2025-cv-23834

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. Filing fees $ 405.00 receipt number AFLSDC-18734402, filed by Louis Vuitton Malletier.

Civil Cover Sheet

(Complaint w/ Exhibits) (caw)

(Text of Proposed Order) (Wiborg-Rodriguez, T.)

Declaration of Hadrien Huet in Support Thereof

Declaration of T. Raquel Wiborg-Rodriguez in Support Thereof

(Schedule "A" to Plaintiff's Complaint for Damages and Injunctive Relief) (Wiborg-Rodriguez, T.) Modified text on 9/10/2025 (kpe). Modified to unseal on 9/12/2025 per DE#19. (scn)

(Summon(s)) (Wiborg-Rodriguez, T.) Modified text on 9/10/2025 (kpe). Modified to unseal on 9/12/2025 per DE#19. (scn)

(Text of Proposed Order)(Wiborg-Rodriguez, T.)

Exhibit 1 to Amended Complaint - Certificates of Registration for the Louis Vuit

Exhibit Certificate of Sevice

Affidavit of Service

Exhibit Corrected Certificate of Sevice

Affidavit of Service

Text of Proposed Order Setting Hearing on Motion for Entry of Preliminary Injunc

Text of Proposed Order

Exhibit Certificate of Sevice

Exhibit A- Peng Decl.

Declaration of T. Raquel Wiborg-Rodriguez in Support Thereof

Exhibit 1 to the Notice of E-mail Correspondence

Declaration of Hadrien Huet in Support of Plaintiff's Reply to Defendant N

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

Clerk's 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. Pro se (NON-PRISONER) litigants may receive Notices of Electronic Filings (NEFS) via email after filing a Consent by Pro Se Litigant (NON-PRISONER) to Receive Notices of Electronic Filing. The consent form is available under the forms section of our website.

(Exhibit 1 to Complaint - Certificates of Registration for the Louis Vuitton Trademarks)

Exhibit 1 to the Declaration of Hadrien Huet

Exhibit 1 to the Declaration of T. Raquel Wiborg-Rodriguez

Affidavit of Service

Affidavit of Service

Exhibit B- Infringing Evidence Provided by Plaintiff

Exhibit 1 to the Declaration of T. Raquel Wiborg-Rodriguez

Exhibit 1 to the Declaration of Hadrien Huet

Text of Proposed Order

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

Declaration of T. Raquel Wiborg-Rodriguez in Support Thereof

Exhibit 2 to the Declaration of T. Raquel Wiborg-Rodriguez

Affidavit of Service

Exhibit 2 to the Declaration of T. Raquel Wiborg-Rodriguez

ORDER REQUIRING SCHEDULING REPORT AND CERTIFICATES OF INTERESTED PARTIES. Signed by Judge Beth Bloom on 8/27/2025. See attached document for full details.

Declaration of Kathleen Burns in Support Thereof

Declaration of Huang Yu Ting in Support Thereof

OMNIBUS ORDER REGARDING SCHEDULE "A" CAUSES OF ACTION re 1 Complaint, filed by Louis Vuitton Malletier Signed by Judge Beth Bloom on 8/27/2025. See attached document for full details.

Exhibit 1, Part 1, to the Declaration of Kathleen Burns

Exhibit 1 to the Declaration of Huang Yu Ting

Plaintiff's Corporate Disclosure Statement by Louis Vuitton Malletier identifying Corporate Parent LVMH Moet Hennessy Louis Vuitton, SE for Louis Vuitton Malletier (Wiborg-Rodriguez, T.)

Exhibit 1, Part 2, to the Declaration of Kathleen Burns

Declaration of Kathleen Burns in Support Thereof

Plaintiff's RESPONSE to 5 Order by Louis Vuitton Malletier. (Wiborg-Rodriguez, T.)

Exhibit 1, Part 3, to the Declaration of Kathleen Burns

Exhibit 1 to the Declaration of Kathleen Burns

Plaintiff's MOTION to Seal per Local Rule 5.4 by Louis Vuitton Malletier.

Exhibit 1, Part 4, to the Declaration of Kathleen Burns

(Text of Proposed Order) (Wiborg-Rodriguez, T.) Modified to unseal on 9/12/2025 per DE#19. (scn)

Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order and Order Restraining Transfer of Assets Against Defendants and Memorandum of Law in Support Thereof by Louis Vuitton Malletier.

(Text of Proposed Order) (Wiborg-Rodriguez, T.) Modified to unseal on 9/12/2025 per DE#19. (scn)

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 Louis Vuitton Malletier.

Order (Text entry; no document attached.)

ORDER granting 8 Motion to Seal Signed by Judge Beth Bloom on 9/10/2025. (amb) Modified to unseal on 9/12/2025 per DE#19.

ORDER granting 9 Ex Parte Motion. Signed by Judge Beth Bloom on 9/10/2025. See attached document for full details. (amb) Modified to unseal on 9/12/2025 per DE#19.

ORDER granting 10 Ex Parte Motion. Signed by Judge Beth Bloom on 9/10/2025. See attached document for full details. (amb) Modified to unseal on 9/12/2025 per DE#19.

NOTICE of Filing of Schedule "A" to Plaintiff's Complaint for Damages and Injunctive Relief re DE 11 Order by Louis Vuitton Malletier.

Notice of Filing Proposed Summonses Under Seal by Louis Vuitton Malletier.

Summons issued as to The Individuals, Business Entities, and Unincorporated Associations Identified on Schedule A. (kpe) Modified to unseal on 9/12/2025 per DE#19.

NOTICE of Conventional filing of Bond by Louis Vuitton Malletier. Bond on Injunction in the amount of $10,000.00 received in Fort Lauderdale. (scn) Modified to unseal on 9/12/2025 per DE#19.

Plaintiff's MOTION to Unseal Case by Louis Vuitton Malletier. Responses due by 9/25/2025.

PAPERLESS ORDER granting ECF No. 18, Motion to Unseal Case. The Clerk of Court is directed to unseal all filings in this case. Signed by Judge Beth Bloom

AMENDED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants, filed by Louis Vuitton Malletier.

Plaintiff's NOTICE upon Defendants via Electronic Mail by Louis Vuitton Malletier re [1] Complaint, [12] Order on Ex Parte Motion, [9] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order and Order Restraining Transfer of Assets Against Defendants and Memorandum of Law in Support Thereof, [18] Plaintiff's MOTION to Unseal Case

CERTIFICATE OF SERVICE by Louis Vuitton Malletier re [4] Order Requiring Joint Scheduling Report, [15] Ex Parte Document, [14] Ex Parte Document, [1] Complaint, [11] Sealed Order on Motion, Order on Motion to Seal, [12] Order on Ex Parte Motion, [9] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order and Order Restraining Transfer of Assets Against Defendants and Memorandum of Law in Support Thereof, [18] Plaintiff's MOTION to Unseal Case, [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, [6] Certificate of Other Affiliates/Corporate Disclosure Statement, [8] Plaintiff's MOTION to Seal per Local Rule 5.4, [5] Order, [3] Form AO 120/121, [2] Clerks Notice of Judge Assignment, [7] Response/Reply (Other), [13] Order on Ex Parte Motion upon Defendants via website posting

SUMMONS (Affidavit) Returned Executed on [1] Complaint, [20] Amended Complaint/Amended Notice of Removal, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Louis Vuitton Malletier. 24fluxury.com served on 9/15/2025, response/answer due 10/6/2025; 24sluxurybag.com served on 9/15/2025, response/answer due 10/6/2025; 7daybag.life served on 9/15/2025, response/answer due 10/6/2025; aceluxuryfactory.com served on 9/15/2025, response/answer due 10/6/2025; adornook.com served on 9/15/2025, response/answer due 10/6/2025; altrava.shop served on 9/15/2025, response/answer due 10/6/2025; americanshoess.com served on 9/15/2025, response/answer due 10/6/2025; aurelar.com served on 9/15/2025, response/answer due 10/6/2025; avaelf88.com served on 9/15/2025, response/answer due 10/6/2025; bagdirect.us served on 9/15/2025, response/answer due 10/6/2025; balabalashop.com served on 9/15/2025, response/answer due 10/6/2025; beseniorsense.com served on 9/15/2025, response/answer due 10/6/2025; blingix.com served on 9/15/2025, response/answer due 10/6/2025; camellialabel.com served on 9/15/2025, response/answer due 10/6/2025; carry.luxe served on 9/15/2025, response/answer due 10/6/2025; caseylw.com served on 9/15/2025, response/answer due 10/6/2025; ccllff.shop served on 9/15/2025, response/answer due 10/6/2025; chi-purses.com served on 9/15/2025, response/answer due 10/6/2025; dejavuhof.com served on 9/15/2025, response/answer due 10/6/2025; dmshoesbag.com served on 9/15/2025, response/answer due 10/6/2025; dripslum.com served on 9/15/2025, response/answer due 10/6/2025; drkick.ru served on 9/15/2025, response/answer due 10/6/2025; fansfave.shop served on 9/15/2025, response/answer due 10/6/2025; fashion.goabag.com served on 9/15/2025, response/answer due 10/6/2025; foryoushopi.com served on 9/15/2025, response/answer due 10/6/2025; freshnook.shop served on 9/15/2025, response/answer due 10/6/2025; gadsneak.com served on 9/15/2025, response/answer due 10/6/2025; glbmerchant.co served on 9/15/2025, response/answer due 10/6/2025; hidasic.com served on 9/15/2025, response/answer due 10/6/2025; ivhub.shop served on 9/15/2025, response/answer due 10/6/2025; kbcoco.cn served on 9/15/2025, response/answer due 10/6/2025; kentsyk.com served on 9/15/2025, response/answer due 10/6/2025; kickzoe.com served on 9/15/2025, response/answer due 10/6/2025; ladytote.com served on 9/15/2025, response/answer due 10/6/2025; loomnoble.com served on 9/15/2025, response/answer due 10/6/2025; louisvuitton-lv.shop served on 9/15/2025, response/answer due 10/6/2025; luxebirkin.com served on 9/15/2025, response/answer due 10/6/2025; luxewardrobes.shop served on 9/15/2025, response/answer due 10/6/2025; luxiebags.com served on 9/15/2025, response/answer due 10/6/2025; luxuryans.com served on 9/15/2025, response/answer due 10/6/2025; luxurybagsupply.com served on 9/15/2025, response/answer due 10/6/2025; luxurylives.shop served on 9/15/2025, response/answer due 10/6/2025; luxurylv.us served on 9/15/2025, response/answer due 10/6/2025; lvbagsoutlet.us.com served on 9/15/2025, response/answer due 10/6/2025; lvinstyle.com served on 9/15/2025, response/answer due 10/6/2025; lwluxusgift.com served on 9/15/2025, response/answer due 10/6/2025; macysclosingsale.com served on 9/15/2025, response/answer due 10/6/2025; melyrix.com served on 9/15/2025, response/answer due 10/6/2025; meridorm.shop served on 9/15/2025, response/answer due 10/6/2025; miss-dreams.com served on 9/15/2025, response/answer due 10/6/2025; moderwears.com served on 9/15/2025, response/answer due 10/6/2025; niceclotheshop.com served on 9/15/2025, response/answer due 10/6/2025; nordstromcreative.shop served on 9/15/2025, response/answer due 10/6/2025; onetoones.com served on 9/15/2025, response/answer due 10/6/2025; opulentshare.com served on 9/15/2025, response/answer due 10/6/2025; packharbor.shop served on 9/15/2025, response/answer due 10/6/2025; plorae.shop served on 9/15/2025, response/answer due 10/6/2025; pplvshop.com served on 9/15/2025, response/answer due 10/6/2025; qualitybeautiful.com served on 9/15/2025, response/answer due 10/6/2025; rebce.com served on 9/15/2025, response/answer due 10/6/2025; redsunclub.com served on 9/15/2025, response/answer due 10/6/2025; replicastore.org served on 9/15/2025, response/answer due 10/6/2025; rieny.com served on 9/15/2025, response/answer due 10/6/2025; schoolbagpark.com served on 9/15/2025, response/answer due 10/6/2025; snilanluxury.com served on 9/15/2025, response/answer due 10/6/2025; starsshop.top served on 9/15/2025, response/answer due 10/6/2025; topfactorystore.com served on 9/15/2025, response/answer due 10/6/2025; topfashionss.com served on 9/15/2025, response/answer due 10/6/2025; towerhobbiesus.com served on 9/15/2025, response/answer due 10/6/2025; urbanboutiquee.com served on 9/15/2025, response/answer due 10/6/2025; vgchekout.com served on 9/15/2025, response/answer due 10/6/2025; vipfasbags.com served on 9/15/2025, response/answer due 10/6/2025; voguehorology.shop served on 9/15/2025, response/answer due 10/6/2025; walmatwholesale.com served on 9/15/2025, response/answer due 10/6/2025; westjuices.com served on 9/15/2025, response/answer due 10/6/2025; yixinfashion.com served on 9/15/2025, response/answer due 10/6/2025; yyycid.com served on 9/15/2025, response/answer due 10/6/2025.

Corrected NOTICE upon Defendants via Electronic Mail by Louis Vuitton Malletier re [1] Complaint, [12] Order on Ex Parte Motion, [9] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order and Order Restraining Transfer of Assets Against Defendants and Memorandum of Law in Support Thereof, [18] Plaintiff's MOTION to Unseal Case

NOTICE of Striking [23] Summons Returned Executed, filed by Louis Vuitton Malletier by Louis Vuitton Malletier

CERTIFICATE OF SERVICE by Louis Vuitton Malletier re [1] Complaint, [12] Order on Ex Parte Motion, [9] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order and Order Restraining Transfer of Assets Against Defendants and Memorandum of Law in Support Thereof, [18] Plaintiff's MOTION to Unseal Case upon Defendant via Registrar

SUMMONS (Affidavit) Returned Executed on [1] Complaint, [20] Amended Complaint/Amended Notice of Removal, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Louis Vuitton Malletier.

Plaintiff's MOTION for Preliminary Injunction Against Defendants and Memorandum of Law in Support Thereof by Louis Vuitton Malletier.

ORDER Setting Hearing on Motion [28] Plaintiff's MOTION for Preliminary Injunction Against Defendants and Memorandum of Law in Support Thereof : Motion Hearing set for 9/25/2025 09:30 AM via Zoom before Judge Beth Bloom. Signed by Judge Beth Bloom on 9/19/2025. See attached document for full details.

Plaintiff's MOTION to Extend Temporary Restraining Order re [12] Order on Ex Parte Motion by Louis Vuitton Malletier.

PAPERLESS ORDER granting ECF No. 30 Motion to Extend Temporary Restraining Order. The Temporary restraining order shall be extended until October 8, 2025, or until the Court rules on the Motion for Preliminary Injunction, whichever is earlier. Signed by Judge Beth Bloom

NOTICE of Attorney Appearance by Jianyin Liu on behalf of altrava.shop. Attorney Jianyin Liu added to party altrava.shop(pty:dft).

Plaintiff's NOTICE upon Defendants via Electronic Mail by Louis Vuitton Malletier re [29] Order Setting Hearing on Motion

CERTIFICATE OF SERVICE by Louis Vuitton Malletier re [29] Order Setting Hearing on Motion, upon Defendant via Registrar

CERTIFICATE OF SERVICE by Louis Vuitton Malletier re [29] Order Setting Hearing on Motion, upon Defendants via website posting

RESPONSE in Opposition re [30] Plaintiff's MOTION to Extend Temporary Restraining Order re [12] Order on Ex Parte Motion, [9] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order and Order Restraining Transfer of Assets Against Defendants and Memorandum of Law in Support Thereof filed by altrava.shop. Replies due by 10/1/2025.

Plaintiff's REPLY in Support of Motion re [28] Plaintiff's MOTION for Preliminary Injunction Against Defendants and Memorandum of Law in Support Thereof. filed by Louis Vuitton Malletier.

Plaintiff's NOTICE of E-Mail Correspondence Received in Connection With Notice by Louis Vuitton Malletier

Plaintiff's NOTICE of Filing the the Declaration of Hadrien Huet by Louis Vuitton Malletier re [37] Reply in Support of Motion

MOTION to Withdraw as Attorney by Jianyin Liu for / by altrava.shop. Responses due by 10/14/2025.

ANSWER and Affirmative Defenses to Amended Complaint with Jury Demand by altrava.shop.

PAPERLESS Minute Entry for proceedings held before Judge Beth Bloom: and MINUTE ORDER Motion Hearing held on 9/25/2025 re ECF No. 28, Plaintiff's MOTION for Preliminary Injunction Against Defendants and Memorandum of Law in Support Thereof filed by Louis Vuitton Malletier. For the reasons stated on the record, Plaintiff's Motion, ECF No. 28, is granted. Paper order to follow. Total time in court: 0 hour(s) : 35 minutes. Attorney Appearance(s): Stephen Michael Gaffigan, T. Raquel Wiborg-Rodriguez, Jianyin Liu, Court Reporter: Yvette Hernandez, 305-523-5698 / Yvette_Hernandez@flsd.uscourts.gov.

ORDER granting [28] Motion for Entry of Preliminary Injunction. Signed by Judge Beth Bloom on 9/30/2025. See attached document for full details.

ORDER granting 40 Motion to Withdraw as Counsel. Jianyin Liu representing altrava.shop (Defendant) withdrawn from case. Deadline to obtain new counsel 10/15/2025. Signed by Judge Beth Bloom on 10/1/2025. See attached document for full details.

Plaintiff's MOTION for Clerk's Entry of Default as to 24fluxury.com, 24sluxurybag.com, 7daybag.life, The Individuals, Business Entities, and Unincorporated Associations Identified on Schedule A, aceluxuryfactory.com, adornook.com, americanshoess.com, aurelar.com, avaelf88.com, bagdirect.us, balabalashop.com, beseniorsense.com, blingix.com, camellialabel.com, carry.luxe, caseylw.com, ccllff.shop, chi-purses.com, dejavuhof.com, dmshoesbag.com, dripslum.com, drkick.ru, fansfave.shop, fashion.goabag.com, foryoushopi.com, freshnook.shop, gadsneak.com, glbmerchant.co, hidasic.com, ivhub.shop, kbcoco.cn, kentsyk.com, kickzoe.com, ladytote.com, loomnoble.com, louisvuitton-lv.shop, luxebirkin.com, luxewardrobes.shop, luxiebags.com, luxuryans.com, luxurybagsupply.com, luxurylives.shop, luxurylv.us, lvbagsoutlet.us.com, lvinstyle.com, lwluxusgift.com, macysclosingsale.com, melyrix.com, meridorm.shop, miss-dreams.com, moderwears.com, niceclotheshop.com, nordstromcreative.shop, onetoones.com, opulentshare.com, packharbor.shop, plorae.shop, pplvshop.com, qualitybeautiful.com, rebce.com, redsunclub.com, replicastore.org, rieny.com, schoolbagpark.com, snilanluxury.com, starsshop.top, topfactorystore.com, topfashionss.com, towerhobbiesus.com, urbanboutiquee.com, vgchekout.com, vipfasbags.com, voguehorology.shop, walmatwholesale.com, westjuices.com, yixinfashion.com, yyycid.com by Louis Vuitton Malletier.