2023-cv-60653

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. Filing fees $ 402.00 receipt number AFLSDC-16511648, filed by The North Face Apparel Corp., TBL Licensing LLC, Vans, Inc.

Civil Cover Sheet

Exhibit 1 to Complaint Certificates of Registration for the The North Face Trademarks

Exhibit 2 to Complaint Certificates of Registration for the Vans Trademarks

(Exhibit 3 to Complaint Certificates of Registration for the Timberland 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. 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) (jc)

Plaintiff's Corporate Disclosure Statement by TBL Licensing LLC, The North Face Apparel Corp., Vans, Inc. identifying Corporate Parent V.F. Corporation, Corporate Parent VF Outdoor, LLC for The North Face Apparel Corp., Vans, Inc.; Corporate Parent V.F. Corporation, Corporate Parent VF International Holding GmbH for TBL Licensing LLC

Plaintiff's MOTION to Seal per Local Rule 5.4 by TBL Licensing LLC, The North Face Apparel Corp., Vans, Inc.

(Text of Proposed Order Granting Motion to Seal)

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 by TBL Licensing LLC, The North Face Apparel Corp., Vans, Inc.

Declaration of Lisa O'Hal in Support Thereof

Declaration of Stephen M. Gaffigan in Support Thereof

Declaration of Kathleen Burns in Support Thereof

Exhibit 1 to the Burns Declaration - part 1

Exhibit 1 to the Burns Declaration - part 2

Exhibit 1 to the Burns Declaration - part 3

Text of Proposed Order Granting ex parte injunctive relief) Modified on 7/17/2023 by Unsealing document per DE

Order (kpe)

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 by TBL Licensing LLC, The North Face Apparel Corp., Vans, Inc.

Declaration of Stephen M. Gaffigan in Support Thereof

Exhibit 1 to the Gaffigan Declaration

Text of Proposed Order Granting Motion for Order Authorizing Alternate Service of Process) Modified on 7/17/2023 by Unsealing document per DE

Order (kpe)

SEALED ORDER Granting 6 Ex Parte Application For Entry Of Temporary Restraining Order. Telephonic Motion Hearing set for 7/27/2023 04:00 PM before Judge Raag Singhal. Signed by Judge Raag Singhal on 6/29/2023. See attached document for full details. (kpe) Modified on 7/17/2023 by Unsealing document per DE 17 Order

ORDER 7 Authorizing Alternative Service Of Process On Defendants Under Federal Rule Of Civil Procedure 4(f)(3). Signed by Judge Raag Singhal on 6/29/2023. See attached document for full details. (kpe) Modified on 7/17/2023 by Unsealing document per DE 17 Order

ORDER to File Under Seal. Order granting 5 Motion to Seal. Signed by Judge Raag Singhal on 6/29/2023. See attached document for full details.

NOTICE of Sealed Filing Schedule A re DE# 10 Order on Motion to Seal by TBL Licensing LLC, The North Face Apparel Corp., Vans, Inc.

Schedule A to Plaintiffs' Complaint) Modified text on 7/5/2023 (kpe). Modified on 7/17/2023 by Unsealing document per DE

Order (kpe)

NOTICE of Filing Proposed Summonses Under Seal re DE# 10 Order on Motion to Seal by TBL Licensing LLC, The North Face Apparel Corp., Vans, Inc.

Summon(s)) Modified text on 7/5/2023 (kpe). Modified on 7/17/2023 by Unsealing document per DE

Order (kpe)

NOTICE of Filing Bond by TBL Licensing LLC, The North Face Apparel Corp., Vans, Inc.

Summons issued as to The Individuals, Business Entities, and Unincorporated Associations. (kpe) Modified on 7/17/2023 by Unsealing document per DE 17 Order

MOTION to Unseal Document(s) by TBL Licensing LLC, The North Face Apparel Corp., Vans, Inc.

(Text of Proposed Order) Modified Relief on 7/17/2023 (ls)

Clerk's Notice to Filer re 15 MOTION to Unseal. Filer Selected the Wrong Motion Relief(s); 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.

ORDER granting 15 Motion to Unseal. The Clerk of Court is DIRECTED to unseal all docket entries in this case and return those portions of the Court file to the public records. Signed by Judge Raag Singhal on 7/17/2023. See attached document for full details.

CLERK'S NOTICE of Compliance Unsealing documents 6 - 9, 11, 12 and 14 pursuant 17 Order.

Plaintiff's NOTICE by TBL Licensing LLC, The North Face Apparel Corp., Vans, Inc. of Identification of Additional Aliases For Defendant Number 5 and Additional PayPal Accounts Used by Defendant Numbers 5 and 6

Declaration of Kathleen Burns in Support Thereof

(Exhibit 1 to the Burns Declaration)

AMENDED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants, filed by The North Face Apparel Corp., TBL Licensing LLC, Vans, Inc.

Exhibit 1 to Amended Complaint Certificates of Registration for the The North Face Trademarks

Exhibit 2 to Amended Complaint Certificates of Registration for the Vans Trademarks

(Exhibit 3 to Amended Complaint Certificates of Registration for the Timberland Trademarks)

NOTICE of Voluntary Dismissal Without Prejudice of Defendant Number 16 by TBL Licensing LLC, The North Face Apparel Corp., Vans, Inc.

Plaintiff's NOTICE by TBL Licensing LLC, The North Face Apparel Corp., Vans, Inc. re 8 Order on Ex Parte Motion, 1 Complaint, 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 upon Defendants via Electronic Mail

(Exhibit Certificate of Sevice)

CERTIFICATE OF SERVICE by TBL Licensing LLC, The North Face Apparel Corp., Vans, Inc. re 8 Order on Ex Parte Motion, 14 Sealed Document, 13 Notice (Other), 9 Order on Ex Parte Motion, 2 Clerks Notice of Judge Assignment, 1 Complaint, 10 Order on Motion to Seal, 5 Plaintiff's MOTION to Seal per Local Rule 5.4, 12 Sealed Document, 11 Sealed Document, 3 Form AO 120/121, 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, 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, 4 Certificate of Other Affiliates/Corporate Disclosure Statement, 15 Motion to Unseal Document(s) upon Defendants via website posting

SUMMONS (Affidavit) Returned Executed on 20 Amended Complaint/Amended Notice of Removal, 1 Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Vans, Inc., The North Face Apparel Corp., TBL Licensing LLC. 247teeshirt.com served on 7/18/2023, response/answer due 8/8/2023; abigailjewellery.com served on 7/18/2023, response/answer due 8/8/2023; allyoloswag.com served on 7/18/2023, response/answer due 8/8/2023; bellidress.com served on 7/18/2023, response/answer due 8/8/2023; blvcks.com served on 7/18/2023, response/answer due 8/8/2023; daisyelsa.com served on 7/18/2023, response/answer due 8/8/2023; drmengele.com served on 7/18/2023, response/answer due 8/8/2023; macallcloth.com served on 7/18/2023, response/answer due 8/8/2023; missinpink.com served on 7/18/2023, response/answer due 8/8/2023; missinstyle.com served on 7/18/2023, response/answer due 8/8/2023; newagetee.com served on 7/18/2023, response/answer due 8/8/2023; oldenvy.com served on 7/18/2023, response/answer due 8/8/2023; senlinlangbs.com served on 7/18/2023, response/answer due 8/8/2023; sistadress.com served on 7/18/2023, response/answer due 8/8/2023; sneakerwell.com served on 7/18/2023, response/answer due 8/8/2023; thegalshop.com served on 7/18/2023, response/answer due 8/8/2023; timberland--boots.net served on 7/18/2023, response/answer due 8/8/2023; violetbabe.com served on 7/18/2023, response/answer due 8/8/2023.

Affidavit of Service

(Affidavit of Service)

PAPERLESS Minute Entry for proceedings held before Judge Raag Singhal: Evidentiary Hearing for Motion on Preliminary Injunction held on 7/27/2023. Total time in court: 15 minutes. Order forthcoming. Attorney Appearance(s): Virgilio Gigante, Court Reporter: Karl Shires, 954-769-5496 / Karl_Shires@flsd.uscourts.gov.

ORDER GRANTING APPLICATION FOR ENTRY OF PRELIMINARY INJUNCTION granting 6 Ex Parte Motion. Signed by Judge Raag Singhal on 7/31/2023. See attached document for full details. (pcs) Modified to unseal per DE 17 on 8/11/2023

Plaintiff's MOTION for Clerk's Entry of Default as to 247teeshirt.com, The Individuals, Business Entities, and Unincorporated Associations, abigailjewellery.com, allyoloswag.com, bellidress.com, blvcks.com, daisyelsa.com, drmengele.com, macallcloth.com, missinpink.com, missinstyle.com, newagetee.com, oldenvy.com, senlinlangbs.com, sistadress.com, sneakerwell.com, thegalshop.com, timberland--boots.net, violetbabe.com by Vans, Inc., The North Face Apparel Corp., TBL Licensing LLC.

Declaration of Stephen M. Gaffigan in Support Thereof

(Text of Proposed Order)

PAPERLESS Clerk's Entry of Default as to 247teeshirt.com, abigailjewellery.com, allyoloswag.com, bellidress.com, blvcks.com, daisyelsa.com, drmengele.com, macallcloth.com, missinpink.com, missinstyle.com, newagetee.com, oldenvy.com, senlinlangbs.com, sistadress.com, sneakerwell.com, thegalshop.com, timberland--boots.net, violetbabe.com - Motions Terminated: 27 Motion for Clerks Entry of Default. Signed by DEPUTY CLERK on 8/11/2023.

ORDER ON DEFAULT FINAL JUDGMENT PROCEDURE. Signed by Judge Raag Singhal on 8/17/2023. See attached document for full details.

Plaintiff's NOTICE by TBL Licensing LLC, The North Face Apparel Corp., Vans, Inc. re 26 Order on Ex Parte Motion, upon Defendants via Electronic Mail

(Exhibit Certificate of Sevice)

CERTIFICATE OF SERVICE by TBL Licensing LLC, The North Face Apparel Corp., Vans, Inc. re 26 Order on Ex Parte Motion, upon Defendants via website posting

Plaintiff's MOTION for Default Judgment Against Defendants and Memorandum of Law In Support Thereof by TBL Licensing LLC, The North Face Apparel Corp., Vans, Inc.

Declaration of Lisa O'Hal in support of Plaintiffs' Motion for Entry of Final Default Judgment

Exhibit 1 to Decl. of Lisa O'Hal

Declaration of Stephen M. Gaffigan in Support of Motion for Final Default Judgment

Text of Proposed Order Granting Motion for Entry of Final Default Judgment

(Text of Proposed Order Granting Final Default Judgment Against Defendants)

Notice of Ninety Days Expiring by TBL Licensing LLC, The North Face Apparel Corp., Vans, Inc. re [32] Plaintiff's MOTION for Default Judgment Against Defendants and Memorandum of Law In Support Thereof filed by The North Face Apparel Corp., Vans, Inc., TBL Licensing LLC

ORDER granting [32] Motion for Final Default Judgment. Signed by Judge Raag Singhal on 2/27/2024. See attached document for full details.

DEFAULT FINAL JUDGMENT and PERMANENT INJUNCTION in favor of TBL Licensing LLC, The North Face Apparel Corp., Vans, Inc. against 247teeshirt.com, abigailjewellery.com, allyoloswag.com, bellidress.com, blvcks.com, daisyelsa.com, drmengele.com, macallcloth.com, missinpink.com, missinstyle.com, newagetee.com, oldenvy.com, senlinlangbs.com, sistadress.com, sneakerwell.com, thegalshop.com, thevaultdesigneraccessories.com, timberland--boots.net, violetbabe.com; Closing Case. Signed by Judge Raag Singhal on 2/27/2024. See attached document for full details.

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

Supplement Default Final Judgment and Permanent Injunction