2024-cv-60442

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. Filing fees $ 405.00 receipt number AFLSDC-17383226, 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 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. Pro se (NON-PRISONER) litigants may receive Notices of Electronic Filings (NEFS) via email after filing a Consent by Pro Se Litigant (NON-PRISONER) to Receive Notices of Electronic Filing. The consent form is available under the forms section of our website.

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

ORDER granting [4] Motion to File Under Seal. Schedule "A" to Plaintiff's Complaint and the Summonses shall be filed under seal and shall remain under seal until further order from this Court. Signed by Judge William P. Dimitrouleas on 3/21/2024. See attached document for full details.

Order (Text entry; no document attached.)

ORDER REQUIRING COUNSEL TO MEET, FILE JOINT SCHEDULING REPORT AND JOINT DISCOVERY REPORT. Signed by Judge William P. Dimitrouleas on 3/21/2024. See attached document for full details.

Order (Text entry; no document attached.)

Plaintiff's NOTICE of Filing Bond by Tiffany (NJ) LLC

Plaintiff's MOTION to Unseal Document Entries 6 and 8-13 by Tiffany (NJ) LLC. Responses due by 4/22/2024.

Text of Proposed Order Granting Motion to Unseal

ORDER Granting [15] Plaintiff's Motion To Unseal. The Clerk of the Court is hereby DIRECTED to unseal all docket entries in this case and return those portions of the Court file to the public records. Signed by Judge William P. Dimitrouleas on 4/9/2024. 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

Plaintiff's NOTICE upon Defendants via Electronic Mail by Tiffany (NJ) LLC re [1] Complaint, [7] Order Requiring Joint Scheduling Report, [10] 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

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Tiffany (NJ) LLC re [3] Certificate of Other Affiliates/Corporate Disclosure Statement, [10] Order on Ex Parte Motion, [1] Complaint, [11] Order on Ex Parte Motion, [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, [2] Clerks Notice of Judge Assignment, [5] Order on Motion to Seal, [7] Order Requiring Joint Scheduling Report, [12] Sealed Document, [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, [4] Plaintiff's MOTION to Seal per Local Rule 5.4, [15] Plaintiff's MOTION to Unseal Document Entries 6 and 8-13, [14] Notice (Other) upon Defendants via website posting

SUMMONS (Affidavit) Returned Executed on [17] Amended Complaint/Amended Notice of Removal, [1] Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Tiffany (NJ) LLC. 2024shopping.ru served on 4/10/2024, response/answer due 5/1/2024; ChristmasGiftsCoShop served on 4/10/2024, response/answer due 5/1/2024; Tiffany&Co.(CA) served on 4/10/2024, response/answer due 5/1/2024; anJiaJiaShangMaoYouXianGongSi served on 4/10/2024, response/answer due 5/1/2024; bagaethnik.com served on 4/10/2024, response/answer due 5/1/2024; buyonbest.com served on 4/10/2024, response/answer due 5/1/2024; chaumalls.com served on 4/10/2024, response/answer due 5/1/2024; coocarit.com served on 4/10/2024, response/answer due 5/1/2024; dorrisa.com served on 4/10/2024, response/answer due 5/1/2024; geargrand.com served on 4/10/2024, response/answer due 5/1/2024; kickwell.999 served on 4/10/2024, response/answer due 5/1/2024; majesticloom.club served on 4/10/2024, response/answer due 5/1/2024; mallshoptp.com served on 4/10/2024, response/answer due 5/1/2024; mygodjewelry.com served on 4/10/2024, response/answer due 5/1/2024; newrgys.com served on 4/10/2024, response/answer due 5/1/2024; replicatiffany.com served on 4/10/2024, response/answer due 5/1/2024; rogerdystore.com served on 4/10/2024, response/answer due 5/1/2024; topfactory66 served on 4/10/2024, response/answer due 5/1/2024; topjacky.com served on 4/10/2024, response/answer due 5/1/2024; wonderkicks.ru served on 4/10/2024, response/answer due 5/1/2024.

Affidavit of Service

Affidavit of Service

PAPERLESS Minute Entry for proceedings held before Judge William P. Dimitrouleas: Motion Hearing held on 4/12/2024 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 Tiffany (NJ) LLC. No Defendants appeared. Court will enter an Order granting the preliminary injunction motion. Total time in court: 5 minutes. Attorney Appearance(s): T. Raquel Wiborg-Rodriguez, Court Reporter: Ellen Rassie, 954-769-5448 / ellen_rassie@flsd.uscourts.gov.

Order (Text entry; no document attached.)

ORDER GRANTING APPLICATION FOR ENTRY OF PRELIMINARY INJUNCTION. ORDER granting [8] Ex Parte Motion. Signed by Judge William P. Dimitrouleas on 4/12/2024. See attached document for full details.

CLERK'S NOTICE re [22] Order on Ex Parte Motion. Additional Notice of Electronic Filing (NEF) sent to Christine Ann Daley, Mallory Ruth Denzl, T. Raquel Wiborg-Rodriguez, Virgilio Gigante, Stephen Michael Gaffigan

Plaintiff's MOTION for Clerk's Entry of Default as to 2024shopping.ru, ChristmasGiftsCoShop, The Individuals, Business Entities, and Unincorporated Associations, Tiffany&Co.(CA), anJiaJiaShangMaoYouXianGongSi, bagaethnik.com, buyonbest.com, chaumalls.com, coocarit.com, dorrisa.com, geargrand.com, kickwell.999, majesticloom.club, mallshoptp.com, mygodjewelry.com, newrgys.com, replicatiffany.com, rogerdystore.com, topfactory66, topjacky.com, wonderkicks.ru 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 2024shopping.ru, ChristmasGiftsCoShop, Tiffany&Co.(CA), anJiaJiaShangMaoYouXianGongSi, bagaethnik.com, buyonbest.com, chaumalls.com, coocarit.com, dorrisa.com, geargrand.com, kickwell.999, majesticloom.club, mallshoptp.com, mygodjewelry.com, newrgys.com, replicatiffany.com, rogerdystore.com, topfactory66, topjacky.com, wonderkicks.ru - Motions Terminated: 24 Motion for Clerks Entry of Default, Signed by DEPUTY CLERK on 5/6/2024.

ORDER TO SHOW CAUSE FOR LACK OF PROSECUTION. Show Cause Response due by 5/24/2024. Signed by Judge William P. Dimitrouleas on 5/17/2024. See attached document for full details.

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 Default Final Judgment

Text of Proposed Order Default Final Judgment and Permanent Injunction

ORDER TO SHOW CAUSE WHY COURT SHOULD NOT GRANT MOTION FOR DEFAULT FINAL JUDGMENT. Show Cause Response due by 6/6/2024. Signed by Judge William P. Dimitrouleas on 5/24/2024. See attached document for full details.

CERTIFICATE OF SERVICE by Tiffany (NJ) LLC re [28] Order to Show Cause upon Defendants via Electronic Mail and via Website Posting

ORDER GRANTING MOTION FOR DEFAULT FINAL JUDGMENT re [27] Motion for Default Judgment. Signed by Judge William P. Dimitrouleas on 6/7/2024. See attached document for full details.

DEFAULT FINAL JUDGMENT AND PERMANENT INJUNCTION in favor of Tiffany (NJ) LLC against 2024shopping.ru, ChristmasGiftsCoShop, The Individuals, Business Entities, and Unincorporated Associations, Tiffany (NJ) LLC, anJiaJiaShangMaoYouXianGongSi, bagaethnik.com, buyonbest.com, chaumalls.com, coocarit.com, dorrisa.com, geargrand.com, kickwell.999, majesticloom.club, mallshoptp.com, mygodjewelry.com, newrgys.com, replicatiffany.com, rogerdystore.com, topfactory66, topjacky.com, wonderkicks.ru. This Clerk shall CLOSE this case and DENY AS MOOT any pending motions. Signed by Judge William P. Dimitrouleas on 6/7/2024. See attached document for full details.

FORM AO 120 SENT TO DIRECTOR OF U.S. PATENT AND TRADEMARK (Copy of AO Form and Order sent)

Order

Plaintiff's NOTICE upon Defendants via Electronic Mail by Tiffany (NJ) LLC re [31] Default Judgment, Permanent Injunction, [30] Order on Motion for Default Judgment

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Tiffany (NJ) LLC re [31] Default Judgment, Permanent Injunction, [30] Order on Motion for Default Judgment, upon Defendants via website posting