2024-cv-60494

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. Filing fees $ 405.00 receipt number AFLSDC-17404724, filed by Chanel, Inc.

Civil Cover Sheet

Exhibit 1 to Complaint Certificates of Registration for the Chanel Trademarks

Clerk's 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.

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

Complaint

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 [5] 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 3/29/2024. 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 4/1/2024. See attached document for full details.

Order (Text entry; no document attached.)

NOTICE OF FILING BOND by Chanel, Inc.

Plaintiff's MOTION to Unseal Document Docket Entries 7-11 and 13-14 by Chanel, Inc. Responses due by 4/23/2024.

Text of Proposed Order Granting Motion to Unseal

ORDER Granting [16] Motion to Unseal Documents Docket Entries 7-11 and 13-14. 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.

NOTICE of Compliance re 17 Order on Motion to Unseal Documents. All docketing entries in this case have been unsealed per DE#17.

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 [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 MOTION for Preliminary Injunction, [12] Order Requiring Joint Scheduling Report, [1] Complaint, [11] Order on Ex Parte Motion, Order on Motion for Preliminary Injunction

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Chanel, Inc. re [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 MOTION for Preliminary Injunction, [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, [16] Plaintiff's MOTION to Unseal Document Docket Entries 7-11 and 13-14, [11] Order on Ex Parte Motion, Order on Motion for Preliminary Injunction, [15] Notice (Other), [2] Clerks Notice of Judge Assignment, [12] Order Requiring Joint Scheduling Report, [6] Order on Motion to Seal, [10] Order on Ex Parte Motion, [7] Sealed Document, [1] Complaint, [13] Sealed Document, [5] Plaintiff's MOTION to Seal per Local Rule 5.4 upon Defendants via website posting

SUMMONS (Affidavit) Returned Executed on [19] Amended Complaint/Amended Notice of Removal, [1] Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Chanel, Inc. 486HaoDian served on 4/10/2024, response/answer due 5/1/2024; Anqing Mota Trading Co., Ltd. served on 4/10/2024, response/answer due 5/1/2024; Anqing Mutuo Trading Co., Ltd. served on 4/10/2024, response/answer due 5/1/2024; Appoanmsmdd served on 4/10/2024, response/answer due 5/1/2024; Bellaqueo served on 4/10/2024, response/answer due 5/1/2024; Blue Moon Info Jewels served on 4/10/2024, response/answer due 5/1/2024; Bright Info Jewels served on 4/10/2024, response/answer due 5/1/2024; Debby05 Jewelry-US served on 4/10/2024, response/answer due 5/1/2024; DongMS served on 4/10/2024, response/answer due 5/1/2024; Fineline Stops served on 4/10/2024, response/answer due 5/1/2024; Guangzhou Fuci Trading Co., Lt served on 4/10/2024, response/answer due 5/1/2024; Guangzhouhuatongshangmaoyouxiangongsi served on 4/10/2024, response/answer due 5/1/2024; Guyuanshiyuanzhouqukunkunmeijiadian served on 4/10/2024, response/answer due 5/1/2024; Hong-Jiu served on 4/10/2024, response/answer due 5/1/2024; Hongye flagship store-US served on 4/10/2024, response/answer due 5/1/2024; JiaoJingShangMao served on 4/10/2024, response/answer due 5/1/2024; Johone served on 4/10/2024, response/answer due 5/1/2024; Kanha Enterprises0 served on 4/10/2024, response/answer due 5/1/2024; Kuka Home served on 4/10/2024, response/answer due 5/1/2024; Leaotig served on 4/10/2024, response/answer due 5/1/2024; Love Crystal store served on 4/10/2024, response/answer due 5/1/2024; MAS Leather Works served on 4/10/2024, response/answer due 5/1/2024; Nikalp Cam served on 4/10/2024, response/answer due 5/1/2024; Rita jewelry US served on 4/10/2024, response/answer due 5/1/2024; Ritanjali Jewels served on 4/10/2024, response/answer due 5/1/2024; SamarthCreations served on 4/10/2024, response/answer due 5/1/2024; Shi Yi Shop served on 4/10/2024, response/answer due 5/1/2024; ShiLisPeng served on 4/10/2024, response/answer due 5/1/2024; Tishya Jewellers served on 4/10/2024, response/answer due 5/1/2024; Unique Info Jewels served on 4/10/2024, response/answer due 5/1/2024; WangChengQiongXiaoDian served on 4/10/2024, response/answer due 5/1/2024; Wenning us served on 4/10/2024, response/answer due 5/1/2024; Wtuuina served on 4/10/2024, response/answer due 5/1/2024; XingYiMinggMinWangLuoKeJi served on 4/10/2024, response/answer due 5/1/2024; YANrong served on 4/10/2024, response/answer due 5/1/2024; YaMiStore served on 4/10/2024, response/answer due 5/1/2024; Yongsong Firm served on 4/10/2024, response/answer due 5/1/2024; Zhang Yu Cheng served on 4/10/2024, response/answer due 5/1/2024; Zhijiangshihaoqiushangmaoyouxiangongsi served on 4/10/2024, response/answer due 5/1/2024; ZhuYiLiangGKDSMFVKLD served on 4/10/2024, response/answer due 5/1/2024; changzhichonghuishangmaoyouxiangongsi served on 4/10/2024, response/answer due 5/1/2024; chuanhu-US served on 4/10/2024, response/answer due 5/1/2024; feidedianpu served on 4/10/2024, response/answer due 5/1/2024; hkj378256 served on 4/10/2024, response/answer due 5/1/2024; paibojingpin served on 4/10/2024, response/answer due 5/1/2024; piaodib-us served on 4/10/2024, response/answer due 5/1/2024; qujingshiqilinquruiwenshangdian served on 4/10/2024, response/answer due 5/1/2024; shenzhenxuannannvzhuang served on 4/10/2024, response/answer due 5/1/2024; spkeou-Jewelry served on 4/10/2024, response/answer due 5/1/2024; xxysm served on 4/10/2024, response/answer due 5/1/2024; yuanshengjilirenyiliaomeirongyouxianzerengongsi served on 4/10/2024, response/answer due 5/1/2024; zhoutingyan-US 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 MOTION for Preliminary Injunction 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.

Order (Text entry; no document attached.)

ORDER GRANTING 8 APPLICATION FOR ENTRY OF PRELIMINARY INJUNCTION. Signed by Judge William P. Dimitrouleas on 4/12/2024. See attached document for full details. (caw) Modified security on 4/16/2024

Plaintiff's NOTICE upon Defendants via Electronic Mail by Chanel, Inc. re [24] Order on Ex Parte Motion, Order on Motion for Preliminary Injunction

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Chanel, Inc. re [24] Order on Ex Parte Motion, Order on Motion for Preliminary Injunction upon Defendants via website posting

Plaintiff's MOTION for Clerk's Entry of Default as to 486HaoDian, Anqing Mota Trading Co., Ltd., Anqing Mutuo Trading Co., Ltd., Appoanmsmdd, Bellaqueo, Blue Moon Info Jewels, Bright Info Jewels, Debby05 Jewelry-US, DongMS, Fineline Stops, Guangzhou Fuci Trading Co., Lt, Guangzhouhuatongshangmaoyouxiangongsi, Guyuanshiyuanzhouqukunkunmeijiadian, Hong-Jiu, Hongye flagship store-US, JiaoJingShangMao, Johone, Kanha Enterprises0, Kuka Home, Leaotig, Love Crystal store, MAS Leather Works, Nikalp Cam, Rita jewelry US, Ritanjali Jewels, SamarthCreations, Shi Yi Shop, ShiLisPeng, The Individuals, Business Entities and Unincorporated Associations Identified on Schedule A, Tishya Jewellers, Unique Info Jewels, WangChengQiongXiaoDian, Wenning us, Wtuuina, XingYiMinggMinWangLuoKeJi, YANrong, YaMiStore, Yongsong Firm, Zhang Yu Cheng, Zhijiangshihaoqiushangmaoyouxiangongsi, ZhuYiLiangGKDSMFVKLD, changzhichonghuishangmaoyouxiangongsi, chuanhu-US, feidedianpu, hkj378256, paibojingpin, piaodib-us, qujingshiqilinquruiwenshangdian, shenzhenxuannannvzhuang, spkeou-Jewelry, xxysm, yuanshengjilirenyiliaomeirongyouxianzerengongsi, zhoutingyan-US 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 486HaoDian, Anqing Mota Trading Co., Ltd., Anqing Mutuo Trading Co., Ltd., Appoanmsmdd, Bellaqueo, Blue Moon Info Jewels, Bright Info Jewels, Debby05 Jewelry-US, DongMS, Fineline Stops, Guangzhou Fuci Trading Co., Lt, Guangzhouhuatongshangmaoyouxiangongsi, Guyuanshiyuanzhouqukunkunmeijiadian, Hong-Jiu, Hongye flagship store-US, JiaoJingShangMao, Johone, Kanha Enterprises0, Kuka Home, Leaotig, Love Crystal store, MAS Leather Works, Nikalp Cam, Rita jewelry US, Ritanjali Jewels, SamarthCreations, Shi Yi Shop, ShiLisPeng, The Individuals, Business Entities and Unincorporated Associations Identified on Schedule A, Tishya Jewellers, Unique Info Jewels, WangChengQiongXiaoDian, Wenning us, Wtuuina, XingYiMinggMinWangLuoKeJi, YANrong, YaMiStore, Yongsong Firm, Zhang Yu Cheng, Zhijiangshihaoqiushangmaoyouxiangongsi, ZhuYiLiangGKDSMFVKLD, changzhichonghuishangmaoyouxiangongsi, chuanhu-US, feidedianpu, hkj378256, paibojingpin, piaodib-us, qujingshiqilinquruiwenshangdian, shenzhenxuannannvzhuang, spkeou-Jewelry, xxysm, yuanshengjilirenyiliaomeirongyouxianzerengongsi, and zhoutingyan-US. Signed by DEPUTY CLERK on 5/17/2024.

ORDER To Show Cause For Lack Of Prosecution. Show Cause Response due by 6/5/2024. Signed by Judge William P. Dimitrouleas on 5/29/2024. See attached document for full details.

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

Declaration of Elizabeth Han in Support of Plaintiff's Motion for Entry of

Exhibit 1 to Decl. of Elizabeth Han

Declaration of Stephen M. Gaffigan in Support of Motion for Final Default Judgm

Text of Proposed Order Granting Motion for Entry of Final Default Judgment

Text of Proposed Order Granting Final Default Judgment Against Defendants

ORDER TO SHOW CAUSE WHY COURT SHOULD NOT GRANT [30] MOTION FOR FINAL DEFAULT JUDGMENT: On or before June 13 2024, Defendants shall Show Cause why this Motion should not be granted. A failure to respond by that deadline will result in the Court granting Plaintiff's Motion. Show Cause Response due by 6/13/2024. Signed by Judge William P. Dimitrouleas on 5/30/2024. See attached document for full details.

ORDER GRANTING [30] MOTION FOR FINAL DEFAULT JUDGMENT. Signed by Judge William P. Dimitrouleas on 6/14/2024. See attached document for full details.

FINAL DEFAULT JUDGMENT AND PERMANENT INJUNCTION in favor of Chanel, Inc. against The Individuals, Business Entities and Unincorporated Associations Identified on Schedule A. CLOSING CASE. Signed by Judge William P. Dimitrouleas on 6/14/2024. See attached document for full details.

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

Final Default Judgment