2026-cv-21904

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. Filing fees $ 405.00 receipt number AFLSDC-19342021, filed by Chloe S.A.S.

Civil Cover Sheet

Exhibit 1 to Complaint Certificates of Registration for Plaintiffs Trademarks

Clerk's Notice of Judge Assignment to Judge David S. Leibowitz. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Panayotta Augustin-Birch 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.

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

Complaint w/ Exhibits

ORDER IN CASES WITH SCHEDULE "A" DEFENDANTS re [1] Complaint, filed by Chloe S.A.S. Signed by Judge David S. Leibowitz on 3/24/2026. See attached document for full details.

Plaintiff's Corporate Disclosure Statement by Chloe S.A.S. identifying Corporate Parent Compagnie Financiere Richemont SA for Chloe S.A.S.

Plaintiff's RESPONSE to [4] Order by Chloe S.A.S.

Plaintiff's MOTION to Seal per Local Rule 5.4 by Chloe S.A.S. Responses due by 4/9/2026.

Text of Proposed Order

ORDER Granting [7] Motion to File Under Seal. Schedule A to Plaintiff's Complaint shall be filed under seal and shall remain under seal until further order from this Court. Signed by Judge David S. Leibowitz on 3/26/2026. See attached document for full details.

Order

Plaintiff's MOTION to Unseal Case by Chloe S.A.S. Responses due by 4/14/2026.

Text of Proposed Order

ORDER Granting [14] Motion to Unseal. The Clerk of the Court is hereby DIRECTED to unseal all docket entries in this case and return those portions of the Court file to the public records. Signed by Judge David S. Leibowitz on 4/1/2026. See attached document for full details.

NOTICE of Compliance re 15 Order on Motion to Unseal Case. All documents have been unsealed per DE#15.

Plaintiff's NOTICE upon Defendants via Electronic Mail by Chloe S.A.S. re [12] Sealed Order on Motion, Order on Ex Parte Motion, [8] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order and Order Restraining Transfer of Assets and Memorandum of Law in Support Thereof, [1] Complaint, [14] Plaintiff's MOTION to Unseal Case

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Chloe S.A.S. re [12] Sealed Order on Motion, Order on Ex Parte Motion, [8] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order and Order Restraining Transfer of Assets and Memorandum of Law in Support Thereof, [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, [11] Sealed Order on Motion, Order on Ex Parte Motion, [10] Order on Motion to Seal, [1] Complaint, [2] Clerks Notice of Judge Assignment, [7] Plaintiff's MOTION to Seal per Local Rule 5.4, [5] Certificate of Other Affiliates/Corporate Disclosure Statement, [4] Order, [14] Plaintiff's MOTION to Unseal Case, [13] Sealed Document, [3] Form AO 120/121, [6] Response/Reply (Other) upon Defendants via website posting

AMENDED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants, filed by Chloe S.A.S.

Exhibit 1 to Amended Complaint Certificates of Registration for Plaintiffs Trad

NOTICE of Filing Proposed Summons(es) by Chloe S.A.S. re [11] Sealed Order on Motion, Order on Ex Parte Motion

Summon(s)

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

Bond on Injunction in the amount of $10,000.00 posted by Chloe S.A.S. Approved by Judge David S. Leibowitz

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

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

SUMMONS (Affidavit) Returned Executed on [19] Amended Complaint/Amended Notice of Removal, [1] Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Chloe S.A.S. compofac.fr served on 4/2/2026, response/answer due 4/23/2026; nacidilekli.com served on 4/2/2026, response/answer due 4/23/2026; refugeeslockdown.com served on 4/2/2026, response/answer due 4/23/2026.

Affidavit of Service

Affidavit of Service

Plaintiff's MOTION for Extension of Time to Extend Temporary Restraining Order Dated March 27, 2026 re [12] Sealed Order on Motion, Order on Ex Parte Motion by Chloe S.A.S. Responses due by 4/21/2026.

Text of Proposed Order

ORDER Granting [25] Motion for Extension of Time. The temporary restraining order shall remain in effect until such time as the Court rules on Plaintiff's motion to convert the temporary restraining order into a preliminary injunction. Signed by Judge David S. Leibowitz on 4/9/2026. See attached document for full details.

Plaintiff's MOTION for Clerk's Entry of Default as to The Individuals, Business Entities, and Unincorporated Associations Identified on Schedule A, compofac.fr, nacidilekli.com, refugeeslockdown.com by Chloe S.A.S. Responses due by 5/8/2026.

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

Text of Proposed Order

Clerk's Entry of Default as to compofac.fr, nacidilekli.com, refugeeslockdown.com - Motions Terminated: 27 Motion for Clerks Entry of Default, Signed by DEPUTY CLERK on 4/27/2026.

Clerk's Entry/Non-Entry of Default - FORM

Notice Setting Hearing [23] Plaintiff's MOTION for Preliminary Injunction and Memorandum of Law in Support Thereof : Motion Hearing set for 5/8/2026 10:30 AM in Miami Division before Judge David S. Leibowitz. Signed by Judge David S. Leibowitz on 4/28/2026. See attached document for full details.

Plaintiff's NOTICE upon Defendants via Electronic Mail by Chloe S.A.S. re [29] Order Setting Hearing on Motion

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by Chloe S.A.S. re [29] Order Setting Hearing on Motion, upon Defendants via website posting

Plaintiff's MOTION for Default Judgment Against Defendants and Memorandum of Law in Support Thereof by Chloe S.A.S. Responses due by 5/14/2026.

Declaration of Emma-Jane Tritton in Support Thereof

Exhibit 1 to the Declaration of Emma-Jane Tritton

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