2025-cv-60199

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. Filing fees $ 405.00 receipt number AFLSDC-18180279, 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 Melissa Damian. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Alicia O. Valle 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 and 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

Order

ORDER granting [5] Motion to File Under Seal. Signed by Judge Melissa Damian on 2/10/2025. See attached document for full details.

Surety BOND in the amount of $10,000.00 posted by Chanel, Inc. Approved by Judge Melissa Damian

Plaintiff's MOTION to Unseal Document Docket Entries 6-7 and 9-13 by Chanel, Inc. Responses due by 4/25/2025.

Text of Proposed Order Granting Motion to Unseal

ORDER Granting [15] Motion to Unseal. Signed by Judge Melissa Damian on 4/14/2025. See attached document for full details.

CLERK'S NOTICE of Compliance (Docket Entries 6-7 and 9-13 have been Unsealed) re 16 Order on Motion to Unseal

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 Tra

NOTICE of Voluntary Dismissal of Defendant Number 55 by Chanel, Inc.

ORDER OF DISMISSAL AS TO ONE DEFENDANT, Party Luxuryproducts Signed by Judge Melissa Damian on 4/16/2025. See attached document for full details.

Plaintiff's NOTICE upon Defendants via Electronic Mail by Chanel, Inc. re [6] 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, [12] Order on Ex Parte Motion, [15] Motion to Unseal Case, [1] Complaint

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Chanel, Inc. re [6] 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, [5] Plaintiff's MOTION to Seal per Local Rule 5.4, [14] Bond, [13] Order on Ex Parte Motion, [12] Order on Ex Parte Motion, [9] Sealed Document, [15] Motion to Unseal Case, [8] Order on Motion to Seal, [10] Sealed Document, [3] Form AO 120/121, [1] Complaint, [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 upon Defendants via website posting

SUMMONS (Affidavit) Returned Executed on [18] 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. _leatherfactory served on 4/14/2025, response/answer due 5/5/2025; 2face_kld served on 4/14/2025, response/answer due 5/5/2025; 9824corey served on 4/14/2025, response/answer due 5/5/2025; AA Fashion Brand Base served on 4/14/2025, response/answer due 5/5/2025; Alexbestsellerluxury served on 4/14/2025, response/answer due 5/5/2025; Alice served on 4/14/2025, response/answer due 5/5/2025; All inclusive served on 4/14/2025, response/answer due 5/5/2025; Amy's Fashion Outlet served on 4/14/2025, response/answer due 5/5/2025; Angela served on 4/14/2025, response/answer due 5/5/2025; Anja served on 4/14/2025, response/answer due 5/5/2025; Antonelaparez served on 4/14/2025, response/answer due 5/5/2025; Aracelli served on 4/14/2025, response/answer due 5/5/2025; Audrey served on 4/14/2025, response/answer due 5/5/2025; Bag & Shoes Sale served on 4/14/2025, response/answer due 5/5/2025; Bags Club served on 4/14/2025, response/answer due 5/5/2025; Bonnie luxury served on 4/14/2025, response/answer due 5/5/2025; Cai Luxury served on 4/14/2025, response/answer due 5/5/2025; Celia served on 4/14/2025, response/answer due 5/5/2025; Chen Yanyu served on 4/14/2025, response/answer due 5/5/2025; Edern served on 4/14/2025, response/answer due 5/5/2025; Elva served on 4/14/2025, response/answer due 5/5/2025; Emily served on 4/14/2025, response/answer due 5/5/2025; Factory direct-selling wholesale served on 4/14/2025, response/answer due 5/5/2025; Factory wholesale served on 4/14/2025, response/answer due 5/5/2025; Faiid served on 4/14/2025, response/answer due 5/5/2025; GD-Ashley served on 4/14/2025, response/answer due 5/5/2025; Happy Shopping served on 4/14/2025, response/answer due 5/5/2025; James Brown served on 4/14/2025, response/answer due 5/5/2025; Jani served on 4/14/2025, response/answer due 5/5/2025; Jennie Store served on 4/14/2025, response/answer due 5/5/2025; Kick Bag served on 4/14/2025, response/answer due 5/5/2025; Kobayashi Luxury wholesale served on 4/14/2025, response/answer due 5/5/2025; Light luxury boutique store served on 4/14/2025, response/answer due 5/5/2025; Lily shop served on 4/14/2025, response/answer due 5/5/2025; Lisa served on 4/14/2025, response/answer due 5/5/2025; Luke served on 4/14/2025, response/answer due 5/5/2025; Luxury brands discount served on 4/14/2025, response/answer due 5/5/2025; Luxuryluyi served on 4/14/2025, response/answer due 5/5/2025; Moon served on 4/14/2025, response/answer due 5/5/2025; Ms cai served on 4/14/2025, response/answer due 5/5/2025; Msli served on 4/14/2025, response/answer due 5/5/2025; PL Shop served on 4/14/2025, response/answer due 5/5/2025; Rachel served on 4/14/2025, response/answer due 5/5/2025; Samba served on 4/14/2025, response/answer due 5/5/2025; Smile-STK1 served on 4/14/2025, response/answer due 5/5/2025; Suger-Shop served on 4/14/2025, response/answer due 5/5/2025; Summit Top Shoes And Bag served on 4/14/2025, response/answer due 5/5/2025; Suna served on 4/14/2025, response/answer due 5/5/2025; Sup-Bag served on 4/14/2025, response/answer due 5/5/2025; Xiamen Zhuobang Xuanhua Technology Co., Ltd. served on 4/14/2025, response/answer due 5/5/2025; Yoyo served on 4/14/2025, response/answer due 5/5/2025; alonefairy988 served on 4/14/2025, response/answer due 5/5/2025; alyssa. Wholesaler served on 4/14/2025, response/answer due 5/5/2025; anna_monica_a served on 4/14/2025, response/answer due 5/5/2025; averyzone88 served on 4/14/2025, response/answer due 5/5/2025; bagcatalog1 served on 4/14/2025, response/answer due 5/5/2025; bellaworkinghard served on 4/14/2025, response/answer due 5/5/2025; bluecantin_tree9 served on 4/14/2025, response/answer due 5/5/2025; chiclifebag2 served on 4/14/2025, response/answer due 5/5/2025; deusonysos served on 4/14/2025, response/answer due 5/5/2025; doumluxe_shop served on 4/14/2025, response/answer due 5/5/2025; jennie.bagstation served on 4/14/2025, response/answer due 5/5/2025; lovechanel999 served on 4/14/2025, response/answer due 5/5/2025; luxetrend38 served on 4/14/2025, response/answer due 5/5/2025; luxuryalan served on 4/14/2025, response/answer due 5/5/2025; lv_tina6 served on 4/14/2025, response/answer due 5/5/2025; lz_kanglin served on 4/14/2025, response/answer due 5/5/2025; meandmy.luxb served on 4/14/2025, response/answer due 5/5/2025; mrym_luna served on 4/14/2025, response/answer due 5/5/2025; nikko served on 4/14/2025, response/answer due 5/5/2025; niko served on 4/14/2025, response/answer due 5/5/2025; nongs_studio served on 4/14/2025, response/answer due 5/5/2025; paddy served on 4/14/2025, response/answer due 5/5/2025; sara served on 4/14/2025, response/answer due 5/5/2025; seankoc served on 4/14/2025, response/answer due 5/5/2025; sherry_bag_club served on 4/14/2025, response/answer due 5/5/2025; thqy0797 served on 4/14/2025, response/answer due 5/5/2025; tia.bagheaven served on 4/14/2025, response/answer due 5/5/2025; tide1566 served on 4/14/2025, response/answer due 5/5/2025; wclub.handbag served on 4/14/2025, response/answer due 5/5/2025; yingmuqingzi93 served on 4/14/2025, response/answer due 5/5/2025; zahraomaphine served on 4/14/2025, response/answer due 5/5/2025; zhangjie3648 served on 4/14/2025, response/answer due 5/5/2025; zhenguogong served on 4/14/2025, response/answer due 5/5/2025; zhou.shopier served on 4/14/2025, response/answer due 5/5/2025.

Affidavit of Service

Affidavit of Service

Plaintiff's NOTICE of Email Correspondence Received from Certain Defendants in Connection with Notice by Chanel, Inc.

Exhibit 1 to the Notice

PAPERLESS Minute Entry for proceedings held before Judge Melissa Damian: Motion Hearing held on 4/21/2025 re 6 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. Total time in court: 0 hour(s) : 4 minutes. Attorney Appearance(s): T. Raquel Wiborg-Rodriguez. Court Reporter: Glenda Powers, 305-523-5022 / Glenda_Powers@flsd.uscourts.gov. (pg00)

ORDER Granting [6] PLAINTIFF'S MOTION FOR ENTRY OF PRELIMINARY INJUNCTION. Signed by Judge Melissa Damian on 4/22/2025. See attached document for full details.

Plaintiff's NOTICE of Identification of Additional Financial Accounts Used By Certain Defendants by Chanel, Inc.

Declaration of Eric Rosaler in Support Thereof

Exhibit 1 to the Rosaler Declaration

Plaintiff's NOTICE upon Defendants via Electronic Mail by Chanel, Inc. re [26] Order on Ex Parte Motion

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Chanel, Inc. re [26] Order on Ex Parte Motion upon Defendants via website posting

Plaintiff's MOTION for Clerk's Entry of Default as to _leatherfactory, 2face_kld, 9824corey, AA Fashion Brand Base, Alexbestsellerluxury, Alice, All inclusive, Amy's Fashion Outlet, Angela, Anja, Antonelaparez, Aracelli, Audrey, Bag & Shoes Sale, Bags Club, Bonnie luxury, Cai Luxury, Celia, Chen Yanyu, Edern, Elva, Emily, Factory direct-selling wholesale, Factory wholesale, Faiid, GD-Ashley, Happy Shopping, James Brown, Jani, Jennie Store, Kick Bag, Kobayashi Luxury wholesale, Light luxury boutique store, Lily shop, Lisa, Luke, Luxury brands discount, Luxuryluyi, Moon, Ms cai, Msli, PL Shop, Rachel, Samba, Smile-STK1, Suger-Shop, Summit Top Shoes And Bag, Suna, Sup-Bag, The Individuals, Business Entities, and Unincorporated Associations Identified on Schedule A, Xiamen Zhuobang Xuanhua Technology Co., Ltd., Yoyo, alonefairy988, alyssa. Wholesaler, anna_monica_a, averyzone88, bagcatalog1, bellaworkinghard, bluecantin_tree9, chiclifebag2, deusonysos, doumluxe_shop, jennie.bagstation, lovechanel999, luxetrend38, luxuryalan, lv_tina6, lz_kanglin, meandmy.luxb, mrym_luna, nikko, niko, nongs_studio, paddy, sara, seankoc, sherry_bag_club, thqy0797, tia.bagheaven, tide1566, wclub.handbag, yingmuqingzi93, zahraomaphine, zhangjie3648, zhenguogong, zhou.shopier 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 of DE 30 - Motions Terminated: 30 Motion for Clerks Entry of Default, Signed by DEPUTY CLERK on 5/8/2025.

Plaintiff's MOTION for Default Judgment Against Defendants 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 Default Final Judgment

Text of Proposed Order Granting Default Final Judgment and Permanent Injunction