2025-cv-20873

2025-cv-20873 Richemont International Sa v. The Individuals, Business Entities, and Unincorporated Associations Identified On Schedule A

Date :2/25/2025
BrandCARTIER 卡地亚
Court :Southern District of Florida
Law FirmSMG

#

Date

Document

1

Feb. 25, 2025

COMPLAINT FOR INJUNCTIVE RELIEF AND DAMAGES against All Defendants. Filing fees $ 405.00 receipt number AFLSDC-18232887, filed by Richemont International SA.

Civil Cover Sheet

Exhibit 1 to Complaint Certificates of Registration for Plaintiffs Trademarks

2

Feb. 25, 2025

Clerks Notice of Judge Assignment to Judge Darrin P. Gayles. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Jonathan Goodman 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.

3

Feb. 25, 2025

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

Complaint and Exhibit

4

Feb. 25, 2025

Plaintiff's Corporate Disclosure Statement by Richemont International SA identifying Corporate Parent Compagnie Financiere Richemont SA for Richemont International SA

Civil Case Terminated. Closing Case.

5

Feb. 25, 2025

Plaintiff's MOTION to Seal per Local Rule 5.4 by Richemont International SA.

Text of Proposed Order

6

Feb. 27, 2025

PAPERLESS ORDER granting 5 Motion to Seal. Schedule "A" to Plaintiff's Complaint 1 shall be filed under seal and shall remain under seal until further order from this Court. Within seven (7) days of completing service, Plaintiff must add all of the Defendants as parties through CM-ECF. Signed by Judge Darrin P. Gayles on 2/27/2025. (hs01)

Order

Civil Case Terminated. Closing Case.

7

Feb. 27, 2025

NOTICE of Sealed Filing Schedule A re DE# 6 Order on Motion to Seal, by Richemont International SA.

(Schedule "A" to Plaintiff's Complaint for Injunctive Relief and Damages) Modified text on 2/28/2025 (kpe)

8

Feb. 28, 2025

Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order and Preliminary Injunction and Memorandum of Law in Support Thereof by Richemont International SA.

Declaration of Emma-Jane Tritton in Support Thereof

Declaration of Stephen M. Gaffigan in Support Thereof

Exhibit 1 to the Declaration of Stephen M. Gaffigan

(Text of Proposed Order)

9

Feb. 28, 2025

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 Richemont International SA.

Declaration of Stephen M. Gaffigan in Support Thereof

Exhibit 1 to the Declaration of Stephen M. Gaffigan

(Text of Proposed Order)

10

March 4, 2025

ORDER granting [8] Ex Parte Temporary Restraining Order. Motion Hearing for Preliminary Injunction set for 3/13/2025 03:30 PM in Miami Division before Judge Darrin P. Gayles. The Clerk of Court is directed to unseal all docket entries in this case and return those portions of the Court file to the public records. Signed by Judge Darrin P. Gayles on 3/4/2025. See attached document for full details.

11

March 4, 2025

ORDER granting [9] Ex Parte Motion Alternate Service. Signed by Judge Darrin P. Gayles on 3/4/2025. See attached document for full details.

12

March 5, 2025

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

Exhibit 1 to Amended Complaint Certificates of Registration for Plaintiffs Trad

13

March 5, 2025

NOTICE of Filing Proposed Summons(es) by Richemont International SA re [11] Order on Ex Parte Motion

Summon(s)

14

March 5, 2025

Summons Issued as to THE INDIVIDUALS, BUSINESS ENTITIES, AND UNINCORPORATED ASSOCIATIONS IDENTIFIED ON SCHEDULE A.

15

March 6, 2025

Bond on Injunction in the amount of $10,000.00 posted by Richemont International SA Approved by Judge Darrin P. Gayles.

16

March 12, 2025

Plaintiff's NOTICE upon Defendants via Electronic Mail by Richemont International SA re [1] Complaint, [12] Amended Complaint/Amended Notice of Removal, [10] Order on Ex Parte Motion, [8] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order and Preliminary Injunction and Memorandum of Law in Support Thereof

Exhibit Certificate of Sevice

17

March 12, 2025

CERTIFICATE OF SERVICE by Richemont International SA re [1] Complaint, [11] Order on Ex Parte Motion, [12] Amended Complaint/Amended Notice of Removal, [3] Form AO 120/121, [10] Order on Ex Parte Motion, [2] Clerks Notice of Judge Assignment, [8] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order and Preliminary Injunction and Memorandum of Law in Support Thereof, [4] Certificate of Other Affiliates/Corporate Disclosure Statement, [7] Sealed Document, [13] Notice of Filing Proposed Summons(es), [6] Order on Motion to Seal, [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, [5] Plaintiff's MOTION to Seal per Local Rule 5.4 upon Defendants via website posting

18

March 13, 2025

PAPERLESS Minute Entry for proceedings held before Judge Darrin P. Gayles: Motion Hearing held on 3/13/2025 re 8 Plaintiff's Motion for Preliminary Injunction. Court Reporter: Patricia Diaz, 305-523-5178 / Patricia_Diaz@flsd.uscourts.gov. (hs01)

19

March 13, 2025

ORDER Granting [8] Motion for Preliminary Injunction. Signed by Judge Darrin P. Gayles on 3/13/2025. See attached document for full details. (hs01)

20

April 7, 2025

SUMMONS (Affidavit) Returned Executed on [1] Complaint, [12] Amended Complaint/Amended Notice of Removal, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by Richemont International SA. bestwatch.cc served on 3/6/2025, response/answer due 3/27/2025; bestwatchaaa.com served on 3/6/2025, response/answer due 3/27/2025; cloneswisswatch.com served on 3/6/2025, response/answer due 3/27/2025; fakewatchshop.com served on 3/6/2025, response/answer due 3/27/2025; nicewatch.cc served on 3/6/2025, response/answer due 3/27/2025; replicaluxury.cc served on 3/6/2025, response/answer due 3/27/2025; replicasale.cc served on 3/6/2025, response/answer due 3/27/2025; replicaswissclocks.com served on 3/6/2025, response/answer due 3/27/2025; replicawatchaaa.cc served on 3/6/2025, response/answer due 3/27/2025; replicawatchhot.com served on 3/6/2025, response/answer due 3/27/2025; siwssreplicas.com served on 3/6/2025, response/answer due 3/27/2025; swissbestwatch.com served on 3/6/2025, response/answer due 3/27/2025; swissreplicas.cc served on 3/6/2025, response/answer due 3/27/2025; swisswatcheshot.com served on 3/6/2025, response/answer due 3/27/2025; watchreplicaswiss.com served on 3/6/2025, response/answer due 3/27/2025; watchrm.com served on 3/6/2025, response/answer due 3/27/2025.

Affidavit of Service

Affidavit of Service

21

April 7, 2025

Plaintiff's NOTICE upon Defendants via Electronic Mail by Richemont International SA re [19] Order on Ex Parte Motion

Exhibit Certificate of Sevice

22

April 7, 2025

CERTIFICATE OF SERVICE by Richemont International SA re [19] Order on Ex Parte Motion upon Defendants via website posting

23

April 7, 2025

Plaintiff's MOTION for Clerk's Entry of Default as to THE INDIVIDUALS, BUSINESS ENTITIES, AND UNINCORPORATED ASSOCIATIONS IDENTIFIED ON SCHEDULE A, bestwatch.cc, bestwatchaaa.com, cloneswisswatch.com, fakewatchshop.com, nicewatch.cc, replicaluxury.cc, replicasale.cc, replicaswissclocks.com, replicawatchaaa.cc, replicawatchhot.com, siwssreplicas.com, swissbestwatch.com, swissreplicas.cc, swisswatcheshot.com, watchreplicaswiss.com, watchrm.com by Richemont International SA.

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

Text of Proposed Order

24

April 7, 2025

Clerk's Entry of Default as to bestwatch.cc, replicasale.cc, replicawatchaaa.cc, siwssreplicas.com, bestwatchaaa.com, fakewatchshop.com, replicaluxury.cc, watchreplicaswiss.com, watchrm.com, replicawatchhot.com, nicewatch.cc, replicaswissclocks.com, cloneswisswatch.com, swissbestwatch.com, swissreplicas.cc, swisswatcheshot.com - Motions Terminated: 23 Motion for Clerks Entry of Default, Signed by DEPUTY CLERK on 4/7/2025.

25

April 22, 2025

Plaintiff's MOTION for Default Judgment Against Defendants and Memorandum of Law in Support Thereof by Richemont International SA.

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)

26

July 23, 2025

Notice of Ninety Days Expiring by Richemont International SA re [25] Plaintiff's MOTION for Default Judgment Against Defendants and Memorandum of Law in Support Thereof filed by Richemont International SA

27

Aug. 12, 2025

ORDER granting [25] Plaintiff's Motion for Entry of Default Final Judgment. Signed by Judge Darrin P. Gayles on 8/12/2025. (hs01)

28

Aug. 12, 2025

FINAL JUDGMENT AND PERMANENT INJUNCTION. Signed by Judge Darrin P. Gayles on 8/12/2025. See attached document for full details. (hs01)

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