2024-cv-60447

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. Filing fees $ 405.00 receipt number AFLSDC-17386039, filed by Chanel, Inc.

Civil Cover Sheet

Exhibit 1 to Complaint Certificates of Registration for the Chanel 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.

Complaint with Exhibits

Plaintiff's Corporate Disclosure Statement by Chanel, Inc.

Plaintiff's MOTION to Seal per Local Rule 5.4 by Chanel, Inc.

Text of Proposed Order Granting Motion to Seal

ORDER GRANTING MOTION TO FILE UNDER SEAL granting [5] Motion to Seal. Signed by Judge William P. Dimitrouleas on 3/21/2024. See attached document for full details.

Order (Text entry; no document attached.)

Set/Reset Deadlines/Hearings. Preliminary Injunction Hearing set for 4/12/2024 10:10 AM in Fort Lauderdale Division before Judge William P. Dimitrouleas. (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 3/22/2024. See attached document for full details.

Set/Reset Deadlines/Hearings. Preliminary Injunction Hearing set for 4/12/2024 10:10 AM in Fort Lauderdale Division before Judge William P. Dimitrouleas. (Text entry; no document attached.)

Order (Text entry; no document attached.)

Plaintiff's Notice of filing bond by Chanel, Inc. re [11] Order on Ex Parte Motion

Plaintiff's MOTION to Unseal Document Docket Entries 7-9 and 11-14 by Chanel, Inc. Responses due by 4/16/2024.

Text of Proposed Order Granting Motion to Unseal

ORDER GRANTING MOTION TO UNSEAL granting [16] Motion to Unseal Case. 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 4/3/2024. See attached document for full details.

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

AMENDED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants, filed by Chanel, Inc.

Exhibit 1 to Amended Complaint Certificates of Registration for the Chanel Trad

Plaintiff's NOTICE upon Defendants via Electronic Mail by Chanel, Inc. re [11] Order on Ex Parte Motion, [1] Complaint, [10] Order Requiring Joint Scheduling Report

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Chanel, Inc. re [11] Order on Ex Parte Motion, [7] Sealed Document, [6] Order on Motion to Seal, [4] Certificate of Other Affiliates/Corporate Disclosure Statement, [3] Form AO 120/121, [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, [2] Clerks Notice of Judge Assignment, [1] Complaint, [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, [15] Notice (Other), [10] Order Requiring Joint Scheduling Report, [12] Order on Ex Parte Motion, [5] Plaintiff's MOTION to Seal per Local Rule 5.4, [16] Motion to Unseal Case, [13] 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 Chanel, Inc. +852 5217 2839 served on 4/3/2024, response/answer due 4/24/2024; Anna served on 4/3/2024, response/answer due 4/24/2024; Dan TOP Quality LUXURY BAGS Replica served on 4/3/2024, response/answer due 4/24/2024; Decisive riddle served on 4/3/2024, response/answer due 4/24/2024; Hebei Huanbi Trading Co., Ltd. served on 4/3/2024, response/answer due 4/24/2024; Lancebb88 served on 4/3/2024, response/answer due 4/24/2024; Opticiannnnnnd served on 4/3/2024, response/answer due 4/24/2024; Tailwagtoys served on 4/3/2024, response/answer due 4/24/2024; _odin75 served on 4/3/2024, response/answer due 4/24/2024; _rocha_nascimento served on 4/3/2024, response/answer due 4/24/2024; alexluxury6868 served on 4/3/2024, response/answer due 4/24/2024; april_outlet served on 4/3/2024, response/answer due 4/24/2024; bagsshoes_lisa served on 4/3/2024, response/answer due 4/24/2024; baileybag02 served on 4/3/2024, response/answer due 4/24/2024; blxckglam_ served on 4/3/2024, response/answer due 4/24/2024; brookqxpofx served on 4/3/2024, response/answer due 4/24/2024; cdetagsksa served on 4/3/2024, response/answer due 4/24/2024; chanelbagfff served on 4/3/2024, response/answer due 4/24/2024; chanelbagfiri served on 4/3/2024, response/answer due 4/24/2024; chanelbagslover served on 4/3/2024, response/answer due 4/24/2024; chinawholesaler1 served on 4/3/2024, response/answer due 4/24/2024; clothes_china_store served on 4/3/2024, response/answer due 4/24/2024; cooperstone792 served on 4/3/2024, response/answer due 4/24/2024; csacjh12juz7c62 served on 4/3/2024, response/answer due 4/24/2024; dauphine_n8v served on 4/3/2024, response/answer due 4/24/2024; dazgixyi93c served on 4/3/2024, response/answer due 4/24/2024; demirigenci858 served on 4/3/2024, response/answer due 4/24/2024; diorstore66 served on 4/3/2024, response/answer due 4/24/2024; eyameili9sd served on 4/3/2024, response/answer due 4/24/2024; goodgoodsus served on 4/3/2024, response/answer due 4/24/2024; gucci.dior.lv.89 served on 4/3/2024, response/answer due 4/24/2024; hajahbabbbab55 served on 4/3/2024, response/answer due 4/24/2024; hishsu1 served on 4/3/2024, response/answer due 4/24/2024; homeofluxuryy served on 4/3/2024, response/answer due 4/24/2024; j_uliadamota28k served on 4/3/2024, response/answer due 4/24/2024; katherinebill66 served on 4/3/2024, response/answer due 4/24/2024; kathyfashion.co served on 4/3/2024, response/answer due 4/24/2024; kellylin5 served on 4/3/2024, response/answer due 4/24/2024; lilili9205 served on 4/3/2024, response/answer due 4/24/2024; lin_wu_bags served on 4/3/2024, response/answer due 4/24/2024; loveluxury_fanspage served on 4/3/2024, response/answer due 4/24/2024; luxlife served on 4/3/2024, response/answer due 4/24/2024; luxury999designer served on 4/3/2024, response/answer due 4/24/2024; luxurybag532 served on 4/3/2024, response/answer due 4/24/2024; luxurykitten_sicily served on 4/3/2024, response/answer due 4/24/2024; luxurylvbag served on 4/3/2024, response/answer due 4/24/2024; oue1475 served on 4/3/2024, response/answer due 4/24/2024; peachmind168 served on 4/3/2024, response/answer due 4/24/2024; precious.lux served on 4/3/2024, response/answer due 4/24/2024; qiqi_owncollect served on 4/3/2024, response/answer due 4/24/2024; qqiangqiang served on 4/3/2024, response/answer due 4/24/2024; quinncy888 served on 4/3/2024, response/answer due 4/24/2024; richagzw7z7 served on 4/3/2024, response/answer due 4/24/2024; sallynnm1213 served on 4/3/2024, response/answer due 4/24/2024; sarah_bc6 served on 4/3/2024, response/answer due 4/24/2024; seamaid_alex served on 4/3/2024, response/answer due 4/24/2024; shoppingrachel3 served on 4/3/2024, response/answer due 4/24/2024; skeys9764 served on 4/3/2024, response/answer due 4/24/2024; steblevaua served on 4/3/2024, response/answer due 4/24/2024; supersmoothlifes served on 4/3/2024, response/answer due 4/24/2024; topbag102 served on 4/3/2024, response/answer due 4/24/2024; topjijia served on 4/3/2024, response/answer due 4/24/2024; user8618028166651 served on 4/3/2024, response/answer due 4/24/2024; wallacexaviera served on 4/3/2024, response/answer due 4/24/2024; xiangrikui67800 served on 4/3/2024, response/answer due 4/24/2024; xiaozeng4122 served on 4/3/2024, response/answer due 4/24/2024; yoyo_elsa799 served on 4/3/2024, response/answer due 4/24/2024; yoyo_kelly1012 served on 4/3/2024, response/answer due 4/24/2024; yy.yami9 served on 4/3/2024, response/answer due 4/24/2024.

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 Chanel, Inc. 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. (rs00)

ORDER GRANTING APPLICATION FOR ENTRY OF PRELIMINARY INJUNCTION, granting [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 by Chanel, Inc. Signed by Judge William P. Dimitrouleas on 4/12/2024. See attached document for full details.

Plaintiff's NOTICE of Identification of Additional PayPal Accounts Used By Defendant Numbers 2, 3, and 47 by Chanel, Inc.

Declaration of Eric Rosaler in Support Thereof

Exhibit 1 to the Rosaler Declaration

Declaration of Kathleen Burns in Support Thereof

Exhibit 1 to the Burns Declaration

ORDER TO SHOW CAUSE FOR LACK OF PROSECUTION. Plaintiff, on or before May 9, 2024, shall either move for Clerk's Entry of Default against Defendants or show cause why Plaintiff's claims should not be dismissed for a lack of prosecution. Signed by Judge William P. Dimitrouleas on 5/2/2024. See attached document for full details.

Plaintiff's NOTICE upon Defendants via Electronic Mail by Chanel, Inc. re [24] Preliminary Injunction

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Chanel, Inc. re [24] Preliminary Injunction, upon Defendants via website posting

Plaintiff's MOTION for Clerk's Entry of Default as to +852 5217 2839, Anna, Dan TOP Quality LUXURY BAGS Replica, Decisive riddle, Hebei Huanbi Trading Co., Ltd., Lancebb88, Opticiannnnnnd, Tailwagtoys, The Individuals, Business Entities, and Unincorporated Associations Identified on Schedule A, _odin75, _rocha_nascimento, alexluxury6868, april_outlet, bagsshoes_lisa, baileybag02, blxckglam_, brookqxpofx, cdetagsksa, chanelbagfff, chanelbagfiri, chanelbagslover, chinawholesaler1, clothes_china_store, cooperstone792, csacjh12juz7c62, dauphine_n8v, dazgixyi93c, demirigenci858, diorstore66, eyameili9sd, goodgoodsus, gucci.dior.lv.89, hajahbabbbab55, hishsu1, homeofluxuryy, j_uliadamota28k, katherinebill66, kathyfashion.co, kellylin5, lilili9205, lin_wu_bags, loveluxury_fanspage, luxlife, luxury999designer, luxurybag532, luxurykitten_sicily, luxurylvbag, oue1475, peachmind168, precious.lux, qiqi_owncollect, qqiangqiang, quinncy888, richagzw7z7, sallynnm1213, sarah_bc6, seamaid_alex, shoppingrachel3, skeys9764, steblevaua, supersmoothlifes, topbag102, topjijia, user8618028166651, wallacexaviera, xiangrikui67800, xiaozeng4122, yoyo_elsa799, yoyo_kelly1012, yy.yami9 by Chanel, Inc.

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, and Unincorporated Associations identified on Schedule "A" hereto, (collectively "Defendants") - Motions Terminated: [29] Motion for Clerks Entry of Default Signed by DEPUTY CLERK on 5/8/2024.

ORDER TO SHOW CAUSE FOR LACK OF PROSECUTION. Show Cause Response due by 5/28/2024. Signed by Judge William P. Dimitrouleas on 5/20/2024. See attached document for full details.

Plaintiff's MOTION for Default Judgment and Memorandum of Law in Support Thereof by Chanel, Inc.

Declaration of Elizabeth Han in Support Thereof

Exhibit 1 to the Declaration of Elizabeth Han

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: re [32] Plaintiff's MOTION for Default Judgment and Memorandum of Law in Support Thereof filed by Chanel, Inc. On or before June 7, 2024, Defendants shall respond to this Order, showing cause why the Court should not grant a default judgment against Defendants. Failure to respond will result in the entry of a default judgement against Defendants. Show Cause Response due by 6/7/2024. Signed by Judge William P. Dimitrouleas on 5/24/2024. See attached document for full details.

CERTIFICATE OF SERVICE by Chanel, Inc. re [33] Order to Show Cause, upon Defendants via Electronic Mail and via Website Posting

ORDER granting [32] Motion for Final 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 Chanel, Inc. against +852 5217 2839, Anna, Dan TOP Quality LUXURY BAGS Replica, Decisive riddle, Hebei Huanbi Trading Co., Ltd., Lancebb88, Opticiannnnnnd, Tailwagtoys, _odin75, _rocha_nascimento, alexluxury6868, april_outlet, bagsshoes_lisa, baileybag02, blxckglam_, brookqxpofx, cdetagsksa, chanelbagfff, chanelbagfiri, chanelbagslover, chinawholesaler1, clothes_china_store, cooperstone792, csacjh12juz7c62, dauphine_n8v, dazgixyi93c, demirigenci858, diorstore66, eyameili9sd, goodgoodsus, gucci.dior.lv.89, hajahbabbbab55, hishsu1, homeofluxuryy, j_uliadamota28k, katherinebill66, kathyfashion.co, kellylin5, lilili9205, lin_wu_bags, loveluxury_fanspage, luxlife, luxury999designer, luxurybag532, luxurykitten_sicily, luxurylvbag, oue1475, peachmind168, precious.lux, qiqi_owncollect, qqiangqiang, quinncy888, richagzw7z7, sallynnm1213, sarah_bc6, seamaid_alex, shoppingrachel3, skeys9764, steblevaua, supersmoothlifes, topbag102, topjijia, user8618028166651, wallacexaviera, xiangrikui67800, xiaozeng4122, yoyo_elsa799, yoyo_kelly1012, yy.yami9; 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

Supplement Final Default Judgment and Permanent Injunction

Plaintiff's MOTION/APPLICATION for Writ of Garnishment on PayPal, Inc. After Judgment by Chanel, Inc.

Text of Proposed Order Writ of Garnishment as to PayPal, Inc.

Clerks Notice of Non-Issuance of WRIT OF GARNISHMENT as to Garnishee PayPal, Inc. Missing Amount indicated on Judgment re: 38 Motion for Writ filed by Chanel, Inc.

Amended MOTION/APPLICATION for Writ of Garnishment on PayPal, Inc. After Judgment by Chanel, Inc.

Text of Proposed Order Writ of Garnishment as to PayPal, Inc.

WRIT OF GARNISHMENT issued as to Garnishee PAYPAL, INC. in the amount of $ 1,000,000.00

CERTIFICATE OF SERVICE by Chanel, Inc. re [40] Amended MOTION/APPLICATION for Writ of Garnishment on PayPal, Inc. After Judgment, [41] Writ of Garnishment

ANSWER to Writ of Garnishment To Respond To Plaintiff's Complaint by The Individuals, Business Entities, and Unincorporated Associations Identified on Schedule A. Reply/Objections to Writ Answer due by 7/14/2025.

CERTIFICATE OF SERVICE by Chanel, Inc. re [43] Answer to Writ of Garnishment and Notice Pursuant to Section 77.055 of the Florida Statutes

Exhibit A - Service Packet

Plaintiff's NOTICE of Voluntary Dissolution of Garnishment Claim Against PayPal, Inc. by Chanel, Inc. re [41] Writ of Garnishment