2023-cv-62203

COMPLAINT for Damages and Injunctive Relief against All Defendants. Filing fees $ 402.00 receipt number AFLSDC-17086598, filed by Burberry Limited, A United Kingdom Company, Burberry Limited, a New York Corporation.

Civil Cover Sheet

(Exhibit 1 to the Complaint)

Clerks Notice of Judge Assignment to Senior Judge James I. Cohn. 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 with Logs) (wce)

(Docketed in Error)FORM AO 121 SENT TO DIRECTOR OF U.S. COPYRIGHT OFFICE.

(Complaint with Logs) (wce) Modified Text on 11/21/2023 (wce)

Plaintiff's Corporate Disclosure Statement by Burberry Limited, Burberry Limited identifying Corporate Parent Burberry Group plc for Burberry Limited, Burberry Limited

Plaintiff's MOTION to Seal per Local Rule 5.4 by Burberry Limited, Burberry Limited.

(Text of Proposed Order Granting Motion to File under Seal)

Plaintiff's EX PARTE Motion for Temporary Restraining Order, MOTION for Preliminary Injunction, MOTION for Order Restraining Transfer of Assets by Burberry Limited, Burberry Limited.

Declaration of Jennifer Halter

Declaration of Christine Ann Daley

Declaration of Kathleen Burns

Exhibit 1 to the Declaration of Kathleen Burns, Part 1 of 4

Exhibit 1 to the Declaration of Kathleen Burns, Part 2 of 4

Exhibit 1 to the Declaration of Kathleen Burns, Part 3 of 4

Exhibit 1 to the Declaration of Kathleen Burns, Part 4 of 4

Text of Proposed Order) Modified by unsealing document on 12/5/2023 per DE

Order (kpe)

Plaintiff's EX PARTE MOTION for Order Authorizing Alternate Service of Process on Defendants Pursuant to Federal Rule of Civil Procedure 4(f)(3) by Burberry Limited, Burberry Limited.

Declaration of Christine Ann Daley in Support of Plaintiffs' Ex Parte Motion for Order Authorizing Alternate Service of Process

Exhibit 1 to the Declaration of Christine Ann Daley

Text of Proposed Order Granting Plaintiffs' Ex Parte Motion for Order Authorizing Alternate Service of Process on Defendants) Modified by unsealing document on 12/5/2023 per DE

Order (kpe)

ORDER granting 6 Motion to File Under Seal. Schedule "A" to Plaintiffs' Complaint and the Summonses shall be filed under seal and shall remain under seal until further order from this Court. Signed by Senior Judge James I. Cohn on 11/21/2023. See attached document for full details.

ORDER granting 7 Ex Parte Application For Entry Of Temporary Restraining Order And Setting Hearing On Motion For Preliminary Injunction. Motion Hearing set for 12/4/2023 10:00 AM in Fort Lauderdale Division before Senior Judge James I. Cohn. Responses due by 12/1/2023. Replies due by 12/3/2023. Signed by Senior Judge James I. Cohn on 11/21/2023. See attached document for full details. (kpe) Modified by unsealing document on 12/5/2023 per DE 22 Order

ORDER granting 8 Ex Parte Motion For Alternate Service. Signed by Senior Judge James I. Cohn on 11/21/2023. See attached document for full details.

SCHEDULING ORDER: (Jury Trial set for 8/19/2024 09:00 AM in Fort Lauderdale Division before Senior Judge James I. Cohn., Calendar Call set for 8/15/2024 09:00 AM in Fort Lauderdale Division before Senior Judge James I. Cohn.), and ORDER REFERRING CASE to Magistrate Judge Alicia O. Valle for Discovery Matters. Signed by Senior Judge James I. Cohn on 11/21/2023. See attached document for full details. (ls) 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.

Clerk's Notice of Docket Correction re 4 Form AO 121. Correction Other. See DE# 3 for correct Form AO 120. DE# 4 Docketed in Error.

NOTICE of Sealed Filing Schedule A re DE# 9 Order on Motion to Seal, by Burberry Limited, Burberry Limited.

Sealed Document: Schedule "A" to the Complaint) Modified text on 11/22/2023 (kpe). Modified by unsealing document on 12/5/2023 per DE

Order (kpe)

NOTICE of Filing Proposed Summons Under Seal re DE# 9 Order on Motion to Seal, by Burberry Limited, Burberry Limited.

Summon(s) Proposed Summons) Modified text on 11/22/2023 (kpe). Modified by unsealing document on 12/5/2023 per DE

Order (kpe)

Summons issued as to The Individuals, Business Entities, And Unincorporated Associations Identified On Schedule A. (kpe) Modified by unsealing document on 12/5/2023 per DE 22 Order

NOTICE of Filing Bond by Burberry Limited, Burberry Limited.

(Bond) (kpe)

Plaintiff's EX PARTE MOTION to Extend Temporary Restraining Order, dated November 21, 2023, and to Continue Hearing Scheduled for December 4, 2023 by Burberry Limited, Burberry Limited.

Declaration of Stephen M. Gaffigan in Support Thereof

Text of Proposed Order) Modified by unsealing document on 12/5/2023 per DE

Order (kpe)

ORDER Granting 18 Ex Parte Motion To Extend Temporary Restraining Order And To Continue Preliminary Injunction Hearing. Motion Hearing set for 12/13/2023 11:00 AM in Fort Lauderdale Division before Senior Judge James I. Cohn. Responses due by 12/10/2023. Replies due by 12/12/2023. Signed by Senior Judge James I. Cohn on 11/30/2023. See attached document for full details. (kpe) Modified by unsealing document on 12/5/2023 per DE 22 Order

Plaintiff's MOTION to Unseal by Burberry Limited, Burberry Limited.

(Text of Proposed Order Unsealing Case)

Plaintiff's AMENDED COMPLAINT for Damages and Injunctive Relief against All Defendants, filed by Burberry Limited, Burberry Limited.

(Exhibit 1 to the Amended Complaint)

ORDER Unsealing Case. Order granting 20 Motion to Unseal. The Clerk of Court is directed to UNSEAL all prior docket entries in this case. Signed by Senior Judge James I. Cohn on 12/4/2023. See attached document for full details.

CLERK'S NOTICE of Compliance by Unsealing documents pursuant to DE 22 Order.

Plaintiff's NOTICE of Filing Certificate of Service by Burberry Limited, Burberry Limited re 10 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, 19 Order on Ex Parte Motion, 12 Scheduling Order, Order Referring Case to Magistrate Judge, 21 Amended Complaint/Amended Notice of Removal, 1 Complaint

(Exhibit Certificate of Sevice)

CERTIFICATE OF SERVICE by Burberry Limited, Burberry Limited re 10 Order on Ex Parte Motion, 6 Plaintiff's MOTION to Seal per Local Rule 5.4, 9 Order on Motion to Seal, 3 Form AO 120/121, 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), 11 Order on Ex Parte Motion, 5 Certificate of Other Affiliates/Corporate Disclosure Statement, 7 Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order, Preliminary Injunction, and Order Restraining Transfer of Assets, 18 Plaintiff's EX PARTE MOTION to Extend Temporary Restraining Order, dated November 21, 2023, and to Continue Hearing Scheduled for December 4, 2023, 15 Sealed Document, 19 Order on Ex Parte Motion, 17 Notice (Other), 2 Clerks Notice of Judge Assignment, 12 Scheduling Order, Order Referring Case to Magistrate Judge, 20 Plaintiff's MOTION to Unseal, 4 Form AO 120/121, 21 Amended Complaint/Amended Notice of Removal, 14 Sealed Document, 1 Complaint, upon Defendants via website posting

SUMMONS (Affidavit) Returned Executed on 1 Complaint, 21 Amended Complaint/Amended Notice of Removal with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Burberry Limited, Burberry Limited. Belinda served on 12/7/2023, response/answer due 12/28/2023; ChengDouGangMoHuDianZiShangWuYouXianGongSi served on 12/7/2023, response/answer due 12/28/2023; Elizerberth Sindy served on 12/7/2023, response/answer due 12/28/2023; FFCC-directly served on 12/7/2023, response/answer due 12/28/2023; WWWT-direct served on 12/7/2023, response/answer due 12/28/2023; agneserin.com served on 12/7/2023, response/answer due 12/28/2023; allyoloswag.com served on 12/7/2023, response/answer due 12/28/2023; ambeljewelry.com served on 12/7/2023, response/answer due 12/28/2023; bagoneer.us served on 12/7/2023, response/answer due 12/28/2023; baihe6688 served on 12/7/2023, response/answer due 12/28/2023; bellefinery.com served on 12/7/2023, response/answer due 12/28/2023; beltcs.online served on 12/7/2023, response/answer due 12/28/2023; bewitchkiss.com served on 12/7/2023, response/answer due 12/28/2023; burberry-sale.com served on 12/7/2023, response/answer due 12/28/2023; buwqzf.com served on 12/7/2023, response/answer due 12/28/2023; caselyve.com served on 12/7/2023, response/answer due 12/28/2023; discount-brand-bag.online served on 12/7/2023, response/answer due 12/28/2023; dritus.com served on 12/7/2023, response/answer due 12/28/2023; ecomhao.com served on 12/7/2023, response/answer due 12/28/2023; eliteclutches.shop served on 12/7/2023, response/answer due 12/28/2023; er6.poq886.shop served on 12/7/2023, response/answer due 12/28/2023; exploremans.com served on 12/7/2023, response/answer due 12/28/2023; fimerry.com served on 12/7/2023, response/answer due 12/28/2023; flyi.shop served on 12/7/2023, response/answer due 12/28/2023; gocacoka.com served on 12/7/2023, response/answer due 12/28/2023; gwenjewellry.com served on 12/7/2023, response/answer due 12/28/2023; heirloomhues.xyz served on 12/7/2023, response/answer due 12/28/2023; iluxycase.com served on 12/7/2023, response/answer due 12/28/2023; luxury-bag-shuoes-clothing a.k.a. Tide brand clothing served on 12/7/2023, response/answer due 12/28/2023; luxury-bags-shoes served on 12/7/2023, response/answer due 12/28/2023; macallcloth.com served on 12/7/2023, response/answer due 12/28/2023; quinnishop.com served on 12/7/2023, response/answer due 12/28/2023; rinphil.com served on 12/7/2023, response/answer due 12/28/2023; sashajewelery.com served on 12/7/2023, response/answer due 12/28/2023; shopaayo.com served on 12/7/2023, response/answer due 12/28/2023; silprints.com served on 12/7/2023, response/answer due 12/28/2023; sneakww.com served on 12/7/2023, response/answer due 12/28/2023; topranklv.com served on 12/7/2023, response/answer due 12/28/2023; torenstore.com served on 12/7/2023, response/answer due 12/28/2023; vipnigo.com served on 12/7/2023, response/answer due 12/28/2023; washbagsonshop.com served on 12/7/2023, response/answer due 12/28/2023; wocacoka.com served on 12/7/2023, response/answer due 12/28/2023; wwhhll served on 12/7/2023, response/answer due 12/28/2023; yupoolyp.x.yupoo.com served on 12/7/2023, response/answer due 12/28/2023.

Affidavit of Service

(Affidavit of Service)

Exhibit List by Burberry Limited, Burberry Limited.

Witness List by Burberry Limited, Burberry Limited.

Plaintiff's NOTICE by Burberry Limited, Burberry Limited of E-mail Inquiries Received from Certain Defendants in Connection with Service

(Exhibit 1 to the Notice of E-mail Inquiries Received from Certain Defendants in Connection with Service)

Minute Entry for proceedings held before Senior Judge James I. Cohn: Evidentiary Motion Hearing held on 12/13/2023 re 7 Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order, Preliminary Injunction, and Order Restraining Transfer of Assets filed by Burberry Limited. See attachment for full details. Court Reporter: Glenda Powers, 305-523-5022 / Glenda_Powers@flsd.uscourts.gov.

ORDER granting 7 Motion for Preliminary Injunction. Signed by Senior Judge James I. Cohn on 12/13/2023. See attached document for full details.

Plaintiff's NOTICE by Burberry Limited, Burberry Limited of Identification of Additional Financial Accounts and Aliases Used by Various Defendants

Declaration of Kathleen Burns in Support

(Exhibit 1 to the Declaration of Kathleen Burns)

Plaintiff's NOTICE by Burberry Limited, Burberry Limited of Identification of Additional Financial Account Used by Defendant Number 40

Declaration of Kathleen Burns in Support of Plaintiffs' Notice of Identification of Additional Financial Account Used by Defendant Number 40

(Exhibit 1 to the Declaration of Kathleen Burns)

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

Plaintiff's NOTICE of Filing Certificate of Service by Burberry Limited, Burberry Limited re 31 Order on Motion for Preliminary Injunction.

(Exhibit Certificate of Sevice) Modified Text on 1/23/2024 (ls)

CERTIFICATE OF SERVICE by Burberry Limited, Burberry Limited re 31 Order on Motion for Preliminary Injunction upon Defendants via website posting

Plaintiff's MOTION for Clerk's Entry of Default as to Belinda, ChengDouGangMoHuDianZiShangWuYouXianGongSi, Elizerberth Sindy, FFCC-directly, The Individuals, Business Entities, And Unincorporated Associations Identified On Schedule A, WWWT-direct, agneserin.com, allyoloswag.com, ambeljewelry.com, bagoneer.us, baihe6688, bellefinery.com, beltcs.online, bewitchkiss.com, burberry-sale.com, buwqzf.com, caselyve.com, discount-brand-bag.online, dritus.com, ecomhao.com, eliteclutches.shop, er6.poq886.shop, exploremans.com, fimerry.com, flyi.shop, gocacoka.com, gwenjewellry.com, heirloomhues.xyz, iluxycase.com, luxury-bag-shuoes-clothing a.k.a. Tide brand clothing, luxury-bags-shoes, macallcloth.com, quinnishop.com, rinphil.com, sashajewelery.com, shopaayo.com, silprints.com, sneakww.com, topranklv.com, torenstore.com, vipnigo.com, washbagsonshop.com, wocacoka.com, wwhhll, yupoolyp.x.yupoo.com by Burberry Limited, Burberry Limited.

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

(Text of Proposed Order)

Defendant's Motion for Extension of Time to File Response/Reply/Answer as to 1 Complaint by heirloomhues.xyz. Responses due by 2/5/2024.

(Text of Proposed Order) Modified Relief on 1/23/2024 (ls)

Clerk's Notice to Filer re 38 Defendant's MOTION for Extension of Time to Respond to the Complaint re 1 Complaint. Filer Selected the Wrong Motion Relief(s); ERROR - The Filer selected the wrong motion relief(s) when docketing the motion. The correction was made by the Clerk. It is not necessary to refile this document but future motions filed must include applicable reliefs.

PAPERLESS Clerk's Entry of Default as to Belinda, ChengDouGangMoHuDianZiShangWuYouXianGongSi, Elizerberth Sindy, FFCC-directly, WWWT-direct, agneserin.com, allyoloswag.com, ambeljewelry.com, bagoneer.us, baihe6688, bellefinery.com, beltcs.online, bewitchkiss.com, burberry-sale.com, buwqzf.com, caselyve.com, discount-brand-bag.online, dritus.com, ecomhao.com, eliteclutches.shop, er6.poq886.shop, exploremans.com, fimerry.com, flyi.shop, gocacoka.com, gwenjewellry.com, iluxycase.com, luxury-bag-shuoes-clothing a.k.a. Tide brand clothing, luxury-bags-shoes, macallcloth.com, quinnishop.com, rinphil.com, sashajewelery.com, shopaayo.com, silprints.com, sneakww.com, topranklv.com, torenstore.com, vipnigo.com, washbagsonshop.com, wocacoka.com, wwhhll, yupoolyp.x.yupoo.com - Motions Terminated: 37 Motion for Clerks Entry of Default. Signed by DEPUTY CLERK on 1/23/2024.

PAPERLESS ORDER by Clerk of Non-Entry of Default re 37 Motion for Clerk's Entry of Default as to heirloomhues.xyz. Reason: Responsive pleading (i.e. Motion for Extention of Time to File Answer to Complaint, Motion to Dismiss Complaint, etc) has been filed. Signed by DEPUTY CLERK on 1/23/2024.

Reset Response/Answer Due Deadline: heirloomhues.xyz response/answer due 2/2/2024. (ls)(per DE #42) (Text entry; no document attached.)

PAPERLESS ORDER granting 38 Motion for Extension of Time to Respond to Complaint. Defendant heirloomhues.xyz's response to Plaintiffs' Complaint is due no later than February 2, 2024. Signed by Senior Judge James I. Cohn on 1/24/2024.

ANSWER and Affirmative Defenses to Amended Complaint by heirloomhues.xyz.

ORDER SETTING TELEPHONIC SCHEDULING CONFERENCE. Scheduling Conference set for 3/26/2024 at 2:00 PM before Magistrate Judge Alicia O. Valle. Signed by Magistrate Judge Alicia O. Valle on 3/19/2024. See attached document for full details.

Plaintiff's SCHEDULING REPORT - Rule 26(f) by Burberry Limited, Burberry Limited

Text of Proposed Order Proposed Scheduling Order

CERTIFICATE OF SERVICE by Burberry Limited, Burberry Limited re [44] Order Setting/Resetting/Cancelling Hearing, upon Defendants via Electronic Mail and via Website Posting

PAPERLESS ORDER REGARDING TELEPHONIC SCHEDULING CONFERENCE. The Telephonic Scheduling Conference scheduled for March 26, 2024 will commence at 2:30 pm. This is solely a time change. All other terms of 44 Order Setting Telephonic Scheduling Conference remain in effect. Signed by Magistrate Judge Alicia O. Valle on 3/26/2024.

ORDER REQUIRING MEDIATION. Signed by Magistrate Judge Alicia O. Valle on 3/26/2024. See attached document for full details.

SCHEDULING ORDER: Amended Pleadings due by 5/10/2024. Expert Discovery due by 5/30/2024. Fact Discovery due by 5/30/2024. Joinder of Parties due by 5/10/2024. Mediation Deadline 7/18/2024. Dispositive Motions due by 6/13/2024. In Limine Motions due by 8/1/2024. Pretrial Stipulation due by 8/12/2024. Signed by Magistrate Judge Alicia O. Valle on 3/26/2024. See attached document for full details.

Plaintiff's MOTION for Default Judgment Against Defendants by Burberry Limited, Burberry Limited.

Declaration of Jennifer Halter in Support of Plaintiffs' Motion for Entry

Exhibit 1 to the Declaration of Jennifer Halter

Declaration of Christine Ann Daley in Support of Plaintiffs' Motion for En

Text of Proposed Order Proposed Final Default Judgment

Joint NOTICE of Mediator Selection. Mediation Hearing set for 6/24/2024 at 9:00 a.m. Selected/Added Mark Stein, Esq. as Mediator. Modified Text on 4/10/2024

NOTICE of Settlement with Defendant Number 21 by Burberry Limited, Burberry Limited

FINAL DEFAULT JUDGMENT in favor of Burberry Limited (UK) and Burberry Limited (NY) against Belinda, ChengDouGangMoHuDianZiShangWuYouXianGongSi, Elizerberth Sindy, FFCC-directly, WWWT-direct, agneserin.com, allyoloswag.com, ambeljewelry.com, bagoneer.us, baihe6688, bellefinery.com, beltcs.online, bewitchkiss.com, burberry-sale.com, buwqzf.com, caselyve.com, discount-brand-bag.online, dritus.com, ecomhao.com, eliteclutches.shop, er6.poq886.shop, exploremans.com, fimerry.com, flyi.shop, gocacoka.com, gwenjewellry.com, iluxycase.com, luxury-bag-shuoes-clothing a.k.a. Tide brand clothing, luxury-bags-shoes, macallcloth.com, quinnishop.com, rinphil.com, sashajewelery.com, shopaayo.com, silprints.com, sneakww.com, topranklv.com, torenstore.com, vipnigo.com, washbagsonshop.com, wocacoka.com, wwhhll, yupoolyp.x.yupoo.com; Granting [50] Plaintiff's MOTION for Final Default Judgment; Closing Case. Signed by Senior Judge James I. Cohn on 4/17/2024. See attached document for full details.

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

Supplement Final Default Judgment

Agreed MOTION to Approve Consent Judgment and Permanent Injunction as to Defendant Number 21 by Burberry Limited, Burberry Limited. Responses due by 5/13/2024.

Exhibit 1: Consent Judgment and Permanent Injunction as to Defendant Number 21

CONSENT FINAL JUDGMENT and PERMANENT INJUNCTION as to Defendant Number 21: Granting [55] Agreed MOTION for Entry of Consent Judgment and Permanent Injunction as to Defendant Number 21. Signed by Senior Judge James I. Cohn on 4/29/2024. See attached document for full details.