2026-cv-21493

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. Filing fees $ 405.00 receipt number AFLSDC-19287683, filed by Omega SA.

Civil Cover Sheet

Exhibit 1 to Complaint Certificates of Registration for the Omega Trademarks

Clerks Notice of Judge Assignment to Judge Jose E. Martinez. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Eduardo I. Sanchez 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

OMNIBUS ORDER REGARDING SCHEDULE "A" CAUSES OF ACTION. Signed by Judge Jose E. Martinez on 3/6/2026. See attached document for full details.

Plaintiff's Corporate Disclosure Statement by Omega SA identifying Corporate Parent The Swatch Group, Ltd. for Omega SA

Plaintiff's RESPONSE to [4] Order by Omega SA.

Plaintiff's MOTION to Seal per Local Rule 5.4 by Omega SA. Responses due by 3/30/2026.

Text of Proposed Order

ORDER denying as moot [7] Motion to File Under Seal. The Clerk kis DIRECTED to unseal all pleadings previously filed under seal. Signed by Judge Jose E. Martinez on 3/24/2026. See attached document for full details.

CLERK'S NOTICE of Compliance by Unsealing DE 8 & 9 pursuant to DE 10 Order.

ORDER Authorization of Alternative Service of Process. The Plaintiff's Motion, [ECF No. [9]] is hereby GRANTED. Signed by Judge Jose E. Martinez on 3/24/2026. See attached document for full details.

Surety BOND in the amount of $10,000.00 receipt # S-999525 posted by Omega SA Approved by Judge Jose E. Martinez

AMENDED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants, filed by Omega SA.

Exhibit 1 to Amended Complaint Certificates of Registration for the Omega Trade

NOTICE of Filing Proposed Summons(es) by Omega SA re [12] Order for Appointment of Special Process Server

Summon(s)

Summons Issued as to The Individuals, Business Entities, and Unincorporated Associations Identified on Schedule A.

Summons Reissued as to The Individuals, Business Entities, and Unincorporated Associations Identified on Schedule A.

Plaintiff's NOTICE upon Defendants via Electronic Mail by Omega SA re [13] Amended Complaint/Amended Notice of Removal, [10] Order on Motion to Seal, [8] Plaintiff's EX PARTE MOTION Entry of Temporary Restraining Order and Order Restraining Transfer of Assets and Memorandum of Law in Support Thereof, [1] Complaint

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Omega SA re [13] Amended Complaint/Amended Notice of Removal, [9] Motion for Appointment of Special Process Server, [4] Order, [5] Certificate of Other Affiliates/Corporate Disclosure Statement, [1] Complaint, [10] Order on Motion to Seal, [3] Form AO 120/121, [7] Plaintiff's MOTION to Seal per Local Rule 5.4, [2] Clerks Notice of Judge Assignment, [12] Order for Appointment of Special Process Server, [15] Notice of Filing Proposed Summons(es), [8] Plaintiff's EX PARTE MOTION Entry of Temporary Restraining Order and Order Restraining Transfer of Assets and Memorandum of Law in Support Thereof, [14] Bond, [6] Response/Reply (Other), [11] Notice of Compliance upon Defendants via website posting

Plaintiff's NOTICE of Identification of Additional Aliases and Additional Financial Accounts Used by Defendant Numbers 1, 2, 7, 10, 11, 20, 27, and 29 by Omega SA

Declaration of Kathleen Burns in Support Thereof

Exhibit 1 to the Declaration of Kathleen Burns

Plaintiff's MOTION for Preliminary Injunction and Memorandum of Law in Support Thereof by Omega SA. Responses due by 4/16/2026.

Text of Proposed Order

ORDER OF REFERENCE TO MAGISTRATE JUDGE REFERRING DE [21] Plaintiff's MOTION for Preliminary Injunction and Memorandum of Law in Support Thereof filed by Omega SA. Motions referred to Judge Eduardo I. Sanchez. Signed by Judge Jose E. Martinez on 4/2/2026. See attached document for full details.

ORDER Setting Preliminary Injunction Hearing and Briefing Schedule. Responses due April 7, 2026; Reply due April 10, 2026. Preliminary Injunction Hearing is SET for April 13, 2026, at 1:30 PM before the Honorable Eduardo I. Sanchez in Courtroom 6 of the C. Clyde Atkins United States Courthouse, located at 301 N. Miami Avenue in Miami, Florida. Signed by Magistrate Judge Eduardo I. Sanchez on 4/2/2026. See attached document for full details. (ab05)

Plaintiff's MOTION to Extend Temporary Restraining Order re [10] Order on Motion to Seal, by Omega SA. Responses due by 4/17/2026.

Text of Proposed Order

Plaintiff's NOTICE upon Defendants via Electronic Mail by Omega SA re [21] Plaintiff's MOTION for Preliminary Injunction and Memorandum of Law in Support Thereof, [23] Order Setting Hearing on Motion, Set/Reset Deadlines, [22] Order Referring Motion

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Omega SA re [21] Plaintiff's MOTION for Preliminary Injunction and Memorandum of Law in Support Thereof, [23] Order Setting Hearing on Motion, Set/Reset Deadlines, [22] Order Referring Motion, upon Defendants via website posting

SUMMONS (Affidavit) Returned Executed on [13] Amended Complaint/Amended Notice of Removal, [1] Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Omega SA. bagfactorysupply.com served on 4/2/2026, response/answer due 4/23/2026; caroline-watch.shop served on 4/2/2026, response/answer due 4/23/2026; chronoxi.com served on 4/2/2026, response/answer due 4/23/2026; cleantimewatch.shop served on 4/2/2026, response/answer due 4/23/2026; cmarno.com served on 4/2/2026, response/answer due 4/23/2026; eternaldynasty.shop served on 4/2/2026, response/answer due 4/23/2026; hbmdz.shop served on 4/2/2026, response/answer due 4/23/2026; heartofgeneva.com served on 4/2/2026, response/answer due 4/23/2026; intfwatch.com served on 4/2/2026, response/answer due 4/23/2026; luxswis.com served on 4/2/2026, response/answer due 4/23/2026; luxurywatchbagdeals.com served on 4/2/2026, response/answer due 4/23/2026; luxurywatchboex.com served on 4/2/2026, response/answer due 4/23/2026; luxurywatchroom.com served on 4/2/2026, response/answer due 4/23/2026; millclub.shop served on 4/2/2026, response/answer due 4/23/2026; nestawatch.com served on 4/2/2026, response/answer due 4/23/2026; philipsiwatch.shop served on 4/2/2026, response/answer due 4/23/2026; royaltimer.com served on 4/2/2026, response/answer due 4/23/2026; silkwatch.shop served on 4/2/2026, response/answer due 4/23/2026; swisslights.shop served on 4/2/2026, response/answer due 4/23/2026; swissreplicaclub.com served on 4/2/2026, response/answer due 4/23/2026; ticktockwear.com served on 4/2/2026, response/answer due 4/23/2026; topluxurywatch.shop served on 4/2/2026, response/answer due 4/23/2026; toptimewatchcenter.com served on 4/2/2026, response/answer due 4/23/2026; touch-watch.com served on 4/2/2026, response/answer due 4/23/2026; uluxurywatch.com served on 4/2/2026, response/answer due 4/23/2026; unitedluxury-us.com served on 4/2/2026, response/answer due 4/23/2026; unitedluxurywatch.com served on 4/2/2026, response/answer due 4/23/2026; victoriawatch.com served on 4/2/2026, response/answer due 4/23/2026; watchtiques.com served on 4/2/2026, response/answer due 4/23/2026; wristenchantment.com served on 4/2/2026, response/answer due 4/23/2026.

Affidavit of Service

Affidavit of Service

ORDER: Granting [24] Motion. Signed by Judge Jose E. Martinez on 4/6/2026. See attached document for full details.

NOTICE of Compliance by Omega SA re [23] Order Setting Hearing on Motion, Set/Reset Deadlines

Plaintiff's NOTICE of E-Mail Correspondence Received by Omega SA

Exhibit 1 to the Notice

PAPERLESS Minute Order for proceedings held before Magistrate Judge Eduardo I. Sanchez: Motion Hearing held on 4/13/2026 re 21 Plaintiff's MOTION for Preliminary Injunction. Report and Recommendations to follow. Total time in court: 26 minutes. Attorney Appearance(s): T. Raquel Wiborg-Rodriguez -Plaintiff Counsel (Digital 13:39:41)

REPORT AND RECOMMENDATION re [21] Plaintiff's Motion for Entry of Preliminary Injunction. Objections to Report and Recommendation due by April 17, 2026. Plaintiff's counsel SHALL SERVE a copy of this Report and Recommendation by no later than 12 noon on April 15, 2026 and shall file proof of service thereof. Signed by Magistrate Judge Eduardo I. Sanchez on 4/14/2026. See attached document for full details.

Plaintiff's NOTICE upon Defendants via Electronic Mail by Omega SA re [32] REPORT AND RECOMMENDATIONS re [21] Plaintiff's MOTION for Preliminary Injunction and Memorandum of Law in Support Thereof filed by Omega SA

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Omega SA re [32] REPORT AND RECOMMENDATIONS re [21] Plaintiff's MOTION for Preliminary Injunction and Memorandum of Law in Support Thereof filed by Omega SA upon Defendants via website posting

NOTICE of Compliance by Omega SA re [32] REPORT AND RECOMMENDATIONS re [21] Plaintiff's MOTION for Preliminary Injunction and Memorandum of Law in Support Thereof filed by Omega SA

ORDER ; granting [21] Motion for Preliminary Injunction; Adopting [32] Report and Recommendations Signed by Judge Jose E. Martinez on 4/20/2026. See attached document for full details.