2023-cv-62186

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. Filing fees $ 402.00 receipt number AFLSDC-17081132, 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 Roy K. Altman and Magistrate Judge Jared M. Strauss. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Jared M. Strauss 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.

Plaintiff's Corporate Disclosure Statement by Chanel, Inc.

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

Complaint

Plaintiff's MOTION to Seal per Local Rule 5.4 by Chanel, Inc.

Text of Proposed Order Granting Motion to Seal

ORDER GRANTING MOTION TO FILE UNDER SEAL granting [5] Motion to Seal. Signed by Judge Roy K. Altman on 11/20/2023. See attached document for full details.

ORDER IN CASES WITH MULTIPLE DEFENDANTS. Signed by Judge Roy K. Altman on 11/20/2023. See attached document for full details.

Plaintiff's MOTION to Unseal by Chanel, Inc.

Text of Proposed Order Granting Motion to Unseal

PAPERLESS ORDER granting 17 the Plaintiff's Motion to Unseal. The Clerk of Court is directed to UNSEAL this case and return all docket entries to the public record. By December 12, 2023, the Plaintiff must add all Defendants as parties to this case on CM/ECF. Signed by Judge Roy K. Altman on 12/4/2023.

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 Trad

Clerk's NOTICE of Compliance re 18 Order on Motion to Unseal. All Docket Entries Unsealed.

Plaintiff's NOTICE by Chanel, Inc. re [1] Complaint, [13] Order on Ex Parte Motion, [15] Order, [19] Amended Complaint/Amended Notice of Removal upon Defendants via Electronic Mail

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Chanel, Inc. re [4] Form AO 120/121, [5] Plaintiff's MOTION to Seal per Local Rule 5.4, [15] Order, [11] Order on Ex Parte Motion, [18] Order on Motion for Miscellaneous Relief, [2] Clerks Notice of Judge Assignment, [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, [7] Sealed Document, [3] Certificate of Other Affiliates/Corporate Disclosure Statement, [17] Plaintiff's MOTION to Unseal, [1] Complaint, [20] Notice of Compliance, [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, [19] Amended Complaint/Amended Notice of Removal, [8] Order, [6] Order on Motion to Seal, [12] Sealed Document 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 Chanel, Inc. alltheworldprint.com served on 12/4/2023, response/answer due 12/27/2023; fp.trendyraccoon.com served on 12/4/2023, response/answer due 12/27/2023; lddcase.com served on 12/4/2023, response/answer due 12/27/2023; luxuryen.com served on 12/4/2023, response/answer due 12/27/2023; nushad.com served on 12/4/2023, response/answer due 12/27/2023; polangsk.com served on 12/4/2023, response/answer due 12/27/2023; shemese.com served on 12/4/2023, response/answer due 12/27/2023; streetwearcrib.com served on 12/4/2023, response/answer due 12/27/2023; teenavi.com served on 12/4/2023, response/answer due 12/27/2023; theheppersales.com served on 12/4/2023, response/answer due 12/27/2023; vincyrep.ru served on 12/4/2023, response/answer due 12/27/2023.

Affidavit of Service

Affidavit of Service

PAPERLESS NOTICE of Hearing: The Preliminary Injunction Hearing is reset for December 21, 2023, at 11:00 AM in the Miami Division, Courtroom 12-4, before Judge Roy K. Altman.

Plaintiff's NOTICE by Chanel, Inc. re [24] Notice re Hearing upon Defendants via Electronic Mail

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Chanel, Inc. re [24] Notice re Hearing upon Defendants via website posting

Plaintiff's NOTICE by Chanel, Inc. of Email Inquiry Received From a Certain Defendant in Connection with Asset Restraint and Service

Exhibit 1 to the Notice

PAPERLESS Minute Entry for proceedings held before Senior Judge Robert N. Scola, Jr: Preliminary Injunction Hearing held on 12/21/2023. Total time in court: 5 minutes. Attorney Appearance(s): Virgilio Gigante. Court Reporter: Francine Salopek, 305-301-3276 / mjsfcs@aol.com.

ORDER GRANTING [9] APPLICATION FOR ENTRY OF PRELIMINARY INJUNCTION. The Clerk of Court is directed to CLOSE this case for administrative purposes only. Any party may move to reopen the case at any time. Closing Case. Signed by Judge Roy K. Altman on 12/21/2023. See attached document for full details.

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

Order

Plaintiff's MOTION for Clerk's Entry of Default as to THE INDIVIDUALS, BUSINESS ENTITIES, AND UNINCORPORATED ASSOCIATIONS IDENTIFIED ON SCHEDULE A, alltheworldprint.com, fp.trendyraccoon.com, lddcase.com, luxuryen.com, nushad.com, polangsk.com, shemese.com, streetwearcrib.com, teenavi.com, theheppersales.com, vincyrep.ru by Chanel, Inc.

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

Text of Proposed Order

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

Exhibit Certificate of Sevice

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

Clerk's Entry of Default as to alltheworldprint.com, fp.trendyraccoon.com, lddcase.com, luxuryen.com, nushad.com, polangsk.com, shemese.com, streetwearcrib.com, teenavi.com, theheppersales.com, vincyrep.ru - Motions Terminated: 31 Motion for Clerks Entry of Default, Signed by DEPUTY CLERK on 2/1/2024.

ORDER ON DEFAULT FINAL JUDGMENT PROCEDURE Signed by Judge Roy K. Altman on 2/1/2024. 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 [36] MOTION FOR FINAL DEFAULT JUDGMENT. In accordance with Federal Rule of Civil Procedure 58, final judgment will be entered separately. Signed by Judge Roy K. Altman on 2/6/2024. See attached document for full details.

FINAL DEFAULT JUDGMENT AND PERMANENT INJUNCTION re [37] ORDER GRANTING [36] MOTION FOR FINAL DEFAULT JUDGMENT. Judgment is entered in favor of the Plaintiff, and against the Defendants listed on the attached Schedule A (the "Defendants"). Statutory Damages pursuant to 15 U.S.C. § 1117(c): Award the Plaintiff damages of $1,000,000.00 against each Defendant, for which let execution issue, based upon the Court's finding that each Defendant infringed at least one (1) trademark on one (1) type of good. Signed by Judge Roy K. Altman on 2/7/2024. See attached document for full details.

CERTIFICATE OF SERVICE by Chanel, Inc. re [37] Order on Motion for Default Judgment, [38] Default Judgment, Permanent Injunction, upon Defendants via website posting

Plaintiff's NOTICE upon Defendants via Electronic Mail by Chanel, Inc. re [37] Order on Motion for Default Judgment, [38] Default Judgment, Permanent Injunction

Exhibit Certificate of Sevice

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.

WRIT OF GARNISHMENT issued as to Garnishee PAYPAL, INC. in the amount of $ 998,324.11

CERTIFICATE OF SERVICE by Chanel, Inc. re [41] Plaintiff's MOTION/APPLICATION for Writ of Garnishment on PayPal, Inc. After Judgment, [42] Writ of Garnishment

ANSWER to Writ of Garnishment by PayPal, Inc. Reply/Objections to Writ Answer due by 1/22/2025.

CERTIFICATE OF SERVICE by Chanel, Inc. re [44] 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 [42] Writ of Garnishment

Exhibit 1 to the Notice of Extension