2025-cv-05647

COMPLAINT filed by Fendi S.R.L.; Filing fee $ 405, receipt number AILNDC-23515271.

Exhibit 1

Exhibit 2

Exhibit 3

(Exhibit 4)

CASE ASSIGNED to the Honorable John Robert Blakey. Designated as Magistrate Judge the Honorable Jeannice W. Appenteng. Case assignment: Random assignment. (Civil Category 2).

CLERK'S NOTICE: Pursuant to Local Rule 73.1(b), a United States Magistrate Judge of this court is available to conduct all proceedings in this civil action. If all parties consent to have the currently assigned United States Magistrate Judge conduct all proceedings in this case, including trial, the entry of final judgment, and all post-trial proceedings, all parties must sign their names on the attached Consent To form. This consent form is eligible for filing only if executed by all parties. The parties can also express their consent to jurisdiction by a magistrate judge in any joint filing, including the Joint Initial Status Report or proposed Case Management Order.

CASE ASSIGNED to the Honorable John Robert Blakey. Designated as Magistrate Judge the Honorable Jeannice W. Appenteng. Case assignment: Random assignment. (Civil Category 2).

CLERK'S NOTICE: Pursuant to Local Rule 73.1(b), a United States Magistrate Judge of this court is available to conduct all proceedings in this civil action. If all parties consent to have the currently assigned United States Magistrate Judge conduct all proceedings in this case, including trial, the entry of final judgment, and all post-trial proceedings, all parties must sign their names on the attached Consent To form. This consent form is eligible for filing only if executed by all parties. The parties can also express their consent to jurisdiction by a magistrate judge in any joint filing, including the Joint Initial Status Report or proposed Case Management Order.

CIVIL Cover Sheet

ATTORNEY Appearance for Plaintiff Fendi S.R.L. by Paul Joseph Kossof

MOTION by Plaintiff Fendi S.R.L. to seal Schedule A and Exhibit 2 to the Declaration of Nicolas Lambert

SEALED DOCUMENT by Plaintiff Fendi S.R.L. Schedule A

NOTIFICATION of Affiliates pursuant to Local Rule 3.2 by Fendi S.R.L.

Notice of Claims Involving Trademarks by Fendi S.R.L.

Trademark Report by Fendi S.R.L.

DECLARATION of Nicolas Lambert

(Exhibit 1)

SEALED DOCUMENT by Plaintiff Fendi S.R.L. Exhibit 2 to the Declaration of Nicolas Lambert

DECLARATION of Paul Kossof

Exhibit 1

Exhibit 2

(Exhibit 3)

MOTION by Plaintiff Fendi S.R.L. to seal Plaintiff's Memorandum Establishing that Joinder is Proper

SEALED DOCUMENT by Plaintiff Fendi S.R.L. Plaintiff's Memorandum Establishing That Joinder is Proper

MOTION by Plaintiff Fendi S.R.L. for temporary restraining order

(Supplement Memorandum in Support of Motion for Temporary Restraining Order)

Motion for Electronic Service by Fendi S.R.L.

Supplement Memorandum in Support of Motion for Electronic Service

Declaration of Paul Kossof in Support of Motion for Electronic Service

Exhibit 1 to the Declaration of Paul Kossof in Support of Motion for Electronic Service

(Exhibit 2 to the Declaration of Paul Kossof in Support of Motion for Electronic Service)

MAILED trademark report to Patent Trademark Office, Alexandria VA

MAILED to plaintiff(s) counsel Lanham Mediation Program materials

Motion for electronic service 15 NOTICE of Motion by Paul Joseph Kossof for presentment of motion to seal 12, motion to seal 4, motion for temporary restraining order 14 before Honorable John Robert Blakey on 6/25/2025 at 11:00 AM.

MINUTE entry before the Honorable John Robert Blakey: The Court grants Plaintiff's motions to seal 4, 12. The Court also finds that Plaintiff's allegations support the joinder of Defendants in this single action. Plaintiff has alleged and established, via memorandum 12, that the sellers identified on Schedule A share "unique identifiers, such as templates with common design elements which intentionally omit any contact information or other information for identifying Defendants or other aliases they operate or use." Plaintiff has also established that the ecommerce stores operating under the Seller Aliases "include other notable common features, such as use of the same registration patterns, accepted payment methods, checkout methods, keywords, advertising tactics, similarities in price and quantities, the same incorrect grammar and misspellings, and/or the use of the same text and images." The Seller Aliases all sell the same unusual unauthorized product utilizing the same product pictures, thus bearing "indicia of being unauthorized to one another, suggesting that the Infringing Products were manufactured by and come from a common source and that Defendants are interrelated." For present purposes, this satisfies the "series of transactions or occurrences" requirement of section 299(a)(1), as well as Fed. R. Civ. P. 20(a)(2), and Plaintiff may proceed against the identified Defendants in this single action. 1, 2. Additionally, based upon the materials submitted, this Court grants Plaintiff's ex parte motion for entry of a temporary restraining order 14. Enter sealed temporary restraining order. Absent further Court order, this TRO will expire 7/7/25. Finally, based upon Plaintiff's submissions, the Court grants Plaintiff's motion for electronic service of process 15. The 6/25/25 Notice of Motion date is stricken. Mailed notice. (jcc,)

SEALED Temporary Restraining Order. Signed by the Honorable John Robert Blakey on 6/23/2025. (jcc,)

NOTICE by Fendi S.R.L. Plaintiffs Notice of Posting Bond

SURETY BOND in the amount of $ 10,000.00 posted by Fendi S.R.L.

SUMMONS Issued (Court Participant) as to Defendant The Partnerships and Unincorporated Associations identified on Schedule A of the Complaint

SUMMONS Returned Executed by Fendi S.R.L. as to All Defendants.

MOTION by Plaintiff Fendi S.R.L. for preliminary injunction

Supplement Memorandum in Support of Motion for Preliminary Injunction

Declaration of Paul Kossof in Support of Motion for Preliminary Injunction

(Exhibit 1 of the Declaration of Paul Kossof in Support of Motion for Preliminary Injunction)

NOTICE of Motion by Paul Joseph Kossof for presentment of motion for preliminary injunction, 26 before Honorable John Robert Blakey on 7/9/2025 at 11:00 AM.

MINUTE entry before the Honorable John Robert Blakey: The Court denies without prejudice Plaintiff's motion for preliminary injunction 26 because Plaintiff has failed to provide a complete proposed order; in particular, the proposed order Plaintiff submitted references a schedule A but neglects to attach the referenced Schedule. The 7/9/25 Notice of Motion date is stricken. Mailed notice.

MOTION by Plaintiff Fendi S.R.L. for preliminary injunction

NOTICE of Motion by Paul Joseph Kossof for presentment of motion for preliminary injunction 29 before Honorable John Robert Blakey on 7/16/2025 at 11:00 AM.

MINUTE entry before the Honorable John Robert Blakey: The Court denies without prejudice Plaintiff's renewed motion for preliminary injunction 29 because it appears Plaintiff has not served Defendants with the motion, as required by Fed. R. Civ. P. 65(a). The 7/16/25 Notice of Motion date is stricken. Mailed notice. (jn,)

MOTION by Plaintiff Fendi S.R.L. for preliminary injunction

(Supplement Memorandum in Support of Motion for Preliminary Injunction)

CERTIFICATE of Service by Plaintiff Fendi S.R.L. regarding MOTION by Plaintiff Fendi S.R.L. for preliminary injunction 32

NOTICE of Motion by Paul Joseph Kossof for presentment of motion for preliminary injunction 32 before Honorable John Robert Blakey on 7/23/2025 at 11:00 AM.

MINUTE entry before the Honorable John Robert Blakey: Based upon its schedule, the Court strikes the 7/23/25 Notice of Motion date and sets this matter for hearing 7/30/25 at 11:00 a.m. in Courtroom 1203. Mailed notice.

MOTION by Plaintiff Fendi S.R.L. for default judgment as to All Defendants Identified on Schedule A

Supplement Memorandum in Support of Motion for Default Judgment

Declaration of Paul Kossof in Support of Motion for Default Judgment

(Exhibit 1 to Declaration of Paul Kossof in Support of Motion for Default Judgment)

CERTIFICATE of Service by Plaintiff Fendi S.R.L. regarding MOTION by Plaintiff Fendi S.R.L. for default judgment as to All Defendants Identified on Schedule A 36

NOTICE of Motion by Paul Joseph Kossof for presentment of motion for default judgment, 36 before Honorable John Robert Blakey on 7/30/2025 at 11:00 AM.

MINUTE entry before the Honorable John Robert Blakey: The Court denies as premature Plaintiff's motion for default judgment 36 and strikes the 7/30/25 Notice of Motion date as to this motion; the motion hearing stands as to Plaintiff's motion for preliminary injunction 32. Mailed notice.

MINUTE entry before the Honorable John Robert Blakey: Motion hearing held on 7/30/2025 on Plaintiff's motion for preliminary injunction 32. The Court denies without prejudice the motion 32 for the reasons stated on the record. Mailed notice.

NOTICE of Voluntary Dismissal by Fendi S.R.L. of All Defendants Identified on Schedule A

MINUTE entry before the Honorable John Robert Blakey: Pursuant to the notice of voluntary dismissal, 41, this case is dismissed without prejudice under Rule 41(a). The Court strikes all set dates and deadlines. Civil case terminated. Mailed notice.