2023-cv-60565

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. Filing fees $ 402.00 receipt number AFLSDC-16457252, filed by Chanel, Inc.

Civil Cover Sheet

Exhibit 1 to Complaint Certificates of Registration for the Chanel Trademarks

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 Alicia O. Valle 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 Chanel, Inc.

Plaintiff's MOTION to Seal per Local Rule 5.4 by Chanel, Inc.

Text of Proposed Order Granting Motion to Seal

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 (and responses to 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 (and responses). 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 3/24/2023.

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 3/24/2023.

Plaintiff's Certificate of Other Affiliates by Chanel, Inc.

ORDER granting 5 Motion to Seal. Signed by Judge Raag Singhal on 3/31/2023. See attached document for full details.

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 [misc] restricted/sealed until further notice. (700785) (Text entry; no document attached.)

SYSTEM ENTRY - Docket Entry 15 [misc] restricted/sealed until further notice. (700785) (Text entry; no document attached.)

Order (Text entry; no document attached.)

PLAINTIFF'S NOTICE OF FILING BOND in the amount of $10,000.00 posted by Chanel, Inc. Approved by Judge Raag Singhal

SYSTEM ENTRY - Docket Entry 16 [misc] restricted/sealed until further notice. (Text entry; no document attached.)

NOTICE of Voluntary Dismissal Without Prejudice of Defendant Number 42 by Chanel, Inc.

Plaintiff's MOTION to Unseal by Chanel, Inc.

(Text of Proposed Order Granting Motion to Unseal) Modified Motion Relief on 4/13/2023 (pcs)

AMENDED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants, filed by Chanel, Inc.

(Exhibit 1 to Amended Complaint Certificates of Registration for the Chanel Trademarks)

NOTICE of Voluntary Dismissal of Certain Claims by Chanel, Inc.

NOTICE by Chanel, Inc. re [1] Complaint, [19] Motion to Unseal Document, [20] Amended Complaint/Amended Notice of Removal upon Defendants via Electronic Mail

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Chanel, Inc. re [8] Notice of Court Practice/to Appear/Other, [11] Order on Motion to Seal, [2] Clerk's Notice of Judge Assignment, [4] Certificate of Other Affiliates/Corporate Disclosure Statement, [5] Plaintiff's MOTION to Seal per Local Rule 5.4, [1] Complaint, [9] Order, [17] Bond, [19] Motion to Unseal Document, [18] Notice of Voluntary Dismissal, [20] Amended Complaint/Amended Notice of Removal, [3] Form AO 120/121, [10] Certificate of Other Affiliates/Corporate Disclosure Statement upon Defendants via website posting

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 Chanel, Inc. 711luxury.com served on 4/14/2023, response/answer due 5/5/2023; alldesigner.shop served on 4/14/2023, response/answer due 5/5/2023; amaluxury.com served on 4/14/2023, response/answer due 5/5/2023; bagyork.com served on 4/14/2023, response/answer due 5/5/2023; bcgr-c.com served on 4/14/2023, response/answer due 5/5/2023; besslisa.com served on 4/14/2023, response/answer due 5/5/2023; bessvivi.com served on 4/14/2023, response/answer due 5/5/2023; better9g.com served on 4/14/2023, response/answer due 5/5/2023; bluegisse.com served on 4/14/2023, response/answer due 5/5/2023; bull2022mall.com served on 4/14/2023, response/answer due 5/5/2023; buyinfashion.com.co served on 4/14/2023, response/answer due 5/5/2023; chartcontingency07.com served on 4/14/2023, response/answer due 5/5/2023; deenor.co served on 4/14/2023, response/answer due 5/5/2023; dolvs.com served on 4/14/2023, response/answer due 5/5/2023; entersoutlet.catalog.to served on 4/14/2023, response/answer due 5/5/2023; gloriaeulalias.com served on 4/14/2023, response/answer due 5/5/2023; godofcase.com served on 4/14/2023, response/answer due 5/5/2023; halatote.com served on 4/14/2023, response/answer due 5/5/2023; happydreamliving.com served on 4/14/2023, response/answer due 5/5/2023; highset.top served on 4/14/2023, response/answer due 5/5/2023; hypedeffect.com served on 4/14/2023, response/answer due 5/5/2023; kelvingift.com served on 4/14/2023, response/answer due 5/5/2023; latestock.com served on 4/14/2023, response/answer due 5/5/2023; layana1989.com served on 4/14/2023, response/answer due 5/5/2023; liure.top served on 4/14/2023, response/answer due 5/5/2023; lovebagmall.shop served on 4/14/2023, response/answer due 5/5/2023; lover-baby.com served on 4/14/2023, response/answer due 5/5/2023; luxescase.com served on 4/14/2023, response/answer due 5/5/2023; luxforless.ca served on 4/14/2023, response/answer due 5/5/2023; luxicas.com served on 4/14/2023, response/answer due 5/5/2023; luxuriousplanet.com.co served on 4/14/2023, response/answer due 5/5/2023; luxurybag.vip served on 4/14/2023, response/answer due 5/5/2023; luxurydiscount1.com served on 4/14/2023, response/answer due 5/5/2023; luxuryforles.store served on 4/14/2023, response/answer due 5/5/2023; luxxcasestore.com served on 4/14/2023, response/answer due 5/5/2023; muranotex.com served on 4/14/2023, response/answer due 5/5/2023; noreha.shop served on 4/14/2023, response/answer due 5/5/2023; omydesigner.com served on 4/14/2023, response/answer due 5/5/2023; perfectreplica.ru served on 4/14/2023, response/answer due 5/5/2023; pinkdee.com served on 4/14/2023, response/answer due 5/5/2023; replicayupoo.ru served on 4/14/2023, response/answer due 5/5/2023; reverlavie.com served on 4/14/2023, response/answer due 5/5/2023; selecstores.com served on 4/14/2023, response/answer due 5/5/2023; shelio.shop served on 4/14/2023, response/answer due 5/5/2023; sineed-jewelry.com served on 4/14/2023, response/answer due 5/5/2023; storeonlinecc.com served on 4/14/2023, response/answer due 5/5/2023; temafes.com served on 4/14/2023, response/answer due 5/5/2023; tewyfc.com served on 4/14/2023, response/answer due 5/5/2023; thouan.store served on 4/14/2023, response/answer due 5/5/2023; winbags.ru served on 4/14/2023, response/answer due 5/5/2023; windoy.shop served on 4/14/2023, response/answer due 5/5/2023; xluxuryy.shop served on 4/14/2023, response/answer due 5/5/2023; yeyebuy.com.co served on 4/14/2023, response/answer due 5/5/2023.

Affidavit of Service

Affidavit of Service

NOTICE by Chanel, Inc. of Identification of Additional PayPal Accounts Used By Defendant Numbers 18, 21, 29, and 50

Declaration of Eric Rosaler in Support Thereof

Exhibit 1 to the Declaration of Eric Rosaler

Declaration of Kathleen Burns in Support Thereof

(Exhibit 1 to the Declaration of Kathleen Burns)

NOTICE by Chanel, Inc. of Email Inquiries Received From Certain Defendants in Connection With Asset Restraint And Service

Exhibit 1 Thereto

PAPERLESS Minute Entry and MINUTE ORDER for proceedings held before Judge Raag Singhal: Motion Hearing held on 5/3/2023 re 6 Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order, Preliminary Injunction, and Order Restraining Transfer of Assets. Total time in court: 15 minutes. Attorney Appearance(s): Virgilio Gigante. Court Reporter: Karl Shires, 954-769-5496 / Karl_Shires@flsd.uscourts.gov.

ORDER GRANTING re [6] Ex Parte Motion, filed by Chanel, Inc. Signed by Judge Raag Singhal on 5/5/2023.

ORDER granting 19 Motion to Unseal Document 19 Motion to Unseal Document. Signed by Judge Raag Singhal on 5/5/2023. See attached document for full details.

NOTICE of Compliance re 29 Order on Motion to Unseal Document. (All docket entries unsealed)

Plaintiff's MOTION for Clerk's Entry of Default as to 711luxury.com, The Individuals, Business Entities, and Unincorporated Associations, alldesigner.shop, amaluxury.com, bagyork.com, bcgr-c.com, besslisa.com, bessvivi.com, better9g.com, bluegisse.com, bull2022mall.com, buyinfashion.com.co, chartcontingency07.com, deenor.co, dolvs.com, entersoutlet.catalog.to, gloriaeulalias.com, godofcase.com, halatote.com, happydreamliving.com, highset.top, hypedeffect.com, kelvingift.com, latestock.com, layana1989.com, liure.top, lovebagmall.shop, lover-baby.com, luxescase.com, luxforless.ca, luxicas.com, luxuriousplanet.com.co, luxurybag.vip, luxurydiscount1.com, luxuryforles.store, luxxcasestore.com, muranotex.com, noreha.shop, omydesigner.com, perfectreplica.ru, pinkdee.com, replicayupoo.ru, reverlavie.com, selecstores.com, shelio.shop, sineed-jewelry.com, storeonlinecc.com, temafes.com, tewyfc.com, thouan.store, winbags.ru, windoy.shop, xluxuryy.shop, yeyebuy.com.co by Chanel, Inc.

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

Text of Proposed Order

Clerk's Entry of Default as to 711luxury.com, alldesigner.shop, amaluxury.com, bagyork.com, bcgr-c.com, besslisa.com, bessvivi.com, better9g.com, bluegisse.com, bull2022mall.com, buyinfashion.com.co, chartcontingency07.com, deenor.co, dolvs.com, entersoutlet.catalog.to, gloriaeulalias.com, godofcase.com, halatote.com, happydreamliving.com, highset.top, hypedeffect.com, kelvingift.com, latestock.com, layana1989.com, liure.top, lovebagmall.shop, lover-baby.com, luxescase.com, luxforless.ca, luxicas.com, luxuriousplanet.com.co, luxurybag.vip, luxurydiscount1.com, luxuryforles.store, luxxcasestore.com, muranotex.com, noreha.shop, omydesigner.com, perfectreplica.ru, pinkdee.com, replicayupoo.ru, reverlavie.com, selecstores.com, shelio.shop, sineed-jewelry.com, storeonlinecc.com, temafes.com, tewyfc.com, thouan.store, winbags.ru, windoy.shop, xluxuryy.shop, yeyebuy.com.co - Motions Terminated: 31 Motion for Clerk's Entry of Default, Signed by DEPUTY CLERK on 6/1/2023.

Plaintiff's NOTICE by Chanel, Inc. of Identification of Additional Aliases and PayPal Accounts Used By Defendant Numbers 2 and 28

Declaration of Eric Rosaler in Support Thereof

Exhibit 1 to the Rosaler Declaration

Declaration of Kathleen Burns in Support Thereof

(Exhibit 1 to the Burns Declaration)

Plaintiff's NOTICE by Chanel, Inc. of Identification of Additional PayPal Account Used By Defendant Number 44

Declaration of Eric Rosaler in Support Thereof

(Exhibit 1 to the Rosaler Declaration)

Plaintiff's MOTION for Default Judgment and Memorandum of Law in Support Thereof by Chanel, Inc.

Declaration of Elizabeth Han in Support Thereof

Exhibit 1 to the Han Declaration

Declaration of Stephen M. Gaffigan in Support Thereof

Text of Proposed Order Granting Motion for Final Default Judgment

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

Notice of Ninety Days Expiring by Chanel, Inc. re 35 Plaintiff's MOTION for Default Judgment and Memorandum of Law in Support Thereof filed by Chanel, Inc.

ORDER granting 35 Motion for Default Judgment. Signed by Judge Raag Singhal on 1/29/2024. See attached document for full details.

DEFAULT FINAL JUDGMENT AND PERMANENT INJUNCTION: re 37 granting Plaintiff's Motion for Entry of Final Default Judgment Against Defendants. JUDGMENT in favor of Chanel, Inc. and against 711luxury.com, The Individuals, Business Entities, and Unincorporated Associations, alldesigner.shop, amaluxury.com, bagyork.com, bcgr-c.com, besslisa.com, bessvivi.com, better9g.com, bluegisse.com, bull2022mall.com, buyinfashion.com.co, chartcontingency07.com, deenor.co, dolvs.com, entersoutlet.catalog.to, gloriaeulalias.com, godofcase.com, halatote.com, happydreamliving.com, highset.top, hypedeffect.com, kelvingift.com, latestock.com, layana1989.com, liure.top, lovebagmall.shop, lover-baby.com, luxescase.com, luxforless.ca, luxicas.com, luxuriousplanet.com.co, luxurybag.vip, luxurydiscount1.com, luxuryforles.store, luxxcasestore.com, muranotex.com, noreha.shop, omydesigner.com, perfectreplica.ru, pinkdee.com, replicayupoo.ru, reverlavie.com, selecstores.com, shelio.shop, sineed-jewelry.com, storeonlinecc.com, temafes.com, tewyfc.com, thouan.store, winbags.ru, windoy.shop, xluxuryy.shop, and yeyebuy.com.co This Clerk of Court is directed to CLOSE the case and DENY AS MOOT any pending motions. Closing Case. Signed by Judge Raag Singhal on 1/29/2024. See attached document for full details.