2022-cv-62376

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. Filing fees $ 402.00 receipt number AFLSDC-16182897, filed by Cartier International A.G., Van Cleef & Arpels SA, Montblanc-Simplo GMBH.

Civil Cover Sheet

Exhibit 1 to Complaint Certificates of Registration for the CARTIER Trademarks

Exhibit 2 to Complaint Certificates of Registration for the MONTBLANC Marks

Exhibit 3 to Complaint Certificates of Registration for the VAN CLEEF Trademark

Clerks Notice of Judge Assignment to Judge Robert N. Scola, Jr. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Jonathan Goodman 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

Plaintiff's Corporate Disclosure Statement by Cartier International A.G., Montblanc-Simplo GMBH, Van Cleef & Arpels SA identifying Corporate Parent Compagnie Financiere Richemont SA for Cartier International A.G., Montblanc-Simplo GMBH, Van Cleef & Arpels SA

Plaintiff's MOTION to Seal per Local Rule 5.4 by Cartier International A.G., Montblanc-Simplo GMBH, Van Cleef & Arpels SA.

Text of Proposed Order

Order Requiring Discovery and Scheduling Conference and Order Referring Discovery Matters to the Magistrate Judge: ORDER REFERRING CASE to Magistrate Judge Jonathan Goodman for Discovery Matters. Signed by Judge Robert N. Scola, Jr on 12/19/2022. See attached document for full details.

Order (Text entry; no document attached.)

ORDER granting 5 Motion to Seal. Schedule "A" to Plaintiffs' Complaint shall be filed under seal and shall remain under seal until further order from this Court. The Summonses in this matter shall be filed and issued under seal and shall remain under seal until further order from this Court. Signed by Judge Robert N. Scola, Jr on 12/20/2022. See attached document for full details.

SYSTEM ENTRY - Docket Entry 10 [misc] restricted/sealed until further notice. (700785) (Text entry; no document attached.)

SYSTEM ENTRY - Docket Entry 11 [misc] restricted/sealed until further notice. (700785) (Text entry; no document attached.)

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

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

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

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

Seizure BOND in the amount of $10,000.00 posted by Cartier International A.G., Montblanc-Simplo GMBH, Van Cleef & Arpels SA. Approved by DEPUTY CLERK.

Plaintiff's MOTION to Unseal by Cartier International A.G., Montblanc-Simplo GMBH, Van Cleef & Arpels SA.

Text of Proposed Order

MAGISTRATE JUDGE GOODMAN'S DISCOVERY PROCEDURES ORDER. Signed by Magistrate Judge Jonathan Goodman on 12/27/2022. See attached document for full details.

AMENDED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants, filed by Cartier International A.G., Van Cleef & Arpels SA, Montblanc-Simplo GMBH.

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

Exhibit 2 to Amended Complaint Certificates of Registration for the MONTBLANC M

Exhibit 3 to Amended Complaint Certificates of Registration for the VAN CLEEF T

PAPERLESS ORDER: grantingthe Plaintiffs' motion to unseal filings. [16]. The Clerk is directed to unseal the following docket entries: ECF Nos. 6, 7, and 10-15. Signed by Judge Robert N. Scola, Jr.

CLERK'S NOTICE of Compliance by Unsealing documents 6, 7, 10 - 15 pursuant to 19 Order.

CERTIFICATE OF SERVICE by Cartier International A.G., Montblanc-Simplo GMBH, Van Cleef & Arpels SA re [8] Order Referring Case to Magistrate Judge, [13] Order on Ex Parte Motion, [9] Order on Motion to Seal, [2] Clerk's Notice of Judge Assignment, [3] Form AO 120/121, [1] Complaint, [4] Certificate of Other Affiliates/Corporate Disclosure Statement, [12] Order on Ex Parte Motion, [5] Plaintiff's MOTION to Seal per Local Rule 5.4, [6] 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, [16] Motion to Unseal Document, [7] 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, [11] Sealed Document, [10] Sealed Document, upon Defendants via website posting

NOTICE by Cartier International A.G., Montblanc-Simplo GMBH, Van Cleef & Arpels SA re [8] Order Referring Case to Magistrate Judge, [1] Complaint, [12] Order on Ex Parte Motion, upon Defendants via Electronic Mail

Exhibit Certificate of Sevice

SUMMONS (Affidavit) Returned Executed on [18] Amended Complaint/Amended Notice of Removal, [1] Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Montblanc-Simplo GMBH, Cartier International A.G., Van Cleef & Arpels SA. acasro.com served on 12/27/2022, response/answer due 1/17/2023; awshleys.shop served on 12/27/2022, response/answer due 1/17/2023; beejury.com served on 12/27/2022, response/answer due 1/17/2023; benecharms.com served on 12/27/2022, response/answer due 1/17/2023; blingjewelry.shop served on 12/27/2022, response/answer due 1/17/2023; bossanovi.com served on 12/27/2022, response/answer due 1/17/2023; daisygina.com served on 12/27/2022, response/answer due 1/17/2023; fassales.com served on 12/27/2022, response/answer due 1/17/2023; firstone.shop served on 12/27/2022, response/answer due 1/17/2023; joyprestige.com served on 12/27/2022, response/answer due 1/17/2023; lbcase.com served on 12/27/2022, response/answer due 1/17/2023; makeweig.com served on 12/27/2022, response/answer due 1/17/2023; mayladi.com served on 12/27/2022, response/answer due 1/17/2023; new-cartier.com served on 12/27/2022, response/answer due 1/17/2023; thedevon.co served on 12/27/2022, response/answer due 1/17/2023; weotem.com served on 12/27/2022, response/answer due 1/17/2023; zhanwicom.com served on 12/27/2022, response/answer due 1/17/2023.

Affidavit of Service

Affidavit of Service

NOTICE by Cartier International A.G., Montblanc-Simplo GMBH, Van Cleef & Arpels SA of E-mail Inquiries Received from Certain Defendants in Connection with Asset Restraint and Service

Exhibit 1 to the Notice of E-mail Inquiries

Order Granting 6 Motion for Preliminary Injunction. Signed by Judge Robert N. Scola, Jr on 1/5/2023. See attached document for full details.

PAPERLESS Minute Entry for proceedings held before Judge Robert N. Scola, Jr: Motion Hearing held on 1/5/2023 re 6 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 Cartier International A.G., Van Cleef & Arpels SA, Montblanc-Simplo GMBH. No appearance on behalf of Defendants individually or through counsel. Total time in court: 5 minutes. Attorney Appearance for Plaintiffs: T. Raquel Wiborg-Rodriguez, Esquire. No appearance on behalf of any of the defendants. Court Reporter: Sharon Velazco, 305-523-5636 / Sharon_PellVelazco@flsd.uscourts.gov.

ORDER on Clerks Default Procedure. Signed by Judge Robert N. Scola, Jr on 1/11/2023. See attached document for full details.

CERTIFICATE OF SERVICE by Cartier International A.G., Montblanc-Simplo GMBH, Van Cleef & Arpels SA re [28] Order upon Defendants via Electronic Mail and via Website Posting

NOTICE of Compliance by Cartier International A.G., Montblanc-Simplo GMBH, Van Cleef & Arpels SA re 28 Order

NOTICE by Cartier International A.G., Montblanc-Simplo GMBH, Van Cleef & Arpels SA re [26] Preliminary Injunction upon Defendants via Electronic Mail

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Cartier International A.G., Montblanc-Simplo GMBH, Van Cleef & Arpels SA re [26] Preliminary Injunction upon Defendants via website posting

Plaintiff's MOTION for Clerk's Entry of Default as to THE INDIVIDUALS, BUSINESS ENTITIES, AND UNINCORPORATED ASSOCIATIONS IDENTIFIED ON SCHEDULE A, acasro.com, awshleys.shop, beejury.com, benecharms.com, blingjewelry.shop, bossanovi.com, daisygina.com, fassales.com, firstone.shop, joyprestige.com, lbcase.com, makeweig.com, mayladi.com, new-cartier.com, thedevon.co, weotem.com, zhanwicom.com by Montblanc-Simplo GMBH, Cartier International A.G., Van Cleef & Arpels SA.

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

Text of Proposed Order

Clerk's Default Entry - Granting 33 Plaintiff's MOTION for Clerk's Entry of Default as to THE INDIVIDUALS, BUSINESS ENTITIES, AND UNINCORPORATED ASSOCIATIONS IDENTIFIED ON SCHEDULE A, acasro.com, awshleys.shop, beejury.com, benecharms.com, blingjewelry.shop, bossanovi.co filed by Cartier International A.G., Van Cleef & Arpels SA, Montblanc-Simplo GMBH. Signed by DEPUTY CLERK on 1/19/2023. See attached document for full details.

Order on Default Judgment Procedure. (Responses due by 2/2/2023) Signed by Judge Robert N. Scola, Jr on 1/19/2023. See attached document for full details.

CERTIFICATE OF SERVICE by Cartier International A.G., Montblanc-Simplo GMBH, Van Cleef & Arpels SA re 35 Order, Set/Reset Deadlines upon Defendants via Electronic Mail and via Website Posting

NOTICE of Compliance by Cartier International A.G., Montblanc-Simplo GMBH, Van Cleef & Arpels SA re 35 Order, Set/Reset Deadlines

NOTICE by Cartier International A.G., Montblanc-Simplo GMBH, Van Cleef & Arpels SA of Identification of Additional Alias Used By Defendant Number 15

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 Cartier International A.G., Montblanc-Simplo GMBH, Van Cleef & Arpels SA.

Declaration of Emma-Jane Tritton in Support Thereof

Exhibit 1 to the Declaration of Emma-Jane Tritton

Declaration of Stephen M. Gaffigan in Support Thereof

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

FINAL DEFAULT JUDGMENT AND PERMANENT INJUNCTION in favor of Cartier International A.G., Montblanc-Simplo GMBH, and Van Cleef & Arpels SA, and against THE INDIVIDUALS, BUSINESS ENTITIES, AND UNINCORPORATED ASSOCIATIONS IDENTIFIED ON SCHEDULE A. GRANTING 39 Plaintiffs' Motion for Default Judgment. ORDER CLOSING CASE. Signed by Judge Robert N. Scola, Jr., on 2/7/2023. See attached document for full details.