2024-cv-24499

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. Filing fees $ 405.00 receipt number AFLSDC-17983769, filed by YETI Coolers, LLC.

Civil Cover Sheet

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

Clerks Notice of Judge Assignment to Judge Rodolfo A. Ruiz, II. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Lauren F. Louis 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

Corporate Disclosure Statement by YETI Coolers, LLC identifying Corporate Parent YETI Holdings, Inc. for YETI Coolers, LLC

Plaintiff's MOTION to Seal per Local Rule 5.4 by YETI Coolers, LLC.

Text of Proposed Order

ORDER granting [5] Motion to Seal. Signed by Judge Rodolfo A. Ruiz II on 11/15/2024. See attached document for full details.

Order

Surety BOND in the amount of $10,000.00 posted by YETI Coolers, LLC Approved by Judge Rodolfo A. Ruiz, II

Plaintiff's MOTION to Unseal Document Docket Entries 7-13 by YETI Coolers, LLC. Responses due by 12/17/2024.

Text of Proposed Order

ORDER granting [15] Motion to Unseal. Signed by Judge Rodolfo A. Ruiz II on 12/4/2024. See attached document for full details.

Plaintiff's NOTICE upon Defendants via Electronic Mail by YETI Coolers, LLC re [1] Complaint, [10] Order on Ex Parte Motion, [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, [15] Motion to Unseal Case

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by YETI Coolers, LLC 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, [15] Motion to Unseal Case, [1] Complaint, [10] Order on Ex Parte Motion, upon Defendants via Registrar

CERTIFICATE OF SERVICE by YETI Coolers, LLC re [6] Order on Motion to Seal, [11] Order on Ex Parte Motion, [2] Clerks Notice of Judge Assignment, [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, [7] Sealed Document, [15] Motion to Unseal Case, [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, [1] Complaint, [5] Plaintiff's MOTION to Seal per Local Rule 5.4, [14] Bond, [10] Order on Ex Parte Motion, [12] Sealed Document, [4] Certificate of Other Affiliates/Corporate Disclosure Statement, [3] Form AO 120/121 upon Defendants via website posting

Plaintiff's NOTICE of E-mail Inquiry Received from a Certain Defendant in Connection with Asset Restraint and Service by YETI Coolers, LLC

Exhibit 1 to the Notice of E-mail Inquiry

Plaintiff's MOTION to Correct Order Authorizing Alternate Service of Process on Defendants Pursuant to Federal Rule of Civil Procedure 4(f)(3) by YETI Coolers, LLC.

Text of Proposed Order Corrected Order Authorizing Alternate Service of Process

NOTICE of Voluntary Dismissal of Defendant Numbers 15, 16, 32 & 39 by YETI Coolers, LLC

Corrected NOTICE upon Defendants via Electronic Mail by YETI Coolers, LLC re [1] Complaint, [10] Order on Ex Parte Motion, [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, [15] Motion to Unseal Case

Exhibit Corrected Certificate of Sevice

CERTIFICATE OF SERVICE by YETI Coolers, LLC 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, [15] Motion to Unseal Case, [1] Complaint, [10] Order on Ex Parte Motion, upon Defendants via Registrar

PAPERLESS Minute Entry for proceedings held before Judge Rodolfo A. Ruiz II: Telephonic Status Conference held on 12/6/2024. Order to follow. Attorney Appearance(s): Virgilio Gigante, Court Reporter: Ilona Lupowitz, 305-523-5737 / Ilona_lupowitz@flsd.uscourts.gov.

CORRECTED ORDER Granting Plaintiff's Ex Parte Motion for Order Authorizing Alternate Service of Process on Defendants Pursuant to Federal Rule of Civil Procedure 4(f)(3). Signed by Judge Rodolfo A. Ruiz, II on 12/6/2024. See attached document for full details.

PAPERLESS ORDER on 22 Notice of Voluntary Dismissal as to Defendant Numbers 15, 16, 32, & 39 ("Notice"). The Court having reviewed the Notice, the record, and being otherwise fully advised, it is hereby ORDERED AND ADJUDGED that Defendants Numbered 15, 16, 32, and 39 on "Schedule A" to the Complaint, see [ECF No. 7-1], are dismissed from this action. Signed by Judge Rodolfo A. Ruiz, II on 12/6/2024.

ORDER GRANTING MOTION FOR PRELIMINARY INJUNCTION. Signed by Judge Rodolfo A. Ruiz, II on 12/9/2024. See attached document for full details.

AMENDED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants, filed by YETI Coolers, LLC.

Exhibit 1 to Amended Complaint - Certificates of Registration for the YETI Trade

SUMMONS (Affidavit) Returned Executed on [1] Complaint, [29] Amended Complaint/Amended Notice of Removal with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by YETI Coolers, LLC. 6ro9.com served on 12/23/2024, response/answer due 1/13/2025; 90mon.com served on 12/23/2024, response/answer due 1/13/2025; a7hh.vip served on 12/23/2024, response/answer due 1/13/2025; aleeeok.com served on 12/23/2024, response/answer due 1/13/2025; barrmall.shop served on 12/23/2024, response/answer due 1/13/2025; beautifuldiscountsmall.shop served on 12/23/2024, response/answer due 1/13/2025; beautybanquet.com.au served on 12/23/2024, response/answer due 1/13/2025; bigbigmall.shop served on 12/23/2024, response/answer due 1/13/2025; brownrucemall.shop served on 12/23/2024, response/answer due 1/13/2025; buybargains.top served on 12/23/2024, response/answer due 1/13/2025; canvasthis.com.au served on 12/23/2024, response/answer due 1/13/2025; cecalorori.com served on 12/23/2024, response/answer due 1/13/2025; clayaery.com served on 12/23/2024, response/answer due 1/13/2025; couturechiccorner.shop served on 12/23/2024, response/answer due 1/13/2025; darrenmall.shop served on 12/23/2024, response/answer due 1/13/2025; enra.shop served on 12/23/2024, response/answer due 1/13/2025; etronrohh.shop served on 12/23/2024, response/answer due 1/13/2025; furnitufb.top served on 12/23/2024, response/answer due 1/13/2025; goodvipl.shop served on 12/23/2024, response/answer due 1/13/2025; hommerock.com served on 12/23/2024, response/answer due 1/13/2025; iptvboxhq.com served on 12/23/2024, response/answer due 1/13/2025; janirlirem.com served on 12/23/2024, response/answer due 1/13/2025; joscryptos.com served on 12/23/2024, response/answer due 1/13/2025; lirupicsa.com served on 12/23/2024, response/answer due 1/13/2025; lyongaz.com served on 12/23/2024, response/answer due 1/13/2025; mallsaleusa.top served on 12/23/2024, response/answer due 1/13/2025; miitunn.shop served on 12/23/2024, response/answer due 1/13/2025; mimindress.com served on 12/23/2024, response/answer due 1/13/2025; miteroh.vip served on 12/23/2024, response/answer due 1/13/2025; mmalk.shop served on 12/23/2024, response/answer due 1/13/2025; nh001.top served on 12/23/2024, response/answer due 1/13/2025; osdaq.com served on 12/26/2024, response/answer due 1/16/2025; panekanine.com served on 12/23/2024, response/answer due 1/13/2025; paulmall.shop served on 12/23/2024, response/answer due 1/13/2025; popeyemall.shop served on 12/23/2024, response/answer due 1/13/2025; qalacerade.com served on 12/26/2024, response/answer due 1/16/2025; qiswetonde.com served on 12/23/2024, response/answer due 1/13/2025; saiyandoc.com served on 12/23/2024, response/answer due 1/13/2025; shoplfy-co.com served on 12/26/2024, response/answer due 1/16/2025; softcooleruk.com served on 12/23/2024, response/answer due 1/13/2025; spainzz.online served on 12/23/2024, response/answer due 1/13/2025; startnowd.com served on 12/23/2024, response/answer due 1/13/2025; stocknexapulsepro.com served on 12/23/2024, response/answer due 1/13/2025; tctocc.shop served on 12/23/2024, response/answer due 1/13/2025; tctocd.shop served on 12/23/2024, response/answer due 1/13/2025; tctocf.shop served on 12/23/2024, response/answer due 1/13/2025; tctoch.shop served on 12/23/2024, response/answer due 1/13/2025; tctocj.shop served on 12/23/2024, response/answer due 1/13/2025; tctock.shop served on 12/23/2024, response/answer due 1/13/2025; tctocp.shop served on 12/23/2024, response/answer due 1/13/2025; tctocr.shop served on 12/23/2024, response/answer due 1/13/2025; tctocv.shop served on 12/23/2024, response/answer due 1/13/2025; thegiftio.com served on 12/23/2024, response/answer due 1/13/2025; ttobao.com served on 12/23/2024, response/answer due 1/13/2025; usexebikel.com served on 12/26/2024, response/answer due 1/16/2025; uskok.shop served on 12/23/2024, response/answer due 1/13/2025; wcwocr.shop served on 12/23/2024, response/answer due 1/13/2025; wcwocs.shop served on 12/23/2024, response/answer due 1/13/2025; wcwocw.shop served on 12/23/2024, response/answer due 1/13/2025; xcxocf.shop served on 12/23/2024, response/answer due 1/13/2025; xcxocg.shop served on 12/23/2024, response/answer due 1/13/2025; xcxoch.shop served on 12/23/2024, response/answer due 1/13/2025; xcxock.shop served on 12/23/2024, response/answer due 1/13/2025; xcxocx.shop served on 12/23/2024, response/answer due 1/13/2025; xcxocy.shop served on 12/23/2024, response/answer due 1/13/2025; xlngtyn.com served on 12/23/2024, response/answer due 1/13/2025; yeti-coolers.top served on 12/23/2024, response/answer due 1/13/2025; yetiarcticgear.shop served on 12/23/2024, response/answer due 1/13/2025; yeticoolerdeals979.shop served on 12/23/2024, response/answer due 1/13/2025; yetifactoryoutlet.com served on 12/23/2024, response/answer due 1/13/2025; yetishopus.com served on 12/23/2024, response/answer due 1/13/2025.

Affidavit of Service

Affidavit of Service

Affidavit of Service

Affidavit of Service

Plaintiff's MOTION for Clerk's Entry of Default as to 6ro9.com, 90mon.com, The Individuals, Business Entities and Unincorporated Associations Identified on Schedule A, a7hh.vip, aleeeok.com, barrmall.shop, beautifuldiscountsmall.shop, beautybanquet.com.au, bigbigmall.shop, brownrucemall.shop, buybargains.top, canvasthis.com.au, cecalorori.com, clayaery.com, couturechiccorner.shop, darrenmall.shop, enra.shop, etronrohh.shop, furnitufb.top, goodvipl.shop, hommerock.com, iptvboxhq.com, janirlirem.com, joscryptos.com, lirupicsa.com, lyongaz.com, mallsaleusa.top, miitunn.shop, mimindress.com, miteroh.vip, mmalk.shop, nh001.top, osdaq.com, panekanine.com, paulmall.shop, popeyemall.shop, qalacerade.com, qiswetonde.com, saiyandoc.com, shoplfy-co.com, softcooleruk.com, spainzz.online, startnowd.com, stocknexapulsepro.com, tctocc.shop, tctocd.shop, tctocf.shop, tctoch.shop, tctocj.shop, tctock.shop, tctocp.shop, tctocr.shop, tctocv.shop, thegiftio.com, ttobao.com, usexebikel.com, uskok.shop, wcwocr.shop, wcwocs.shop, wcwocw.shop, xcxocf.shop, xcxocg.shop, xcxoch.shop, xcxock.shop, xcxocx.shop, xcxocy.shop, xlngtyn.com, yeti-coolers.top, yetiarcticgear.shop, yeticoolerdeals979.shop, yetifactoryoutlet.com, yetishopus.com by YETI Coolers, LLC.

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# 31 - Motions Terminated: 31 Motion for Clerks Entry of Default, Signed by DEPUTY CLERK on 2/6/2025.

NOTICE of Identification of Additional Financial Account Used by Defendant Number 4 by YETI Coolers, LLC

Declaration of Kathleen Burns in Support Thereof

Exhibit 1 to the Declaration of Kathleen Burns

ORDER REQUIRING MOTION FOR DEFAULT JUDGMENT. Signed by Judge Rodolfo A. Ruiz, II on 2/10/2025. See attached document for full details.

Plaintiff's MOTION for Extension of Time to File Motion for Default Judgment as to Defendant Number 66 re [34] Administrative Order by YETI Coolers, LLC. Responses due by 3/5/2025.

Text of Proposed Order

PAPERLESS ORDER granting 35 Motion to Extend Deadline to File Motion for Default Final Judgment as to Defendant Number 66 ("Motion"). Plaintiff shall file a Motion for Default Final Judgment as to Defendant thegiftio.com ("Defendant Number 66") on or before March 6, 2025. In the event that Plaintiff and Defendant Number 66 reach a settlement agreement as contemplated in the Motion and advise the Court of the same, said agreement shall obviate the requirement that Plaintiff file a Motion for Default Final Judgment as to Defendant Number 66. Signed by Judge Rodolfo A. Ruiz, II on 2/19/2025.

Plaintiff's MOTION for Default Judgment Against Defendants and Memorandum of Law in Support Thereof by YETI Coolers, LLC.

Declaration of Jeni Zuercher in Support Thereof

Exhibit 1 to the Declaration of Jeni Zuercher

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 granting [37] Plaintiff's Motion for Default Final Judgment. Signed by Judge Rodolfo A. Ruiz, II on 2/26/2025. See attached document for full details.

DEFAULT FINAL JUDGMENT AND PERMANENT INJUNCTION. Signed by Judge Rodolfo A. Ruiz, II on 2/26/2025. See attached document for full details.

Set Deadlines Per DE#41. Motions due by 3/26/2025.

Second MOTION for Extension of Time to File Motion for Default Judgment as to Defendant Number 66 re [36] Order on Motion for Extension of Time, by YETI Coolers, LLC. Responses due by 3/19/2025.

Text of Proposed Order

Set Deadlines Per DE#41. Motions due by 3/26/2025.

PAPERLESS ORDER granting 40 Plaintiff's Second Motion to Extend Deadline to File Motion for Default Final Judgment as to Defendant Number 66. Plaintiff shall file a Motion for Default Final Judgment as to Defendant Number 66 on or before March 26, 2025. Signed by Judge Rodolfo A. Ruiz, II on 3/5/2025.

Plaintiff's MOTION to Approve Consent Judgment (Responses due by 4/1/2025.), MOTION for Permanent Injunction as to Defendant Number 66 by YETI Coolers, LLC.

Exhibit 1 - Consent Judgment and Permanent Injunction as to Defendant Number 66

(Exhibit 2 - Statement of Consent as to Defendant Number 66)

CONSENT FINAL JUDGMENT AND PERMANENT INJUNCTION AS TO DEFENDANT NUMBER 66. Signed by Judge Rodolfo A. Ruiz, II on 3/18/2025. See attached document for full details.

Plaintiff's NOTICE upon Defendants via Electronic Mail by YETI Coolers, LLC re 38 Order on Motion for Default Judgment, 39 Default Judgment

(Exhibit Certificate of Sevice)

CERTIFICATE OF SERVICE by YETI Coolers, LLC re 38 Order on Motion for Default Judgment, 39 Default Judgment upon Defendants via website posting

Plaintiff's MOTION for Discovery for Order Authorizing Discovery in Aid of Execution of Judgment by YETI Coolers, LLC. Responses due by 9/5/2025.

Declaration of Stephen M. Gaffigan in Support Thereof

Text of Proposed Order

ORDER GRANTING [46] JUDGMENT CREDITOR'S MOTION TO INITIATE DISCOVERY IN AID OF EXECUTION OF JUDGMENT. Signed by Judge Rodolfo A. Ruiz, II on 8/22/2025. See attached document for full details.