2024-cv-60156

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. Filing fees $ 405.00 receipt number AFLSDC-17248335, filed by Cartier International A.G., Van Cleef & Arpels SA.

Civil Cover Sheet

Exhibit 1 to the Complaint Certificates of Registration for the CARTIER Tradema

Exhibit 2 to the Complaint Certificates of Registration for the VAN CLEEF Trade

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 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.

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

Plaintiff's Corporate Disclosure Statement by Cartier International A.G., Van Cleef & Arpels SA identifying Corporate Parent Compagnie Financiere Richemont SA for Cartier International A.G., Van Cleef & Arpels SA

Plaintiff's MOTION to Seal per Local Rule 5.4 by Cartier International A.G., Van Cleef & Arpels SA.

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 2/1/2024.

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 2/1/2024.

Plaintiff's Certificate of Other Affiliates by Cartier International A.G., Van Cleef & Arpels SA

ORDER TO FILE UNDER SEAL granting [5] Motion to Seal. Signed by Judge Raag Singhal on 2/2/2024. See attached document for full details.

Order (Text entry; no document attached.)

Plaintiff's MOTION to Unseal Document Docket Entries 6-7, 12-17 by Cartier International A.G., Van Cleef & Arpels SA. Responses due by 2/21/2024.

Text of Proposed Order

AMENDED COMPLAINT against All Defendants, filed by Cartier International A.G., Van Cleef & Arpels SA.

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

Exhibit 2 to Amended Complaint Certificates of Registration for the VAN CLEEF T

ORDER granting [18] Motion to Unseal Case. The Clerk of Court is DIRECTED to unseal all docket entries in this case and return those portions of the Court file to the public records. Signed by Judge Raag Singhal on 2/13/2024. See attached document for full details.

Clerk's NOTICE of Compliance re 20 Order on Motion to Unseal Case. All Docket Entries Unsealed.

Plaintiff's NOTICE upon Defendants via Electronic Mail by Cartier International A.G., Van Cleef & Arpels SA re [12] Order on Ex Parte Motion, [1] Complaint

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Cartier International A.G., Van Cleef & Arpels SA re [2] Clerks Notice of Judge Assignment, [11] Order on Motion to Seal, [4] Certificate of Other Affiliates/Corporate Disclosure Statement, [8] Notice of Court Practice/to Appear/Other, [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, [13] Order on Ex Parte Motion, [5] Plaintiff's MOTION to Seal per Local Rule 5.4, [10] Certificate of Other Affiliates/Corporate Disclosure Statement, [18] Motion to Unseal Case, [14] Sealed Document, [12] Order on Ex Parte Motion, [1] Complaint, [9] Order, [3] Form AO 120/121, [7] Plaintiff's EX PARTE MOTION for Order Authorizing Alternate Service of Process on Defendant Pursuant to Federal Rule of Civil Procedure 4(f)(3) and Memorandum of Law in Support Thereof, [15] Sealed Document, [17] 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 Cartier International A.G., Van Cleef & Arpels SA. The Individual, Business Entity, or Unincorporated Association served on 2/9/2024, response/answer due 3/1/2024.

Affidavit of Service

Affidavit of Service

PAPERLESS Minute Entry for proceedings held before Judge Raag Singhal: Evidentiary Motion Hearing held on 2/15/2024 re 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 filed by Van Cleef & Arpels SA, Cartier International A.G. No defendants appeared. Order forthcoming. Total time in court: 0 hour(s) : 15 minutes. Attorney Appearance(s): Christine Ann Daley. Court Reporter: Karl Shires, 954-769-5496 / Karl_Shires@flsd.uscourts.gov. (lp00)

ORDER GRANTING APPLICATION FOR ENTRY OF PRELIMINARY INJUNCTION, granting [6] Application for Entry of Preliminary Injunction. Signed by Judge Raag Singhal on 2/20/2024. See attached document for full details.

Plaintiff's NOTICE of Identification of Additional Aliases and Additional Payment Accounts Used by Defendant by Cartier International A.G., Van Cleef & Arpels SA

Declaration of Kathleen Burns in Support Thereof

Exhibit 1 to the Declaration of Kathleen Burns - Part 1

Exhibit 1 to the Declaration of Kathleen Burns - Part 2

Exhibit 1 to the Declaration of Kathleen Burns - Part 3

Exhibit 1 to the Declaration of Kathleen Burns - Part 4

Exhibit 1 to the Declaration of Kathleen Burns - Part 5

Exhibit 1 to the Declaration of Kathleen Burns - Part 6

Plaintiff's NOTICE upon Defendant via Electronic Mail by Cartier International A.G., Van Cleef & Arpels SA re [26] Preliminary Injunction

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Cartier International A.G., Van Cleef & Arpels SA re [26] Preliminary Injunction upon Defendant via website posting

Plaintiff's MOTION for Clerk's Entry of Default as to All Defendants by Cartier International A.G., Van Cleef & Arpels SA.

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

Text of Proposed Order

Clerk's Entry of Default as to The Individual, Business Entity, or Unincorporated Association - Motions Terminated: 30 Motion for Clerks Entry of Default, Signed by DEPUTY CLERK on 3/7/2024.

Plaintiff's NOTICE of Identification of Additional Aliases and Additional Payment Account Used by Defendant by Cartier International A.G., Van Cleef & Arpels SA

Declaration of Kathleen Burns in Support Thereof

(Exhibit 1 to the Declaration of Kathleen Burns)

Plaintiff's MOTION for Default Judgment Against Defendant and Memorandum of Law in Support Thereof by Cartier International A.G., Van Cleef & Arpels SA.

Declaration of Emma-Jane Tritton in Support Thereof

Exhibit 1 to the Declaration of Emma-Jane Tritton

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 [33] Motion for Final Default Judgment. Signed by Judge Raag Singhal on 7/23/2024. See attached document for full details.

DEFAULT FINAL JUDGMENT AND PERMANENT INJUNCTION: DEFAULT JUDGMENT in favor of Cartier International A.G., Van Cleef & Arpels SA and against The Individual, Business Entity, or Unincorporated Association, the Individual, Business Entity, or Unincorporated Association. The Clerk of Court is directed to CLOSE the case and DENY AS MOOT any pending motions. Closing Case. Signed by Judge Raag Singhal on 7/23/2024. See attached document for full details.

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

Judgment from DE#35