2023-cv-61797

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. Filing fees $ 402.00 receipt number AFLSDC-16929853, 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 Raag Singhal. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Alicia O. Valle 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) (rbe)

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)

NOTICE OF COURT PRACTICE Unless otherwise specified by the Court, every motion, legal memorandum, brief, and otherwise shall: be double-spaced, in justified alignment, in 12-point font, using either Times New Roman or Arial typeface. This Notice does not supplant the requirements and provisions of Local Rule 7.1(c). The Court cautions parties against excessive use of footnotes. Multiple Plaintiffs or Defendants shall file joint motions (and responses to motions) with co-parties unless there are clear conflicts of position. If conflicts of position exist, parties shall explain the conflicts in their separate motions (and responses). Parties are encouraged to seek extensions of time in a timely fashion. "A motion for extension of time is not self-executing; no motion is, unless expressly provided for by the applicable rule. Yet, by filing these motions on or near the last day, and then sitting idle pending the Court's disposition of the motion, parties essentially grant their own motion. The Court will not condone this." Compere v. Nusret Miami, LLC, 2020 WL 2844888, at *2 (S.D. Fla. May 7, 2020) (internal citations omitted). Exhibits to pleadings and motions shall be docketed in accordance with the Courts CM/ECF procedures, Rule 3L.(2): (2) Describing an Attachment to a Docket Entry A party filing an attachment to a document shall select one of the prescribed attachment categories from the drop-down menu (e.g., affidavit, transcript), provide an alphabetical or numerical designation (e.g., Exhibit A, Exhibit 1), and descriptively name each attachment (e.g., Exhibit 1 - Affidavit of Boo Radley) in a manner that enables the Court to easily locate and distinguish attachments. (Emphasis added.) Local Rule 16.4, Local Rules for the United States District Court for the Southern District of Florida, requires that a Notice of Settlement "shall be filed and served jointly by counsel for all parties to the settlement." A unilateral notice of settlement will not stay pre-trial deadlines or hearings. Failure to comply with any of these procedures may result in the imposition of appropriate sanctions. Signed by Judge Raag Singhal on 9/21/2023. (am00)

PAPERLESS ORDER TO FILE CERTIFICATE OF INTERESTED PERSONS Within SEVEN (7) DAYS of entry of an appearance, each party, including governmental parties, must file certificates of interested parties and corporate disclosure statements that contain a complete list of persons, associated persons, firms, partnerships, or corporations that have a financial interest in the outcome of this case, including subsidiaries, conglomerates, affiliates, parent corporations, and other identifiable legal entities related to a party. The parties shall not include Judge Singhal or the paired magistrate judges unless they have an interest in the litigation. Throughout the pendency of the action, the parties are under a continuing obligation to amend, correct, and update the certificates. Signed by Judge Raag Singhal on 9/21/2023. (am00)

Plaintiff's Certificate of Other Affiliates by Chanel, Inc.

ORDER TO FILE UNDER SEAL granting [5] Motion to Seal. Signed by Judge Raag Singhal on 9/22/2023. See attached document for full details.

Order (Text entry; no document attached.)

Plaintiff's MOTION to Unseal by Chanel, Inc.

Text of Proposed Order Granting Motion to Unseal

AMENDED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants, filed by Chanel, Inc.

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

NOTICE of Voluntary Dismissal Without Prejudice of Defendant Number 14 by Chanel, Inc.

Order Of Dismissal With Prejudice re [20] NOTICE of Voluntary Dismissal Without Prejudice of Defendant Number 14 by Chanel, Inc. This matter is DISMISSED WITHOUT PREJUDICE as to Defendant No. 14 hiyajewellery.com a/k/a hiyajewellery a/k/a Hiya Jewellery a/k/a hiyajewellerystore. Signed by Judge Raag Singhal on 10/2/2023. See attached document for full details.

Order on Motion to Unseal Case

Clerk's NOTICE of Compliance re 22 Order on Motion to Unseal Case. All Docket Entries Unsealed.

Plaintiff's NOTICE by Chanel, Inc. re [1] Complaint, [12] Order on Ex Parte Motion, upon Defendants via Electronic Mail

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Chanel, Inc. re [1] Complaint, [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, [18] Motion to Unseal Case, [12] Order on Ex Parte Motion, upon Defendants via Registrar

CERTIFICATE OF SERVICE by Chanel, Inc. re [4] Certificate of Other Affiliates/Corporate Disclosure Statement, [18] Motion to Unseal Case, [17] Sealed Document, [3] Form AO 120/121, [9] Order, [10] Certificate of Other Affiliates/Corporate Disclosure Statement, [15] Sealed Document, [11] Order on Motion to Seal, [5] Plaintiff's MOTION to Seal per Local Rule 5.4, [1] Complaint, [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, [2] Clerks Notice of Judge Assignment, [13] Order on Ex Parte Motion, [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, [12] Order on Ex Parte Motion, [14] Sealed Document, [8] Notice of Court Practice/to Appear/Other, upon Defendants via website posting

Plaintiff's NOTICE by Chanel, Inc. of Email Inquiries Received From Certain Defendants in Connection With Asset Restraint And Service

Exhibit 1 to the Notice

PAPERLESS Minute Entry and MINUTE ORDER for proceedings held before Judge Raag Singhal: Motion Hearing held on 10/5/2023 re 6 Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order, Preliminary Injunction, and Order Restraining Transfer of Assets. Total time in court: 0 hour(s) : 15 minutes. Attorney Appearance(s): T. Raquel Wiborg-Rodriguez. Court Reporter: Karl Shires, 954-769-5496 / Karl_Shires@flsd.uscourts.gov. Signed by Judge Raag Singhal on 10/5/2023. (am00)

ORDER GRANTING [6] APPLICATION FOR ENTRY OF PRELIMINARY INJUNCTION. Signed by Judge Raag Singhal on 10/10/2023. See attached document for full details.

Plaintiff's NOTICE by Chanel, Inc. of Identification of Additional Aliases for Defendant Numbers 12, 33, and 38 and Additional Financial Accounts Used By Defendant Numbers 12, 32, 34, 35, 37, 38, 42, and 43

Declaration of Eric Rosaler in Support Thereof

Exhibit 1 to the Rosaler Declaration

Declaration of Kathleen Burns in Support Thereof

Exhibit 1 to the Burns Declaration

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 Chanel, Inc. 247teeshirt.com served on 9/29/2023, response/answer due 10/20/2023; amityshirt.com served on 9/29/2023, response/answer due 10/20/2023; amonici.com served on 9/29/2023, response/answer due 10/20/2023; baskick.ru served on 9/29/2023, response/answer due 10/20/2023; bugalooboutique.com served on 9/29/2023, response/answer due 10/20/2023; bunbotee.com served on 9/29/2023, response/answer due 10/20/2023; burgerstee.com served on 9/29/2023, response/answer due 10/20/2023; chanelhandbags.us served on 9/29/2023, response/answer due 10/20/2023; chanelline.sale served on 9/29/2023, response/answer due 10/20/2023; chanelshoes.us served on 9/29/2023, response/answer due 10/20/2023; chicabulls.com served on 9/29/2023, response/answer due 10/20/2023; copshoe.ru served on 9/29/2023, response/answer due 10/20/2023; cteeshirt.com served on 9/29/2023, response/answer due 10/20/2023; dopebuzz.com.br served on 9/29/2023, response/answer due 10/20/2023; dopestkickzclub.ru served on 9/29/2023, response/answer due 10/20/2023; ebuycos.com served on 9/29/2023, response/answer due 10/20/2023; epkick.ru served on 9/29/2023, response/answer due 10/20/2023; forkick.shop served on 9/29/2023, response/answer due 10/20/2023; glamifiedcosmetics.com served on 9/29/2023, response/answer due 10/20/2023; highkicks.cc served on 9/29/2023, response/answer due 10/20/2023; hiyajewellery.com served on 9/29/2023, response/answer due 10/20/2023; iovebags.com served on 9/29/2023, response/answer due 10/20/2023; juicytee.com served on 9/29/2023, response/answer due 10/20/2023; keepskick.ru served on 9/29/2023, response/answer due 10/20/2023; lgrose.ru served on 9/29/2023, response/answer due 10/20/2023; lookick.ru served on 9/29/2023, response/answer due 10/20/2023; luxemall.top served on 9/29/2023, response/answer due 10/20/2023; mercaritee.com served on 9/29/2023, response/answer due 10/20/2023; omgkickz.vip served on 9/29/2023, response/answer due 10/20/2023; pazzale.com served on 9/29/2023, response/answer due 10/20/2023; poshkicks.ru served on 9/29/2023, response/answer due 10/20/2023; reviewshirt.com served on 9/29/2023, response/answer due 10/20/2023; rlndstore.com served on 9/29/2023, response/answer due 10/20/2023; saycase.com served on 9/29/2023, response/answer due 10/20/2023; shoeki.co served on 9/29/2023, response/answer due 10/20/2023; shoepop.ru served on 9/29/2023, response/answer due 10/20/2023; topfashion520.com served on 9/29/2023, response/answer due 10/20/2023; usbestify.com served on 9/29/2023, response/answer due 10/20/2023; vipgoapple.top served on 9/29/2023, response/answer due 10/20/2023; winkick.ru served on 9/29/2023, response/answer due 10/20/2023; yesyeezyshoes.ru served on 9/29/2023, response/answer due 10/20/2023; zabluxury.com served on 9/29/2023, response/answer due 10/20/2023; zerelam.com served on 9/29/2023, response/answer due 10/20/2023.

Affidavit of Service

Affidavit of Service

Affidavit of Service

Plaintiff's NOTICE by Chanel, Inc. re [29] Order upon Defendants via Electronic Mail

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Chanel, Inc. re [29] Order upon Defendants via Registrar

CERTIFICATE OF SERVICE by Chanel, Inc. re [29] Order upon Defendants via website posting

Plaintiff's MOTION for Clerk's Entry of Default as to 247teeshirt.com, THE INDIVIDUALS, BUSINESS ENTITIES, AND UNINCORPORATED ASSOCIATIONS IDENTIFIED ON SCHEDULE A, amityshirt.com, amonici.com, baskick.ru, bugalooboutique.com, bunbotee.com, burgerstee.com, chanelhandbags.us, chanelline.sale, chanelshoes.us, chicabulls.com, copshoe.ru, cteeshirt.com, dopebuzz.com.br, dopestkickzclub.ru, ebuycos.com, epkick.ru, forkick.shop, glamifiedcosmetics.com, highkicks.cc, iovebags.com, juicytee.com, keepskick.ru, lgrose.ru, lookick.ru, luxemall.top, mercaritee.com, omgkickz.vip, pazzale.com, poshkicks.ru, reviewshirt.com, rlndstore.com, saycase.com, shoeki.co, shoepop.ru, topfashion520.com, usbestify.com, vipgoapple.top, winkick.ru, yesyeezyshoes.ru, zabluxury.com, zerelam.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: [35] Motion for Clerks Entry of Default Signed by DEPUTY CLERK on 12/7/2023.

ORDER ON DEFAULT FINAL JUDGMENT PROCEDURE re [36] Clerk's Entry/Non-Entry of Default. Responses due by 1/3/2024. Signed by Judge Raag Singhal on 12/11/2023. See attached document for full details.

Plaintiff's MOTION for Default Judgment Against Defendants and Memorandum of Law In Support Thereof by Chanel, Inc.

Declaration of Elizabeth Han in Support of Plaintiff's Motion for Entry of

Exhibit 1 to Decl. of Elizabeth Han

Declaration of Stephen M. Gaffigan in Support of Motion for Final Default Judgm

Text of Proposed Order Granting Motion for Entry of Final Default Judgment

Text of Proposed Order Granting Final Default Judgment Against Defendants

ORDER GRANTING 38 MOTION FOR FINAL DEFAULT JUDGMENT. In accordance with Federal Rule of Civil Procedure 58, judgment for Plaintiff will be entered separately. Signed by Judge Raag Singhal on 12/19/2023. See attached document for full details.

DEFAULT FINAL JUDGMENT AND PERMANENT INJUNCTION re 39 ORDER GRANTING 38 MOTION FOR FINAL DEFAULT JUDGMENT. ORDERED AND ADJUDGED that Final Default Judgment is entered in favor of Plaintiff, Chanel, Inc. ("Plaintiff"), and against Defendants the Individuals, Business Entities and Unincorporated Associations identified on Schedule "A" hereto (collectively, "Defendants"). This Clerk of Court is directed to CLOSE the case and DENY AS MOOT any pending motions. Closing Case. Signed by Judge Raag Singhal on 12/19/2023. See attached document for full details.

Plaintiff's NOTICE upon Defendants via Electronic Mail by Chanel, Inc. re [39] Order on Motion for Default Judgment, [40] Default Judgment, Permanent Injunction

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Chanel, Inc. re [39] Order on Motion for Default Judgment, [40] Default Judgment, Permanent Injunction, upon Defendants via website posting

Plaintiff's MOTION/APPLICATION for Writ of Garnishment on PayPal, Inc. After Judgment by Chanel, Inc.

Text of Proposed Order Writ of Garnishment as to PayPal, Inc.

Clerks Notice of Non-Issuance of WRIT OF GARNISHMENT as to Garnishee PayPal, Inc. Amount different than indicated on Judgment re: 43 Motion for Writ filed by Chanel, Inc.

Writ of Garnishment Issued (or Clks Ntc of Non-Issuance) (Text entry; no document attached.)

Amended MOTION/APPLICATION for Writ of Garnishment on PayPal, Inc. After Judgment by Chanel, Inc.

Text of Proposed Order Writ of Garnishment as to PayPal, Inc.

WRIT OF GARNISHMENT issued as to Garnishee PAYPAL, INC. in the amount of $ 1,000,000.00 re: [45] Motion for Writ filed by Chanel, Inc.

CERTIFICATE OF SERVICE by Chanel, Inc. re [45] Amended MOTION/APPLICATION for Writ of Garnishment on PayPal, Inc. After Judgment, [46] Writ of Garnishment

ANSWER to Writ of Garnishment by PayPal, Inc. Reply/Objections to Writ Answer due by 2/3/2025.

CERTIFICATE OF SERVICE by Chanel, Inc. re [48] Answer to Writ of Garnishment and Notice Pursuant to Section 77.055 of the Florida Statutes

Exhibit A - Service Packet

Plaintiff's NOTICE of Extension of Writ of Garnishment by Chanel, Inc. re [46] Writ of Garnishment

Exhibit 1 to the Notice of Extension