2023-cv-61701

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. Filing fees $ 402.00 receipt number AFLSDC-16893303, filed by LUXOTTICA GROUP S.p.A., COSTA DEL MAR, INC., OAKLEY, INC.

Civil Cover Sheet

Exhibit 1 to Complaint Certificates of Registration for the Ray-Ban Trademarks

Exhibit 2 to Complaint Certificates of Registration for the Oakley Trademarks

Exhibit 3 to Complaint Certificates of Registration for the Costa Trademarks

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

Corporate Disclosure Statement by COSTA DEL MAR, INC., LUXOTTICA GROUP S.p.A., OAKLEY, INC. identifying Corporate Parent FGX International, Inc. for COSTA DEL MAR, INC.; Corporate Parent EssilorLuxottica S.A. for LUXOTTICA GROUP S.p.A. (Wiborg-Rodriguez, T.)

Plaintiff's MOTION to Seal per Local Rule 5.4 by COSTA DEL MAR, INC., LUXOTTICA GROUP S.p.A., OAKLEY, INC.

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.

NOTICE TO PARTIES IN FLSA CASES. Signed by Judge William P. Dimitrouleas on 9/6/2023. See attached document for full details.

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.

Order (Text entry; no document attached.)

Set/Reset Deadlines/Hearings per De [12]. Preliminary Injunction Hearing set for 10/6/2023 10:40 AM 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 [12]. Preliminary Injunction Hearing set for 10/6/2023 10:40 AM in Fort Lauderdale Division before Judge William P. Dimitrouleas. (Text entry; no document attached.)

Order (Text entry; no document attached.)

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

Set/Reset Deadlines/Hearings per De 12. Preliminary Injunction Hearing set for 10/6/2023 10:40 AM in Fort Lauderdale Division before Judge William P. Dimitrouleas. (Text entry; no document attached.)

SYSTEM ENTRY - Docket Entry 13 [order] restricted/sealed until further notice. (Text entry; no document attached.)

Order (Text entry; no document attached.)

Plaintiffs' Notice of Filing Seizure Bond: in the amount of $25,000.00 posted by COSTA DEL MAR, INC., LUXOTTICA GROUP S.p.A., OAKLEY, INC. Approved by Judge William P. Dimitrouleas

SYSTEM ENTRY - Docket Entry 14 [misc] restricted/sealed until further notice. (1336528) (Text entry; no document attached.)

SYSTEM ENTRY - Docket Entry 15 [misc] restricted/sealed until further notice. (Text entry; no document attached.)

Plaintiff's MOTION To Unseal by COSTA DEL MAR, INC., LUXOTTICA GROUP S.p.A., OAKLEY, INC.

Text of Proposed Order

ORDER granting [17] Motion to Unseal Case. 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 9/20/2023. See attached document for full details.

NOTICE of Compliance re 18 Order on Motion to Unseal Case. (All docket entries unsealed)

AMENDED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants, filed by LUXOTTICA GROUP S.p.A., COSTA DEL MAR, INC., OAKLEY, INC.

Exhibit 1 to Amended Complaint Certificates of Registration for the Ray-Ban Tra

Exhibit 2 to Amended Complaint Certificates of Registration for the Oakley Trad

Exhibit 3 to Amended Complaint Certificates of Registration for the Costa Trade

NOTICE by COSTA DEL MAR, INC., LUXOTTICA GROUP S.p.A., OAKLEY, INC. of E-mail Inquiries Received from Certain Defendants in Connection with Asset Restraint and Service

Exhibit 1 to the Notice of E-Mail Inquiries

Plaintiff's NOTICE by COSTA DEL MAR, INC., LUXOTTICA GROUP S.p.A., OAKLEY, INC. re [8] Order Requiring Joint Scheduling Report, [12] Order on Ex Parte Motion, [1] Complaint, upon Defendants via Electronic Mail

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by COSTA DEL MAR, INC., LUXOTTICA GROUP S.p.A., OAKLEY, INC. re [18] Order on Motion to Unseal Case, [5] Plaintiff's MOTION to Seal per Local Rule 5.4, [7] Notice of Court Practice/to Appear/Other, [11] Sealed Document, [16] Bond, [6] Order on Motion to Seal, [10] 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, [19] Notice of Compliance, [4] Certificate of Other Affiliates/Corporate Disclosure Statement, [8] Order Requiring Joint Scheduling Report, [12] Order on Ex Parte Motion, [13] Order on Ex Parte Motion, [9] 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, [17] Motion to Unseal Case, [1] Complaint, [2] Clerks Notice of Judge Assignment, [14] Sealed Document upon Defendants via website posting

SUMMONS (Affidavit) Returned Executed on [20] Amended Complaint/Amended Notice of Removal, [1] Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by OAKLEY, INC., LUXOTTICA GROUP S.p.A., COSTA DEL MAR, INC. Bage Garment Factory served on 9/26/2023, response/answer due 10/17/2023; Baibian Glasses served on 9/26/2023, response/answer due 10/17/2023; Because of U served on 9/26/2023, response/answer due 10/17/2023; Better me served on 9/26/2023, response/answer due 10/17/2023; Big Bull Ge served on 9/26/2023, response/answer due 10/17/2023; Brother fashion two served on 9/26/2023, response/answer due 10/17/2023; CFD served on 9/26/2023, response/answer due 10/17/2023; Chaolong Mens Clothinghing served on 9/26/2023, response/answer due 10/17/2023; EPAY served on 9/26/2023, response/answer due 10/17/2023; FarPeak served on 9/26/2023, response/answer due 10/17/2023; Fashion Elements served on 9/26/2023, response/answer due 10/17/2023; Fashions served on 9/26/2023, response/answer due 10/17/2023; GAEIVOL sports outdoors served on 9/26/2023, response/answer due 10/17/2023; GMS served on 9/26/2023, response/answer due 10/17/2023; HEIMANANZHUANGDIAN served on 9/26/2023, response/answer due 10/17/2023; Hall Style Man served on 9/26/2023, response/answer due 10/17/2023; HappyHub served on 9/26/2023, response/answer due 10/17/2023; HelloGO served on 9/26/2023, response/answer due 10/17/2023; Hotmaxx served on 9/26/2023, response/answer due 10/17/2023; Huawu served on 9/26/2023, response/answer due 10/17/2023; Langzai Selection served on 9/26/2023, response/answer due 10/17/2023; Magers served on 9/26/2023, response/answer due 10/17/2023; Meng Meng style museum served on 9/26/2023, response/answer due 10/17/2023; Mr Closet served on 9/26/2023, response/answer due 10/17/2023; NOMAD served on 9/26/2023, response/answer due 10/17/2023; Penda served on 9/26/2023, response/answer due 10/17/2023; Potamoes served on 9/26/2023, response/answer due 10/17/2023; Reverse served on 9/26/2023, response/answer due 10/17/2023; Rhaegal served on 9/26/2023, response/answer due 10/17/2023; The Cool Boy served on 9/26/2023, response/answer due 10/17/2023; Vannida served on 9/26/2023, response/answer due 10/17/2023; WANGLIUCONG served on 9/26/2023, response/answer due 10/17/2023; WYHTE served on 9/26/2023, response/answer due 10/17/2023; WYTHE served on 9/26/2023, response/answer due 10/17/2023; Wale served on 9/26/2023, response/answer due 10/17/2023; Window on the World served on 9/26/2023, response/answer due 10/17/2023; ZEBRAS served on 9/26/2023, response/answer due 10/17/2023; blueeyewhales served on 9/26/2023, response/answer due 10/17/2023; duo la served on 9/26/2023, response/answer due 10/17/2023.

Affidavit of Service

Affidavit of Service

PAPERLESS Minute Entry for proceedings held before Judge William P. Dimitrouleas: Motion Hearing held on 10/6/2023 re 9 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 OAKLEY, INC., COSTA DEL MAR, INC., LUXOTTICA GROUP S.p.A. Defendants failed to appear. The 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. (rs00)

ORDER GRANTING APPLICATION FOR ENTRY OF PRELIMINARY INJUNCTION. Signed by Judge William P. Dimitrouleas on 10/6/2023. See attached document for full details.

Plaintiff's MOTION for Discovery for Order Authorizing Plaintiffs to Initiate Discovery by COSTA DEL MAR, INC., LUXOTTICA GROUP S.p.A., OAKLEY, INC. Responses due by 10/26/2023

Declaration of T. Raquel Wiborg-Rodriguez in Support Thereof

Text of Proposed Order

ORDER granting [27] Plaintiff's Motion to Initiate Discovery. Signed by Judge William P. Dimitrouleas on 10/13/2023. See attached document for full details.

ORDER TO SHOW CAUSE FOR LACK OF PROSECUTION. Plaintiffs, on or before November 1, 2023, shall either move for Clerk's Entry of Default against Defendants or show cause why Plaintiffs claims against Defendants should not be dismissed for a lack of prosecution. Show Cause Response due by 11/1/2023. Signed by Judge William P. Dimitrouleas on 10/25/2023. See attached document for full details.

Plaintiff's MOTION for Extension of Time to Move for Clerk's Entry of Default re [29] Order to Show Cause, by COSTA DEL MAR, INC., LUXOTTICA GROUP S.p.A., OAKLEY, INC. Responses due by 11/13/2023

Declaration of T. Raquel Wiborg-Rodriguez in Support Thereof

Text of Proposed Order

ORDER GRANTING MOTION FOR EXTENSION OF TIME TO MOVE FOR CLERK'S ENTRY OF DEFAULT. ORDER granting [30] Motion for Extension of Time. Plaintiffs shall move for Clerk's Entry of Default on or before December 1, 2023. Signed by Judge William P. Dimitrouleas on 10/30/2023. See attached document for full details.

Plaintiff's MOTION for Protective Order by COSTA DEL MAR, INC., LUXOTTICA GROUP S.p.A., OAKLEY, INC.

Text of Proposed Order

ORDER REFERRING MOTION AND DISCOVERY. ORDER REFERRING [32] Plaintiff's MOTION for Protective Order filed by OAKLEY, INC., COSTA DEL MAR, INC., LUXOTTICA GROUP S.p.A., ORDER REFERRING CASE to Magistrate Judge the Motion [DE 32] and all discovery in the above-captioned cause is referred to United States Magistrate Judge Panayotta Augustin-Birch for appropriate disposition of all pretrial discovery motions, and all motions that relate directly to these motions, such as motions for extension of time, motions for reconsideration, motions for sanctions, and motions for mental or physical examinations. Motions referred to Judge Panayotta D Augustin-Birch. Signed by Judge William P. Dimitrouleas on 11/15/2023. See attached document for full details.

ORDER granting [32] Motion for Confidentiality Order. Signed by US Magistrate Judge Panayotta D Augustin-Birch on 11/17/2023. See attached document for full details.

Exhibit Stipulated Protective Order

ORDER SETTING DISCOVERY PROCEDURES. Signed by US Magistrate Judge Panayotta D Augustin-Birch on 11/17/2023. See attached document for full details.

NOTICE of Attorney Appearance by Jeffrey W. Gutchess on behalf of HappyHub, NOMAD, WYHTE, WYTHE. Attorney Jeffrey W. Gutchess added to party HappyHub(pty:dft), Attorney Jeffrey W. Gutchess added to party NOMAD(pty:dft), Attorney Jeffrey W. Gutchess added to party WYHTE(pty:dft), Attorney Jeffrey W. Gutchess added to party WYTHE(pty:dft).

Unopposed MOTION for Extension of Time to File Response/Reply/Answer as to [1] Complaint, by HappyHub, NOMAD, WYHTE, WYTHE.

Text of Proposed Order

ORDER GRANTING [37] Motion for Extension of Time to File Response/Answer to a Complaint or Other Case Initiating Document HappyHub. Response/Answer due 1/2/2024; NOMAD. Response/Answer due 1/2/2024; WYHTE. Response/Answer due 1/2/2024; WYTHE. Defendants 18, 27, 37, and 38 shall respond to the Complaint on or before January 2, 2024. Response/Answer due 1/2/2024. Signed by Judge William P. Dimitrouleas on 11/30/2023. See attached document for full details.

Plaintiff's MOTION for Clerk's Entry of Default as to Bage Garment Factory, Baibian Glasses, Because of U, Better me, Big Bull Ge, Brother fashion two, CFD, Chaolong Mens Clothinghing, EPAY, FarPeak, Fashion Elements, Fashions, GAEIVOL sports outdoors, GMS, HEIMANANZHUANGDIAN, Hall Style Man, HelloGO, Hotmaxx, Huawu, Langzai Selection, Magers, Meng Meng style museum, Mr Closet, Penda, Potamoes, Reverse, Rhaegal, The Cool Boy, The Individuals, Business Entities And Unincorporated Associations Identified On Schedule A, Vannida, WANGLIUCONG, Wale, Window on the World, ZEBRAS, blueeyewhales, duo la by OAKLEY, INC., LUXOTTICA GROUP S.p.A., COSTA DEL MAR, INC.

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

Text of Proposed Order

Plaintiff's NOTICE by COSTA DEL MAR, INC., LUXOTTICA GROUP S.p.A., OAKLEY, INC. re [26] Preliminary Injunction upon Defendants via Electronic Mail

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by COSTA DEL MAR, INC., LUXOTTICA GROUP S.p.A., OAKLEY, INC. re [26] Preliminary Injunction upon Defendants via website posting

Clerk's Entry of Default as to The Individuals, Business Entities And Unincorporated Associations Identified On Schedule A, - Motions Terminated: 39 Motion for Clerks Entry of Default, Signed by DEPUTY CLERK on 12/1/2023.

ORDER TO SHOW CAUSE FOR LACK OF PROSECUTION. Plaintiffs, on or before December 19, 2023, shall either move for default judgment against Defendants or show cause why they have not done so; and A failure to comply with this Order may result in immediate dismissal of this casewithout prejudice. Show Cause Response due by 12/19/2023. Signed by Judge William P. Dimitrouleas on 12/12/2023. See attached document for full details.

Plaintiff's MOTION for Extension of Time to Move for Default Judgment re [43] Order to Show Cause, by COSTA DEL MAR, INC., LUXOTTICA GROUP S.p.A., OAKLEY, INC. Responses due by 12/28/2023

Declaration of T. Raquel Wiborg-Rodriguez in Support Thereof

Text of Proposed Order

ORDER granting [44] Motion for Extension of Time to Move for Default Judgment. Signed by Judge William P. Dimitrouleas on 12/15/2023. See attached document for full details.

Defendant No. 18, 27, 37, and 38s ANSWER and Affirmative Defenses to Amended Complaint by HappyHub, NOMAD, WYHTE, WYTHE.

Plaintiff's NOTICE of Identification of Additional Alias and Additional Financial Account Used by Defendant Number 5 by COSTA DEL MAR, INC., LUXOTTICA GROUP S.p.A., OAKLEY, INC.

Declaration of Stephen M. Gaffigan in Support Thereof

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 COSTA DEL MAR, INC., LUXOTTICA GROUP S.p.A., OAKLEY, INC.

Declaration of Jason Groppe in Support Thereof

Exhibit 1 to the Declaration of Jason Groppe

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

ORDER TO SHOW CAUSE WHY THE COURT SHOULD NOT GRANT MOTION FOR FINAL DEFAULT JUDGMENT. Defendants shall show cause or before February 1, 2024 why Plaintiffs' Motion for Entry of Final Default Judgment Against Defendants [DE [48]] should not be granted. Show Cause Response due by 2/1/2024. Signed by Judge William P. Dimitrouleas on 1/18/2024. See attached document for full details.

NOTICE of Attorney Appearance by David P. Reiner, II on behalf of GAEIVOL sports outdoors. Attorney David P. Reiner, II added to party GAEIVOL sports outdoors(pty:dft).

ORDER GRANTING MOTION FOR FINAL DEFAULT JUDGMENT. ORDER granting [48] Motion for Default Judgment. In accordance with Federal Rule of Civil Procedure 58, a separate final judgment will be entered. Signed by Judge William P. Dimitrouleas on 2/2/2024. See attached document for full details.

FINAL DEFAULT JUDGMENT AND PERMANENT INJUNCTION. Accordingly, it is ORDERED AND ADJUDGED that Final Default Judgment is hereby entered in favor of Plaintiffs, Luxottica Group S.p.A., Oakley, Inc., and Costa Del Mar, Inc. (collectively Plaintiffs), and against Defendants, the Individuals, Business Entities, and Unincorporated Associations identified on Schedule A hereto (collectively Defendants). This case remains open as to Defendant Number 18, 27, 37 and 38 ONLY, until further Order of the Court. Signed by Judge William P. Dimitrouleas on 2/2/2024. See attached document for full details.

ANSWER and Affirmative Defenses to Amended Complaint by GAEIVOL sports outdoors.

Unopposed MOTION to Set Aside [52] Default Judgment, [51] Order on Motion for Default Judgment, by GAEIVOL sports outdoors.

Text of Proposed Order

Joint SCHEDULING REPORT - Rule 26(f) by COSTA DEL MAR, INC., LUXOTTICA GROUP S.p.A., OAKLEY, INC.

Text of Proposed Order

ORDER VACATING JUDGMENT AS TO CERTAIN DEFENDANT. ORDER granting [54] Motion to Set Aside. The Clerks Entry of Default [DE 42] is hereby VACATED as to Defendant No. 15 (GAEIVOL sports outdoors) only. The Courts entry of Final Default Judgment [DE 52] is hereby VACATED as to Defendant No. 15 (GAEIVOL sports outdoors) only. Signed by Judge William P. Dimitrouleas on 2/6/2024. See attached document for full details.

ORDER SETTING TRIAL DATE & DISCOVERY DEADLINES, REFERRING CASE TO MEDIATION & REFERRING DISCOVERY MOTIONS TO UNITED STATES MAGISTRATE JUDGE. SCHEDULING ORDER: (Jury Trial set for 4/21/2025 in Fort Lauderdale Division before Judge William P. Dimitrouleas., Calendar Call set for 4/18/2025 10:00 AM in Fort Lauderdale Division before Judge William P. Dimitrouleas.), ORDER REFERRING CASE to Mediation., ORDER REFERRING CASE to Magistrate Judge Judge Augustin-Birch for appropriate disposition of all pretrial discovery motions, and all motions that relate directly to these motions, such as motions for extension of time, motions for reconsideration, motions for sanctions, and motions for mental or physical examinations. Signed by Judge William P. Dimitrouleas on 2/7/2024. See attached document for full details. (amb) Pattern Jury Instruction Builder - To access the latest, up to date changes to the 11th Circuit Pattern Jury Instructions go to https://pji.ca11.uscourts.gov or click here.

Joint NOTICE of Mediator Selection. Selected/Added Mark Stein as Mediator.

NOTICE of Settlement with Defendant Number 15 by COSTA DEL MAR, INC., LUXOTTICA GROUP S.p.A., OAKLEY, INC.

Joint MOTION to Approve Consent Judgment (Responses due by 5/9/2024.), MOTION for Permanent Injunction as to Defendant Number 15 by COSTA DEL MAR, INC., LUXOTTICA GROUP S.p.A., OAKLEY, INC.

Exhibit 1 - Consent Final Judgment and Permanent Injunction as to Defendant Numb

CONSENT FINAL JUDGMENT AND PERMANENT INJUNCTION AS TO DEFENDANT NUMBER 15. Plaintiffs' Motion, [DE [60]], is GRANTED. Final Judgment is entered in favor of Plaintiffs and against Defendant Number 15. Motions terminated: [60] Joint MOTION to Approve Consent Judgment MOTION for Permanent Injunction as to Defendant Number 15 filed by OAKLEY, INC., COSTA DEL MAR, INC., LUXOTTICA GROUP S.p.A. Signed by Judge William P. Dimitrouleas on 4/25/2024. See attached document for full details.

NOTICE of Attorney Appearance by Shanshan Liang on behalf of HappyHub, NOMAD, WYHTE, WYTHE. Attorney Shanshan Liang added to party HappyHub(pty:dft), Attorney Shanshan Liang added to party NOMAD(pty:dft), Attorney Shanshan Liang added to party WYHTE(pty:dft), Attorney Shanshan Liang added to party WYTHE(pty:dft).

STIPULATED MOTION for Substitution of Counsel. Substituting Shanshan Liang for Jeffrey W. Gutchess by HappyHub, NOMAD, WYHTE, WYTHE. Responses due by 8/7/2024.

Text of Proposed Order

ORDER granting [63] Joint Stipulation For Substitution Of Counsel. Attorney Shanshan Liang representing HappyHub (Defendant) and NOMAD (Defendant) and WYHTE (Defendant); and WYTHE (Defendant); terminated. Signed by Judge William P. Dimitrouleas on 7/25/2024. See attached document for full details.

Attorney Jeffrey W. Gutchess representing HappyHub (Defendant) and NOMAD (Defendant) and WYHTE (Defendant); and WYTHE (Defendant); terminated. Attorney Shanshan Liang is the attorney of record. (Text entry; no document attached.)

FINAL MEDIATION REPORT by Mediator Mark Stein. Disposition: Settled in full. Mediation held/partially held via video-conference. Filed by Mark Stein.

ORDER TO SHOW CAUSE. That no later than August 28, 2024, the parties shall either file appropriate dismissal documents or show cause why they have not been filed. Show Cause Response due by 8/28/2024. Signed by Judge William P. Dimitrouleas on 8/21/2024. See attached document for full details.

Joint MOTION for Extension of Time to Submit Final Documents as to Defendant Numbers 18, 27, 37 & 38 re [66] Order to Show Cause, by COSTA DEL MAR, INC., LUXOTTICA GROUP S.p.A., OAKLEY, INC. Responses due by 9/10/2024.

Text of Proposed Order

ORDER GRANTING JOINT MOTION FOR EXTENSION OF TIME TO SUBMIT FINAL DOCUMENTS AS TO DEFENDANT NUMBERS 18, 27, 37 & 38. ORDER granting [67] Motion for Extension of Time. The Parties shall submit the final papers to finalize this action on or before September 4, 2024. Signed by Judge William P. Dimitrouleas on 8/27/2024. See attached document for full details.

Joint MOTION to Approve Consent Judgment (Responses due by 9/18/2024.), MOTION for Permanent Injunction as to Defendant Numbers 18 & 27 by COSTA DEL MAR, INC., LUXOTTICA GROUP S.p.A., OAKLEY, INC.

Exhibit 1 - Consent Judgment and Permanent Injunction as to Defendant Numbers 18

Joint MOTION to Approve Consent Judgment (Responses due by 9/18/2024.), MOTION for Permanent Injunction as to Defendant Numbers 37 & 38 by COSTA DEL MAR, INC., LUXOTTICA GROUP S.p.A., OAKLEY, INC.

1 - Consent Judgment and Permanent Injunction as to Defendant Numbers 37 & 38

CONSENT FINAL JUDGMENT AND PERMANENT INJUNCTION AS TO DEFENDANT NUMBERS 18 AND 27. ORDER granting [69] Motion to Approve Consent Judgment; granting [69] Motion for Permanent Injunction. Signed by Judge William P. Dimitrouleas on 9/5/2024. See attached document for full details.

CONSENT FINAL JUDGMENT AND PERMANENT INJUNCTION AS TO DEFENDANT NUMBERS 37 AND 38; ORDER CLOSING CASE. ORDER granting [70] Motion to Approve Consent Judgment; granting [70] Motion for Permanent Injunction. Closing Case. Motions Terminated: [70] Joint MOTION to Approve Consent Judgment MOTION for Permanent Injunction as to Defendant Numbers 37 & 38 filed by OAKLEY, INC., COSTA DEL MAR, INC., LUXOTTICA GROUP S.p.A. Signed by Judge William P. Dimitrouleas on 9/5/2024. See attached document for full details.

SATISFACTION OF JUDGMENT as to Defendant Number 26 by LUXOTTICA GROUP S.p.A., OAKLEY, INC., COSTA DEL MAR, INC. (Wiborg-Rodriguez, T.)