2023-cv-61685

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. Filing fees $ 402.00 receipt number AFLSDC-16885304, filed by Tiffany (NJ) LLC.

Civil Cover Sheet

Exhibit 1 to Complaint Certificates of Registration for the Tiffany Trademarks

Clerks Notice of Judge Assignment to Judge Robin L. Rosenberg and US Magistrate Judge Panayotta D Augustin-Birch. 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 with Trademark Registration

Plaintiff's Corporate Disclosure Statement by Tiffany (NJ) LLC identifying Corporate Parent Tiffany & Co., Corporate Parent LVMH Moet Hennessy Louis Vuitton SE, Corporate Parent Tiffany and Company, Other Affiliate Christian Dior SE for Tiffany (NJ) LLC

Plaintiff's MOTION to Seal per Local Rule 5.4 by Tiffany (NJ) LLC.

Text of Proposed Order Granting Motion to Seal

PAPERLESS ORDER granting [5] Motion to Seal insofar as the filings shall remain under seal until further order of the Court. Signed by Judge Robin L. Rosenberg

Order (Text entry; no document attached.)

ORDER GRANTING PLAINTIFF'S [7] MOTION TO AUTHORIZE ALTERNATE SERVICE OF PROCESS. Signed by Judge Robin L. Rosenberg on 9/19/2023. See attached document for full details.

Order (Text entry; no document attached.)

Seizure BOND in the amount of $10,000.00 posted by Tiffany (NJ) LLC received in Clerk's office in Fort Lauderdale, FL. Approved by DEPUTY CLERK on 9/20/2023.

Plaintiff's MOTION to Unseal by Tiffany (NJ) LLC.

Text of Proposed Order Granting Motion to Unseal

Plaintiff's MOTION to Extend Temporary Restraining Order Dated September 19, 2023 by Tiffany (NJ) LLC.

Text of Proposed Order Granting Motion to Extend Temporary Restraining Order

PAPERLESS ORDER granting 15 Motion to Unseal. The Clerk of Court is directed to UNSEAL all docket entries in this action and return those portions of the Court file to the public records. Signed by Judge Robin L. Rosenberg

NOTICE of Compliance re 17 Order on Motion to Unseal. All documents in this case have been unsealed per DE#17.

PAPERLESS ORDER. Pursuant to the Court's order granting a temporary restraining order at docket entry 9, the Defendants had until noon on October 2, 2023, to file any response to the Plaintiff's Motion for Preliminary Injunction. No response appears in the court file. Pursuant to Local Rule 7.1(c) and the Defendant's failure to file a response to the Motion for Preliminary Injunctive Relief, the Court GRANTS the Motion for Preliminary Injunctive Relief by default and CANCELS the hearing (set for October 4, 2023) on the matter. The Plaintiff is ORDERED to provide the Court with a proposed order in Microsoft Word format, at rosenberg@flsd.uscourts.gov, within two business days of the date of this Order, in light of the Court's granting of the Motion herein. The Plaintiff's Motion to Extend the Temporary Restraining Order 16 is DENIED AS MOOT. Signed by Judge Robin L. Rosenberg

AMENDED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants, filed by Tiffany (NJ) LLC.

Exhibit 1 to Amended Complaint Certificates of Registration for the Tiffany Tra

Plaintiff's NOTICE by Tiffany (NJ) LLC re [1] Complaint, [9] Sealed Order, Set/Reset Sealed Motion/R&R Deadlines and Hearings, upon Defendants via Electronic Mail

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Tiffany (NJ) LLC re [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, [12] Sealed Document, [10] Order, Terminate Motions, [1] Complaint, [9] Sealed Order, Set/Reset Sealed Motion/R&R Deadlines and Hearings, [8] Order on Motion to Seal, [16] Plaintiff's MOTION to Extend Temporary Restraining Order Dated September 19, 2023, [15] Plaintiff's MOTION to Unseal, [14] Bond, [5] Plaintiff's MOTION to Seal per Local Rule 5.4, [2] Clerks Notice of Judge Assignment, [11] Sealed Document, [3] Form AO 120/121, [4] Certificate of Other Affiliates/Corporate Disclosure Statement, [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 upon Defendants via website posting

NOTICE of Compliance by Tiffany (NJ) LLC re [19] Order on Motion for Miscellaneous Relief

ORDER GRANTING [6] PLAINTIFF'S MOTION FOR ENTRY OF PRELIMINARY INJUNCTION. Signed by Judge Robin L. Rosenberg on 10/4/2023. See attached document for full details.

Reset Deadlines Per DE#25 Status Report due by 11/1/2023. (Text entry; no document attached.)

PAPERLESS ORDER requiring the Plaintiff to inform the Court of the status of service, defaults, and any motion for default judgment in this case. The Plaintiff's status report is due by November 1, 2023. Signed by Judge Robin L. Rosenberg

Reset Deadlines Per DE#25 Status Report due by 11/1/2023. (Text entry; no document attached.)

Plaintiff's NOTICE by Tiffany (NJ) LLC re [19] Order on Motion for Miscellaneous Relief, upon Defendants via Electronic Mail

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Tiffany (NJ) LLC re [19] Order on Motion for Miscellaneous Relief, upon Defendants via website posting

SUMMONS (Affidavit) Returned Executed on [1] Complaint, [20] Amended Complaint/Amended Notice of Removal with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Tiffany (NJ) LLC. Gails Gold Jewelry Shop served on 10/2/2023, response/answer due 10/23/2023; Gzbags999 Store served on 10/2/2023, response/answer due 10/23/2023; allshoesbagsonline.com served on 10/2/2023, response/answer due 10/23/2023; blvckmart.net served on 10/2/2023, response/answer due 10/23/2023; bullsnkrs.com served on 10/2/2023, response/answer due 10/23/2023; dksneakers.net served on 10/2/2023, response/answer due 10/23/2023; enjoyraces.com served on 10/2/2023, response/answer due 10/23/2023; finde.store served on 10/2/2023, response/answer due 10/23/2023; getjewelrys.ru served on 10/2/2023, response/answer due 10/23/2023; hermere.com served on 10/2/2023, response/answer due 10/23/2023; jewerlyremate.com served on 10/2/2023, response/answer due 10/23/2023; kickswind.com.co served on 10/2/2023, response/answer due 10/23/2023; ldlee_shop served on 10/2/2023, response/answer due 10/23/2023; lvcase.com served on 10/2/2023, response/answer due 10/23/2023; monajewelery.com served on 10/2/2023, response/answer due 10/23/2023; raresneaker1 served on 10/2/2023, response/answer due 10/23/2023; sunhauls.com served on 10/2/2023, response/answer due 10/23/2023; the tote bag Store served on 10/2/2023, response/answer due 10/23/2023; wechatp.com served on 10/2/2023, response/answer due 10/23/2023; wixgifts.com served on 10/2/2023, response/answer due 10/23/2023; xrare3887 served on 10/2/2023, response/answer due 10/23/2023; zaformo.com served on 10/2/2023, response/answer due 10/23/2023; Luxury Discount Global served on 10/2/2023, response/answer due 10/23/2023.

Affidavit of Service

Affidavit of Service

Plaintiff's NOTICE by Tiffany (NJ) LLC re [24] Preliminary Injunction upon Defendants via Electronic Mail

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Tiffany (NJ) LLC re [24] Preliminary Injunction upon Defendants via website posting

Plaintiff's MOTION for Clerk's Entry of Default as to Gails Gold Jewelry Shop, Gzbags999 Store, The Individuals, Business Entities, and Unincorporated Associations Identified on Schedule A, allshoesbagsonline.com, blvckmart.net, bullsnkrs.com, dksneakers.net, enjoyraces.com, finde.store, getjewelrys.ru, hermere.com, jewerlyremate.com, kickswind.com.co, ldlee_shop, lvcase.com, monajewelery.com, raresneaker1, sunhauls.com, the tote bag Store, wechatp.com, wixgifts.com, xrare3887, zaformo.com, Luxury Discount Global by Tiffany (NJ) LLC.

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

Text of Proposed Order

CLERK'S DEFAULT ENTRY - Granting [31] Plaintiff's MOTION for Clerk's Entry of Default as to Gails Gold Jewelry Shop, Gzbags999 Store, The Individuals, Business Entities, and Unincorporated Associations Identified on Schedule A, allshoesbagsonline.com, blvckmart.net, bullsnk filed by Tiffany (NJ) LLC, Motions terminated: [31] Plaintiff's MOTION for Clerk's Entry of Default as to Gails Gold Jewelry Shop, Gzbags999 Store, The Individuals, Business Entities, and Unincorporated Associations Identified on Schedule A, allshoesbagsonline.com, blvckmart.net, bullsnk filed by Tiffany (NJ) LLC. Signed by DEPUTY CLERK on 10/31/2023. See attached document for full details.

Plaintiff's NOTICE by Tiffany (NJ) LLC re [25] Order, of Filing Status Report as to Service, Default, and Motion for Default Judgment

Exhibit Status Report Regarding Services

Plaintiff's MOTION for Default Judgment Against Defendants and Memorandum of Law in Support Thereof by Tiffany (NJ) LLC.

Declaration of Pilar Toro in Support Thereof

Exhibit 1 to the Declaration of Pilar Toro

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 [34] PLAINTIFF'S MOTION FOR ENTRY OF FINAL DEFAULT JUDGMENT. The Clerk of the Court shall CLOSE THIS CASE. Closing Case. Signed by Judge Robin L. Rosenberg on 11/9/2023. See attached document for full details.

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

Order

FINAL DEFAULT JUDGMENT AND PERMANENT INJUNCTION: In favor of Tiffany (NJ) LLC, and against Gails Gold Jewelry Shop, Gzbags999 Store, Luxury Discount Global, allshoesbagsonline.com, blvckmart.net, bullsnkrs.com, dksneakers.net, enjoyraces.com, finde.store, getjewelrys.ru, hermere.com, jewerlyremate.com, kickswind.com.co, ldlee_shop, lvcase.com, monajewelery.com, raresneaker1, sunhauls.com, the tote bag Store, wechatp.com, wixgifts.com, xrare3887, and zaformo.com. The Clerk of Court shall RELEASE the bond posted by Plaintiff in the amount of $10,000.00. The Clerk shall ADMINISTRATIVELY CLOSE the case. Signed by Judge Robin L. Rosenberg on 11/9/2023. See attached document for full details.