2023-cv-60835

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. Filing fees $ 402.00 receipt number AFLSDC-16595388, 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

(Exhibits) (nan)

Plaintiff's Corporate Disclosure Statement by Chanel, Inc.

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

SYSTEM ENTRY - Docket Entry 6 [motion] restricted/sealed until further notice. (700785) (Text entry; no document attached.)

SYSTEM ENTRY - Docket Entry 7 [motion] restricted/sealed until further notice. (700785) (Text entry; no document attached.)

(Text of Proposed Order Granting Motion to Seal)

ORDER granting [5] Motion to Seal. Signed by Judge Raag Singhal on 6/5/2023. See attached document for full details.

Order (Text entry; no document attached.)

Planitiff's Notice of Filing BOND in the amount of $10,000.00 posted by Chanel, Inc. Approved by Judge Raag Singhal

Plaintiff's MOTION to Unseal by Chanel, Inc.

Text of Proposed Order Granting Motion to Unseal

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 Trad

Plaintiff's NOTICE by Chanel, Inc. re [15] Plaintiff's MOTION to Unseal, [1] Complaint, upon Defendants via Electronic Mail

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Chanel, Inc. re [8] Order on Motion to Seal, [4] Certificate of Other Affiliates/Corporate Disclosure Statement, [3] Form AO 120/121, [5] Plaintiff's MOTION to Seal per Local Rule 5.4, [2] Clerk's Notice of Judge Assignment, [15] Plaintiff's MOTION to Unseal, [1] Complaint, [14] Bond upon Defendants via website posting

SUMMONS (Affidavit) Returned Executed on [16] Amended Complaint/Amended Notice of Removal, [1] Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Chanel, Inc. ANer 10-18 Delivery served on 6/16/2023, response/answer due 7/7/2023; AOYONT Direct served on 6/16/2023, response/answer due 7/7/2023; Anqing Jiaohu Trading Co., Ltd. served on 6/16/2023, response/answer due 7/7/2023; Anqing Laytu Trading Co., Ltd. served on 6/16/2023, response/answer due 7/7/2023; Anqing Zuoshu Trading Co., Ltd. served on 6/16/2023, response/answer due 7/7/2023; BUDIAN-DAMIA served on 6/16/2023, response/answer due 7/7/2023; Boutiqueshop222 served on 6/16/2023, response/answer due 7/7/2023; CUNLINFAS served on 6/16/2023, response/answer due 7/7/2023; Caolianchuans served on 6/16/2023, response/answer due 7/7/2023; ChenF served on 6/16/2023, response/answer due 7/7/2023; DAIGUOQING served on 6/16/2023, response/answer due 7/7/2023; DERIFA JEWELRY served on 6/16/2023, response/answer due 7/7/2023; DTYGDTY served on 6/16/2023, response/answer due 7/7/2023; Daleny Jewelry served on 6/16/2023, response/answer due 7/7/2023; ElenaDong Shop served on 6/16/2023, response/answer due 7/7/2023; FEOCOO served on 6/16/2023, response/answer due 7/7/2023; Fehkso served on 6/16/2023, response/answer due 7/7/2023; HUOENBAIHUO served on 6/16/2023, response/answer due 7/7/2023; Haikou Kailinyi Trading Co., LTD served on 6/16/2023, response/answer due 7/7/2023; Heze Haobo served on 6/16/2023, response/answer due 7/7/2023; JEYKOY served on 6/16/2023, response/answer due 7/7/2023; JIVATU JEWELRY served on 6/16/2023, response/answer due 7/7/2023; Janet Jones served on 6/16/2023, response/answer due 7/7/2023; KEACEY served on 6/16/2023, response/answer due 7/7/2023; KJASDHASD served on 6/16/2023, response/answer due 7/7/2023; KNCVUBCKJ served on 6/16/2023, response/answer due 7/7/2023; LRCVTR served on 6/16/2023, response/answer due 7/7/2023; LiShaoHuiUS served on 6/16/2023, response/answer due 7/7/2023; LiuFengLiuFeng served on 6/16/2023, response/answer due 7/7/2023; Lyxhry served on 6/16/2023, response/answer due 7/7/2023; Mallfeel served on 6/16/2023, response/answer due 7/7/2023; NPAOLIGEI served on 6/16/2023, response/answer due 7/7/2023; NPGQM served on 6/16/2023, response/answer due 7/7/2023; PUTIANSHIL served on 6/16/2023, response/answer due 7/7/2023; PingShangLong served on 6/16/2023, response/answer due 7/7/2023; Professional earbuds manufacturer served on 6/16/2023, response/answer due 7/7/2023; ROMUKA Jewelry served on 6/16/2023, response/answer due 7/7/2023; Reasonable price (about two weeks delivery) served on 6/16/2023, response/answer due 7/7/2023; SAJKHHLJK served on 6/16/2023, response/answer due 7/7/2023; TaoTaoCool served on 6/16/2023, response/answer due 7/7/2023; TeodorsJY served on 6/16/2023, response/answer due 7/7/2023; UOOANUO Store served on 6/16/2023, response/answer due 7/7/2023; WangDeMinngJiHaoShang served on 6/16/2023, response/answer due 7/7/2023; Wanning Qihuitao Trading Co., LTD served on 6/16/2023, response/answer due 7/7/2023; Wym-shop served on 6/16/2023, response/answer due 7/7/2023; YL Store 7-15days delivery served on 6/16/2023, response/answer due 7/7/2023; Youboda served on 6/16/2023, response/answer due 7/7/2023; Zhifu Ziyi decoration material firm served on 6/16/2023, response/answer due 7/7/2023; ZhongYiLinsnhb served on 6/16/2023, response/answer due 7/7/2023; baijiandinshishang served on 6/16/2023, response/answer due 7/7/2023; buahhasima served on 6/16/2023, response/answer due 7/7/2023; caizengqiangbeimeizhan served on 6/16/2023, response/answer due 7/7/2023; chengdulinyaweicunshangmaoyouxiangongsi served on 6/16/2023, response/answer due 7/7/2023; chenzihaobeimeizhan served on 6/16/2023, response/answer due 7/7/2023; dongmengqingdebeimeidianpu served on 6/16/2023, response/answer due 7/7/2023; foshanshishunwanhongmaoyiyouxiangongsi served on 6/16/2023, response/answer due 7/7/2023; guangzhououyushangmaoyouxiangongsi served on 6/16/2023, response/answer due 7/7/2023; hefeishimiduidianzishangwuyouxiangongsi served on 6/16/2023, response/answer due 7/7/2023; hnhkhjm served on 6/16/2023, response/answer due 7/7/2023; huanshuobaihuoshanghang served on 6/16/2023, response/answer due 7/7/2023; jackchan served on 6/16/2023, response/answer due 7/7/2023; jinanjianjijinshangmaoyouxiangongsi served on 6/16/2023, response/answer due 7/7/2023; nanyangxihuanwangluokejiyouxiangongsi served on 6/16/2023, response/answer due 7/7/2023; qiuyandianpu served on 6/16/2023, response/answer due 7/7/2023; shangchengxianpandudubaihuolingshoushangdian served on 6/16/2023, response/answer due 7/7/2023; songcaixuan served on 6/16/2023, response/answer due 7/7/2023; tangxiangrongbaodan served on 6/16/2023, response/answer due 7/7/2023; wenshanmingyudianzishangwuyouxiangongsi served on 6/16/2023, response/answer due 7/7/2023; wuweishichushimeijiadian served on 6/16/2023, response/answer due 7/7/2023; wuzhongqulinhuyimeifangfuzhuangdian served on 6/16/2023, response/answer due 7/7/2023; yifengmoweiyouxiangongsi served on 6/16/2023, response/answer due 7/7/2023; zhengzhouruhoushangmaoyouxiangongsi served on 6/16/2023, response/answer due 7/7/2023; zhijiangshinuoqiushangmaoyouxiangongsi served on 6/16/2023, response/answer due 7/7/2023.

Affidavit of Service

Affidavit of Service

PAPERLESS Minute Entry and MINUTE ORDER for proceedings held before Judge Raag Singhal: Motion Hearing held on 6/20/2023 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): T. Raquel Wiborg-Rodriguez. Court Reporter: Karl Shires, 954-769-5496 / Karl_Shires@flsd.uscourts.gov.

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 6/26/2023. See attached document for full details.

ORDER GRANTING 6 APPLICATION FOR ENTRY OF PRELIMINARY INJUNCTION. Signed by Judge Raag Singhal on 6/26/2023. See attached document for full details.

Plaintiff's NOTICE by Chanel, Inc. re 22 Preliminary Injunction upon Defendants via Electronic Mail

(Exhibit Certificate of Sevice)

CERTIFICATE OF SERVICE by Chanel, Inc. re 22 Preliminary Injunction upon Defendants via website posting

Plaintiff's MOTION for Clerk's Entry of Default as to ANer 10-18 Delivery, AOYONT Direct, Anqing Jiaohu Trading Co., Ltd., Anqing Laytu Trading Co., Ltd., Anqing Zuoshu Trading Co., Ltd., BUDIAN-DAMIA, Boutiqueshop222, CUNLINFAS, Caolianchuans, ChenF, DAIGUOQING, DERIFA JEWELRY, DTYGDTY, Daleny Jewelry, ElenaDong Shop, FEOCOO, Fehkso, HUOENBAIHUO, Haikou Kailinyi Trading Co., LTD, Heze Haobo, JEYKOY, JIVATU JEWELRY, Janet Jones, KEACEY, KJASDHASD, KNCVUBCKJ, LRCVTR, LiShaoHuiUS, LiuFengLiuFeng, Lyxhry, Mallfeel, NPAOLIGEI, NPGQM, PUTIANSHIL, PingShangLong, Professional earbuds manufacturer, ROMUKA Jewelry, Reasonable price (about two weeks delivery), SAJKHHLJK, TaoTaoCool, TeodorsJY, The Individuals, Business Entities, and Unincorporated Associations, UOOANUO Store, WangDeMinngJiHaoShang, Wanning Qihuitao Trading Co., LTD, Wym-shop, YL Store 7-15days delivery, Youboda, Zhifu Ziyi decoration material firm, ZhongYiLinsnhb, baijiandinshishang, buahhasima, caizengqiangbeimeizhan, chengdulinyaweicunshangmaoyouxiangongsi, chenzihaobeimeizhan, dongmengqingdebeimeidianpu, foshanshishunwanhongmaoyiyouxiangongsi, guangzhououyushangmaoyouxiangongsi, hefeishimiduidianzishangwuyouxiangongsi, hnhkhjm, huanshuobaihuoshanghang, jackchan, jinanjianjijinshangmaoyouxiangongsi, nanyangxihuanwangluokejiyouxiangongsi, qiuyandianpu, shangchengxianpandudubaihuolingshoushangdian, songcaixuan, tangxiangrongbaodan, wenshanmingyudianzishangwuyouxiangongsi, wuweishichushimeijiadian, wuzhongqulinhuyimeifangfuzhuangdian, yifengmoweiyouxiangongsi, zhengzhouruhoushangmaoyouxiangongsi, zhijiangshinuoqiushangmaoyouxiangongsi by Chanel, Inc.

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

(Text of Proposed Order)

ORDER Granting [25] Plaintiff's MOTION for Clerk's Entry of Default as to ANer 10-18 Delivery, AOYONT Direct, Anqing Jiaohu Trading Co., Ltd., Anqing Laytu Trading Co., Ltd., Anqing Zuoshu Trading Co., Ltd., BUDIAN-DAMIA, Boutiqueshop222, CUNLINFAS, Caolia filed by Chanel, Inc., Motions terminated: [25] Plaintiff's MOTION for Clerk's Entry of Default as to ANer 10-18 Delivery, AOYONT Direct, Anqing Jiaohu Trading Co., Ltd., Anqing Laytu Trading Co., Ltd., Anqing Zuoshu Trading Co., Ltd., BUDIAN-DAMIA, Boutiqueshop222, CUNLINFAS, Caolia filed by Chanel, Inc. Motions terminated: [25] Plaintiff's MOTION for Clerk's Entry of Default as to ANer 10-18 Delivery, AOYONT Direct, Anqing Jiaohu Trading Co., Ltd., Anqing Laytu Trading Co., Ltd., Anqing Zuoshu Trading Co., Ltd., BUDIAN-DAMIA, Boutiqueshop222, CUNLINFAS, Caolia filed by Chanel, Inc. Signed by DEPUTY CLERK on 8/21/2023. See attached document for full details.

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

Declaration of Elizabeth Han in Support of Plaintiff's Motion for Entry of Final Default Judgment Against Defendants

Exhibit Exhibit 1 to Decl. of Elizabeth Han

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)

ORDER ON DEFAULT FINAL JUDGMENT PROCEDURE. Signed by Judge Raag Singhal on 8/23/2023. See attached document for full details.

NOTICE of Compliance by Chanel, Inc. re 28 Order

Notice of Ninety Days Expiring by Chanel, Inc. re [27] Plaintiff's MOTION for Default Judgment Against Defendants and Memorandum of Law In Support Thereof filed by Chanel, Inc.

ORDER granting [27] Motion for Default Judgment. Accordingly, it is hereby ORDERED AND ADJUDGED that Plaintiff's Default Judgment Motion (DE [27]) is GRANTED. In accordance with Federal Rule of Civil Procedure 58, judgment for Plaintiff will be entered separately. Signed by Judge Raag Singhal on 2/1/2024. See attached document for full details.

DEFAULT FINAL JUDGMENT AND PERMANENT INJUNCTION: re [31]Plaintiff's Motion for Entry of Final Default Judgement. DEFAULT JUDGMENT in favor of Chanel, Inc. and against ANer 10-18 Delivery, AOYONT Direct, Anqing Jiaohu Trading Co., Ltd., Anqing Laytu Trading Co., Ltd., Anqing Zuoshu Trading Co., Ltd., BUDIAN-DAMIA, Boutiqueshop222, CUNLINFAS, Caolianchuans, ChenF, DAIGUOQING, DERIFA JEWELRY, DTYGDTY, Daleny Jewelry, ElenaDong Shop, FEOCOO, Fehkso, HUOENBAIHUO, Haikou Kailinyi Trading Co., LTD, Heze Haobo, JEYKOY, JIVATU JEWELRY, Janet Jones, KEACEY, KJASDHASD, KNCVUBCKJ, LRCVTR, LiShaoHuiUS, LiuFengLiuFeng, Lyxhry, Mallfeel, NPAOLIGEI, NPGQM, PUTIANSHIL, PingShangLong, Professional earbuds manufacturer, ROMUKA Jewelry, Reasonable price (about two weeks delivery), SAJKHHLJK, TaoTaoCool, TeodorsJY, The Individuals, Business Entities, and Unincorporated Associations, UOOANUO Store, WangDeMinngJiHaoShang, Wanning Qihuitao Trading Co., LTD, Wym-shop, YL Store 7-15days delivery, Youboda, Zhifu Ziyi decoration material firm, ZhongYiLinsnhb, baijiandinshishang, buahhasima, caizengqiangbeimeizhan, chengdulinyaweicunshangmaoyouxiangongsi, chenzihaobeimeizhan, dongmengqingdebeimeidianpu, foshanshishunwanhongmaoyiyouxiangongsi, guangzhououyushangmaoyouxiangongsi, hefeishimiduidianzishangwuyouxiangongsi, hnhkhjm, huanshuobaihuoshanghang, jackchan, jinanjianjijinshangmaoyouxiangongsi, nanyangxihuanwangluokejiyouxiangongsi, qiuyandianpu, shangchengxianpandudubaihuolingshoushangdian, songcaixuan, tangxiangrongbaodan, wenshanmingyudianzishangwuyouxiangongsi, wuweishichushimeijiadian, wuzhongqulinhuyimeifangfuzhuangdian, yifengmoweiyouxiangongsi, zhengzhouruhoushangmaoyouxiangongsi, and zhijiangshinuoqiushangmaoyouxiangongsi. This Clerk of the Court is directed to CLOSE the case and DENY AS MOOT any pending motions. Closing Case. Signed by Judge Raag Singhal on 2/1/2024. See attached document for full details.

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

Order