2023-cv-62410

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. Filing fees $ 405.00 receipt number AFLSDC-17170962, filed by YETI COOLERS, LLC.

Civil Cover Sheet

Exhibit 1 to Complaint Certificates of Registration for the YETI 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 Patrick M. Hunt 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

Corporate Disclosure Statement by YETI COOLERS, LLC identifying Corporate Parent YETI Holdings, Inc. for YETI COOLERS, LLC

Plaintiff's MOTION to Seal per Local Rule 5.4 by YETI COOLERS, LLC.

Text of Proposed Order

ORDER granting [5] Motion to Seal. Signed by Judge William P. Dimitrouleas on 12/28/2023. 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 1/2/2024. See attached document for full details.

Order

Plaintiff's Notice of Filing Bond on Injunction in the amount of $50,000.00 posted by YETI COOLERS, LLC Approved by Judge William P. Dimitrouleas

MOTION To Unseal by YETI COOLERS, LLC.

Text of Proposed Order

ORDER GRANTING MOTION TO UNSEAL granting [16] Motion to Unseal Case. Signed by Judge William P. Dimitrouleas on 1/19/2024. See attached document for full details.

Clerk's NOTICE of Compliance re 17 Order on Motion to Unseal. All Docket Entries Unsealed.

AMENDED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants, filed by YETI COOLERS, LLC.

Exhibit 1 to Amended Complaint Certificates of Registration for the YETI Tradem

NOTICE of E-mail Inquiry Received from a Certain Defendant in Connection with Asset Restraint and Service by YETI COOLERS, LLC

Exhibit 1 to the Notice of E-Mail Inquiries

Plaintiff's NOTICE upon Defendants via Electronic Mail by YETI COOLERS, LLC re [11] Order on Ex Parte Motion, [1] Complaint, [7] Order Requiring Joint Scheduling Report

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by YETI COOLERS, LLC re [16] Motion to Unseal Case, [11] Order on Ex Parte Motion, [8] 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, [1] Complaint, [7] Order Requiring Joint Scheduling Report upon Defendants via Registrar

CERTIFICATE OF SERVICE by YETI COOLERS, LLC re [15] Bond, [3] Form AO 120/121, [16] Motion to Unseal Case, [4] Certificate of Other Affiliates/Corporate Disclosure Statement, [13] Sealed Document, [11] Order on Ex Parte Motion, [6] Order on Motion to Seal, [2] Clerks Notice of Judge Assignment, [9] 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, [1] Complaint, [8] 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, [5] Plaintiff's MOTION to Seal per Local Rule 5.4, [7] Order Requiring Joint Scheduling Report, [12] Order on Ex Parte Motion, [10] Sealed Document, [14] Sealed Document upon Defendants via website posting

PAPERLESS Minute Entry for proceedings held before Judge William P. Dimitrouleas: Motion Hearing held on 1/26/2024 re 8 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 YETI COOLERS, LLC. No Defendants appeared. Court will enter Order granting Plaintiff's Motion. Total time in court: 5 minutes. Attorney Appearance(s): T. Raquel Wiborg-Rodriguez, Court Reporter: Patricia Bailey-Entin, 305-523-5635 / Patricia_BaileyEntin@flsd.uscourts.gov.

ORDER GRANTING APPLICATION FOR ENTRY OF PRELIMINARY INJUNCTION Signed by Judge William P. Dimitrouleas on 1/26/2024. See attached document for full details.

ORDER TO SHOW CAUSE FOR LACK OF PROSECUTION Show Cause Response due by 4/1/2024. Signed by Judge William P. Dimitrouleas on 3/25/2024. See attached document for full details.

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 YETI COOLERS, LLC. 16kvv3l3.online served on 1/23/2024, response/answer due 2/13/2024; 211.nilweerra served on 1/23/2024, response/answer due 2/13/2024; accentonline.top served on 1/23/2024, response/answer due 2/13/2024; bkboddxag.shop served on 1/23/2024, response/answer due 2/13/2024; buy-yeti.com served on 1/23/2024, response/answer due 2/13/2024; cheap-yeti.com served on 1/23/2024, response/answer due 2/13/2024; cheapyeti.com served on 1/23/2024, response/answer due 2/13/2024; coolersyeti.de served on 1/23/2024, response/answer due 2/13/2024; coolersyetiitalia.com served on 1/23/2024, response/answer due 2/13/2024; coolersyetinorge.com served on 1/23/2024, response/answer due 2/13/2024; coolersyetiperu.com served on 1/23/2024, response/answer due 2/13/2024; coolersyetischweiz.com served on 1/23/2024, response/answer due 2/13/2024; coolersyetiusa.com served on 1/23/2024, response/answer due 2/13/2024; darshanra8901 served on 1/23/2024, response/answer due 2/13/2024; dertsllpsdt.shop served on 1/23/2024, response/answer due 2/13/2024; discount-yeti.com served on 1/23/2024, response/answer due 2/13/2024; discountbloc.ru served on 1/23/2024, response/answer due 2/13/2024; gayanmaduwanth-224 served on 1/23/2024, response/answer due 2/13/2024; grace-696 served on 1/23/2024, response/answer due 2/13/2024; guitarol.com served on 1/23/2024, response/answer due 2/13/2024; kasunikey_mart234 served on 1/23/2024, response/answer due 2/13/2024; kitchenscamp.com served on 1/23/2024, response/answer due 2/13/2024; kummud0 served on 1/23/2024, response/answer due 2/13/2024; kuruduanilsud_0 served on 1/23/2024, response/answer due 2/13/2024; lhzoutrmall.shop served on 1/23/2024, response/answer due 2/13/2024; merimen229 served on 1/23/2024, response/answer due 2/13/2024; moragoda-242 served on 1/23/2024, response/answer due 2/13/2024; nimantha72 served on 1/23/2024, response/answer due 2/13/2024; osjay47 served on 1/23/2024, response/answer due 2/13/2024; outdoor-gears.com served on 1/23/2024, response/answer due 2/13/2024; outdoor-goods.shop served on 1/23/2024, response/answer due 2/13/2024; outdoor-sporting-supplies.top served on 1/23/2024, response/answer due 2/13/2024; qjzspif_59 served on 1/23/2024, response/answer due 2/13/2024; sajaml97 served on 1/23/2024, response/answer due 2/13/2024; sale-yeti.com served on 1/23/2024, response/answer due 2/13/2024; saraga1997 served on 1/23/2024, response/answer due 2/13/2024; sayban86 served on 1/23/2024, response/answer due 2/13/2024; shecr-5569 served on 1/23/2024, response/answer due 2/13/2024; shefern_259 served on 1/23/2024, response/answer due 2/13/2024; shiungshop.com served on 1/23/2024, response/answer due 2/13/2024; shopmodeusx.com served on 1/23/2024, response/answer due 2/13/2024; shopspinningreels.com served on 1/23/2024, response/answer due 2/13/2024; snaaiee.shop served on 1/23/2024, response/answer due 2/13/2024; sulekan86 served on 1/23/2024, response/answer due 2/13/2024; sura0241 served on 1/23/2024, response/answer due 2/13/2024; tazaki2 served on 1/23/2024, response/answer due 2/13/2024; tharimart served on 1/23/2024, response/answer due 2/13/2024; thhtro_54 served on 1/23/2024, response/answer due 2/13/2024; tiskalpa_0 served on 1/23/2024, response/answer due 2/13/2024; topopen-air.com served on 1/23/2024, response/answer due 2/13/2024; usyeti.com served on 1/23/2024, response/answer due 2/13/2024; vunmiore.top served on 1/23/2024, response/answer due 2/13/2024; yeti-archery.com served on 1/23/2024, response/answer due 2/13/2024; yeti-chairs.top served on 1/23/2024, response/answer due 2/13/2024; yeti-hopper.top served on 1/23/2024, response/answer due 2/13/2024; yeti-official.com served on 1/23/2024, response/answer due 2/13/2024; yeti-online.com served on 1/23/2024, response/answer due 2/13/2024; yeti-online.shop served on 1/23/2024, response/answer due 2/13/2024; yeti-outlet.com served on 1/23/2024, response/answer due 2/13/2024; yeti-refrigerator.shop served on 1/23/2024, response/answer due 2/13/2024; yeti-sale.com served on 1/23/2024, response/answer due 2/13/2024; yetiaubottle.com served on 1/23/2024, response/answer due 2/13/2024; yetiausale.com served on 1/23/2024, response/answer due 2/13/2024; yetiaustralia.com served on 1/23/2024, response/answer due 2/13/2024; yetiaustraliasale.com served on 1/23/2024, response/answer due 2/13/2024; yetibottleau.com served on 1/23/2024, response/answer due 2/13/2024; yetibottleoutlet.com served on 1/23/2024, response/answer due 2/13/2024; yeticup.top served on 1/23/2024, response/answer due 2/13/2024; yeticupsaleau.com served on 1/23/2024, response/answer due 2/13/2024; yetidanmark.com served on 1/23/2024, response/answer due 2/13/2024; yetideutschland.com served on 1/23/2024, response/answer due 2/13/2024; yetifactoryoutlet.com served on 1/23/2024, response/answer due 2/13/2024; yetiforsale.com served on 1/23/2024, response/answer due 2/13/2024; yetigreece.com served on 1/23/2024, response/answer due 2/13/2024; yetihu.com served on 1/23/2024, response/answer due 2/13/2024; yetimxico.com served on 1/23/2024, response/answer due 2/13/2024; yetioutlets.shop served on 1/23/2024, response/answer due 2/13/2024; yetiphilippines.com served on 1/23/2024, response/answer due 2/13/2024; yetis.shop served on 1/23/2024, response/answer due 2/13/2024; yetisale.com served on 1/23/2024, response/answer due 2/13/2024; yetistore.shop served on 1/23/2024, response/answer due 2/13/2024; yetitools.us served on 1/23/2024, response/answer due 2/13/2024; yetiturkey.com served on 1/23/2024, response/answer due 2/13/2024; yetlshop.com served on 1/23/2024, response/answer due 2/13/2024.

Affidavit of Service

Affidavit of Service

Affidavit of Service

Plaintiff's NOTICE upon Defendants via Electronic Mail by YETI COOLERS, LLC re [25] Preliminary Injunction

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by YETI COOLERS, LLC re [25] Preliminary Injunction upon Defendants via website posting

Plaintiff's MOTION for Clerk's Entry of Default as to All Defendants by YETI COOLERS, LLC.

Exhibit

Text of Proposed Order

Clerk's Entry of Default as to The Defendants herein, the Individuals, Partnerships and Unincorporated Associations identified on Schedule A hereto, (collectively Defendants) - Motions Terminated: [30] Motion for Clerks Entry of Default Signed by DEPUTY CLERK on 3/28/2024.

ORDER TO SHOW CAUSE FOR LACK OF PROSECUTION Show Cause Response due by 4/16/2024. Signed by Judge William P. Dimitrouleas on 4/9/2024. See attached document for full details.

Plaintiff's MOTION for Default Judgment Against Defendants and Memorandum of Law in Support Thereof by YETI COOLERS, LLC.

Declaration of Jeni Zuercher in Support Thereof

Exhibit 1 to the Declaration of Jeni Zuercher

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 TO SHOW CAUSE WHY COURT SHOULD NOT GRANT MOTION FOR FINAL DEFAULT JUDGMENT re [33] Plaintiff's MOTION for Default Judgment Against Defendants and Memorandum of Law in Support Thereof filed by YETI COOLERS, LLC. Show Cause Response due by 4/30/2024. Signed by Judge William P. Dimitrouleas on 4/16/2024. See attached document for full details.

CERTIFICATE OF SERVICE by YETI COOLERS, LLC re [34] Order to Show Cause, upon Defendants via Electronic Mail and via Website Posting

ORDER granting [33] Motion for Default Judgment. Signed by Judge William P. Dimitrouleas on 6/10/2024. See attached document for full details.

FINAL DEFAULT JUDGMENT AND PERMANENT INJUNCTION in favor of YETI COOLERS, LLC against 16kvv3l3.online, 211.nilweerra, The Individuals, Business Entities, and Unincorporated Associations, accentonline.top, bkboddxag.shop, buy-yeti.com, cheap-yeti.com, cheapyeti.com, coolersyeti.de, coolersyetiitalia.com, coolersyetinorge.com, coolersyetiperu.com, coolersyetischweiz.com, coolersyetiusa.com, darshanra8901, dertsllpsdt.shop, discount-yeti.com, discountbloc.ru, gayanmaduwanth-224, grace-696, guitarol.com, kasunikey_mart234, kitchenscamp.com, kummud0, kuruduanilsud_0, lhzoutrmall.shop, merimen229, moragoda-242, nimantha72, osjay47, outdoor-gears.com, outdoor-goods.shop, outdoor-sporting-supplies.top, qjzspif_59, sajaml97, sale-yeti.com, saraga1997, sayban86, shecr-5569, shefern_259, shiungshop.com, shopmodeusx.com, shopspinningreels.com, snaaiee.shop, sulekan86, sura0241, tazaki2, tharimart, thhtro_54, tiskalpa_0, topopen-air.com, usyeti.com, vunmiore.top, yeti-archery.com, yeti-chairs.top, yeti-hopper.top, yeti-official.com, yeti-online.com, yeti-online.shop, yeti-outlet.com, yeti-refrigerator.shop, yeti-sale.com, yetiaubottle.com, yetiausale.com, yetiaustralia.com, yetiaustraliasale.com, yetibottleau.com, yetibottleoutlet.com, yeticup.top, yeticupsaleau.com, yetidanmark.com, yetideutschland.com, yetifactoryoutlet.com, yetiforsale.com, yetigreece.com, yetihu.com, yetimxico.com, yetioutlets.shop, yetiphilippines.com, yetis.shop, yetisale.com, yetistore.shop, yetitools.us, yetiturkey.com, yetlshop.com, Closing Case. Signed by Judge William P. Dimitrouleas on 6/10/2024. See attached document for full details.

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