2023-cv-61007

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. Filing fees $ 402.00 receipt number AFLSDC-16651906, filed by Gucci America, Inc.

Civil Cover Sheet

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

Clerks Notice of Judge Assignment to Judge Rodney Smith. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Lisette M. Reid 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) (nwn)

Plaintiff's Certificate of Other Affiliates/Corporate Disclosure Statement by Gucci America, Inc. identifying Corporate Parent Kering Americas, Inc., Corporate Parent Kering Holland NV, Corporate Parent Kering SA for Gucci America, Inc. (Wiborg-Rodriguez, T.)

SYSTEM ENTRY - Docket Entry 8 [misc] restricted/sealed until further notice. (1336528) (Text entry; no document attached.)

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

SYSTEM ENTRY - Docket Entry 6 [motion] restricted/sealed until further notice. (1336528) (Text entry; no document attached.)

SYSTEM ENTRY - Docket Entry 7 [motion] restricted/sealed until further notice. (1336528) (Text entry; no document attached.)

(Text of Proposed Order) (Wiborg-Rodriguez, T.)

Notice of Ninety Days Expiring Regarding Docket Entries 6 and 7 by Gucci America, Inc. (Wiborg-Rodriguez, T.)

Notice of Ninety Days Expiring Second Notice Regarding Docket Entries 6 and 7 by Gucci America, Inc. (Wiborg-Rodriguez, T.)

ORDER GRANTING MOTION TO SEAL granting [5] Motion to Seal. Signed by Judge Rodney Smith on 12/12/2023. See attached document for full details.

Order (Text entry; no document attached.)

Bond on Injunction in the amount of $10,000 posted by Gucci America, Inc. Approved by DEPUTY CLERK on 12/29/2023.

Plaintiff's MOTION to Unseal by Gucci America, Inc.

Text of Proposed Order

ORDER TO UNSEAL granting [18] Motion to Unseal Case. The Clerk shall UNSEAL all docket entries in this case. Signed by Judge Rodney Smith on 1/5/2024. See attached document for full details.

Clerk's NOTICE of Compliance re 19 Order on Motion to Unseal Case. All Docket Entries Unsealed.

Plaintiff's NOTICE upon Defendants via Electronic Mail by Gucci America, Inc. re [15] Order on Ex Parte Motion, [1] Complaint

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Gucci America, Inc. re [11] Order on Motion to Seal, [5] Plaintiff's MOTION to Seal per Local Rule 5.4, [16] Order on Ex Parte Motion, [9] Notice of Ninety Days Expiring, [3] Form AO 120/121, [18] Motion to Unseal Case, [15] Order on Ex Parte Motion, [1] Complaint, [17] Bond, [12] Sealed Document, [6] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order, Preliminary Injunction, and Order Restraining Transfer of Assets Against Defendants and Memorandum of Law in Support Thereof, [13] Sealed 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, [8] Ex Parte Document, [4] Certificate of Other Affiliates/Corporate Disclosure Statement, [2] Clerks Notice of Judge Assignment, [10] Notice of Ninety Days Expiring upon Defendants via website posting

NOTICE of Voluntary Dismissal Without Prejudice, of Defendant Number 13 by Gucci America, Inc.

Text of Proposed Order

ORDER DISMISSING DEFENDANT NUMBER 13 re [23] Notice of Voluntary Dismissal filed by Gucci America, Inc. ORDERED that Defendant factorylux.shop (Defendant Number 13) is DISMISSED WITHOUT PREJUDICE. This case remains open and pending as to the remaining Defendants. Signed by Judge Rodney Smith on 1/8/2024. See attached document for full details.

PAPERLESS Minute Entry for proceedings held before Judge Rodney Smith: Motion Hearing held on 1/8/2024 re 6 Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order, Preliminary Injunction, and Order Restraining Transfer of Assets Against Defendants and Memorandum of Law in Support Thereof filed by Gucci America, Inc. Attorney Appearance(s): Stephen Michael Gaffigan, T. Raquel Wiborg-Rodriguez, Jason Stearns-nonparty attorney. Court Reporter: Ellen Rassie, 954-769-5448 / ellen_rassie@flsd.uscourts.gov.

NOTICE of Voluntary Dismissal Without Prejudice, of Defendant Number 4 by Gucci America, Inc.

Text of Proposed Order

ORDER GRANTING MOTION FOR ENTRY OF PRELIMINARY INJUNCTION re [6] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order, Preliminary Injunction, and Order Restraining Transfer of Assets Against Defendants and Memorandum of Law in Support Thereof by Gucci America, Inc. Signed by Judge Rodney Smith on 1/16/2024. See attached document for full details.

ORDER DISMISSING DEFENDANT NUMBER 4 re [26] Notice of Voluntary Dismissal filed by Gucci America, Inc. ORDERED that Defendant brandoff-store.com (Defendant Number 4) is DISMISSED WITHOUT PREJUDICE. This case remains open and pending as to the remaining Defendants. Signed by Judge Rodney Smith on 1/16/2024. See attached document for full details.

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

Exhibit 1 to Amended Complaint Certificates of Registration for the Gucci Trade

NOTICE of Voluntary Dismissal Without Prejudice, of Defendant Number 41 by Gucci America, Inc.

Text of Proposed Order

Plaintiff's NOTICE upon Defendants via Electronic Mail by Gucci America, Inc. re [27] Preliminary Injunction

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Gucci America, Inc. re [27] Preliminary Injunction, upon Defendants via Registrar

CERTIFICATE OF SERVICE by Gucci America, Inc. re [27] Preliminary Injunction, upon Defendants via website posting

SUMMONS (Affidavit) Returned Executed on [29] Amended Complaint/Amended Notice of Removal, [1] Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Gucci America, Inc. COCOSneakers.to served on 1/17/2024, response/answer due 2/7/2024; alishirts.com served on 1/17/2024, response/answer due 2/7/2024; borseluxe.com served on 1/17/2024, response/answer due 2/7/2024; braytime.com served on 1/17/2024, response/answer due 2/7/2024; chandeco.com served on 1/17/2024, response/answer due 2/7/2024; dengyun778 served on 1/17/2024, response/answer due 2/7/2024; discreetcouture.com served on 1/17/2024, response/answer due 2/7/2024; dreamluxuryshop.com served on 1/17/2024, response/answer due 2/7/2024; evelyngifts.com served on 1/17/2024, response/answer due 2/7/2024; evoss.shop served on 1/17/2024, response/answer due 2/7/2024; fashionprint.top served on 1/17/2024, response/answer due 2/7/2024; fdeew.shop served on 1/17/2024, response/answer due 2/7/2024; foumin.shop served on 1/17/2024, response/answer due 2/7/2024; gocacoka.com served on 1/17/2024, response/answer due 2/7/2024; guccieyewear-fr.com served on 1/17/2024, response/answer due 2/7/2024; hightopcustom.com served on 1/17/2024, response/answer due 2/7/2024; insunglass.com served on 1/17/2024, response/answer due 2/7/2024; jacquemusuk.shop served on 1/17/2024, response/answer due 2/7/2024; jacquemusus.shop served on 1/17/2024, response/answer due 2/7/2024; kananasu.com served on 1/17/2024, response/answer due 2/7/2024; kelvingift.com served on 1/17/2024, response/answer due 2/7/2024; kickside.com.br served on 1/17/2024, response/answer due 2/7/2024; kingofbag.com served on 1/17/2024, response/answer due 2/7/2024; kingshooz.com served on 1/17/2024, response/answer due 2/7/2024; luckyluxshop.com served on 1/17/2024, response/answer due 2/7/2024; luxuriousgoods.shop served on 1/17/2024, response/answer due 2/7/2024; luxury goods served on 1/17/2024, response/answer due 2/7/2024; luxury-bags-shoes served on 1/17/2024, response/answer due 2/7/2024; luxurydiscount1.com served on 1/17/2024, response/answer due 2/7/2024; lvgucci188.com served on 1/17/2024, response/answer due 2/7/2024; mousuni.shop served on 1/17/2024, response/answer due 2/7/2024; ohhhcasetie.com served on 1/17/2024, response/answer due 2/7/2024; perfectkickznews.ru served on 1/17/2024, response/answer due 2/7/2024; repgod.ru served on 1/17/2024, response/answer due 2/7/2024; sgvipsbags.com served on 1/17/2024, response/answer due 2/7/2024; shop.xieehop.ga served on 1/17/2024, response/answer due 2/7/2024; sneakerhomie.su served on 1/17/2024, response/answer due 2/7/2024; tycloset.com served on 1/17/2024, response/answer due 2/7/2024; vvs.lyc served on 1/17/2024, response/answer due 2/7/2024; wemadecases.com served on 1/17/2024, response/answer due 2/7/2024; womenbags.nl served on 1/17/2024, response/answer due 2/7/2024; xirance.top served on 1/17/2024, response/answer due 2/7/2024; yyaaho.com served on 1/17/2024, response/answer due 2/7/2024.

Affidavit of Service

Affidavit of Service

Affidavit of Service

Plaintiff's MOTION for Clerk's Entry of Default as to COCOSneakers.to, The Individuals, Business Entities, and Unincorporated Associations identified on Schedule A, alishirts.com, borseluxe.com, braytime.com, chandeco.com, dengyun778, discreetcouture.com, dreamluxuryshop.com, evelyngifts.com, evoss.shop, fashionprint.top, fdeew.shop, foumin.shop, gocacoka.com, guccieyewear-fr.com, hightopcustom.com, insunglass.com, jacquemusuk.shop, jacquemusus.shop, kananasu.com, kelvingift.com, kickside.com.br, kingofbag.com, kingshooz.com, luckyluxshop.com, luxuriousgoods.shop, luxury goods, luxury-bags-shoes, luxurydiscount1.com, lvgucci188.com, mousuni.shop, ohhhcasetie.com, perfectkickznews.ru, repgod.ru, sgvipsbags.com, shop.xieehop.ga, sneakerhomie.su, tycloset.com, vvs.lyc, wemadecases.com, womenbags.nl, xirance.top, yyaaho.com by Gucci America, Inc.

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

Text of Proposed Order

Clerk's Entry of Default as to Individuals, Business Entities, and Unincorporated Associations identified on Schedule A hereto, (collectively Defendants), - Motions Terminated: [35] Motion for Clerks Entry of Default Signed by DEPUTY CLERK on 3/25/2024.

ORDER DISMISSING DEFENDANT NUMBER 41. Dismissing Case as to Party(ies) usbestyle.com - case remains open. (Without Prejudice) Signed by Judge Rodney Smith on 3/26/2024. See attached document for full details.

Plaintiff's NOTICE of Identification of Additional Financial Accounts Used By Defendant Number 30 by Gucci America, Inc.

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 Gucci America, Inc.

Declaration of Sydney Kipen in Support Thereof

Supplement 1 to the Declaration of Sydney Kipen

Declaration of T. Raquel WIborg-Rodriguez in Support Thereof

Text of Proposed Order Granting Motion for Default Final Judgment

Text of Proposed Order Default Final Judgment and Permanent Injunction

Notice of Ninety Days Expiring by Gucci America, Inc. re [39] Plaintiff's MOTION for Default Judgment Against Defendants and Memorandum of Law in Support Thereof filed by Gucci America, Inc. (Wiborg-Rodriguez, T.)

ORDER granting 39 Motion for Default Judgment. Case is Closed. Signed by Judge Rodney Smith on 11/4/2024. See attached document for full details.

DEFAULT FINAL JUDGMENT and PERMANENT INJUNCTION in favor of Gucci America, Inc. against COCOSneakers.to, alishirts.com, borseluxe.com, braytime.com, chandeco.com, dengyun778, discreetcouture.com, dreamluxuryshop.com, evelyngifts.com, evoss.shop, fashionprint.top, fdeew.shop, foumin.shop, gocacoka.com, guccieyewear-fr.com, hightopcustom.com, insunglass.com, jacquemusuk.shop, jacquemusus.shop, kananasu.com, kelvingift.com, kickside.com.br, kingofbag.com, kingshooz.com, luckyluxshop.com, luxuriousgoods.shop, luxury goods, luxury-bags-shoes, luxurydiscount1.com, lvgucci188.com, mousuni.shop, ohhhcasetie.com, perfectkickznews.ru, repgod.ru, sgvipsbags.com, shop.xieehop.ga, sneakerhomie.su, tycloset.com, vvs.lyc, wemadecases.com, womenbags.nl, xirance.top, yyaaho.com. Signed by Judge Rodney Smith on 11/4/2024. 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) (ls)