2024-cv-61345

COMPLAINT FOR INJUNCTIVE RELIEF AND DAMAGES against All Defendants. Filing fees $ 405.00 receipt number AFLSDC-17709714, 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.

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

Complaint with Exhibits

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 Granting Motion to Seal

ORDER granting [5] Motion to File Under Seal. Schedule "A" to Plaintiff's Complaint shall be filed under seal and shall remain under seal until further order from this Court. Signed by Judge William P. Dimitrouleas on 7/29/2024. See attached document for full details.

Order

Sealed Document re DE# [6] Order on Motion to Seal, by Tiffany (NJ) LLC.

Schedule "A" to Plaintiff's Complaint

ORDER REQUIRING COUNSEL TO MEET, FILE JOINT SCHEDULING REPORT AND JOINT DISCOVERY REPORT: Within thirty-five (35) calendar days of the filing of the first responsive pleading by the last responding defendant, unless this action is excluded under Rule 26(a)(1)(B), the parties shall file a Joint Scheduling Report and Joint Proposed Order pursuant to Local Rule 16.1.B.2. Signed by Judge William P. Dimitrouleas on 7/29/2024. See attached document for full details.

Order

Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order and Preliminary Injunction and Memorandum of Law in Support Thereof by Tiffany (NJ) LLC.

Declaration of Pilar Toro in Support Thereof

Declaration of Stephen M. Gaffigan in Support Thereof

Exhibit 1 to the Declaration of Stephen M. Gaffigan - part 1

Exhibit 1 to the Declaration of Stephen M. Gaffigan - part 2

Exhibit 1 to the Declaration of Stephen M. Gaffigan - part 3

Exhibit 1 to the Declaration of Stephen M. Gaffigan - part 4

Text of Proposed Order

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 by Tiffany (NJ) LLC.

Declaration of Stephen M. Gaffigan in Support Thereof

Exhibit 1 to the Declaration of Stephen M. Gaffigan

Text of Proposed Order Granting Motion for Order Authorizing Alternate Service o

ORDER GRANTING EX PARTE [9] APPLICATION FOR ENTRY OF TEMPORARY RESTRAINING: Preliminary Injunction Hearing set for 8/21/2024 1:15 PM in Fort Lauderdale Division before Judge William P. Dimitrouleas. Responses due by 8/16/2024. Replies due by 8/19/2024. The Clerk is directed to UNSEAL all docket entries in this case. Signed by Judge William P. Dimitrouleas on 7/30/2024. See attached document for full details.

NOTICE of Compliance re 11 Order. All documents in this case have been unsealed per DE#11.

ORDER AUTHORIZING ALTERNATE SERVICE OF PROCESS ON DEFENDANTS PURSUANT TO FEDERAL RULE OF CIVIL PROCEDURE 4(f)(3): Granting [10] Ex Parte Motion for Order Authorizing Alternate Service of Process. Signed by Judge William P. Dimitrouleas on 7/30/2024. See attached document for full details.

AMENDED COMPLAINT FOR INJUNCTIVE RELIEF AND DAMAGES against All Defendants, filed by Tiffany (NJ) LLC.

Exhibit 1 to Amended Complaint - Certificates of Registration for the Tiffany Tr

NOTICE of Filing Proposed Summons(es) by Tiffany (NJ) LLC re [13] Order on Ex Parte Motion

Summon(s)

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

Bond on Injunction in the amount of $25,000.00 posted by Tiffany (NJ) LLC. Approved by DEPUTY CLERK on July 31, 2024.

Plaintiff's NOTICE upon Defendants via Electronic Mail by Tiffany (NJ) LLC re [11] Order, Terminate Motions, Set/Reset Hearings, Set/Reset Motion/R&R Deadlines and Hearings, [8] Order Requiring Joint Scheduling Report, [9] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order and Preliminary Injunction and Memorandum of Law in Support Thereof MOTION for Temporary Restraining Order MOTION for Preliminary Injunction, [1] Complaint, [14] Amended Complaint/Amended Notice of Removal

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Tiffany (NJ) LLC re [11] Order, Terminate Motions, Set/Reset Hearings, Set/Reset Motion/R&R Deadlines and Hearings, [1] Complaint, [8] Order Requiring Joint Scheduling Report, [9] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order and Preliminary Injunction and Memorandum of Law in Support Thereof MOTION for Temporary Restraining Order MOTION for Preliminary Injunction, [14] Amended Complaint/Amended Notice of Removal upon Defendants via Registrar

CERTIFICATE OF SERVICE by Tiffany (NJ) LLC re [11] Order, Terminate Motions, Set/Reset Hearings, Set/Reset Motion/R&R Deadlines and Hearings, [4] Certificate of Other Affiliates/Corporate Disclosure Statement, [10] 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, [1] Complaint, [8] Order Requiring Joint Scheduling Report, [3] Form AO 120/121, [9] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order and Preliminary Injunction and Memorandum of Law in Support Thereof MOTION for Temporary Restraining Order MOTION for Preliminary Injunction, [12] Notice of Compliance, [14] Amended Complaint/Amended Notice of Removal, [7] Sealed Document, [2] Clerks Notice of Judge Assignment, [13] Order on Ex Parte Motion, [6] Order on Motion to Seal, [5] Plaintiff's MOTION to Seal per Local Rule 5.4 upon Defendants via website posting

PAPERLESS Minute Entry for proceedings held before Judge William P. Dimitrouleas: Motion Hearing held on 8/21/2024 re 9 Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order and Preliminary Injunction and Memorandum of Law in Support Thereof MOTION for Temporary Restraining Order MOTION for Preliminary Injunction filed by Tiffany (NJ) LLC. Defendants failed to appear. The court will grant the preliminary injunction. 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 [9] Application for Entry of Preliminary Injunction. Signed by Judge William P. Dimitrouleas on 8/21/2024. See attached document for full details.

ORDER TO SHOW CAUSE FOR LACK OF PROSECUTION: Plaintiff, on or before September 4, 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 8/28/2024. See attached document for full details.

SUMMONS (Affidavit) Returned Executed on [1] Complaint, [14] Amended Complaint/Amended Notice of Removal with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Tiffany (NJ) LLC. My18kjewelry.com served on 8/1/2024, response/answer due 8/22/2024; aaaclothes.com served on 8/1/2024, response/answer due 8/22/2024; aaaclothes.is served on 8/1/2024, response/answer due 8/22/2024; beelove.it served on 8/1/2024, response/answer due 8/22/2024; bestfakejewelry.com served on 8/1/2024, response/answer due 8/22/2024; buyonlinebehappy.com served on 8/1/2024, response/answer due 8/22/2024; cocokickk.com served on 8/1/2024, response/answer due 8/22/2024; copyaaayupoo.ru served on 8/1/2024, response/answer due 8/22/2024; denetebayelabat.shop served on 8/1/2024, response/answer due 8/22/2024; fashionrep.is served on 8/1/2024, response/answer due 8/22/2024; flysneaker.ru served on 8/1/2024, response/answer due 8/22/2024; hoyee.shop served on 8/1/2024, response/answer due 8/22/2024; hypeunique.is served on 8/1/2024, response/answer due 8/22/2024; jewelryreluxe.com served on 8/1/2024, response/answer due 8/22/2024; josehigh.com served on 8/1/2024, response/answer due 8/22/2024; lojamusthave.com.br served on 8/1/2024, response/answer due 8/22/2024; luxjewelryforless.com served on 8/1/2024, response/answer due 8/22/2024; martinepampuch.com served on 8/1/2024, response/answer due 8/22/2024; meejuri.com served on 8/1/2024, response/answer due 8/22/2024; mewjews.com served on 8/1/2024, response/answer due 8/22/2024; perfectkickz.org served on 8/1/2024, response/answer due 8/22/2024; premiumjewellery.shop served on 8/1/2024, response/answer due 8/22/2024; replicashoesbuy.ru served on 8/1/2024, response/answer due 8/22/2024; shopprimereps.com served on 8/1/2024, response/answer due 8/22/2024; sneakersrep.org served on 8/1/2024, response/answer due 8/22/2024; soc.sc served on 8/1/2024, response/answer due 8/22/2024; tamerabraner.com served on 8/1/2024, response/answer due 8/22/2024; tcooutlet.net served on 8/1/2024, response/answer due 8/22/2024; tiffanybrasillojas.com served on 8/1/2024, response/answer due 8/22/2024; tommyearls.com served on 8/1/2024, response/answer due 8/22/2024; tonyacasual.com served on 8/1/2024, response/answer due 8/22/2024; vivalana.com served on 8/1/2024, response/answer due 8/22/2024; vogomix.co served on 8/1/2024, response/answer due 8/22/2024; wfhsale.com served on 8/1/2024, response/answer due 8/22/2024; yimahandbags.cn served on 8/1/2024, response/answer due 8/22/2024; zapatillasreplica.com served on 8/1/2024, response/answer due 8/22/2024.

Affidavit of Service

Affidavit of Service

Affidavit of Service

Plaintiff's NOTICE upon Defendants via Electronic Mail by Tiffany (NJ) LLC re [22] Order on Motion for Preliminary Injunction

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Tiffany (NJ) LLC re [22] Order on Motion for Preliminary Injunction upon Defendants via Registrar

CERTIFICATE OF SERVICE by Tiffany (NJ) LLC re [22] Order on Motion for Preliminary Injunction upon Defendants via website posting

Plaintiff's MOTION for Clerk's Entry of Default as to My18kjewelry.com, The Individuals, Business Entities, and Unincorporated Associations Identified on Schedule A, aaaclothes.com, aaaclothes.is, beelove.it, bestfakejewelry.com, buyonlinebehappy.com, cocokickk.com, copyaaayupoo.ru, denetebayelabat.shop, fashionrep.is, flysneaker.ru, hoyee.shop, hypeunique.is, jewelryreluxe.com, josehigh.com, lojamusthave.com.br, luxjewelryforless.com, martinepampuch.com, meejuri.com, mewjews.com, perfectkickz.org, premiumjewellery.shop, replicashoesbuy.ru, shopprimereps.com, sneakersrep.org, soc.sc, tamerabraner.com, tcooutlet.net, tiffanybrasillojas.com, tommyearls.com, tonyacasual.com, vivalana.com, vogomix.co, wfhsale.com, yimahandbags.cn, zapatillasreplica.com by Tiffany (NJ) LLC.

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

Text of Proposed Order

Clerks Entry of Default: Granting [28] Plaintiff's MOTION for Clerk's Entry of Default as to My18kjewelry.com, The Individuals, Business Entities, and Unincorporated Associations Identified on Schedule A, aaaclothes.com, aaaclothes.is, beelove.it, bestfakejewelry.com, buyonl filed by Tiffany (NJ) LLC. Motions terminated: [28] Plaintiff's MOTION for Clerk's Entry of Default as to My18kjewelry.com, The Individuals, Business Entities, and Unincorporated Associations Identified on Schedule A, aaaclothes.com, aaaclothes.is, beelove.it, bestfakejewelry.com, buyonl filed by Tiffany (NJ) LLC. Signed by DEPUTY CLERK on 9/4/2024. See attached document for full details.

NOTICE of Voluntary Dismissal of Defendant Number 36 by Tiffany (NJ) LLC

Text of Proposed Order

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 GRANTMOTION FOR DEFAULT FINAL JUDGMENT: On or before September 24, 2024, Defendants shall respond to this Order to Show Cause, showing why this Motion should not be granted. Failure to respond shall result in the Court granting Plaintiff's Motion [DE [31]]. Show Cause Response due by 9/24/2024. Signed by Judge William P. Dimitrouleas on 9/11/2024. See attached document for full details.

ORDER GRANTING [31] MOTION FOR DEFAULT FINAL JUDGMENT: In accordance with Federal Rule of Civil Procedure 58, a separate final judgment will be entered. Signed by Judge William P. Dimitrouleas on 9/25/2024. See attached document for full details.

DEFAULT FINAL JUDGMENT AND PERMANENT INJUNCTION: JUDGMENT in favor of Tiffany (NJ) LLC and against My18kjewelry.com, The Individuals, Business Entities, and Unincorporated Associations Identified on Schedule A, aaaclothes.com, aaaclothes.is, beelove.it, bestfakejewelry.com, buyonlinebehappy.com, cocokickk.com, copyaaayupoo.ru, denetebayelabat.shop, fashionrep.is, flysneaker.ru, hoyee.shop, hypeunique.is, jewelryreluxe.com, josehigh.com, lojamusthave.com.br, luxjewelryforless.com, martinepampuch.com, meejuri.com, mewjews.com, perfectkickz.org, premiumjewellery.shop, replicashoesbuy.ru, shopprimereps.com, sneakersrep.org, soc.sc, tamerabraner.com, tcooutlet.net, tiffanybrasillojas.com, tommyearls.com, tonyacasual.com, vivalana.com, vogomix.co, wfhsale.com, yimahandbags.cn, zapatillasreplica.com. This Clerk shall CLOSE this case and DENY AS MOOT any pending motions. Closing Case. Signed by Judge William P. Dimitrouleas on 9/25/2024. See attached document for full details.

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

Default Judgment Order