2023-cv-62371

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. Filing fees $ 405.00 receipt number AFLSDC-17155321, filed by Tiffany (NJ) LLC.

Civil Cover Sheet

Exhibit 1 to Complaint Certificates of Registration for the Tiffany Trademarks

Clerks Notice of Judge Assignment to Judge Robin L. Rosenberg and Magistrate Judge Panayotta D. Augustin-Birch. 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.

Exhibit

Plaintiff's Corporate Disclosure Statement by Tiffany (NJ) LLC identifying Corporate Parent Tiffany & Co., Corporate Parent LVMH Moet Hennessy Louis Vuitton SE, Corporate Parent Tiffany and Company, Other Affiliate Christian Dior SE for Tiffany (NJ) LLC

Plaintiff's MOTION to Seal per Local Rule 5.4 by Tiffany (NJ) LLC.

Text of Proposed Order Granting Motion to Seal

ORDER OF REFERENCE TO MAGISTRATE JUDGE AND ORDER OF COURT-MANDATED REQUIREMENTS ON SERVICE, DEFAULTS, AND JOINT SCHEDULING REPORTS. ORDER REFERRING CASE to Magistrate Judge Magistrate Judge Panayotta D. Augustin-Birch for appropriate disposition of all pro hac vice motions, motions to substitute counsel, and pretrial motions related to discovery., Order of Court-Mandated Requirements in, Order Requiring Joint Scheduling Report Signed by Judge Robin L. Rosenberg on 12/21/2023. See attached document for full details.

ORDER granting [5] Motion to Seal. Signed by Judge Robin L. Rosenberg on 12/21/2023. See attached document for full details.

Order (Text entry; no document attached.)

Plaintiff's NOTICE of Filing Status Report Regarding Service by Tiffany (NJ) LLC re [8] Order Referring Case to Magistrate Judge, Order of Requirements, Order Requiring Joint Scheduling Report

Status Report Regarding Service

Plaintiff's Notice of Filing Seizure Bond in the amount of $10000.00 posted by Tiffany (NJ) LLC Approved by Judge Robin L. Rosenberg

Plaintiff's NOTICE of Inability to Serve Defendants by Tiffany (NJ) LLC

Order (Text entry; no document attached.)

Plaintiff's MOTION to Unseal by Tiffany (NJ) LLC.

Text of Proposed Order

Plaintiff's NOTICE upon Defendants via Electronic Mail by Tiffany (NJ) LLC re [1] Complaint, [19] Plaintiff's MOTION to Unseal

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Tiffany (NJ) LLC re [1] Complaint, [19] Plaintiff's MOTION to Unseal upon Defendant via Registrar

CERTIFICATE OF SERVICE by Tiffany (NJ) LLC re [17] Notice (Other), [5] Plaintiff's MOTION to Seal per Local Rule 5.4, [3] Form AO 120/121, [4] Certificate of Other Affiliates/Corporate Disclosure Statement, [13] Notice (Other), [1] Complaint, [9] Order on Motion to Seal, [19] Plaintiff's MOTION to Unseal, [2] Clerks Notice of Judge Assignment, [8] Order Referring Case to Magistrate Judge, Order of Requirements, Order Requiring Joint Scheduling Report, [16] Bond upon Defendants via website posting

Order (Text entry; no document attached.)

ORDER GRANTING PLAINTIFFS EX PARTE MOTION TO EXTEND TEMPORARY RESTRAINING ORDER AND CONTINUE HEARING. ORDER granting [18] Ex Parte Motion. Prelinjhrg Hearing set for 1/22/2024 03:00 PM before Judge Robin L. Rosenberg. Signed by Judge Robin L. Rosenberg on 1/11/2024. See attached document for full details.

AMENDED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants, filed by Tiffany (NJ) LLC.

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

ORDER granting [19] Motion to Unseal. Signed by Judge Robin L. Rosenberg on 1/12/2024. See attached document for full details.

NOTICE of Compliance re 25 Order on Motion for Miscellaneous Relief. (All docket entries Unsealed)

Plaintiff's NOTICE upon Defendants via Electronic Mail by Tiffany (NJ) LLC re [23] Order on Ex Parte Motion

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Tiffany (NJ) LLC re [23] Order on Ex Parte Motion, upon Defendant via Registrar

CERTIFICATE OF SERVICE by Tiffany (NJ) LLC re [23] Order on Ex Parte Motion, upon Defendants via website posting

Deadline(s)/Hearing(s) terminated per paperless order de#30. (Text entry; no document attached.)

PAPERLESS ORDER. Pursuant to the Court's order extending the temporary restraining order at docket entry 23, the Defendants had until 3 pm EST on January 19, 2024, to file any response to the Plaintiff's Motion for Preliminary Injunction. No response appears in the court file. Pursuant to Local Rule 7.1(c) and the Defendants' failure to file a response to the Motion for Preliminary Injunctive Relief, the Court GRANTS the Motion for Preliminary Injunctive Relief by default and CANCELS the hearing (set for January 22, 2024) on the matter. The Plaintiff is ORDERED to provide the Court with a proposed order in Microsoft Word format, at rosenberg@flsd.uscourts.gov, within two business days of the date of this Order, in light of the Court's granting of the Motion herein. Signed by Judge Robin L. Rosenberg

Deadline(s)/Hearing(s) terminated per paperless order de#30. (Text entry; no document attached.)

NOTICE of Compliance by Tiffany (NJ) LLC re [30] Order

ORDER GRANTING PLAINTIFF'S MOTION FOR ENTRY OF PRELIMINARY INJUNCTION.ORDER granting [6] Ex Parte Motion. Signed by Judge Robin L. Rosenberg on 1/24/2024. See attached document for full details.

Plaintiff's NOTICE of Identification of Additional Alias for Defendant Number 37 and Additional Payment Accounts Used By Defendant Numbers 1, 21, 24, 37, and 43 by Tiffany (NJ) LLC

Declaration of Kathleen Burns in Support Thereof

Exhibit 1 to the Declaration of Kathleen Burns

SUMMONS (Affidavit) Returned Executed on [1] Complaint, [24] Amended Complaint/Amended Notice of Removal with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Tiffany (NJ) LLC. Mladenkakodic.com served on 1/12/2024, response/answer due 2/2/2024; Tiffanyberlin.de served on 1/12/2024, response/answer due 2/2/2024; Tiffanymilanooutlet.it served on 1/12/2024, response/answer due 2/2/2024; Tiffanystockholm.com.se served on 1/12/2024, response/answer due 2/2/2024; Xiaochen88666 served on 1/12/2024, response/answer due 2/2/2024; airjordane.shop served on 1/12/2024, response/answer due 2/2/2024; ambeljewelry.com served on 1/12/2024, response/answer due 2/2/2024; billionsneaker.com served on 1/12/2024, response/answer due 2/2/2024; boutiquesbag.com served on 1/12/2024, response/answer due 2/2/2024; cicicottage served on 1/12/2024, response/answer due 2/2/2024; classicbags.us served on 1/12/2024, response/answer due 2/2/2024; cocokick.pw served on 1/12/2024, response/answer due 2/2/2024; cyferstreet.com served on 1/12/2024, response/answer due 2/2/2024; dasingab.com served on 1/12/2024, response/answer due 2/2/2024; developerboring.com served on 1/12/2024, response/answer due 2/2/2024; diy77777 served on 1/12/2024, response/answer due 2/2/2024; eljewelrydesigns.com served on 1/12/2024, response/answer due 2/2/2024; ellef.shop served on 1/12/2024, response/answer due 2/2/2024; evelynbelt.com served on 1/12/2024, response/answer due 2/2/2024; fined-fashion.shop served on 1/12/2024, response/answer due 2/2/2024; jensjewellerysales served on 1/12/2024, response/answer due 2/2/2024; jewelryshopshine.com served on 1/12/2024, response/answer due 2/2/2024; jewelryshopwedding.com served on 1/12/2024, response/answer due 2/2/2024; kicksfreake.vip served on 1/12/2024, response/answer due 2/2/2024; kingsneaker.ru served on 1/12/2024, response/answer due 2/2/2024; latica.co served on 1/12/2024, response/answer due 2/2/2024; legionkick.com served on 1/12/2024, response/answer due 2/2/2024; luminajw.com served on 1/12/2024, response/answer due 2/2/2024; moonchildworldltd.com served on 1/12/2024, response/answer due 2/2/2024; moopdf.icu served on 1/12/2024, response/answer due 2/2/2024; pawscanva.com served on 1/12/2024, response/answer due 2/2/2024; repsoles.com served on 1/12/2024, response/answer due 2/2/2024; sailkicks.cn served on 1/12/2024, response/answer due 2/2/2024; semam8844 served on 1/12/2024, response/answer due 2/2/2024; shopletch.com served on 1/12/2024, response/answer due 2/2/2024; sloveos.com served on 1/12/2024, response/answer due 2/2/2024; sneakersnhut.com served on 1/12/2024, response/answer due 2/2/2024; sportivibes.com served on 1/12/2024, response/answer due 2/2/2024; stylesneaks.com served on 1/12/2024, response/answer due 2/2/2024; tiffanywien.at served on 1/12/2024, response/answer due 2/2/2024; tyfashionshoes.shop served on 1/12/2024, response/answer due 2/2/2024; user3193349967434 served on 1/12/2024, response/answer due 2/2/2024; vendorsalisonsun served on 1/12/2024, response/answer due 2/2/2024; wereplica.is served on 1/12/2024, response/answer due 2/2/2024; witiboss.com served on 1/12/2024, response/answer due 2/2/2024; zhangli1136 served on 1/12/2024, response/answer due 2/2/2024; zinzeex.com served on 1/12/2024, response/answer due 2/2/2024.

Affidavit of Service

Affidavit of Service

Affidavit of Service

Plaintiff's NOTICE of Filing Status Report Regarding Service by Tiffany (NJ) LLC re [8] Order Referring Case to Magistrate Judge, Order of Requirements, Order Requiring Joint Scheduling Report

Status Report Regarding Service

Plaintiff's NOTICE of Identification of Additional Aliases for Defendant Numbers 4 and 23 and Additional Payment Accounts Used By Defendant Numbers 4, 23, and 43 by Tiffany (NJ) LLC

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 Clerk's Entry of Default as to Mladenkakodic.com, The Individuals, Business Entities, and Unincorporated Associations Identified on Schedule A, Tiffanyberlin.de, Tiffanymilanooutlet.it, Tiffanystockholm.com.se, Xiaochen88666, airjordane.shop, ambeljewelry.com, billionsneaker.com, boutiquesbag.com, cicicottage, classicbags.us, cocokick.pw, cyferstreet.com, dasingab.com, developerboring.com, diy77777, eljewelrydesigns.com, ellef.shop, evelynbelt.com, fined-fashion.shop, jensjewellerysales, jewelryshopshine.com, jewelryshopwedding.com, kicksfreake.vip, kingsneaker.ru, latica.co, legionkick.com, luminajw.com, moonchildworldltd.com, moopdf.icu, pawscanva.com, repsoles.com, sailkicks.cn, semam8844, shopletch.com, sloveos.com, sneakersnhut.com, sportivibes.com, stylesneaks.com, tiffanywien.at, tyfashionshoes.shop, user3193349967434, vendorsalisonsun, wereplica.is, witiboss.com, zhangli1136, zinzeex.com by Tiffany (NJ) LLC.

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, andUnincorporated Associations identified on Schedule A hereto, (collectively Defendants) - Motions Terminated: 37 Motion for Clerks Entry of Default, Signed by DEPUTY CLERK on 2/7/2024.

Clerk's Entry of Default as to The Individuals, Business Entities, and Unincorporated Associations identified on Schedule A hereto, (collectively Defendants) Signed by DEPUTY CLERK on 2/7/2024.

Plaintiff's MOTION for Default Judgment Against Defendants and Memorandum of Law in Support Thereof by Tiffany (NJ) LLC.

Declaration of Pilar Toro in Support Thereof

Exhibit 1 to the Declaration of Pilar Toro

Declaration of Stephen M. Gaffigan in Support Thereof

Text of Proposed Order Granting Motion for Final Default Judgment

Text of Proposed Order Final Default Judgment and Permanent Injunction

ORDER granting [40] Motion for Entry of Final Default Judgment. Closing Case. Signed by Judge Robin L. Rosenberg on 2/21/2024. See attached document for full details.

FINAL DEFAULT JUDGMENT and PERMANENT INJUNCTION in favor of Tiffany (NJ) LLC against airjordane.shop; ambeljewelry.com; Tiffanymilanooutlet.it, Xiaochen88666, billionsneaker.com, cocokick.pw, dasingab.com, developerboring.com, diy77777, kicksfreake.vip, kingsneaker.ru, legionkick.com, pawscanva.com, repsoles.com, sailkicks.cn, semam8844, sneakersnhut.com, sportivibes.com, zhangli1136, zinzeex.com; boutiquesbag.com; Mladenkakodic.com, cyferstreet.com, ellef.shop, evelynbelt.com, jensjewellerysales, latica.co, moonchildworldltd.com, user3193349967434; classicbags.us, fined-fashion.shop; cicicottage, eljewelrydesigns.com, moopdf.icu; Tiffanyberlin.de, Tiffanystockholm.com.se, jewelryshopshine.com, jewelryshopwedding.com, luminajw.com, shopletch.com, tiffanywien.at, tyfashionshoes.shop; sloveos.com, witiboss.com; vendorsalisonsun, wereplica.is; Closing Case. Signed by Judge Robin L. Rosenberg on 2/21/2024. See attached document for full details.

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

Supplement Final Default Judgment and Permanent Injunction