2023-cv-61010

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. Filing fees $ 402.00 receipt number AFLSDC-16652724, 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 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.

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 Rodney Smith on 6/9/2023. See attached document for full details.

Order (Text entry; no document attached.)

Seizure Bond in the amount of $10,000.00 posted by Chanel, Inc. Approved by Judge Rodney Smith.

Plaintiff's MOTION to Unseal by Chanel, Inc.

Text of Proposed Order Granting Motion to Unseal

Plaintiff's AMENDED COMPLAINT For Damages and Injunctive Relief against chanellike.com, chanccoco.com, chanclo.com, cococl.com, foreswatch.com, insunglass.com, owingwatch.com, filed by Chanel, Inc.

Exhibit to Amended Complaint Certificates of Registration for Chanel's Trad

ORDER granting [14] Motion to Unseal. Signed by Judge Rodney Smith on 6/15/2023. See attached document for full details.

NOTICE of Compliance re 16 Order on Motion for Miscellaneous Relief. (All docket entries unsealed)

Summons Issued as to chanccoco.com, chanclo.com, chanellike.com, cococl.com, foreswatch.com, insunglass.com, owingwatch.com.

Plaintiff's NOTICE by Chanel, Inc. re 15 Amended Complaint/Amended Notice of Removal, 1 Complaint, 12 Order on Ex Parte Motion, upon Defendants via Electronic Mail

(Exhibit Certificate of Sevice)

CERTIFICATE OF SERVICE by Chanel, Inc. re 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, 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, 1 Complaint, 4 Certificate of Other Affiliates/Corporate Disclosure Statement, 3 Form AO 120/121, 10 Sealed Document, 5 Plaintiff's MOTION to Seal per Local Rule 5.4, 16 Order on Motion for Miscellaneous Relief, 13 Bond, 15 Amended Complaint/Amended Notice of Removal, 14 Plaintiff's MOTION to Unseal, 8 Order on Motion to Seal, 11 Sealed Document, 2 Clerk's Notice of Judge Assignment, 9 Order on Ex Parte Motion, 12 Order on Ex Parte Motion, upon Defendants via website posting

SUMMONS (Affidavit) Returned Executed on 1 Complaint, 15 Amended Complaint/Amended Notice of Removal, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Chanel, Inc. chanccoco.com served on 6/20/2023, response/answer due 7/11/2023; chanclo.com served on 6/20/2023, response/answer due 7/11/2023; chanellike.com served on 6/20/2023, response/answer due 7/11/2023; cococl.com served on 6/20/2023, response/answer due 7/11/2023; foreswatch.com served on 6/20/2023, response/answer due 7/11/2023; insunglass.com served on 6/20/2023, response/answer due 7/11/2023; owingwatch.com served on 6/20/2023, response/answer due 7/11/2023.

Affidavit of Service

(Affidavit of Service)

PAPERLESS Minute Entry for proceedings held before Judge Rodney Smith: Miscellaneous Hearing held on 6/26/2023, 8:50-9am. After hearing from plaintiff's counsel, the Court found plaintiff met its burden for issuance of preliminary injunction Attorney Appearance(s): Virgilio Gigante, Court Reporter: Ellen Rassie, 954-769-5448 / ellen_rassie@flsd.uscourts.gov.

ORDER Granting 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 Chanel, Inc. Signed by Judge Rodney Smith on 6/26/2023. See attached document for full details.

Plaintiff's MOTION for Discovery for Order Authorizing Plaintiff to Initiate Discovery by Chanel, Inc. Responses due by 7/20/2023

Declaration of Stephen M. Gaffigan in Support Thereof

Text of Proposed Order Granting Plaintiff's Motion to Initiate Discovery

ORDER granting 24 Motion for Order Authorizing Plaintiff to Initiate Discovery. Signed by Judge Rodney Smith on 7/7/2023. See attached document for full details.

Plaintiff's NOTICE by Chanel, Inc. of Identification of Additional Aliases for Defendant Numbers 2, 4, and 6 and Additional PayPal Accounts Used By Defendant Numbers 2, 3, 4, and 6

Declaration of Kathleen Burns in Support Thereof

Exhibit 1 - Part 1 to the Declaration of Kathleen Burns

Exhibit 1 - Part 2 to the Declaration of Kathleen Burns

Plaintiff's NOTICE by Chanel, Inc. re [23] Order, upon Defendants via Electronic Mail

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Chanel, Inc. re [23] Order, upon Defendants via website posting

Plaintiff's MOTION for Clerk's Entry of Default as to The Individuals, Business Entities, and Unincorporated Associations, chanccoco.com, chanclo.com, chanellike.com, cococl.com, foreswatch.com, insunglass.com, owingwatch.com 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 The Individuals, Business Entities, and Unincorporated Associations identified on Schedule A hereto, (collectively Defendants) - Motions Terminated: 29 Motion for Clerks Entry of Default, Signed by DEPUTY CLERK on 7/13/2023.

Second NOTICE by Chanel, Inc. of Identification of Additional Aliases and PayPal Accounts Used By Defendant Numbers 1 and 6

Declaration of Kathleen Burns in Support Thereof

(Exhibit 1 to the Burns Declaration)

Third NOTICE by Chanel, Inc. of Identification of Additional Aliases and PayPal Accounts Used By Defendant Number 1

Declaration of Kathleen Burns in Support Thereof

(Exhibit 1 to the Burns Declaration)

STATUS REPORT by Chanel, Inc.

Plaintiff's MOTION for Protective Order by Chanel, Inc.

(Text of Proposed Order Granting Plaintiff's Motion for Protective Order)

ORDER granting [34] Motion for Protective Order. Signed by Judge Rodney Smith on 10/6/2023. See attached document for full details.

Plaintiff's NOTICE by Chanel, Inc. of Filing Fourth Notice of Identification of Additional Aliases and PayPal Accounts Used By Defendant Number 1

Declaration of Kathleen Burns In Support of Plaintiff's Fourth Notice of I

Exhibit 1 to Decl. of Kathleen Burns

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 Declaration of Elizabeth Han

Declaration of Stephen M. Gaffigan in Support Thereof

Text of Proposed Order Granting Motion for Final Default Judgment

Text of Proposed Order Final Default Judgment and Permanent Injunction

ORDER granting 37 Motion for Final Default Judgment. Signed by Judge Rodney Smith on 3/28/2024. See attached document for full details.

FINAL DEFAULT JUDGMENT AND PERMANENT INJUNCTION in favor of Chanel, Inc. against The Individuals, Business Entities, and Unincorporated Associations; in favor of Chanel, Inc. against chanccoco.com, chanclo.com, chanellike.com, cococl.com, foreswatch.com, insunglass.com; in favor of Chanel, Inc. against owingwatch.com, Signed by Judge Rodney Smith on 3/28/2024. See attached document for full details.

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

Civil Case Terminated. Closing Case. (per DE 39). (Text entry; no document attached.)

CERTIFICATE OF SERVICE by Chanel, Inc. re [39] Judgment, Permanent Injunction, [38] Order on Motion for Default Judgment upon Defendants via website posting

Plaintiff's NOTICE upon Defendants via Electronic Mail by Chanel, Inc. re [39] Judgment, Permanent Injunction, [38] Order on Motion for Default Judgment

Exhibit Certificate of Sevice