2025-cv-23363

COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against All Defendants. Filing fees $ 405.00 receipt number AFLSDC-18653657, filed by YETI COOLERS, LLC.

Civil Cover Sheet

Complaint and Exhibit

Text of Proposed Order

Supplemental Attachment Document

Text of Proposed Order

Text of Proposed Order

Exhibit Certificate of Sevice

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

Exhibit 1 to Amended Complaint - Certificates of Registration for the YETI Trade

Exhibit Certificate of Sevice

Affidavit of Service

Clerks Notice of Judge Assignment to Judge Rodolfo A. Ruiz, II. Pursuant to 28 USC 636(c), the parties are hereby notified that the U.S. Magistrate Judge Lauren F. Louis 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 the YETI Trademarks

Affidavit of Service

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

Affidavit of Service

Plaintiff's Corporate Disclosure Statement by YETI COOLERS, LLC identifying Corporate Parent YETI Holdings, Inc. for YETI COOLERS, LLC

OMNIBUS ORDER REGARDING SCHEDULE "A" CAUSES OF ACTION. Signed by Judge Rodolfo A. Ruiz, II on 7/28/2025. See attached document for full details.

Plaintiff's RESPONSE to [5] Administrative Order by YETI COOLERS, LLC.

Plaintiff's MOTION to Seal per Local Rule 5.4 by YETI COOLERS, LLC.

Order (Text entry; no document attached.)

Order (Text entry; no document attached.)

Order (Text entry; no document attached.)

ORDER granting [7] Motion to File Under Seal. Signed by Judge Rodolfo A. Ruiz, II on 8/15/2025. See attached document for full details.

Bond on Injuction BOND in the amount of $10,000.00 receipt # S-985253 posted by YETI COOLERS, LLC Approved by Judge Rodolfo A. Ruiz, II

NOTICE of Compliance by YETI COOLERS, LLC

Plaintiff's MOTION to Unseal Document Docket Entries 8-9, 11-13, 15, 17 by YETI COOLERS, LLC. Responses due by 9/10/2025.

ORDER granting 18 Plaintiff's Motion to Unseal Docket Entries 8-9, 11-13, 15, 17. Signed by Judge Rodolfo A. Ruiz, II on 8/27/2025. See attached document for full details. (gp)

Plaintiff's MOTION to Extend Temporary Restraining Order re [11] Order on Ex Parte Motion by YETI COOLERS, LLC.

ORDER granting [20] Motion to Extend Temporary Restraining Order. Signed by Judge Rodolfo A. Ruiz, II on 8/27/2025. See attached document for full details.

NOTICE of Voluntary Dismissal of Defendant Number 86 by YETI COOLERS, LLC

Plaintiff's NOTICE upon Defendants via Electronic Mail by YETI COOLERS, LLC re [11] Order on Ex Parte Motion, [18] Plaintiff's MOTION to Unseal Document Docket Entries 8-9, 11-13, 15, 17, [1] Complaint, [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

CERTIFICATE OF SERVICE by YETI COOLERS, LLC re [11] Order on Ex Parte Motion, [18] Plaintiff's MOTION to Unseal Document Docket Entries 8-9, 11-13, 15, 17, [1] Complaint, [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 upon Defendants via Registrar

CERTIFICATE OF SERVICE by YETI COOLERS, LLC re [7] Plaintiff's MOTION to Seal per Local Rule 5.4, [2] Clerks Notice of Judge Assignment, [11] Order on Ex Parte Motion, [19] Order on Motion to Unseal Case, [15] Sealed Document, [20] Plaintiff's MOTION to Extend Temporary Restraining Order re [11] Order on Ex Parte Motion, [18] Plaintiff's MOTION to Unseal Document Docket Entries 8-9, 11-13, 15, 17, [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, [16] Notice of Compliance, [6] Response/Reply (Other), [1] Complaint, [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, [5] Administrative Order, [10] Order on Motion to Seal, [4] Certificate of Other Affiliates/Corporate Disclosure Statement, [3] Form AO 120/121, [12] Order on Ex Parte Motion, [13] Sealed Document upon Defendants via website posting

Plaintiff's MOTION for Preliminary Injunction and Memorandum of Law in Support Thereof by YETI COOLERS, LLC.

ORDER Setting Hearing on [26] Plaintiff's Motion for Preliminary Injunction. A telephonic hearing is set before this Court on September 11, 2025, at 1:00 P.M., to allow Defendants and/or any other affected persons to challenge the appropriateness of the Temporary Restraining Order and move to dissolve the same--and at which time the Court will hear argument on Plaintiff's requested preliminary injunction. The parties are instructed to call (833) 568-8864 by no later than 12:55 P.M. on September 11, 2025. The phone conference ID is 160 623 6605 and the Passcode is 304850. The Court requires that the parties appear via a landline (i.e., not a cellular phone or a speaker phone), if possible, for clarity. Signed by Judge Rodolfo A. Ruiz, II on 8/29/2025. See attached document for full details.

ORDER DISMISSING DEFENDANT BYBYKSOO.SHOP. Signed by Judge Rodolfo A. Ruiz, II on 8/29/2025. See attached document for full details.

AMENDED COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF against The Individuals, Business Entities, and Unincorporated Associations Identified on Schedule A, yeti-store.com, aloppelmarek.shop, dabbesza.store, gpellosmakrets.store, looewstoer.store, rainbowsmarket.shop, snowmakemall.shop, teifinoning.store, weelppeo.shop, boosleimark.shop, ebayc.top, foot188.com, go118.top, hxbf1.top, in-5g.com, zqqo.top, ehdspecials.shop, lightningspeed.shop, minimiraclemerch.vip, tisedfing.shop, aliexpmall.store, caeuollmakerts.store, dsuoinling.store, heslehnsarket.shop, minnowdiscount.shop, neiaerckuiquer.store, peoremarket.shop, sewdemarket.shop, specialsmarets.store, sgllopemmll.store, klp99mall.com, ksaerwtu7irtfb.shop, rcodi.uk, naior.shop, btrcooe.uk, bkutdrui.uk, cuoi.shop, uing.shop, xuos.uk, yuiom.uk, yuuiio.shop, reoe.shop, ceoon.store, handlinginventoryitems.store, bufferneolu.shop, bufferneolt.shop, jjczoceh.shop, jjczocem.shop, jjczocen.shop, jjczocez.shop, kkczoced.shop, kmmczocec.shop, mkmmczocei.shop, kmmczocen.shop, kmmczoceu.shop, kmmczocez.shop, pprocem.shop, jjczocei.shop, jjczocea.shop, pprocer.shop, wwczocec.shop, wwczocek.shop, zzzczocec.shop, zzzczocei.shop, zzzczocez.shop, pprocen.shop, kkczoceu.shop, kmmczocei.shop, bufferneolw.shop, jjczocec.shop, kkczocen.shop, mkmmczoceh.shop, pproceb.shop, newperseverance.shop, pulpyfresh.com, bakuol.com, buybuybottle.com, boutiquemall.shop, lalalivemall.shop, millionairemall.shop, newstartmall.shop, overstocemall.shop, panningmall.shop, superiormall.shop, supershopingmall.shop, ekpc.shop, kdey.shop, whze.shop, kee.phapluats.top, online.satukyabe.top, thestillbargrill.com, rafamko.com, sparatic.com, whgsales.shop, xdli.shop, filed by YETI COOLERS, LLC.

Plaintiff's NOTICE upon Defendants via Electronic Mail by YETI COOLERS, LLC re [27] Order Setting Hearing on Motion

CERTIFICATE OF SERVICE by YETI COOLERS, LLC re [27] Order Setting Hearing on Motion, upon Defendants via Registrar

CERTIFICATE OF SERVICE by YETI COOLERS, LLC re [27] Order Setting Hearing on Motion, upon Defendants via website posting

SUMMONS (Affidavit) Returned Executed on [29] Amended Complaint/Amended Notice of Removal, [1] Complaint, with a 21 day response/answer filing deadline pursuant to Fed. R. Civ. P. 12 by YETI COOLERS, LLC. aliexpmall.store served on 9/3/2025, response/answer due 9/24/2025; aloppelmarek.shop served on 9/3/2025, response/answer due 9/24/2025; bakuol.com served on 9/3/2025, response/answer due 9/24/2025; bkutdrui.uk served on 9/3/2025, response/answer due 9/24/2025; boosleimark.shop served on 9/3/2025, response/answer due 9/24/2025; boutiquemall.shop served on 9/3/2025, response/answer due 9/24/2025; btrcooe.uk served on 9/3/2025, response/answer due 9/24/2025; bufferneolt.shop served on 9/3/2025, response/answer due 9/24/2025; bufferneolu.shop served on 9/3/2025, response/answer due 9/24/2025; bufferneolw.shop served on 9/3/2025, response/answer due 9/24/2025; buybuybottle.com served on 9/3/2025, response/answer due 9/24/2025; caeuollmakerts.store served on 9/3/2025, response/answer due 9/24/2025; ceoon.store served on 9/3/2025, response/answer due 9/24/2025; cuoi.shop served on 9/3/2025, response/answer due 9/24/2025; dabbesza.store served on 9/3/2025, response/answer due 9/24/2025; dsuoinling.store served on 9/3/2025, response/answer due 9/24/2025; ebayc.top served on 9/3/2025, response/answer due 9/24/2025; ehdspecials.shop served on 9/3/2025, response/answer due 9/24/2025; ekpc.shop served on 9/3/2025, response/answer due 9/24/2025; foot188.com served on 9/3/2025, response/answer due 9/24/2025; go118.top served on 9/3/2025, response/answer due 9/24/2025; gpellosmakrets.store served on 9/3/2025, response/answer due 9/24/2025; handlinginventoryitems.store served on 9/3/2025, response/answer due 9/24/2025; heslehnsarket.shop served on 9/3/2025, response/answer due 9/24/2025; hxbf1.top served on 9/3/2025, response/answer due 9/24/2025; in-5g.com served on 9/3/2025, response/answer due 9/24/2025; jjczocea.shop served on 9/3/2025, response/answer due 9/24/2025; jjczocec.shop served on 9/3/2025, response/answer due 9/24/2025; jjczoceh.shop served on 9/3/2025, response/answer due 9/24/2025; jjczocei.shop served on 9/3/2025, response/answer due 9/24/2025; jjczocem.shop served on 9/3/2025, response/answer due 9/24/2025; jjczocen.shop served on 9/3/2025, response/answer due 9/24/2025; jjczocez.shop served on 9/3/2025, response/answer due 9/24/2025; kdey.shop served on 9/3/2025, response/answer due 9/24/2025; kee.phapluats.top served on 9/3/2025, response/answer due 9/24/2025; kkczoced.shop served on 9/3/2025, response/answer due 9/24/2025; kkczocen.shop served on 9/3/2025, response/answer due 9/24/2025; kkczoceu.shop served on 9/3/2025, response/answer due 9/24/2025; klp99mall.com served on 9/3/2025, response/answer due 9/24/2025; kmmczocec.shop served on 9/3/2025, response/answer due 9/24/2025; kmmczocei.shop served on 9/3/2025, response/answer due 9/24/2025; kmmczocen.shop served on 9/3/2025, response/answer due 9/24/2025; kmmczoceu.shop served on 9/3/2025, response/answer due 9/24/2025; kmmczocez.shop served on 9/3/2025, response/answer due 9/24/2025; ksaerwtu7irtfb.shop served on 9/3/2025, response/answer due 9/24/2025; lalalivemall.shop served on 9/3/2025, response/answer due 9/24/2025; lightningspeed.shop served on 9/3/2025, response/answer due 9/24/2025; looewstoer.store served on 9/3/2025, response/answer due 9/24/2025; millionairemall.shop served on 9/3/2025, response/answer due 9/24/2025; minimiraclemerch.vip served on 9/3/2025, response/answer due 9/24/2025; minnowdiscount.shop served on 9/3/2025, response/answer due 9/24/2025; mkmmczoceh.shop served on 9/3/2025, response/answer due 9/24/2025; mkmmczocei.shop served on 9/3/2025, response/answer due 9/24/2025; naior.shop served on 9/3/2025, response/answer due 9/24/2025; neiaerckuiquer.store served on 9/3/2025, response/answer due 9/24/2025; newperseverance.shop served on 9/3/2025, response/answer due 9/24/2025; newstartmall.shop served on 9/3/2025, response/answer due 9/24/2025; online.satukyabe.top served on 9/3/2025, response/answer due 9/24/2025; overstocemall.shop served on 9/3/2025, response/answer due 9/24/2025; panningmall.shop served on 9/3/2025, response/answer due 9/24/2025; peoremarket.shop served on 9/3/2025, response/answer due 9/24/2025; pproceb.shop served on 9/3/2025, response/answer due 9/24/2025; pprocem.shop served on 9/3/2025, response/answer due 9/24/2025; pprocen.shop served on 9/3/2025, response/answer due 9/24/2025; pprocer.shop served on 9/3/2025, response/answer due 9/24/2025; pulpyfresh.com served on 9/3/2025, response/answer due 9/24/2025; rafamko.com served on 9/3/2025, response/answer due 9/24/2025; rainbowsmarket.shop served on 9/3/2025, response/answer due 9/24/2025; rcodi.uk served on 9/3/2025, response/answer due 9/24/2025; reoe.shop served on 9/3/2025, response/answer due 9/24/2025; sewdemarket.shop served on 9/3/2025, response/answer due 9/24/2025; sgllopemmll.store served on 9/3/2025, response/answer due 9/24/2025; snowmakemall.shop served on 9/3/2025, response/answer due 9/24/2025; sparatic.com served on 9/3/2025, response/answer due 9/24/2025; specialsmarets.store served on 9/3/2025, response/answer due 9/24/2025; superiormall.shop served on 9/3/2025, response/answer due 9/24/2025; supershopingmall.shop served on 9/3/2025, response/answer due 9/24/2025; teifinoning.store served on 9/3/2025, response/answer due 9/24/2025; thestillbargrill.com served on 9/3/2025, response/answer due 9/24/2025; tisedfing.shop served on 9/3/2025, response/answer due 9/24/2025; uing.shop served on 9/3/2025, response/answer due 9/24/2025; weelppeo.shop served on 9/3/2025, response/answer due 9/24/2025; whgsales.shop served on 9/3/2025, response/answer due 9/24/2025; whze.shop served on 9/3/2025, response/answer due 9/24/2025; wwczocec.shop served on 9/3/2025, response/answer due 9/24/2025; wwczocek.shop served on 9/3/2025, response/answer due 9/24/2025; xdli.shop served on 9/3/2025, response/answer due 9/24/2025; xuos.uk served on 9/3/2025, response/answer due 9/24/2025; yeti-store.com served on 9/3/2025, response/answer due 9/24/2025; yuiom.uk served on 9/3/2025, response/answer due 9/24/2025; yuuiio.shop served on 9/3/2025, response/answer due 9/24/2025; zqqo.top served on 9/3/2025, response/answer due 9/24/2025; zzzczocec.shop served on 9/3/2025, response/answer due 9/24/2025; zzzczocei.shop served on 9/3/2025, response/answer due 9/24/2025; zzzczocez.shop served on 9/3/2025, response/answer due 9/24/2025.