2023-cv-61700

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. Filing fees $ 402.00 receipt number AFLSDC-16893232, filed by Louis Vuitton Malletier.

Civil Cover Sheet

Exhibit 1 to Complaint - Certificates of Registration for the Louis Vuitton Trad

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 with Exhibits

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 5 Motion to Seal. Signed by Judge William P. Dimitrouleas on 9/6/2023. See attached document for full details.

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

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

SYSTEM ENTRY - Docket Entry 9 [misc] restricted/sealed until further notice. (1336528) (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 9/6/2023. See attached document for full details.

SYSTEM ENTRY - Docket Entry 11 [order] restricted/sealed until further notice. (Text entry; no document attached.)

SYSTEM ENTRY - Docket Entry 12 [order] restricted/sealed until further notice. (Text entry; no document attached.)

Order (Text entry; no document attached.)

Plaintiff's Notice of Filing Seizure Bond in the amount of $25,000.00 posted by Louis Vuitton Malletier Approved by Judge William P. Dimitrouleas.

Plaintiff's MOTION to Unseal by Louis Vuitton Malletier.

Text of Proposed Order

ORDER granting [15] Motion to Unseal Case. Signed by Judge William P. Dimitrouleas on 9/13/2023. See attached document for full details.

NOTICE of Compliance re 17 Order on Motion to Unseal Case. (All docket entries unsealed)

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 Vuitton Trademarks)

Plaintiff's NOTICE by Louis Vuitton Malletier re [1] Complaint, [10] Order Requiring Joint Scheduling Report, [11] Order on Ex Parte Motion, [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 upon Defendants via Electronic Mail

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Louis Vuitton Malletier re [1] Complaint, [15] Motion to Unseal Case, [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, [9] Sealed Document, [3] Form AO 120/121, [16] Bond, [4] Certificate of Other Affiliates/Corporate Disclosure Statement, [6] Order on Motion to Seal, [10] Order Requiring Joint Scheduling Report, [11] Order on Ex Parte Motion, [5] Plaintiff's MOTION to Seal per Local Rule 5.4, [12] Order on Ex Parte Motion, [13] Sealed Document, [2] Clerks Notice of Judge Assignment, [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 upon Defendants via website posting

SUMMONS (Affidavit) Returned Executed on [1] Complaint, [19] 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. 66se1.shop served on 9/18/2023, response/answer due 10/10/2023; Elizerberth Sindy served on 9/18/2023, response/answer due 10/10/2023; aaaluxury.shop served on 9/18/2023, response/answer due 10/10/2023; aolisbags.com served on 9/18/2023, response/answer due 10/10/2023; blacksheepsneaker.com served on 9/18/2023, response/answer due 10/10/2023; calmly.site served on 9/18/2023, response/answer due 10/10/2023; conveyoflove.com served on 9/18/2023, response/answer due 10/10/2023; ebarardbp.com served on 9/18/2023, response/answer due 10/10/2023; elegantbagss.com served on 9/18/2023, response/answer due 10/10/2023; fantaisbag.com served on 9/18/2023, response/answer due 10/10/2023; fashionmeedusa.com served on 9/18/2023, response/answer due 10/10/2023; ghwatches.top served on 9/18/2023, response/answer due 10/10/2023; glamsavings.shop served on 9/18/2023, response/answer due 10/10/2023; gwenjewelry.com served on 9/18/2023, response/answer due 10/10/2023; handbagvips.com served on 9/18/2023, response/answer due 10/10/2023; icas.buzz served on 9/18/2023, response/answer due 10/10/2023; izhbbdf.top served on 9/18/2023, response/answer due 10/10/2023; kocacoka.com served on 9/18/2023, response/answer due 10/10/2023; lkorxu.com served on 9/18/2023, response/answer due 10/10/2023; louis-vuitton-us.shop served on 9/18/2023, response/answer due 10/10/2023; lulubags.shop served on 9/18/2023, response/answer due 10/10/2023; luxbags.live served on 9/18/2023, response/answer due 10/10/2023; luxuriaworld.com served on 9/18/2023, response/answer due 10/10/2023; luxurymeedusa.com served on 9/18/2023, response/answer due 10/10/2023; lvservicecenter.shop served on 9/18/2023, response/answer due 10/10/2023; mariajewel.com served on 9/18/2023, response/answer due 10/10/2023; monicasneaker.org served on 9/18/2023, response/answer due 10/10/2023; omgbags.shop served on 9/18/2023, response/answer due 10/10/2023; onlinefashion.life served on 9/18/2023, response/answer due 10/10/2023; puggy.shop served on 9/18/2023, response/answer due 10/10/2023; sstn.shop served on 9/18/2023, response/answer due 10/10/2023; sunarise.store served on 9/18/2023, response/answer due 10/10/2023; suncofashion.com served on 9/18/2023, response/answer due 10/10/2023; sunglasses-vip.com served on 9/18/2023, response/answer due 10/10/2023; topmostbags.com served on 9/18/2023, response/answer due 10/10/2023; topranke.shop served on 9/18/2023, response/answer due 10/10/2023; toprankgod.com served on 9/18/2023, response/answer due 10/10/2023; toprankstores.com served on 9/18/2023, response/answer due 10/10/2023; udenshop.com served on 9/18/2023, response/answer due 10/10/2023; ustoprank.com served on 9/18/2023, response/answer due 10/10/2023; xyybags.shop served on 9/18/2023, response/answer due 10/10/2023; znbbags.shop served on 9/18/2023, response/answer due 10/10/2023; zzbbags.com served on 9/18/2023, response/answer due 10/10/2023.

Affidavit of Service

Affidavit of Service

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

Exhibit 1 to the Notice of E-mail Inquiries

PAPERLESS Minute Entry for proceedings held before Judge William P. Dimitrouleas: Motion Hearing held on 10/6/2023 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. No Defendants appeared. Court will enter proposed Order granting preliminary injunction. Total time in court: 5 minutes. Attorney Appearance(s): T. Raquel Wiborg-Rodriguez, Court Reporter: Karl Shires, 954-769-5496 / Karl_Shires@flsd.uscourts.gov.

ORDER granting [7] Ex Parte Motion. Signed by Judge William P. Dimitrouleas on 10/6/2023. See attached document for full details.

ORDER TO SHOW CAUSE FOR LACK OF PROSECUTION re [22] Summons Returned Executed, filed by Louis Vuitton Malletier. Show Cause Response due by 10/23/2023. Signed by Judge William P. Dimitrouleas on 10/16/2023. See attached document for full details.

Plaintiff's NOTICE by Louis Vuitton Malletier re [25] Order on Ex Parte Motion upon Defendants via Electronic Mail

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Louis Vuitton Malletier re [25] Order on Ex Parte Motion upon Defendants via website posting

Plaintiff's MOTION for Clerk's Entry of Default as to 66se1.shop, Elizerberth Sindy, The Individuals, Business Entities, and Unincorporated Associations identified on Schedule A, aaaluxury.shop, aolisbags.com, blacksheepsneaker.com, calmly.site, conveyoflove.com, ebarardbp.com, elegantbagss.com, fantaisbag.com, fashionmeedusa.com, ghwatches.top, glamsavings.shop, gwenjewelry.com, handbagvips.com, icas.buzz, izhbbdf.top, kocacoka.com, lkorxu.com, louis-vuitton-us.shop, lulubags.shop, luxbags.live, luxuriaworld.com, luxurymeedusa.com, lvservicecenter.shop, mariajewel.com, monicasneaker.org, omgbags.shop, onlinefashion.life, puggy.shop, sstn.shop, sunarise.store, suncofashion.com, sunglasses-vip.com, topmostbags.com, topranke.shop, toprankgod.com, toprankstores.com, udenshop.com, ustoprank.com, xyybags.shop, znbbags.shop, zzbbags.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, or Unincorporated Associations identified on Schedule "A" - Motions Terminated: [29] Motion for Clerks Entry of Default, Signed by DEPUTY CLERK on 10/19/2023.

ORDER TO SHOW CAUSE for Lack of Prosecution re [30] Clerk's Entry/Non-Entry of Default. Show Cause Response due by 11/10/2023. Signed by Judge William P. Dimitrouleas on 10/30/2023. See attached document for full details.

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 Plaintiffs Motion for Final Default Judgment

Text of Proposed Order Final Default Judgment and Permanent Injunction

ORDER TO SHOW CAUSE WHY COURT SHOULD NOT GRANT MOTION FOR FINAL DEFAULT JUDGMENT: re 32 Plaintiff's MOTION for Default Judgment Against Defendants and Memorandum of Law in Support Thereof filed by Louis Vuitton Malletier. Show Cause Response due by 11/15/2023. Signed by Judge William P. Dimitrouleas on 11/2/2023. See attached document for full details.

ORDER granting 32 Motion for Final Default Judgment. Signed by Judge William P. Dimitrouleas on 11/16/2023. See attached document for full details.

FINAL DEFAULT JUDGMENT AND PERMANENT INJUNCTION in favor of Louis Vuitton Malletier against The Individuals, Business Entities, and Unincorporated Associations identified on Schedule A, Closing Case. Signed by Judge William P. Dimitrouleas on 11/16/2023. See attached document for full details.

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

Plaintiff's NOTICE upon Defendants via Electronic Mail by Louis Vuitton Malletier re [34] Order on Motion for Default Judgment, [35] Judgment, Permanent Injunction

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Louis Vuitton Malletier re [34] Order on Motion for Default Judgment, [35] Judgment, Permanent Injunction, upon Defendants via website posting