2023-cv-61357

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. Filing fees $ 402.00 receipt number AFLSDC-16769400, filed by Louis Vuitton Malletier.

Civil Cover Sheet

Exhibit 1 to Complaint Certificates of Registration for the Louis Vuitton Trade

Clerks Notice of Judge Assignment to Judge William P. Dimitrouleas. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Panayotta Augustin-Birch 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 Louis Vuitton Malletier identifying Corporate Parent LVMH Moet Hennessy Louis Vuitton, SE for Louis Vuitton Malletier (Wiborg-Rodriguez, T.)

Plaintiff's MOTION to Seal per Local Rule 5.4 by Louis Vuitton Malletier.

Text of Proposed Order

ORDER GRANTING MOTION TO FILE UNDER SEAL granting [5] Motion to Seal. Signed by Judge William P. Dimitrouleas on 7/18/2023. See attached document for full details.

Order (Text entry; no document attached.)

Set/Reset Deadlines/Hearings per DE [10]. Preliminary Injunction Hearing set for 8/2/2023 01:10 PM in Fort Lauderdale Division before Judge William P. Dimitrouleas. (Text entry; no document attached.)

Order (Text entry; no document attached.)

Set/Reset Deadlines/Hearings per DE [10]. Preliminary Injunction Hearing set for 8/2/2023 01:10 PM in Fort Lauderdale Division before Judge William P. Dimitrouleas. (Text entry; no document attached.)

Order (Text entry; no document attached.)

ORDER REQUIRING COUNSEL TO MEET, FILE JOINT SCHEDULING REPORT AND JOINT DISCOVERY REPORT. Signed by Judge William P. Dimitrouleas on 7/19/2023. See attached document for full details.

Order (Text entry; no document attached.)

Plaintiff's Notice of Filing Bond. Seizure Bond BOND in the amount of $50,000.00 posted by Louis Vuitton Malletier Approved by Judge William P. Dimitrouleas

SYSTEM ENTRY - Docket Entry 14 [misc] restricted/sealed until further notice. (Text entry; no document attached.)

Plaintiff's MOTION to Unseal by Louis Vuitton Malletier.

Text of Proposed Order

AMENDED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants, filed by Louis Vuitton Malletier.

Exhibit 1 to Amended Complaint Certificates of Registration for the Louis Vuitt

ORDER GRANTING PLAINTIFF'S MOTION TO UNSEAL: The Clerk of the Court is hereby DIRECTED to unseal all docket entries in this case and return those portions of the Court file to the public records. Signed by Judge William P. Dimitrouleas on 7/27/2023. See attached document for full details.

NOTICE of Compliance re 18 Order to Unseal. All documents in this case have been unsealed per the order at DE#18.

Plaintiff's NOTICE by Louis Vuitton Malletier re [17] Amended Complaint/Amended Notice of Removal, [1] Complaint, [13] Order Requiring Joint Scheduling Report, [10] Order on Ex Parte Motion, upon Defendants via Electronic Mail

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Louis Vuitton Malletier re [14] Sealed Document, [9] Sealed Document, [1] Complaint, [6] Order on Motion to Seal, [5] Plaintiff's MOTION to Seal per Local Rule 5.4, [15] Bond, [10] Order on Ex Parte Motion, [2] Clerks Notice of Judge Assignment, [8] 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, [16] Plaintiff's MOTION to Unseal, [3] Form AO 120/121, [17] Amended Complaint/Amended Notice of Removal, [7] 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, [12] Sealed Document, [13] Order Requiring Joint Scheduling Report, [11] Order on Ex Parte Motion upon Defendants via website posting

Plaintiff's NOTICE by Louis Vuitton Malletier of E-Mail Inquiries Received from Certain Defendants

Exhibit 1 to the to the Notice of E-mail Inquiries

Plaintiff's NOTICE by Louis Vuitton Malletier of E-Mail Inquiry Received from Defendant Number 22 in Connection With Service of Temporary Restraining Order

(Exhibit 1 to the to the Notice of E-mail Inquiry) (Wiborg-Rodriguez, T.)

PAPERLESS Minute Entry for proceedings held before Judge William P. Dimitrouleas: Motion Hearing held on 8/2/2023 re 7 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 Louis Vuitton Malletier. Defendants failed to appear. The Court will enter an Order granting the preliminary injunction. Total time in court: 5 minutes. Attorney Appearance(s): T. Raquel Wiborg-Rodriguez, Court Reporter: Patricia Bailey-Entin, 305-523-5635 / Patricia_BaileyEntin@flsd.uscourts.gov. (rs00)

ORDER GRANTING APPLICATION FOR ENTRY OF PRELIMINARY INJUNCTION. Plaintiffs Application for Preliminary Injunction [DE 7] is GRANTED. Signed by Judge William P. Dimitrouleas on 8/2/2023. See attached document for full details.

ORDER TO SHOW CAUSE FOR LACK OF PROSECUTION. Plaintiff, on or before August 31, 2023, shall either move for Clerk's Entry of Default against Defendants or show cause why Plaintiff's claims should not be dismissed for a lack of prosecution. (Show Cause Response due by 8/31/2023). Signed by Judge William P. Dimitrouleas on 8/24/2023. See attached document for full details.

SUMMONS (Affidavit) Returned Executed on [1] Complaint, [17] Amended Complaint/Amended Notice of Removal, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Louis Vuitton Malletier. 711luxury.studio served on 8/1/2023, response/answer due 8/22/2023; 711top.com served on 8/1/2023, response/answer due 8/22/2023; 711topstudio.com served on 8/1/2023, response/answer due 8/22/2023; Aplan served on 8/1/2023, response/answer due 8/22/2023; adoraluxury.com served on 8/1/2023, response/answer due 8/22/2023; anemone-ve.com served on 8/1/2023, response/answer due 8/22/2023; bagmkt.com served on 8/1/2023, response/answer due 8/22/2023; bagnow.shop served on 8/1/2023, response/answer due 8/22/2023; bagstree.shop served on 8/1/2023, response/answer due 8/22/2023; chclothes.com served on 8/1/2023, response/answer due 8/22/2023; cheap.uaonlines.com served on 8/1/2023, response/answer due 8/22/2023; classicshop.life served on 8/1/2023, response/answer due 8/22/2023; designbags.cn served on 8/1/2023, response/answer due 8/22/2023; dolabuyclub.com.co served on 8/1/2023, response/answer due 8/22/2023; eliteclutches.com served on 8/1/2023, response/answer due 8/22/2023; fashenn.store served on 8/1/2023, response/answer due 8/22/2023; fashionbag668.com served on 8/1/2023, response/answer due 8/22/2023; fashionmeedusaa.com served on 8/1/2023, response/answer due 8/22/2023; feekzfoot.life served on 8/1/2023, response/answer due 8/22/2023; fiawatch.com served on 8/1/2023, response/answer due 8/22/2023; glamifiedcosmetics.com served on 8/1/2023, response/answer due 8/22/2023; justinbie.com served on 8/1/2023, response/answer due 8/22/2023; lobsreu.shop served on 8/1/2023, response/answer due 8/22/2023; lopiex.com served on 8/1/2023, response/answer due 8/22/2023; love.handbags-specials.top served on 8/1/2023, response/answer due 8/22/2023; lovecrossroads.com served on 8/1/2023, response/answer due 8/22/2023; luxurydeal.club served on 8/1/2023, response/answer due 8/22/2023; luxurylvcuu.com served on 8/1/2023, response/answer due 8/22/2023; luxurysellertop.com served on 8/1/2023, response/answer due 8/22/2023; luxurysfactory.com served on 8/1/2023, response/answer due 8/22/2023; lvbages.shop served on 8/1/2023, response/answer due 8/22/2023; lvbagsshop.com served on 8/1/2023, response/answer due 8/22/2023; lvluxurybags.shop served on 8/1/2023, response/answer due 8/22/2023; lvluxuryhandbag.com served on 8/1/2023, response/answer due 8/22/2023; lvoutlets.us served on 8/1/2023, response/answer due 8/22/2023; lvxbags.shop served on 8/1/2023, response/answer due 8/22/2023; meedusabag.com served on 8/1/2023, response/answer due 8/22/2023; modermore.com served on 8/1/2023, response/answer due 8/22/2023; namaaktassen.de served on 8/1/2023, response/answer due 8/22/2023; omgow23.vip served on 8/1/2023, response/answer due 8/22/2023; polarstreets.com served on 8/1/2023, response/answer due 8/22/2023; roka-moka.com served on 8/1/2023, response/answer due 8/22/2023; sariu.shop served on 8/1/2023, response/answer due 8/22/2023; topranklv.com served on 8/1/2023, response/answer due 8/22/2023; topranktes.shop served on 8/1/2023, response/answer due 8/22/2023; tothatwatch.com served on 8/1/2023, response/answer due 8/22/2023; uaplg.co served on 8/1/2023, response/answer due 8/22/2023; uswatchesabc.com served on 8/1/2023, response/answer due 8/22/2023; vrtev.com served on 8/1/2023, response/answer due 8/22/2023; zabluxury.com served on 8/1/2023, response/answer due 8/22/2023.

Affidavit of Service

Affidavit of Service

Plaintiff's NOTICE by Louis Vuitton Malletier re 25 Preliminary Injunction upon Defendants via Electronic Mail

(Exhibit Certificate of Sevice)

CERTIFICATE OF SERVICE by Louis Vuitton Malletier re [25] Preliminary Injunction upon Defendants via website posting

Plaintiff's MOTION for Clerk's Entry of Default as to 711luxury.studio, 711top.com, 711topstudio.com, Aplan, The Individuals, Business Entities, and Unincorporated Associations identified on Schedule A, adoraluxury.com, anemone-ve.com, bagmkt.com, bagnow.shop, bagstree.shop, chclothes.com, cheap.uaonlines.com, classicshop.life, designbags.cn, dolabuyclub.com.co, eliteclutches.com, fashenn.store, fashionbag668.com, fashionmeedusaa.com, feekzfoot.life, fiawatch.com, glamifiedcosmetics.com, justinbie.com, lobsreu.shop, lopiex.com, love.handbags-specials.top, lovecrossroads.com, luxurydeal.club, luxurylvcuu.com, luxurysellertop.com, luxurysfactory.com, lvbages.shop, lvbagsshop.com, lvluxurybags.shop, lvluxuryhandbag.com, lvoutlets.us, lvxbags.shop, meedusabag.com, modermore.com, namaaktassen.de, omgow23.vip, polarstreets.com, roka-moka.com, sariu.shop, topranklv.com, topranktes.shop, tothatwatch.com, uaplg.co, uswatchesabc.com, vrtev.com, zabluxury.com by Louis Vuitton Malletier.

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" 711luxury.studio - Motions Terminated: 30 Motion for Clerks Entry of Default Signed by DEPUTY CLERK on 8/25/2023.

CLERK'S NOTICE re 31 Clerk's Entry/Non-Entry of Default

Order To Show Cause For Lack Of Prosecution re 1 COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF, 17 AMENDED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF. Plaintiff, on or before September 13, 2023, shall either move for default judgment against Defendants or show cause why it has not done so. Signed by Judge William P. Dimitrouleas on 9/6/2023. See attached document for full details.

Plaintiff's NOTICE by Louis Vuitton Malletier of Additional Aliases for Defendant Numbers 8, 9, 10, 12, and 36, and Additional Financial Accounts Used by Various Defendants

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 MOTION for Default Judgment Against Defendants and Memorandum of Law in Support Thereof by Louis Vuitton Malletier.

Declaration of Hadrien Huet in Support Thereof

Exhibit 1 to the Declaration of Hadrien Huet

Declaration of T. Raquel WIborg-Rodriguez in Support Thereof

Text of Proposed Order Granting Motion for Final Default Judgment

(Text of Proposed Order Final Default Judgment and Permanent Injunction)(Wiborg-Rodriguez, T.)

Order To Show Cause Why Court Should Not Grant Motion For Final Default Judgment. On or before September 27, 2023, Defendants shall respond to this Order to Show Cause, showing why this Motion should not be granted.Failure to respond shall result in the Court granting Plaintiffs Motion DE 35. Signed by Judge William P. Dimitrouleas on 9/13/2023. See attached document for full details.

CERTIFICATE OF SERVICE by Louis Vuitton Malletier re [36] Order to Show Cause, upon Defendants via Electronic Mail and via Website Posting

Order Granting [35] Motion For Final Default Judgment. Signed by Judge William P. Dimitrouleas on 9/28/2023. See attached document for full details.

Final Default JUDGMENT in favor of Louis Vuitton Malletier against 711luxury.studio, 711top.com, 711topstudio.com, Aplan, The Individuals, Business Entities, and Unincorporated Associations identified on Schedule A, adoraluxury.com, anemone-ve.com, bagmkt.com, bagnow.shop, bagstree.shop, chclothes.com, cheap.uaonlines.com, classicshop.life, designbags.cn, dolabuyclub.com.co, eliteclutches.com, fashenn.store, fashionbag668.com, fashionmeedusaa.com, feekzfoot.life, fiawatch.com, glamifiedcosmetics.com, justinbie.com, lobsreu.shop, lopiex.com, love.handbags-specials.top, lovecrossroads.com, luxurydeal.club, luxurylvcuu.com, luxurysellertop.com, luxurysfactory.com, lvbages.shop, lvbagsshop.com, lvluxurybags.shop, lvluxuryhandbag.com, lvoutlets.us, lvxbags.shop, meedusabag.com, modermore.com, namaaktassen.de, omgow23.vip, polarstreets.com, roka-moka.com, sariu.shop, topranklv.com, topranktes.shop, tothatwatch.com, uaplg.co, uswatchesabc.com, vrtev.com, zabluxury.com. Closing Case. Signed by Judge William P. Dimitrouleas on 9/28/2023. See attached document for full details.

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

Final Judgment