2025-cv-23126

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. Filing fees $ 405.00 receipt number AFLSDC-18612866, filed by Richemont International SA.

Civil Cover Sheet

Complaint and Exhibit

Text of Proposed Order

Text of Proposed Order

Exhibit 1 to Amended Complaint - Certificates of Registration for Plaintiff&#039

Exhibit Certificate of Sevice

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

Text of Proposed Order

Exhibit Certificate of Sevice

Affidavit of Service

Exhibit 1 to the Notice of E-mail Correspondence

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

Declaration of Emma-Jane Tritton in Support Thereof

(Order of Dismissal) (wce)

Clerks Notice of Judge Assignment to Judge Beth Bloom. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Marty Fulgueira Elfenbein 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.

Exhibit 1 to Complaint - Certificates of Registration for Plaintiff's Trade

Affidavit of Service

Text of Proposed Order

Exhibit 1 to the Declaration of Emma-Jane Tritton

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

Affidavit of Service

Declaration of Stephen M. Gaffigan in Support Thereof

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

Declaration of Kathleen Burns in Support Thereof

ORDER REQUIRING SCHEDULING REPORT AND CERTIFICATES OF INTERESTED PARTIES Signed by Judge Beth Bloom on 7/14/2025. See attached document for full details. (ar24)

Exhibit 1 to the Declaration of Kathleen Burns

OMNIBUS ORDER REGARDING SCHEDULE "A" CAUSES OF ACTION. Signed by Judge Beth Bloom on 7/14/2025. See attached document for full details. (ar24)

Text of Proposed Order On Motion for Default Final Judgment

Plaintiff's RESPONSE to [6] Order by Richemont International SA.

(Text of Proposed Order Default Final Judgment and Permanent Injunction)

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

Order (Text entry; no document attached.)

Order (Text entry; no document attached.)

ORDER ON MOTION TO FILE UNDER SEAL granting [8] Motion to Seal. Signed by Judge Beth Bloom on 7/21/2025. See attached document for full details.

Plaintiff's MOTION to Unseal Case by Richemont International SA. Responses due by 8/12/2025.

ORDER TO UNSEAL granting [18] Motion to Unseal Case. The Clerk of Court is directed to UNSEAL all docket entries in this action and return those portions of the Court file to the public records. Signed by Judge Beth Bloom on 7/29/2025. See attached document for full details.

Clerk's NOTICE of Compliance re 19 Order on Motion to Unseal Case. All Docket Entries Unsealed.

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

Plaintiff's NOTICE upon Defendants via Electronic Mail by Richemont International SA re [5] Order Requiring Joint Scheduling Report, [1] Complaint, [18] Plaintiff's MOTION to Unseal Case, [9] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order and Order Restraining Transfer of Assets and Memorandum of Law in Support Thereof, [12] Order on Ex Parte Motion

CERTIFICATE OF SERVICE by Richemont International SA re [5] Order Requiring Joint Scheduling Report, [18] Plaintiff's MOTION to Unseal Case, [1] Complaint, [9] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order and Order Restraining Transfer of Assets and Memorandum of Law in Support Thereof, [12] Order on Ex Parte Motion upon Defendant via Registrar

CERTIFICATE OF SERVICE by Richemont International SA re [17] Sealed Document, [15] Sealed Document, [10] 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] Order Requiring Joint Scheduling Report, [11] Order on Motion to Seal, [1] Complaint, [7] Response/Reply (Other), [13] Order on Ex Parte Motion, [8] Plaintiff's MOTION to Seal per Local Rule 5.4, [3] Form AO 120/121, [14] Sealed Document, [6] Order, [18] Plaintiff's MOTION to Unseal Case, [9] Plaintiff's EX PARTE MOTION for Entry of Temporary Restraining Order and Order Restraining Transfer of Assets and Memorandum of Law in Support Thereof, [12] Order on Ex Parte Motion, [4] Certificate of Other Affiliates/Corporate Disclosure Statement, [2] Clerks Notice of Judge Assignment, upon Defendants via website posting

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

Plaintiff's MOTION to Extend Temporary Restraining Order re [12] Order on Ex Parte Motion by Richemont International SA.

ORDER SETTING HEARING ON MOTION FOR ENTRY OF PRELIMINARY INJUNCTION: Preliminary Injunction Hearing set for 8/21/2025 9:30 AM via Zoom video conference in Miami Division before Judge Beth Bloom. Signed by Judge Beth Bloom on 8/4/2025. See attached document for full details.

ORDER GRANTING PLAINTIFF'S [26] MOTION TO EXTEND TEMPORARY RESTRAINING ORDER. The Temporary Restraining Order, ECF No. [12], is extended and remains in effect until August 22, 2025. Signed by Judge Beth Bloom on 8/4/2025. See attached document for full details.

Plaintiff's NOTICE upon Defendants via Electronic Mail by Richemont International SA re [28] Order on Motion for Miscellaneous Relief, [27] Order Setting/Resetting/Cancelling Hearing

CERTIFICATE OF SERVICE by Richemont International SA re [28] Order on Motion for Miscellaneous Relief, [27] Order Setting/Resetting/Cancelling Hearing, upon Defendant via Registrar

CERTIFICATE OF SERVICE by Richemont International SA re [28] Order on Motion for Miscellaneous Relief, [27] Order Setting/Resetting/Cancelling Hearing, upon Defendants via website posting

SUMMONS (Affidavit) Returned Executed on [1] Complaint, [21] 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. 79karat.co served on 7/31/2025, response/answer due 8/21/2025; aaareplica.org served on 7/31/2025, response/answer due 8/21/2025; ab-jewelry.co served on 7/31/2025, response/answer due 8/21/2025; abcluxury.biz served on 7/31/2025, response/answer due 8/21/2025; aeihmm.shop served on 7/31/2025, response/answer due 8/21/2025; aria-zoeyluxuryzone.com.co served on 7/31/2025, response/answer due 8/21/2025; asperitymart.com served on 7/31/2025, response/answer due 8/21/2025; atlantis-store.us served on 7/31/2025, response/answer due 8/21/2025; backes.live served on 7/31/2025, response/answer due 8/21/2025; bagsion.com served on 7/31/2025, response/answer due 8/21/2025; bestuhren.de served on 7/31/2025, response/answer due 8/21/2025; blackmerchantwatch.com served on 7/31/2025, response/answer due 8/21/2025; bobswatchesmith.com served on 7/31/2025, response/answer due 8/21/2025; bsax.online served on 7/31/2025, response/answer due 8/21/2025; carolyni.shop served on 7/31/2025, response/answer due 8/21/2025; catheluxury.shop served on 7/31/2025, response/answer due 8/21/2025; cedglobal.world served on 7/31/2025, response/answer due 8/21/2025; certiwatchs.com served on 7/31/2025, response/answer due 8/21/2025; charmaries.com served on 7/31/2025, response/answer due 8/21/2025; clytialove.com served on 7/31/2025, response/answer due 8/21/2025; dollluxurio.us served on 7/31/2025, response/answer due 8/21/2025; dsact.top served on 7/31/2025, response/answer due 8/21/2025; dwatchglobal.com served on 7/31/2025, response/answer due 8/21/2025; eggplan.shop served on 7/31/2025, response/answer due 8/21/2025; elysees-boutique.com served on 7/31/2025, response/answer due 8/21/2025; faseon.live served on 7/31/2025, response/answer due 8/21/2025; finerlabels.io served on 7/31/2025, response/answer due 8/21/2025; ghfhksf.shop served on 7/31/2025, response/answer due 8/21/2025; godbeliver.com served on 7/31/2025, response/answer due 8/21/2025; herebuywatches.com served on 7/31/2025, response/answer due 8/21/2025; hont.watch served on 7/31/2025, response/answer due 8/21/2025; iliket.net served on 7/31/2025, response/answer due 8/21/2025; kudosjewellery.co.uk served on 7/31/2025, response/answer due 8/21/2025; lechat.site served on 7/31/2025, response/answer due 8/21/2025; liomz.com served on 7/31/2025, response/answer due 8/21/2025; luxurylifeii.shop served on 7/31/2025, response/answer due 8/21/2025; maxluxes.life served on 7/31/2025, response/answer due 8/21/2025; mkarno.com served on 7/31/2025, response/answer due 8/21/2025; neimanmarcustmer.com served on 7/31/2025, response/answer due 8/21/2025; niralondon.com served on 7/31/2025, response/answer due 8/21/2025; ottwatches.com served on 7/31/2025, response/answer due 8/21/2025; prettysourceqsy.shop served on 7/31/2025, response/answer due 8/21/2025; roejewels.com served on 7/31/2025, response/answer due 8/21/2025; rotetan.com served on 7/31/2025, response/answer due 8/21/2025; rothnwan.shop served on 7/31/2025, response/answer due 8/21/2025; rowahina.shop served on 7/31/2025, response/answer due 8/21/2025; royal-jewelrys.com served on 7/31/2025, response/answer due 8/21/2025; salmonon.shop served on 7/31/2025, response/answer due 8/21/2025; saveb.top served on 7/31/2025, response/answer due 8/21/2025; sheonte.shop served on 7/31/2025, response/answer due 8/21/2025; supwatchmart.com served on 7/31/2025, response/answer due 8/21/2025; tabluxury.com served on 7/31/2025, response/answer due 8/21/2025; thechronolux.com served on 7/31/2025, response/answer due 8/21/2025; theoutnetstore.com served on 7/31/2025, response/answer due 8/21/2025; ticktocktreasures.shop served on 7/31/2025, response/answer due 8/21/2025; tockera.com served on 7/31/2025, response/answer due 8/21/2025; ultimaterealtime.com served on 7/31/2025, response/answer due 8/21/2025; vip.buylily.shop served on 7/31/2025, response/answer due 8/21/2025; watchalpine.com served on 7/31/2025, response/answer due 8/21/2025; watchesultra.com served on 7/31/2025, response/answer due 8/21/2025; watchsloro.com served on 7/31/2025, response/answer due 8/21/2025.

NOTICE of Attorney Appearance by Christine Ann Daley on behalf of Richemont International SA. Attorney Christine Ann Daley added to party Richemont International SA(pty:pla).

Plaintiff's NOTICE of E-Mail Correspondence Received From Certain Defendants in Connection with Notice by Richemont International SA

ORDER GRANTING PLAINTIFF'S MOTION FOR ENTRY OF PRELIMINARY INJUNCTION: Accordingly, it is ORDERED AND ADJUDGED that pursuant to 15 U.S.C. § 1116, Federal Rule of Civil Procedure 65, 28 U.S.C. § 1651(a), and the Court's inherent authority, Plaintiff's Motion, ECF No. [25], is GRANTED in Part and DENIED in Part. Signed by Judge Beth Bloom on 8/21/2025. See attached document for full details.

PAPERLESS Minute Entry for proceedings held before Judge Beth Bloom: and MINUTE ORDER. Motion Hearing held on 8/21/2025 re 25 Plaintiff's MOTION for Preliminary Injunction Against Defendants and Memorandum of Law in Support Thereof filed by Richemont International SA. The Motion was granted in part and denied in part. Paper order to follow. Total time in court: 15 minutes. Attorney Appearance(s): Christine Ann Daley, Court Reporter: Yvette Hernandez, 305-523-5698 / Yvette_Hernandez@flsd.uscourts.gov. Signed by Judge Beth Bloom.

Plaintiff's MOTION for Clerk's Entry of Default as to 79karat.co, THE INDIVIDUALS, BUSINESS ENTITIES, AND UNINCORPORATED ASSOCIATIONS IDENTIFIED ON SCHEDULE A, aaareplica.org, ab-jewelry.co, abcluxury.biz, aeihmm.shop, aria-zoeyluxuryzone.com.co, asperitymart.com, atlantis-store.us, backes.live, bagsion.com, bestuhren.de, blackmerchantwatch.com, bobswatchesmith.com, bsax.online, carolyni.shop, catheluxury.shop, cedglobal.world, certiwatchs.com, charmaries.com, clytialove.com, dollluxurio.us, dsact.top, dwatchglobal.com, eggplan.shop, elysees-boutique.com, faseon.live, finerlabels.io, ghfhksf.shop, godbeliver.com, herebuywatches.com, hont.watch, iliket.net, kudosjewellery.co.uk, lechat.site, liomz.com, luxurylifeii.shop, maxluxes.life, mkarno.com, neimanmarcustmer.com, niralondon.com, ottwatches.com, prettysourceqsy.shop, roejewels.com, rotetan.com, rothnwan.shop, rowahina.shop, royal-jewelrys.com, salmonon.shop, saveb.top, sheonte.shop, supwatchmart.com, tabluxury.com, thechronolux.com, theoutnetstore.com, ticktocktreasures.shop, tockera.com, ultimaterealtime.com, vip.buylily.shop, watchalpine.com, watchesultra.com, watchsloro.com by Richemont International SA.

Clerk's Entry of Default: Granting [36] Plaintiff's MOTION for Clerk's Entry of Default as to 79karat.co, THE INDIVIDUALS, BUSINESS ENTITIES, AND UNINCORPORATED ASSOCIATIONS IDENTIFIED ON SCHEDULE A, aaareplica.org, ab-jewelry.co, abcluxury.biz, aeihmm.shop, aria-zoeyluxuryzo filed by Richemont International SA. Signed by DEPUTY CLERK on 8/22/2025. See attached document for full details.

ORDER ON DEFAULT JUDGMENT PROCEDURE: Accordingly, it is ORDERED AND ADJUDGED that the Plaintiff must file one of the following two responses by September 22, 2025: Plaintiff's failure to file a Motion for Default Final Judgment or Notice of Joint Liability within the specified time will result in sanctions, including but not limited to, dismissal without prejudice as to these Defendants. Signed by Judge Beth Bloom on 8/22/2025. See attached document for full details.

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

ORDER ON MOTION FOR ENTRY OF DEFAULT FINAL JUDGMENT: Accordingly, it is ORDERED AND ADJUDGED that Plaintiff's Motion, ECF No. 40, is GRANTED against those Defendants listed in the attached Schedule "A." Default Final Judgment will be entered by separate order. The Clerk shall CLOSE the case. Signed by Judge Beth Bloom on 8/27/2025. See attached document for full details.

DEFAULT FINAL JUDGMENT AND PERMANENT INJUNCTION: JUDGMENT in favor of Richemont International SA and against 79karat.co, THE INDIVIDUALS, BUSINESS ENTITIES, AND UNINCORPORATED ASSOCIATIONS IDENTIFIED ON SCHEDULE A, aaareplica.org, ab-jewelry.co, abcluxury.biz, aeihmm.shop, aria-zoeyluxuryzone.com.co, asperitymart.com, atlantis-store.us, backes.live, bagsion.com, bestuhren.de, blackmerchantwatch.com, bobswatchesmith.com, bsax.online, carolyni.shop, catheluxury.shop, cedglobal.world, certiwatchs.com, charmaries.com, clytialove.com, dollluxurio.us, dsact.top, dwatchglobal.com, eggplan.shop, elysees-boutique.com, faseon.live, finerlabels.io, ghfhksf.shop, godbeliver.com, herebuywatches.com, hont.watch, iliket.net, kudosjewellery.co.uk, lechat.site, liomz.com, luxurylifeii.shop, maxluxes.life, mkarno.com, neimanmarcustmer.com, niralondon.com, ottwatches.com, prettysourceqsy.shop, roejewels.com, rotetan.com, rothnwan.shop, rowahina.shop, royal-jewelrys.com, salmonon.shop, saveb.top, sheonte.shop, supwatchmart.com, tabluxury.com, thechronolux.com, theoutnetstore.com, ticktocktreasures.shop, tockera.com, ultimaterealtime.com, vip.buylily.shop, watchalpine.com, watchesultra.com, watchsloro.com. Signed by Judge Beth Bloom on 8/27/2025. See attached document for full details.

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

Plaintiff's NOTICE Regarding Supplemental Brief by Richemont International SA