2024-cv-24954

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. Filing fees $ 405.00 receipt number AFLSDC-18062535, 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 Beth Bloom. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Marty Fulgueira Elfenbein 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

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, Burberry Limited (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

PAPERLESS ORDER granting ECF No. 5, Plaintiffs' Motion to File Under Seal. Plaintiffs may file Schedule "A" to the Complaint and the Summonses under sealand they shall remain under seal until further order from this Court. Signed by Judge Beth Bloom

Order

NOTICE OF CONVENTIONAL FILING OF THE ORIGINAL BOND CERTIFICATE by Burberry Limited(a United Kingdom company), and Burberry Limited(a New York corporation)

Plaintiff's MOTION to Unseal Document Entries 7-13 by Burberry Limited(a United Kingdom company), Burberry Limited(a New York corporation). Responses due by 1/13/2025.

Text of Proposed Order

PAPERLESS ORDER granting Plaintiffs' Motion to Unseal, ECF No. 15. The Clerk of Court is directed to unseal all sealed docket entries in this Case, ECF Nos. 7, 8, 9, 10, 11, 12, and 13. Signed by Judge Beth Bloom

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

NOTICE of Compliance re 16 Order on Motion to Unseal Document. All documents noted in the order at DE#16 have been unsealed.

Plaintiff's NOTICE upon Defendants via Electronic Mail by Burberry Limited(a New York corporation), Burberry Limited(a United Kingdom company) 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 MOTION for Temporary Restraining Order MOTION for Preliminary Injunction, [10] Sealed Order on Motion, Set/Reset Sealed Deadlines/Hearings, Set/Reset Sealed Motion/R&R Deadlines and Hearings, Order on Ex Parte Motion, Order on Motion for Temporary Restraining Order, [15] Plaintiff's MOTION to Unseal Document Entries 7-13, [17] Amended Complaint/Amended Notice of Removal, [1] Complaint

Exhibit Certificate of Sevice

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

CERTIFICATE OF SERVICE by Burberry Limited(a New York corporation), Burberry Limited(a United Kingdom company) 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 MOTION for Temporary Restraining Order MOTION for Preliminary Injunction, [17] Amended Complaint/Amended Notice of Removal, [10] Sealed Order on Motion, Set/Reset Sealed Deadlines/Hearings, Set/Reset Sealed Motion/R&R Deadlines and Hearings, Order on Ex Parte Motion, Order on Motion for Temporary Restraining Order, [1] Complaint, [15] Plaintiff's MOTION to Unseal Document Entries 7-13 upon Defendants via Registrar

CERTIFICATE OF SERVICE by Burberry Limited(a New York corporation), Burberry Limited(a United Kingdom company) 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 MOTION for Temporary Restraining Order MOTION for Preliminary Injunction, [17] Amended Complaint/Amended Notice of Removal, [10] Sealed Order on Motion, Set/Reset Sealed Deadlines/Hearings, Set/Reset Sealed Motion/R&R Deadlines and Hearings, Order on Ex Parte Motion, Order on Motion for Temporary Restraining Order, [1] Complaint, [15] Plaintiff's MOTION to Unseal Document Entries 7-13 upon Defendant via Registrar

Plaintiff's NOTICE of E-mail Correspondence Received by Burberry Limited(a New York corporation), Burberry Limited(a United Kingdom company)

Exhibit 1 to Plaintiffs' Notice of E-mail Correspondence Received

ORDER GRANTING [8] PLAINTIFFS' MOTION FOR ENTRY OF PRELIMINARY INJUNCTION. Signed by Judge Beth Bloom on 1/2/2025. See attached document for full details.

PAPERLESS Minute Entry for proceedings held before Judge Beth Bloom: Motion Hearing held on 1/2/2025 re 8 Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order, Preliminary Injunction, and Order Restraining Transfer of Assets. Plaintiffs' Motion granted. Total time in court: 4 minutes. Attorney Appearance(s): T. Raquel Wiborg-Rodriguez, Court Reporter: Yvette Hernandez, 305-523-5698 / Yvette_Hernandez@flsd.uscourts.gov.

Plaintiff's NOTICE of Identification of Additional Alias and Financial Account Used By Defendant Number 27 by Burberry Limited(a New York corporation), Burberry Limited(a United Kingdom company)

Declaration of Kathleen Burns in Support Thereof

Exhibit 1 to the Declaration of Kathleen Burns

Plaintiff's NOTICE of Identification of Additional Financial Account Used by Defendant Number 14 by Burberry Limited(a New York corporation), Burberry Limited(a United Kingdom company)

Declaration of Kathleen Burns in Support Thereof

Exhibit 1 to the Declaration of Kathleen Burns

CERTIFICATE OF SERVICE by Burberry Limited(a New York corporation), Burberry Limited(a United Kingdom company) re [24] Order on Motion for Preliminary Injunction upon Defendants via website posting

Plaintiff's NOTICE upon Defendants via Electronic Mail by Burberry Limited(a New York corporation), Burberry Limited(a United Kingdom company) re [24] Order on Motion for Preliminary Injunction

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Burberry Limited(a New York corporation), Burberry Limited(a United Kingdom company) re [24] Order on Motion for Preliminary Injunction upon Defendants via Registrar

SUMMONS (Affidavit) Returned Executed on [17] Amended Complaint/Amended Notice of Removal, [1] Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Burberry Limited(a New York corporation), Burberry Limited(a United Kingdom company). akmood.com served on 1/2/2025, response/answer due 1/23/2025; aplusrelu.com served on 1/2/2025, response/answer due 1/23/2025; azelleshop.com served on 1/2/2025, response/answer due 1/23/2025; bagagents.com served on 1/2/2025, response/answer due 1/23/2025; bagsattire.com served on 1/2/2025, response/answer due 1/23/2025; bagsch.com served on 1/2/2025, response/answer due 1/23/2025; bagshubb.com served on 1/2/2025, response/answer due 1/23/2025; barbarasharon.com served on 1/2/2025, response/answer due 1/23/2025; bartona.top served on 1/2/2025, response/answer due 1/23/2025; bearsold.com served on 1/2/2025, response/answer due 1/23/2025; beeonevip.com served on 1/2/2025, response/answer due 1/23/2025; boycemoa.online served on 1/2/2025, response/answer due 1/23/2025; cetusstore.com served on 1/2/2025, response/answer due 1/23/2025; chicopulent.com served on 1/2/2025, response/answer due 1/23/2025; cocosike.cc served on 1/2/2025, response/answer due 1/23/2025; elegantbag.shop served on 1/2/2025, response/answer due 1/23/2025; evaluxurystore.com served on 1/2/2025, response/answer due 1/23/2025; extravagant-fashion.com served on 1/2/2025, response/answer due 1/23/2025; feething.com served on 1/2/2025, response/answer due 1/23/2025; freedoam.com served on 1/2/2025, response/answer due 1/23/2025; funzebrabags.com served on 1/2/2025, response/answer due 1/23/2025; futbolmercado.co served on 1/2/2025, response/answer due 1/23/2025; geetor.com served on 1/2/2025, response/answer due 1/23/2025; gukxbag.shop served on 1/2/2025, response/answer due 1/23/2025; josiejewelry.com served on 1/2/2025, response/answer due 1/23/2025; kkserrtt.shop served on 1/2/2025, response/answer due 1/23/2025; knightshop.top served on 1/2/2025, response/answer due 1/23/2025; krystalove.com served on 1/2/2025, response/answer due 1/23/2025; kuicur.com served on 1/2/2025, response/answer due 1/23/2025; lifeastop.com served on 1/2/2025, response/answer due 1/23/2025; limradesigns.com served on 1/2/2025, response/answer due 1/23/2025; linaq.shop served on 1/2/2025, response/answer due 1/23/2025; lussosbag.com served on 1/2/2025, response/answer due 1/23/2025; luxetsy.com served on 1/2/2025, response/answer due 1/23/2025; luxuriesbrand.com served on 1/2/2025, response/answer due 1/23/2025; luxurioustotes.myshopify.com served on 1/2/2025, response/answer due 1/23/2025; luxuryoutfits.shop served on 1/2/2025, response/answer due 1/23/2025; luxuryvaluebags.com served on 1/2/2025, response/answer due 1/23/2025; luxybags.shop served on 1/2/2025, response/answer due 1/23/2025; lvbags.ru served on 1/2/2025, response/answer due 1/23/2025; meegift.com served on 1/2/2025, response/answer due 1/23/2025; saksoff5th.love served on 1/2/2025, response/answer due 1/23/2025; sneaksnstuff.com served on 1/2/2025, response/answer due 1/23/2025; superwatch.top served on 1/2/2025, response/answer due 1/23/2025; teecoolstore.com served on 1/2/2025, response/answer due 1/23/2025; toplevelbag.shop served on 1/2/2025, response/answer due 1/23/2025; tpomi.com served on 1/2/2025, response/answer due 1/23/2025; tshirtvan.com served on 1/2/2025, response/answer due 1/23/2025; ultra-collection.com served on 1/2/2025, response/answer due 1/23/2025; vip.follow-trends.com served on 1/2/2025, response/answer due 1/23/2025; waxinmne.com served on 1/2/2025, response/answer due 1/23/2025; yoostyletrends.com served on 1/2/2025, response/answer due 1/23/2025; you-shiny.com served on 1/2/2025, response/answer due 1/23/2025; yupoovendor.ru served on 1/2/2025, response/answer due 1/23/2025; zekeego.cc served on 1/2/2025, response/answer due 1/23/2025; zorabbit.com served on 1/2/2025, response/answer due 1/23/2025.

Affidavit of Service

Affidavit of Service

Affidavit of Service

Plaintiff's MOTION for Clerk's Entry of Default as to The Individuals, Business Entities, and Unincorporated Associations Identified on Schedule A, akmood.com, aplusrelu.com, azelleshop.com, bagagents.com, bagsattire.com, bagsch.com, bagshubb.com, barbarasharon.com, bartona.top, bearsold.com, beeonevip.com, boycemoa.online, cetusstore.com, chicopulent.com, cocosike.cc, elegantbag.shop, evaluxurystore.com, extravagant-fashion.com, feething.com, freedoam.com, funzebrabags.com, geetor.com, gukxbag.shop, josiejewelry.com, kkserrtt.shop, knightshop.top, krystalove.com, kuicur.com, lifeastop.com, limradesigns.com, linaq.shop, lussosbag.com, luxetsy.com, luxuriesbrand.com, luxurioustotes.myshopify.com, luxuryoutfits.shop, luxuryvaluebags.com, luxybags.shop, lvbags.ru, meegift.com, saksoff5th.love, sneaksnstuff.com, superwatch.top, teecoolstore.com, toplevelbag.shop, tpomi.com, tshirtvan.com, ultra-collection.com, vip.follow-trends.com, waxinmne.com, yoostyletrends.com, you-shiny.com, yupoovendor.ru, zekeego.cc, zorabbit.com by Burberry Limited(a New York corporation), Burberry Limited(a United Kingdom company).

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" hereto, (collectively "Defendants") - Motions Terminated: [32] Motion for Clerks Entry of Default, Signed by DEPUTY CLERK on 1/28/2025.

NOTICE of Settlement with Defendant Number 22 by Burberry Limited(a New York corporation), Burberry Limited(a United Kingdom company) (O'Leary, Annie)

ORDER ON DEFAULT JUDGMENT PROCEDURE. Responses due by 2/28/2025. Signed by Judge Beth Bloom on 1/29/2025. See attached document for full details.

Plaintiff's MOTION to Approve Consent Judgment as to Defendant Number 22 (Responses due by 2/18/2025.), Plaintiff's MOTION for Permanent Injunction as to Defendant Number 22 by Burberry Limited(a New York corporation), Burberry Limited(a United Kingdom company).

Exhibit 1 - Statement of Consent

Exhibit 2 - Proposed Consent Final Judgment

CONSENT FINAL JUDGMENT AND PERMANENT INJUNCTION AS TO DEFENDANT NUMBER 22: The Parties Motion, ECF No. [36], is GRANTED. Final Judgment is entered in favor of Plaintiffs and against Defendant Number 22. Signed by Judge Beth Bloom on 2/4/2025. 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 New York corporation), Burberry Limited(a United Kingdom company).

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 Granting Motion for Default Final Judgment

Text of Proposed Order Granting Default Final Judgment and Permanent Injunction

Plaintiff's MOTION for Extension of Time to File Motion for Default Final Judgment or Notice of Joint Liability as to Defendant Number 20 re [35] Order, Set/Reset Deadlines by Burberry Limited(a New York corporation), Burberry Limited(a United Kingdom company). Responses due by 3/4/2025.

Text of Proposed Order

PAPERLESS ORDER granting 39 Motion for Extension of Time until March 14, 2025, to file their Motion for Default Final Judgment or a Notice of Joint Liability as to Defendant Number 20. Signed by Judge Beth Bloom

Plaintiff's NOTICE of Identification of Additional Financial Account Used By Defendant Number 16 by Burberry Limited(a New York corporation), Burberry Limited(a United Kingdom company)

Declaration of Kathleen Burns in Support Thereof

Exhibit 1 to the Declaration of Kathleen Burns

Plaintiff's MOTION to Approve Consent Judgment as to Defendant Number 20 by Burberry Limited(a New York corporation), Burberry Limited(a United Kingdom company). Responses due by 3/13/2025.

Exhibit 1 - Statement of Consent

Text of Proposed Order Consent Final Judgment and Permanent Injunction as to Def

ORDER GRANTING 42 MOTION TO APPROVE CONSENT JUDGMENT AND CONSENT FINAL JUDGMENT AND PERMANENT INJUNCTION AS TO DEFENDANT NUMBER 20. Signed by Judge Beth Bloom on 2/28/2025. See attached document for full details.

DEFAULT FINAL JUDGMENT AND PERMANENT INJUNCTION in favor of PLAINTIFFS, Burberry Limited, et al., and against DEFENDANTS, The Individuals, Business Entities, and Unincorporated Associations Identified on Schedule A. ADMINISTRATIVELY CLOSING CASE. Signed by Judge Beth Bloom on 2/28/2025. See attached document for full details.

Plaintiff's NOTICE upon Defendants via Electronic Mail by Burberry Limited(a New York corporation), Burberry Limited(a United Kingdom company) re [44] Default Judgment

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Burberry Limited(a New York corporation), Burberry Limited(a United Kingdom company) re [44] Default Judgment, upon Defendants via website posting