10/2022, response/answer due 12/1/2022; pone9 served on 11/10/2022, response/answer due 12/1/2022; putiannikeon1 served on 11/10/2022, response/answer due 12/1/2022; pwhk served on 11/10/2022, response/answer due 12/1/2022; q3ls served on 11/10/2022, response/answer due 12/1/2022; qqly served on 11/10/2022, response/answer due 12/1/2022; ravishing served on 11/10/2022, response/answer due 12/1/2022; raymondate served on 11/10/2022, response/answer due 12/1/2022; rerh served on 11/10/2022, response/answer due 12/1/2022; shen84 served on 11/10/2022, response/answer due 12/1/2022; shenzhen2058 served on 11/10/2022, response/answer due 12/1/2022; shigi.us served on 11/10/2022, response/answer due 12/1/2022; sihuai05 served on 11/10/2022, response/answer due 12/1/2022; snapyeteiva.com served on 11/10/2022, response/answer due 12/1/2022; sodatx served on 11/10/2022, response/answer due 12/1/2022; sts_the_child served on 11/10/2022, response/answer due 12/1/2022; syctradinginc served on 11/10/2022, response/answer due 12/1/2022; thedavidyurman.us served on 11/10/2022, response/answer due 12/1/2022; thefalconwears.com served on 11/10/2022, response/answer due 12/1/2022; themaxshops.com served on 11/10/2022, response/answer due 12/1/2022; tongda2018 served on 11/10/2022, response/answer due 12/1/2022; tphk served on 11/10/2022, response/answer due 12/1/2022; vander served on 11/10/2022, response/answer due 12/1/2022; vd1o served on 11/10/2022, response/answer due 12/1/2022; viulue served on 11/10/2022, response/answer due 12/1/2022; vn9a served on 11/10/2022, response/answer due 12/1/2022; voay served on 11/10/2022, response/answer due 12/1/2022; watermen01 served on 11/10/2022, response/answer due 12/1/2022; wizb served on 11/10/2022, response/answer due 12/1/2022; wmpr served on 11/10/2022, response/answer due 12/1/2022; yihai2021 served on 11/10/2022, response/answer due 12/1/2022; yizhan02 served on 11/10/2022, response/answer due 12/1/2022; youyiq3 served on 11/10/2022, response/answer due 12/1/2022; yuanjiu168 served on 11/10/2022, response/answer due 12/1/2022.

Affidavit of Service

Affidavit of Service

(Affidavit of Service)

NOTICE by David Yurman Enterprises LLC, David Yurman IP LLC re 26 Preliminary Injunction, upon Defendants via Electronic Mail

(Exhibit Certificate of Sevice)

CERTIFICATE OF SERVICE by David Yurman IP LLC re 26 Preliminary Injunction, upon Defendant via Registrar

CERTIFICATE OF SERVICE by David Yurman Enterprises LLC, David Yurman IP LLC re 26 Preliminary Injunction, upon Defendants via website posting

Plaintiff's MOTION for Clerk's Entry of Default as to AsWell, Boys Jewellery, Brillian Store, Idas Shop, Msiena Smnuer Official Store, Shop911052112 Store, Sunny Jewelry Store, Taklu, The Individuals, Business Entities, and Unincorporated Associations, Winhime, Zalman Jewelry Official Store, Zdjynyq, Zocivan Official Store, aiyue2020, babygod666, beautgirl, beauty_li, beautysaloon, benana, boyun2021, buyancangate, cgstea.com, chromeheartsstore, cycinternational, czjyczjya, d8jd, dbft, dhfumubuyit, diorstores88, directlyoperatedstor, djyg, dwyp, earringdesigner, economic8, fashion198507, fgyo, fitr, fuu2, fzctb1, fzctc3, fzctd2, fzcti6, fzctl2, fzcto6, geland, gesv, godengaimen, godisomnipotent, h9en, haiyigood, haomingrui, hdoe, heheda1, helay2021, hh3e, hkmo, hmmo, hookah14, hzma, jauh, jesses4315, jessup, jizc, jjhp, jtkb, judydoll, knab, kour, likegrace, mavns503zn, melvinassa, misihan04, mlmt, ninn, nrd5, nyfly, o7zw, ocf8, ogcct97tt, outstandingquality04, pg24, pickled_peppers, pone9, putiannikeon1, pwhk, q3ls, qqly, ravishing, raymondate, rerh, shen84, shenzhen2058, shigi.us, sihuai05, snapyeteiva.com, sodatx, sts_the_child, syctradinginc, thedavidyurman.us, thefalconwears.com, themaxshops.com, tongda2018, tphk, vander, vd1o, viulue, vn9a, voay, watermen01, wizb, wmpr, yihai2021, yizhan02, youyiq3, yuanjiu168 by David Yurman IP LLC, David Yurman Enterprises LLC.

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

(Text of Proposed Order)

Clerk's Entry of Default as to Brillian Store and the Defendants herein, the Individuals, Business Entities, and Unincorporated Associations identified on Schedule A hereto, (collectively Defendants), - Motions Terminated: 34 Motion for Clerk's Entry of Default, Signed by DEPUTY CLERK on 12/19/2022.

CLERK'S NOTICE re 35 Clerk's Entry of Default

ORDER TO SHOW CAUSE: Show Cause Response due by 1/6/2023. Signed by Judge William P. Dimitrouleas on 12/30/2022. See attached document for full details.

MOTION for Extension of Time to File Response/Reply/Answer as to 1 Complaint, by COOLSTEELANDBEYOND.

(Text of Proposed Order Proposed Order)

Plaintiff's MOTION for Default Judgment Against Defendants and Memorandum of Law in Support Thereof by David Yurman Enterprises LLC, David Yurman IP LLC.

Declaration of Stephen M. Gaffigan in Support Thereof

Text of Proposed Order Granting Motion for Final Default Judgment

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

NOTICE of Compliance by David Yurman Enterprises LLC, David Yurman IP LLC re 37 Order to Show Cause

ORDER GRANTING UNOPPOSED MOTION FOR EXTENSION OF TIME, granting 38 Motion for Extension of Time to File Response/Answer to a Complaint or Other Case Initiating Document COOLSTEELANDBEYOND. Answer due 1/27/2023. Signed by Judge William P. Dimitrouleas on 1/6/2023. 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 1/20/2023. Signed by Judge William P. Dimitrouleas on 1/6/2023. See attached document for full details.

CERTIFICATE OF SERVICE by David Yurman Enterprises LLC, David Yurman IP LLC re [42] Order to Show Cause upon Defendants via Electronic Mail and via Website Posting

NOTICE of Compliance by David Yurman Enterprises LLC, David Yurman IP LLC re 42 Order to Show Cause (Wiborg-Rodriguez, T.)

ORDER granting 39 Motion for Final Default Judgment. Signed by Judge William P. Dimitrouleas on 1/23/2023. See attached document for full details.

FINAL DEFAULT JUDGMENT in favor of David Yurman Enterprises LLC, David Yurman IP LLC against AsWell, Boys Jewellery, Brillian Store, Idas Shop, Msiena Smnuer Official Store, Shop911052112 Store, Sunny Jewelry Store, Taklu, The Individuals, Business Entities, and Unincorporated Associations, Winhime, Zalman Jewelry Official Store, Zdjynyq, Zocivan Official Store, aiyue2020, babygod666, beautgirl, beauty_li, beautysaloon, benana, boyun2021, buyancangate, cgstea.com, chromeheartsstore, cycinternational, czjyczjya, d8jd, dbft, dhfumubuyit, diorstores88, directlyoperatedstor, djyg, dwyp, earringdesigner, economic8, fashion198507, fgyo, fitr, fuu2, fzctb1, fzctc3, fzctd2, fzcti6, fzctl2, fzcto6, geland, gesv, godengaimen, godisomnipotent, h9en, haiyigood, haomingrui, hdoe, heheda1, helay2021, hh3e, hkmo, hmmo, hookah14, hzma, jauh, jesses4315, jessup, jizc, jjhp, jtkb, judydoll, knab, kour, likegrace, mavns503zn, melvinassa, misihan04, mlmt, ninn, nrd5, nyfly, o7zw, ocf8, ogcct97tt, outstandingquality04, pg24, pickled_peppers, pone9, putiannikeon1, pwhk, q3ls, qqly, ravishing, raymondate, rerh, shen84, shenzhen2058, shigi.us, sihuai05, snapyeteiva.com, sodatx, sts_the_child, syctradinginc, thefalconwears.com, themaxshops.com, tongda2018, tphk, vander, vd1o, viulue, vn9a, voay, watermen01, wizb, wmpr, yihai2021, yizhan02, youyiq3, yuanjiu168; in favor of David Yurman Enterprises LLC, David Yurman IP LLC against thedavidyurman.us and PERMANENT INJUNCTION. This case remains open as to Defendant Numbers 10 and 11 ONLY, until further Order of the Court. Signed by Judge William P. Dimitrouleas on 1/23/2023. See attached document for full details.

ANSWER and Affirmative Defenses to Amended Complaint by COOLSTEELANDBEYOND.

NOTICE of Change of Address, Email or Law Firm Name by Virgilio Gigante

NOTICE of Change of Address, Email or Law Firm Name by Stephen Michael Gaffigan

CLERK'S NOTICE - Attorney Admissions has updated the email information for attorney Virgilio Gigante.

CLERK'S NOTICE - Attorney Admissions has updated the email information for attorney Stephen Michael Gaffigan.

ORDER REQUIRING STATUS REPORT FROM PLAINTIFFS. Status Report due by 2/28/2023. Signed by Judge William P. Dimitrouleas on 2/21/2023. See attached document for full details.

Joint MOTION to Approve Consent Judgment (Responses due by 3/13/2023), MOTION for Permanent Injunction as to Defendant Number 10 by David Yurman Enterprises LLC, David Yurman IP LLC.

Exhibit 1 - Consent Final Judgment and Permanent Injunction as to Defendant Numb

NOTICE of Voluntary Dismissal With Prejudice of Defendant Number 11 by David Yurman Enterprises LLC, David Yurman IP LLC (Wiborg-Rodriguez, T.)

STATUS REPORT by David Yurman Enterprises LLC, David Yurman IP LLC (Wiborg-Rodriguez, T.)

CONSENT FINAL JUDGMENT AND PERMANENT INJUNCTION AS TO DEFENDANT NUMBER 10,granting [53] Motion to Approve Consent Judgment; granting [53] Motion for Permanent Injunction. Signed by Judge William P. Dimitrouleas on 2/27/2023. See attached document for full details.

ORDER. Dismissing Case / Closing Case. (With Prejudice) Signed by Judge William P. Dimitrouleas on 2/27/2023. See attached document for full details.

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

Order

Plaintiff's MOTION for Release of Bond Obligation by David Yurman Enterprises LLC, David Yurman IP LLC. Responses due by 3/14/2023

Text of Proposed Order

ORDER GRANTING PLAINTIFFS MOTION FOR RELEASE OF BOND, granting 59 Motion for Release of Bond Obligation. Signed by Judge William P. Dimitrouleas on 3/1/2023. See attached document for full details.