2025-cv-60732

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. Filing fees $ 405.00 receipt number AFLSDC-18372534, filed by Burberry Limited, a United Kingdom Company, Burberry Limited, a New York Corporation.

Civil Cover Sheet

Exhibit 1 to Complaint - Certificates of Registration for the Burberry Trademark

Clerks Notice of Judge Assignment to Judge David S. Leibowitz. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Panayotta Augustin-Birch 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 Exhibit

Plaintiff's Corporate Disclosure Statement by Burberry Limited, a United Kingdom Company, Burberry Limited, a New York Corporation identifying Corporate Parent Burberry Group plc for Burberry Limited, a New York Corporation, Burberry Limited, a United Kingdom Company (O'Leary, Annie)

Plaintiff's MOTION to Seal per Local Rule 5.4 by Burberry Limited, a United Kingdom Company, Burberry Limited, a New York Corporation.

Text of Proposed Order on Motion to File Under Seal

Order

Order

Order

ORDER granting [5] Motion to File Under Seal. Within seven (7) days of completing service, Plaintiff shall move to unseal Schedule "A" and add all of the Defendants as parties through CM/ECF. Signed by Judge David S. Leibowitz on 4/18/2025. See attached document for full details.

NOTICE of Filing Bond by Burberry Limited, a United Kingdom Company, Burberry Limited, a New York Corporation.

Supplemental Attachment Bond

Plaintiff's MOTION to Unseal Document Docket Entries 6-7, 9-13, and 15 by Burberry Limited, a United Kingdom Company, Burberry Limited, a New York Corporation. Responses due by 5/8/2025.

Text of Proposed Order

AMENDED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants, filed by Burberry Limited, a United Kingdom Company, Burberry Limited, a New York Corporation.

Exhibit 1 to Amended Complaint - Certificates of Registration for the Burberry T

ORDER granting [16] Motion to Unseal. 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 David S. Leibowitz on 4/24/2025. See attached document for full details.

CLERK'S NOTICE of Compliance by unsealing documents pursuant to DE 18 Order.

Plaintiff's NOTICE upon Defendants via Electronic Mail by Burberry Limited, a United Kingdom Company, Burberry Limited, a New York Corporation re [9] Order on Ex Parte Motion, [16] Plaintiff's MOTION to Unseal Document Docket Entries 6-7, 9-13, and 15, [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, [15] Sealed Order, Set/Reset Sealed Deadlines/Hearings, [1] Complaint, [17] Amended Complaint/Amended Notice of Removal

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Burberry Limited, a United Kingdom Company, Burberry Limited, a New York Corporation re [9] Order on Ex Parte Motion, [8] Order on Motion to Seal, [4] Certificate of Other Affiliates/Corporate Disclosure Statement, [3] Form AO 120/121, [10] Order on Ex Parte Motion, [16] Plaintiff's MOTION to Unseal Document Docket Entries 6-7, 9-13, and 15, [12] Sealed Document, [2] Clerks Notice of Judge Assignment, [14] Notice (Other), [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, [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, [15] Sealed Order, Set/Reset Sealed Deadlines/Hearings, [5] Plaintiff's MOTION to Seal per Local Rule 5.4, [1] Complaint, [17] Amended Complaint/Amended Notice of Removal, [11] Sealed Document, upon Defendants via website posting

SUMMONS (Affidavit) Returned Executed on [1] Complaint, [17] Amended Complaint/Amended Notice of Removal, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Burberry Limited, a United Kingdom Company, Burberry Limited, a New York Corporation. getluxelabel.com served on 4/28/2025, response/answer due 5/19/2025; lourelle.co served on 4/28/2025, response/answer due 5/19/2025; shopmoon.co served on 4/28/2025, response/answer due 5/19/2025.

Affidavit of Service

Affidavit of Service

PAPERLESS Minute Entry for proceedings held before Judge David S. Leibowitz: Preliminary Injunction Hearing held on 5/1/2025 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 Burberry Limited, a United Kingdom Company, Burberry Limited, a New York Corporation. Total time in court: 10 minutes. Attorney Appearance(s): T. Raquel Wiborg-Rodriguez, Court Reporter: Gina Rodriguez, 305-523-5026 / gina_rodriguez@flsd.uscourts.gov.

ORDER granting 6 Plaintiffs' Motion for Entry of a Preliminary Injunction. Signed by Judge David S. Leibowitz See attached document for full details.

Plaintiff's MOTION for Clerk's Entry of Default as to THE INDIVIDUALS, BUSINESS ENTITIES, AND UNINCORPORATED ASSOCIATIONS IDENTIFIED ON SCHEDULE A, getluxelabel.com, lourelle.co, shopmoon.co by Burberry Limited, a United Kingdom Company, Burberry Limited, a New York Corporation.

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

Text of Proposed Order

Clerk's Entry of Default as to lourelle.co, getluxelabel.com, shopmoon.co - Motions Terminated: 25 Motion for Clerks Entry of Default, Signed by DEPUTY CLERK on 5/23/2025.

ORDER ON DEFAULT FINAL JUDGMENT PROCEDURE, (Responses due by 6/13/2025.) Signed by Judge David S. Leibowitz on 5/23/2025. See attached document for full details.

Plaintiff's MOTION for Default Judgment Against Defendants and Memorandum of Law in Support Thereof by Burberry Limited, a United Kingdom Company, Burberry Limited, a New York Corporation.

Declaration of Jennifer Halter in Support Thereof

Exhibit 1 to the Declaration of Jennifer Halter

Declaration of Christine Ann Daley in Support Thereof

Text of Proposed Order Order on Motion for Default Final Judgment

Text of Proposed Order Default Final Judgment and Permanent Injunction

ORDER GRANTING PLAINTIFFS' MOTION FOR DEFAULT FINAL JUDGMENT re [28] Motion for Default Judgment. Signed by Judge David S. Leibowitz on 5/30/2025. See attached document for full details.

DEFAULT FINAL JUDGMENT AND PERMANENT INJUNCTION in favor of Burberry Limited, a New York Corporation, Burberry Limited, a United Kingdom Company against lourelle.co, getluxelabel.com, shopmoon.co. The Clerk is directed to CLOSE this case and DENY any pending motions as moot. Signed by Judge David S. Leibowitz on 5/30/2025. See attached document for full details.

FORM AO 120 SENT TO DIRECTOR OF U.S. PATENT AND TRADEMARK (AO Form and Order sent)

Order

Plaintiff's NOTICE upon Defendants via Electronic Mail by Burberry Limited, a New York Corporation, Burberry Limited, a United Kingdom Company re [30] Default Judgment, Permanent Injunction, [29] Order on Motion for Default Judgment

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Burberry Limited, a New York Corporation, Burberry Limited, a United Kingdom Company re [30] Default Judgment, Permanent Injunction, [29] Order on Motion for Default Judgment upon Defendants via website posting

Plaintiff's MOTION for Discovery for Order Authorizing Discovery in Aid of Execution of Judgment by Burberry Limited, a New York Corporation, Burberry Limited, a United Kingdom Company. Responses due by 9/3/2025.

Declaration of Christine Ann Daley in Support Thereof

Text of Proposed Order

ORDER. The Motion DE [34] is GRANTED. The Judgment Creditors may initiate discovery in aid of execution of judgment in this matter. Signed by Judge David S. Leibowitz on 8/21/2025. See attached document for full details.