2025-cv-60729

COMPLAINT for Damages and Injunctive Relief against All Defendants. Filing fees $ 405.00 receipt number AFLSDC-18371812, filed by GIANNI VERSACE, S.R.L.

Civil Cover Sheet

Exhibit 1 to the Complaint

Clerks Notice of Judge Assignment to Judge Rodney Smith. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Patrick M. Hunt 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.

Clerk's Notice of Judge Assignment and Optional Consent

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

Complaint

Plaintiff's Corporate Disclosure Statement by GIANNI VERSACE, S.R.L. identifying Corporate Parent Capri Holdings Limited for GIANNI VERSACE, S.R.L.

Plaintiff's MOTION to Seal per Local Rule 5.4 by GIANNI VERSACE, S.R.L.

Text of Proposed Order Order Granting Motion to Seal

ORDER granting [5] Motion to File Under Seal. Signed by Judge Rodney Smith on 4/16/2025. See attached document for full details.

Order

NOTICE of Filing BOND in the amount of $10,000.00 posted by GIANNI VERSACE, S.R.L. Approved by Judge Rodney Smith

Plaintiff's MOTION to Unseal Case by GIANNI VERSACE, S.R.L. Responses due by 5/5/2025.

Text of Proposed Order Granting Motion to Unseal

Plaintiff's AMENDED COMPLAINT for Damages and Injunctive Relief against All Defendants, filed by GIANNI VERSACE, S.R.L.

Exhibit 1 to the Amended Complaint

ORDER Granting [15] Motion to Unseal. Signed by Judge Rodney Smith on 4/22/2025. See attached document for full details.

CLERK'S NOTICE of Compliance (All Docket Entries in this Case have been Unsealed) re 17 Order on Motion to Unseal.

Plaintiff's NOTICE upon Defendants via Electronic Mail by GIANNI VERSACE, S.R.L. re [16] Amended Complaint/Amended Notice of Removal, [15] Plaintiff's MOTION to Unseal Case, [12] Order on Ex Parte Motion, [6] Plaintiff's EX PARTE MOTION Entry of Temporary Restraining Order, Preliminary Injunction, and Order Restraining Transfer of Assets, [1] Complaint

Exhibit Certificate of Sevice

CERTIFICATE OF SERVICE by GIANNI VERSACE, S.R.L. re [4] Certificate of Other Affiliates/Corporate Disclosure Statement, [16] Amended Complaint/Amended Notice of Removal, [10] Sealed Document, [15] Plaintiff's MOTION to Unseal Case, [8] Order on Motion to Seal, [14] Bond, [12] Order on Ex Parte Motion, [9] Sealed Document, [5] Plaintiff's MOTION to Seal per Local Rule 5.4, [2] Clerks Notice of Judge Assignment, [3] Form AO 120/121, [6] Plaintiff's EX PARTE MOTION Entry of Temporary Restraining Order, Preliminary Injunction, and Order Restraining Transfer of Assets, [7] Plaintiff's EX PARTE MOTION Order Authorizing Alternate Service of Process on Defendants Pursuant to Federal Rule of Civil Procedure 4(f)(3), [1] Complaint, [13] Order on Ex Parte Motion upon Defendants via website posting

CERTIFICATE OF SERVICE by GIANNI VERSACE, S.R.L. re [16] Amended Complaint/Amended Notice of Removal, [15] Plaintiff's MOTION to Unseal Case, [12] Order on Ex Parte Motion, [6] Plaintiff's EX PARTE MOTION Entry of Temporary Restraining Order, Preliminary Injunction, and Order Restraining Transfer of Assets, [1] Complaint, upon Defendant via Registrar

CERTIFICATE OF SERVICE by GIANNI VERSACE, S.R.L. re [16] Amended Complaint/Amended Notice of Removal, [15] Plaintiff's MOTION to Unseal Case, [12] Order on Ex Parte Motion, [6] Plaintiff's EX PARTE MOTION Entry of Temporary Restraining Order, Preliminary Injunction, and Order Restraining Transfer of Assets, [1] Complaint, upon Defendant via Registrar

Plaintiff's NOTICE E-mail Inquiry Received from Defendant Number 35 in Connection with Service by GIANNI VERSACE, S.R.L.

Exhibit 1 to the Notice of E-mail Inquiry Received from Defendant Number 35 in C

ORDER RESETTING CALENDAR CALL (DIAL-IN ONLY) set for 5/1/2025 09:00 AM before Judge Rodney Smith. Signed by Judge Rodney Smith on 4/30/2025. See attached document for full details.

ORDER RESETTING CALENDAR CALL (DIAL-IN ONLY) Calendar Call set for 5/1/2025 09:00 AM before Judge Rodney Smith. Signed by Judge Rodney Smith on 4/30/2025. See attached document for full details.

Calendar Call Hearing(s) terminated.

Entry entered in error. Document has been re-docket. see DE 24 (ksr). Modified on 4/30/2025 (mr1).

PAPERLESS CORRECTIVE NOTICE of Hearing: Telephonic Preliminary Injunction Hearing set for 5/1/2025 09:00 AM in Fort Lauderdale Division before Judge Rodney Smith. Counsel shall call the audio conference toll-free number 833-435-1820, five (5) minutes prior to the start of the hearing. As prompted enter the Meeting ID number, 161-394-8699. The system will request a Participant ID, please disregard. As prompted enter the Passcode 632303. Counsel shall enter *6 to unmute and state your name and the name of the party you represent.

Calendar Call Hearing(s) terminated.

PAPERLESS NOTICE of Resetting Hearing: **TIME CHANGE ONLY** Preliminary Injunction Hearing set for 5/1/2025 08:45 AM in Fort Lauderdale Division before Judge Rodney Smith.

CERTIFICATE OF SERVICE by GIANNI VERSACE, S.R.L. re [23] Notice (Other), [27] Notice re Hearing, [24] Order Setting/Resetting/Cancelling Hearing, [26] Notice re Hearing, upon Defendants via Electronic Mail and via Website Posting

Plaintiff's NOTICE of E-mail Inquiry Received from Defendant Numbers 21, 43, and 49 in Connection with Service by GIANNI VERSACE, S.R.L.

Exhibit 1 to the Notice of E-mail Inquiry Received from Defendant Numbers 21, 43

PAPERLESS Minute Entry for proceedings held before Judge Rodney Smith: Miscellaneous Hearing held on 5/1/2025, after hearing from plaintiff's counsel, the Court to enter preliminary injunction, Order to follow. Attorney Appearance(s): Christine Ann Daley Court Reporter: Ellen Rassie, 954-769-5448 / ellen_rassie@flsd.uscourts.gov.

ORDER GRANTING MOTIONFOR ENTRY OF PRELIMINARY INJUNCTION re DE [6] Signed by Judge Rodney Smith on 5/1/2025. See attached document for full details.

(STRICKEN PER DE 33) Plaintiff's NOTICE of Additional Aliases for Defendant Numbers 13 and 40 and Additional Financial Accounts Used by Various Defendants by GIANNI VERSACE, S.R.L.

Declaration of Kathleen Burns in Support of Plaintiff's Notice of Additional Aliases for Defendant Numbers 13 and 40 and Additional Financial Accounts Used by Various Defendants

(Exhibit 1 to the Declaration of Kathleen Burns) Text Modified on 5/14/2025 (cqs)

NOTICE of Striking 32 Notice (Other), filed by GIANNI VERSACE, S.R.L. by GIANNI VERSACE, S.R.L.

Plaintiff's NOTICE of Additional Aliases for Defendant Numbers 13 and 40 and Additional Financial Accounts Used by Various Defendants by GIANNI VERSACE, S.R.L.

Declaration of Kathleen Burns in Support of Plaintiff's Notice of Additional Aliases for Defendant Numbers 13 and 40 and Additional Financial Accounts Used by Various Defendants

(Exhibit 1 to the Declaration of Kathleen Burns)

Plaintiff's NOTICE of Additional Alias for Defendant Number 6 and Additional Financial Accounts Used by Various Defendants by GIANNI VERSACE, S.R.L.

Declaration of Kathleen Burns in Support of Plaintiff's Notice of Addition

Exhibit 1 to the Declaration of Kathleen Burns

SUMMONS (Affidavit) Returned Executed on [16] Amended Complaint/Amended Notice of Removal, [1] Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by GIANNI VERSACE, S.R.L. 93stores.com served on 4/25/2025, response/answer due 5/16/2025; annaluxbag.com served on 4/25/2025, response/answer due 5/16/2025; annareps.com served on 4/25/2025, response/answer due 5/16/2025; astropya.shop served on 4/25/2025, response/answer due 5/16/2025; bagssense.com served on 4/25/2025, response/answer due 5/16/2025; bessvivien.com served on 4/25/2025, response/answer due 5/16/2025; bestmybest.xyz served on 4/25/2025, response/answer due 5/16/2025; bonniesunglass.com served on 4/25/2025, response/answer due 5/16/2025; brandhic.com served on 4/25/2025, response/answer due 5/16/2025; breeze-chic.myshopify.com served on 4/25/2025, response/answer due 5/16/2025; cbags.shop served on 4/25/2025, response/answer due 5/16/2025; cclcc.store served on 4/25/2025, response/answer due 5/16/2025; chbagsan.com served on 4/25/2025, response/answer due 5/16/2025; derels.com served on 4/25/2025, response/answer due 5/16/2025; eastcoastmerch.ca served on 4/25/2025, response/answer due 5/16/2025; ellyluxury.com served on 4/25/2025, response/answer due 5/16/2025; fashionswatchlook.shop served on 4/25/2025, response/answer due 5/16/2025; fcabins.top served on 4/25/2025, response/answer due 5/16/2025; feytwo.com served on 4/25/2025, response/answer due 5/16/2025; foxdark.com served on 4/25/2025, response/answer due 5/16/2025; glamogallery.myshopify.com served on 4/25/2025, response/answer due 5/16/2025; glasshub.shop served on 4/25/2025, response/answer due 5/16/2025; judyjewelry.com served on 4/25/2025, response/answer due 5/16/2025; larauntman.com served on 4/25/2025, response/answer due 5/16/2025; lbagsnew.com served on 4/25/2025, response/answer due 5/16/2025; lbagsv.com served on 4/25/2025, response/answer due 5/16/2025; luuxurbag.com served on 4/25/2025, response/answer due 5/16/2025; luxfade.com served on 4/25/2025, response/answer due 5/16/2025; luxnicely.com served on 4/25/2025, response/answer due 5/16/2025; luxuryuto.com served on 4/25/2025, response/answer due 5/16/2025; manlyfor.com served on 4/25/2025, response/answer due 5/16/2025; midhall.com served on 4/25/2025, response/answer due 5/16/2025; monvantiluxury.com served on 4/25/2025, response/answer due 5/16/2025; moorsfashion.top served on 4/25/2025, response/answer due 5/16/2025; nt-luxury.com served on 4/25/2025, response/answer due 5/16/2025; opphcz.shop served on 4/25/2025, response/answer due 5/16/2025; pod90luxury.com served on 4/25/2025, response/answer due 5/16/2025; reverlavie.com served on 4/25/2025, response/answer due 5/16/2025; sneakfitx.com served on 4/25/2025, response/answer due 5/16/2025; spendoy.live served on 4/25/2025, response/answer due 5/16/2025; stylemis.com served on 4/25/2025, response/answer due 5/16/2025; sunshineluxury520.cc served on 4/25/2025, response/answer due 5/16/2025; supre-tee.com served on 4/25/2025, response/answer due 5/16/2025; theluxcy.com served on 4/25/2025, response/answer due 5/16/2025; topbags-br.com served on 4/25/2025, response/answer due 5/16/2025; toteer.com served on 4/25/2025, response/answer due 5/16/2025; vogueclassique.com served on 4/25/2025, response/answer due 5/16/2025; xluxurys.com served on 4/25/2025, response/answer due 5/16/2025; yomolux.com served on 4/25/2025, response/answer due 5/16/2025; zzak.cc served on 4/25/2025, response/answer due 5/16/2025.

Affidavit of Service

Affidavit of Service

Affidavit of Service

Plaintiff's MOTION for Clerk's Entry of Default as to 93stores.com, The Individuals, Business Entities, and Unincorporated Associations Identified on Schedule "A", annaluxbag.com, annareps.com, astropya.shop, bagssense.com, bessvivien.com, bestmybest.xyz, bonniesunglass.com, brandhic.com, breeze-chic.myshopify.com, cbags.shop, cclcc.store, chbagsan.com, derels.com, eastcoastmerch.ca, ellyluxury.com, fashionswatchlook.shop, fcabins.top, feytwo.com, foxdark.com, glamogallery.myshopify.com, glasshub.shop, judyjewelry.com, larauntman.com, lbagsnew.com, lbagsv.com, luuxurbag.com, luxfade.com, luxnicely.com, luxuryuto.com, manlyfor.com, midhall.com, monvantiluxury.com, moorsfashion.top, nt-luxury.com, opphcz.shop, pod90luxury.com, reverlavie.com, sneakfitx.com, spendoy.live, stylemis.com, sunshineluxury520.cc, supre-tee.com, theluxcy.com, topbags-br.com, toteer.com, vogueclassique.com, xluxurys.com, yomolux.com, zzak.cc by GIANNI VERSACE, S.R.L.

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

Text of Proposed Order

Clerk's Entry of Default as to 93stores.com, annaluxbag.com, annareps.com, astropya.shop, bagssense.com, bessvivien.com, bestmybest.xyz, bonniesunglass.com, brandhic.com, breeze-chic.myshopify.com, cbags.shop, cclcc.store, chbagsan.com, derels.com, eastcoastmerch.ca, ellyluxury.com, fashionswatchlook.shop, fcabins.top, feytwo.com, foxdark.com, glamogallery.myshopify.com, glasshub.shop, judyjewelry.com, larauntman.com, lbagsnew.com, lbagsv.com, luuxurbag.com, luxfade.com, luxnicely.com, luxuryuto.com, manlyfor.com, midhall.com, monvantiluxury.com, moorsfashion.top, nt-luxury.com, opphcz.shop, pod90luxury.com, reverlavie.com, sneakfitx.com, spendoy.live, stylemis.com, sunshineluxury520.cc, supre-tee.com, theluxcy.com, topbags-br.com, toteer.com, vogueclassique.com, xluxurys.com, yomolux.com, zzak.cc.Granting DE 37 Motion for Clerks Entry of Default. Signed by DEPUTY CLERK on 7/14/2025.

ORDER ON DEFAULT FINAL JUDGMENT PROCEDURE, (Responses due by 7/31/2025.) Signed by Judge Rodney Smith on 7/17/2025. See attached document for full details.

Plaintiff's MOTION for Default Judgment Against Defendants by GIANNI VERSACE, S.R.L.

Declaration of Laura Felstead in Support of Plaintiff's Motion for Entry o

Exhibit 1 to the Declaration of Laura Felstead

Declaration of Christine Daley in Support of Plaintiff's Motion for Entry

Text of Proposed Order Granting Motion for Default Final Judgment

Text of Proposed Order Proposed Default Final Judgment and Permanent Injunction

ORDER granting [40] Motion for Default Judgment. Signed by Judge Rodney Smith on 8/15/2025. See attached document for full details.

DEFAULT FINAL JUDGMENT AND PERMANENT INJUNCTION in favor of GIANNI VERSACE, S.R.L. against The Individuals, Business Entities, and Unincorporated Associations Identified on Schedule "A" Closing Case. Signed by Judge Rodney Smith on 8/15/2025. See attached document for full details.

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