2024-cv-61245

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. Filing fees $ 405.00 receipt number AFLSDC-17680664, filed by Gucci America, Inc.

Civil Cover Sheet

Exhibit 1 to Complaint - Certificates of Registration for the Gucci Trademarks

Clerks Notice of Judge Assignment to Judge Rodney Smith. 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 Certificate of Other Affiliates/Corporate Disclosure Statement by Gucci America, Inc. identifying Corporate Parent Kering Americas, Inc., Corporate Parent Kering Holland NV, Corporate Parent Kering SA for Gucci America, Inc. (Wiborg-Rodriguez, T.)

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

(Text of Proposed Order) (Wiborg-Rodriguez, T.)

SYSTEM ENTRY - Docket Entry 6 [motion] restricted/sealed until further notice. (1336528)

SYSTEM ENTRY - Docket Entry 7 [motion] restricted/sealed until further notice. (1336528)

Notice of Ninety Days Expiring Regarding Docket Entries 6 and 7 by Gucci America, Inc. (Wiborg-Rodriguez, T.)

PAPERLESS ORDER granting 5 Plaintiff's Motion to Seal. Plaintiff may file Schedule "A" to the Complaint under seal. The document shall remain under seal until further order of the Court. Signed by Judge Rodney Smith on 1/2/2025. (kv00)

Order

PLAINTIFF'S NOTICE OF FILING BOND. Surety BOND in the amount of $$10,000 posted by Gucci America, Inc. Approved by Judge Rodney Smith.

PAPERLESS NOTICE of Hearing: Pursuant to DE 11 Telephonic Motion Hearing set for 1/23/2025 09:30 AM in Fort Lauderdale Division before Judge Rodney Smith. Counsel shall call the audio conference toll-free number 833-435-1820, five (5) minutes prior to the start of the hearing. As prompted enter the Meeting ID number, 161-394-8699. The system will request a Participant ID, please disregard. As prompted enter the Passcode 632303. Counsel shall enter *6 to unmute and state your name and the name of the party you represent.

Plaintiff's MOTION to Unseal Case by Gucci America, Inc. Responses due by 1/30/2025.

Text of Proposed Order

ORDER granting [15] Motion to Unseal Case. Signed by Judge Rodney Smith on 1/22/2025. See attached document for full details.

NOTICE of Compliance re [16] Order on Motion to Unseal Case. (All docket entries Unsealed)

Plaintiff's NOTICE of E-Mail Correspondence Received in Connection with Notice by Gucci America, Inc.

Exhibit 1 to the to the Notice of E-mail Correspondence

Plaintiff's NOTICE upon Defendants via Electronic Mail by Gucci America, Inc. re [11] Order on Ex Parte Motion, Order on Motion for Temporary Restraining Order, [6] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order, Preliminary Injunction, and Order Restraining Transfer of Assets Against Defendants and Memorandum of Law in Support Thereof MOTION for Temporary Restraining Order MOTION for Preliminary Injunction, [14] Notice re Hearing, [1] Complaint, [15] Plaintiff's MOTION to Unseal Case

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Gucci America, Inc. re [9] Order on Motion to Seal, [10] Sealed Document, [11] Order on Ex Parte Motion, Order on Motion for Temporary Restraining Order, [5] Plaintiff's MOTION to Seal per Local Rule 5.4, [13] Bond, [6] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order, Preliminary Injunction, and Order Restraining Transfer of Assets Against Defendants and Memorandum of Law in Support Thereof MOTION for Temporary Restraining Order MOTION for Preliminary Injunction, [8] Notice of Ninety Days Expiring, [14] Notice re Hearing, [7] 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, [4] Certificate of Other Affiliates/Corporate Disclosure Statement, [1] Complaint, [3] Form AO 120/121, [15] Plaintiff's MOTION to Unseal Case, [12] Order on Ex Parte Motion, upon Defendants via website posting

CERTIFICATE OF SERVICE by Gucci America, Inc. re [11] Order on Ex Parte Motion, Order on Motion for Temporary Restraining Order, [6] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order, Preliminary Injunction, and Order Restraining Transfer of Assets Against Defendants and Memorandum of Law in Support Thereof MOTION for Temporary Restraining Order MOTION for Preliminary Injunction, [14] Notice re Hearing, [1] Complaint, [15] Plaintiff's MOTION to Unseal Case upon Defendants via Registrar

NOTICE of Attorney Appearance by Christine Ann Daley on behalf of Gucci America, Inc. Attorney Christine Ann Daley added to party Gucci America, Inc. (pty:pla).

PAPERLESS Minute Entry for proceedings held before Judge Rodney Smith: Telephone hearing on preliminary injunction held on 1/23/2025, 9:30-9:33, after hearing from counsel, the Court granted motion, order to follow. Attorney Appearance(s): Christine Ann Daley, Court Reporter: Ellen Rassie, 954-769-5448 / ellen_rassie@flsd.uscourts.gov.

ORDER GRANTING [6] MOTION FOR ENTRY OF PRELIMINARY INJUNCTION. Signed by Judge Rodney Smith on 1/23/2025. See attached document for full details.

NOTICE of Filing Proposed Summons(es) by Gucci America, Inc.

Summon(s)

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

Exhibit 1 to Amended Complaint - Certificates of Registration for the Gucci Trad

Summons Issued as to The Individuals, Business Entities, and Unincorporated Associations Identified on Schedule A.

Plaintiff's NOTICE of Identification of Additional Alias for Defendant Numbers 79 and Additional Financial Accounts Used by Various Defendants by Gucci America, Inc.

Declaration of Kathleen Burns in Support Thereof

Exhibit 1 to the Declaration of Kathleen Burns

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

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Gucci America, Inc. re [24] Order on Motion for Preliminary Injunction upon Defendants via Registrar

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

SUMMONS (Affidavit) Returned Executed on [26] Amended Complaint/Amended Notice of Removal, [1] Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. 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Affidavit of Service

Affidavit of Service

Appendix of Service

Plaintiff's MOTION for Clerk's Entry of Default as to 1:1 replica brand luxury bag WhatsApp +8613766601610, 447477220881, Abigali_TOP Quality LUXURY BAGS Replica !, Replicabags.to, The Individuals, Business Entities, and Unincorporated Associations Identified on Schedule A, affordbag.com, airgagafasoul.com, alamode-store.com, amlick.com, ariabags.myshopify.com, ashoesfactory.top, astropya.shop, bagbagsss.shop, baglifes.com, bagsnzone.myshopify.com, bagxbag.shop, bibobag.shop, brendast688, buwwub.com, buy.crystar.shop, buzzbags.shop, chicopulent.com, cqwt1567, dazhongguo90, dicky0750.com, dvsneakers.com, easiernew.com, ebayluxurywatchcenter.com, eleanor4907, factory.bag_wholesale, fei99deng, fireteex.com, ghxy, globalchicstyles.com, guristore.com, handbagsalepro.com, hbagstore.com, i890.net, jessica-bags.myshopify.com, jkyouxuan.shop, jonasbob.com, joparker.online, judyjewelry.com, kebags.shop, kingmonn.online, kkluxurious.com, kokfashion.com, liuliha92888, luxeseasonal.com, luxurybags685, luxurybagshop88, luxuryeshoes.shop, luxuryhope.com, markuto.com, moehfashion.com, ntlwatches.com, nushad.com, olawto, onemorebags.com, oodiscount.store, rubypumps.com, shoppingvogue.com, shoppjm.com, sineed17.com, sneakerdaily.us, sneaksnstuff.com, streetwearcrib.com, stylepulsetrends.com, thgbfxru49j, trendyopulent.com, upscalebagshop.com, vip.fashionhaven.top, vip.go-fashion.club, vivideadg.com, wbag148, wishluxurywatchcenter.com, worldcenterforluxurywatches.com, xxjnkj.com, yanjiechen105, yolandajewelry.com, zehrine.com by Gucci America, Inc.

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

Text of Proposed Order

Plaintiff's NOTICE of Identification of Additional Alias for Defendant Numbers 18 and Additional Financial Accounts Used by Various Defendants by Gucci America, Inc.

Declaration of Kathleen Burns in Support Thereof

Exhibit 1 to the Declaration of Kathleen Burns

Clerk's Entry of Default as to 1:1 replica brand luxury bag WhatsApp +8613766601610, 447477220881, Abigali_TOP Quality LUXURY BAGS Replica !, Replicabags.to, The Individuals, Business Entities, and Unincorporated Associations Identified on Schedule A, affordbag.com, airgagafasoul.com, alamode-store.com, amlick.com, ariabags.myshopify.com, ashoesfactory.top, astropya.shop, bagbagsss.shop, baglifes.com, bagsnzone.myshopify.com, bagxbag.shop, bibobag.shop, brendast688, buwwub.com, buy.crystar.shop, buzzbags.shop, chicopulent.com, cqwt1567, dazhongguo90, dicky0750.com, dvsneakers.com, easiernew.com, ebayluxurywatchcenter.com, eleanor4907, factory.bag_wholesale, fei99deng, fireteex.com, ghxy, globalchicstyles.com, guristore.com, handbagsalepro.com, hbagstore.com, i890.net, jessica-bags.myshopify.com, jkyouxuan.shop, jonasbob.com, joparker.online, judyjewelry.com, kebags.shop, kingmonn.online, kkluxurious.com, kokfashion.com, liuliha92888, luxeseasonal.com, luxurybags685, luxurybagshop88, luxuryeshoes.shop, luxuryhope.com, markuto.com, moehfashion.com, ntlwatches.com, nushad.com, olawto, onemorebags.com, oodiscount.store, rubypumps.com, shoppingvogue.com, shoppjm.com, sineed17.com, sneakerdaily.us, sneaksnstuff.com, streetwearcrib.com, stylepulsetrends.com, thgbfxru49j, trendyopulent.com, upscalebagshop.com, vip.fashionhaven.top, vip.go-fashion.club, vivideadg.com, wbag148, wishluxurywatchcenter.com, worldcenterforluxurywatches.com, xxjnkj.com, yanjiechen105, yolandajewelry.com, zehrine.com. Signed by DEPUTY CLERK on 4/3/2025.

Plaintiff's MOTION for Default Judgment Against Defendants and Memorandum of Law in Support Thereof by Gucci America, Inc.

Declaration of Sydney Kipen in Support Thereof

Declaration of T. Raquel Wiborg-Rodriguez in Support Thereof

Text of Proposed Order Granting Motion for Default Final Judgment

(Text of Proposed Order Default Final Judgment and Permanent Injunction)(Wiborg-Rodriguez, T.)

ORDER granting [36] Motion for Default Final Judgment. Signed by Judge Rodney Smith on 5/22/2025. See attached document for full details.

DEFAULT FINAL JUDGMENT AND PERMANENT INJUNCTION in favor of Gucci America, Inc. against 1:1 replica brand luxury bag WhatsApp +8613766601610, 447477220881, Abigali_TOP Quality LUXURY BAGS Replica !, Replicabags.to, affordbag.com, airgagafasoul.com, alamode-store.com, amlick.com, ariabags.myshopify.com, ashoesfactory.top, astropya.shop, bagbagsss.shop, baglifes.com, bagsnzone.myshopify.com, bagxbag.shop, bibobag.shop, brendast688, buwwub.com, buy.crystar.shop, buzzbags.shop, chicopulent.com, cqwt1567, dazhongguo90, dicky0750.com, dvsneakers.com, easiernew.com, ebayluxurywatchcenter.com, eleanor4907, factory.bag_wholesale, fei99deng, fireteex.com, ghxy, globalchicstyles.com, guristore.com, handbagsalepro.com, hbagstore.com, i890.net, jessica-bags.myshopify.com, jkyouxuan.shop, jonasbob.com, joparker.online, judyjewelry.com, kebags.shop, kingmonn.online, kkluxurious.com, kokfashion.com, liuliha92888, luxeseasonal.com, luxurybags685, luxurybagshop88, luxuryeshoes.shop, luxuryhope.com, markuto.com, moehfashion.com, ntlwatches.com, nushad.com, olawto, onemorebags.com, oodiscount.store, rubypumps.com, shoppingvogue.com, shoppjm.com, sineed17.com, sneakerdaily.us, sneaksnstuff.com, streetwearcrib.com, stylepulsetrends.com, thgbfxru49j, trendyopulent.com, upscalebagshop.com, vip.fashionhaven.top, vip.go-fashion.club, vivideadg.com, wbag148, wishluxurywatchcenter.com, worldcenterforluxurywatches.com, xxjnkj.com, yanjiechen105, yolandajewelry.com, zehrine.com. Closing Case. Signed by Judge Rodney Smith on 5/22/2025. See attached document for full details.