UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF ...

Case 1:12-cv-23295-JLK Document 6-4 Entered on FLSD Docket 09/12/2012 Page 1 of 7 

ADIDAS AG, et al., 

vs. 

Plaintiffs, 

UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

CASE NO. 12-23295-CIV-KING/MCALILEY 

ADIDASJEREMYSCOTTTEDDYBEAR.COM, et al., 

Defendants. 

DECLARATION OF STEPHEN M. GAFFIGAN 

IN SUPPORT OF PLAINTIFFS’ EX PARTE APPLICATION 

I, Stephen M. Gaffigan, declare and state as follows: 

1. I am an attorney for Plaintiffs, adidas AG, adidas International Marketing B.V., 

and adidas America, Inc. (collectively “Plaintiffs” or “adidas”) in the above captioned action. I 

am duly authorized and licensed to practice law before all courts in the State of Florida, the 

Southern and Middle Districts of Florida, the Eastern District of Michigan, the Northern District 

of Illinois, the District of Colorado, the Eleventh Circuit Court of Appeals, and the Federal 

Circuit Court of Appeals. I submit this Declaration, which is filed in support of Plaintiffs’ Ex 

Parte Application for Entry of Temporary Restraining Order, Preliminary Injunction, and Order 

Restraining Transfer of Assets Tied to the Counterfeiting Operation (the “Application for TRO”) 

against Defendants. I am personally knowledgeable of the matters set forth in this Declaration 

and, if called upon to do so, I could and would competently testify to the following facts set forth 

below. 

/


RE: INVESTIGATION OF DEFENDANTS 

2. Prior to filing this action, my firm accessed and used the fully interactive, 

commercial Internet websites operating under the domain names identified in Schedule “A” to 

Plaintiffs’ Application for TRO (the “Subject Domain Names”). The websites advertise and 

offer for sale at least footwear, sunglasses, and apparel, bearing the adidas trademarks at issue in 

this action. Upon accessing the websites, a consumer is able to browse the online stores for 

products bearing adidas trademarks, add products to the online shopping carts, proceed to a point 

of checkout, and otherwise actively exchange data with the websites. True and correct copies of 

the website printouts my firm captured for the Internet websites operating under the Subject 

Domain Names are attached hereto as Composite Exhibit “A.” 1 

3. Additionally, my firm obtained the available WHOIS domain registration data for 

the Subject Domain Names. A chart outlining the Registrant and Administrative Contact 

information identified on the WHOIS domain registration records for the Subject Domain Names 

is attached hereto as Composite Exhibit “B.” 

1 The Internet website operating under the Subject Domain Name, adidasporsches.com, 

automatically redirects and forwards to the website operating under the Subject Domain Name, 

adidasporsches.net. Accordingly, the downloaded captures for the adidasporsches.com website is 

necessarily encompassed in the downloaded captures for the adidasporsches.net website. 

The Internet website operating under the Subject Domain Name, chaussurefoot2011.org, 

automatically redirects and forwards to the website operating under the Subject Domain Name, 

chaussurefoot2012.info. Accordingly, the downloaded captures for the chaussurefoot2011.org 

website is necessarily encompassed in the downloaded captures for the chaussurefoot2012.info 

website. 

Additionally, the Internet website operating under the Subject Domain Name, 

cheapbrandpolo.com, automatically redirects and forwards to the website operating under the 

Subject Domain Name, cheapbrandpolos.com. Accordingly, the downloaded captures for the 

cheapbrandpolo.com website is necessarily encompassed in the downloaded captures for the 

cheapbrandpolos.com website. 

2


4. Furthermore, my firm accessed the Internet websites operating under the Subject 

Domain Names nike2sales.com and nike-zapatillas.com.es. The “Payment” page for each 

website provides the bank transfer information for finalizing payments for purchases identifying 

the bank accounts as follows: 

Subject Domain Name Bank Transfer Account 2 

nike2sales.com 

nike-zapatillas.com.es 

Bank Of China; Bank Account Number **** 

**** **** ***2 457; Account Name XiuMei 

Lin; Swift “BKCHCNBJ73C” 

Bank Of China; Bank Account Number *** **** 

**** **** 3309; Account Name Huiying wu; 

Swift “BKCHCNBJ73C” 

True and correct redacted copies of the web page captures for the Internet websites operating 

under the Subject Domain Names nike2sales.com and nike-zapatillas.com.es, showing the bank 

transfer account for each website, are attached hereto as Composite Exhibit “C.” 

5. On behalf of Plaintiffs’, my firm retained Investigative Consultants, a licensed 

private investigative firm, and AED Investigations, Inc., a licensed private investigative firm, to 

investigate the suspected sales of counterfeit adidas-branded products by the Defendants and to 

determine the Defendants’ payee data for receipt of funds paid for the sale of counterfeit adidas- 

branded merchandise. As part of their investigation, I instructed both investigators not to finalize 

their purchases via the majority of the Internet websites so as to avoid contributing additional 

funds to the Defendants’ coffers. Further, the investigators were instructed to intentionally 

purchase non-adidas-branded merchandise as part of their investigative process. I have personal 

knowledge that making purchases of mixed brands is a technique commonly used by 

2 In compliance with Fed. R. Civ. P. 5.2(a)(4), I am only disclosing the last four digits of all 

financial institution account numbers identified herein. 

3


investigators to avoid inadvertently tipping off the target as to which brand owner is conducting 

the investigation 

RE: EX PARTE RELIEF 

6. Plaintiffs are seeking ex parte relief because they reasonably believe if they 

proceed on notice to Defendants prior to modifying control of the Subject Domain Names, as 

requested in their Application for TRO, Defendants can easily and quickly transfer the 

registrations for many of the Subject Domain Names, or modify registration data and content, 

change hosts, and redirect traffic to other websites, thereby thwarting Plaintiffs’ ability to obtain 

meaningful relief and continuing to cause irreparable injury to Plaintiffs. Accordingly, Plaintiffs 

have made no effort to notify Defendants of their Application for TRO or obtain a stipulation. 

7. I have personal knowledge that under the operating rules of most domain name 

Registrars, Registrants can easily transfer ownership of domain names simply by submitting an 

authorization letter and an application form. Defendants involved in domain name litigation 

easily can, and often will, modify registration data and content, change hosts, and redirect traffic 

to other websites they control. 

8. I have learned through multiple prior cases I have filed on behalf of other clients 

that, upon notice of a lawsuit, counterfeit website owners often immediately set up a redirect for 

their website which essentially informs a search engine that the website being crawled has 

permanently moved to another domain and instructs the search engine to divert traffic to the 

other website. The result is to slingshot the new domains to the top of the search engine results 

pages by leveraging the Internet traffic to the domains in suit which was built through the illegal 

use of adidas’s trademarks. 

4


9. Attached hereto as Composite Exhibit “D” are four examples of post-suit redirects 

captured by my firm with respect to four domain names, chanelfans.com, yeschanelgifts.com, 

tick2buy.com, and watches-collection.com, which previously were home to counterfeit websites. 

As reflected in the Exhibit, after the domain name owners received notice of an action but before 

the domain names were transferred to the plaintiff through litigation, the owners simply 

redirected all traffic to new domain names, chanelfan.com, yeschanelgift.com, morncity.com, 

and replicagood.com, respectively. Accordingly, by the time the plaintiff obtained control of the 

domain names, all of the value to the counterfeiters had already been diverted to the new domain 

names, and the plaintiff was left to start over. In short, injunctive relief was rendered almost 

meaningless by advance notice to the domain name owners that the websites were the subject of 

a legal action. This case is being filed on an ex parte basis to prevent such an injustice from 

occurring herein. 

RE: RESTRAINING TRANSFER OF ASSETS 

10. In recent virtually identical cases in the Southern District of Florida, several 

Courts have entered the precise relief sought in Plaintiffs’ current Application for TRO with 

respect to restraining financial accounts used to receive monies from the sale of counterfeit 

goods. See: 

� Chanel, Inc. v. 7perfecthandbags.com, Case No. 1:12-cv-22057-PAS (S.D. Fla. 

Sept. 4, 2012) (Order granting Second TRO restraining funds held or received by 

the PayPal accounts tied to the counterfeiting operation); 

� Gucci America, Inc. v. Cheapguccihandbagsusaoutlet.com, Case No. 1:12-cv- 

23061-JAL (S.D. Fla. August 24, 2012) (Order granting TRO restraining funds 

held or received by the PayPal accounts tied to counterfeiting operation); 

� Louis Vuitton Malletier, S.A. v. Cheaplouisvuitton10.com, Case No. 1:12-cv- 

21936-UU (S.D. Fla. June 1, 2012) (Order granting TRO restraining funds held or 

received by the PayPal accounts tied to counterfeiting operation); 

5


� Abercrombie & Fitch Trading Co. v. 4cheapbags.com, Case No. 1:12-cv-21088- 

UU (S.D. Fla. May 18, 2012) (Order adopting Report and Recommendation 

granting TRO restraining funds held or received by the PayPal accounts tied to 

counterfeiting operation); 

� adidas AG v. Wu, Case No. 1:11-cv-24094-MGC (S.D. Fla. March 23, 2012) 

(Order adopting Report and Recommendation granting TRO restraining funds 

held or received by Western Union tied to counterfeiting operation); 

� Louis Vuitton Malletier, S.A. v. Cheapwholesalereplica.com, Case No. 1:12-cv- 

21026-KMM (S.D. Fla. March 22, 2012) (Order granting TRO restraining funds 

held or received by the PayPal accounts tied to counterfeiting operation); 

� Abercrombie & Fitch Trading Co. v. Zhiming, Case No. 0:11-cv-62370-KMW 

(S.D. Fla. Feb. 3, 2012) (Order granting TRO restraining funds held or received 

by the PayPal accounts tied to counterfeiting operation); 

� Tiffany (NJ) LLC v. Yaoqiang, Case No. 1:11-cv-24116-UU (S.D. Fla. Dec. 22, 

2011) (Order adopting Report and Recommendation granting TRO restraining 

funds held or received by the PayPal accounts tied to counterfeiting operation); 

� Philip Morris USA Inc. v. Jiang, Case No. 1:11-cv-24049-KMM (S.D. Fla. Nov. 

16, 2011) (Order granting TRO restraining funds held or received by Western 

Union tied to counterfeiting operation); 

� Acushnet Company v. Hainan, Case No. 1:11-cv-23557-UU (S.D. Fla. Nov. 3, 

2011) (Order granting TRO restraining funds held or received by the PayPal 

accounts tied to counterfeiting operation); 

� Gucci America, Inc. v. Zhang, Case No. 1:11-cv-23380-UU (S.D. Fla. Oct. 26, 

2011) (Order adopting Report and Recommendation granting TRO restraining 

funds held or received by Western Union and restraining the PayPal accounts tied 

to counterfeiting operation); 

� Chanel, Inc. v. Dai, Case No. 1:11-cv-23051-DLG (S.D. Fla. Sept. 7, 2011) 

(Order adopting Report and Recommendation granting TRO restraining funds 

held or received by Western Union and restraining the PayPal accounts tied to 

counterfeiting operation); and 

� Gucci America, Inc. v. Zhou, Case No. 1:11-cv-22734-PAS (S.D. Fla. Aug. 18, 

2011) (Order granting TRO restraining the Western Union transfers tied to 

counterfeiting operation). 

True and correct copies of the aforementioned cases are attached hereto as Composite Exhibit 

“E.” 

6


11. The PayPal, Inc. company admits on its website, paypal.com (last visited on 

March 8, 2012), that it is licensed to operate in the State of Florida as a money transmitter and 

payment instrument by the Florida Office of the Controller. A true and correct copy of PayPal’s 

license to engage in the business of money transmission downloaded from PayPal’s website is 

attached hereto as Exhibit “F.” Accordingly, PayPal is subject to personal jurisdiction in this 

Court. 

I declare under penalty of perjury under the laws of the United States of America that the 

foregoing is true and correct. Executed the 12th day of September, 2012, at Fort Lauderdale, 

Florida. 

7


Composite Exhibit A


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Before you begin you on-line buying fantasy, we strongly advise 

you to check out this privacy policy. Here you will find how your 

privacy is to be treasured and guarded by our site. And we 

believe, with your help , we will build to strong fortress for you 

to shop in. 

First of all, we know most of the information losses come from 

the inside, so we are staffed with the most experienced Ebusiness 

expert.Be there on the technology department or the 

customer services or others. We will make sure that they have a 

excellent credit record before they get in. And all of them have 

to go through a probation period before we give them access to 

sensitive information. Besides, we never stop training them with 

the awareness in privacy protection and the most updated 

network knowledge.So basically we are unbreakable within. 

Second, we never underestimate the importance of equipment. 

No matter they are computers, servers or databases, we buy 

the most sophisticated ones on the market. Besides, we have a 

special top-notch tech team taking care of them.So on the tech 

side, we are more than prepared . 

Thirdly, we do achieve more when it comes to our promises to 

the customers. All your information are stored in an encrypted 

database, which only limited number of people can access. 

Under no condition will we sell or give your information to the 

third party, nor do we ourselves take their advantage. We know 

how much you care about your information, so we just use 

some of your browsing or buying history to do market research. 

And they are only confined in our site.So no junk mail or spam 

message is guaranteed. 

Fourth, third party issue. We have to stress on the third party. 

By that we mean our business partner like the transportation 

companies. Although we don't usually shoulder their 

responsibility , but in order to lower the danger of information 

reveal to the minimum, we always couple with the most 

reputable ones ones, although they charge more. Besides, we 

sign special contract with them in terms of your privacy 

protection before we give your information to them. 

Of course one can never be too carefully facing information 

security,but we are trying hard, and we will never stop. 

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Adidas Shoes Home :: Shipping & Returns 


Shopping Policy 

1). Without exception, on receipt of the order, we are going to 

send the goods in 24 to 48 hours. In order to process your 

order smoothly, we strongly recommend you to use the same 

address for both your shipping and billing address or your order 

could be delayed for verification. 

2). All the goods will send from China. 

3). Two kinds of type of shipping. 

(1). EMS, which is free, and it is the same as USPS in America. 

It needs 5 to 7days. 

(2). Express, like the FedEx, TNT, UPS. It is a faster way and 

another $30 demanded. 

4). The following countries’ freight are free: USA, UK, France, 

Germany, Spain, Italy, Canada, Australia, New Zealand, Mexico, 

Switzerland, Belgium, Ireland, Denmark, Japan, Portugal, 

Norway, Greece, Singapore, and Vietnam. 

Holland, Iraq, Russia, Poland, and Iran need to pay another 

$30. 

The two specific countries are Brazil and Guadeloupe. They 

need to pay $10 and $50. 

5). There should be someone at home to sign for the arrived 

packages. The children who under the 18 can not be allowed to. 

If there is nobody at home, the packages will be return to the 

local post office. Please contact with the post office in time. 

6). If you didn't receive the package, please report to us via 

email or phone call within ten days after place order. 

Return Policy 

1). If the products which have sent off are wrong for its size, 

color, or number, you can reserve it, and we will freely send the 

right product as soon as possible. 

2). We cannot accept returns of certain items for a refund, 

including: 

Any item that is returned more than 30 days after 

delivery. 

Any product that has been damaged by any human 

errors. 

Any item that is not in its original bottle or box. 

3). If have any questions, please have a connection with 

customer service. 

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Adidas Shoes Home :: Adidas Throwstar :: Adidas Throwstar White 

Black 

Adidas Throwstar 


White Black 

$312.56 $78.56 

Save: 75% off 

Striped velcro strap across the midfoot enables the Adidas 

Throwstar White Black shoes become very fantastic. The 

perforated synthetic upper is breathable and durable. The 

white brand logos make the shoes turn to be eye-catching. 

Your feet can feel very cozy with the padded collar and 

tongue. 

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Model: Adidas Throwstar 2 




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About Us 

www.adidasfirst.com was established in 2008 to be one of the 

excellent retailers of Adidas Shoes. Adidas is the largest 

sportswear manufacturer in Europe and the second biggest 

sportswear manufacturer in the world. Adidas had provided 

many kinds of shoes and are accounting a large market share 

around the world. Our website are now offering you this 

chance to shopping online to get the attractive products. We 

ensure that the quality of Adidas Shoes sold through our 

website is highly commented among people and the price is 

reasonable. Our website has an efficient service group that 

will provide you with the best service. You don’t need to 

doubt the quality of Adidas Shoes in our websites. We will 

carry out timely delivery as the orders are placed. If you have 

any questions, contact our service department as soon as you 

can. Wish you a happy shopping time in our website. Thank 

you. 

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This policy illustrates you the details how we use and keep 

your personal information secure. To see. summary of this 

policy, and for more information to answer your privacy 

concerns, please turn to our online CUSTOMER SERVICE, 

which has professional staff to solve your problems right 

away all the time . 

Scope 

This Privacy Policy aims to show you how we handle your 

personal information for our services on our website. It 

applies generally to website that’s sort of related to this .By 

accepting the Privacy Policy and the User aggrement in 

registration, you expressly consent to our collection, storage, 

use of your personal information as described in this 

Privacy Policy. 

Collection 

You can browse our sites without telling us who you are or 

unveiling any personal information about yourself. Once you 

offer us your personal information, you are not anonymous 

to us base on our business regulations that never give away 

or rent your personal information. We may collect and store 

the information like email address, physical contact 

information, and (depending on the service used) sometimes 

financial information, such as credit; shipping, billing and 

other information you provide to purchase or ship an order; 

other information from your interaction with our sites, 

services, content and advertising, including computer and 

connection information, statistics on page views, taffic to 

and from the sites, ad data, IP address and standard web log 

information; additional information we ask you to submit to 

authenticate yourself or if we believe you are violating site 

policies. for example, we may ask you to send us an ID or 

bill to verify your address ,or to answer additional questions 

online to help clarify your identity or ownership of an item 

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you list. . 

Marketing 

We don’t sell or rent your personal information to third 

parties for their marketing purposes without your explicit 

consent .We may combine your information with 

information we collect from other companies and use it to 

improve and personalize our services, content and 

advertising. 

USE 

Our primary purpose in collecting personal information is to 

provide you with. safe, smooth, efficient, and customized 

experience. You consent to that we may use your personal 

information to : 

Provide the service and customer support you request. 

Resolve disputes, collect fees, and troubleshoot problems ; 

Prevent potentially prohitied or illegal activities, and enforce 

our User Agreement ; 

Customize ,measure and improve our services, content and 

advertising . 

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Shipping policy: 

1. No sooner had customers paid the order by cash and 

check than the articles ordered would be given out 

within 24 hours. However, if encounter holidays and 

weekends, then, we will endeavor for shipping the 

articles at the soonest. 

2. All articles, being in good condition, will be sent 

from china. 

3. Within5 to 10 days, the articles will get to customers’ 

hand. 

4. Please note to remain contacting the local post office 

without any delay for the reason that the articles 

should be signed on reaching, or else, they will be 

withdrew to the local post office. 

5. Carriage free is for the following countries: USA, 

UK, France, German, Spain, Italy, Canada, Australia, 

New Zealand, Mexico, Switzerland, Belgium, Ireland, 

Denmark, Japan, Portugal, Norway, Greece, 

Singapore and Vietnam. 

The following countries should charge carriage: 

30 Dollars: Holland, Iraq, Russia, Poland and Iran; 

10 Dollars: Brazil 

50 Dollars: Guadeloupe. 

Return Policy: 

1. Owing to the inappropriate size, customers may return 

articles one week after they have received them, 

customers are responsible for the return shipping fee 

and 15% of restocking fee will be demanded. 

2. A second free object may gained by customers in the 

event that we have shipped the wrong size, style and 

colors, however, returning the goods are not claimed. 

3. If for any reason customers dislike the articles, then, 

returning is not permitted. 

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adidasjeremyscottteddybear.com


adidasjeremyscottteddybear 


adidas originals by jeremy scott js 

wings luminous 

$116.21 

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2012 js Wings red 

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Home :: FAQ 


1.What Payment Methods does Adidasjeremyscottteddybear.com accept? 

Adidasjeremyscottteddybear.com accepts PAYPAL and CreditCard(VISA,MASTERCARD). (For First Time customers, please make sure to place your 

order to your billing address or we will deny your transaction. We can only ship to an address different from your billing address if you are a returning 

customer.) 

Customers without a Paypal account will have an option to set up an account with Paypal while you go through the payment process. However, you 

do not need to create a PayPal account if you choose not to. You will be prompted by PayPal concerning whether you would like to create an 

account with them or not after the transaction goes through. 

If you have or choose to create a Paypal account, returning purchases to Adidasjeremyscottteddybear.com or to any websites that accepts Paypal 

payments as well as eBay auctions can be done in a few clicks. Paypal is an eBay company with industry leading security to protect your financial 

info. 

NOTE: cause of the supplier of the credit card payment method is a U.S. company, so our credit card payment method only accept USD currency. 

So no matter what currency the customers choosed for checkout, our system will translate it into USD. 

2.What is Paypal? 

Founded in 1998, PayPal, an eBay Company, enables any individual or business with an email address to securely, easily and quickly send and 

receive payments online. PayPal's service builds on the existing financial infrastructure of bank accounts and credit cards and utilizes the world's 

most advanced proprietary fraud prevention systems to create a safe, global, real-time payment solution. 

PayPal has quickly become a global leader in online payment solutions with 40 million account members worldwide. Available in 38 countries around 

the world, buyers and sellers on eBay, online retailers, online businesses, as well as traditional offline businesses are transacting with PayPal. 

PayPal has received close to 20 awards for technical excellence from the Internet industry and the business community at large -most recently the 

2003 Webby Award for Best Finance Site and the 2003 Webby People's Voice Award for Best Finance Site. 

Located in San Jose, California, PayPal was acquired by eBay Inc. in October, 2002. 

3.Is Adidasjeremyscottteddybear.com a retail store? 

We are currently only an online store with office. No retail locations. 

4.Is My Payment to Adidasjeremyscottteddybear.com Secure? 

Not only our website, but also the payment method are all with 128 bit SSL(Secure Socket Layer certificate.so you never have to worry about your 

credit card info gets stolen or sold to other party online. 

5.Does Adidasjeremyscottteddybear.com Have A Satisfaction Guarantee? 

We have a 100% satisfaction guarantee. If you are not satisfied with your product within 365 days of receipt you can send it back to us for full refund 

(less shipping fees) 

* All returns and exchanges must be in original new condition with all accessories in new condition. We cannot take back any worn or used products. 

*Additional shipping fee will be requested for exchange. 

6.Check My Order History Online 

Order history is a benefit for our registered users. It allows you to review up to the last nine months of orders placed online, by phone or by mail. To 

view your order history online, you must be a registered user. 

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To access your order history, please follow the directions below: 

Login to your account using the "My Account" link in the upper Center of the page. 

From the My Account page, click the " View the orders I have made." link. 

Your previously placed orders will be listed, along with their current status. 

To view the order in detail, click on the "View Order" link. 


When an order is sent to us from our site, we are generally unable to change or cancel your order. The order is automatically processed as soon as 

you press "Place Order." You may contact us if you wish to make a change. However, due to the above, we cannot guarantee your order will be 

changed. If you need to change/exchange or return an item that you ordered in error, please return it to us as soon as you receive it. If you want to 

add an item to a recently placed order, please place a new order. 

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Adidasjeremyscottteddybear.com uses Paypal's shopping cart system to accept credit card and bank payments. (For First Time customers, please 

make sure to place your order to your billing address or we will deny your transaction. We can only ship to an address different from your billing 

address if you are a returning customer.) 


Once you have a Paypal account, returning purchases to Adidasjeremyscottteddybear.com or to any websites that accepts Paypal payments as well 

as eBay auctions can be done in a few clicks. Paypal is an eBay company with industry leading security to protect your financial info. 









We only ship to your confirmed address (the address on file with your credit card company,if you need to ship to an alternative address,please call 

your credit card company and add the alternative ship-to address to your acct) 


There is 24 hours processing period once payment is received. Once shoes are shipped ,You will get an email from us with tracking number so you 

may track your order. You will have your products within 3-5 business days (not counting weekends or Holidays). Most orders are processed and 

received by customers within 3 days . Some orders may take longer due to uncontrollable circumstance. 



Return Policy 

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We will gladly accept return in brand new condition. All trainers purchased from Adidasjeremyscottteddybear.com can only be returned in brand new 

condition with original box and all applicable accessories (ex. retro card, original trainer laces, etc..) The return must be requested 365 days from the 

day the trainers are delivered to our customers. Returns and exchanges back to Adidasjeremyscottteddybear.com must be posted marked within 365 

days your request has been approved. 

*Defective trainers must be mailed back to Manufacturers in exchange a gift certificate at the trainers' suggested retail price value. We can only 

guarantee that the trainers purchased from Adidasjeremyscottteddybear.com are authentic and in brand new condition, no exceptions. We can not 

guarantee the condition of the trainerbox. For collectors or as a gift, please add a note on the note line when placing the order for us to pick the best 

trainerbox. For detail information on how to return your defective trainers please email us. 

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adidasjeremyscottwings.com

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We have a 100% satisfaction guarantee. If you are not satisfied with your product within 365 days 

of receipt you can send it back to us for full refund. 

There is 24 hours processing period once payment is received. Once shoes are shipped ,You will get 

an email from us with tracking number so you may track your order. You will have your products 

within 3-5 business days (not counting weekends or Holidays). Most orders are processed and 

received by customers within 3 days . 

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gold black ) 

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Jeremy Scott x adidas JS Wings 2.0 US Air Flag Adidas Originals x Jeremy Scott JS Wings 2.0( 

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high Sneakers 

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FAQ : adidas jeremy scott,adidas wings,jeremy scott adidas,jeremy scott wings,adidas js wings, jeremy scott adidas,adidas jeremy scott store and adidas wings,adidas js wings,jeremy sco... 


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1.What Payment Methods does Adidasjeremyscottwings.com accept? 

Adidasjeremyscottwings.com accepts PAYPAL and CreditCard(VISA,MASTERCARD). (For First Time customers, please make sure to place your 

order to your billing address or we will deny your transaction. We can only ship to an address different from your billing address if you are a returning 

customer.) 

Customers without a Paypal account will have an option to set up an account with Paypal while you go through the payment process. However, you 

do not need to create a PayPal account if you choose not to. You will be prompted by PayPal concerning whether you would like to create an 

account with them or not after the transaction goes through. 

If you have or choose to create a Paypal account, returning purchases to Adidasjeremyscottwings.com or to any websites that accepts Paypal 

payments as well as eBay auctions can be done in a few clicks. Paypal is an eBay company with industry leading security to protect your financial 

info. 

NOTE: cause of the supplier of the credit card payment method is a U.S. company, so our credit card payment method only accept USD currency. 

So no matter what currency the customers choosed for checkout, our system will translate it into USD. 

2.What is Paypal? 








Located in San Jose, California, PayPal was acquired by eBay Inc. in October, 2002. 

3.Is Adidasjeremyscottwings.com a retail store? 

We are currently only an online store with office. No retail locations. 

4.Is My Payment to Adidasjeremyscottwings.com Secure? 

Not only our website, but also the payment method are all with 128 bit SSL(Secure Socket Layer certificate.so you never have to worry about your 

credit card info gets stolen or sold to other party online. 

5.Does Adidasjeremyscottwings.com Have A Satisfaction Guarantee? 

We have a 100% satisfaction guarantee. If you are not satisfied with your product within 365 days of receipt you can send it back to us for full refund 

(less shipping fees) 

* All returns and exchanges must be in original new condition with all accessories in new condition. We cannot take back any worn or used products. 

*Additional shipping fee will be requested for exchange. 

6.Check My Order History Online 

Order history is a benefit for our registered users. It allows you to review up to the last nine months of orders placed online, by phone or by mail. To 

view your order history online, you must be a registered user. 

http://www.adidasjeremyscottwings.com/index.php?main_page=faq&zenid=v7rtsgi11nrvidg4mh0pliks73[6/7/2012 1:40:37 PM] 

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Back 


To access your order history, please follow the directions below: 

Login to your account using the "My Account" link in the upper Center of the page. 

From the My Account page, click the " View the orders I have made." link. 

Your previously placed orders will be listed, along with their current status. 

To view the order in detail, click on the "View Order" link. 


When an order is sent to us from our site, we are generally unable to change or cancel your order. The order is automatically processed as soon as 

you press "Place Order." You may contact us if you wish to make a change. However, due to the above, we cannot guarantee your order will be 

changed. If you need to change/exchange or return an item that you ordered in error, please return it to us as soon as you receive it. If you want to 

add an item to a recently placed order, please place a new order. 

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We will gladly accept return in brand new condition. All trainers purchased from Adidasjeremyscottwings.com can only be returned in brand new 

condition with original box and all applicable accessories (ex. retro card, original trainer laces, etc..) The return must be requested 365 days from the 

day the trainers are delivered to our customers. Returns and exchanges back to Adidasjeremyscottwings.com must be posted marked within 365 

days your request has been approved. 

*Defective trainers must be mailed back to Manufacturers in exchange a gift certificate at the trainers' suggested retail price value. We can only 

guarantee that the trainers purchased from Adidasjeremyscottwings.com are authentic and in brand new condition, no exceptions. We can not 

guarantee the condition of the trainerbox. For collectors or as a gift, please add a note on the note line when placing the order for us to pick the best 

trainerbox. For detail information on how to return your defective trainers please email us. 

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Womens Jeremy Scott 

Adidas Originals OBYO 

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$115.99 tax incl. On sale! 

Worn by Lil' Wayne, but more likely designed with the intentions of Fred or Wilma, the Adidas ObyO JS 

Bones is the latest kick from Jeremy Scott. The mid top, inspired by one of his favorite themes, the Flintstones, 

comes in white premium leather with turquoise accents and three large bones placed on the upper. The 

Womens Adidas JS Bones is just one of many Jeremy Scott sneakers that will demand attention. Do not 

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AdidasPorsches was established in 2008, base in China, is a professional trading company on Adidas Porsche 

Design, Adidas Jeremy Scott, Soccer Cleats and other kinds of shoes. We perform retailing, wholesale and 

manufacturing for our customer located all over the world. Being a leading worldwide trade company,we supply highquality 

merchandise to international buyers who are interested in shopping online. 

As an online business platform mainly retailing,we provide our buyers with an efficient and manageable procurement 

process covering every phase of the international supply chain and streamlining trade channels. Also welcome 

wholesaling! 

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1.To provide our customers one-stop sercvice and point-to-point trade solution for you customizing. 

2.To establish a transparent, automatic and collaborative round-the-clock e-marketplace. 

3.To offer cost-effective trade services by leveraging the latest e-commerce technologies and integrating trade 

channels. 

4.To maximize our international buyer's profitability and competitiveness 

Our Advantages 

1.Abundant resources and multiple trade channels in e-commerce both at home and abroad; 

2.Advanced searching technology which could provide information of various categories; 

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We collect information from you when you place an order or subscribe to our newsletter. 

When ordering or registering on our site, as appropriate, you may be asked to enter your: name, e-mail address, 

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We offer the use of a secure server. All supplied sensitive/credit information is transmitted via Secure Socket Layer 

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include trusted third parties who assist us in operating our website, conducting our business, or servicing you, so 

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All of our products are free shipping to the worldwide with DHL, EMS, USPS, chronopost, canadapost, etc. You can 

refer to site http://www.ems.com.cn/english-main.jsp or http://www.dhl.com for more details. 

As a rule, delivery time is about 7 working days. We will inform you tracking info once we send out your items. 

We offers a 30 Day Satisfaction Guarantee. If for any reason, you are not completely satisfied with your purchase, we 

will gladly accept your return for an exchange or refund within 30 days of your delivery date if the following 

conditions are met: 

1. Returned items must be completely new in saleable condition. 

We WILL NOT accept returns and/or exchanges if there is evidence that the shoes have been worn outdoors. We 

reserves the right to refuse any return and/or exchange that does not meet the conditions stated herein. 

2. A return authorization number must accompany all returns and exchanges. 

To return a product, you must contact Customer Service for a return authorization number. It is the same as Order 

Number. If a return authorization number is not obtained prior to returning the package, the return may not be 

accepted. during normal business hours of 8 am - 4 pm Pacific to obtain a return authorization number. Return 

authorization numbers will not be provided by email. 

Return for Exchange 

Ordering your exchange item will better ensure availability. We will refund your purchase price once we receive your 

return. If you choose not to order, you still must call to obtain a return authorization number. Once you have 

obtained this authorization, please complete the form by following the instructions located at the bottom of your 

receipt. 

1. Return Shipping Charges: Customer will be responsible for the any charge to ship the item back to us. If 

you believe an error was made in your order, please contact Customer Service. 

2. Items returned for exchange: If the desired item is out of stock, the return will be treated as a return for 

refund. 

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Womens Adidas Adicolor Blue White [Womens Adidas Adicolor 17] - $68.40 : Adidas Shoes , Cheap Adidas Shoes On Sale in AdidasRed.com 



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Blue Womens White Adidas Adicolor 

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Adicolor Blue 

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$204.40 $68.40 

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Fascinating Womens Adidas Adicolor Blue 

White shoes with a blue full grain leather upper 

are very fashionable and durable for you to 

wear. The brand logos on the tongue and the 

heel tab are also in blue. Apart from these, the 

shoes feature transparent stripes along the 

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About Us 

Adidasred.com is one of the largest selection of 

Adidas Red Shoes online. Our mission is to make 

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us as their primary source for team related 

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athlete with the best possible equipment of Adidas 

Red Shoes for any types of sports, such as soccer, 

fitness and training, basketball, trail running and golf. 

They are all in red colorway for you! 

With several years hard working, we have earned a 

solid reputation for quality, reliability and 

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cover favorable policy, affiliate discount, instant and 

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This statement contains our practices in protecting 

your privacy,and by using this web site, you consent 

to our collection and use of certain information as 

stated below. All changes to our privacy policy will be 

posted on this page or our home page so the 

customer is always aware of the information we 

collect and how we use it. The information in this 

policy can change at anytime and we encourage all 

customers to review this policy as often as necessary. 

Collection of information 

We collect your information during your buying 

process. For starter, you need to fill in a form 

with your basic information when you sign up for 

the site. These information is used to set up 

your account.Then, after you place an order, you 

should give us your credit card information for 

the payment. Then, after the successful paying, 

we need you to confirm your contact information 

which we will share with the transporatation 

company for the delivery. 

We also collection your system information. 

These information are things like your buying 

history, the IP address of your ISP server, your 

browser type etc. We provide these information 

to you only as reference and we ourselves use 

them to do market research and better the 

quality of our site. 

Protection of information 

We have taken various measures to protect your 

information. For your basic information, we will store 

them in an encrypted database with limited number of 

staff accessing them. And your credit card information 

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from our site is able to get them. Besides, we will 

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company concerning the privacy of information. 

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system collect and process them automatically. 

Besides, we may delete them when our system go 

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Shipping Policy 

1. We will deliver the items in two days if no 

exception happens. 

2. All the goods will be sent out from China. 

3. You have two choices. One is posting by? 

EMS(equivalent to American USPS), the other is 

posting by FedEx, TNT, or UPS, which takes 3 

or 4 days and costs extra 30$. 

4. Shipping to one of the countries below is free of 

charge: USA, UK, France, Germany, Spain, 

Italy, Canada, Australia, New Zealand, Mexico, 

Switzerland, Belgium , Ireland, Denmark, Japan, 

Portugal, Norway, Greece, Singapore, and 

Vietnam. And it takes 10$ to Brazil, 30$ to one 

of the countries below: Holland, Iraq, Russia, 

Poland, and Iran, and 50$ to Guadeloupe. 

5. A bill should be signed by an adult on the items’ 

arrival. If not, it will be sent to the local post 

office and please contact the post office. 

Return Policy 

1. If we mistake the style, color or the size, keep 

the item and we will deliver the right one as soon 

as possible. 

2. We can accept your Return or Exchange. 

There are 3 points we have to make clear. 

Firstly, if the size doesn’t fit you, contact our 

Customer Service and get our correct address. 

Secondly, the buyer should be responsible for 

the charge of posting back the item. 

Thirdly, if you want to return and get a refund 

because of the item’s quality we will discount 

10% of the figure of the order. 


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Adidas ZX 800 Purple Grey Blue Yellow [Adidas ZX 800 2] - $70.68 : Adidas Shoes, adidasrunning.net 



Adidas ZX 800 (1/2) 


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800 Purple Grey 

Blue Yellow 

$70.68 

Well here's a pretty fresh runner from Adidas. 

From the ZX family comes the ZX800. The 

deep hued colorup is composed of nubuck and 

various meshes in purple, grey, and blue. 

Yellow and white accents on the midsole. 

Looks like comfort and breathability was 

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Welcome to adidasrunning.net 

Our website offers the customers more than just shoes! 

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Adidasrunning.net is a leading Adidas Running Shoes 

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Size:36-44 

ID:20998 

Package:Original binding Adidas box 

Place of origin: Made in Germay 

http://www.adidas-sport.com/Adidas-Daroga-Two-11-CC-2012-Black-Red-1034.html[9/6/2012 3:40:37 PM] 


Height: 

Color: 

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Size: 

Black/Red 

$70 

Choose your size 

Quantity: 

Add to Cart 

Free Shipping To Most Countries! 

Secure Payments by visa,american express,jcb, 

western union. 

Adidas Daroga Two 11 Climacool 2012 Black/Red for lovers is featured by the air holes in the red outsole, making the 

shoes breathable, as well as the tooth-shaped outsole also makes the shoes skid-resistant. The big logo Daroga in the 

heel is very eye-catching. The design of thin shoe's body gives you a cool feeling.



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Adidas Camo Sandals Black White 

$63 

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Adidas MEGA TORSION FLEX Blue Adidas MEGA TORSION FLEX Black 

$80 

$80 

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Adidas MEGA TORSION FLEX 

$80 

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http://www.adidas-sport.com/About-Us.html[9/6/2012 3:39:52 PM] 

Adi Dassler’s dream is to create the best sports shoes.It takes decades to develop from the birth to being the leader in 

modern sports brands. 

Usually, adidas represents a special kind of status symbol, and some people call it “the three lines of victory”.Since the 

founding date in 1948, adidas has helped countless athlete succeed to achieve many great performance.Therefore, 

adidas can be also treated as the best model with public trust and respect. 

As to the support degree, especially in the world of football, there is no a sporting goods manufactory can be compared 

with adidas.Besides football, adidas also plays an important role in other sport fields, like basketball, cricket, rugby, 

baseball, handball, athletics, tennis, boxing, swimming and the latest extreme sport.Many famous top athletes are 

captivated by the quality of adidas. 

Today, adidas also upholds the spirit of Adi Dassler, which is making the best shoes, always communicate with the 

world’s top athletes and coaches to exchange experiences and needs, then work out the ergonomic products after a 

series of repeated measurements and tests. These products can not only help every kind of athletes to improve their 

performance, but also can meet the general consumer’s demands for high-quality sporting goods.In recent years, adidas 

has breakthroughs in design and function.The representative design concept of the three lines has also been another 

wave in popular trend, attracting the youngsters in this modern society to form a new fashion style and leading the global 

movement of goods into a more diversified world. 

In general, there are three categories of sub brand, they are adidas Original, adidas Style and adidas Performance,which 

is the most popular.And the corresponding, the number of adidas logo is three, not one.The corresponding logo of adidas 

Original is shamrock, adidas Style is three round half pack stripes and adidas Performance is three stripes(some people 

call it “three bricks”), which can be often seen in adidas store. 

Free Shipping.Return Policy.Always! 

Our website address is www.adidas-sport.com. Welcome! 

Complaints mailbox:adidas-sport.vip@hotmail.com 

Website http://www.adidas-sport.com 


Copyright © 1998-2012 www.adidas-sport.com Inc. Adidas TM Design

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TEL:+86(0591)87893913 

http://www.adidas-sport.com/Contact-Us.html[9/6/2012 3:40:17 PM] 

www.adidas-sport.com is dedicated to Customer service. To serve our customers efficiently,our 

friendly and efficient staff can be contacted in many different ways. 

24 hours on line. 

All e-mails received during business hours will receive a reply the same business day. 

All other e-mails will receive a reply before noon eastern time the following business day. 

Phone: 86(0591)87893913 

E-mail:adidas-sport.vip@hotmail.com 

Online Customer Service: Click Here 

Please complete the form below to help us understand your needs A member of our solutions team will 

then contact you directly.Thank you for your enquiry! 



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http://www.adidas-sport.com/Faq.html[9/6/2012 3:40:05 PM] 

1. What are the return ,exchange, refund policies? 

If you are not satisfied with the item, please take a picture of the items first, then send us an email to 

confirm, in 10 days, you can return the items to us and we will make an exchange after its passing an 

offical inspection. 

2. Are all products showed in the website? 

We are not displaying all products on this website now. If you are expecting other styles which are not 

shown here,please tell us which one you are interested in asap,and we will do our utmost to meet your 

requirements ! 

3. What do you need to get your item ? 

You need to show your identification card to the postman when they send your item to your house.The 

express company will call you if your address has changed. 

4. Are the pictures true or false? 

All of the pictures are definitely taken by ourselves,The color phenomenon may occurred only in a few 

pictures, check them clearly before put the item into your cart. 

5. How long does it take for delivery? 

Generally, you may receive the item in 5-14 days after you paid for your orders,which are free shipping to 

any countries in the world. 

6. Patment methods : 

Please pay by visa card,master card, western union. 

7. About cancel the order and refund 

You will get fully refund in 3 days ,if you pay by VISA , master card and jcb will deduct from the refund 

5% commissions. 

8.What does Common payment error code stand for? 

3 The trade amount exceeds the maximum single purchase. 

4 The trading amount this month have exceeded the monthly limit. 

5 Multiple transactions occured from the same IP. 

6 Multiple transactions occured from the same email address. 

7 Multiple transactions occured from the same card . 

8 Multiple transactions occured from the same Cookies. 

9 The scale of Maxmind is excessive. 

10 You haven't registered yet. 

11 The Activation code doesn't exist. 

12 You haven't choose the currency yet. 

13 The name of card holder . 

14 You entered wrong back link. 

16 The way of payment does not open. 

17 Hacked card bean. 

18 Some error or abnormal condition in the system.

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http://www.adidas-sport.com/Faq.html[9/6/2012 3:40:05 PM] 

19 Transactions of the VIP Customer being processed. 

20 Some error in the settings of ways of payment . 

21 The payment of this card have exceeded the maximum amount. 

22 The URL of transaction is incorrect. 

23 The trading currency is incorrect. 

24 Multiple transactions occured from the same number of transaction. 

25 The informations of card holder are incorrect. 

26 The trading amount exceeds the maximum, $50000. 

88 Success. 




adidasstar.com

Adidas 35th Anniversary Black White [Adidas 35th Anniversary 7] - $77.95 : Adidas Shoes, AdidasStar.com 



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http://www.adidasstar.com/adidas-35th-anniversary-black-white-p-548.html[9/7/2012 2:09:46 PM] 


Adidas Shoes Home :: Adidas 35th Anniversary :: Adidas 

35th Anniversary Black White 


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Adidas 35th 

Anniversary Black 

White 

$308.95 $77.95 

Save: 75% off 

Modern Adidas 35th Anniversary Black White 

shoes are monogrammed with classic trefoil logo. 

The white triple strips, heel tab and branding on 

the tongue make the shoes look timeless. The 

silver tone metal eyelets are engraved with 35th 

Anniversary. The shell toe made of rubber looks 

very nice. 

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Adidas 35th Anniversary Black White was added to Adidas 

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http://www.adidasstar.com/shippinginfo.html[9/7/2012 3:14:03 PM] 




1. All items start from China. 

2. Shipping the order within 24-48 hours 

after clarifying your payment is cleared. 

3. We choose EMS as our consignment , 

which has 5-10 days for finishing the 

shipment .Act like UPS in USA . 

4. For your convenience , we also offer the 

rush delivery through TNT, UPS,FEDEX 

which call for 3-4 days to fulfill the 

delivery and fee around $30. 

5. Mail the order freely to some countries 

like USA, UK, France, Germany, Italy, 

Australia, Canada , New Zealand, 

Mexico, Switzerland, Denmark, Portugal, 

Vietnam, Spain, Belgium, Ireland, Japan, 

Norway, Greece , but need $30 for the 

countries like Holland, Iraq, Russia, 

Poland, Iran, Slovakia , $10 for Brazil 

,and $50 for Guadeloupe . please contact 

Customer Service for inquiring more 

information. 

6. It’s better for the person who is above 18 

sign for the parcel , if nobody is available 

for signing when the order arrive , It 

would be sent back to local post office , 

please call the local post office in time. 

Return policy: 

1. If something is wrong with an order , like 

you receive the wrong size , wrong color 

or wrong style goods, according to our 

make-up principle , you can keep the 

products unconditionally , also we will 

send you the ideal order again. 

2. Please afford the return-shipped cost . 

3. Please take care of the return orders , 

such as no washed and no worn when 

take an comparison to original items. 

4. We will send you the refund as soon as 

possible when the return items were 

received . 

5. Before mail us the return , please make 

sure contact us for our detail address. 

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http://www.adidasstar.com/privacy.html[9/7/2012 3:14:15 PM] 



Before you actually sign up for the site ,please 

spare a moment to read this privacy policy 

because by using this web site, you consent to 

the collection and use of certain information by 

us.And all changes to our privacy policy will be 

posted on this page or our home page so the 

customer is always aware of the information 

we collect and how we use it. The information 

in this policy can change at anytime and we 

encourage all customers to review this policy 

as often as necessary. 

Personal information: 

We need you to provide certain amount of 

information to finish the buying. First of all, 

when you sign up for the site, we need your 

basic information to set up an account for you. 

After you place an order, we need you to 

confirm your contact information for the 

delivery. And then, before you send out our 

goods, we need you to finish the payment by 

giving us your credit card information. All 

these information are entered by you and they 

are your personal information. You can look 

up, changes, delete them anytime you like. 

Non-Personal information: 

By Non-Personal information we mean the 

system information collected automatically 

during your buying process, they are your 

buying history, the IP address of you ISP, your 

browser information etc. We provide them to 

you only as reference and we us them to do 

market research and improve our site quality. 

These information can not be operated by you, 

and we may delete them when our system go 

upgrade. 

Our measures to protect your information: 

We have taken enough measure to secure your 

information. We have strict rule as for when 

these information can be abstracte and 

used.We are crewed with the most experienced 

staff in E-business and they are equipped with 

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we have a strong tech team to watch all the 

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http://www.adidasstar.com/about_us.html[9/7/2012 3:13:50 PM] 


About Us 

Dear friend from the world, welcome for 

visiting our AdidasStar.com. AdidasStar.com is 

a professional and reliable online retailer that 

selling Adidas Shoes with high quality and 

reasonable price. You can find fullest range of 

Adidas shoes here. You can receive best 

services here. We take pride in our prompt 

delivery and considerate customer service. 

Responsible for our products, we provide a 

very sound after-sales service. Just remove 

your worries and trust us! adidasstar.com 

promise your purchase is 100% secure and we 

don't share your any personal information 

which you remains with us. Adidasstar.com 

insists that "Customer first Quality first". We 

ensure you top quality and low price. Don't 

hesitate to contact us if you have any other 

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adidaszxshoes.com

Adidas ZX 500 Olive Grey Green [Adidas ZX 500 2] - $70.95 : Adidas ZX Shoes, Adidas Shoes - AdidasZXShoes.com 



Adidas ZX 500 (3/5) 

http://www.adidaszxshoes.com/adidas-zx-500-olive-grey-green-p-14.html[9/6/2012 4:06:25 PM] 

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Metallic Blue 

$75.00 

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$68.80 

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Adidas Shoes Home :: Adidas ZX 500 :: Adidas ZX 500 

Olive Grey Green 

Adidas ZX 500 

Adidas ZX 500 Olive 

Grey Green 

$70.95 

The adidas ZX 500 was the running shoe of the 

future. This Adidas ZX 500 Olive Grey Green is a 

fresh creation brings olive suede and grey mesh 

upper. It is accented with green laces, Adidas 

three stripes, heel tab, and midsole stripe. Try it! 

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Adidas ZX 500 Olive Grey Green was added to Adidas ZX 500 

on Tuesday 27 April, 2010 



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http://www.adidaszxshoes.com/about_us.html[9/6/2012 4:05:51 PM] 





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Adidas ZX 8000 White Yellow 

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$73.50 

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Metallic Gold 

$72.99 

Adidas ZX 8000 Midnight Navy 

Black Blue 

$75.50 


About Us 

Welcome to visit on AdidaszxShoes.com! 

AdidaszxShoes.com is a new generation 

specialized in sports products, which was 

founded in 2008. However, we have got our 

reputations through our best effort these years. 

For we always provide the high quality, lower 

price, and fast shipment to our customers all 

over the world. You will also feel safe purchasing 

on our site for we have some encryption system 

to protect your information. 

Here we will firstly introduce you the Adidas ZX 

Shoes. Shoes from Adidas ZX series are 

considered as the jogging shoes launched in the 

80’s. The original design has been highlighted on 

the comfort, using a material having the buffer 

function into sole, as well as toe cap design for 

more relax. The Adidas ZX Shoes are also well 

known for the bright colorway used on them. 

There are many ZX series like ZX 500, ZX 700, 

ZX 5000, ZX 8000 and so on. So if you like any 

of these Adidas ZX Shoes, please feel free to 

contact with our customer service once you have 

any questions. 

Thank you. Enjoy yourselves! 

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1. Adidas ZX 5000 

Blue Red White 


White Yellow... 


Camo Pack 

4. Adidas ZX 800 x 

Footpatrol 

5. ACU x Adidas ZX 

800 Chinese Flag 

6. Adidas x Kendo 

ZX 800 AZX 

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9. Adidas ZX700 

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http://www.adidaszxshoes.com/privacy.html[9/6/2012 4:06:13 PM] 





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Adidas ZX 800 Animal Pack Black 

White 

$74.99 

Adidas ZX 800 Red Dark Brown 

$75.85 

Adidas ZX 800 Brown White Black 

$76.69 



This policy illustrates you the details how we use 

and keep your personal information secure. To 

see. summary of this policy, and for more 

information to answer your privacy concerns, 

please turn to our online CUSTOMER SERVICE, 

which has professional staff to solve your 

problems right away all the time . 

Scope 

This Privacy Policy aims to show you how we 

handle your personal information for our services 

on our website. It applies generally to website 

that’s sort of related to this .By accepting the 

Privacy Policy and the User aggrement in 

registration, you expressly consent to our 

collection, storage, use of your personal 

information as described in this Privacy Policy. 

Collection 

You can browse our sites without telling us who 

you are or unveiling any personal information 

about yourself. Once you offer us your personal 

information, you are not anonymous to us base 

on our business regulations that never give away 

or rent your personal information. We may 

collect and store the information like email 

address, physical contact information, and 

(depending on the service used) sometimes 

financial information, such as credit; shipping, 

billing and other information you provide to 

purchase or ship an order; other information 

from your interaction with our sites, services, 

content and advertising, including computer and 

connection information, statistics on page views, 

taffic to and from the sites, ad data, IP address 

and standard web log information; additional 

information we ask you to submit to 

authenticate yourself or if we believe you are 

violating site policies. for example, we may ask 

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item you list. . 

Marketing 

We don’t sell or rent your personal information 

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http://www.adidaszxshoes.com/privacy.html[9/6/2012 4:06:13 PM] 

to third parties for their marketing purposes 

without your explicit consent .We may combine 

your information with information we collect 

from other companies and use it to improve and 

personalize our services, content and 

advertising. 

USE 

Our primary purpose in collecting personal 

information is to provide you with. safe, smooth, 

efficient, and customized experience. You 

consent to that we may use your personal 

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Provide the service and customer support you 

request. 

Resolve disputes, collect fees, and troubleshoot 

problems ; 

Prevent potentially prohitied or illegal activities, 

and enforce our User Agreement ; 

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http://www.adidaszxshoes.com/shippinginfo.html[9/6/2012 4:06:00 PM] 





Categories 

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Adidas ZX 9000 White Black 

$74.69 

Adidas ZX 9000 Black Golden 

White 

$75.50 

Adidas ZX 9000 X Crooked 

Tongues 

$76.00 




1. No sooner had customers paid the order by 

cash and check than the articles ordered 

would be given out within 24 hours. 

However, if encounter holidays and 

weekends, then, we will endeavor for 

shipping the articles at the soonest. 

2. All articles, being in good condition, will be 

sent from china. 

3. Within5 to 10 days, the articles will get to 

customers’ hand. 

4. Please note to remain contacting the local 

post office without any delay for the reason 

that the articles should be signed on 

reaching, or else, they will be withdrew to 

the local post office. 

5. Carriage free is for the following countries: 

USA, UK, France, German, Spain, Italy, 

Canada, Australia, New Zealand, Mexico, 

Switzerland, Belgium, Ireland, Denmark, 

Japan, Portugal, Norway, Greece, Singapore 

and Vietnam. 

The following countries should charge 

carriage: 

30 Dollars: Holland, Iraq, Russia, Poland 

and Iran; 

10 Dollars: Brazil 

50 Dollars: Guadeloupe. 

Return Policy: 

1. Owing to the inappropriate size, customers 

may return articles one week after they 

have received them, customers are 

responsible for the return shipping fee and 

15% of restocking fee will be demanded. 

2. A second free object may gained by 

customers in the event that we have 

shipped the wrong size, style and colors, 

however, returning the goods are not 

claimed. 

3. If for any reason customers dislike the 

articles, then, returning is not permitted. 

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botasdemessi.com

Football Boots Adidas Copa Mundial AG Black [botas_6255] - € 69.00 http://www.botasdemessi.com/botas-de-futbol-adidas-copa-mundial-ag-n... 


Info PR: ? I: ? L: ? LD: ? I: ? Rank: ? Age: ? I: ? whois source Theft: ? Sitemap: ? Rank: ? Price: ? Links: 70 | 2 Density ? 

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Product Description 

Enlarge image 

Boots Nike Mercurial Vapor VIII FG Black Green 

Football Boots Adidas Copa Mundial AG Black 

€ 208.00 € 69.00 

Save: 67% off 

Model: botas_6255 



Size 

Umbro football shirt of Ireland 2 2011-2012 

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Following 

Product 1/4 

Add to Cart 

The World Cup is undoubtedly the best football boot there, besides being the oldest boots market, which shows that for a lot of technologies that exist fail 

to overcome. 's World Cup adapt the foot to perfection to play with a glove on your feet. 

Customers who bought this item also bought ... 

This product was added to our catalog on Thursday 15 September 2011. 

T 2011-2012 1st Schweinsteiger Bayern # 31 

1 of 2 9/6/2012 5:17 PM

Football Boots Adidas Copa Mundial AG Black [botas_6255] - € 69.00 http://www.botasdemessi.com/botas-de-futbol-adidas-copa-mundial-ag-n... 

Case 1:12-cv-23295-JLK Document 6-5 Entered on FLSD Docket 09/12/2012 Page 100 of 

128 

2nd T 2011-2012 Schweinsteiger Bayern # 21 

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Football boots Black Adidas world cup SG 

€ 208.00 € 69.00 

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Daily News 

Adidas football shirt of Germany Schweinsteiger # 

7 1st 2011 

Football Boots Adidas World Cup SG White 

€ 208.00 € 69.00 

Save: 67% off 

Football Boots Adidas Copa Mundial Team Astro 

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Enlarge image 

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Product 10/48 

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Contact 

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E-mail: zapatillas4futbol@163.com 

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Table of Contents 

- FAQ 

* Contact 






1 of 1 9/6/2012 5:11 PM

FAQ : Comprar Camisetas de futbol, camisetas futbol imitacion http://www.botasdemessi.com/index.php?main_page=page&id=20 


128 


Inicio FAQ 

FAQ 

Anterior 

Continuar 

Siguiente 

If you have any other questions, please feel free to 

contact us. Our online support will reply to you in 10 

hours. 

Q:Are your items Brand-new? 

Tabla de contenido 

* FAQ 

- Contacto 

A:Yes. all of our Products are Brand-new and come with their authentic quality, original casing. variants, or customized products. 

Q:Why our products are so cheap? 

We sell direct from our factory to the customer and cut out the middleman. 

Q:How long I will receive my order? 

We will ship item in 12 hours after we recieved your payment,the delivery time is 5-7 days. 

Some case products sold out Take long time 5-7 days Because We wait factory New process this product or go to find product with another company . 

Q:What's your payment? 

1: VISA (Accept credit cards quickly and easily and without exposing credit card numbers to the merchant ) 

2: Westerunion,Moneygram or Bank transfer (we will give you 10% discount if you choose these 3 payment.) 

Q:How about the shipping fee? 

A:The shipping cost is Eur20 for first item,Eur30 for 2 items,Eur35 for 3 items,and you will get free shipping if your order over 3 items 

Q: Where is your store? Can I pay after receive goods? 

A:Sorry,we are online shop,we don’t have store. You should to pay for us first,we will ship out your package after you make payment. 

Q:How do i do the process to buy products? 

A:Follow these 5 step 

1.When you find products you would like to purchase, choose the appropriate quantities, sizes, etc. and add the items to your cart. 

2.When you have finished shopping and are ready to checkout, click the Checkout button on the shopping cart page. 

3.Fill in all of the required information on the shipping and billing pages. If you have forgotten to fill in a required field, we will alert you to the area in red text so you can go back and try 

again. Complete the required field with the requested information and continue to checkout again. 

4.Review your order before submitting to verify all of the information is correct and to get your calculated order total. 

5.if you just pay by credit card , there will be let u fill the information for twice .and pls be patient for this ,for one is for our site . one is for the credit card centre . and that will protect your 

right, and tracking your phurchase.if you want to choose other payment,please contact with us by e-mail.We will shipping your shoes in 24 hours after the payment.we can make special 

discount if you pay via western union or wholesale. 

Q:Shipping Information ,how do i know you have shipped my goods. 

A:After we shipped your order , we will send you a tracking number.that will show you where your goods right now on line . 

Q:Can I exchange or cancel an order? 

A:When an order is sent to us from our site, we are generally unable to change or cancel your order. The order is automatically processed as soon as you press "check out",You may 

contact us by e-mail,if you wish to make a change as soon as you want to change it .However, due to the above, we cannot guarantee your order will be changed. For we just send the 

shoes after you ordered it from us in several hours. 

Q:Shipping Information ,how do i know you have shipped my goods. 

A:after we shipped your goods, we will send you a tracking number 

that will show you where your goods at right now .If you still some confused about your order,you can contact with us by E-mail. 

Q:How to get wholesale price? 

1 of 2 9/6/2012 4:46 PM

FAQ : Comprar Camisetas de futbol, camisetas futbol imitacion http://www.botasdemessi.com/index.php?main_page=page&id=20 


128 

A: If you buy more than Eur500 once,we can give you wholesale price for you.and you need contact with us by e-mail.By the way,wholesale only accept Western union and we need your 

payment fax. 

wholesale price all negotiation decide by quantity of your order. 

Noticias al día 

Malheureux Ronaldo au Real Madrid ... Nike Green Boots velocidad ... Lionel Messi anota dos veces en la victo ... 

Italia Euro 2012 Camiseta portero de fú ... Euro 2012 Irland Umbro Fußball Trikot ... Euro 2012 Umbro de Irlanda Camiseta de F ... 

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2 of 2 9/6/2012 4:46 PM


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Welcome / Adidas / Adidas Adipure / Adidas Football Boots Men's World Cup (Black / White) 

Click to View Large Image 

Details 

1 Model:Football Boots adidas Predator Absolion TRX FG 

2 Color:Black / White 

Men's World Cup 

Adidas Football Boots Men's World Cup (Black / White) 

Ref. :0000028 

Availability: In stock 

205,00 € 

104,00 € 

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Quantity: 1 Add to cart 

Quick Overview - adidas Football Boots Men's World Cup (Black / White) 

Adidas Football Boots Men's World Cup (Black / White) 

Designed kangaroo leather footwear for a special ultra-comfortable, the football boot adidas World Cup offers a striking surface smooth, 

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185,00 € 205,00 € 185,00 € 185,00 € 205,00 € 185,00 € 106,00 € 

Kangaroo leather upper for light weight, durability and ultra-comfortable footwear 

EVA insole: comfort 

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Your Position: Home > Service > Shipping 

Service 

contact 

UEFA EURO 2012 soccer 

Jersey 

Real Madrid Ronaldo 

Payment Instructions 

Shipping 

About Us 

Feedback 

Shipping 

Courier Destination of China Express Price List for International EMS 

USA, Canada, U.K, Australia, $25USD for first 500g, Additional weight is $10USD per 

West Europe 

kg. 

$30USD for first 500g, Additional weight is $15USD per 

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kg. 


Africa 

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The delivery status of a package can be checked via the Internet at http://www.ems.com.cn/english-main.jsp 

we also use DHL, UPS, Fedex, TNT and SCS, special way according to the destination. shipping charges is different from EMS. We will 

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Your item(s) will normally be sent out within 2 business days and it takes approximately 5 business days to arrive depending on the 

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If you suspect your order cannot be delivered as addressed and you have not receive confirmation of its return to us after 4 weeks from 

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Dropshipping 

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We accept four way payment. That’s Western Union, Money Gram and Bank Wire, 

The system will send to you an E-mail for the our detail information of payment after you submit the order. 

1.Western Union 

Western union is fastest way to transfer money worldwide. With its cheaper charge and convenient office locations, 

we are willing to accept this payment method, You can use your credit cards to pay us via Western union online. You 

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at:http://www.westernunion.com 

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Our Delivery 

www.football-en-salle.com has many delivery spots to service shoppers from all over the world. Our Football Boots online would do delivery for United States & Canada whereas 

our European customers would have their items delivered directly from the factory as well as other countries will also delivery from these warehouse. 

Delivery Time 

Items will be shipped out 2 - 3 days after receiving the order. In general, it may take about 3 - 10 business days for delivery, depending on the different delivery means you select. 

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Order Tracking 

We allow you to track your order at the click of a mouse. When your shipment is confirmed, you'll receive a tracking number in your confirmation e-mail. We do not exclude the 

possibility that our products may run out of stock in our local warehouse. In this case, we reserve the right to ship the products from Hong Kong without any additional fees. 

What will I be charged for shipping? 

Shipping and handling charges vary greatly depending upon the value of the materials and craftsmanship of the piece and its final shipment destination. The shipping and handling 

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Please allow up to 10 business days for your item to be delivered. If it still does not arrive, please reach us by clicking the ‘Contact Us' button on the website. We will get back to 

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How do I ship items to a different address? 

During our checkout process, specify where you want your purchase shipped. It can be different from your credit card billing address. You may specify any ship-to street address. 

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At www.football-en-salle.com your complete satisfaction is our top priority for long-term business between us, we offer the return and exchange instruction. Before you want to 

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Within 3 days (From the date products were received), if you find the football boots Wholesale you choose from our site are not satisfying you in terms of color or size, it can be 

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us. Our online support will reply to you in 10 hours. 

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We do not cheat any client. We have engaged in online retail&wholesale Air Yeezy Shoes for years.We hope do business with you 

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We usually accept Credit Card.Of course,wholesale price largely depend on quantity of your order. 

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When your order shipping address differs from the billing address,we will send a confirm email to ask for your confirmation.After 

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We will send you a confirmation email detailing the exact order received shortly after your order is placed. 

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Normaly,when we deliver items,you will receive the tracking number via e-mail.And you can track to Express Mail Service Official 

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They are authentic, brand new in original packing. As we can guarantee you: WHAT YOU SEE IS WHAT YOU WILL GET!! If you find any quality 

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We accept credit cards, Western Union, Money Gram, and Bank Transfer, etc. Note: All prices are listed in US $. 

Where do you ship and what are your shipping rates? 

1. We Ship to worldwide area for free by EMS. But charge you $30/pair if you want them ship by UPS/DHL. 

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All the items are handled by EMS (Express Mail Service, door to door service). Generally you will get your items in 5-7 days after your order has 

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You can contact us via the online Msger or via email. All inquiries are answered within 12 Hours. If you have not heard from us, please check 

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There are no returns/exchanges allowed unless wrong shoe or wrong size shoes was received. Ex: Ordered size 11, received size 9 (based on 

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$15.00 

Official FC Barcelona Away Shirt 

11-12 L/S +UCL+Respect +Fifa 

world champions 2011 

$22.99 

New Official Chelsea home Shirt 

12/13 

$15.00 

New Ajax Amsterdam Away 

football shirt 2012-13 

$15.00 

New France Euro 2012 home Kit 


$15.00 



$15.00




Username: 




Club Teams 





Size Info. 

Home >International teams > International teams > Germany >New Germany Euro 2012 home 


New Germany Euro 2012 home Kit 


Adidas Football Shirts - Adidas Germany home 

Short Sleeve home Jersey. Replica Clothing. 

Offer official printing on most football shirts. We 

use the same printing style worn by the players for 

fully authentic printing and customer can 

customize name and number write name and 

number on Name& Number box 

You Have Germany home football shirt for the 

12/13 season or yet 

Buy the New Germany home football shirt today at 

website. kittysoccersports.com 

Fabric: 100% Polyester 

Brand : Adidas 

Price : 15 $ 

Detail : 

http://kittysoccersports.com/product_detail.php?id=261&catid=10&catsubid=11&catsubid1=102&name=New Germany Euro 2012 home Kit football shirt[6/26/2012 10:24:45 AM] 

Size : 

Sleeve Patch : None 

Name & 

None 

Number : 

Other Name & 

Number : 

Quantity : 

S 

Size info. 

( 5 $ ) 

Search 



$15.00 



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Username: 




Club Teams 





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Home >Privacy 

http://kittysoccersports.com/contactus.php[6/26/2012 10:23:31 AM] 

Contact Us. 

Live Chat . MSN kittysoccersports@hotmail.com 

if you want buy many up to 15-20 item contact we can discount price 

All questions will be answered with 24-48 hours of you sending it so please 

just hang in there 

: : : Contact Us Form : : : 

First Name - Last Name * 

Telephone * 

Email * 

Title * 

Detail 

* 

Search 



$15.00 



$15.00 



$15.00 



$15.00




Username: 




Club Teams 





Size Info. 

Home >Shipping Charges 

http://kittysoccersports.com/shipping_charges.php[6/26/2012 10:30:50 AM] 

SHIPPING CHARGES AND DELIVERY TIMES 

1. The shipping cost of football shirt = 10.00 USD for the first item and next 8.00 USD per item. 

2. The shipping cost of soccer patches = 6.00 USD for the first item and next 4.00 USD per 

item. 

3. And the shipping cost. For other shipping methods such as EMS,please contact us 

4. Normally for shipping process, the item(s) will have been sent within 1-3 days after the 

payment completed. 

5. The customer will receive the item(s) 3-4 weeks after the shipping. 

Please keep in mind that we can not control the delay / damage during the post, such as custom 

randomly check packages from foreign countries. 

Payment Methods: Accepts paypal only 

In an attempt to protect our customers from any fraudulent use of their credit/debit cards, 

kittysoccersports.com Accepts paypal only 

To pay by Paypal, please send mail to me 

Upon receipt, we will send you paypal address again. 

Contact us : Live Chat. MSN kittysoccersports@hotmail.com 

Ordering Online: 

All orders are processed on our secure server. Simply select the items you require and add 

them to the shopping basket. In the case of multiple purchases you will always be advised first if 

we cannot fully complete your order in case you wish to cancel the whole order. 

Attention. 

Item. Payment must be received within 7 days after the you buy 

Items. not paid for within 7 days will be or sold to another buyers 

or delete order. 

Returns Policy 

kittysoccersports.com relies on the customer to order the correct size. If the specified size is 

supplied we will not accept any costs involved in exchanging the product and the customer will 

be responsible for any further return postage and packing costs. This applies to any items for 

exchange or refund. Personalized items including loose names and numbers will not be 

accepted. 

Any item for return must be returned with all outlet packaging and labels intact and be in the 

exact condition in which it was received. We will not accept the goods without tags or original 

packaging. 

Please inform us of your intention to return within 7 days of receipt. 

Attention. For buyers From Italy and France Please do not bid as we do not ship to your 

countries. 

Search 



$15.00 



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Home | Club Teams | International teams | Accessories & Other Product | Shipping Charges | Privacy | Contact us 

http://kittysoccersports.com/shipping_charges.php[6/26/2012 10:30:50 AM] 

2011 kittysoccersports.com. All Rights Reserved.


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Back to: Home » Payment 

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Our Western Union data 

First Name:xiumei Last Name:lin 

Address: JianShe Road 168, ChengXiang District,PuTian City, 

FuJian Province,China 

Our Money Gram data: 





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Name XiuMei Lin 

Account Number:6013 8264 0700 3152 457 

Address: 933 wenxian, ChengXiang District,PuTian City, 


Swift:BKCHCNBJ73C 

Post Code:351100 

Paypal address 

We will tell you the paypal address by email. 

Attentions please 

Please remember not to write any sensitive word in the paypal details when you make the payment. 

1, Don’t write our website link during payment comments. 

2, Don’t write the order number during payment comments. 

You can tell me the order number by email. 

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Shipping 

Shipping time 

After your payment your products will be sent within 24-48 hours. 

Reship Service 

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If you pay additional insurance fees (5% of whole price) and the package is broken or lost during the shipping, it is our responsibility to 

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Our staff will offer the best shipping way for you.. 

DHL: 3-5 days. It is available for USA, Canada, UK, France, Switzerland, Ireland, Netherlands, Italy, Chile and so on. The shipping 

cost is very cheap when your parcel is more than 21kg. 

CSS: 5-15 days. It is available for Germany, Norway, Sweden, Belgium, Denmark, Austria, Italy, Netherlands, Hungary, Czech, Greece, 

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EMS: 3-9 days. It is available for USA, Canada, UK, France, Switzerland, Ireland, Spain, Australia, New Zealand, Japan, Singapore, 

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UPS: The tracking number will be on line in 3-5 business days.. 

TNT: The tracking number will be on line in 3-5 business days. 


FedEx: The tracking number will be on line in 3-5 business days.. 

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Who is www.nike-zapatillas.com.es ? 

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Home | List of Measures | Price List | Our cooperated factory | Package Tracking | Returns and Exchanges | Site Map | Shoes News 

E-mail: madeinpt@live.com MSN: madeinpt@live.com 


dropship and wholesale contact madeinpt@live.com 

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Contact Us 

Contact Us! We are always happy to listen to our customers. If want to ask a question or request for information contained in 

mde-in-pt.com, we recommend that you contact us by: 

Phone 

If you need immediate attention, call customer service. 

0086-5942215930 

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Chat 





Click the Live Chat sign up for a live chat window. Representatives are ready to answer your questions. 

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you can send an email to our manager directly if you are not satisfied with our service. 

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Back to: Home »Payment 

Payment 

Our Western Union information: 

Name: Huiying Name: Wu 

Address: Gang Cheng Road, Li Cheng District, Putian City, 

Fujian Province, China 

Money Gram our data : 




Our bank account transfer: 

Name: Huiying name: wu 

Account number: 735 6013 8264 0700 3309 

Address: 933 Wenxian, Chengxiang District, Putian City, 


Swift: BKCHCNBJ73C 

Postal Code: 351100 

Please contact me to learn about our PayPal email if you want to pay by PayPal. 

Attention 

Please remember not to write any word sensitive in the details of paypal when you send payment. 

1, Do not write your website link in the comments of payment. 

2, Do not write the number of payment order in the comments. 


Paypal know our website from the order number. 

Because our web order number on the front page too. 

3, Do not list of Product reviews in payment. 

For example: LV, Armani, Gucci, Channel, Nike, etc.. 

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Back to: Home »Transportation 

Transport 

Delivery time: The products can be shipped within 6-48 hours. 

Resend service: 

if your package is held at the China Customs, we will resend all the products you ordered. Before sending the package, we have to pack 

safely. If the package is broken or lost during shipment, it is my responsibility if you pay additional insurance fees (5% of total). We will 

refund your money including shipping or reimburse the product. 

Instructions on how to send different 

DHL: The shipping time is 3-5 days. that is suitable for the following country: USA, Canada, UK, France, Switzerland, Ireland, 

Netherlands, Italy, Chile and so on. Shipping cost is very cheap when the package is more than21 kg. 

EMS: The shipping time is 3-9 days. that is suitable for the following country: USA, Canada, UK, France, Switzerland, Ireland, Spain, 

Australia, New Zealand, Japan, Singapore, Philippines and so on. Customers do not have to pay taxes. 

HKP: The shipping time is 15-30 days. can be2 kgeach package maximum. that is suitable for the following country: Argentina, Brazil, 

Uruguay, Mexico, Peru, Paraguay, Venezuela, Colombia, Ecuador, Chile and so on. Customers need not pay tax, they can get the 

package at home. 

CSS: The shipping time is 5-15 days. that is suitable for the following country: Germany, Norway, Sweden, Belgium, Denmark, Austria, 

Italy, Netherlands, Hungary, Czech Republic, Greece, Portugal, Finland and so on. Shipping cost is very cheap when the package is 

more than21 kg. 

UPS: The shipping time is 3-5 working days after the tracking number is online. 

TNT: The shipping time is 3-5 working days after the tracking number is online. 

FedEx: The shipping time is 3-5 working days after the tracking number is online. 

Notes: Our company also has a special method, including Argentina customers 

purchase more than 21 kg.Los customers can get the package at home until they buy 

many products of our company. you know, our company is famous in theArgentina. so 

different from other Chinese company! 





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DESCRIPTION FEATURES BUYER'S GUIDE REVIEWS 

Officially Licensed 

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5. Our quality and price advantages. 

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7. How do I find the clothing size fitting me? 

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9. How many payment method do you accept? 

10. How long can I get the customized Product? 

11. Why do you charge my card more than your product price? 

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1. How do I find the item I want to buy? 

Find on home page the category of the item you want to buy (in the category list on the top of the page below the site title), move your mouse to the category name, you will see a 

list of sub-categories. Choose the one your item belongs to, and you will to transferred to the product page. You can choose the item you want to buy here. 

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After click the item you are looking for, select size and fill in quantity,and then click Add to Cart. Review the items in your shopping cart. Enter coupons or discount codes if you have 

any. When you are ready, click Proceed to Checkout. Choose your check out method as guest or registered customer(registered customers can log in from the right page). Click 

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case that you may need to check your order status. 

3. How do you send my purchased items? 

When We received your payment, we will deal with your order with 24 hours.If anything goes well, we will ship it out with 2 days. 

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After we ship it ,Ordinary the parcel will be delivery in 5-7 workdays during all the post process. Well, due to unforeseen circumstances, the time will be last a little longer. Please do 

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If you are a registered member at our website, you may track your order using the "Order Inquiry" link. Or, our Customer Service can help you track your order.And when we get the 

tracking number from the express company, we also can send it and the tracking link to track the parcel's status. 

6. How do I find the items size fitting me? 

You can find Size Chart below the Size Selecting field. 

7. How do I can change my order or cancel my order? 

When we received your payment, we will deal with your order within 2 days. So if you real want to change it or cancel it, we hope you can tell us within 2 days. Because if we ship it 

out , it is difficult to stop the parcel for you. So we hope you can understand. 

8. How do I can return the items to your company? 

If the product's quality is no problem, we can't to accept the return it.If there's a few problems of goods (for example, the stain or the line did not cut off clearly), we hope you can 

wash it or clean it,then we will give our guest appropriate compensation. If the size is small for you , or when you received your jersey, you find you don't like it and so on, these 

problem we don't accept .So hope you can understand us. 

9. How many payment method do you accept? 

We can received the payment through Visa Card,Master Card,Paypal Method,Western Union and Money Gram.

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10. How long can I get the customized Product? 

Because the product is customized, we must ask the manufacture to product it. So usally it need about 15 days to get the item from the factory. We hope you can wait for it patiently. 

And once the parcel is shipped,we will give you the tracking number. 

11. Why do you charge my card more than your product price? 

We only receive the product price. The extra money may be charged by the blank as the blank fee.Hope you can understand. 


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129 

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CONTACT US 

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Composite Exhibit B


WHOIS Summary Chart: adidas AG, et al. v. adidasjeremyscottteddybear.com, et al. , Case No. 12-23295-CIV-KING/MCALILEY 

Domain Name Registrant Address 

sichuanshenneijiangshi 

neijiang, sichuan 641000 

Phone Number Email Address 

addidasjeremyscott.com wang chen 

China +1.8989134600 jeremyscott188@163.com 

adidasjeremyscottteddybear.com yang weibing 

adidasjeremyscottwings.com chen jian 

adidasporsches.com Porsche Adidas 

adidasporsches.net Ciathi Togns 

chaussuredefootdiscount.com black bull 

chaussurefoot2011.org liu jie / hong lin fei xiang 

chaussurefoot2012.info 

kokie resebtter / business 

fa zhan 

cheapbrandpolo.com linfei / hezhing 

cheapbrandpolos.com lin jing 

esadidas.com 

Adidas INC / JEREMYS 

sCHERY 

Yingbing Road,Panyu Guangzhou 

Guangzhou, guangdong 513000 

China 

no.6 fengcheng road 

wuhan, hubei 201410 

0086-189289003 dasjeremyscottt@163.com 

China 

Remshartgaees 12 Augsbur 

Ausbrug, Ausburg 86152 

13965220014 adidasjeremyscottw@163.com 

DE 

Guanghua Road 20hao 

xiamen, Fujian 351100 

+49.34565426905 service@adidasporsches.com 

CN 

66 avenue du pic d'anie ledeuix 

Paris, Paris 64400 

+86.5922668558 service@adidasporsches.net 

France 0559342469 zhengyi0032@yahoo.com.cn 

wu hang shi 

wu hang, wuhang shi, 35641, CN 

shang hai zhong shan lu,nan bei 

xiao qu 

+86.1569855596 moncleronline01@gmail.com 

25 hao, shang hai, 21000, CN 

guang zhou shi dong feng xi lu 

120hao 26C 

+64.8931845 shoppingonlinestorep@gmail.com 

guangzhou, GD, CN, 510000 +86.13794977168 cheapbrandpolo@163.com 

guang zhou shi xi lu 1120hao 26C 

guangzhou, GD, CN, 510000 

C/Xeira, No Moana 

Pontevdra, Pontevdar 36950 

+86.02038675643 cheapbrandpolos@163.com 

ES +34.5912654269 service@esadidas.com



Domain Name Registrant Address Phone Number Email Address 

football-en-salle.com 

hiphoptrade.com 

World-shine Global Trade 

Co,.LTD 

HIPHOP TRADE / IVAN 

FONG 

jeremyscottadidaswings.net zheng yuanguo 

kittysoccersports.com Domain Privacy Service 

Floor 9F,simao 

Building,huangcuo 

,Xiamen City,Fujian 

Province,China 

xiamen, fj 361005 

China 

Yiya Garden , Haizhu district, 

guangzhou. 

City : guangzhou 

Province/State : Guangdong 

Country : CN 

+592.6958688 kellypryde@hotmail.com 

Postal Code : 510240 

huanchengdonglu 

yueqing, zhejiang 201413 

86--37588178 artistsquare@hotmail.com 

China 

1958 South 950 East 

Provo, Utah - 

+86.13968596858 tadidaswings@163.com 

United States 

xiaxi road 

fuzhou, fujian 350000 

+1.8014948462 support@hostmonster.com 

China 1-588-031-3131 15880313131@139.com 

nike2sales.com David Yang 

nike-zapatillas.com.es David Yang None provided 

quanzhoushiquangangqujieshanzh 

en 

quanzhou fujian 362000 

+1 5880313131 15880313131@139.com 

saleonshoesforcheap.com kuangfengbaoyu / aibin ke cn 

anhui hefeishi luyangqu suixilu 

hefeishi 

15080111172 646994186@qq.com 

zhang jian shui / zhang anhui,230000 

wholesalenflauthenticjerseys.com jianshui 

CN +86.05512298889 2448271424@qq.com 

addidasshop.net jiale chen 

cangshanqulongjinhuayuan6#8 

08 

fuzhou, fujian 355001 

China 18605934044 addidasshop@163.com




adidas-boots.com Namecheap.com 

adidasfirst.com arena stick 

adidasred.com hi shoes 

adidasrunning.net yalun yan 

adidas-sport.com Lee Daniel 

adidasstar.com Kelli Fiegen 

adidaszxshoes.com yu yajing 

botasdemessi.com Domain Admin 

8939 S. Sepulveda Blvd. #110 - 

732 

Westchester, CA 90045 

putian 

tianpu 

fujian 

351100 

1.661310211 support@namecheap.com 

CN 

putian 

putian, FUJIAN 351100 

+1.893195609 admin@adidasfirst.com 

CN 

6 New Street 

River City Avenue 165 

dandong 118000 

86.60222983 airjordanstore@hotmail.com 

China 

Shanghai 2602 Excellence 

Times Plaza 

Shanghai 

Shanghai,518000 

0415-2810888 webmaster@adidasrunning.net 

CN 

888 Northeast 4th Avenue 

Canby, OR 

Canby, CT 97013 

86.02187654 xuanranstudio@163.com 

US 

No.8 Xicheng District Zhao 

Dengyu Road 

beijing 

beijing 

100035 

1.5032666712 bravopurchase@gmail.com 

CN 

ID#10760, PO Box 16 

Nobby Beach 

null,QLD 4218 

+1.01025321562 root@adidaszxshoes.com 

AU +45.36946676 contact@privacyprotect.org




fussballschuhe2012.com DomainsByProxy.com 

ijeremyscottadidas.com tim tim 

jeremyscottadidasforsale.com Dabai Guo 

jeremyscottadidasny.com tim tim 

jeremyscottadidasus.com tim tim 

officialchicagobullsshop.com Mikelson Brad 

15111 N. Hayden Rd., Ste 160, 

PMB 353 

Scottsdale, Arkansas 80260 

United States 

Conner AvenueWestfield 

Massachusetts, GA 12201 

+1.4806242599 aa@byproxy.com 

United States 

putian fujian china 

putian, fujian 351100 

+1.3876567894 jeremyscottchen@hotmail.com 

China 



8615080383078 tinker@163.com 

United States 




United States 

S20033 County Road KK 

Nelson Wisconsin 54756 


US +86.07156734061 lpyeshen99@gmail.com


Composite Exhibit C


nike2sales.com















AAA Products 

Brand Watch 






Kid Apparel 

Kid Shoes 

Back to: Home » Payment 

Payment 

Our Western Union data 




Our Money Gram data: 





cart 

Cart 0 item(s)




Our bank transfer account: 

Name XiuMei Lin 

Account Number:6013 8264 0700 3152 457 

Address: 933 wenxian, ChengXiang District,PuTian City, 


Swift:BKCHCNBJ73C 

Post Code:351100 

Paypal address 

We will tell you the paypal address by email. 

Attentions please 

Please remember not to write any sensitive word in the paypal details when you make the payment. 

1, Don’t write our website link during payment comments. 

2, Don’t write the order number during payment comments. 


Paypal will know our website from the order number. 

Because our website write order number in the homepage too. 

3, Don’t write the product name during payment comments. 

For example:LV ,Armani,Gucci,Channel,Nike,Adidas,and so on. 

you know,most of our products are replica.Both of our paypal will be limited if you add any sensitive word! 

thank you for your cooperation! 






nike-zapatillas.com.es






Best sellers 

Men's Shoes 

Women's Shoes 





Watches 


Jewelry 

Pens 





Back to: Home »Payment 

Payment 

Our Western Union information: 




Money Gram our data : 




Our bank account transfer: 

Name: Huiying name: wu 

Account number: 735 6013 8264 0700 3309 

Address: 933 Wenxian, Chengxiang District, Putian City, 


Swift: BKCHCNBJ73C 

Postal Code: 351100 

Please contact me to learn about our PayPal email if you want to pay by PayPal. 

Attention 

Please remember not to write any word sensitive in the details of paypal when you send payment. 

1, Do not write your website link in the comments of payment. 

2, Do not write the number of payment order in the comments. 


Paypal know our website from the order number. 

Because our web order number on the front page too. 

3, Do not list of Product reviews in payment. 

For example: LV, Armani, Gucci, Channel, Nike, etc.. 

You know, most of our products are our replies. Both my paypal and your paypal is limited if you add a word 

sensitive! 

thanks for your help! 



2 of 3 6/26/2012 10:59 AM


Composite Exhibit D



Webmaster Tools - Change of address 

AdWords AdSense Analytics 

Apps 

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Messages 

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Sitemaps 

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Sitelinks 

Change of address 

Settings 

Your site on the web 

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www.tick2buy.com 

Help with: 

Moving your site 

Using the Change of 

Address tool 

301 redirects 

Change of address 

gaffican@gmail.com |My Account |Help |Sign out 

www.tick2buy.com has been moved to www.morncity.com 

(tick2buy.com has also been moved to www.morncity.com) 

Submitted Sep 9, 2010 

https://www.google.com/webmasters/tools/change-address?hl=en&siteUrl=http://www.tick2buy.com/[9/28/2010 1:59:10 PM] 

« Back to Home 

Now that you've submitted your change of address, check your Webmaster Tools data 

periodically to see if your new site has been crawled and indexed. If you have a Sitemap you 

can check Sitemap details to see how many of the pages have been crawled and indexed. 

Withdrawing a change of address 

If you've changed your mind, you can withdraw your change of address. 

Reminders 

Your old site's server should be configured to serve 301 permanent redirects to your new site. 

Ask webmasters to update their links to your new domain, and make sure incoming links to 

your old site are redirected correctly using 301 redirects. 

For other general questions refer to our guidelines for moving your site to a new domain. 

Duration of effect 

Your change of address notification remains in effect for 180 days, by which time Google's 

index will be fully updated with your new site's information. After 180 days, you can extend the 

period by submitting the change of address again. 

© 2010 Google Inc. - Webmaster Central - Terms of Service - Privacy Policy - Webmaster Tools Help

Check Server Headers Tool - HTTP Status Codes Checker 


WEBMASTER TOOLS 

Webmaster Tools Index 

Check Compression 

Check Server Headers 

Run a DNS Report 

HTML Batch Validation 

Semantic Data Extractor 

SPF Record Testing 

Whois Lookup 

Convert Inches to Decimal 

WEBMASTER TIPS 

Webmaster Tips Index 

http://www.seoconsultants.com/tools/headers#Results[9/20/2010 11:26:35 AM] 

SEO Search / SEO Jobs / SEO Tips / SEO Blog / Forums / SEO Testing / Tools / URI 

Valet 

Check Server Headers Tool - HTTP Status 

Codes Checker 

Single URI - Basic Single URI - Advanced Batch URI 

URI Valet 

Single URI Processing - Basic 

Enter the full URI path for the page that you are checking server 

headers for e.g. http://www.seoconsultants.com/tools/headers 

URI: 

Check server headers and verify HTTP Status Codes 

There are seven HTTP status 

codes 

Google Analytics - Free 

Gain traffic and optimize your site 

with Google Analytics. Free! 

www.google.com/Analytics 

(200|301|302|304|307|404|410) that we are primarily interested in 

from an indexing and search engine marketing perspective. It is 

recommended that you verify your URIs are returning the proper 

Status-Code in the Server Header. 

Single URI Processing 

Single URI Processing with Advanced Features 

Batch URI Processing 

Our Check Server Headers tool (Single URI Processing with Recursive 

Results) will identify itself (userAgent) as...



SEO Consultants Directory CSH Bot V2S User IP: 

173.162.97.230 

from /tools/headers 


SEO Consultants Directory Check Server Headers - Single URI 

Results 

Current Date and Time: 2010-09-20T11:26:18-0700 

User IP Address: 173.162.97.230 

#1 Server Response: http://www.watchescollection.com 

HTTP Status Code: HTTP/1.1 301 Moved Permanently 

Content-Length: 150 

Content-Type: text/html 

Location: http://www.replicagood.com/ 

Server: Microsoft-IIS/6.0 

Date: Mon, 20 Sep 2010 18:26:18 GMT 

Redirect Target: http://www.replicagood.com/ 

#2 Server Response: http://www.replicagood.com/ 

HTTP Status Code: HTTP/1.1 200 OK 

Content-Length: 23493 

Content-Type: text/html 

Content-Location: 

http://www.replicagood.com/index.html 

ETag: "85245c9e34fcb1:7f4a" 

Last-Modified: Thu, 09 Sep 2010 05:56:46 GMT 

The Web Server can use the following Header Fields 

1. Method 

2. HTTP-Version 

3. URI 

4. Date 

5. Connection 

6. Authorization 

7. If-Modified-Since 

8. Content-Length 

9. Content-Type 

All other server headers are parsed, but they are ignored. 

HTTP Status Codes that the Web Server can return - 

Definitions 

1. 200 OK 

2. 301 Moved Permanently 

3. 302 Found 

4. 304 Not Modified 

5. 307 Temporary Redirect



6. 400 Bad Request 

7. 401 Unauthorized 

8. 403 Forbidden 

9. 404 Not Found 

10. 410 Gone 

11. 500 Internal Server Error 

12. 501 Not Implemented 

HTTP Status Code - 200 OK 


The request has succeeded. The information returned with the response 

is dependent on the method used in the request. 

Back to Previous 

HTTP Status Code - 301 Moved Permanently 

The requested resource has been assigned a new permanent URI and 

any future references to this resource SHOULD use one of the returned 

URIs. 

Test URI: /w3c/status-codes/301 


HTTP Status Code - 302 Found 

The requested resource resides temporarily under a different URI. Since 

the redirection might be altered on occasion, the client SHOULD 

continue to use the Request-URI for future requests. 


Admin Note: 2005-03-14 - During the past several months, many 

discussions have been taking place in the search engine marketing 

communities concerning what many refer to as pagejacking. What you 

are about to read concerns everyone who has a website online, this is 

not an isolated incident. Those who are involved with the page jacking 

issues may not even know that they are causing harm to those they are 

linking to using a 302 Found redirect. Many of the 302s are generated 

from exit tracking scripts. 

302 Pagejacking - The 302 Page Hijacking Exploit by Claus 

Schmidt 


HTTP Status Code - 304 Not Modified



If the client has performed a conditional GET request and access is 

allowed, but the document has not been modified, the server SHOULD 

respond with this status code. The 304 response MUST NOT contain a 

message-body, and thus is always terminated by the first empty line 

after the header fields. 



HTTP Status Code - 307 Temporary Redirect 

The requested resource resides temporarily under a different URI. Since 

the redirection MAY be altered on occasion, the client SHOULD continue 

to use the Request-URI for future requests. This response is only 

cacheable if indicated by a Cache-Control or Expires header field. 



HTTP Status Code - 400 Bad Request 

The request could not be understood by the server due to malformed 

syntax. The client SHOULD NOT repeat the request without 

modifications. 


HTTP Status Code - 401 Unauthorized 

The request requires user authentication. The response MUST include a 

WWW-Authenticate header field containing a challenge applicable to the 

requested resource. 


HTTP Status Code - 403 Forbidden 

The server understood the request, but is refusing to fulfill it. 

Authorization will not help and the request SHOULD NOT be repeated. 


HTTP Status Code - 404 Not Found 

The server has not found anything matching the Request-URI. No 

indication is given of whether the condition is temporary or permanent. 

Test URI: /w3c/status-codes/404




HTTP Status Code - 410 Gone 


The requested resource is no longer available at the server and no 

forwarding address is known. This condition is expected to be 

considered permanent. Clients with link editing capabilities SHOULD 

delete references to the Request-URI after user approval. 

If the server does not know, or has no facility to determine, whether or 

not the condition is permanent, the status code 404 Not Found SHOULD 

be used instead. This response is cacheable unless indicated otherwise. 



HTTP Status Code - 500 Internal Server Error 

The server encountered an unexpected condition which prevented it 

from fulfilling the request. 


HTTP Status Code - 501 Not Implemented 

The server does not support the functionality required to fulfill the 

request. This is the appropriate response when the server does not 

recognize the request method and is not capable of supporting it for any 

resource. 


Ads by Google Mail Server Image Headers Blog Headers Header Size 

W3 References 

1. W3C - 10 Status Code Definitions 

2. W3C - 14 Header Field Definitions 

IIS Tools - Windows Server Tools 

IIS Server Modules Index CacheRight httpZip ZipEnable ServerMask 

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ISAPI Rewrite 301 Tips 

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Last modified: 2010-08-15T08:08:14-0700


Composite Exhibit E

Case 1:12-cv-23295-JLK 1:12-cv-22057-PAS Document 6-10 32 Entered on FLSD Docket 09/04/2012 09/12/2012 Page 1 2 of 30 261 

CHANEL, lNC., 

VS. 

Plaintiff, 

7PERFECTHANDBAGS.COM, et al., 

Defendants. 



CASE NO. 12-22057-CIV-SElTZ/SlMONTON 

ORDER GM NTING SECOND TEM PORARY RESTRM NING ORDERFXJNAFF 

THIS CAUSE came before the Court on Plaintiff s Second Ex Parte Application for 

Entry of Temporary Restraining Order, Preliminry lnjunction, and Order Restraining Transfer 

of Assets Tied to the Counterfeiting Operation (the Gçsecond Application for Temporary 

Restraining Order ' ) aga i ns t Defendants 23-66 , 1 plzrsuant to 15 U .S.C. j 1 116 and Fed. R. Civ. P. 

65, for alleged violations of the Lanham Act, 15 U.S.C. jj 1 114, and 1125(a) and (d) (DE-281. 

Because Plaintiff has satisfied the requirements for the issuance of a temporary restraining order, 

the Court wil grant Plaintiff s Second Application for Temporary Restraining Order (DE-281 for 

the reasons discussed below. 

1 Defendants 23-66 are the Pm nerships and Unincorporated Associations identified on Schedule 

ktA, jwreto.


1 . 

Factual Backzround 2 

Plaintiff manufactures, promotes, distributes, and sells in interstate commerce, 

including within this judicial district, luxury goods under multiple federaly registered 

trademarks. (See Declaration of Adrielme Hahn Sisbarro in Support of Plaintiff s Second 

Application for Temporary Restraining Order (stl-lahn Decl.'j ! 3.) 

Plaintiff is the registeredowner of the following trademarks on the Principal 

Register of the United States Patent and Trademark Office (colectively, the 'Chanel Marksl'l; 

T Registration Registration 

rademark Number 

Date 

Classtesl/Goods 

CHANEL 0 September 13, , 

,612,169 1955 (lnt l Class: 14) Necklaces 

CHANEL 0,626,035 May l , 1956 (lnt'l Class: 18) Women's handbags 

CHANEL 0,955,074 March 13, 1973 (lnt'l Class: 14) Watches 

(Int'l Class: 25) Suits, jackets, skirts, 

dresses, pants, blouses, tunics, 

JM 1,241,264 June 7, 1983 sweaters, cardigans, tee-shirts, coats, 

raincoats, scarves, shoes and boots 

CHANEL 1,241,265 Jtme 7, 1983 

(Int'l Class: 25) Suits, jackets, skirts, 

dresses, pants, blouses, tunics, 

sweaters, cardigans, coats, raincoats, 

scarves, shoes and boots 

2 The factual background is taken from Plaintiff s First Amended Complaint, Second Application 

for Temporary Restraining Order, and supporting evidentiary submissions. Plaintiff filed 

declarations and exhibits almexed thereto in support of its Second Application for Temporary 

Restraining Order. The declarations are available in the docket at the folowing entries: 

Declaration of Adrienne Hahn Sisbano EDE 28-11, Declaration of Eric Rosaler (DE 28-62, and 

Declaration of Stephen M. Gaffigan (DE 28-121. 

2


T Registration Registration 

rademark Number Date Classtesl/Goods 

r 1 ,347,094 July 9,1985 

(lnt'l Class: 3) A ful line of 

perfumery, cosmetics, and toiletries 

(Int'l Class: 3) Full line of perfumery, 

CHANEL 1 ,348,842 July 16, 1985 cosmetics and toiletries 

(lnt'l Class: 6) Keychains 

(Int'l Class: 14) Costume jewelry 

(Int'l Class: 16) Gift wrapping paper 

1,501,898 August 30, 1988 (lnt , 1 Class: 25) Blouses 

, shoes, belts, 

scarvesrjackets, men's ties 

(lnt'l Class: 26) Brooches, buttons for 

clothing 

November 1, ,j cj 

CHANEL 1,510,757 1988 (Int ass: 9) sunglasses 

1,654,252 August 20, 1991 (lnt'l Class: 9) Sunglasses 

CHANEL 1 

,733,051 

(lnt'l Class: 18) Leather goods; 

namely, handbags, wallets, travel bags, 

November 17, luggage, business and credit card 

1992 

cases, change purses, tote bags, 

cosmetic bags sold empty, and 

gannent bags for travel 

(lnt'l Class: 18) Leather goods; 

1,734,822 

N 

ovember 24, 

namely, handbags, wallets, travel bags, 

1992 luggage, business card cases, change 

ptlrses, tote bags, and cosmetic bags 

sold empty 

(Int'l Class: 9) Mobile phone straps, 

eyeglass frames, sunglasses 

r 3 ,025,936 December ,:()5 13, (Int , 1 Class: 25) Gloves, swimwear 

(Int'l Class: 26) Hair accessories 

namely barretes and pony-tail holders 

3


Registration Registration 

Trademark Classtesl/Goods 

N umber Date 

CHANEL 3,133, 139 August 22, 2006 (Int'l Class: 14) Jewelry and watches 

(Int'l Class: 9) Ski goggles, eyeglass 

frames, mobile phone straps, 

sunglasses, sunglass parts, cases for 

spectacles and sunglasses 

(lnt'l Class: 20) Mirrors, nnmely 

personal compacts and hand-held 

mirrors 

(Int'l Class: 25) Ski boots, sun visors, 

CHANEL 3,134,695 August 29, 2006 suspenders, sweatbands, swimwear, i 

stockings and socks 

(Int'l Class: 26) Hair accessories 

nnmely barretes and pony-tail holders 

(Int'l Class: 28) Bags specialy adopted 

for sports equipment, basketbals, 

kites, skis, ski pols, tennis rackets, 

tennis bals, termis racket covers, golf 

clubs, golf bags, snow boards 

CHANEL 3,890,159 

(Int'l Class: 9) Cases for telephones 

December 14, , 

2010 (lnt 1 Class: 16) Temporary tattoos 

(lnt'l Class: 18) Key cases 

(Int'l Class: 9) Protective covers for 

portable electronic devices, handheld 

D digital devices, personal computers 

ecember 20, 

r 4,074,269 2011 and cel phones 

(lnt'l Class: 16) Temporary tattoos 

(lnt'l Class: 18) Key cases 

The Chanel Marks are used in connection with the manufactlre and distribution of goods in the 

categories identified above. (See Halm Decl. ! 44 see also United States Trademark Registrations 

of the Chanel Marks at issue attached as Composite Exhibit A to the Hnhn Decl.) 

4


3. Defendants 23-66, through the Internet websites operating under the domain 

names identified on Schedule içA' hereto (the dtGroup 11 Subject Domain Names'l, have 

advertised, promoted, offered for sale, and/or sold , at least, handbags, walets, shoes, boots, belts, 

sunglasses, watches, cases for telephones, protective covers for portable electronic devices , 

including cel phones, cosmetics, and costume jewelry, including necklaces, bracelets, eanings 

and rings bearing what Plaintiff has determined to be cotmterfeits, infringements, reproductions , 

and/or colorable imitations of the Chanel Marks. (See Hnhn Decl. !! 9-15.) 

4. Although each Defendant may not copy and infringe each Chanel Mark for each 

category of goods protected, Plaintiff has submitted sufficient evidence showing each Defendant 

has infringed, at least, one or more of the Chanel Marks. (See Hahn Decl. !! 12-15.) Defendants 

23-66 are not now, nor have they ever been, authorized or licensed to use, reproduce, or make y 

counterfeits, reproductions, and/or colorable imitations of the Chanel Marks. (See Hahn Decl. ! 

9.) 

5. Plaintiff retained AED lnvestigations, lnc., a licensed private investigative finn, 

to investigate the sale of counterfeit versions of Plaintif s products by Defendants 23 -66. (See 

Hahn Decl. ! 10; Declaration of Eric Rosaler in Support of Plaintiff s Second Application for 

Temporary Restraining Order rsRosaler Decl.'1 ! 3.) è E 

6. In August 2012, Eric Rosaler (1Rosa1er'), an officer of AED lnvestigations, lnc., 

( 

( 

placed an order for the purchase of (i) a protective cover for cel phones bearing at least one of 

the Chanel Marks at issue in this action through the lnternet website operating under the Group 11 ' 

i 

l 

S ubject Domain Name chanelhandbagszolz-net; (ii) a handbag bearing at least one of the 

Chanel Marks at issue in this action through the lntenwt website operating under the Group 1 y t 

Subject Domain Nnme chinchin.org; and (i) a watch bearing at least one of the Chanel Marks ) 

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at issue in this action through the Intemet website operating under the Group 11 Subject Domain 

Name pickyourwatch.com. (SeeRosaler Decl. !! 4-6.) Rosalerfinalized payment for the 

Chanel-branded protective cover for cel phones purchased through chanelhandbagszolz.net 

via Paypal to the Paypal account, lusahali@gmail.com. (See Rosaler Decl. ! 4 and Composite 

Exhibit A attached thereto.) Rosaler finalized payment for theChanel-branded handbag 

purchased through chinchin-org via Paypal to the Paypal account, loliilol@hotmail.com. (See 

Rosaler Decl. ! 5 and Composite Exhibit B attached thereto.) Rosaler finalized payment for the 

Chanel-branded watch purchased through pickyourwatch.com via Paypal to the Paypal account, 

services@pickyourwatch.com. (See Rosaler Decl. ! 6 and Composite Exhibit C attached 

thereto.) 

Additionally, in July 20 12 and August 2012, Rosaler accessed Internet websites 

operating under the Group 11 Subject Domain Nnmes identified in the table below, and went 

through the purchasing process3 for various products, al but one of which bore counterfeits of, at 

least, one of the Chanel Marks at issue in this action. 4 ( Id . at !! 7-8 and Composite Exhibits D 

and E thereto.) Folowing submission of his orders, Rosaler received information for finalizing 

payment for each of the items ordered via Paypal to Defendants 23-66's respective Paypal 

accotmts as folows: 

Domain Name Paypal Account 

zolzchanelbagstore.com firstzshopping@yahoo.com 

buychanel4u.com firstzshopping@yahoo.com 

buyluxurychanel.com firstzshopping@yahoo.com 

3 R osa1er 

intentionally did not finalize his purchases from the Internet websites so as to avoid 

contributing funds to Defendants 23-66's coffers. 

4 Although the website operating under the Group 11 Subject Domain Nnme replicaolbagsacom 

ofers for sale Chanel branded items (see Hahn Decl. ! 13 and Composite Exhibit B atached 

thereto, (DE-28-3, pp. 169-1784), Rosaler intentionally purchased non-chanel-branded 

merchandise as part of his investigative process. (See Rosaler Decl. ! 7, n. 1.) 

6



chanelbags4u.org firstzshopping@yahoo.com 

chanelbagsus.org firstzshopping@yahoo.com 

chanelbubblebags.com frstzshopping@yahoo.com 

luxuriouschanel.com srstzshopping@yahoo.com 

luxurychaneler.com firstzshopping@yahoo.com 

artemee.com artemeezbuy@gmail.com 

bagsstores.net 576445667@qq.c0m 

bestchanelzu.com topserviceszolz@hotmail.com 

bykicks.com cwj8g@live.com 

bykicks.net cwj8g@live.com 

chanel-2012.org lisamylifez@hotmail.com 

chanel-bags-sale.org lisamylifez@hotmail.com 

chanelbagssaleonline.org lisamylifez@hotmail.com 

chanel-outlet-online.org lisamylifez@hotmail.com 

cheapchanelsale.org aomeitrade@live.com 

chanelzolzbags.com wmserviceoo3@gmail.com 

chanelahandbagszolz.com wmserviceoo3@gmail.com 

chanelauthenticbag.com jiarujiebbbb@l63.com 

chanelbagssaks.com paymentshowtime@gmail.com 

chanelbags-sale.net jenshonggg@gmail.com 

chanelbagsstores.net yinzhiling@lz6.com 

chanelbagstrade.com onlinesalenol@gmail.com 

chanelbagswaletsus.com tradeworldus@hotmail.com 

chanelcheapstore.com yuyongjtm8o@l63.com 

chanel-com.net 35154064@qq.com 

chanel-factory-online.com shoplong77o@hotmail.com 

chanelfactoryoutlet.com shoplong77o@hotmail.com 

chrel-factory-outlet-online.com shoplong77o@hotmail.com 

chanel-factory-store.com shoplong77o@hotmail.com 

chanel-factory-store-online.com shoplong77o@hotmail.com 

chrel-handbags-uockoffs.com shoplong77o@hotmail.com 

chanel-outlet-coupons.com shoplong77o@hotmail.com 

chanel-outlet-online-zolz.com shoplong77o@hotmail.com 

chanel-purses-replica.com shoplong77o@hotmail.com 

china-chrel-outlet-online.com shoplong77o@hotmail.com 

chinesereplicahandbags.com shoplong77o@hotmail.com 

fashionlinebags.com shoplong77o@hotmail.com 

replica-chanel-hrdbags-zolz.com shoplong77o@hotmail.com 

7



chanelflats.biz calinaywhite@gmail.com 

sacchanelzolz.com calinaywhite@gmail.com 

chanelhandbagszolz.net goodrisy@gmail.com 

chanelsandalshoes.com goodrisy@gmail.com 

jpchanelbags.com goodrisy@gmail.com 

jpchanelshop.com goodrisy@gmail.com 

chanelhandbagsbagsonline.biz paymentouk@gmail.com 

chanelhandbagsstores.co.uk paymenttouk@gmail.com 

chanelhandbagsstores.com sairongservice@gmail.com 

chaneloutlet4sale.com globalonline4@gmail.com 

chaneloutlet4sales.com globalonline4@gmail.com 

chaneloutletonlineshops.com copperoilcn@gmail.com 

cheapchanelin.com yunnhuachen@yeah.net 

cheapchrelonlineshopping.com huangcongl l6@gmail.com 

cheapchanelshopping.com 5 h uangcong 1 l6@gmail.com 

vintagechanelonline.com 6 h uangcong 1 l6@gmail.com 

cheapstorestradezu.com lifangligz@yahoo.com 

chinchin.org hujiangg6@live.com 

classic-shopping.com chinawppay@qq.com 

enjoyreplica.com vickygotbags@gmail.com 

eootop.com 4474%l@gmail.com 

etradeshoes.com cotmtresgoo@hotmail.com 

fakechanelbagss.com mygoodjolmgol@hotmail.com 

fakechanelhandbags.co.uk 

falinzfashion.com 

zhu520fa@163.com 

wujingzhenlg88@gmail.com 

louisvuilon-outlet-online.net messbuyuk@hotmail.com 

luxebagsale.com beststorelg84@gmail.com 

macmakeu-p.com shoppingnewlz@hotmail.com 

5 The Stpayment' page for the cheapchanelshopping.com website provides the bnnk transfer 

information for tinalizing payments for purchases identifying the bnnk accotmt information: 

Cong Huang; Bank Of China Guang Dong Branch; Bank Account Number 

***************3609. (See Gaffigan Decl. ! 3 and Composite Exhibit A thereto.) The ful 

account numbers of a1 tinancial institution accounts identified herein have been redacted to 

avoid disclosure of private financial information, in compliance with Fed. R. Civ. P. 5.2(a)(4). 

6 The tkpayment' page for the vintagechanelonline.com website provides the bank transfer 

information for finalizing payments for purchases identifying the bank account information: 

Cong Huang; Bank Of China Guang Dong Branch; Bnnk Account Number 

*****+*********3609. (See Gaffigan Decl. ! 3 and Composite Exhibit A thereto.) 

8

Case 1:12-cv-22057-PAS Document 32 Entered on FLSD Docket 09/04/2012 Page 9 of 30 


261 


manoloblahnikwedding.org go-pay@hotmail.com 

replicaolbags.com credit-pay@hotmail.com 

replicaschanel.biz topebay3zl@gmail.com 

solomonleather.com solmanzcn@tom.com 

SZWCar .C0m 7 Szr aymentVs ina.com 

wholesale-lv-hermes.com wujiejun@hotmail.com 

8 

ecgoshopping.com enjoyshopping 

(see Rosaler Decl. !! 7-8 and Composite Exhibits D-E thereto.) 

8. Thereafter, Plaintiff s representative reviewed and visualy inspected the web 

page listings, including images, for the items bearing Plaintif s trademarks purchased by Rosaler 

and detenuined the items to be non-genuine versions of Plaintiff s products. (See Hnhn Decl. ! 

12.) Additionaly, Plaintiff's representative reviewed and visually inspected the items bearing 

Plaintiff's trademarks offered for sale tlzrough the lnternet websites operating under the Group 11 

Subject Domain Names and detennined the products to be unauthorized, non-genuine versions of 

Plaintiff s products. (See Halm Decl. !! 13-15.) 

lI. LEGAL STANDARD 

In order to obtain a temporary restraining order, a party must demonstrate iû(1) (there is) a 

substantial likelihood of success on the merits; (2) that irreparable injury will be suffered if the 

relief is not granted; (3) that the threatened injury outweighs the harm the relief would inflict on 

the non-movant; and (4) that the entry of the relief would serve the public interest.' Schiavo ex. 

rel Schindler v. Schiavo, 403 F.3d 1223, 1225-26 (1 1th Cir. 2005); see also L evi Strauss dr Co. 

1 The tdpayment Methods' page for the szwear.com website provides the bnnk transfer 

information for finalizing payments for purchases identifying the bank account information: Lin 

Qinghua; Bank Of China; Bank Account Number ***************0705. (See Gaffigan Decl. ! 

3 and Composite Exhibit A attached thereto.) 

8 F ollowing 

the submission of Rosaler's order via ecgoshopping.com, Rosaler was provided a 

link and instructions for finalizing payment using Paypal via wwwabeltal.com, to the seller 

identified as dteniovshoppinc.' (See Rosaler Decl. ! 8 and Composite Exhibit E attached thereto.) 

9



261 

v. Sunrise 1nt 'l. Trading lnc. , 5 1 F. 3d 982, 985 (1 1th Cir. 1995) (applying the test to a 

preliminary injunction in a Lnnhnm Act case). Additionaly, a court may only issue a temporary 

restraining order without notice to the adverse party or its attorney if; 

(A) specific facts in an aftidavit or a verified complaint clearly show that immediate and 

irreparable injury, loss, or damage will result to the movant before the adverse party can 

be heard in opposition (andl (B) the movant's attorney certifies in miting any efforts 

made to give notice and the reasons why it should not be required. 

FED. R. CIV. P. 65(b). Exparte temporary restraining orders tshould be restricted to serving their 

underlying purpose of preserving the status quo and preventing irreparable harm just so long as 

is necessary to hold a hearing and no longer.' Granny Goose Foods, lnc. v. Brotherhood of 

Teamsters dr Auto TruckDrivers L ocal No. 70 ofAlameida Cn@, efc., 415 U.S. 423, 439 (1974). 

111. ANALYSIS 

The declarations Plaintiff submited in support of its Second Application for Temporary 

Restraining Order support the folowing conclusions of law: 

Plaintiff has a very strong probability of proving at trial that conslmers are likely 

to be confused by Defendants 23-66's advertisement, promotion, sale, offer for sale, and/or 

distribution of handbags, walets, shoes, boots, belts, sunglasses, watches, cases for telephones, 

protective covers for portable electronic devices, including cel phones, cosmetics, and costlme 

jewelry, including necklaces, bracelets, earrings and rings bearing counterfeits, reproductions, 

and/or colorable imitations of the Chanel Marks, and that the products Defendants 23-66 are 

seling and promoting are copies of Plaintiff s products that bear copies of the Chanel Marks on 

handbags, wallets, shoes, boots, belts, sunglasses, watches, cases for telephones, protective 

covers for portable electronic devices, including cel phones, cosmetics, and costlme jewelry, 

including necklaces, bracelets, earrings and rings. 

10



261 

B. Because of the infringement of the Chanel Marks , Plaintiff is likely to suffer 

immediate and irreparable injury if a temporary restraining order is not granted. It clearly 

appears from the following specific facts, as set forth in Plaintiff s First Amended Complaint , 

Second Application for Temporary Restraining Order , and accompanying declarations on tlle, 

that immediate and irreparable loss , damage, and injtu'y wil result to Plaintiff and to consumers 

before Defendants 23-66 can be heard in opposition unless Plaintiff s request for cx parte relief 

is granted'. 

Defendants 23-66 own or control Internet website businesses which 

advertise, promote, offer for sale , and sell, 

at least handbags, walets, shoes, boots , belts, 

sunglasses, watches, cases for telephones, protective covers for portable electronic devices , 

including cell phones, cosmetics, and costume jewelry, including necklaces, bracelets, eanings 

and rings bearing counterfeit and infringing trademarks in violation of Plaintiff s rights' , 

2. There is good cause to believe that more counterfeit and infringing 

products bearing Plaintiff s trademarks will appear in the marketplace; that constzmers are likely 

to be misled, confused, and disappointed by the quality of these products; and that Plaintiff may 

suffer loss of sales for its genuine products; 

There is good cause to believe that if Plaintiff proceeds on notice to 

Defendants 23-66 on this Second Application for Temporary Restraining Order , Defendants 23- 

66 can easily and quickly transfer the registrations for many of the Group 11 Subject Domain 

Nmnes, or modify registration data and content , change hosts, and redirect traftk to other 

websites, thereby thwarting Plaintif s ability to obtain meaningful relief; 

C. The balance of potential hal'm to Defendants 23-66 in restraining their trade in 

counterfeit and infringing branded goods if a temporary restraining order is issued is far 

11



261 

outweighed by the potential harm to Plaintiff, its reputation and goodwill as a manufacturer and 

distributor of quality products, if such relief is not issued; and 

D. The public interest favors issuance of the temporary restraining order in order to 

protect Plaintiff s trademark interests and protect the public from being defrauded by the 

palming off of cotmterfeit goods as genuine goods of Plaintiff. 

E. Under 15 U.S.C. j 1 1 17(a), Plaintiff may be entitled to recover, as an equitable 

remedy, the illegal profits gained through Defendants 23-66's distribution and sales of handbags, 

walets, shoes, boots, belts, sunglasses, watches, cases for telephones, protective covers for 

portable electronic devices, including cell phones, cosmetics, and costume jewelry, including 

necklaces, bracelets, earrings and ringsbearing counterfeits andinfringements of the Chanel 

Marks. See Reebok Int 'l, L td. v. Marnatech Enters., Inc. , 970 F.2d 552, 559 (9th Cir. 1992) 

(quoting Fuler Brush Products Co. v. Fuler Brush Co. , 299 F.2d 772, 777 (7th Cir. 1962) (1$An 

accounting of profits tmder j 1 1 17(a) is not synonymous with an award of monetary damages: 

i (aln accounting for profits . . . is an equitable remedy subject to the principles of equity.''l) 

F. Requesting equitable relief ûdinvokes the district court's inherent equitable powers 

to order preliminary relief, including an asset freeze, in order to assure the availability of 

permanent relief.' f evi Strauss & Co. v. Sunrise Int 1 Trading Inc., 51 F.3d 982, 987 (1 1th Cir. 

1995) (citing Federal Trade Commission v. United States Oil and Gas Corp., 748 F.2d 1431, 

1433-34 (1 1th Cir. 1984)). 

G. In light of the inherently deceptive nature of the counterfeiting business, and 

Defendants 23-66's blatant violation of the federal trademark laws, Plaintiff has good reason to 

believe Defendants 23-66 wil hide or transfer their il-goten assets beyond the jurisdiction of 

this Court unless those assets are restrained. 

12



261 

For the foregoing reasons, it is 

lV. CONCLUSION 

ORDERED AND ADJUDGED that Plaintifps Second Application for Temporary 

Restraining Order is hereby GRANTED @DE-28) as follows: 

Each Defendant, its officers, directors, employees, agents , subsidiaries, 

distributors, and al persons in adive concert or pm icipation with any Defendant having notict 

of this Order are hereby temporarily restrained: 

(2) 

a. From manufacturing, importing, advertising, promoting, offering to sel, 

seling, distributing, or transferring any products bearing the Chanel 

Marks, or any confusingly similar trademarks, other than those actualy 

manufactured or distributed by Plaintiff; and 

b. From secreting, concealing, destroying, seling off, transferring, or 

otherwise disposing of: (i) any products, not manufactured or distributed 

by Plaintiff, bearing the Chanel Marks, or any confusingly similar 

trademarks; or (i) any evidence relating to the manufacttzre, importation, 

sale, offer for sale, distribution, or transfer of any products bearing the 

Chanel Marks, or any confusingly similar trademarks. 

Each Defendant, its officers, directors, employees, agents, subsidiaries, 

distributors, and a1 persons in active concert or pm icipation with any Defendant having notice 

of this Order shall immediately discontinue the use of the Chanel Marks or any confusingly 

similar trademarks, on or in connection with a11 Intemet websites owned and operated , or 

controled by them including the Internet websites operating under the Group 11 Subject Domain 

Nnmes; 

(3) Each Defendant, its oficers, directors, employees, agents, subsidiaries, 

distributors, and al persons in active concert or participation with any Defendant having notice 

of this Order shal immediately discontinue the use of the Chanel Marks, or any confusingly 

similar trademarks within domain name extensions, metatags or other markers within website 

13



261 

source code, from use on any webpage (including as the title of any web page), any advertising 

links to other websites, from search engines' databases or cache memory, and any other form of 

use of such terms which is visible to a computer user or serves to direct computer searches to 

websites registered by, owned, or operated by each Defendant, including the lnternet websites 

operating under the Group 11 Subject Domain Names; 

(4) Each Defendant shal not transfer ownership of the Group 11 Subject Domain 

Names during the pendency of this Action, or until further Order of the Court; 

(5) The domain nnme Registrars for the Group 11 Subject Domain Names shal 

immediately assist in changing the Registrar of record for the Group 11 Subject Domain Names, 

excepting any such domain names which such Registrars have been notitied in miting by 

Plaintiff have been or wil be dismissed from this action, to a holding account with a Registrar of 

Plaintiff s choosing (the iNew Registrar'). To the extent the Registrars do not assist in changing 

the Registrars of Record for the domains under their respective control within one (1) business 

day of receipt of this Order, the top-level domain (TLD) Registries tor their administrators) for 

the Group 11 Subject Domain Names, within five (5) business days of receipt of this Order, shal, 

change or assist in changing, the Registrar of record for the Group 11 Subject Domain Nnmes, 

excepting any such domain names which such Registries have been notified in writing by 

Plaintiff have been or wil be dismissed from this action, to a holding accotmt with the New 

Registrar. As a mater of law, this Order shal no longer apply to any Defendant or associated 

domain name dismissed from this action. Upon the change of the Registrar of record for the 

Group 11 Subject Domain Names, the New Registrar will maintain access to the Group 11 Subject 

Domain Names in trust for the Court during the pendency of this action. Additionaly, the New 

Registrar shal immediately institute a temporary 302 domain name redirection which wil 

14



261 

automaticaly redirect any visitor to the Group 11 Subject Domain Names to the folowing 

Unifonn Resource Locator ($URL') htp:/servincnotice.com/omc/index.html whereon copies of 

the First Amended Complaint and a1l other documents on tile in this action are displayed. 

Altematively, the New Registrar may update the Domain Name System (iEDNS') data it 

maintains for the Group 11 Subject Domain Names, which link the domain names to the IP 

addresses where their associated websites are hosted, to NSI.MEDIATEMPLE.NET and 

NSZ.MEDIATEMPLE.NET, which will cause the domain names to resolve to the website where 

copies of the First Amended Complaint, Temporary Restraining Order, and a1 other documents 

on file in this action are displayed. After the New Registrar has effected this change, the Group 11 

Subject Domain Names shal be placed on Lock status, preventing the modification or deletion 

of the domains by the New Registrar or Defendants 23-66,. 

(6) Upon Plaintiff's request, the privacy protection senice for any Group 11 Subject 

Domain Names for which the Registrant uses such privacy protection service to conceal the 

Registrant's identity and contact information are ordered to disclose to Plaintiff the true identities 

and contact infonnation of those Registrants; 

(7) Plaintiff may enter the Group 11 Subject Domain Names into Google's Webmaster 

Tools and cancel any redirection of the domains that have been entered there by Defendants 23- 

66 which redirect traffic to the counterfeit operations to a new domain name or website and 

thereby evade the provisions of this Order; 

(8) 

Each Defendant shal preserve copies of al computer files relating to the use of 

any of the Group 11 SubjectDomain Names and shal take a11 steps necessary to retrieve 

computer files relating to the use of the Group 1 Subject Domain Names that may have been 

deleted before the entry of this Order; 

15



261 

(9) Upon receipt of notice of this Order, Paypal, Inc. ($TayPa1') and its related 

companies and affiliates shal immediately freeze a1l funds, asopposed 

to ongoing accotmt 

activity, in or which hereafter are transmited into the Paypal accounts related to the Paypal 

account recipients: 

lusahali@gmail.com 

loliilol@hotmail.com 

services@pickyourwatch.com 

firstzshopping@yahoo.com 

artemeezbuy@gmail.com 

576445667@qq.c0m 

topserviceszolz@hotmail.com 

cwj8g@live.com 

lisamylifez@hotmail.com 

aomeitrade@live.com 

wmserviceoo3@gmail.com 

jianljiebbbb@l63.com 

paymehtshowtime@gmail.com 

jenshonggg@gmail.com 

yirlzhiling@lz6.com 

onlinesalenol@gmail.com 

tradeworldus@hotmail.com 

yuyongjun8o@l63.com 

35154064@qq.com 

shoplong77o@hotmail.com 

calinaywhite@gmail.com 

goodrisy@gmail.com 

paymentouk@gmail.com 

sairongservice@gmail.com 

globalonline4@gmail.com 

copperoilcn@gmail.com 

yuanhuachen@yeah.net 

huangcongl l6@gmail.com 

lifangligz@yahoo.com 

16



261 

hujiangg6@live.com 

chinawppay@qq.com 

vickygotbags@gmail.com 

4474hxl@gmai1.com 

countresgoo@hotmail.com 

mygoodjolmgol@hotmail.com 



messbupzk@hotmail.com 

beststorelg84@gmail.com 

shoppingnewlz@hotmail.com 

go-pay@hotmail.com 

credit-pay@hotmail.com 

topebay3zl@gmail.com 

solmanzcn@tom.com 

szwpayment@sina.com 

mzjiejun@hotmail.com 

as well as a1 f'unds in or which are transmited into (i) any other related accounts of the same 

customerts), (ii) any other accounts which transfer funds into the same financial institution 

accountts), and/or any of the other Paypal accounts subject to this Order; and (i) any other 

Paypal accounts tied to or used by any of the Group 1 Subject Domain Names identified on 

Schedule $1A ' hereto; 

(10) Upon receipt of notice of this Order, Paypal and its related companies and 

affiliates shal immediately freeze al1 f'unds, as opposed to ongoing accotmt activity, in or which 

hereafter are transmitted into Paypal accounts linked to, associated with, or that transmit funds 

into Defendants 23-665s identified bank accounts,g including but not limited to , the Bank of 

9 T h e ful account numbers have been redacted to avoid disclosure of private financial 

information, in compliance with Fed. R. Civ. P. 5.2(a)(4); however, the ful account numbers are 

identified on Plaintiff's Notice of Filing Reference List, filed under seal, which shal be disclosed 

to Paypal to effectuate the relief ordered herein.



261 

China Guang Dong Branch, Account Name, Cong Huang, Bank Account Number, 

***************3609; and Bank of China, Account Name, Lin Qinghua, Bank Account 

Number, ************ ***0705; and any other related accotmts of the same customers', 

(1 1) Paypal shal also immediately divert to a holding account for the tnzst of the Court 

al1 funds in a1 Paypal accounts related to the Paypal account recipients: 

lusahali@gmail.com 

loliilol@hotmail.com 

services@pickyounvatch.com 

firstzshopping@yahoo.com 

artemeezbuy@gmail.com 

576445667@qq.c0m 

topserviceszolz@hotmail.com 

cwj8g@live.com 

lisamylifez@hotmail.com 

aomeitrade@live.com 

wmserviceoo3@gmail.com 

jianljiebbbb@l63.com 

paymentshowtime@gmail.com 

jenshonggg@gmail.com 

yirlzhiling@lz6.com 

onlinesalenol@gmail.com 

tradeworldus@hotmail.com 

yuyongxiun8o@l63.com 

35154064@qq.com 

shoplong77o@hotmail.com 

calinaywhite@gmail.com 

goodrisy@gmail.com 

paymenttouk@gmail.com 

sairongservice@gmail.com 

globalonline4@gmail.com 

copperoilcn@gmail.com 

yuanhuachen@yeah.net 

18



261 

huangcongl l6@gmail.com 

lifangligz@yahoo.com 

hujiangg6@live.com 

chinawppay@qq.com 

vickygotbags@gmail.com 

4474hx1@gmail.com 

countresgoo@hotmail.com 

mygoodjohngol@hotmail.com 



messbuyuk@hotmail.com 

beststorelg84@gmail.com 

shoppingnewlz@hotmail.com 

go-pay@hotmail.com 

credit-pay@hotmail.com 

topebay3zl@gmail.com 

solmanzcn@tom.com 

szwpayment@sina.com 

mzjiejun@hotmail.com 

and any other related accounts of the same customerts), and/or al1 Paypal accounts lirlked to, 

associated with, or that transmit funds into Defendants 23-66's identified bank accounts to the 

Bank of China Guang Dong Branch, Account Name , Cong Huang, Bank Account Number, 

***************3609* and Bank of China, Account Name, Lin Qinghua, Bank Account 

Number, ***** #****** ***0705 and any other related accounts of the same customers as well 

as any other accounts which transfer funds into the same financial institution accounts) as any of 

the other Paypal accounts subject to this Order; 

(12) Paypal shall further, within five days of receiving this Order, provide Plaintiff s 

counsel with al data which details an accounting of the total funds frozen and identities the 

Paypal accountts) which the frozen funds are related too.Such freezing of the funds and the 

19



261 

disclosure of the related financial institution account information shall be made without notice to 

the account owners or the tinancial institutions until further order of this Court . Paypal shall 

receive and maintain this Order and its contents as confidential until further order of this Court; 

Upon receipt of notice of this Order, the operator of the Internet website existing 

under the domain name beltal.com (dBe1ta1') and its related companies and affiliates shal 

immediately freeze al ftmds, as opposed to ongoing account adivity, in or which hereafter are 

transmitted into the Paypal accotmts related to the Internet website operating tmder the domain 

name ecgoshopping.com and/or the Beltal member identified as Stenjoyshopping,' as wel as all 

funds in or which are transmitted into (i) any other related accounts of the snme customerts), (i) 

any other accounts which transfer funds into the snme tinancial institution accotmts), and/or any 

of the other Beltal accounts subject to this Order; and (ii) any other Beltal accounts tied to or 

used by any of the Group 11 Subjed Domain Names identitied on Schedule ICA' hereto; 

(14) Beltal shall also immediately divert to a holding account for the trust of the Court 

a11 funds in al Paypal accounts related to the Internet website operating under the domain nnme 

ecgoshopping.com and/or the member identified as tenjoyshopping,' and any other related 

accounts of the same customers as wel as any other accounts which transfer funds into the same 

financial institution accountts) as any of the other Beltal accounts subject to this Order; 

(15) Beltal shal further, within five days of receiving this Order, provide Plaintiff s 

counsel with a1l data which details an accounting of the total funds frozen and identifies the 

Paypal accountts) which the frozen funds are related too. Such freezing of the ftmds and the 

disclosure of the related financial institution account information shal be made without notice to 

the account owners or the tinancial institutions until further order of this Court. Beltal shall 

receive and maintain this Order and its contents as confidential until further order of this Court; 

20



261 

(16) This Second Temporary Restraining Order shall remain in efect tmtil the date for 

the hearing on the Motion for Preliminary lnjunction set forth below, or until such further dates 

as set by the Court or stipulated to by the parties; 

Pursuant to 15 U.S.C. j 1 1 16(d)(5)(D),Plaintiff shal maintain its previously 

posted bond in the amount of Ten Thousand Dolars and Zero Cents ($10,000.00), as payment of 

dnmages to which Defendants 23-66 may be entitled for a wrongful injunction or restraint, 

during the pendency of this action, or until further Order of the Court. In the Court's discretion, 

the bond may be subject to increase should the amotmt of the f'unds seized exceed $10,000.00; 

(18) A hearing is set before this Court in the United States Courthouse located at 400 

North Miami Avenue, Miami, Florida 33128, Courtroom 1 1-4, on September 18. 2012 at 9:00 

a.m., or at such other time that this Court deems appropriate, at which time Defendants 23-66 

and/or any other affected persons may challenge the appropriateness of this Order and move to 

dissolve the same and at which time the Court wil hear argtzment on Plaintiff s requested 

preliminary injunction; 

(19) Plaintif shall serve a copy of the First Amended Complaint, the Second 

Application for Temporary Restraining Order, this Order, and a1 other pleadings and doclments 

on file in this action on each Defendant via the corresponding e-mail addresses provided by 

Defendants 23-66 (i) as part of the domain registration data for each of their respective domain 

names, or (i) on their Internet websites, and the customer service e-mail addresses used to 

commtmicate with Plaintifps investigator, al of which are identitied on Schedule $tB' hereto. ln 

addition, Plaintiff shal post a copy of the First Amended Complaint, the Second Application for 

Temporary Restraining Order, and this Order, as well as a1 other documents filed in this action 

on the website located at htp://seNingnotice.com/omc/index.html, within forty-eight (48) hours 

21



261 

of control of the Group 11 Subject Domain Names being changes to the Court via the New 

Registrar's holding account , and such notice so given shall be deemed good and sufficient 

service thereof. Plaintiff shall continue to provide notice of these proceedings and copies of the 

documents on file in this mater to Defendants 23-66 by regularly updating the website located at 

htp://servingnotice.coeom#index.html or by other means reasonably calculated to give notice 

which is permitted by the Court. 

(20) Any response or opposition to Plaintifps Motion for Preliminary Injunction 

must be tiled and served on Plaintiffs counsel within forty-eight (48) hours prior to the hearing 

set for September 18, 2012 at 9 a.m. and must be tiled with the Court , along with Proof of 

Service bv September 14. 2012 at 9 a .m. Plaintiff shal file any Reply M emorandum on or 

before September 17, 2012. The above dates may be revised upon stipulation by al parties and 

approval of this Court. Defendants 23-66 are hereby on notice that failure to appear at the 

hearing may result in the imposition of a preliminary injunction against them pursuant to 

15 U.S.C. j 1116(d), Fed. R. Civ. P. 65, and this Court's inherent authority . 

DONE AND ORDERED in in Miami , Florida, this day of UV 2012 at 

#* yx . 

:.-344. -. 

CC* All Counsel of Record 

l 

PATRI IA A. T 

UNITED STA ES DISTRICT JUDGE 

22



261 

SCHEDULE KiA ' 

DEFENDANTS BY NUM BER AND GROUP 11 SUBJECT DOM AIN NAM ES 

Defendant Number Defendant / Subject Domain Name 

Defendant 23 zolzchanelbagstore.com 

Defendant 23 buychanel4u.com 

Defendant 23 buyluxurychanel.com 

Defendant 23 chanelbags4u.org 

Defendant 23 chanelbagstyle.com 

Defendant 23 chanelbagsus.org 

Defendant 23 chanelbubblebags.com 

Defendant 23 chanelhandbagsstyles.com 

Defendant 23 chanelhobobags.com 

Defendant 23 luxurychanelzu.com 

Defendant 23 luxuriouschanel.com 

Defendant 23 luxurychaneler.com 

Defendant 24 artemee.com 

Defendant 25 bagsstores.net 

Defendant 26 bestchanelzu.com 

Defendant 27 bykicks.com 

Defendant 27 bykicks.net 

Defendant 28 chanel-2012.org 

Defendant 28 chanelbagsales.org 

Defendant 28 chanel-bags-sale.org 

Defendant 28 chanelbagssaleonline.org 

Defendant 28 chanelbagssales.org 

Defendant 28 chanel-handbags-zolz.com 

Defendant 28 chanel-outlet-online.org 

Defendant 28 cheapchaneloutlet.org 

Defendant 28 cheapchanelsale.org 

Defendant 29 chanelzolzbags.com 

Defendant 29 chanelahandbagszolz.com 

Defendant 30 chanelauthenticbag.com 

Defendant 3 1 chanelbagssaks.com 

23



261 

Defendant 32 chanelbags-sale.net 

Defendant 32 thechanelbags.net 

Defendant 33 chanelbagsstores.net 

Defendant 34 chanelbagstrade.com 

Defendant 35 chanelbagswaletsus.com 

Defendant 35 chanelhandbagswaletsus.net 

Dtftndant 36 chantlchtapstort.com 

Defendant 37 chanel-com.net 

Defendant 38 chanel-factory-online.com 

Defendant 38 chanelfactoryoutlet.com 

Defendant 38 chanel-factory-outlet-online.com 

Defendant 38 chanel-factory-store.com 

Defendant 38 chrel-factory-store-online.com 

Defendant 38 chu el-handbags-u ockoffs.com 

Defendant 38 chanel-outlet-coupons.com 

Defendant 38 chanel-outlet-online-zolz.com 

Defendant 38 chanel-purses-replica .com 

Defendant 38 china-chrel-outlet-online,com 

Defendant 38 chinesereplicahandbags.com 

Defendant 38 fake-chanel-bags.com 

Defendant 38 fashionlinebags.com 

Defendant 38 replica-chrel-hrdbags-zolz.com 

Defendant 39 chaneltlats.biz 

Defendant 39 sacchanelzolz.com 

Defendant 40 chanelhandbagszolz.net 

Defendant 40 chanelsandalshoes.com 

Defendant 40 jpchanelbags.com 

Defendant 40 jpchanelshop.com 

Defendant 40 bolsoschanelprecios.com 

Defendant 41 chrelhandbagsbagsonline.biz 

Defendant 41 chanelhandbagsstores.co.uk 

Defendant 42 chanelhandbagsstores.com 

Defendant 43 chaneloutlet4sale.com 

24



261 

Defendant 43 chaneloutlet4sales .com 

Defendant 44 chaneloutletonlineshops.com 

Defendant 45 cheapchanelin.com 

Defendant 46 cheapchanelonlineshopping .com 

Defendant 46 cheapchanelshopping .com 

Defendant 46 chanelpearlnecklace .com 

Defendant 46 vintagechanelonline.com 

Defendant 47 cheapstorestradezolz .com 

Defendant 47 cheapstorestradezu .com 

Defendant 48 chinchin.org 

Defendant 49 classic-shopping .com 

Defendant 49 classic255 .com 

Defendant 50 ecgoshopping.com 

Defendant 51 enjoyreplica.com 

Defendant 52 eootop .com 

Defendant 53 etradeshoes.com 

Defendant 54 fakechanelbagss .com 

Defendant 54 okreplicachanel .com 

Defendant 55 fakechanelhandbags.co.uk 

Defendant 56 falinzfashion.com 

Defendant 57 louisvuitton-outlet-online .net 

Defendant 58 luxebagsale.com 

Defendant 59 mac-make-online .org 

Defendant 59 macmakeu-p ,com 

Defendant 60 manoloblahnikwedding.org 

Defendant 61 pickyourwatch.com 

Defendant 62 replicaolbags.com 

Defendant 63 replicaschanel .biz 

Defendant 63 replicas-chanel.com 

Defendant 64 solomonleather.com 

Defendant 65 szwear.com 

Defendant 66 wholesale-lv-hennes .com 

25



261 

SCHEDULE içB' 

DEFENDANT PARTNERSHIPS OR UNINCORPORATED ASSOCIATIONS 

BY SUBJECT DOMAIN NAME AND ASSOCIATED E-M AIL ADDRESSES 

N 

umber 

Defendant / 

Subject 

Domain Name 

E-M ail Addresses 

23 zolzchanelbagstore .com luxuryhandbag4u@gmail.com 

vocutqt zkugwhoisservices.cn 

buychanel4u .com luxuryhandbag4u@gmail.com 

allensel@hotmail.com 

23 buyluxurychanel .com whokeyone@gmail.com 

allensell@hotmail.com 

23 chanelbags4u .org 

adidasbones@gmail.com 

ajensejghotmail 

.com 

23 chanelbagstyle.com bbzmqewqqu@whoisservices.cn 

23 chanelbagsus .org luxuryhandbag4u@gmail.com 

jejasejlghotmail.com 

23 chanelbubblebags .com 

luxuryhandbag4u@gmail.com 

mzgp j) wyqdkgwhoisservices 

.cn 

23 chanelhandbagsstyles.com dmgvkyairf@whoisservices.cn 

23 chanelhobobags.com jhgqqnzmrg@whoisservices.cn 

23 luxurychanelzu.com alensell@hotmail.com 

luxuriouschanel .com luxuryhandbag4u@gmail.com 

alensel@hotmail.com 

23 luxurychaneller .com ltlxuryhandbag4u@gmail.com 

jjeysejjgjyotmail.com 

artemee .com 

a 

a 

Artemeezbuy@gmail.com 

victorzwc@qq.com 

longhrshengsale@hotmail.com 

25 bagsstores .net d omain@whoisprotectionse>ice.org 

26 bestchanelzu.com 1367228225@qq.c0m 

bykicks .com 

bykicks zhu@hotmail.com 

buy4u@bykicks.com - 

27 bykicks .net bbykicks -zhu@hotmail.com 

uy4u@bykicks.net 

28 chanel-2012.org murrilltaka@hotmail.com 

28 chanelbagsales.org murilltaka@hotmail.com 

26



261 

28 chanel-bags -sale.org davidtradezo jjt lz@hotmail.com 

muu akaghotmail.com 

28 chanelbagssaleonline .org davidtradezolz@hotmail.com 

adtyqq.oom 

varmoecom 

28 chanelbagssales.org muniltaka@hotmail.com 

28 chanel-handbags-zolz.com murrilltaka@hotmail.com 

28 chanel-outlet-online.org davidtradezolz@hotmail.com jjt 

muU akaljwtmail.com 

28 cheapchaneloutlet.org murrilltaka@hotmail.com 

28 cheapchanelsale .org Davidtradezolz@hotmail.com 

murriltaka@hotmail.com 

29 chanelzolzbags.com 10780275@qq.com 

29 chanelahandbagszolz.com beatsbydrdreheadphonessale@gmail.com 

30 chanelauthenticbag.com yangmengliang@msn.com 

31 chanelbagssaks .com 

salesdepartmentoz@gmail.com 

supras jj oesaugjwtmail.com 

32 chanelbags-sale.net 

chrelbagsseaice@hotmail.com 

( 

jiabeizhenxi@gmail .com 

32 thechanelbags.net jiabeizhenxi@gmail.com 

33 chanelbagsstores.net sairongservice@gmail.com 

34 chanelbagstrade.com kujdyh@sina.com 

35 chanelbagswaletsus.com honestworldss@l63.com 

35 chanelhandbagswaletsus.net honestworldsus@gmail.com 

chrelcheapstore@chrelcheapstore.com 

36 chanelcheapstore.com cheapfinereplica@gmail.com 

yuyongjun8o@l63.com 

37 chanel-com.net 35154064@qq.com .' 

38 chanel-factory- online.com longge63gl@hotmail.com yyjjygygytyqq.oom ) 

38 chanelfactoryoutlet .com 

longge63gl@hotmail.com 

domain@whoisprotectionse>ice.org 

) 

, 

38 chuel -factory-outlet-online.com 


J 

365138484@qq è 

.c0m . 

l ) 

38 chanel-factory- ongge63gl@hotmail.com ) 

store.com y 

365138484@qq .c0m 

.J 

27 F 

t. 

) 

) 

)



261 


38 chanel-factory-store-online .com 365138484@qq.c0m 

38 chanel-hrdbags-uockoffs .com 


944598882@qq .c0m 

38 chanel-outlet-coupons .com 


944598882@qq .c0m 

38 chrel-outlet-online -zolz.com longge63gl@hotmail.com 

365138484@qq.c0m 


38 chanel-purses-replica .com 944598882@qq.c0m 

38 ehina-chanel-outlet-online .com 944598882@qq.c0m 

38 chinesereplicahandbags .com 

chinesebags@l63.com 

365jggyyzjtyqq 

.oom 

38 fake-chanel-bags.com 944598882@qq.c0m 

fashionlinebags@hotmail.com 

38 fashionlinebags.com longge63gl@hotmail.com 

944598882@qq.c0m 

38 

replica-chanel-handbags- 

2012 .com 

944598882@qq.c0m 

chanelflats .biz service@chaneltlats.biz 

chanelflatsbiz@lz6.com 

39 sacchanelzolz.com sacchane12012com@126.com 

40 chanelhandbagszolz.net chanel bags2012net@126.com 

40 chanelsandalshoes.com chanelsandalshoes@gmail.com 

40 jpchanelbags.com jpchanelbagscom@lz6.com 

40 jpohanelshop.com jpchanelshopcom@lz6.com 

40 bolsoschanelprecios.com bolsos -precioscom@lz6.com 

41 chanelhrdbagsbagsonline .biz laupayment@gmail.com 

41 chanelhandbagsstores.co.uk handbagsuk.online@gmail.com 

42 chanelhandbagsstores .com yinzhiling@lz6.com 

43 chaneloutlet4sale.com mkorsoutlet@gmail.com 

43 chaneloutlet4sales.com xmyoyo@hotmail.com 

44 chaneloutletonlineshops .com 

sewice@chaneloutletonlineshops.com 

609006012@qq .com 

chanelstock@gmail.com 

45 cheapchanelin .com jerixyr@hotmail.com 

28



261 

46 cheapchanelonlineshopping.com toziyntj@yahoo.com 

46 cheapchanelshopping.com dewonehev@yahoo.com 

46 chanelpearlnecklace.com milbsjwse@yahoo.com 

46 vintagechanelonline.com lceaktze@yahoo.com 

47 cheapstorestradezolz.com rqb@dingdian.cn 

47 cheapstorestradezu .com 

ouyatrade@yahoo.com 

ldd@dingdian .cn 

48 chinchin .org chinchin sales@chinchin.org 

.org@domainsproxy.org 

49 classic-shopping.com websoso@lz6.com 

49 c1assic255.com kooserzolo@gmail.com 

ecgoshopping@gmail.com 

ecgoshopping .com 

5 1 enjoyreplica.com 

ecgoshopping@hotmail.com 

ecgoshopping@ymail.com 

928661548@qq.c0m 

enjoyreplica@gmail.com 

bhcpv5c4l48ddebb4ad@t02cduv4D99K55f64.privatewhois.net 

xmjo4a4s4gddeb9d5d@t02cduv4599r55f64.privatewhois.net 

sr6rsf64%48ddebc481@t02cduv4S99r55f64.pr'1vatewhois.net 

52 eootop.com 1 127951313@qq.com 

etradeshoes .com 

shoesbagsmall@hotmail.com 

dsfsdfadtz34@qq .com 

54 fakechanelbagss.com onlinelily3s@gmail.com 

54 okzeplicachanel.com onlinelily3s@gmail.com 

55 fakechanelhandbags.co.uk hahabags@xustore.com 

56 fallinzfashion .com fallinfashionz@gmail.com 

jess ag6tyj6g.oom 

57 louisvuilon-outlet-online.net eckjnl@yeah.net 

58 luxebagsale .com 

bagsvendor@yahoo.com 

bagsvendor@gmail .com 

59 mac-make-online.org 80864321@qq.com 

59 macmakeu-p.com 80864321@qq.com 

60 manoloblahnikwedding .org mroloblahnikwedding@hotmail.com 

njeniwggmail.com 

61 pickyourwatch.com proxy18601 l7@lrdl-private-registration.com 

62 replicaolbags.com hudbags-shaping@hotmail.com 

29



261 

63 replicaschanel .biz replicachanelsale@gmail.com 

goodl 111 1@163.com 

63 replicas-chanel.com goodll 1 1@163.com 

64 solomonleather .com solomonleather@gmail.com 

solmanzcn@gmail.com 

65 szwear .com 

support@szwear.com 

1 149234307@qq .c0m 

66 wholesale-lv-hermes .com 

lucky.lin68@gmail.com 

serv j ce g yeskey 

.com .cn 

30

Case 1:12-cv-23061-JAL Document 10 Entered on FLSD Docket 08/24/2012 Page 1 of 32 


261 



CASE NO. 12-23061-CIV-LENARD 

GUCCI AMERICA, INC., a New York corporation, 

vs. 

Plaintiff, 

CHEAPGUCCIHANDBAGSUSAOUTLET.COM, 

et al., 

Defendants. 

ORDER GRANTING PLAINTIFF’S EX PARTE MOTION 

FOR TEMPORARY RESTRAINING ORDER 

THIS CAUSE is before the Court on Plaintiff, Gucci America, Inc., (“Gucci”)’s Ex Parte 

Application for Entry of Temporary Restraining Order, Preliminary Injunction, and Order 

Restraining Transfer of Assets Tied to the Counterfeiting Operation (the “Ex Parte Application 

for TRO”) [ECF No. 6]. The Ex Parte Application for TRO asks the Court to issue a temporary 

restraining order and an order restraining the financial accounts used by Defendants, pursuant to 

15 U.S.C. § 1116 and Fed. R. Civ. P. 65, and then a preliminary injunction against various 

partnerships or unincorporated associations who operate the websites that infringe Gucci’s 

trademarks and that promote and sell counterfeit Gucci goods. Among other things, Gucci asks 

that the Court enjoin Defendants from producing or selling goods which infringe its trademarks, and 

that the Court seize control of the domain names of the infringing websites and redirect the web 

traffic searching for those domains to another site that displays a copy of the pleadings from 

this case. The Court has carefully considered the Ex Parte Application for TRO and pertinent 

portions of the record. 

/



261 

I. PROCEDURAL BACKGROUND 

Plaintiff, Gucci, is suing the Partnerships Or Unincorporated Associations identified on 

Schedule “A” hereto and Does 1-10 (collectively “Defendants”) and their various unknown 

associates for trademark counterfeiting and infringement; false designation of origin under 

section 43(a) of the Lanham Act, 15 U.S.C. §1125(a); and cybersquatting under 15 U.S.C. 

§1125(d). Gucci’s Complaint [ECF No. 1] alleges Defendants are promoting, advertising, 

distributing, offering for sale and selling counterfeit and infringing Gucci branded products 

within the Southern District of Florida through fully interactive commercial Internet websites 

operating under certain domain names (the “Subject Domain Names”). 1 

Gucci alleges Defendants’ unlawful activities have caused and will continue to cause 

irreparable injury to Gucci because Defendants have (1) deprived Gucci of its right to determine 

the manner in which Gucci’s trademarks are presented to the public through merchandising; (2) 

defrauded the public into thinking Defendants’ goods are authorized Gucci goods; (3) deceived 

the public as to Gucci’s association with Defendants’ goods and the websites which market and 

sell the goods; and (4) wrongfully traded and capitalized on Gucci’s reputation and goodwill as 

well as the commercial value of Gucci’s trademarks. 

In the Ex Parte Application for TRO, Gucci moves for the issuance of a temporary 

restraining order and an order restraining the financial accounts used by Defendants, and, upon 

expiration of the temporary restraining order, a preliminary injunction against Defendants, 

pursuant to 15 U.S.C. § 1116 and Federal Rule of Civil Procedure 65, for alleged violations of 

the Lanham Act. 

1 The complete list of websites includes forty-six domain names. For a complete list, see Schedule A of this Order. 

2



261 

II. FACTUAL BACKGROUND 2 

Gucci is a corporation duly organized under the laws of the State of New York with its 

principal place of business in the United States located at 685 Fifth Avenue, New York, New 

York 10022. (See Declaration of Nicole Marra in Support of Plaintiff’s Application for TRO 

[“Marra Decl.”] 2.) Gucci manufactures, promotes, distributes, and sells in interstate 

commerce, including within this Judicial District, high quality products under a number of 

Gucci’s trademarks. (See Marra Decl. 3.) 

Gucci is the registered owner of the following trademarks on the Principal Register of the 

United States Patent and Trademark Office, all of which are valid and all but three of which 

incontestable pursuant to 15 U.S.C. § 1065 3 (collectively, the “Gucci Marks”): 

Trademark 

Registration 

Number 

GUCCI 0,876,292 

Registration 

Date 

September 9, 

1969 

3 

Class / Goods 

IC 018 - pocketbooks, wallets, travel 

and duffel bags, attache cases, toilet 

cases sold empty, shoe bags, and 

umbrellas. 

IC 021 - vacuum bottles, compacts sold 

empty, and vanity cases sold empty. 

IC 025 – shoes and boots. 

GUCCI 0,959,338 May 22, 1973 IC 014 - watches. 

1,106,722 

November 21, 

1978 

IC 025 - neckties, scarves, belts, 

footwear, shirts, sweaters, coats, suits, 

and bathing suits 

2 The factual background is taken from the Ex Parte Application for TRO, and supporting Declarations submitted 

by Gucci. 

3 Trademark Registrations Numbers 3,376,129, 3,378,755, and 3,391,739 are not incontestable.



261 

Trademark 

(Green Red Green 

Stripe Design) 

Registration 

Number 

1,107,311 

GUCCI 1,168,477 

(Green Red Green 

Stripe Design) 

Registration 

Date 

November 28, 

1978 

1,122,780 July 24, 1979 

September 8, 

1981 

1,483,526 April 5, 1988 IC 025 – footwear 

GUCCI 1,340,599 June 11, 1985 

3,039,629 

January 10, 

2006 

3,072,549 March 28, 2006 

4 

Class / Goods 

IC 018 - wallets, purses, handbags, 

shoulder bags, clutch bags, tote bags, 

card cases, partly and wholly of leather, 

key cases, passport cases, cosmetic 

cases, attaché cases, valises, suitcases, 

and duffles. 



card cases, attaché cases, valises, 

suitcases, duffles, and key cases. 

IC 025 - neckties; scarves; belts; 

footwear; shirts; sweaters; coats; suits; 

dressing gowns; hats; socks; dresses, 

and bathing suits. 

IC 014 - jewelry- namely, earrings, 

collar bars and tie bars made wholly or 

in part of precious metal. 

IC 025 - footwear and belts. 



business card cases, credit card cases, 

partly and wholly of leather, key cases, 

cosmetic cases sold empty, briefcases, 

attaché cases, valises, suitcases, and 

duffles.



261 

Trademark 

Registration 

Number 

3,376,129 

3,378,755 

Registration 

Date 

January 29, 

2008 

February 5, 

2008 

5 

Class / Goods 

IC 006 - key rings made of metal, metal 

key rings covered in leather, and metal 

key rings partially covered with enamel. 







duffles. 

IC 009 - eyeglass frames and sunglasses. 

IC 014 - jewelry, watches, and clocks. 

IC 016 - address books, agendas, 

notebooks, stationary in the form of 

writing paper, and pens. 







duffles. 

IC 025 - scarves, belts, footwear, shirts, 

sweaters, coats, suits, dressing gowns, 

and dresses 

3,391,739 March 4, 2008 IC 009 - eyeglass frames and sunglasses. 

The Gucci Marks are used in connection with the manufacture and distribution of quality 

goods in the categories identified above. (See Marra Decl. 5; see also United States Trademark 

Registrations of the Gucci Marks at issue [“Gucci Trademark Registrations”] attached as 

Composite Exhibit A to the Marra Decl.)



261 

Gucci retained AED Investigations, Inc., a licensed private investigative firm, and 

Investigative Consultants, a licensed private investigative firm, to investigate the sale of 

counterfeit versions of Gucci’s products by Defendants. (See Marra Decl. 10-12; Declaration 

of Eric Rosaler in Support of Plaintiff’s Application for TRO [“Rosaler Decl.”] 3; Declaration 

of Joey Alvarez in Support of Plaintiff’s Application for TRO [“Alvarez Decl.”] 3.) Eric 

Rosaler (“Rosaler”), an officer of AED Investigations, Inc., placed an order for the purchase of 

(i) a belt bearing the Gucci Marks at issue via the Internet website operating under the domain 

name, cheapguccihandbagsusaoutlet.com; and (ii) a handbag bearing the Gucci Marks at issue 

via the Internet website operating under the domain name, luxuryhandbagsreplicas.net, and 

requested each product purchased be shipped to one of his addresses in Florida. (See Rosaler 

Decl. 4, 6 and Composite Exhibits A and C thereto.) Rosaler finalized payment for the Gucci 

branded belt purchased through cheapguccihandbagsusaoutlet.com via PayPal, Inc. (“PayPal”) 

to the PayPal account identified as, naiguangsell@hotmail.com, and received a receipt for his 

payment providing the transaction identification number, 03M896370C488383B. (See Rosaler 

Decl. 4 and Composite Exhibit A thereto.) Rosaler finalized payment for the Gucci branded 

handbag purchased through luxuryhandbagsreplicas.net via PayPal to the PayPal account 

identified as, thebusinesspay@gmail.com, and received a receipt for his payment providing the 

transaction identification number, 5B999961BY572094W. (See Rosaler Decl. 6 and 

Composite Exhibit C thereto.) Moreover, Rosaler went through another purchasing process via 

the luxuryhandbagsreplicas.net online store, and he received different PayPal information for 

finalizing the payment process, identifying the PayPal account, happybagspay@gmail.com. (See 

id. at 8 and Ex. E thereto.) Each of Rosaler’s purchases was processed entirely online, and he 

6



261 

received confirmation of his purchases via e-mail. (See Rosaler Decl. 4, 6 and Composite 

Exhibits A and C thereto.) 

Rosaler also accessed Defendants’ Internet websites operating under the Subject Domain 

Names: aaashoestrade.com, brands-b2bstore.com, buyshopchina.com, buytop-bag.com, 

cheapbeltoutlet.com, chinashoesclothes.net, chogorius.com, clothingshoeschina.net, disbags.com, 

grandbuying.com, guccioutletauthentication.com, guccireplicabelts.com, iokbags.com, 

perfectxclones.com, picktopaaa.net, qiqimalls.com, qqfashiontrade.com, replicacchanel.com, 

replicaconvener.com, replica-watches-onsales.com, samegucci.com, soeasybuy.com, 

sunglasseshutflagship.org, thesneakerspoint.com, thewatchau.com, watches-seller.com, 

watchessss.com, watchghy.com, watchww.com, and yannatrade.com, and went through the 

purchasing process for various products bearing counterfeits of, at least, one of the Gucci Marks 

at issue in this action. 4 (See Rosaler Decl. 9-44.) Rosaler communicated with Defendants 

electronically via e-mail and/or on-site contact page and received information for finalizing 

payment for each of the Gucci-branded items ordered via PayPal and/or bank transfer to 

Defendants’ respective PayPal and/or bank accounts, as follows: 

Subject Domain Name Payment Method Account 5 

aaashoestrade.com Bank Transfer 

7 

Zheng Wen Zong 

China Bank 

Bank Account Number **** **** 

**** ***1 876 

4 Rosaler intentionally did not finalize his purchases from aaashoestrade.com, brands-b2bstore.com, 

buyshopchina.com, buytop-bag.com, cheapbeltoutlet.com, chinashoesclothes.net, chogorius.com, 

clothingshoeschina.net, disbags.com, grandbuying.com, guccioutletauthentication.com, guccireplicabelts.com, 

iokbags.com, perfectxclones.com, picktopaaa.net, qiqimalls.com, qqfashiontrade.com, replicacchanel.com, 

replicaconvener.com, replica-watches-onsales.com, samegucci.com, soeasybuy.com, sunglasseshutflagship.org, 

thesneakerspoint.com, thewatchau.com, watches-seller.com, watchessss.com, watchghy.com, watchww.com, and 

yannatrade.com so as to avoid contributing funds to the Defendants’ coffers. 

5 The full account numbers of all financial institution accounts identified herein have been redacted to avoid 

disclosure of private financial information, in compliance with Fed. R. Civ. P. 5.2(a)(4).



261 


brands-b2bstore.com 6 PayPal fightinglife2013@gmail.com 

buyshopchina.com PayPal sinehuo@yahoo.com.cn 

buytop-bag.com Bank Transfer 7 

8 

Shi Ping Fang 

Bank of China, Guangzhou ZhuDao 

Garden Sub Branch 

Bank Account Number 

**************8076 

Swift Code: BKCHCNBJ400 

cheapbeltoutlet.com PayPal lilychenshop@yahoo.com 

chinashoesclothes.net PayPal 8 fuinanliu@gmail.com 

chogorius.com PayPal 9 

clothingshoeschina.net Bank Transfer 

wuheyo@gmail.com 

Lzhh613846@gmail.com 

Huang Yanfei 

Bank of China 

Card Number ********7337 

Swift Code: BKCHCNBJ73C 

disbags.com PayPal disbags@hotmail.com 

grandbuying.com Bank Transfer 

Huang Jing Shun 

Bank of China Guangzhou Baiyun 

Sub Branch 

Bank Account Number ***** **** 

**** ***0 077 


guccioutletauthentication.com PayPal 10 deallucky2012@yahoo.com 

guccireplicabelts.com PayPal mariahleopold@gmail.com 

6 The website operating under the domain name, brands-b2bstore.com, self identifies as designerhandbagsusd.com. 

7 Rosaler received identical bank transfer information following the purchasing process via vip-handbag.org, which 

Defendant buytop-bag.com uses as an alias. (See Rosaler Decl. 13.) 

8 Rosaler received identical PayPal account information following the purchasing process via jumpmanlocker.org, 

which Defendant chinashoesclothes.net uses as an alias. (See Rosaler Decl. 16.) 

9 Rosaler went through two separate purchasing processes via the chogorius.com online store. Following the 

submission of his first order, Rosaler was instructed to effect payment the PayPal account, wuheyo@gmail.com. 

Following the submission of his second order, Rosaler was instructed to effect payment the PayPal account, 

Lzhh613846@gmail.com. (See Rosaler Decl. 17.) 

10 

Rosaler received identical PayPal account information following the purchasing process via 

guccioutletfranchise.com, which Defendant guccioutletauthentication.com uses as an alias. (See Rosaler Decl. 22.)



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iokbags.com Bank Transfer 

9 

JianXiong Li 

Bank of China 

Bank Account Number *** **** 

**** **** 2259 

Swift Code: BKCHCNBJ73C 

perfectxclones.com PayPal zhenshangle@gmail.com 

picktopaaa.net PayPal kejie1986@hotmail.com 

qiqimalls.com PayPal jinying2594@hotmail.com 

qqfashiontrade.com PayPal newfashiontrade@qq.com 

replicacchanel.com PayPal zhangshunliag89@gmail.com 

replicaconvener.com PayPal convener88@gmail.com 

replica-watches-onsales.com PayPal jojo198835@hotmail.com 

samegucci.com PayPal 11 

gongliwu168@gmail.com 

xiaosaxiaosa914@163.com 

soeasybuy.com PayPal cc888dang@live.com 

sunglasseshutflagship.org PayPal 12 serviceisgood@hotmail.com 

thesneakerspoint.com PayPal trey4niter@hotmail.com 

thewatchau.com Bank Transfer 

Cai Zhou Qing 

Bank of China, Fujian Branch 

Bank Account Number 

***************9046 


watches-seller.com PayPal karenosborn@163.com 

watchessss.com PayPal jialigoodluck3344@gmail.com 

watchghy.com PayPal live-aaa@live.com 

watchww.com PayPal zhilinyang13@gmail.com 

11 The “Order Confirmation” page of the samegucci.com website identified the PayPal account, 

gongliwu168@gmail.com. However, following the submission of his order, Rosaler received the PayPal 

information for finalizing the payment process identifying the PayPal account, xiaosaxiaosa914@163.com. (See 

Rosaler Decl. 32.) Additionally, Rosaler received identical PayPal account information following the purchasing 

process via samegucci.org, which Defendant samegucci.com uses as an alias. (See id. at 33.) 

12 

Rosaler received identical PayPal account information following the purchasing process via 

sunglassesflagshipstore.com, which Defendant sunglasseshutflagship.org uses as an alias. (See Rosaler Decl. 36.)



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yannatrade.com Bank Transfer 

10 

Liu XiangJiang 

Bank of China Guangzhou Huan Shi 

Xi Road Sub Branch 

Bank Account Number *******- 

****-***921-9 

Swift Code: BKCHCN BJ400 

Furthermore, Joey Alvarez (“Alvarez”), an employee of Investigative Consultants, 

accessed the Internet website operating under the Subject Domain Name, handbagscn.com, and 

went through the purchasing process for a product bearing counterfeits of, at least, one of the 

Gucci Marks at issue in this action. 13 Alvarez likewise communicated with Defendants 

electronically via e-mail and received information for finalizing payment for the Gucci-branded 

item ordered via PayPal to the PayPal account, htl168998@163.com. (See Alvarez Decl. 4.) 

Subsequently, Rosaler received a package containing the Gucci branded belt purchased 

via cheapguccihandbagsusaoutlet.com, which was sent to his North Miami Beach address via 

Express Mail Service (“EMS”). (See Rosaler Decl. 5 and Comp. Ex. B thereto.) Moreover, 

Rosaler received a package containing the Gucci branded handbag purchased via 

luxuryhandbagsreplicas.net, which was sent to his Aventura address via EMS. (See Rosaler 

Decl. 7 and Comp. Ex. C thereto.) 

Thereafter, a representative of Gucci, Nicole Marra (“Marra”), reviewed the Gucci 

branded belt Rosaler purchased and received via cheapguccihandbagsusaoutlet.com and the 

Gucci branded handbag Rosaler purchased and received via luxuryhandbagsreplicas.net, together 

with the respective detailed web page listings and images, and determined both products to be 

non-genuine, unauthorized Gucci products. (Marra Decl. 11-12, 15.) Marra also reviewed 

and visually inspected the items bearing the Gucci Marks offered for sale via the Internet 

13 Alvarez intentionally did not finalize his purchase from handbagscn.com so as to avoid contributing additional 

funds to the Defendants’ coffers.



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websites operating under the Subject Domain Names and determined the products were 

unauthorized, non-genuine versions of Gucci’s products. (See Marra Decl. 13, 15.) 

Based on the investigations, Gucci alleges Defendants have advertised, offered for sale, 

and/or sold handbags, wallets, watches, belts, shoes, hats, jewelry, and sunglasses bearing 

counterfeits, reproductions, and/or colorable imitations of the Gucci Marks. (See Marra Decl. 

11-15; Rosaler Decl. 4-44 and Composite Exhibits A through D attached thereto; Alvarez 

Decl. 4; Gaffigan Decl. 2-3 and Composite Exhibit B attached thereto; see also relevant 

web pages from Defendants’ Internet websites operating under the Subject Domain Names 

[“Defendants’ Websites”] attached as Composite Exhibit A to the Gaffigan Decl.) Defendants 

are not now, nor have they ever been authorized or licensed to use, reproduce, or make 

counterfeits, reproductions, and/or colorable imitations of the Gucci Marks. (See Marra Decl. 

9, 12-15.) 

III. LEGAL STANDARD 

Gucci has filed claims pursuant to 15 U.S.C. §§ 1114(1)(a), 1125(a), and 1125(d). Title 

15 U.S.C. section 1116(a) provides the Court “shall have power to grant injunctions, according 

to the principles of equity and upon such terms as the court may deem reasonable, to prevent the 

violation of any right of the registrant of a mark registered in the Patent and Trademark Office or 

to prevent a violation under subsection (a), (c), or (d) of section 1125 of this title.” 15 U.S.C. § 

1116. Injunctive relief is also available under section 1116(a) for a violation of section 

1114(1)(a). See 15 U.S.C. § 1116(d)(1)(A). 

In order to obtain a temporary restraining order, a party must demonstrate “(1) [there is] a 

substantial likelihood of success on the merits; (2) that irreparable injury will be suffered if the 

relief is not granted; (3) that the threatened injury outweighs the harm the relief would inflict on 

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the non- movant; and (4) that the entry of the relief would serve the public interest.” Schiavo ex. 

rel Schindler v. Schiavo, 403 F.3d 1223, 1225–26 (11th Cir. 2005); see also Levi Strauss & Co. v. 

Sunrise Int’l. Trading Inc., 51 F. 3d 982, 985 (11th Cir. 1995) (applying the test to a preliminary 

injunction in a Lanham Act case). Additionally, a court may only issue a temporary restraining 

order without notice to the adverse party or its attorney if: 

(A) specific facts in an affidavit or a verified complaint clearly show that immediate and 

irreparable injury, loss, or damage will result to the movant before the adverse party or 

can be heard in opposition [and] (B) the movant’s attorney certifies in writing any 

efforts made to give notice and the reasons why it should not be required. 

FED. R. CIV. P. 65(b). Ex parte temporary restraining orders “should be restricted to serving their 

underlying purpose of preserving the status quo and preventing irreparable harm just so long as 

is necessary to hold a hearing and no longer.” Granny Goose Foods, Inc. v. Bhd. of Teamsters & 

Auto Truck Drivers Local No. 70 of Alameida Cnty, etc., 415 U.S. 423, 439 (1974). 

With respect to scope, generally, “persons who are not actual parties to the action or in 

privity with any of them may not be brought within the effect of a[n injunctive] decree merely by 

naming them in the order.” 11C WRIGHT & A. MILLER, FEDERAL PRACTICE AND PROCEDURE, § 

2956 at 335–36 (2d ed. 1995) (footnote omitted). However, “a decree of injunction not only 

binds the parties defendant but also those identified with them in interest, in ‘privity’ with them, 

represented by them or subject to their control.” Golden State Bottling Co. v. NLRB, 414 U.S. 

168, 180 (1973) (citing Regal Knitwear Co. v. NLRB, 324 U.S. 9, 14 (1945)); see also Fed. R. 

Civ. P. 65(d)(2). Specifically relevant to this case, 15 U.S.C. section 1114(2)(D) implicitly 

provides the Court with authority to request or order “[a] domain name registrar, domain name 

registry, or other domain name registration authority . . . [to] deposit[]with a court, in which an 

action has been filed regarding the disposition of the domain name, documents sufficient for the 

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court to establish the court’s control and authority regarding the disposition of the registration 

and use of the domain name.” 15 U.S.C. §§ 1114(2)(D)(i)–(ii). 

Under 15 U.S.C. § 1117(a), a plaintiff may be entitled to recover, as an equitable remedy, 

the illegal profits gained through a defendant’s distribution and sale of goods bearing counterfeit 

and infringing trademarks. See Reebok Int’l, Ltd. v. Marnatech Enters., Inc., 970 F.2d 552, 559 

(9th Cir. 1992) (quoting Fuller Brush Products Co. v. Fuller Brush Co., 299 F.2d 772, 777 (7th 

Cir. 1962) (“An accounting of profits under § 1117(a) is not synonymous with an award of 

monetary damages: ‘[a]n accounting for profits . . . is an equitable remedy subject to the 

principles of equity.’” Requesting equitable relief “invokes the district court’s inherent equitable 

powers to order preliminary relief, including an asset freeze, in order to assure the availability of 

permanent relief.” Levi Strauss & Co. v. Sunrise Int’l Trading Inc., 51 F.3d 982, 987 (11th Cir. 

1995) (citing Fed. Trade Comm’n v. United States Oil & Gas Corp., 748 F.2d 1431, 1433–34 

(11th Cir. 1984)). 

IV. DISCUSSION 

A. Probability of Success on the Merits 

1. Counterfeiting and Infringement – 15 U.S.C. § 1114 

Section 32 of The Lanham Act, 15 U.S.C. § 1114, provides liability for trademark 

infringement if, without the consent of the registrant, a defendant uses “in commerce any 

reproduction, counterfeit, copy, or colorable imitation of a registered mark: which is likely to 

cause confusion, or to cause mistake, or to deceive.” To prevail on its trademark infringement 

claim, Gucci must demonstrate “(1) that it had prior rights to the mark at issue and (2) that the 

defendant had adopted a mark or name that was the same, or confusingly similar to its mark, 

such that consumers were likely to confuse the two.” Planetary Motion, Inc. v. Techsplosion, 

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Inc., 261 F.3d 1188, 1193 (11th Cir. 2001) (citing Lone Star Steakhouse & Saloon, Inc. v. 

Longhorn Steaks, Inc., 106 F.3d 355, 360 (11th Cir. 1997) (internal citation omitted)). 

To evaluate likelihood of consumer confusion in a Lanham Act trademark claim, the 

Eleventh Circuit has developed a seven factor balancing test. See Dieter v. B & H Indus. of Sw. 

Fla., Inc., 880 F.2d 322, 326 (11th Cir. 1989). The seven factors are: “(1) type [or strength] of 

mark; (2) similarity of mark; (3) similarity of the products the marks represent; (3) similarity of 

the parties’ retail outlets and customers; (5) similarity of advertising media; (6) defendant’s 

intent; and (7) actual confusion.” Lipscher v. LRP Publ’ns, Inc., 266 F.3d 1305, 1313 (11th Cir. 

2001); see also Dieter, 880 F.2d at 326; Safeway Stores, Inc. v. Safeway Disc. Drugs, Inc., 675 

F.2d 1160, 1164 (11th Cir. 1982). No single factor is dispositive. Lipscher, 266 F.3d at 1313. 

The Court has considered these seven factors in light of the submissions provided by 

Gucci and concludes the balance of factors indicates there is a likelihood consumers would 

confuse Defendants’ websites and products with the genuine Gucci versions. In particular, the 

submissions provided by Gucci support the strength of the Gucci Marks, show that the goods 

produced and sold by Defendants are nearly identical to genuine Gucci products, indicate that 

both Gucci and Defendants target the same U.S. customers on the Internet, suggest that 

Defendants intended to benefit from the use of Gucci’s brand reputation, and show that 

consumers viewing Defendants’ counterfeit goods post-sale would actually confuse them for real 

Gucci products. Accordingly, Gucci has shown a probability of success on the merits of its 

trademark counterfeiting and infringement claim under section 1114. 

2. False Designation of Origin – 15 U.S.C. § 1125(a) 

The test for liability for false designation of origin under 15 U.S.C. § 1125(a) is the same 

as for a trademark counterfeiting and infringement claim — i.e., whether the public is likely to 

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be deceived or confused by the similarity of the marks at issue. See Two Pesos, Inc. v. Taco 

Cabana, Inc., 505 U.S. 763, 780 (1992). As just discussed in relation to Gucci’s trademark 

counterfeiting and infringement claims, Defendants’ goods are likely to be confused by 

consumers for genuine Gucci products. Therefore, Gucci has shown a likelihood of success on 

Gucci’s claim of false designation of origin. 

3. Cybersquatting Claim – 15 U.S.C. § 1125(d) 

The Anticybersquatting Consumer Protection Act (“ACPA”) protects the owner of a 

distinctive or famous trademark from another’s bad faith intent to profit from the trademark 

owner’s mark by registering or using a domain name which is identical or confusingly similar to, 

or dilutive of, the trademark owner’s mark without regard to the goods or services of the parties. 

See 15 U.S.C. § 1125(d). “To prevail under the ACPA, a plaintiff must prove that (1) its mark is 

distinctive or famous and entitled to protection; (2) the defendant’s domain name is identical or 

confusingly similar to the plaintiff’s mark; and (3) the defendant registered or used the domain 

name with a bad faith intent to profit.” Bavaro Palace, S.A. v. Vacation Tours, Inc., 203 F. 

App’x 252, 256 (11th Cir. 2006) (citing Shields v. Zuccarini, 254 F.3d 476, 482 (3d Cir. 2001)). 

As to the first element, the Gucci Marks are inherently distinctive because they are 

arbitrary as applied to the products which they identify — i.e., they “do[] not suggest or describe 

the goods or services offered thereunder.” Victoria’s Cyber Secret Ltd. P’ship v. V Secret 

Catalogue, Inc., 161 F. Supp. 2d 1339, 1349 (S.D. Fla. 2001) (citing Frehling Enters., Inc. v. 

Int’l Select Group, Inc., 192 F.3d 1330, 1335–36 (11th Cir. 1999)). Moreover, the Gucci Marks 

are indisputably famous because they enjoy widespread recognition by consumers. Regarding 

the second element — use of confusingly similar domain names — Gucci has supplied a list of 

domain names allegedly used by Defendants to sell counterfeit Gucci products. The Subject 

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Domain Names Defendants have registered include at least the domains names 

cheapguccihandbagsusaoutlet.com, guccioutletauthentication.com, guccioutletfranchise.com, 

guccireplicabelts.com, samegucci.com, and samegucci.org. (See Schedule A attached to 

Guccci’s Motion for TRO.) 14 Gucci has provided sufficient evidence in its submissions to 

support the conclusion that these domain names are confusingly similar to at least some Gucci 

Marks. With regard to the third element — whether Defendants registered the domain names 

with the bad faith intent to profit — the Court has considered the nine factors laid out in 15 

U.S.C. § 1125(d)(1)(B)(i)(I)–(IX) and concludes the submissions provided by Gucci adequately 

demonstrate Defendants registered the Subject Domain Names in bad faith to attract customers 

using the Gucci Marks to sell them counterfeit Gucci products. Consequently, Gucci has shown a 

likelihood of success on the merits of its section 1125(d) claim. 

B. Irreparable Injury 

The Eleventh Circuit has acknowledged that “once a plaintiff establishes a likelihood of 

success on the merits of a trademark infringement claim,” 15 there is a “presumption of 

irreparable harm.” N. Am. Med. Corp. v. Axiom Worldwide, Inc., 522 F.3d 1211, 1227 (11th Cir. 

2008); see also McDonald’s Corp. v. Robertson, 147 F.3d 1301, 1310 (11th Cir. 1998). 

However, the strength of this presumption has been called into question by the Supreme Court’s 

decision in eBay Inc. v. MercExchange, L.L.C., 547 U.S. 388 (2006). See N. Am. Med. Corp., 

522 F.3d at 1228. After eBay, a court may grant preliminary injunctive relief “without the 

benefit of a presumption of irreparable injury,” or may “decide that the particular circumstances 

14 The Court may seize control of the remaining Subject Domain Names which do not themselves contain any Gucci 

Marks because the websites associated with those domain names allegedly promote and offer for sale goods which 

infringe the Gucci Marks in violation of sections 1114 and 1125(a). See Tiffany (NJ), LLC v. Zheng, 11-60171-Civ- 

Altonaga, at 9 (S.D. Fla. Feb. 1, 2011) [ECF No. 13]. 

15 As discussed in the legal standard section supra, injunctive relief is available on each of Gucci’s three claims, not 

only the trademark infringement claim. 15 U.S.C. § 1116(a). 

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of the instant case bear substantial parallels to previous cases such that a presumption of 

irreparable injury is an appropriate exercise of its discretion in light of the historical traditions.” 

Id. 

As already discussed, based on Gucci’s submissions to this point, there is a substantial 

likelihood that consumers will incorrectly believe Defendants’ websites and products are 

approved or sponsored by Gucci. Although the Court may be permitted to presume irreparable 

harm from the likely consumer confusion in this case, it is not necessary to rely on a 

presumption. The operation of Defendants’ websites displaying the Gucci Marks and the sale of 

Defendant’s inferior goods to consumers is likely to cause irreparable damage to Gucci’s 

reputation if it continues because Gucci will not have the ability to control the quality of what 

appears to be its products in the marketplace. This damage to Gucci’s reputation and goodwill 

could not be easily quantified nor could it be undone through an award of money damages. See 

Paulsson Geophysical Servs., Inc. v. Sigmar, 529 F.3d 303, 313 (5th Cir. 2008). 

C. The Balance of Hardships 

The Court is satisfied after reviewing Gucci’s submissions that the risk to the reputation 

and goodwill associated with the Gucci Marks should Defendants’ infringing activities continue 

outweighs any hardship to Defendants caused by enjoining those activities. It does not appear 

that Defendants will suffer any legitimate hardship if a temporary restraining order is issued 

because they have no legal right to use the Gucci Marks on their websites or to sell counterfeit 

Gucci products. 

D. Public Interest 

The public has an interest in not being misled as to the origin, source, or sponsorship of 

trademarked products. See Nike, Inc. v. Leslie, 227 U.S.P.Q. 574, 575 (1985) (“[A]n injunction 

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to enjoin infringing behavior serves the public interest in protecting consumers from such 

behavior.”); Nailtiques Cosmetic Corp. v. Salon Sciences, Corp., 41 U.S.P.Q.2d 1995, 1999 

(1997) (citing Scarves By Vera, Inc. v. Todo Imports Ltd., 544 F.2d 1167 (2d Cir. 1976)) (“The 

interests of the public in not being victimized and misled are important considerations in 

determining the propriety of granting injunctive relief.”). Here, Gucci has demonstrated that 

Defendants’ websites and products mislead consumers into believing they are approved or 

sponsored by Gucci and make it more difficult for a consumer to be sure he or she is purchasing 

a genuine Gucci product. 

V. CONCLUSION 

Based on Plaintiff’s Complaint, Ex Parte Application for TRO, and evidentiary 

submissions, the undersigned concludes that the four-part test for injunctive relief has been 

satisfied. Moreover, because providing notice of this suit before granting injunctive relief would 

allow Defendants to funnel traffic to their current websites to new domains and allow Defendants 

to continue selling counterfeit products, a temporary restraining order should issue. 

Additionally, in light of the inherently deceptive nature of the counterfeiting business and 

Defendants’ blatant violation of the federal trademark laws, Plaintiff has good reason to believe 

Defendants will hide or transfer their ill-gotten assets beyond the jurisdiction of this Court unless 

those assets are restrained. 

Accordingly, it is ORDERED AND ADJUDGED that Plaintiff’s Ex Parte Application 

for TRO is GRANTED as follows: 

1. Each Defendant, their officers, directors, employees, agents, subsidiaries, distributors, 

and all persons in active concert or participation with them having notice of this Order 

are hereby temporarily restrained: 

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a. From manufacturing, importing, advertising, promoting, offering to sell, selling, 

distributing, or transferring any products bearing the Gucci Marks, or any 

confusingly similar trademarks, other than those actually manufactured or 

distributed by Plaintiff; and 

b. From secreting, concealing, destroying, selling off, transferring, or otherwise 

disposing of: (i) any products, not manufactured or distributed by Plaintiff, 

bearing the Gucci Marks, or any confusingly similar trademarks; or (ii) any 

evidence relating to the manufacture, importation, sale, offer for sale, distribution, 

or transfer of any products bearing the Gucci Marks, or any confusingly similar 

trademarks. 



shall immediately discontinue the use of the Gucci Marks or any confusingly similar 

trademarks, on or in connection with all Internet websites owned and operated, or 

controlled by them including the Internet websites operating under the Subject Domain 

Names; 



shall immediately discontinue the use of the Gucci Marks, or any confusingly similar 

trademarks within domain name extensions, metatags or other markers within website 

source code, from use on any webpage (including as the title of any web page), any 

advertising links to other websites, from search engines’ databases or cache memory, and 

any other form of use of such terms which is visible to a computer user or serves to direct 

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computer searches to websites registered by, owned, or operated by each Defendant, 

including the Internet websites operating under the Subject Domain Names; 

4. Each Defendant shall not transfer ownership of the Subject Domain Names during the 

pendency of this Action, or until further Order of the Court; 

5. The domain name Registrars for the Subject Domain Names are directed to transfer to 

Plaintiff’s counsel, for deposit with this Court, domain name certificates for the Subject 

Domain Names; 

6. The Registrars shall immediately assist in changing the Registrar of record for the 

Subject Domain Names, excepting any such domain names which such Registrars have 

been notified in writing by the Plaintiff have been or will be dismissed from this action, 

to a holding account with a Registrar of Plaintiff’s choosing (the “New Registrar”). To 

the extent the Registrars do not assist in changing the Registrars of Record for the 

domains under their respective control within one (1) business day of receipt of this TRO 

and instructions on the change of the Registrars of Record, the top-level domain (TLD) 

Registries (or their administrators) for the Subject Domain Names, within five (5) 

business days of receipt of this TRO, shall update the Registrar of record for the Subject 

Domain Names, excepting any such domain names which such Registries have been 

notified in writing by the Plaintiff have been or will be dismissed from this action, to the 

New Registrar. As a matter of law, this Temporary Restraining Order shall no longer 

apply to any Defendant or associated domain name dismissed from this action. Upon the 

change of the Registrar of record for the Subject Domain Names, the New Registrar will 

maintain access to the Subject Domain Names in trust for the Court during the pendency 

of this action. Additionally, the New Registrar shall immediately institute a temporary 

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302 domain name redirection which will automatically redirect any visitor to the Subject 

Domain Names to the following Uniform Resource Locator (“URL”) 

http://servingnotice.com/ggpp/index.html whereon copies of the Complaint and all other 

documents on file in this action are displayed. Alternatively, the New Registrar may 

update the Domain Name System (“DNS”) data it maintains for the Subject Domain 

Names, which link the domain names to the IP addresses where their associated websites 

are hosted, to NS1.MEDIATEMPLE.NET and NS2.MEDIATEMPLE.NET, which will 

cause the domain names to resolve to the website where copies of the Complaint, 

Summonses, Temporary Restraining Order, and all other documents on file in this action 

are displayed. After the New Registrar has effected this change, the Subject Domain 

Names shall be placed on Lock status, preventing the modification or deletion of the 

domains by the Registrar or the Defendants; 

7. Upon Plaintiff’s request, the privacy protection service for any Subject Domain Names 

for which the Registrant uses such privacy protection service to conceal the Registrant’s 

identity and contact information are ordered to disclose to Plaintiff the true identities and 

contact information of those Registrants; 

8. Plaintiff may enter the Subject Domain Names into Google’s Webmaster Tools and 

cancel any redirection of the domains that have been entered there by Defendants which 

redirect traffic to the counterfeit operations to a new domain name and thereby evade the 

provisions of this Order; 

9. Each Defendant shall preserve copies of all their computer files relating to the use of any 

of the Subject Domain Names and shall take all steps necessary to retrieve computer files 

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relating to the use of the Subject Domain Names that may have been deleted before the 

entry of this Order; 

10. Upon receipt of notice of this Order, PayPal, Inc. (“PayPal”) 16 and its related companies 

and affiliates shall immediately freeze all funds, as opposed to ongoing account activity, 

in or which hereafter are transmitted into the PayPal accounts related to the PayPal 

account recipients naiguangsell@hotmail.com, thebusinesspay@gmail.com and 

happybagspay@gmail.com, fightinglife2013@gmail.com, sinehuo@yahoo.com.cn, 

lilychenshop@yahoo.com, fuinanliu@gmail.com, wuheyo@gmail.com and 

Lzhh613846@gmail.com, disbags@hotmail.com, deallucky2012@yahoo.com, 

mariahleopold@gmail.com, zhenshangle@gmail.com, kejie1986@hotmail.com, 

jinying2594@hotmail.com, newfashiontrade@qq.com, zhangshunliag89@gmail.com, 

convener88@gmail.com, jojo198835@hotmail.com, gongliwu168@gmail.com and 

xiaosaxiaosa914@163.com, cc888dang@live.com, serviceisgood@hotmail.com, 

trey4niter@hotmail.com, karenosborn@163.com, jialigoodluck3344@gmail.com, live- 

aaa@live.com, zhilinyang13@gmail.com, and htl168998@163.com, as well as all funds 

in or which are transmitted into (i) any other related accounts of the same customer(s), 

(ii) any other accounts which transfer funds into the same financial institution account(s), 

and/or any of the other PayPal accounts subject to this Order; and (iii) any other PayPal 

accounts tied to or used by any of the Subject Domain Names identified on Schedule A 

hereto; 

11. Upon receipt of notice of this Order, PayPal and its related companies and affiliates shall 

immediately freeze all funds, as opposed to ongoing account activity, in or which 

16 PayPal is licensed to do business in the State of Florida by the Florida Office of the Controller and is therefore 

subject to personal jurisdiction in this Court. (See Gaffigan Decl. 9 and Exhibit E attached thereto.) 

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hereafter are transmitted into PayPal accounts linked to, associated with, or that transmit 

funds into Defendants’ identified bank accounts, 17 including but not limited to, the China 

Bank, account owner Zheng Wen Zong, Bank Account Number, **** **** **** ***1 

876; Bank of China, Guangzhou ZhuDao Garden Sub Branch, account owner Shi Ping 

Fang, Bank Account Number, **************8076; Bank of China, account owner 

Huang Yanfei, Bank Account Card Number, ********7337; Bank of China Guangzhou 

Baiyun Sub Branch, account owner Huang Jing Shun, Bank Account Number, ***** 

**** **** ***0 077; Bank of China, account owner JianXiong Li, Bank Account 

Number, *** **** **** **** 2259; Bank of China, Fujian Branch, account owner Cai 

Zhou Qing, Bank Account Number, ***************9046; and Bank of China 

Guangzhou Huan Shi Xi Road Sub Branch, account owner Liu XiangJiang, Bank 

Account Number, *******-****-***921-9, and any other related accounts of the same 

customers; 

12. PayPal shall also immediately divert to a holding account for the trust of the Court all 

funds in all PayPal accounts related to the PayPal account recipients 

naiguangsell@hotmail.com, thebusinesspay@gmail.com and happybagspay@gmail.com, 

fightinglife2013@gmail.com, sinehuo@yahoo.com.cn, lilychenshop@yahoo.com, 

fuinanliu@gmail.com, wuheyo@gmail.com and Lzhh613846@gmail.com, 

disbags@hotmail.com, deallucky2012@yahoo.com, mariahleopold@gmail.com, 

zhenshangle@gmail.com, kejie1986@hotmail.com, jinying2594@hotmail.com, 

newfashiontrade@qq.com, zhangshunliag89@gmail.com, convener88@gmail.com, 

jojo198835@hotmail.com, gongliwu168@gmail.com and xiaosaxiaosa914@163.com, 

17 The full account numbers have been redacted to avoid disclosure of private financial information, in compliance 

with Fed. R. Civ. P. 5.2(a)(4); however, the full account numbers are identified on Plaintiff’s Notice of Filing 

Reference List, filed under seal, which shall be disclosed to PayPal to effectuate the relief ordered herein. 

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cc888dang@live.com, serviceisgood@hotmail.com, trey4niter@hotmail.com, 

karenosborn@163.com, jialigoodluck3344@gmail.com, live-aaa@live.com, 

zhilinyang13@gmail.com, and htl168998@163.com, and any other related accounts of 

the same customer(s), and/or all PayPal accounts linked to, associated with, or that 

transmit funds into Defendants’ identified bank accounts to the China Bank, account 

owner Zheng Wen Zong, Bank Account Number, **** **** **** ***1 876; Bank of 

China, Guangzhou ZhuDao Garden Sub Branch, account owner Shi Ping Fang, Bank 

Account Number, **************8076; Bank of China, account owner Huang Yanfei, 

Bank Account Card Number, ********7337; Bank of China Guangzhou Baiyun Sub 

Branch, account owner Huang Jing Shun, Bank Account Number, ***** **** **** ***0 

077; Bank of China, account owner JianXiong Li, Bank Account Number, *** **** **** 

**** 2259; Bank of China, Fujian Branch, account owner Cai Zhou Qing, Bank Account 

Number, ***************9046; and Bank of China Guangzhou Huan Shi Xi Road Sub 

Branch, account owner Liu XiangJiang, Bank Account Number, *******-****-***921-9, 

and any other related accounts of the same customers as well as any other accounts which 

transfer funds into the same financial institution account(s) as any of the other PayPal 

accounts subject to this Order; 

13. PayPal shall further, within five days of receiving this Order, provide Plaintiff’s counsel 

with all data which details an accounting of the total funds frozen and identifies the 

PayPal account(s) which the frozen funds are related too. Such freezing of the funds and 

the disclosure of the related financial institution account information shall be made 

without notice to the account owners or the financial institutions until further order of this 

24



261 

Court. PayPal shall receive and maintain this Order and its contents as confidential until 

further order of this Court; 

14. This Temporary Restraining Order shall remain in effect until the date for the hearing on 

the Motion for Preliminary Injunction set forth below, or until such further dates as set by 

the Court or stipulated to by the parties; 

15. Pursuant to 15 U.S.C. § 1116(d)(5)(D), Plaintiff shall post a bond in the amount of Ten 

Thousand Dollars and Zero Cents ($10,000.00), as payment of damages to which 

Defendants may be entitled for a wrongful injunction or restraint. In the Court’s 

discretion, the bond may be subject to increase should the amount of the funds seized 

exceed $10,000.00. Plaintiff shall post the bond prior to requesting the Registry to 

change the registrar of record for the Subject Domain Names; 

16. A hearing is set before Magistrate Judge John J. O’Sullivan at the Clyde C. Atkins United 

States Courthouse at 301 North Miami Avenue, 5th Floor, Miami, FL, 33128, on 

Thursday, September 6, 2012, at 4:00 P.M., or at such other time that this Court deems 

appropriate, at which time Defendants and/or any other affected persons may challenge 

the appropriateness of this Order and move to dissolve the same and at which time the 

Court will hear argument on Plaintiff’s requested preliminary injunction; 

17. Plaintiff shall serve a copy of the Complaint, the Ex Parte Application for TRO, and this 

Order on each Defendant via the corresponding e-mail addresses provided to the 

Registrars responsible for the Subject Domain Names and the customer service e-mail 

addresses used to communicate with Plaintiff’s investigator, all of which are identified on 

Schedule “B” hereto. In addition, Plaintiff shall post a copy of the Complaint, the Ex 

Parte Application for TRO, and this Order, as well as all other documents filed in this 

25



261 

action on the website located at http://servingnotice.com/ggpp/index.html, upon being 

changed to the Registrar of record’s holding account, and such notice so given shall be 

deemed good and sufficient service thereof. Any response or opposition to Plaintiff’s 

Motion for Preliminary Injunction must be filed and served on Plaintiff’s counsel and 

filed with the Court, along with Proof of Service, by August 31, 2012. Plaintiff shall file 

any Reply Memorandum on or before September 4, 2012. The above dates may be 

revised upon stipulation by all parties and approval of this Court. Defendants are hereby 

on notice that failure to appear at the hearing may result in the imposition of a 

preliminary injunction against them pursuant to 15 U.S.C. § 1116(d) and Fed. R. Civ. P. 

65. 

This Temporary Restraining Order expires at 1:05 P.M. on September 7, 2012, unless 

extended for good cause. 

at 1:05 P.M. 

DONE AND ORDERED in Chambers at Miami, Florida this 24th day of August, 2012, 

cc: counsel of record 

________________________________ 

JOAN A. LENARD 

UNITED STATES DISTRICT JUDGE 

26



261 

SCHEDULE “A” 

DEFENDANTS BY SUBJECT DOMAIN NAMES AND DEFENDANT NUMBER 


Defendant 1 cheapguccihandbagsusaoutlet.com 

Defendant 2 luxuryhandbagsreplicas.net 

Defendant 2 luxuryhandbagsreplicas.org 

Defendant 3 aaashoestrade.com 

Defendant 4 brands-b2bstore.com 

Defendant 4 designerhandbagsusd.com 

Defendant 5 buyshopchina.com 

Defendant 6 buytop-bag.com 

Defendant 6 buy-topbags.biz 

Defendant 6 vip-handbag.org 

Defendant 6 vip-handbag.net 

Defendant 7 cheapbeltoutlet.com 

Defendant 8 chinashoesclothes.net 

Defendant 8 jumpmanlocker.org 

Defendant 8 nipponhermes.com 

Defendant 8 saleoutlet-store.com 

Defendant 9 chogorius.com 

Defendant 10 clothingshoeschina.net 

Defendant 11 disbags.com 

Defendant 12 grandbuying.com 

Defendant 13 guccioutletauthentication.com 

27



261 


Defendant 13 guccioutletfranchise.com 

Defendant 14 guccireplicabelts.com 

Defendant 15 handbagscn.com 

Defendant 16 iokbags.com 

Defendant 17 perfectxclones.com 

Defendant 18 picktopaaa.net 

Defendant 19 qiqimalls.com 

Defendant 20 qqfashiontrade.com 

Defendant 21 replicacchanel.com 

Defendant 22 replicaconvener.com 

Defendant 23 replica-watches-onsales.com 

Defendant 24 samegucci.com 

Defendant 24 samegucci.org 

Defendant 25 soeasybuy.com 

Defendant 26 sunglasseshutflagship.org 

Defendant 26 sunglasseshutflagship.com 

Defendant 26 sunglassesflagshipstore.com 

Defendant 27 thesneakerspoint.com 

Defendant 28 thewatchau.com 

Defendant 29 watches-seller.com 

Defendant 30 watchessss.com 

Defendant 31 watchghy.com 

Defendant 32 watchww.com 

28



261 


Defendant 33 yannatrade.com 

Defendant 33 fireclothing.org 

29

Defendant 

Number 

SCHEDULE “B” 

DEFENDANT PARTNERSHIPS OR UNINCORPORATED ASSOCIATIONS 

BY SUBJECT DOMAIN NAME AND ASSOCIATED E-MAIL ADDRESSES 

Defendant / 

Subject Domain Name 

1 cheapguccihandbagsusaoutlet.com 

2 

luxuryhandbagsreplicas.net 

luxuryhandbagsreplicas.org 

3 aaashoestrade.com 

4 

brands-b2bstore.com 

designerhandbagsusd.com 

5 buyshopchina.com 

6 

buytop-bag.com 

buy-topbags.biz 

vip-handbag.org 

vip-handbag.net 

7 cheapbeltoutlet.com 

8 

chinashoesclothes.net 

jumpmanlocker.org 

nipponhermes.com 

saleoutlet-store.com 

9 chogorius.com 

10 clothingshoeschina.net 

11 disbags.com 

30 

E-Mail Address(es) 

cheapguccihandbagsusaoutlet@gmail.com 

service@cheapguccihandbagsusaoutlet.com 

8b5644ab9e6442ec82b6a4868ec667d5.protect@whoisguard.com 

LuxuryHandbagsReplicas.com@gmail.com 

luxuryhandbagsreplicas@gmail.com 

aaashopmyshoes@hotmail.com 

chou@diytrade.net 

designerhandbagsusd@hotmail.com 

94462781@qq.com 

532456587@qq.com 

buyshopchina@hotmail.com 

rqb@dingdian.cn 

buytopreplica@gmail.com 

salesvipbags@gmail.com 

good11111@163.com 

jerseyssite@hotmail.com 

aoleytrade@gmail.com 

chinaclothingshoes@gmail.com 

80180569@qq.com 

jumpmanlocker@yahoo.com.cn 

1832000488@qq.com 

chogorius@gmail.com 

chogorier@gmail.com 

cheapshoesapparel@gmail.com 


disbags@hotmail.com 

taoxinrong@gmail.com 

12 grandbuying.com grandbuying@hotmail.com 

13 



261 

guccioutletauthentication.com 

guccioutletfranchise.com 

14 guccireplicabelts.com guccireplicabelts@hotmail.com 

sales@guccioutletauthentication.com 

sales@guccioutletfranchise.com 

4ff692f16ct79p8g@t02cduv4f7f99a255f64.privatewhois.net 

xmtpq0f4fc85cfaedb92@t02cduv4f7f99a255f64.privatewhois.net

Defendant 

Number 

Defendant / 


15 handbagscn.com jerryjw08@hotmail.com 

16 iokbags.com 

17 perfectxclones.com 

18 picktopaaa.net 

19 qiqimalls.com 

20 qqfashiontrade.com 

21 replicacchanel.com 

22 replicaconvener.com 

iokbags@hotmail.com 

51321641@qq.com 

sales@perfect88clones.com 

madoka.biz@gmail.com 

picktopaaa@hotmail.com 

domain@diyworld.com 

gogomalls@live.com 

agogoyou@yahoo.com.cn 

contact@privacyprotect.org 

qqfashiontrade@live.com 

domain@diyworld.com 

service@replicacchanel.com 

admin@replicacchanel.com 

service@replicaconvener.com 

gavinchow1@gmail.com 

23 replica-watches-onsales.com hemu2080@gmail.com 

24 

samegucci.com 

samegucci.org 

samegucci@repury.com 

lp1988123126@hotmail.com 

samegucci@126.com 

25 soeasybuy.com xu_chunjin@hotmail.com 

26 



261 

sunglasseshutflagship.org 

sunglasseshutflagship.com 

sunglassesflagshipstore.com 

27 thesneakerspoint.com 

31 

E-Mail Address(es) 

sunglassesflagshipstore@hotmail.com 

f4d56328f3c5436ba7d44333111fa39f.protect@whoisguard.com 

customerser@hotmail.com 

thesneakerspoint@yahoo.com 

ruanfa@yahoo.cn 

28 thewatchau.com xufangjiao@gmail.com 

29 watches-seller.com 

30 watchessss.com 

31 watchghy.com 

watchesseller@163.com 

guojinlong88@126.com 

service@watchessss.com 

admin@watchessss.com 

watchghy@hotmail.com 

y7519@126.com

Defendant 

Number 

Defendant / 


32 watchww.com 

33 



261 

yannatrade.com 

fireclothing.org 

service@watchww.com 

admin@watchww.com 

service@yannatrade.com 

juiccyer@gmail.com 

onwholesale@gmail.com 

32 

E-Mail Address(es)

Case 1:12-cv-23295-JLK 1:12-cv-21936-UU Document 10 6-10 Entered on on FLSD Docket 06/01/2012 09/12/2012 Page Page 1 of 64 26 of 

261 

Case 1:12-cv-21936-UU Document 6-29 Entered on FLSD Docket 05/29/2012 Page 1 of 26 

LOUIS VUITTON MALLETIER, S.A., 

vs. 

Plaintiff, 

CHEAPLOUISVUITTONI0.COM, 

et aI., 

Defendants. 

------------------------------ I 



CASE NO. 1:12-cv-21936-UU 

ORDER GRANTING EXPARTE TEMPORARY RESTRAINING ORDER 

THIS CAUSE is before the Court on Plaintiff's Ex Parte Application for Entry of 

Temporary Restraining Order, Preliminary Injunction, and Order Restraining Transfer of Assets 

Tied to the Counterfeiting Operation (the "Application for TRO"). The Court has carefully 

reviewed the Application, the entire court file and is otherwise fully advised in the premises. 

By the instant Application, Plaintiff, Louis Vuitton Malletier, S.A. ("Plaintiff" or "Louis 

Vuitton") moves ex parte, for entry of a temporary restraining order against Defendants the 

Partnerships or Unincorporated Associations identified on Schedule "A" hereto and Does 1-10 

(collectively "Defendants") and an order restraining the financial accounts used by Defendants, 

pursuant to 15 U.S.C. § 1116 and Fed. R. Civ. P. 65. 

I. Factual Backeround 

The Court bases this Order on the following facts from Plaintiff's Complaint, Application 

for TRO, and supporting evidentiary submissions. 

Louis Vuitton is a foreign business entity organized under the laws of the Republic of 

France with its principal of business in Paris, France. (See Declaration of Nikolay Livadkin in


Case 1:12-cv-21936-UU Document 6-29 Entered 261on 

FLSD Docket 05/29/2012 Page 4 of 26 

Trademark 

+ 2,177,828 

Registration 

Number 

Registration Date 

August 4, 1998 

4 

Class(es) I Relevant Goods 

IC 14: goods made of precious 

metals, namely, shoe ornaments, 

ornamental pins; jewelry, namely, 

rings, ear rings, cufflinks, bracelets, 

charms, necklaces; horological 

instruments, straps for watches, 

watches and wrist-watches, and cases 

for watches. 

IC 18: goods made of leather or 

imitations of leather are not included 

in other classes, namely, boxes made 

from leather; trunks, valises, 

traveling bags, luggage for travel, 

garment bags for travel, vanity cases 

sold empty, rucksacks, hand bags, 

beach bags, shopping bags, shoulder 

bags, attache cases, briefcases, and 

fine leather goods, namely, pocket 

wallets, purses, leather key holders, 

business card cases, calling card 

cases, and credit card cases, and 

umbrellas. 

IC 25: clothing and underwear, 

namely, sweaters, shirts, suits, 

waistcoats, raincoats, skirts, coats, 

pullovers, trousers, dresses, jackets, 

shawls, stoles, sashes for wear, 

scarves, neckties, pocket squares, 

gloves, belts, socks, bath robes, 

shoes, boots, and sandals. 

f 

I 

I 

I 

I 

f 

Ii


Case 1:12-cv-21936-UU Document 6-29 Entered 261 

on FLSD Docket 05/29/2012 Page 7 of 26 

Trademark 

LOUIS VUITTON 

PARIS 

Registration 

Number 

Registration Date Class(es) I Relevant Goods 

2,378,388 August 22, 2000 

7 

Ie 18: goods made of leather or 

imitations of leather not included in 

other classes, namely, boxes of 

leather principally used for travel 

purposes, trunks, valises, traveling 

bags, traveling sets for containing 

cosmetics and jewelry, rucksacks, 

handbags, beach bags, shopping 

bags, shoulder bags, brief cases, 

pouches, fine leather goods namely, 

pocket wallets, purses, key cases, 

business card cases, credit card 

cases, and calling card cases.

Case 1:12-cv-21936-UU 1:12-cv-23295-JLK Document 10 6-10 Entered on on FLSD FLSD Docket Docket 06/01/2012 09/12/2012 Page Page 10 73 of 26 of 



Trademark 

!II)( !II 

)(8)( 

!II)( !II 

FLOWER 

PATTERN 

Registration 

Number 

Registration Date Class(es) 1Relevant Goods 

3,107,072 June 20, 2006 

10 

IC 09: Spectacles, sunglasses, and 

spectacle cases. 

IC 14: Jewelry, namely, rings, key 

rings of precious metal, earrings and 

ear clips, cuff links, bracelets, 

charms, brooches, necklaces, tie 

pins, ornaments of precious metal, 

medallions; horological and 

chronometric apparatus and 

instruments, namely watches, watch 

cases, alarm clocks; jewelry boxes of 

precious metal, their alloys or coated 

therewith. 

IC 18: Leather and imitation leather 

products, namely, traveling bags, 

traveling sets comprised of bags or 

luggage, trunks and suitcases, 

garment bags for travel purposes; 

vanity cases sold empty, rucksacks, 

shoulder bags, handbags, attache 

cases, document wallets and 

briefcases made of leather, pouches 

made of leather, wallets, purses, key 

cases, business card cases, credit 

card cases; umbrellas. 

IC 25: Clothing and undergarments, 

namely, sweaters, shirts, tee-shirts, 

belts, scarves, neckties, shawls, 

waistcoats, skirts, raincoats, 

overcoats, suspenders, trousers, 

denim trousers, pullovers, dresses, 

jackets, sashes for wear, gloves, 

tights, bathing suits, bath robes, 

pajamas, nightgowns, shorts, pocket 

squares; shoes, boots, slippers; 

headgear, namely, hats and caps; 

underwear.




II. Conclusions of Law 

The declarations Plaintiff submitted in support of its Application for TRO support the 

following conclusions of law: 

A. Plaintiff has a very strong probability of proving at trial that consumers are likely 

to be confused by Defendants' advertisement, promotion, sale, offer for sale, and/or distribution 

of handbags, wallets, watches, sunglasses, belts, key holders, jewelry, shirts, and shoes bearing 

counterfeits, reproductions, and/or colorable imitations of the Louis Vuitton Marks, and that the 

handbags, wallets, watches, sunglasses, belts, key holders, jewelry, shirts, and shoes Defendants 

are selling are copies of Plaintiffs products that bear copies of the Louis Vuitton Marks. 

B. Because of the infringement of the Louis Vuitton Marks, Plaintiff is likely to 

suffer immediate and irreparable injury if a temporary restraining order is not granted. It clearly 

appears from the following specific facts, as set forth in Plaintiffs Complaint, Application for 

TRO, and accompanying declarations on file, that immediate and irreparable loss, damage, and 

injury will result to Plaintiff and to consumers before Defendants can be heard in opposition 

unless Plaintiffs request for ex parte relief is granted: 

1. Defendants are operating Internet businesses which advertise, promote, 

offer for sale, and sell handbags, wallets, watches, sunglasses, belts, key holders, jewelry, shirts, 

and shoes bearing counterfeit and infringing trademarks in violation of Plaintiffs rights; 


handbags, wallets, watches, sunglasses, belts, key holders, jewelry, shirts, and shoes bearing 

Plaintiff's trademarks will appear in the marketplace; that consumers may be misled, confused, 

and disappointed by the quality of these products; and that Plaintiff may suffer loss of sales for 

its genuine products; 

15




3. There is good cause to believe that if Plaintiff proceeds on notice to 

Defendants on this Application for TRO, Defendants can easily and quickly transfer the 

registrations for many of the Subject Domain Names, or modify registration data and content, 

change hosts, and redirect traffic to other websites, thereby thwarting Plaintiff's ability to obtain 

meaningful relief; 

4. The balance of potential harm to Defendants in restraining their trade in 

counterfeit and infringing branded products if a temporary restraining order is issued is far 

outweighed by the potential harm to Plaintiff, its reputation and goodwill as a manufacturer of 

high quality products, if such relief is not issued; and 

5. The public interest favors issuance of the temporary restraining order in 

order to protect Plaintiff's trademark interests and the public from being defrauded by the 

palming off of counterfeit products as genuine products of Plaintiff. 

C. Under 15 U.S.C. § 1117(a), Plaintiff may be entitled to recover, as an equitable 

remedy, the illegal profits gained through Defendants' distribution and sales of handbags, 

wallets, watches, sunglasses, belts, key holders, jewelry, shirts, and shoes bearing counterfeits 

and infringements of the Louis Vuitton Marks. See Reebok Int'!, Ltd v. Marnatech Enters., Inc., 

970 F.2d 552, 559 (9th Cir. 1992) (quoting Fuller Brush Products Co. v. Fuller Brush Co., 299 

F.2d 772, 777 (7th Cir. 1962) ("An accounting of profits under § 1117(a) is not synonymous 

with an award of monetary damages: '[a]n accounting for profits ... is an equitable remedy 

subject to the principles of equity.'" 

D. Requesting equitable relief "invokes the district court's inherent equitable powers 


permanent relief." Levi Strauss & Co. v. Sunrise Int '/ Trading Inc., 51 F.3d 982, 987 (l1th Cir. 

16




1995) (citing Federal Trade Commission v. United States Oil and Gas Corp., 748 F.2d 1431, 

1433-34 (lIth Cir. 1984». 

E. In light of the inherently deceptive nature of the counterfeiting business, and 

Defendants' blatant violation of the federal trademark laws, Plaintiff has good reason to believe 



Accordingly, after due consideration, it is 

ORDERED AND ADJUDGED that Plaintiff's Ex Parte Application for a Temporary 

Restraining Order and Order Restraining Transfer of Assets Tied to the Counterfeiting Operation 

is hereby GRANTED as follows: 

(l) Each Defendant, their officers, directors, employees, agents, subsidiaries, 

distributors, and all persons in active concert or participation with them having notice of this 

Order are hereby temporarily restrained: 

a. From manufacturing, importing, advertising, promoting, offering to sell, 

selling, distributing, or transferring any products bearing the Louis Vuitton 

Marks, or any confusingly similar trademarks, other than those actually 


b. From secreting, concealing, destroying, selling off, transferring, or 


by Plaintiff, bearing the Louis Vuitton Marks, or any confusingly similar 

trademarks; or (ii) any evidence relating to the manufacture, importation, 


Louis Vuitton Marks, or any confusingly similar trademarks. 

(2) Each Defendant, their officers, directors, employees, agents, subsidiaries, 


Order shall immediately discontinue the use of the Louis Vuitton Marks or any confusingly 

17




similar trademarks, on or in connection with all Internet websites owned and operated, or 

controlled by them including the Internet websites operating under the Subject Domain Names; 



Order shall immediately discontinue the use of the Louis Vuitton Marks, or any confusingly 

similar trademarks within domain name extensions, metatags or other markers within website 



use of such terms which is visible to a computer user or serves to direct computer searches to 

websites registered by, owned, or operated by each Defendant, including the Internet websites 

operating under the Subject Domain Names; 

(4) Each Defendant shall not transfer ownership ofthe Subject Domain Names during 

the pendency of this Action, or until further Order ofthe Court; 

(5) The domain name Registrars for the Subject Domain Names are directed to 

transfer to Plaintiffs counsel, for deposit with this Court, domain name certificates for the 

Subject Domain Names; 

(6) The Registrars shall immediately assist in changing the Registrar of record for the 

Subject Domain Names, excepting any such domain names which such Registrars have been 

notified in writing by the Plaintiff have been or will be dismissed from this action, to a holding 

account with a Registrar of Plaintiffs choosing (the "New Registrar"). To the extent the 

Registrars do not assist in changing the Registrars of Record for the domains under their 

respective control within one (1) business day of receipt of this TRO and instructions on the 

change of the Registrars of Record, the top-level domain (TLD) Registries (or their 

18



on FLSD Docket 05/29/2012 Page 19 of 26 t 

administrators) for the Subject Domain Names, within five (5) business days of receipt of this I 

TRO, shall update the Registrar of record for the Subject Domain Names, excepting any such 

domain names which such Registries have been notified in writing by the Plaintiff have been or 

will be dismissed from this action, to the New Registrar. As a matter of law, this Temporary 

I 

Restraining Order shall no longer apply to any Defendant or associated domain name dismissed 

from this action. Upon the change of the Registrar of record for the Subject Domain Names, the 

New Registrar will maintain access to the Subject Domain Names in trust for the Court during 

the pendency of this action. Additionally, the New Registrar shall immediately institute a 

temporary 302 domain name redirection which will automatically redirect any visitor to the 

Subject Domain Names to the following Uniform Resource Locator ("URL") 

http://servingnotice.com/lvpp2/index.htmlwhereon copies of the Complaint and all other 

documents on file in this action are displayed. Alternatively, the New Registrar may update the 

Domain Name System ("DNS") data it maintains for the Subject Domain Names, which link the 

domain names to the IP addresses where their associated websites are hosted, to 

NS I.MEDIA TEMPLE.NET and NS2.MEDIATEMPLE.NET, which will cause the domain 

names to resolve to the website where copies of the Complaint, Summonses, Temporary 

Restraining Order, and all other documents on file in this action are displayed. After the New 

Registrar has effected this change, the Subject Domain Names shall be placed on Lock status, 

preventing the modification or deletion of the domains by the Registrar or the Defendants; 

(7) Upon Plaintiff's request, the privacy protection service for any Subject Domain 

Names for which the Registrant uses such privacy protection service to conceal the Registrant's 

identity and contact information are ordered to disclose to Plaintiff the true identities and contact 

information of those Registrants; 

19 

I 

I 

I


261 

Case 1:12-cv-21936-UU Document 6-29 Entered on FLSD Docket OS/29/2012 Page 24 of 26 

SCHEDULE "A" 

DEFENDANTS BY DEFENDANT NUMBER AND SUBJECT DOMAIN NAMES 

Defendant 1 

cheaplouisvuitton 1 O.com 

louisvuittonoutlet20.com 

Defendant 2 discountlvhandbagsoutlet.com 

Defendant 3 louisvuittonya.com 

annawholesaleshop.com 

Defendant 4 bizclothingoutlet.com 

bizclothingoutlet.net 

Defendant 5 anylar.com 

Defendant 6 bestclassichandbags.com 

Defendant 7 chogori.us 

Defendant 8 eooshop.com 

Defendant 9 jewellery-discount.com 

Defendant 10 louisvuittononly.com 

Defendant 11 louisvuittonstoreus.com 

Defendant 12 popbagsoutlet.com 

Defendant 13 

Defendant 14 

Defendant 15 

Defendant 16 

replica-handbags.us 

watchaaa.com 

watchaaa.net 

watchaah.com 

wish89.com 

24 

; 

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I 

f 

I 

t 

f 

r 

I 

I 

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I 

r 

t


Case 1:12·cv·21936·UU Document 6·29 Entered on 261 

FLSD Docket 05/29/2012 Page 25 of 26 

SCHEDULE "B" 

DEFENDANT PARTNERSHIPS AND UNINCORPORATED ASSOCIATIONS 


cheapJouisvuitton 1 O.com 

louisvuittonoutlet20.com 

Defendant 

2 discountlvhandbagsoutlet.com 

Defendant 314031762@163.com 

louisvuittonya.com 

3 loui svuittonya@hotmail.com 

Defendant annawholesaJeshop.com 

4 bizclothingoutlet.com 

bizclothingoutlet.net 

Defendant anylar.com 

5 

Defendant bestclassichandbags.com 

6 

Defendant chogori.us 

7 

bizclothing@163.com 

annysale@163.com 

caowholesaJe@163.com 

Defendant eooshop.com itcn88@yahoo.com.cn 

8 

Defendant 

9 

Defendant 

10 

Defendant 

11 

Defendant 

12 

my2085@hotmail.com 

jewellery-discount.com fiona@marlary.com 

fiona@wholesale-;ewels.com 

louisvuittononly.com aUang.2007@gmail.com 

louisvuittonstoreus.com jersey2008@tom.com 

popbagsoutlet.com 

Defendant 

replica-handbags.us 

13 I 

Defendant watchaaa.com 

14 watchaaa.net 

Defendant 

. watchaah.com 

15 

1 007288de9d545d5896gecb8185bed84.protect@whoisguard.com 

vipsaleservice@gmai!.com 

replica 123@oswo.net 

handbags5661 @gmail.com 

rydjxs@gmail.com 

25




Defendant 

16 wish89.com 1 imengrao2007@hotmail.com 

26

Case 1:12-cv-21088-UU Document 12 Entered on FLSD Docket 05/21/2012 Page 1 of 2 


261 

ABERCROMBIE & FITCH TRADING CO., 

Plaintiff, 

vs. 

4CHEAPBAGS.COM, 

Defendant. 

_____________________________/ 



Case No. 12-21088-UU 

ORDER ADOPTING MAGISTRATE'S REPORT AND RECOMMENDATION 

THIS CAUSE came before the Court upon Plaintiff’s Ex Parte Application for Entry of 

Temporary Restraining Order and Preliminary Injunction (D.E 6). 

THE MATTER was referred to the Honorable Edwin G. Torres, United States Magistrate 

Judge. A Report and Recommendation, has been filed, recommending that the Ex Parte Motion 

be granted (D.E. 10). Defendant has failed to file objections to the Report. See LoConte v. 

Dugger, 847 F.2d 145 (11th Cir. 1988), cert. denied, 488 U.S. 958 (1988) (holding the failure to 

file timely objections bars the parties from attacking factual findings on appeal). The matter is 

ripe for disposition. 

THIS COURT has made a de novo review of the entire file and record herein, and, being 

otherwise fully advised in the premises, it is hereby 

ORDERED and ADJUDGED that United States Magistrate Judge Torres’s Report and 

Recommendation (D.E. 10) is RATIFIED, AFFIRMED and ADOPTED. An evidentiary hearing 

on the preliminary injunction shall take place on Wednesday May 30, 2012, at 3 p.m., James 

Lawrence King Bldg., 99 N.E. Fourth Street, Tenth Floor, Courtroom 5, Miami FL, before 

Magistrate Judge Torres. As stated in the Report and Recommendation, the temporary 

restraining order already in place shall remain in effect until the date of this hearing and A&F



261 

shall post a bond in the amount of $10,000.00, as payment of damages to which Defendants may 

be entitled for a wrongful injunction or restraint. All other forms of relief provided in the Report 

and Recommendation have full force and effect. 

DONE AND ORDERED in Chambers at Miami, Florida, this 18th day of May, 2012. 

copies provided: 

U.S. Magistrate Judge Torres 

Counsel of Record 

UNITED STATES DISTRICT JUDGE



261 



Case No. 12-21088-Civ-UNGARO/TORRES 


v. 

Plaintiff, 

4CHEAPBAGS.COM, et al., 

Defendants. 

_____________________________________/ 

REPORT AND RECOMMENDATION 

ON PLAINTIFF’S EX PARTE APPLICATION FOR ENTRY OF 

TEMPORARY RESTRAINING ORDER AND PRELIMINARY INJUNCTION 

This matter came before the Court upon Plaintiff’s Ex Parte Application for 

Entry of Temporary Restraining Order and Preliminary Injunction (“Motion”). [D.E. 

1 

6]. Based on the motion, affidavits and documents submitted therewith, Plaintiff’s 

Motion should be GRANTED insofar as the Ex Parte Motion should be entered and a 

preliminary injunction hearing should be set for April 11, 2012. 

A temporary restraining order is used primarily for maintaining the status quo 

of the parties. See, e.g., Cate v. Oldham, 707 F.2d 1176, 1185 (11th Cir. 1983). A party 

seeking a temporary restraining order must show: 1) a substantial likelihood of success 

on the merits; 2) irreparable injury; 3) that the injury to Plaintiffs outweigh the harm 

an injunction may cause Defendants; and, 4) that granting the injunction would not 

disserve the public interest. See, e.g., Tefel v. Reno, 180 F.3d 1286, 1295 (11th Cir 

1 

By Order dated March 20, 2012, the Honorable Ursula Ungaro referred 

this motion to the undersigned [D.E. 9].



261 

1999). “The court may issue a temporary restraining order without written or oral 

notice to the adverse party or its attorney only if: (A) specific facts in an affidavit or a 

verified complaint clearly show that immediate and irreparable injury, loss, or damage 

will result to the movant before the adverse party can be heard in opposition; and, (B) 

the movant’s attorney certifies in writing any efforts made to give notice and the 

reasons why it should not be required.” Fed. R. Civ. P. 65(b)(1). 

In this case, Abercrombie & Fitch Trading Co. (“A&F”) makes a sufficient 

evidentiary showing to support issuing a temporary restraining order. The Court bases 

its ruling on the facts found in A&F’s Complaint, Ex Parte Motion, Declarations of 

2 3 4 

Stephen M. Gaffigan (A&F’s attorney”), Brandon Scott, Brandon Tanori, exhibits 

thereto and the complete record. 

A&F is engaged in the manufacture, promotion, distribution, and sale in 

interstate commerce of high quality products under multiple federally registered 

trademarks. Scott Decl. at 4-5. A&F is the owner of all rights in and to those 

trademarks which are valid and registered on the Principal Register of the United 

2 

See [D.E. 6-4; Declaration of Stephen M. Gaffigan (“Gaffigan Decl.”)]. 

3 

A&F’s Senior Manager of Brand Protection, who is responsible for A&F’s 

trademark and anti-counterfeiting efforts in the Unites States. See [D.E. 6-1; 

Declaration of Brandon Scott (“Scott Decl.”) at 3]. 

4 

An employee of Investigative Consultants, a licensed private investigative 

firm that A&F hired to investigate the suspected sale of counterfeit versions of A&F’s 

products by Defendants via the Internet. See [D.E. 6-10; Declaration of Brandon Tanori 

(“Tanori Decl.”) at 2-3]. 

2



261 

States Patent and Trademark Office (collectively the “A&F Marks”). Scott Decl. at Ex. 

A. 

Defendants have advertised, offered for sale and/or sold at least t-shirts, polo 

shirts, sweat shirts, sweaters, sweat pants, underwear, shorts, jeans, jacket, vests and 

caps bearing counterfeit and infringing trademarks which are exact copies of the A&F 

Marks. Id. at 11-12, 14; Tanori Decl. at 4-14, Ex. A-K; Gaffigan Decl. at 2-3, 

Comp. Ex. B. The A&F Marks have never been assigned or licensed to the Defendants, 

and the Defendants do not have, nor have they ever had, the right or authority to use 

the A&F Marks. Scott Decl. at 9, 12, 14. 

A&F retained Brandon Tanori (“Tanori”) to investigate the suspected sale of 

counterfeit versions of its products by the Defendants through the internet on various 

5 

domain names operated by them. Scott Decl. at 10-11; Tanori Decl. at 3. Tanori 

accessed Defendants’ eleven websites (“4cheapnamebrandclothes.com,” 

“4cheapnambrandhandbags.com,” “4cheapbags.com,” “abercrombie-clothes.net,” 

“abercrombieandfitchuksales.org,” “abercrombieoutlett.com,” “afonlinesell.com,” 

“icheapclothing.com,” “mygo2like.com,” “polowholesaler.com,” and “spring-grass.com,”) 

and placed orders to purchase at least one A&F product – each product bearing at least 

one counterfeit A&F Mark – to be shipped to Miami, Florida. Tanori Decl. at 4-14, 

Ex. A-K. Tanori communicated with these Defendants electronically via e-mail and/or 

on-site contact page and received information for finalizing (or nearly finalizing) 

5 

A list of Defendants’ domain names (“Subject Domain Names”) is 

reproduced below at Schedule “A.” 

3



261 

payment for each of the A&F-branded items purchased via PayPal to Defendants’ 

respective PayPal accounts: 

Subject Domain Name PayPal Account 

4cheapbags.com 

4cheapnamebrandclothes.com 

6 

This Defendant did not accept PayPal, but provided bank transfer 

information for a Bank of China Putian Branch; Bank Acct # ending in -4662. Id. at 

9. 

7 

This Defendant did not accept PayPal, but provided bank transfer 

information for a Bank of China Putian Branch; Bank Acct # ending in -2302. Id. at 

12. 

4 

wangyunhong01@hotmail.com 

huangqingan4@hotmail.com 

4cheapnambrandhandbags.com wealharry@hotmail.com 

abercrombieandfitchuksales.org haoyanmei1986@gmail.com 

abercrombie-clothes.net haoyanmei1986@gmail.com 

abercrombieoutlett.com N/A 6 

afonlinesell.com anftu@hotmail.com 

icheapclothing.com 13783007710@qq.com 

sunhe719@gmail.com 

mygo2like.com N/A 7 

polowholesaler.com handfolk2011@hotmail.com 

spring-grass.com ning-focus@homtail.com 

Tanori Decl. 4-14, Exs. A-K. 

A&F’s representative Scott reviewed the detailed web page listings and images 

of the A&F branded apparel that Tanori purchased from the websites operated by the 

Defendants and determined the products to be non-genuine, unauthorized A&F 

products. Scott Decl. 11-14. Scott also reviewed and visually inspected all of the



261 

Subject Domain Name websites, as well as pictures of items bearing the A&F Marks 

offered for sale on those websites and determined that the products were not genuine 

A&F products. Id., Ex. B. 

On this record, we find that A&F has a substantial likelihood of success on the 

merits and thus satisfied this prong. 

Moreover, Defendants’ unauthorized use of the A&F Marks and sale of 

counterfeit products is sufficiently likely to cause confusion that may “by itself 

constitute a showing of ... [a] substantial threat of irreparable harm.” Ferrellgas Ptnrs., 

L.P. v. Barrow, 143 F. App’x 180, 191 (11th Cir. 2005) (citing McDonald’s Corp. v. 

Robertson, 147 F.3d 1301, 1310 (11th Cir. 1998)). Therefore, based on the record before 

us, A&F is likely to suffer an irreparable injury to its reputation if Defendants are 

permitted to continue their activities. 

The balance of potential harm to Defendants in restraining their trade in 

counterfeit and infringing branded goods if a temporary restraining order is issued is 

far outweighed by the potential harm to A&F, its reputation and goodwill as 

manufacturer of, among other things, high quality clothing. Furthermore, public 

interest favors issuance of the temporary restraining order in order to protect A&F’s 

trademarks and the public from Defendants’ sale of non-genuine products. 

If notice is given to Defendants of the pendency of this Motion, Defendants are 

likely to transfer registration for many, if not all, of the Subject Domain Names or 

otherwise modify registration data and content, change hosts, and redirect traffic to 

other websites to evade A&F’s ability to obtain the relief sought. We find good cause 

5



261 

exists for entry of this Order without notice to Defendants to assure retention of the 

Subject Domain Names under the control of this Court. We thus find that A&F’s 

counsel’s certification attached to the Motion has merit and satisfies Rule 65(b)(1)(B). 

See Gaffigan Decl. at 4-7. 

Under 15 U.S.C. § 1117(a), A&F may be entitled to recover, as an equitable 

remedy, the illegal profits gained through Defendants’ distribution and sale of 

counterfeit and infringing A&F branded goods. See Reebok Int’l, Ltd. v. Marnatech 

Enters., Inc., 970 F.2d 552, 559 (9th Cir. 1992) (quoting Fuller Brush Products Co. v. 

Fuller Brush Co., 299 F.2d 772, 777 (7th Cir. 1962) (“An accounting of profits under § 

1117(a) is not synonymous with an award of monetary damages: ‘[a]n accounting for 

profits... is an equitable remedy subject to the principles of equity.’”)). 

Requesting equitable relief “invokes the district court’s inherent equitable 

powers to order preliminary relief, including an asset freeze, in order to assure the 

availability of permanent relief.” Levi Strauss & Co. v. Sunrise Int’l Trading Inc., 51 

F.3d 982, 987 (11th Cir. 1995) (citing Federal Trade Commission v. United States Oil 

and Gas Corp., 748 F.2d 1431, 1433-34 (11th Cir. 1984)). 

In light of the inherently deceptive nature of the counterfeiting business, and 

Defendants’ blatant violation of the federal trademark laws, A&F has good reason to 

believe Defendants will hide or transfer their ill-gotten assets beyond the jurisdiction 

of this Court unless those assets are restrained. 

6



261 

Based on the foregoing reasons, we RECOMMEND that A&F’s Ex Parte Motion 

[D.E. 6] be GRANTED. It should also be ORDERED and ADJUDGED as follows: 

TEMPORARY RESTRAINING ORDER 

1. Each Defendant, their officers, directors, employees, agents, subsidiaries 

distributors, and all persons in active concert or participation with Defendants having 

notice of this Order are hereby temporarily restrained: 

a. From manufacturing, importing, advertising, promoting, offering 

to sell, selling, distributing, or transferring any products bearing 

the A&F Marks, or any confusingly similar trademarks, other than 

those actually manufactured or distributed by A&F; and 


otherwise disposing of: (i) any products, not manufactured or 

distributed by A&F, bearing the A&F Marks, or any confusingly 

similar trademarks; or (ii) any evidence relating to the 

manufacture, importation, sale, offer for sale, distribution, or 

transfer of any products bearing the A&F Marks, or any 

confusingly similar trademarks. 

2. Each Defendant, their officers, directors, employees, agents, subsidiaries, 


notice of this Order shall immediately discontinue the use of the A&F Marks or any 

confusingly similar trademarks, on or in connection with all Internet websites owned 

7



261 

and operated, or controlled by them including the Internet websites operating under 

the Subject Domain Names; 



notice of this Order shall immediately discontinue the use of the A&F Marks, or any 

confusingly similar trademarks within domain name extensions, metatags or other 

markers within website source code, from use on any webpage (including as the title 

of any web page), any advertising links to other websites, from search engines’ 

databases or cache memory, and any other form of use of such terms which is visible 

to a computer user or serves to direct computer searches to websites registered by, 

owned, or operated by each Defendant, including the Internet websites operating under 


4. Each Defendant shall not transfer ownership of the Subject Domain 


5. The domain name Registrars for the Subject Domain Names are directed 

to transfer to A&F’s counsel, for deposit with this Court, domain name certificates for 


6. The Registrars and the top-level domain (TLD) Registries for the Subject 

Domain Names, within ten (10) days of receipt of this Temporary Restraining Order, 

shall change, or assist in changing, the Registrar of record for the Subject Domain 

Names, excepting any such domain names which such Registries have been notified 

in writing by the A&F have been or will be dismissed from this action, to a holding 

8



261 

account with the United States based Registrar, GoDaddy.com, Inc. As a matter of 

law, this Temporary Restraining Order shall no longer apply to any Defendant or 

associated domain name dismissed from this action. Upon transfer of the Subject 

Domain Names into the holding account, GoDaddy.com, Inc. will hold the Subject 

Domain Names in trust for the Court during the pendency of this action. Additionally, 

GoDaddy.com, Inc. shall immediately update the Domain Name System (“DNS”) data 

it maintains for the Subject Domain Names, which links the domain names to the IP 

addresses where their associated websites are hosted, to NS1.MEDIATEMPLE.NET 

and NS2.MEDIATEMPLE.NET, which will cause the domain names to resolve to the 

website where a copy of the Complaint, Summonses, and Temporary Restraining Order 

and other documents on file in this action are displayed. Alternatively, GoDaddy.com, 

Inc. may institute a domain name forwarding which will automatically redirect any 

visitor to the Subject Domain Names to the following Uniform Resource Locator 

(“URL”) http://www.servingnotice.com/afpp/index.html whereon a copy of the 

Complaint, Summonses, and Temporary Restraining Order and other documents on 

file in this action are displayed. After GoDaddy.com, Inc. has effected this change the 

Subject Domain Names shall be placed on Lock status, preventing the modification or 

deletion of the domains by the Registrar or the Defendants; 

7. A&F may enter the Subject Domain Names into Google’s Webmaster 

Tools and cancel any redirection of the domains that have been entered there by 

Defendants which redirect traffic to the counterfeit operations to a new domain name 

and thereby evade the provisions of this Order; 

9



261 

8. Each Defendant shall preserve copies of all their computer files relating 

to the use of any of the Subject Domain Names and shall take all steps necessary to 

retrieve computer files relating to the use of the Subject Domain Names that may have 

been deleted before the entry of this Order; 

9. Upon receipt of this Order, PayPal, Inc. (“PayPal”) and its related 

companies and affiliates shall immediately freeze all PayPal accounts related to the 

PayPal account recipients: huangqingan4@hotmail.com, wealharry@hotmail.com, 

wangyunhong01@hotmail.com, yingkesell@hotmail.com, haoyanmei1986@gmail.com, 

anftu@hotmail.com, 13783007710@qq.com, Sunhe719@gmail.com, 

handfolk2011@hotmail.com and Ning-Focus@Hotmail.com, and any other related 

accounts of the same customer(s), as well as any other accounts which transfer funds 

into the same financial institution account(s) as any of the other PayPal accounts 

subject to this Order; 

10. Upon receipt of notice of this Order, PayPal and its related companies and 

affiliates shall immediately freeze all PayPal accounts linked to, associated with, or 

that transmit funds into Defendants’ identified bank accounts, including but not 

limited to, the Bank of China Putian Branch, Bank Account Number ending in -4662 

and Bank of China Putian Branch, Bank Account Number ending in -2302, and any 

other related accounts of the same customers; 8 

8 

The complete account information is filed under seal at [D.E. 8]. 

10



261 

11. PayPal shall also immediately divert to a holding account for the trust of 

the Court all funds currently in, or which during the pendency of this Order come in 

to, all PayPal accounts related to the PayPal account recipients 

huangqingan4@hotmail.com, wealharry@hotmail.com, wangyunhong01@hotmail.com, 

yingkesell@hotmail.com, haoyanmei1986@gmail.com, anftu@hotmail.com, 

13783007710@qq.com, Sunhe719@gmail.com, handfolk2011@hotmail.com and Ning- 

Focus@Hotmail.com, and any other related accounts of the same customer(s), and/or 

all PayPal accounts linked to, associated with, or that transmit funds into Defendants’ 

identified bank accounts to the Bank of China Putian Branch, Bank Account Number 

ending in 4662 and Bank of China Putian Branch Bank Account Number ending 

in2302, and any other related accounts of the same customers as well as any other 

accounts which transfer funds into the same financial institution account(s) as any of 

the other PayPal accounts subject to this Order; 

12. PayPal shall further, within fifteen (15) days of receiving this Order, 

provide A&F’s counsel with all data which identifies the PayPal accounts frozen, as 

well as an accounting of the funds in the frozen accounts. Such freezing of the accounts 

and the disclosure of the related financial institution account information shall be 

made without notice to the account owners or the financial institutions until further 

order fo this Court. PayPal shall receive and maintain this Order and its contends as 

confidential until further order of this Court. A&F’s counsel shall bear any costs to 

PayPal arising from this request; 

11



261 

13. This Temporary Restraining Order shall remain in effect until the date 

for the hearing on the Motion for Preliminary Injunction set forth below, or until such 

further dates as set by the Court or stipulated to by the parties; 

BOND TO BE POSTED 

14. Pursuant to 15 U.S.C. § 1116(d)(5)(D), A&F shall post a bond in the 

amount of Ten Thousand Dollars and Zero Cents ($10,000.00), as payment of damages 

to which Defendants may be entitled for a wrongful injunction or restraint. A&F shall 

post the bond prior to requesting the Registry to transfer control of the Subject Domain 

Names; 

PRELIMINARY INJUNCTION 

15. An evidentiary hearing shall take place on Wednesday, April 11, 2012, at 

3:00 p.m., James Lawrence King Bldg., 99 N.E. Fourth Street, Tenth Floor, Courtroom 

5, Miami, Florida, before the undersigned Magistrate Judge. Defendants shall present 

evidence at that hearing why the temporary restraining order should be vacated and 

why a preliminary injunction order pending trial not be entered. 

16. A&F shall serve a copy of the Ex Parte Application for TRO and this Order 

on each Defendant via their known e-mail addresses, specifically: upon Defendant 

4cheapnamebrandclothes.com at the e-mail addresses “sales@4cheapbags.com” and 

“cheapbags4@hotmail.com,” Defendant 4cheapnambrandhandbags.com at the e-mail 

address “chinabrandclothing@hotmail.com,” and upon the remaining Defendants via 

the corresponding e-mail addresses provided to the Registrars responsible for the 

Subject Domain Names and the customer service e-mail addresses used to 

12



261 

communicate with A&F’s investigator all of which are identified on Schedule “B” 

appended hereto. In addition, A&F shall post a copy of the Complaint, Summonses, 

the Ex Parte Application for TRO and this Order, as well as all other documents filed 

in this action on the website located at http://www.servingnotice.com/afpp/index.html, 

upon transfer of the Subject Domain Names into the holding account with 

GoDaddy.com, Inc., and such notice so given shall be deemed good and sufficient 

service thereof. Any response or opposition to A&F’s Motion for Preliminary Injunction 

must be filed with the Court and served on A&F’s counsel by April 9, 2012. A&F shall 

file a Reply Memorandum, if any, on or before April 11, 2012 at 12:00 p.m. The above 

dates may be revised upon stipulation by all parties and approval of this Court. 

Defendants are hereby on notice that failure to appear at the hearing may result in the 

imposition of a preliminary injunction against them pursuant to 15 U.S.C. § 1116(d) 

and Fed. R. Civ. P. 65. 

April, 2012. 

DONE AND SUBMITTED in Chambers at Miami, Florida, this 4th day of 

13 

/s/ Edwin G. Torres 

Edwin G. Torres 

United States Magistrate Judge

Case 1:12-cv-21088-UU 1:12-cv-23295-JLK 1:12-cv-21088-UU Document 6-22 10 6-10 Entered Entered on on on FLSD FLSD Docket Docket 04/04/2012 03/19/2012 09/12/2012 Page Page 14 17 105 of of 15 18 of 

261 

SCHEDULE A 



Defendant 1 



Defendant 2 4cheapnambrandhandbags.com 

Defendant 3 abercrombieandfitchuksales.org 

Defendant 4 abercrombie-clothes.net 

Defendant 5 abercrombieoutlett.com 

Defendant 6 afonlinesell.com 

Defendant 7 icheapclothing.com 

Defendant 8 mygo2like.com 

Defendant 9 polowholesaler.com 

Defendant 10 spring-grass.com 

14

Case 1:12-cv-21088-UU 1:12-cv-23295-JLK 1:12-cv-21088-UU Document 6-22 10 6-10 Entered Entered on on on FLSD FLSD Docket Docket 04/04/2012 03/19/2012 09/12/2012 Page Page 15 18 106 of of 15 18 of 

261 

Defendant 

Number 

SCHEDULE “B” 



Defendant 1 

Defendant / Subject Domain Name E-Mail Addresses 



Defendant 2 4cheapnambrandhandbags.com 

Defendant 3 abercrombieandfitchuksales.org 

Defendant 4 abercrombie-clothes.net 

Defendant 5 abercrombieoutlett.com 

Defendant 6 afonlinesell.com 

Defendant 7 icheapclothing.com 

Defendant 8 mygo2like.com 

Defendant 9 polowholesaler.com 

Defendant 10 spring-grass.com 

15 

12658867@qq.com 

sales@4cheapbags.com 

cheapbags4@hotmail.com 

rekarman@gmail.com 

chinabrandclothing@hotmail.com 

354899963632@qq.com 

noreply@vcom-inc.com 

service@vcom-inc.com 

sam201108@163.com 

anfnsam@gmail.com 

afsales2006@hotmail.com 

506969707@qq.com 

abercrombiesale@hotmail.com 

szykhr@163.com 

anfnsam@gmail.com 

afsales2006@hotmail.com 

afonlinesell@hotmail.com 


NiceBoots4Girls@hotmail.com 

arthur688@hotmail.com 

arthur@mygo2like.com 

arthurshoeseller@gmail.com 

wholesalepoloshirtonline@gmail.com 

kamewholesales@hotmail.com 

alexlee200248@yahoo.com 

spring-service@hotmail.com 

spring-sales@263.net

Case 1:11-cv-24094-MGC Document 17 Entered on FLSD Docket 03/23/2012 Page 1 of 1 


261 


vs. 

Plaintiffs 

DANYU WU, et al., 

Defendants. 

_________________________________/ 



Case No. 11-24094-Civ-COOKE/TURNOFF 


THIS MATTER was referred to the Honorable William C. Turnoff, United States 

Magistrate Judge, for a Report and Recommendation on the Plaintiff’s Ex Parte Application for 

Entry of Temporary Restraining Order, Preliminary Injunction, and Order Restraining Transfer of 

Assets (ECF No. 6). On February 1, 2012, Judge Turnoff held a hearing on Plaintiff’s Application. 

Judge Turnoff has now issued a Report and Recommendation (ECF No. 16) recommending that 

Plaintiff’s Application for Temporary Restraining Order be granted. After reviewing the matter de 

novo, I find Judge Turnoff’s Report clear, cogent, and compelling. 

Accordingly, Judge Turnoff’s Report and Recommendation (ECF No. 16) is AFFIRMED 

and ADOPTED. Plaintiff’s Application for Temporary Restraining Order (ECF No. 6) is 

GRANTED, consistent with Judge Turnoff’s Report. 

DONE and ORDERED in chambers at Miami, Florida, this 23 rd day of March 2012. 

Copies furnished to: 

William C. Turnoff, U.S. Magistrate Judge 

Counsel of record



261 


vs. 

Plaintiffs, 

DANYU WU, et al., 

Defendants. 

_____________________/ 



CASE NO. 11-24094- CIV-COOKE/Turnoff 

REPORT AND RECOMMENDATION REGARDING PLAINTIFFS’ EX PARTE 

APPLICATION FOR ENTRY OF TEMPORARY RESTRAINING ORDER, 

PRELIMINARY INJUNCTION, AND ORDER RESTRAINING TRANSFER OF 

ASSETS TIED TO COUNTERFEITING OPERATION 

THIS CAUSE is before the Court on Plaintiffs’ Ex Parte Application for Entry of 

Temporary Restraining Order, Preliminary Injunction, and Order Restraining Transfer of Assets Tied 

to the Counterfeiting Operation (ECF No. 6). This matter was referred to the undersigned for Report 

and Recommendation by the Honorable Marcia G. Cooke, United States District Judge for the 

Southern District of Florida. (ECF No. 11). A hearing on this matter was held before the undersigned 

on February 1, 2012. (ECF No. ). The Court has carefully reviewed the Application, the entire court 

file, the applicable law, and is otherwise fully advised in the premises. 

By the instant Application, Plaintiffs, adidas AG, adidas International Marketing B.V., adidas 

America, Inc., Reebok International Limited, and Reebok International Ltd. (collectively 

“Plaintiffs”), move ex parte, for entry of a temporary restraining order against Defendants Danyu 

Wu, the Partnerships and Unincorporated Associations identified on Schedule “A” hereto, and Does 

Page 1 of 20



261 

1-10 (collectively “Defendants”), and for an order restraining the financial accounts used by 

Defendant Danyu Wu, pursuant to 15 U.S.C. § 1116 and Fed. R. Civ. P. 65. 

I. Factual Background 

The Court bases this Order on the following facts from Plaintiffs’ Complaint, Application 

for TRO, and supporting evidentiary submissions. 

Plaintiff adidas AG (“adidas AG”) is a joint stock company organized and existing under the 

laws of the Federal Republic of Germany, having its office and principal place of business at Postach 

1120, D-91072 Herzogenaurach, Federal Republic of Germany. (ECF No. 1) at 4. Plaintiff adidas 

International Marketing B.V. (“adidas International”) is a corporation organized and existing under 

the laws of the Netherlands, having its principal place of business in the Netherlands. Id. at 5. 

Plaintiff adidas America, Inc. (“adidas America”) is a corporation organized and existing under the 

laws of the State of Delaware, having its principal place of business at 5055 N. Greeley Avenue, 

Portland, Oregon, 97217. Id. at 6. adidas International and adidas America (collectively, “adidas”) 

are wholly owned by adidas AG and its affiliates. Id. at 5-6. 

adidas is engaged in the manufacture, promotion, distribution, and sale in interstate 

commerce, including within this judicial district, of athletic footwear, apparel, and sporting 

equipment under the trademarks , , and (collectively, the “adidas Marks”). 

Declaration of Jeni B. Zuercher in Support of Plaintiffs’ Ex Parte Application for Entry of 

Temporary Restraining Order, Preliminary Injunction, and Order Restraining Transfer of Assets Tied 

to the Counterfeiting Operation [“Zuercher Decl.”] (ECF 6-18) at 4-5. 

Page 2 of 20



261 

adidas is the owner of multiple trademark registrations for the adidas Marks, including the 

following valid and incontestable trademark registrations, issued by the United States Patent and 

Trademark Office: 

Trademark 

Registration 

Number 

Registration 

Date 

ADIDAS 0,891,222 May 19, 1970 

0,973,161 

November 20, 

1973 

1,300,627 October 16, 1984 

1,310,140 

2,411,802 

December 18, 

1984 

December 12, 

2000 

Page 3 of 20 

Class / Goods 

IC25 - sportswear namely, suits, shorts, 

pants, tights, shirts, gloves, and the like; 

jerseys; socks; sport shoes namely, track 

and field training shoes, basketball shoes, 

and tennis shoes. 

IC 13 - tote bags 

IC 25 - specific purpose athletic shoes; 

general purpose sport shoes, sports wearnamely, 

suits, shorts, pants, tights, shirts, 

jerseys, socks, and gloves. 

IC 025 - sportswear namely, suits, shorts, 

pants, tights, shirts, jerseys, socks, gloves, 

jackets, coats, swimwear, sweaters, caps, 

pullovers, warm-up suits, rain suits, ski 

suits, jump suits, boots, shoes, slippers. 

IC 025 - sportswear-namely, suits, shorts, 

pants, tights, shirts, jerseys, socks, gloves, 

jackets, coats, swimwear, sweaters, caps, 

pullovers, warm-up suits, rain suits, ski 

suits, jump suits, boots, shoes, slippers. 

IC 018 - all purpose sport bags, athletic 

bags, traveling bags, backpacks, knapsacks, 

beach bags. 

IC 025 - sports and leisure wear, namely, 

shorts, pants, shirts, t-shirts, jerseys, tights, 

socks, gloves, jackets, swimwear, caps and 

hats, pullovers, sweat-shirts, sweat suits, 

track suits, warm-up suits, rain suits; boots, 

slippers, sandals, specific purpose athletic 

shoes and general all purpose sports shoes. 

IC 028 - sports balls and playground balls; 

guards for athletic use, namely, shin guards, 

knee guards and leg guards.



261 

Trademark 

Registration 

Number 

Registration 

Date 

3,104,117 June 13, 2006 

Page 4 of 20 

Class / Goods 

IC 009 - optical apparatus and instruments, 

namely, eyeglasses and sunglasses. 

IC 014 - horological and chronometric 

instruments, namely, watches. 

IC 018 - leather and imitations of leather, 

and goods made from these materials in the 

nature of bags for general and sport use, 

namely handbags, tote bags, waist packs, 

overnight bags, backpacks, knapsacks and 

beach bags; trunks; traveling bags for 

general and sport use; leather and imitations 

of leather and goods made from these 

materials, namely, wallets, briefcases, and 

key cases. 

IC 025 – sports and leisure wear, namely 

suits, shorts, pants, sweatpants, skirts, 

skorts, dresses, blouses, shirts, t-shirts, 

sleeveless tops, polo shirts, vests, jerseys, 

sweaters, sweatshirts, pullovers, coats, 

jackets, track suits, training suits, warm-up 

suits, swimwear, underwear, socks, gloves, 

scarves, wristbands and belts; headgear, 

namely caps, hats, visors, headbands; 

athletic footwear and leisure foot wear, 

namely boots, sandals, specific purpose 

athletic shoes and general purpose sports 

shoes. 

The adidas Marks are used in connection with the manufacture and distribution of quality 

goods in at least the categories identified above. Zuercher Decl. (ECF No. 6-18) at 5; see also 

United States Trademark Registrations for the adidas Marks at issue [“adidas Trademark 

Registrations”] attached as Composite Exhibit A to the Zuercher Decl. 

Plaintiff Reebok International Limited (“Reebok International”) is a corporation organized 

and existing under the laws of England, having its principal place of business at 11/12 Pall Mall, 

London SWI Y 5LU, England. (ECF No. 1) at 7. Plaintiff Reebok International Ltd. (“Reebok



261 

Ltd.”) is a corporation organized and existing under the laws of the Commonwealth of 

Massachusetts, having its principal place of business at 1895 J.W. Foster Boulevard, Canton, 

Massachusetts, 02021. Id. at 8. Reebok International and Reebok Ltd. are wholly owned by adidas 

AG and its affiliates. Id. at 7-8. Reebok International and Reebok Ltd. shall be referred to herein 

collectively as “Reebok.” 

Reebok is engaged in the manufacture, promotion, distribution, and sale in interstate 

commerce, including within this judicial district, of athletic footwear, apparel, and sporting 

equipment under the trademarks REEBOK, RBK, and (collectively, the “Reebok Marks”). 

Zuercher Decl. (ECF No. 6-18) at 13-14. 

Reebok is the owner of multiple trademark registrations for the Reebok Marks, including the 

following valid and incontestable trademark registrations, issued by the United States Patent and 

Trademark Office: 

Trademark 

Registration 

Number 

Registration Date Class / Goods 

REEBOK 1,133,704 April 22, 1980 IC 25 - shoes for use in athletic sports. 

REEBOK 1,390,793 April 22, 1986 

1,848,848 August 9, 1994 

Page 5 of 20 

IC 18 - all purpose sport bags. 

IC 25 - sweatpants, shorts, sweaters, polo 

shirts, hats, visors, headbands, 

sweatbands, t-shirts, sweatshirts. 

IC 018 - all purpose sport bags, duffel 

bags, tote bags, knapsacks, and shoulder 

bags. 

IC 025 - footwear and apparel; namely, tshirts, 

shirts, sweatshirts, sweaters, 

jackets, hats, visors, socks, sweatpants, 

pants, shorts, skirts, unitards, and leotards.



261 

Trademark 

Registration 

Number 

RBK 3,074,802 March 28, 2006 


Page 6 of 20 

IC 09 - eyewear, namely, eyewear cases; 

eyewear cleaning cloths; sunglasses; 

protective helmets for hockey, and skating. 

IC 025 - footwear; headwear; apparel, 

namely, sweatpants, sweatshirts, shirts, 

shorts, sweaters, socks, jackets, sweat 

suits, warm-up suits, shooting shirts, 

fleece tops, tank tops, polo shirts, pants, 

athletic bras, leggings, skirts, turtlenecks, 

vests, dresses, athletic uniforms, gloves, 

infant wear, running suits. 

IC 028 - sports equipment, namely, 

basketballs, footballs, rugby balls, soccer 

balls, in-line skates, hockey skates; 

protective hockey equipment, namely shin 

pads, elbow pads, shoulder pads, and 

pants; protective in-line skating 

equipment, namely kneepads and elbow 

pads. 

The Reebok Marks are used in connection with the manufacture and distribution of quality 

goods in at least the categories identified above. Zuercher Decl. (ECF No. 6-18) at 14; see also 

United States Trademark Registrations for the Reebok Marks at issue [“Reebok Trademark 

Registrations”] attached as Composite Exhibit B to the Zuercher Decl. 

Plaintiffs retained Investigative Consultants, a licensed private investigative firm, to 

investigate the sale of counterfeit versions of Plaintiffs’ respective products by Defendants. Zuercher 

Decl. (ECF No. 6-18) at 23; Declaration of Brandon Tanori in Support of Plaintiffs’ Ex Parte 

Application for Entry of Temporary Restraining Order, Preliminary Injunction, and Order 

Restraining Transfer of Assets Tied to the Counterfeiting Operation [“Tanori Decl.”] (ECF No. 6-21) 

at 3. In August 2011, Brandon Tanori (“Tanori”), an employee of Investigative Consultants, placed



261 

an order for the purchase of a pair of shoes bearing one or more of the adidas Marks at issue via the 

Internet website operating under the domain name, helloadidas.com, to be shipped directly to his 

address located in Miami, Florida. Tanori Decl. (ECF No. 6-21) at 4, and Composite Exhibit A 

attached thereto. Tanori’s purchase was processed entirely online, and he received payment 

instructions and confirmation of his purchase electronically via the e-mail address, 

helloadidas@live.com. Tanori Decl. (ECF No. 6-21) at 5 and Composite Exhibit B attached 

thereto. Tanori finalized payment for his purchase using Western Union Financial Services, Inc. 

(“Western Union”) to the Western Union payee, “Danyu Wu,” and was given a Money Transfer 

Control Number (“MTCN”) of 062-664-6191. Id. 

In August 2011, Tanori also placed an order for the purchase of a pair of shoes bearing one 

or more of the Reebok Marks at issue via the Internet website operating under the domain name, 

reebokonlineoutlet.com, to be shipped directly to his address located in Florida. Tanori Decl. (ECF 

No. 6-21) at 7, and Composite Exhibit D attached thereto. Tanori’s purchase was processed entirely 

online, and he received confirmation of his purchase electronically via the e-mail address, 

reebokonlineoutlet@gmail.com. Id. at 8, and Composite Exhibit E attached thereto. 

Upon his receipt of the purchased goods, Tanori forwarded the products to Plaintiffs’ 

representative, Jeni B. Zuercher, for physical inspection. Tanori Decl. (ECF No. 6-21) at 6, 9, and 

Composite Exhibits C and F attached thereto; Zuercher Decl. (ECF No. 6-18) at 24, 26. Ms. 

Zuercher personally examined the adidas-branded shoes purchased by Tanori via helloadidas.com, 

and the Reebok-branded shoes purchased by Tanori via reebokonlineoutlet.com, and she determined 

each were non genuine, unauthorized versions of Plaintiffs’ respective products. Zuercher Decl. 

(ECF No. 6-18) at 25, 27. Additionally, Ms. Zuercher reviewed and visually inspected the Internet 

Page 7 of 20



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websites operating under the partnership and/or unincorporated association names identified on 

Schedule “A” hereto (the “Subject Domain Names”), as well as pictures of items bearing the adidas 

Marks and Reebok Marks offered for sale on the Internet web sites, and determined the products 

were unauthorized, non-genuine versions of Plaintiffs’ respective products. Id. at 28; see also 

relevant web pages from Defendants’ Internet web sites operating under the Subject Domain Names 

[“Defendants’ Websites”] attached as Composite Exhibit A to the Declaration of Stephen M. 

Gaffigan in Support of Plaintiffs’ Ex Parte Application for Entry of Temporary Restraining Order, 

Preliminary Injunction, and Order Restraining Transfer of Assets Tied to the Counterfeiting 

Operation [“Gaffigan Decl.”] (ECF No. 6-2). 

Based on the investigations, Plaintiffs allege Defendants have advertised, offered for sale, 

and/or sold at least (I) sports and leisure wear, namely, suits, shirts, t-shirts, polo shirts, jerseys, 

jackets, track suits, and warm-up suits; headgear, namely hats; athletic footwear and leisure foot 

wear, namely boots, sandals, specific purpose athletic shoes and general purpose sports shoes; and 

all purpose sport bags, athletic bags, and backpacks bearing counterfeit and infringing trademarks 

which are exact copies of the adidas Marks, and (ii) footwear and apparel namely shirts, t-shirts, and 

athletic uniforms bearing counterfeit and infringing trademarks which are exact copies of the Reebok 

Marks. Zuercher Decl. (ECF No. 6-18) at 22; Tanori Decl. (ECF No. 6-21) at 4, 6-7, 9, and 

Composite Exhibits A, C, D, and F attached thereto; Gaffigan Decl. (ECF No. 6-2) at 2-4, and 

Exhibits B and C attached thereto; see also Defendants’ Websites attached as Composite Exhibit A 

to the Gaffigan Decl. Defendants are not now, nor have they ever been, authorized or licensed to use, 

reproduce, or make counterfeits, reproductions, and/or colorable imitations of the adidas Marks and 

Reebok Marks (collectively “Plaintiffs’ Marks”). Zuercher Decl. (ECF No. 6-18) at 22. 

Page 8 of 20



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The declarations Plaintiffs submitted in support of their Application for TRO support the 

following conclusions of law: 

A. Plaintiffs have a very strong probability of proving at trial that consumers are likely 

to be confused by Defendants’ advertisement, promotion, sale, offer for sale, and/or distribution of 

athletic footwear, apparel, and sporting equipment bearing counterfeits, reproductions, and/or 

colorable imitations of Plaintiffs’ Marks, and that the products Defendants are selling are copies of 

Plaintiffs’ respective products that bear copies of the adidas Marks on sports and leisure wear, 

namely, suits, shirts, t-shirts, polo shirts, jerseys, jackets, track suits, and warm-up suits; headgear, 

namely hats; athletic footwear and leisure foot wear, namely boots, sandals, specific purpose athletic 

shoes and general purpose sports shoes; and all purpose sport bags, athletic bags, and backpacks, and 

the Reebok Marks on footwear and apparel, namely shirts, t-shirts, and athletic uniforms. 

B. Because of the infringement of Plaintiffs’ Marks, Plaintiffs are likely to suffer 

immediate and irreparable injury if a temporary restraining order is not granted. It clearly appears 

from the following specific facts, as set forth in Plaintiffs’ Complaint, Application for TRO, and 

accompanying declarations on file, that immediate and irreparable loss, damage, and injury will 

result to Plaintiffs and to consumers before Defendants can be heard in opposition unless Plaintiffs’ 

request for ex parte relief is granted: 

1. Defendants are operating Internet businesses which advertise, offer for sale, 

and sell, at least, sports and leisure wear, namely, suits, shirts, t-shirts, polo shirts, jerseys, jackets, 

track suits, and warm-up suits; headgear, namely hats; athletic footwear and leisure foot wear, 

namely boots, sandals, specific purpose athletic shoes and general purpose sports shoes; and all 

Page 9 of 20



261 

purpose sport bags, athletic bags, and backpacks bearing counterfeit and infringing trademarks in 

violation of adidas’ rights; and footwear and apparel namely shirts, t-shirts, and athletic uniforms 

bearing counterfeit and infringing trademarks in violation of Reebok's rights; 

2. There is good cause to believe that more counterfeit and infringing products 

bearing Plaintiffs’ respective trademarks will appear in the marketplace; that consumers may be 

misled, confused, and disappointed by the quality of these products; and that Plaintiffs may suffer 

loss of sales for their respective genuine products; 

3. There is good cause to believe that if Plaintiffs proceed on notice to 

Defendants on this Application for TRO, Defendants can easily and quickly transfer the registrations 

for many of the Subject Domain Names, or modify registration data and content, change hosts, and 

redirect traffic to other websites, thereby thwarting Plaintiffs’ ability to obtain meaningful relief; 


counterfeit and infringing branded goods if a temporary restraining order is issued is far outweighed 

by the potential harm to Plaintiffs, their respective reputations, and goodwill as manufacturers of 

quality products if such relief is not issued; and 

5. The public interest favors issuance of the temporary restraining order in order 

to protect Plaintiffs’ respective trademark interests and protect the public from being defrauded by 

the palming off of counterfeit goods as genuine goods of the respective Plaintiffs. 

C. Under 15 U.S.C. § 1117(a), Plaintiffs may be entitled to recover, as an equitable 

remedy, the illegal profits gained through Defendants’ distribution and sales of goods bearing 

counterfeits and infringements of Plaintiffs’ Marks. See Reebok Int’l, Ltd. v. Marnatech Enters., Inc., 

970 F.2d 552, 559 (9th Cir. 1992) (quoting Fuller Brush Products Co. v. Fuller Brush Co., 299 F.2d 

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261 

772, 777 (7th Cir. 1962) (“An accounting of profits under § 1117(a) is not synonymous with an 

award of monetary damages: ‘[a]n accounting for profits . . . is an equitable remedy subject to the 

principles of equity.’”)). 

D. Requesting equitable relief “invokes the district court’s inherent equitable powers to 

order preliminary relief, including an asset freeze, in order to assure the availability of permanent 

relief.” Levi Strauss & Co. v. Sunrise Int’l Trading Inc., 51 F.3d 982, 987 (11th Cir. 1995) (citing 

Federal Trade Commission v. United States Oil and Gas Corp., 748 F.2d 1431, 1433-34 (11th Cir. 

1984)). 


Defendants’ blatant violation of federal trademark laws, Plaintiffs have good reason to believe 



Recommendation 

Accordingly, after due consideration, it is hereby RESPECTFULLY RECOMMENDED 

that Plaintiffs’ Ex Parte Application for a Temporary Restraining Order and Order Restraining 

Transfer of Assets Tied to the Counterfeiting Operation (ECF No. 6) be GRANTED as follows: 

(1) Each Defendant, their officers, directors, employees, agents, subsidiaries, distributors, 

and all persons in active concert or participation with them having notice of this Order are hereby 

temporarily restrained: 


selling, distributing, or transferring any products bearing the adidas Marks 

Page 11 of 20



261 

and/or the Reebok Marks, or any confusingly similar trademarks, other than 

those actually manufactured or distributed by Plaintiffs; and 


disposing of: (I) any products, not manufactured or distributed by Plaintiffs, 

bearing the adidas Marks and/or the Reebok Marks, or any confusingly 

similar trademarks; or (ii) any evidence relating to the manufacture, 

importation, sale, offer for sale, distribution, or transfer of any products 

bearing the adidas Marks and/or the Reebok Marks, or any confusingly 

similar trademarks. 


and all persons in active concert or participation with them having notice of this Order shall 

immediately discontinue the use of the adidas Marks and/or the Reebok Marks or any confusingly 

similar trademarks, on or in connection with all Internet websites owned and operated, or controlled 

by them, including the Internet websites operating under the Subject Domain Names; 



immediately discontinue the use of the adidas Marks and/or the Reebok Marks, or any confusingly 

similar trademarks within domain name extensions, metatags or other markers within website source 

code, from use on any webpage (including as the title of any web page), any advertising links to other 

websites, from search engines’ databases or cache memory, and any other form of use of such terms 

which is visible to a computer user or serves to direct computer searches to websites registered by, 

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261 

owned, or operated by Defendants, including the Internet websites operating under the Subject 

Domain Names; 

(4) Defendants shall not transfer ownership of the Subject Domain Names during the 


(5) The domain name Registrars for the Subject Domain Names are directed to transfer 

to Plaintiffs’ counsel, for deposit with this Court, domain name certificates for the Subject Domain 

Names; 

(6) Upon entry of this Order, Plaintiffs shall provide a copy of the Order by e-mail to the 

registrar of record for each of the Subject Domain Names, so that the registrar of record of each of 

the Subject Domain Names may, in turn, notify each registrant of the Order and provide notice of 

the locking of the domain name to the registrant of record. After providing such notice to the 

registrars so the domain names may be locked, Plaintiffs shall also provide notice and a copy of this 

Order to the registrant of each Subject Domain Name via e-mail to the e-mail address provided as 

part of the domain registration data for each of the Subject Domain Names identified in Composite 

Exhibit B to the Declaration of Stephen M. Gaffigan in Support of the Application for TRO. After 

forty-eight (48) hours have elapsed after provision of this Order to the registrars of record and the 

registrants, Plaintiffs shall provide a copy of this Order to the registries for the Subject Domain 

Names for the purposes described in Paragraph 7 infra. 

(7) The Registrars and the top-level domain (TLD) Registries for the Subject Domain 

Names, within ten (10) business days of receipt of this Temporary Restraining Order, shall change 

or assist in changing the Registrar of record for the Subject Domain Names, excepting any such 

domain names which such Registries have been notified in writing by Plaintiffs have been or will 

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261 

be dismissed from this action, to a holding account with the United States based Registrar, 

GoDaddy.com, Inc. As a matter of law, this Temporary Restraining Order shall no longer apply to 

any Defendant or associated domain name dismissed from this action. Upon the change of the 

Registrar of record for the Subject Domain Names to GoDaddy.com, Inc., GoDaddy.com, Inc. will 

maintain access to the Subject Domain Names in trust for the Court during the pendency of this 

action. Additionally, GoDaddy.com, Inc. shall immediately update the Domain Name System 

(“DNS”) data it maintains for the Subject Domain Names, which link the domain names to the IP 

addresses where their associated websites are hosted, to NS1.MEDIATEMPLE.NET and 

NS2.MEDIATEMPLE.NET, which will cause the domain names to resolve to the website where a 

copy of the Complaint, Summonses, Temporary Restraining Order, and all other documents on file 

in this action are displayed. Alternatively, GoDaddy.com, Inc. may institute a domain name 

forwarding which will automatically redirect any visitor to the Subject Domain Names to the 

following Uniform Resource Locator (“URL”) http://www.servingnotice.com/wu2/index.html, 

whereon a copy of the Complaint, Summonses, Temporary Restraining Order, and other documents 

on file in this action are displayed. After GoDaddy.com, Inc. has effected this change the Subject 

Domain Names shall be placed on Lock status, preventing the modification or deletion of the 

domains by the Registrar or Defendants; 

(8) Plaintiffs may enter the Subject Domain Names into Google’s Webmaster Tools and 

cancel any redirection of the domains that have been entered there by Defendants which redirect 

traffic to the counterfeit operations to a new domain name and thereby evade the provisions of this 

Order; 

(9) Defendants shall preserve copies of all their computer files relating to the use of any 

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261 

of the Subject Domain Names and shall take all steps necessary to retrieve computer files relating 

to the use of the Subject Domain Names that may have been deleted before the entry of this Order; 

(10) Upon receipt of this Order, Western Union Financial Services, Inc. (“Western 

Union”) shall divert all money transfers sent by United States consumers to Danyu Wu in Putian 

Fujian, People's Republic of China, with the date of birth and identification number provided by the 

recipient of MTCN 062-664-6191, and hold such transfers until it receives further direction from the 

Court; 1 

(11) In the event any money transfers are diverted in accordance with Paragraph 10 of this 

Order, Western Union shall be permitted to inform consumers who may contact Western Union 

about the transfers that the transfers are being held pursuant to a Court Order in adidas AG, et al. v. 

Wu, et al., Case No. 11-24094-CIV-COOKE, entered by the United States District Court for the 

Southern District of Florida and that they may contact Plaintiffs’ counsel for additional information; 

(12) Western Union shall also, within five business days of receiving this Order, provide 

to Plaintiffs’ counsel records of all money transfers that have been paid to Danyu Wu in Putian 

Fujian, People's Republic of China, with the date of birth and identification number provided by the 

recipient of MTCN 062-664-6191, as well as records of money transfers that have been diverted in 

accordance with Paragraph 10 of this Order. For any transfers that have been diverted in accordance 

with this Order, Plaintiffs’ counsel will respond to any consumer inquiries and will provide notice 

of the Order and the disposition of the transfers to any affected consumer. Western Union shall 

1 

Western Union is licensed to do business in the State of Florida by the Florida Office of Financial 

Regulation and is, therefore, subject to personal jurisdiction in this Court. See Gaffigan Decl. (ECF 

No. 6-2) at 9, and Exhibit E attached thereto. 

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261 

receive and maintain this Order and its contents as confidential as to Danyu Wu and any other 

recipient associated with the MTCN 062-664-6191, until further order of this Court; 

(13) This Temporary Restraining Order shall remain in effect until the date for the hearing 

on the Motion for Preliminary Injunction to be set by Judge Cooke, or until such further dates as set 

by the Court or stipulated to by the parties; 

(14) Pursuant to 15 U.S.C. § 1116(d)(5)(D), Plaintiffs shall post a bond in the amount of 

Ten Thousand Dollars and Zero Cents ($10,000.00), as payment of damages to which Defendants 

may be entitled for a wrongful injunction or restraint. Plaintiffs shall post the bond prior to 

requesting the Registry to transfer control of the Subject Domain Names; 

(15) A hearing shall be set before this Court by Judge Cooke at which time Defendants 

and/or any other affected persons may challenge the appropriateness of this Order and move to 

dissolve the same and at which time the Court will hear argument on Plaintiffs’ requested 

preliminary injunction; 

(16) Plaintiffs shall serve a copy of the Application for TRO and this Order on Defendant 

Danyu Wu by e-mail to the e-mail addresses helloadidas@live.comH and 1142424520@qq.com; and 

upon the remaining Defendants by e-mail as described in Paragraph 6 supra. In addition, Plaintiffs 

shall post a copy of the Application for TRO and this Order on the website located at 

http://servingnotice.com/wu2/index.html, upon transfer of the Subject Domain Names into the 

holding account with GoDaddy.com, Inc., and such notice so given shall be deemed good and 

sufficient service thereof. Any response or opposition to Plaintiffs’ Motion for Preliminary 

Injunction must be filed and served on Plaintiffs’ counsel forty-eight (48) hours prior to the hearing 

and filed with the Court, along with Proof of Service. Plaintiffs shall file any Reply Memorandum 

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261 

twenty-four (24) hours prior to the hearing. The above dates may be revised upon stipulation by all 

parties and approval of this Court. Defendants are hereby on notice that failure to appear at the 

hearing may result in the imposition of a preliminary injunction against them pursuant to 15 U.S.C. 

§ 1116(d) and Fed. R. Civ. P. 65. 

Pursuant to S.D. Fla. Magistrate Rule 4(b), the parties may serve and file written objections 

to this Recommendation with the Honorable Marcia G. Cooke, United States District Judge for the 

Southern District of Florida, within fourteen (14) days after being served with a copy of this Report 

and Recommendation. Failure to file timely objections shall bar the parties from attacking on appeal 

any factual findings contained herein. RTC v. Hallmark Builders, Inc., 996 F.2d 1144 (11th Cir. 

1993); LoConte v. Dugger, 847 F.2d 745 (11th Cir. 1988). 

RESPECTFULLY RECOMMENDED in Chambers in Miami, Florida, this 1st day of 

February 2012. 

cc: Hon. Marcia G. Cooke 

All Counsel of Record 

________________________________ 

WILLIAM C. TURNOFF 

United States Magistrate Judge 

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SCHEDULE A 

DEFENDANTS BY NUMBER AND SUBJECT DOMAIN NAMES 

Defendant 2 2010shopjerseys.org 

Defendant 3 4adidas.com 

Defendant 4 888shop-jerseys.com 

888shopjerseys.com 

ccmjerseys.com 

ccmjerseys.org 

Defendant 5 adiclothing.com 

Defendant 7 adidasempire.com 

Defendant 8 adidas-f50-adizero.com 

Defendant 9 adidasf50adizeroshop.com 

mercurial2012.com 

Defendant 10 adidasf50shoes.com 

wholesalenikemercurial.com 

Defendant 11 adidasjeremyscott.com 

Defendant 12 adidasjp.com 

Defendant 14 adidas-online-shop.com 

Defendant 15 adidas-originals.com 

Defendant 16 adidasporschedesignde.com 

Defendant 17 adidassbounce.com 

Defendant 19 adidasshoes001.com 

Defendant 20 adidasshoeshop.com 

Defendant 21 adidassmith.com 

Defendant 22 adidassuperstarshoes.com 

Defendant 24 adidastour360.com 

Defendant 25 adidaswings.com 

Defendant 27 selladidas.com 

Defendant 28 autobotshop.com 

Defendant 29 buyjerseysonline.com 

Defendant 30 buyjerseyswholesale.com 

Defendant 32 caminio.com 

Defendant 35 cheap001.com 

cheapnikevip.com 

Defendant 36 cheap999.com 

Defendant 38 cheapkicksforsale.com 

Defendant 39 cheapnbashoes.com 

Defendant 40 cheapshopping4u.com 

cheapnikeshoes2u.com 

Defendant 41 cn-jerseys.com 

Defendant 42 everysportuniforms.com 

Defendant 43 fashion333.com 

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261 

Defendant 46 footballjerseys4sale.com 

Defendant 48 helloadidas.com 

Defendant 49 ilove-shopping.org 

b2cshop.us 

love-shopping.org 

loveshopping.us 

iloveushopping.com 

Defendant 50 indoor-soccershoes.com 

indoor-soccershoess.com 

Defendant 51 inthestyleshop.com 

Defendant 52 jeremyscottsadidas.com 

Defendant 53 jeremyscottwing.com 

Defendant 54 jerseysforcheap.biz 

jerseysfromchina.net 

Defendant 55 jerseysfromchina.org 

jerseysfromchina.asia 

Defendant 56 jerseysfromchina.info 

Defendant 57 jerseysfull.com 

superstonejerseys.com 

Defendant 58 jerseys-googler.com 

Defendant 60 lowestbestexport.com 

Defendant 61 mercurialshoesoutlet.com 

Defendant 62 nba-basketball-shoes.net 

Defendant 63 nba-home.com 

Defendant 64 nikemercurialshoes.com 

nikemercurialvaporsuperfly3.com 

Defendant 65 nike-mercurial-store.com 

nikemercurialvaporsales.com 

Defendant 66 nikeshoes001.com 

Defendant 68 outlet-jerseys.com 

Defendant 69 plentystock.com 

Defendant 70 ptjerseys.com 

Defendant 75 reebok-member.com 

nfl-depot.com 

reebokmember.com 

reeboktrade.com 

sportjerseystown.org 

sportjerseys-town.net 

Defendant 77 shopadicolor.com 

Defendant 78 shopsoccerjerseys.com 

Defendant 79 soccercleats4u.com 

Defendant 80 soccercleatsnike.com 

Defendant 81 soccercleatsshoes.com 

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261 

Defendant 82 soccer-cleats-shoes.com 

adidaspredatoroutlet.com 

Defendant 83 soccerjerseycenter.com 

Defendant 84 socceroutlets.com 

socceroutletss.com 

Defendant 85 soccershoes4you.com 

Defendant 86 soccershoesforsales.com 

Defendant 87 soccershoesproducts.com 

nikemercurialoutlets.com 

Defendant 88 soccershoesstores.com 

Defendant 89 soccerusa4you.com 

officialsoccershoes.com 

Defendant 90 supercheapsoccer.com 

Defendant 92 toahk.com 

Defendant 93 topjerseysorder.com 

Defendant 94 tradeccc.net 

mosscc.net 

Defendant 95 trikotdiscount.com 

Defendant 96 usa-soccer-jersey.com 

Defendant 98 various-jersey-wholesale.com 

Defendant 99 well-sports.com 

inthestyleshop.com 

Defendant 101 wholesalejerseysfromchina.com 

jerseysfromchina.co 

Defendant 103 womenadidas.com 

Defendant 104 world-jerseys.com 

Defendant 105 world-soccer-shoes.com 

Page 20 of 20

Case 1:12-cv-21026-KMM Document 10 Entered on FLSD Docket 03/22/2012 Page 1 of 14 


261 

LOUIS VUITTON MALLETIER, S.A., 

VS. 

Plaintif: 

IN THE UNITED STATES DISTRICT COURT 

FOR THE SOUTHERN DISTRICT OF FLORIDA 

CHEAPW HOLESALEREPLICA.COM, et al., 

Defendants. 

Case No. 1:12-cv-21026-KMM 

ORDER GM NTING EX PARTE APPLICATION 

FOR A TEMPOM RY RESTRAINING ORDER 

/ 

THIS CAUSE came before the Court upon Plaintiff s Ex Parte Application for Entry of 

Temporat'y Restraining Order, Preliminary Injtmction, and Order Restraining Transfer of Assets 

Tied to the Counterfeiting Operation (çplaintifs Ex Parte Application') (ECF No. 6). UPON 

CONSD ERATION of the Motion, the pertinent portions of the Record , and being otherwise 

fuly advised in the premises, this Court enters the folowing Order . 

1 

1 . BACKGROUND 

Louis Vuiton is the registered owner of numerous trademarks used in connection with 

the manufacture and distribution of high quality handbags , walets, watches, stmglasses, belts, 

and key holders. Among these trademarks are trademarks mssociated with United States Patent 

and Trademrk Office (CUSPTO') No. 0,297,594, registered on September 20, 1932; USPTO 

No. 1,045,932, registered on August 10, 1976; USPTO No. 1,519,828, registered on January 10, 

1 The facts herein are taken from Plaintiffs Complaint (ECF No . 1) and Plaintiffs Ex Parte 

Application (ECF No. 6).



261 

1989; USPTO No. 1,794,905, registered on September 28, 1993; USPTO No. 1 ,938,808, 

registered on November 28, 1995; USPTO No. 1,990,760, registered on August 6 , 1996; USPTO 

No. 2,177,828, registered on August 4, 1998; USPTO No. 2,181,753, registered on August 18 , 

1998; USPTO No. 2,346,373, registered on May 2, 2000; USPTO No. 2,378,388, registered on 

August 22, 2000; USPTO No. 2,361,695, registered on June 27, 2000; USPTO No. 2,773 ,107, 

registered on October 14, 2003; USPTO No. 3,021,231, registered on November 29, 2005; 

USPTO No. 3,023,930, registered on December 6, 2005; USPTO No. 3,051,235, registered on 

January 24, 2006; and USPTO No. 3,107,072, registered on June 20, 2006 (colectively, çtzouis 

Vuitton Marks'). Defendants are unknown partnerships or unincorporated associations, residing 

in the People's Republic of China (



261 

purchase these products using Paypal (with a Paypal account and transaction number providcd 

by Defendants). Ld= At the conclusion of the process, Mr. Tanori forwarded detailed web page 

captures of the Louis Vuitton branded goods purchased to Louis Vuitton's representative , 

Nikolay Livadkin, for inspection. Ld= Mr. Livadkin personaly analyzed the detailed web page 

captures of the Louis Vuiton branded goods ptlrchased by Mr . Tanori and determined the 

purchased goods to be non-genuine, unauthorized Louis Vuiton branded products . See Decl. of 

Nikolay Livadkin, at !! 1 1, 14 (ECF No. 6). Additionaly, Mr. Livadkin conducted a review of 

the various Louis Vuitton branded products offered for sale by Defendants via the Internet 

websites operating tmder each of the Subject Domain Names, and determined the products were 

not genuine and/or authorized Louis Vuitton products. Ld -a at 111 12, 14. 

II. LEGAL STANDARD 

show that 

In order to prevail on a motion for an cx parte temporary restraining ordtr , Plaintiff must 

(1) it clearly appears from specific facts shown by affidavit or by the verified 

complaint that immediate and ireparable injury, loss, or dnmage wil result to the 

applicant before the adverse party or that party's atorney can be heard in 

opposition, and (2) the applicant's attomey certifies to the court in writing the 

efforts, if any, which have been made to give the notice and the remsons 

supporting the claim that notice should not be required. 

Fed. R. Civ. P. 6509. çAn exparte restraining order is an extreme remedy only to be used with 

the utmost caution.' Levine v. Comcoa. Ltd. , 70 F.3d 1191, 1194 (11th Cir. 1995). 

Once the moving party meets the threshold requirements of Rule 651) to secure an ex 

parte temporary restraining order, Plaintiff must demonstrate (1) a substantial likelihood of 

success on the merits; (2) that irreparable injury wil be suffered unless the injunction issues; (3) 

the threatened injury to the movant outweighs whatever dnmage the proposed injtmction may 

cause the opposing party; and (4) if issued, the injunction would not be adverse to the public 

3



261 

interest in order to obtain injunctive relief.Four Seasons Hotels & Resorts. B.V. v. Consorcio 

Bam S.A., 320 F.3d 1205, 1210 (11th Cir. 2003); McDonald's Com. v. Robertson, 147 F.3d 

1301, 1306 (11th Cir. 1998). 

111. ANALYSIS 

The declarations Plaintif submitted in support of its Application for a temporary 

restraining order (çTRO') support the following conclusions of law: 

1. Plaintiff has a very strong probability of proving at trial that constlmers are likely to 

be confused by Defendants' advertisement, promotion, sale, offer for sale, and/or 

distribution of handbags, walets, watches, sunglasses, belts, and key holders bearing 

counterfeits, reproductions, and/or colorable imitations of the Louis Vuitton Mrks, 

and that the handbags, wallets, watches, stmglasses, belts, and key holders Defendants 

are seling are copies of Plaintiffs products that bear marks which are substantialy 

indistinguishable from and/or colorful imitations of the Louis Vuitton Marks. 

2. Because of the infringement of the Louis Vuiton Marks, Plaintiff is likely to suffer 

immediate and irreparable injury if a TRO is not granted. 

a. Through the operation of fourteen commercial Internet websites Defendants 

are operating Internet businesses which advertise, promote, offer for sale, and 

sel, handbags, walets, watches, sunglasses, belts, and key holders bearing 

counterfeit and infringing trademarks in violation of Plaintiffs rights; 

There is good cause to believe that more colmterfeit and infringing handbags , 

wallets, watches, sunglasses, belts, and key holders bearing Plaintiff s 

trademarks wil appear in the marketplace; that consumers may be misled, 

confused, and disappointed by the quality of these products; and that Plaintiff 

may suffer loss of sales for its genuine products;



261 

c. Given the ease with which Defendants may transfer and/or redirect 

commercial activity from one lntemet Domain Name to another, there is good 

cause to believe that if Plaintiff proceeds on notice to Defendants on this 

Plaintif s Ex Parte Application, Plaintiff s ability to obtain meaningful relief 

wil be thwarted; 

d. The balance of potential harm to Defendants in restraining their trade in 

cotmterfeit and infringing branded products if a TRO is issued is far 

outweighed by the potential harm to Plaintiff, its reputation, and goodwill as a 

manufacturer of high quality products, if such relief is not issued; and 

e. The public interest favors issuance of the TRO to protect Plaintiff s trademark 

interests and the public from being defrauded by the palming off of counterfeit 

products as genuine products of Plaintiff. 

3. Under 15 U.S.C. j 1 1 17(a), Plaintiff may be entitled to recover, as an equitable 

remedy, the ilegal profits gained through Defendants' distribution and sales of 

handbags, wallets, watches, sunglasses, belts, and key holders bearing cotmterfeits 

and infringements of the Louis Vuiton Marks. 

4. Requesting equitable relief çinvokes the district court's inherent equitable powers to 

order preliminary relief, including an asset freeze, in order to assme the availability of 

permanent relief.' Levi Strauss & Co. v. Sunrise Int'l Trading Inc., 51 F.3d 982, 987 

(11th Cir. 1995) (citing FTC v. Oi1 & Gas Corp., 748 F.2d 1431, 1433-34 (11th Cir. 

1984)). 

ln light of the inherently deceptive natme of the counterfeiting business , and 

Defendants' aleged violation of the federal trademark laws, Plaintiff has good reason 

5



261 

to believe Defendants wil hide or transfer their ill-goten assets beyond the 

jurisdiction of this Court unless those assets are restrained. 

IV. CONCLUSION 

For the foregoing reasons, it is ORDERED AND ADJUDGED that Plaintifrs Ex Parte 

Application (ECF No. 6) is GRANTED. It is further 

ORDERED M D ADJUDGED that 

1. Each Defendant, their officers, directors, employees, agents , subsidiaries, distributors, 

and a11 persons in active concert or pm icipation with them having notice of this 


a. From manufacturing, importing, advertising, promoting, offering to sel, 

seling, distributing, or transferring any products bearing the Louis Vuitton 

Marks, or any confusingly similar trademarks, other than those actualy 

manufactured or distributed by Plaintif; and 

b. From secreting, concealing, destroying, seling oftl transfening, or otherwise 


bearing the Louis Vuitton Marks, or any confusingly similar trademarks; or 

(i) any evidence relating to the manufacture, importation, sale, offer for sale, 

distribution, or transfer of any products bearing the Louis Vuitton Marks , or 

any confusingly similar trademarks. 

Each Defendant, their oftkers, directors, employees, agents, subsidiaries , distributors, 

and al persons in active concert or participation with them having notice of this 

Order shall immediately discontinue the use of the LouisVuitton Marks or any 

confusingly similar trademarks, on or in connection with a11 Intemet websites owned



261 

and operated, or controlled by them, including the Intemet websites operating under 

the Subject Domain Nnmes; 3 


and a1 persons in active concert or pm icipation with them having notice of this 

Order shal immediately discontinue the use of the Louis Vuiton Marks or any 

confusingly similar trademarks within domain name extensions, metatags , or other 

markers within website sotlrce code, from use on any webpage (including as the title 

of any web page), any advertising links to other websites, 9om search engines' 



owned, or operated by each Defendant, including the Internet websites operating 

under the Subject Domain Names; 

4. Each Defendant shal not transfer ownership of the Subject Domain Names during the 



Plaintiff s counsel, for deposit with this Court, domain nnme certificates for the 

Subject Domain Nnmes; 

6. The Registrars and the top-level domain (TLD) Registries for the Subject Domain 

Names, within ten (10) business days of receipt of this TRO, shal change, or assist in 

changing, the Registrar of record for the Subject Domain Nnmes, excepting any such 

domain names which such Registries have been notified in writing by the Plaintiff 

have been or wil be dismissed from this action, to a holding accotmt with the United 

3 s eeschedule 

A of this Order . 

7



261 

States based Registrar, GoDaddy.com, Inc. As a matter of law, this TRO shal no 

longer apply to any Defendant or associated domain name dismissed from this action. 

Upon the change of the Registrar of record for the Subject Domain Names to 

GoDaddy.com, Inc., GoDaddy.com, Inc. will maintain access to the Subject Domain 

Names in trust for the Court during the pendency of this action. Additionaly, 

GoDaddy.com, Inc. shal immediately update the Domain Name System (çDNS') 

data it maintains for the Subject Domain Nnmes, which link the domain names to the 

IP addresses where their associated websites are hosted, to 

NSI.MEDIATEMPLE.NET and NSZ.MEDG TEMPLE.NET, which wil cause the 

domain names to resolve to the website where copies of the Complaint , Slmmonses, 

TRO, and a11 other doclments on file in this action are displayed. Altematively, 

GoDaddy.com, Inc. may institute a domain name forwarding which wil 

automaticaly redirect any visitor to the Subject Domain Names to the folowing 

Uniform Resolzrce Locator CCURL'I ht*:/se>inaotice.coelap/index.html 

whereon copies of the Complaint, Summonses, TRO, and a1 other documents on file 

in this action are displayed. Aûer GoDaddy.com, lnc. has effected this change , the 

Subject Domain Names shall be placed on Lock status, preventing the modification or 

deletion of the domains by the Registrar or the Defendants; 

7. Plaintiff may enter the Subject Domain Names into Google's Webmaster Tools and 

cancel any redirection of the domains that have been entered there by Defendants 

which redirect traffic to the counterfeit operations to a new domain name and thereby 

evade the provisions of this Order;



261 

8. Each Defendant shall preserve copies of a1l their computer files relating to the use of 

any of the Subject Domain Nnmes and shall take al steps necessary to retrieve 

computer files relating to the use of the Subject Domain Names that may have been 

deleted before the entry of tlis Order; 

Upon receipt of notice of this Order, Paypal, Inc. ( çpa yPal')4 

and its related 

compimies and affiliates shal immediately freeze a11 Paypal accounts related to the 

Paypal account recipients xiaoyang197894@163.com, 

ivoguepay@n ail.com 

and 

xcgseo@gmail.com, 

bagpayzolz@> ail.com, 

zhangxiaozhenl3s@gmail.com, shoes5227@gmail.com, natelichun@gmail.com, 

sihuazhang7o@gmail.com, chtmyinpn@yahoo.com, stylecity8@pnail.com, 

leonazollnew@gmail.com, boxiaoh@r ail.com,tiandiyingo7@hotmail.com, and 

zhouzhoutwo@gmail.com, and any other related accounts of the same customerts), as 

wel as any other accounts which transfer funds into the same financial instimtion 

accountts) as any of the other Paypal accounts subject to this Order; 

10. Paypal shal also immediately divert to a holding account for the trust of the Court a1l 

funds currently in, or which during the pendency of this Order come in to, a11 Paypal 

accounts related to the Paypal account recipients xiaoyang197894@163.com, 

xcgseo@gmail.com, 

zhangxiaozhenl3s@pnail.com, 

ivoguepay@gmail.com and 

shoes5227@pnai1.com, 

bagpayzolz@n ail.com, 

natelichtm@pnail.com, 

sihuazhang7o@gmail.com, chunyinm @yahoo.com, stylecity8@m ail.com, 

leonazollnew@r ail.com, boxiaoh@r ail.com, tiandiyingo7@hotmail.com, and 

4 Pa yPal 

is licensed to do business in the State of Florida by the Florida Office of the Controler 

and is therefore subject to personal jurisdiction in this Court. See Decl. of Gaffigan, at ! 1 IIECF 

No. 6), and Exhibit G atached thereto.



261 

zhouzhoutwo@r ail.com, and any other related accounts of the same customerts), as 

wel as any other accounts which transfer funds into the snme financial institution 

accountts) as any of the other Paypal accounts subject to this Order; 

1 1. Paypal shall further, within five days of receiving this Order, provide Plaintiffs 

counsel with a11 data which identifies the Paypal accounts gozen, as wel as an 

accounting of the funds in the frozen accounts. Such freezing of the accounts and the 

disclosme of the related financialinstitution account information shall be made 

without notice to the account owners or the financial institutions until further order of 

this Court. Paypal shal receive and maintain this Order and its contents ms 

confidential until further order of this Court; 

12. This TRO shall remain in effect until the date for the hearing on the Motion for 

Preliminary Injunction set forth below, or until such further dates as set by the Court 

or stipulated to by the parties, but under no circumstances shal this TRO remain in 

effect for more than fourteen (14) days from the date of this Order; 

13. Ptlrsuant to 15 U.S.C. j 1116(d)(5)(D), Plaintiff shall post a bond in the nmount of 

Fihy Thousand Dolars and Zero Cents ($50,000.00), as payment of dnmages to 

which Defendants may be entitled for a wrongful injunction or restraint. ln the 

Court's discretion, the bond may be subject to increase should the nmount of the 

funds seized exceed $50,000.00. Plaintif shall post the bond ptior to requesting the 

Registry to change the registrar of record for the Subject Domain Names; 

14. A hearing is set before this Court in the United States Courthouse located at 400 

North M iami Avenue, Minmi, Florida 33128, Courtroom 13-1, on March 26, 2012, at 

1:0%m, or at such other time that this Court deems appropriate, at which time 

10



261 

Defendants and/or any other affected ptrsons may challenge the appropriateness of 

this Order and move to dissolve the same and at which time the Court wil hear 

argument on Plaintiffs requested preliminary injunction; 

15. Plaintiff shall serve a copy of the Complaint, Slmmonses, Plaintiffs Ex Parte 

Application, and this Order on Defendants via their known e-mail addresses, 

specitkally: upon Defendant cheapwholesalereplica.com at the e-mail addresses 

1aopeng197880@163.com and marktonyang@l63.com; upon Defendant high- 

replicahandbag.com at the e-mail addresses highreplicasale@gmail.com and 

Alexas66ctones@gmail.com; upon Defendant replicabagstyle.com at the e-mail 

addresses replicabagstyle@gmail.com and sam60@163.com; and upon the remaining 

Defendants via th , e corresponding e-mail addresses provided to the Registrars 

responsible for the Subject Domain Names and the customer service e-mail addresses 

used to communicate with Plaintiffs investigator, a1 of which are identified on 

Schedule EB' hereto. In addition, Plaintiff shall post a copy of the Complaint, 

Slmmonses, Plaintiffs Ex Parte Application, and this Order, as wel as a1 other 

documents filed in this action on the website located at 

he ://sewinrotice.coe lap/index.h% l, upon being changed to the GoDaddy.com, 

Inc. holding account, and such notice so given shall be deemed good and suftkient 

service thereof. Any response or opposition to Plaintiff s Motion for Preliminary 

Injunction must be filed and served on Plaintifs counsel forty-eight (48) hours prior 

to the hearing set for March 26, 2012, and filed with the Court, along with Proof of 

Service, on or before March 23, 2012. Plaintiff shal file any Reply Memorandum on 

or before March 26, 2012. The above dates may be revised upon stipulation by a1 

11



261 

parties and approval of this Court. Deftndants are hereby on notice that failzre to 

appear at the hearing may result in the imposition of a preliminary injunction against 

them pursuant to 15 U.S.C. j 1116(d) and Fed. R. Civ. P. 65. 

DONE A'ND ORDERED in Chambers at Miami, Florida, thi day of March, 2012. 

cc: A11 counsel of record 

12 

* 

e 

K. CHAEL MOOM 




261 

SCHEDULE RAO 

DEFENDANTS BY SUBJECT DOMM N NAM ES AND DEFENDANT NUMBER 

Defendant 1 cheapwholesalereplica.com 

Defendant 2 high-replicahandbag.com 

Defendant 3 replicabagstyle.com 

Defendant 4 best-replicas-watches.com 

Defendant 5 epopshoes.com 

Defendant 6 goodhandbagsonsale.com 

Defendant 7 karry669.com 

Defendant 8 replica-luxurpshop.com 

Defendant 9 replicalvhandbags.net 

Defendant 10 replicapurse.net 

D efendant 1 1 

super-replicas.com 

ebestreplica.com 

Defendant 12 topreplica.net 

Defendant 13 upscalereplica.com



261 

SCHEDULE GB' 

DEFENDANT PARTNERSHIPS AND UNINCORPOM TED ASSOCIATIONS BY 

SUBJECT DOMM N NAM E AND ASSOCIATED E-MM L ADDRESSES 

Defendant 1 cheapwholesalereplica .com 1a0peng197880@163.com 

mrktonyanggj6g.com 

Defendant 2 high -replicahandbag.com highreplicasale@pnail.com xj 

exas66ctones@gmail.com 

Defendant 3 replicabagstyle .com replicabagstyle@pnail.com 

SanAytltjyj6a.com 

Defendant 4 best-replicas-watches.com admin@best-replica-watches.com 

Defendant 5 epopshoes.com 2723921 ll@qq.com 

Defendant 6 goodhandbagsonsale .com 

798979466@qq.c0m 

goooantsagsonsale@gmail.com 

Defendant 7 karry669 .com sales@dong666.com 

505175638@qq.c0m 

Defendant 8 replica -luxurpshop.com replicaluxuryshop@gmail.com j 

cwapbrandshop@pnail.com 

oejkndant 9 replicalvhandbags .net j jangyjgyggmaj.com 

relicalvhrdbagsnet@m ail.com 

z 

mikaluno@gmail.com 

Defendant 10 replicapurse .net d erekdoo@qq.com 

super-replica@l63.com 

sales@super-replicas.com 

super-replicas@hotmail.com 

Defendant 11 super-replicas.com haijimmy@l63.com 

swisswatche@vip.l63.com 

noplaygame@yeah.net 

webmaster@ebestreplica.com 

nicolehuanglg86@gmail.com 

Defendant 12 ebestreplica .com 343440218@qq.c0m 

Defendant 13 topreplica .net 

14 

clmelisz@pnail.com 

upscalereplica@l63.com

Case 0:11-cv-62370-KMW Document 43 Entered on FLSD Docket 02/03/2012 Page 1 of 18 


261 


Plaintiff, 

WANG ZHIMING, ef al 

Defendants. 



CASE NO. 11-62370-CIV-W ILLIAMS 

/ 

ORDER GRANTING THIRD TEMPORARY RESTRAINING ORDER EX PARTE 

THIS CAUSE is before the Court on Plaintiff's Third Ex Parfe Application for 

Entry of Temporary Restraining Order, Preliminary Injunction, and Order Restraining 

Transfer of Assets Tied to the Counterfeiting Operation (the 'Third Application for 

TRO'). The Coud hascarefuly reviewed theApplication, the entire coud file and is 

otherwise fuly advised in the premises. 

By the instant Application, Plaintif, Abercrombie & Fitch Trading Co. 

(ldAbercrombie') moves ex parle, for entry of a temporary restraining order against 

Defendants, the Padnerships and Unincorporated Associations identified on Schedule 

'A' atached hereto (colectively 'Defendantsn), and for an order restraining the financial 

accounts used by Defendants, pursuant to 15 U.S.C. j 1116 and Fed. R. Civ. P. 65. 

Factual Backqround 

The Coud bases this Order on the folowing facts from Plaintif's Second 

Amended Complaint, Third Application for TRO, and supporting evidentiary 

submissions.



261 

Abercrombie is a corporation organized and existing under the Iaws of the State 

of Ohio with its principal place of business Iocated at 6301 Fitch Path, New Albany, 

Ohio 43054. (Second Amended Complaint. !1 3.) Abercrombie is engaged in the 

manufacture, promotion, distribution, and sale in interstate commerce, including within 

this Judicial District, of high quality products under multiple federaly registered 

trademarks. (Declaration of Brandon Scott in Suppod of Third Application for TRO 

('scot DecI.') 111 4-5.) 

Abercrombie is the registered owner of the folowing trademarks on the Principal 

Register of the United States Patent and Trademark Office (colectively the 

'Abercrombie Marksnl: 

T 

rademark 

Registration 

Number 

Registration 

Date 

Class I Goods 

IC 025 - men's and women's 

ABERCROMBIE 

clothing and footwear-namely pants, 

JANUARY 23, 

& FITCH 

0 

,951 ,410 1973 shirts, skirts, jackets, coats, gloves, 

mitens, hats, underwear, shoes, 

belts, caps, 

IC 025 - Clothing, namely, coats, 

jackets, knit shids, woven shids, t- 

JANUARY 4, Shirts, Shids, underwear, pants, 

abercrombie 2,305,464 2000 jeans, hats and shoes. 

IC 035 Retail clothing store 

services. 

IC 003 personal care products, 

namely, perfume. 

IC 014 - jewelry, namely, necklaces 

and bracelets. 

ABERCROMBIE OCTOBER lc 018 - handbags , tote bags and 

2 ,500,146 

& FITCH 23 , 2001 travel bags . 

2 

IC 025 - clothing, namely, t-shirts, 

sweatshids, sweatpants, jeans, 

sandals, visors, tank tops, 

swimwear, bikinis and camisoles.



261 

IC 025 - clothing, namely, hats, 

caps, shirts, t-shids, tank tops, knit 

tops, woven tops, halter tops, 

sweatshids, sweatpants, 

underwear, boxer shods, pants, 

A & F 2 JANUARY 15, Short pants, jeans, skirts, footwear, 

,530,664 sweaters 

2002 , vests, coats, jackets, 

SCarVeS. 

IC 035 - retail personal care product 

and clothing store services and mail 

order catalog services featuring 

personal care products and clothing. 

* 3 

,212,644 

IC 025 - clothing, namely, polo 

shirts, sweaters, t-shirts, shids, knit 

tops, woven tops, sweatshids, 

sweatpants, pants, shorts, caps, 

hats, scarves, jackets, coats, 

sandals, flip flops, belts, tank tops, 

February 27, underwear 

2007 

, boxer shods, swim 

suits, pajamas, sleepwear. 

IC 035 - retail store services, and 

on-line retail store services featuring 

clothing, footwear, fashion 

accessories, fragrances and 

jewelry. 

IC 025 belts', blouses; boxer 

shorts; camisoles', caps; coats; 

footwear; halter tops', hats; jackets', 

jeans', knit shirts; Ioungewear', 

HOLLISTER 3 OCTOBER pants', sandals', scarves; shirts; 

,310,650 . . kirts. sweat pants; 

16 , 2007 shoes, shorts, s , 

sweat shirts; sweat shorts; 

sweaters', swim wear; t-shirts; tank 

tops', underpants', undershirts; 

underwear. 

AUGUST 12 IC 025 - coats', jackets', knit shids; 

2008 , . . derwear; pants; 

. . 

jeans, hats, sjyoes. 

ABERCROMBIE 3,484,799 shids, t-shids, un 

3



261 

IC 025 clothing, namely, boxer 

shorts, caps, coats, hats, jackets, 

knit shirts, knit tops, Ioungewear, 

NOVEMBER pants , shids, slacks, sweat pants, 

HCO 3 ,529,071 4 , 2008 sweat shids , t-shids and underwear. 

IC 035 - retail store services and on- 

Iine retail services featuring clothing. 

The Abercrombie Marks are used in connection with the manufacture and 

distribution of quality goods in the categories identified above. (Scot Decl. !1 5', see also 

United States Trademark Registrations of the Abercrombie Marks at issue 

E'Abercrombie Trademark Registrations') atached as Composite Exhibit A to the Scott 

DecI.) 

Abercrombie retained Investigative Consultants, a Iicensed private investigative 

firm, to investigate the promotion and sale of counterfeit and infringing Abercrombie 

branded products by Defendants. (Declaration of Brandon Tanori in Suppod of Third 

Application for TRO ('Tanori DecI.') !1 3.) Brandon Tanori (d1Tanori'), an employee of 

lnvestigative Consultants, accessed the Internet websites operating under the domain 

names: aooshop.com, warmabercrombies.com, abercrombieandfitch-paris.com, 

abercrombieandfitch-france.org, abercrombiefitchhoodie.net, and abercrombiemilano- 

it.com, and went through the purchasing process for various products bearing 

counterfeits of, at Ieast, one of the Abercrombie Marks at issue in this action. (Id. at %11 

4-9 and Composite Exhibits A through F thereto.) Tanori communicated with 

Defendants electronicaly via e-mail and/or on-site contact page and received 

information for finalizing payment for each of the Abercrombie-branded items ordered 

via Paypal, Inc. ('$PayPaI') and/or bank transfer to Defendants' respective Paypal 

and/or bank accounts. Specificaly, folowing the submission of his order via 

4



261 

aooshop.com, the Paypal information provided to Tanori for finalizing the payment 

process identified the Paypal account as 'pay4grace@gmail.com.' (Id. at :1 4 and 

Composite Exhibit A atached thereto.) Folowing the submission of his order via 

warmabercrombies.com, Tanori received instructions to effect payment via Paypal to 

the Paypal account identified as d'aubootsalees@hotmail.com.' (Id. at % 5 and 

Composite Exhibit B atached thereto.) Additionaly, folowing the submission of Tanori's 

order using the abercrombieandfitch-paris.com and abercrombieandfitch-france.org 

websites, the bank transfer information provided to Tanori for finalizing the payment 

process identified the Bank of China Putian Branch Bank Account Number, 

***************4662.1 1swift 

'BKcHcNBJ73c .' (Id. at !1 6, 9 and composite Exhibits c and 

F attached thereto.) Fudher, the bank transfer information provided to Tanori for 

finalizing the payment process via the abercrombiefitchhoodie.net website identified the 

www wwwwwj 838.2 swift 'SHSBCHKHHHKH .' (/d. at !1 7 

HSBC Hong Kong Account Number, , 

and Composite Exhibit D atached thereto.)Folowing the submission of Tanori's order 

using the abercrombiemilano-it.com website, the bank transfer information provided to 

Tanori for finalizing the payment process identified the Bank of China Putian Branch 

..............c8 j 7 . 3 swift 'd B Kc H c N BJ 7 3C . ' çld. at !! 8 a nd 

6al1k Account Number, , 

Composite Exhibit E attached thereto.) Fudhermore, Plaintifrs Senior Manager of 

Brand Protection, Brandon Scot('Scott), reviewed and visualy inspected the items 

bearing the Abercrombie Marks offered for sale by the Defendants via the lnternet 

1 The ful account number has been redacted to avoid disclosure of private financial 

information, in compliance with Fed. R. Civ. P. 5.2(a)(4). 





5



261 

websites operating under the padnership and/or unincorporated association names 

identified on Schedule 'A' hereto (the 'Group II Subject Domain Names') and 

determined the products were non-genuine, unauthorized versions Abercrombie 

products. (Scott Decl. at !1 10-1 1 .) 

Based on the investigations, Plaintiff aleges Defendants have advedised, offered 

for sale, and/or sold at Ieast t-shids, polo shirts, sweat shirts, sweat pants, shorts, jeans, 

jackets, and caps, bearing what Plaintif has determined to be counterfeits, 

reproductions, and/or colorable imitations of the Abercrombie Marks. (Scott Decl. II!I 14, 

18-23 and Ex. H thereto', Galigan Decl. $1 2-4 and Composite Exhibits A and B 

thereto). Defendants are not now, nor have they ever been, authorized or Iicensed to 

use, reproduce, or make counterfeits, reproductions, and/or colorable imitations of the 

Abercrombie Marks. (Scot Decl. !1 9.) 


The declarations Plaintiff submited in support of its Third Application for TRO 

support the folowing conclusions of Iaw: 

A. 

Plaintiff has a very strong probability of proving at trial that consumers are 

Iikely to be confused by Defendants' advedisement, promotion, sale, offer for sale, 

and/or distribution of goods, including t-shirts, polo shirts, sweat shirts, sweat pants, 

shods, jeans, jackets, and caps, bearing counterfeits, reproductions, and/or colorable 

imitations of the Abercrombie Marks, and that the products Defendants are seling are 

copies of Plaintiff's products that bear copies of the Abercrombie Marks on goods, 

including t-shids, polo shirts, sweat shirts, sweat pants, shorts, jeans, jackets, and caps. 

6



261 

B . Because of the infringement of the Abercrombie Marks, Plaintiff is Iikely to 

suffer immediate and irreparable injury if a temporary restraining order is not granted. lt 

clearly appears from the folowing specific facts, as set forth in Plaintiff's Second 

Amended Complaint, Third Application for TRO, and accompanying declarations on file, 

that immediate and irreparable Ioss, damage, and injury wil result to Plaintiff and to 

consumers before Defendants can be heard in opposition unless Plaintifrs request for 

ex parte relief is granted'. 

Defendants are operating lnternet businesses which advedise, offer 

for sale, and sel, at Ieast t-shids, polo shirts, sweat shids, sweat pants, shods, jeans, 

jackets, and caps, bearing counterfeit and infringing trademarks in violation of Plaintifrs 

rights; 


products bearing Plaintiff's trademarks wil appear in the marketplace; that consumers 

may be misled, confused, and disappointed by the quality of these products; and that 

Plaintiff may suffer Ioss of sales for its genuine products', 


Defendants on this Third Application for TRO, Defendants can easily and quickly 

transfer the registrations for many of the Subject Domain Names, or modify registration 

data and content, change hosts, and redirect traffic to other websites, thereby thwading 

Plaintiff's ability to obtain meaningful relief', 

4. The balance of potential harm to Defendants in restraining their 

trade in counterfeit and infringing branded goods if a temporary restraining order is 

7



261 

issued is far outweighed by the potential harm to Plaintiff, its reputation, and goodwil as 

a manufacturer of high quality products if such relief is not issued', and 

5. The public interest favors issuance of the temporary restraining 

order in order to protect Plaintifrs trademark interests and the public from being 

defrauded by the palming off of counterfeit goods as genuine goods of Plaintiff. 

C. Under 15 U.S.C. j 1117(a), Plaintiff may be entitled to recover, as an 

equitable remedy, the ilegal profits gained through Defendants' distribution and sales of 

products bearing counterfeits and infringements of the Abercrombie Marks. See Reebok 

Inth Ltd. v. Marnatech Enterw, Inc., 970 F.2d 552, 559 (9th Cir. 1992) (quoting Fuler 

Brush Products Co. B. Fuler Brush Co., 299 F.2d 772, 777 (7th Cir. 1962) ('An 

accounting of profits 

damages: 'Ealn accounting for profits . . . is an equitable remedy subject to the principles 

of equity.').) 

under j 1 1 17(a) is not synonymous withan award of monetary 

D . Requesting equitable relief 'invokes the district court's inherent equitable 


availability of permanent relief.' Levi Strauss & Co. ?. Sunrise Int'l Trading Inc. , 51 F.3d 

982, 987 (1 1th Cir. 1 995) (citing Federal Trade Commission F. United States Oil and 

Gas Corp., 748 F.2d 1431 , 1433-34 (1 1th Cir. 1984)). 

E. 

In light of the inherently deceptive nature of the counterfeiting business, 

and Defendants' blatant violation of the federal trademark Iaws, Plaintiff has good 

reason to believe Defendants wil hide or transfer their il-gotten assets beyond the 

jurisdiction of this Coud unless those assets are restrained. 

8



261 


ORDERED AND ADJUDGED that Plaintif's Ex Pade Application for a 

Temporary Restraining Order and OrderRestraining Transfer of Assets Tied to the 

Counterfeiting Operation is hereby GRANTED as folows: 


distributors, and aI persons in active concert or padicipation with them having notice of 

this Order are hereby temporarily restrained: 

a. From manufacturing, impoding, advertising, promoting, offering to 

sel, seling, distributing, or transferring any products bearing the 

Abercrombie Marks, or any confusingly similar trademarks, other 

than those actualy manufactured or distributed by Plaintiff; and 

b. From secreting, concealinj, destroying, seling o@, transfering, or 

otherwise disposing of: (I) any products, not manufactured or 

distributed by Plaintift bearing the Abercrombie Marks, or any 

confusingly similar trademarks', or (i) any evidence relating to the 

manufacture, impodation, sale, offer for sale, distribution, or 

transfer of any products bearing the Abercrombie Marks, or any 


(2) Each Defendant, their oficers, directors, employees, agents, subsidiaries, 

distributors, and aI persons in active conced or participation with them having notice of 

this Order shal immediately discontinue the use of the Abercrombie Marks or any 

confusingly similar trademarks, on or in connection with aI lnternet websites owned and 

operated, or controled by them, including the Internet websites operating under the 

Subject Domain Names', 


distributors, and aI persons in active conced or padicipation with them having notice of 

this Order shal immediately discontinue the use 

confusingly similar trademarks within domain 

9 

of the Abercrombie Marks, or any 

name extensions, metatags or other



261 

markers within website source code, from use on any webpage (including as the title of 

any web page), any advedising Iinks to other websites, from search engines' databases 

or cache memory, and any other form of use of such terms which is visible to a 

computer user or serves to direct computer searches to websites registered by, owned, 

or operated by each Defendant, including the Internet websites operating under the 

Subject Domain Names', 

(4) Each Defendant shal nottransfer ownership of the Subject Domain 


(5) The domain name Registrars for the Subject Domain Names are directed 

to transfer to Plaintiff's counsel, for deposit with this Coud, domain name cedificates for 

the Subject Domain Names', 

(6) Upon Plaintiff's request, the privacy protection service for any Group I 

Subject Domain Names for which the Registrant uses such privacy protection service to 

conceal the Registrant's identity and contact information are ordered to disclose to 

Plaintiff the true identities and contact information of those Registrants', 

(7) Upon entry of this Order, Plaintiff shal provide a copy of the Order by 

email to the registrar of record for each of the Group II Subject Domain Names, so that 

the registrar of record of each of the Group ll Subject Domain Names may, in turn, 

notify each registrant of the Order and provide notice of the Iocking of the domain name 

to the registrant of record. After providing such notice to the registrars so the domain 

names may be Iocked, Plaintiff shal also provide notice and a copy of this Order to the 

registrant of each Group ll Subject Domain Name via email to the email address 

provided as pad of the domain registrationdata for each of the Group I Subject



261 

Domain Names identified in the Third Application for TRO. lf an email address was not 

provided as part of the domain registration data for a Group Il Subject Domain Name, 

Plaintiff shal provide notice and a copy of this Order to the operators of the Internet 

websites via an email address and/or online submission forms provided on the Internet 

websites operating under such Group II Subject Domain Names. After fody-eight (48) 

hours have elapsed after the emailing of this Order to the registrars of record and the 

registrants, Plaintiff shal provide a copy of this Order to the registries for the Group II 

Subject Domain Names for the purposes described in Paragraph 8, infra; 

(8) The Registrars and the top-level domain (TLD) Registries for the Group II 

Subject Domain Names,within ten (10) business daysof receipt of this Temporary 

Restraining Order, shal, change or assist in changing, the Registrar of record for the 

Group Il Subject Domain Names, excepting any such domain names which such 

Registries have been notified in writing by the Plaintiff have been or wil be dismissed 

from this action, to a holding account the United States based Registrar, GoDaddy.com, 

Inc. As a mater of law, this Temporary Restraining Order shal no Ionger apply to any 

Defendant or associated domain name dismissed from this action. Upon the change of 

the Registrar of record for the Group II Subject Domain Names to GoDaddy.com, Inc., 

GoDaddy.com, Inc. wil maintain access to the Group II Subject Domain Names in trust 

for the Coud during the pendency of this action. Additionaly, GoDaddy.com, Inc. shal 

immediately update the Domain Name System (1'DNS') data it maintains for the Group 

II Subject Domain Names, which Iink the domain names to the IP addresses where 

their associated websites are hosted, to NSI.MEDIATEMPLE.NET and 

NSZ.MEDIATEMPLE.NET, which wil cause the domain names to resolve to the website



261 

where a copy of the Second Amended Complaint, Summonses, Temporary Restraining 

Order, and other documents on file in this action are displayed. Alternatively, 

GoDaddy.com, Inc. may institute a domain name forwarding which wil automaticaly 

redirect any visitor to the Group II SubjectDomain Names to the folowing Uniform 

Resource Locator ('1URL') h/p://se-inqnotice.com/zhiminq/index.html whereon a 

copy of the Second Amended Complaint, Summonses, Temporary Restraining Order, 

and other documents on file in this action are displayed. After GoDaddy.com, Inc. has 

effected this change the Group l Subject Domain Names shal be placed on Lock 

status, preventing the modification ordeletion of the domains by the Registrar or 

Defendants', 

(9) Plaintiff may enter the Group IIlSubject Domain Names into Google's 

Webmaster Tools and cancel any redirection of the domains that have been entered 

there by Defendants which redirect traffic to the counterfeit operations to a new domain 

name and thereby evade the provisions of this Temporary Restraining Order; 

(10) Each Defendant shafl preserve copies of aI their computer files relating to 

the use of any of the Group lII Subject Domain Names and shal take aI steps 

necessary to retrieve computer fifes relating to the use of the Group I Subject Domain 

Names that may have been deleted before the entry of this Temporary Restraining 

Order', 

(1 1) Upon receipt of notice of this Order, Paypal, Inc. ('PayPaI') and its related 

companies and affiliates shal immediately freeze aIPaypal 

accounts related to the 

Paypal account recipients nav4nraceoqmail.com, aubootsaleesa hotmail.com and any 

other related accounts of the same customers;



261 

(12) Upon receipt of notice of this Order, Paypal and its related companies and 

aliliates shal immediately freeze aI Paypal accounts Iinked to, associated with, or that 

transmit funds into Defendants' identified bank accounts, including but not Iimited to, the 

**************466é 4 Sayjk lj CjljRz 

Bank of China Putian Branch Bank Account Number , , 

Putian Branch Bank Account Number, **************0817.,5HSBC Hong Kong Account 

*** *****1 838 6 and any other related accounts of the same customers j '? 

Number , , 

(13) Paypal shal also immediately dived to a holding account for the trust of 

the Court al funds curently in, or which during the pendency of this Order come in to, 

al Paypal accounts related to the Paypal accountrecipients pav4nraceanmail.com, 

aubootsaleesa hotmail.com, and any other related accounts of the same customers, 

and/or aI Paypal accounts Iinked to, associated with, or that transmit funds into 

Defendants' identified bank accounts to the Bank of China Putian Branch Bank Account 

Number, **************4662 Bank of China Putian Branch Bank Account Number, 

1 

************W*Q@ j 7. I H$$G Yong Song Accotjnt Skjmscrj ... .....j 8a8 1and 

any other 

related accounts of the same customers', 


information, in compliance with Fed. R. Civ. P. 5.2(a)(4)', however, the ful account 

number is identified on Plaintiff's Notice of Filing Reference List ! filed under seal, which 

shal be disclosed to Paypal to effectuate the relief ordered hereln. 


information, in compliance with Fed. R. Civ. P. 5.2(a)(4)', however, the ful account 

number is identified on Plaintif's Notice of Filing Reference List Jfiled 

under seal, which 

shal be disclosed to Paypal to effectuate the relief ordered hereln. 


information, in compliance with Fed. R. Civ. P. 5.2(a)(4),' however, the ful account 

number is identified on Plaintiff's Notice of Filing Reference List, filed under seal, which 

shal be disclosed to Paypal to effectuate the relief ordered herein. 

7 Paypal is Iicensed to do business in the State of Florida by the Florida Ofice of the 

Controler and is therefore subject to personal jurisdiction in this Court. (See Gaffigan 

Decl. 11 8 and Exhibit D atached thereto.)



261 

(14) Paypal shal fudher, within five business 

days of receiving this Order, 

provide Plaintiffs' counsel with aI data which identifies the Paypal accounts frozen, as 

wel as an accounting of the funds in the frozen accounts. Such freezing of the 

accounts and the disclosure of the related financial institution account information shal 

be made without notice to the account owners or the financial institutions until further 

order of this Court. Paypal shal receive and maintain this Order and its contents as 

confidential until fudher order of this Coud; 

(15) This Temporary Restraining Order shal remain in effect until the date for 

the hearing on the Motion for Preliminary Injunction set fodh below, or until such fudher 

dates as set by the Court or stipulated to by the padies', 

(16) Pursuant to 15 U.S.C. j 11 16(d)(5)(D), Plaintiff shal maintain its 

previously posted bond in the amount of Ten Thousand Dolars and Zero Cents 

($10,000.00), as payment of damages to which Defendants may be entitled for a 

wrongful injunction or restraint; 

(17) Plaintiff shal serve copies of the Third Application for TRO and this 

Temporary Restraining Order and aIl other pleadings and documents on file in this 

action on Defendants by email as described above and by posting copies of the Third 

Application for TRO and this Temporary Restraining Order on the website located at 

h/pi//se-inqnotice.com/zhiminq/index.html within fody-eight (48) hours of control of 

the Group I Subject Domain Names being changed to the Court via the GoDaddy.com, 

Inc. holding account, and such notice so given shal be deemed good and sufficient 

service thereof. Plaintiff shal continue to provide notice of these proceedings and 

copies of the documents on file in this mater to Defendants by regularly updating the



261 

website located at h/p://se-inqnotice.com/zhiminq/index.html or by other means 

reasonably calculated to give notice which is permitted by the Coud. Any response or 

opposition to Plaintifrs Motion for Preliminary lnjunction must be filed and served on 

Plaintiffs counsel and filed with the Court, along with Proof of Service, before February 

16, 2012. Plaintif shal file any Reply Memorandum on or before February 17, 2012. 

The above dates may be revised upon stipulation by aI1 parties and approval of this 

Court. Defendants are hereby on notice that failure to appear at the hearing may result 

in the imposition of a preliminary injunction against them pursuant to 15 U.S.C. j 

1 1 16(d) and Fed. R. Civ. P. 65. 

20 1 2 . 

DONE AND ORDERED in chambers in Miami, Florida, thi day of February, 

KATHLEEN . W ILLIAMS 

UNITED ST TES DISTRICT JUDGE 

15



261 

SCHEDULE A 


Defendant 6: 

Defendant 7: 

Defendant 8: 

abercrombieandfitchau.com 

abercrombieandfitch-canada.net 

abercrombiemilanoit.com 

abercrombiemilanoit.net 

abercrombie-espana.com 

abercrombiemilanoit.org 

abercrombieandfitchcanada.com 

abercrombieandfitchmilano.org 

abercrombieandfitchcopenhagendk.com 

Defendant 9: abercrombieandfitchdk.eu 

abercrombieandfitchdk.org 

abercrombienfitch.eu 

Defendant 10: abercrombieandfitch-france.org 

abercrombieandfitch-paris.com 

Defendant 1 1: abercrombieandfitchfranceparis.com 

Defendant 12: abercrombieandfitch-madrid.com 

Defendant 13: abercrombieandfitchmilano.it 

abercrombieefitch.it 

Defendant 14: abercrombieandfitchmilanoit.com 

Defendant 15: abercrombieandfitchmilano-it.com 

Defendant 16: abercrombieandfitchoxboutique.com 

abercrombieandfitchuboutique.com 

Defendant 17: abercrombieandfitchparisfrance.com 

abercrombiefitchparis.co 

Defendant 18: abercrombieandfitchparisfrance.org 

abercrombieparis-france.org 

holistersaleuk.org.uk 

holisteruksale.org 

Defendant 19: abercrombieandfitchsdk.com 

Defendant 20: abercrombieandfitchstore.org 

Defendant 21 : abercrombieandfitchsydney.com



261 

Defendant 22: abercrombiebelgium.net 

abercrombiefitchgilet.net 

abercrombiegilet.net 

abercrombiefitchhoodies.net 

Defendant 23: abercrombiebest.net 

Defendant 24: abercrombiebrussel.net 

Defendant 25: abercrombieeiitchpascher.com 

Defendant 26: abercrombieetfitchshop.com 

Defendant 27: abercrombie-fitchlondon.com 

Defendant 28: abercrombie-fitch-london.org 

Defendant 29: abercrombiefitch-madrid.com 

abercrombiefitchmadrid.com 

abercrombie-singapore.com 

abercrombiesingapore.net 

Defendant 30: abercrombiefitchmadrid-es.com 

Defendant 31: abercrombiefitchpascher.net 

Defendant 32: abercrombiefitchprix.com 

Defendant 33: abercrombiefitchsaleshops.com 

saleabercrombie.uk.com 

Defendant 34: abercrombie-hoodies.net 

Defendant 35: abercrombiemilano.ws 

Defendant 36: abercrombiemilano-it.com 

abercrombiemilano-it.net 

abercrombiemilano-it.org 

abercrombiemilanositouliciale.net 

abercrombiesale-uk.org 

Defendant 37: abercrombiemilanositouficiale.org 

Defendant 38: abercrombiemilanousuficiale.com 

abercrombiemilanoiuliciale.com 

Defendant 39: abercrombieonlinesales.com 

abercrombieandfitchukstore.com 

Defendant 40: abercrombieonlineshopping.com



261 

Defendant 41: abercrombieparis.ws 

Defendant 42: abercrombiesalget.com 

Defendant 43: abercrombiesingapore.com 

Defendant 44: abercrombiespace.com 

Defendant 45: abercrombieuksales.co.uk 

Defendant 46: abercrombieverkauf.de.com 

Defendant 47: aooshop.com 

abercrombieoutletsonline.org 

Defendant 48: einkaufenabercrombie.com 

Defendant 49: fashionabercrombies.com 

Defendant 50: holisterparis.com 

Defendant 51: modischabercrombiexcom 

Defendant 52: ukabercrombieclothing.com 

abercrombieandfitchmilano.info 

abercrombiemilanoo#icial.eu 

abercrombieandfitchparis.co 

abercrombiepariss.me 

abercrombieparis.bz 

abercrombiepariss.mn 

abercrombiedeutschlands.de.com 

abercrombiedeutschlanduliciale.de.com 

abercrombiefitchdeutschlandss.de.com 

abercrombiemilanos.com 

abercrombiefitchmilanos.net 

abercrombiemilanos.org 

abercrombiedeutschlanddusseldod.de.com 

Defendant 53: ukholistersales.co.uk 

holisteruksale.uk.net 

holisteruksales.co.uk 

Defendant 54: warmabercrombies.com 

18



261 

TIFFANY (NJ), LLC, 

v. 

Plaintiff, 

CHEN YAOQIANG, et. al, 

Defendants. 

/ 



Case No. 1:11-cv-24116 UU 


THIS CAUSE came before the Court upon the Plaintiff’s Ex Parte Application for Entry of 

a Temporary Restraining Order (“TRO”) and Preliminary Injunction. (D.E. 9.) 

THE MATTER was referred to the Honorable Edwin G. Torres, United States Magistrate 

Judge. A Report and Recommendation has been filed, recommending that the Motion be granted 

insofar as the Ex Parte Motion should be entered and a preliminary hearing should be set for 

December 27, 2011. (D.E. 9.) 

Defendant has failed to file objections to the Report. See LoConte v. Dugger, 847 F.2d 145 

(11th Cir. 1988), cert. denied, 488 U.S. 958 (1988) (holding the failure to file timely objections bars 

the parties from attacking factual findings on appeal). The matter is ripe for disposition. 

THIS COURT has made a de novo review of the entire file and record herein, and, being 

otherwise fully advised in the premises, it is hereby 

ORDERED and ADJUDGED that United States Magistrate Judge Torres’ said Report and 

Recommendation is RATIFIED, AFFIRMED and ADOPTED.



261 

DONE AND ORDERED in Chambers at Miami, Florida, this 21st day of December, 2011. 

Copies to: Counsel of Record 

Magistrate Torres 

2 




261 

TIFFANY (NY), LLC, 

v. 

Plaintiff, 

CHEN YAOQUIANG, et al., 

Defendants. 

_____________________________________/ 





ON PLAINTIFF’S EX PARTE APPLICATION FOR ENTRY OF 


This matter came before the Court upon Plaintiff’s Ex Parte Application for 


1 

6]. Based on the motion, affidavits and documents submitted therewith, Plaintiff’s 

Motion should be GRANTED insofar as the Ex Parte Motion should be entered and a 

preliminary injunction hearing should be set for December 27, 2011. 






disserve the public interest. See, e.g., Tefel v. Reno, 180 F.3d 1286, 1295 (11th Cir 

1 

By Order dated November 21, 2011, the Honorable Ursula Ungaro referred this 

motion to the undersigned [D.E. 7].



261 







In this case, Tiffany (NJ), LLC (“Tiffany”) makes a sufficient evidentiary 

showing to support issuing a temporary restraining order. The Court bases its ruling 

on the facts found in Tiffany’s Complaint, Ex Parte Motion, Declarations of Stephen M. 

2 3 4 

Gaffigan (Tiffany’s attorney”), Steven Costello, Brandon Tanori, exhibits thereto and 

the complete record. 

Tiffany is engaged in the manufacture, promotion, distribution, and sale in 

interstate commerce of high quality jewelry, including bracelets, necklaces, pendants, 

earrings, rings, watches and gift boxes under multiple federally registered trademarks. 

Costello Decl. at 4-5. Tiffany is the owner of all rights in and to those trademarks 

2 

See [D.E. 6-5; Declaration of Stephen M. Gaffigan (“Gaffigan Decl.”)]. 

3 

Tiffany’s trademark enforcement specialist, who is responsible for Tiffany’s 

trademark and anti-counterfeiting efforts in the Unites States. See [D.E. 6-2; 

Declaration of Steven Costello (“Costello Decl.”) at 3]. 

4 

An employee of Investigative Consultants, a licensed private investigative firm 

that Tiffany hired to investigate the suspected sale of counterfeit versions of Plaintiff’s 

products by Defendants via the Internet. See [D.E. 6-13; Declaration of Brandon Tanori 

(“Tanori Decl.”) at 2-3]. 

2



261 

which are valid and registered on the Principal Register of the United States Patent 

and Trademark Office (collectively the “Tiffany Marks”). Costello Decl. at Ex. A. 

Defendants have advertised, offered for sale and/or sold jewelry, including 

bracelets, necklaces, pendants, earrings, rings, watches and gift boxes bearing 

counterfeit and infringing trademarks which are exact copies of the Tiffany Marks. Id. 

at 9, 11-12; Tanori Decl. at 4-12, Ex. A-U; Gaffigan Decl. at 2-3, Comp. Ex. A, 

B. The Tiffany Marks have never been assigned or licensed to the Defendants, and the 

Defendants do not have, nor have they ever had, the right or authority to use the 

Tiffany Marks. Costello Decl. at 9. 

Tiffany retained Brandon Tanori (“Tanori”) to investigate the suspected sale of 

counterfeit versions of its products by the Defendants through the internet on various 

5 

domain names operated by them. Costello Decl. at 10; Tanori Decl. at 3. Tanori 

accessed three of Defendants’ websites (“discounttiffanyweb.com,” “shinytiffany.com” 

and “tiffany-necklace.biz”) and placed orders to purchase various Tiffany products 

including a necklace and two bracelets – each product bore at least one counterfeit 

Tiffany Mark – to be shipped to Miami, Florida. Tanori Decl. at 4, Ex. A. Tanori paid 

for these items through PayPal to the merchant identified as Chen Yaochiang 

(discounttiffanyweb@hotmail.com), Lv Shuxin (suwgday@gmail.com) and Qui Shaomin 

(modenthree@hotmail.com), respectively. In addition to those websites, Tanori also 

accessed the other Subject Domain Names and completed the same purchase process 

5 

A list of Defendants’ domain names (“Subject Domain Names”) is reproduced 

below at Schedule “A.” 

3



261 

for the Tiffany-branded products. Tanori Decl. at 7-24, Exs. D-U. Tanori 

communicated with these Defendants electronically via e-mail and/or on-site contact 

page and received information for finalizing payment for each of the Tiffany-branded 

items purchased via PayPal to Defendants’ respective PayPal accounts: 

Subject Domain Name PayPal Account 

925jewelryoutlet.com jimmy2011097@hotmail.com 

chanjewelry.com goseem@hotmail.com 

china-cheap-bags.com yuyoucun@live.com 

cooltrade123.com mybestsugar@yahoo.com.cn 

crowntco.com tonyjian57@gmail.com 

freshshippingnow.com freeshippingnow@yahoo.com 

heidoudou.com susanyan214@hotmail.com 

intbay.com intbayservice@gmail.com 

itisbags.com fashionlee1990@hotmail.com 

jackcart.com paypal_pay@yahoo.com 

jewelryshop365.com pengpengebaystore@gmail.com 

myluxuryshop.info billing@bagbook.info 

progiftstore.com glassface001@gmail.com 

sitetiffany.com number1949@hotmail.com 

tiffanycorings.com tradetoworld@hotmail.com 

tiffanyjewelryoutletus.org onlinemallsale@hotmail.com 

tiffanyjewlryoutletusa.org onlinemallsale@hotmail.com 

Tanori Decl. 7-24, Exs. D-U. 

Tiffany’s representative Costello reviewed the detailed web page listings and 

images of the Tiffany branded necklace and bracelets that Tanori purchased from the 

4



261 

websites operated by “discounttiffanyweb.com,” “shinytiffany.com” and “tiffany- 

necklace.biz” and determined the products to be non-genuine, unauthorized Tiffany 

products. Costello Decl. 11, 14. Costello also reviewed and visually inspected all 

of the Subject Domain Name websites, as well as pictures of items bearing the Tiffany 

Marks offered for sale on those websites and determined that the products were not 

genuine Tiffany products. Id. at 12-14, Ex. B. 

On this record, we find that Tiffany has a substantial likelihood of success on the 

merits and thus satisfied this prong. 

Moreover, Defendants’ unauthorized use of the Tiffany Marks and sale of 

counterfeit products is sufficiently likely to cause confusion that may “by itself 


L.P. v. Barrow, 143 F. App’x 180, 191 (11th Cir. 2005) (citing McDonald’s Corp. v. 


us, Tiffany is likely to suffer an irreparable injury to its reputation if Defendants are 

permitted to continue their activities. 



far outweighed by the potential harm to Tiffany, its reputation and goodwill as 

manufacturer of, among other things, high quality jewelry. Furthermore, public 

interest favors issuance of the temporary restraining order in order to protect Tiffany’s 

trademarks and the public from Defendants’ sale of non-genuine products. 

5



261 




other websites to evade Tiffany’s ability to obtain the relief sought. We find good cause 

exists for entry of this Order without notice to Defendants to assure retention of the 

Subject Domain Names under the control of this Court. We thus find that Tiffany’s 

counsel’s certification attached to the Motion has merit and satisfies Rule 65(b)(1)(B). 

See Gaffigan Decl. at 4-7. 

Under 15 U.S.C. § 1117(a), Tiffany may be entitled to recover, as an equitable 

remedy, the illegal profits gained through Defendants’ distribution and sale of 

counterfeit and infringing Tiffany branded goods. See Reebok Int’l, Ltd. v. Marnatech 

Enters., Inc., 970 F.2d 552, 559 (9th Cir. 1992) (quoting Fuller Brush Products Co. v. 

Fuller Brush Co., 299 F.2d 772, 777 (7th Cir. 1962) (“An accounting of profits under § 

1117(a) is not synonymous with an award of monetary damages: ‘[a]n accounting for 

profits... is an equitable remedy subject to the principles of equity.’”)). 






6



261 


Defendants’ blatant violation of the federal trademark laws, Tiffany has good reason 

to believe Defendants will hide or transfer their ill-gotten assets beyond the 


Based on the foregoing reasons, we RECOMMEND that Tiffany’s Ex Parte 

Motion [D.E. 6] be GRANTED. It should also be ORDERED and ADJUDGED as 

follows: 







the Tiffany Marks, or any confusingly similar trademarks, other 

than those actually manufactured or distributed by Tiffany; and 



distributed by Tiffany, bearing the Tiffany Marks, or any 

confusingly similar trademarks; or (ii) any evidence relating to the 

manufacture, importation, sale, offer for sale, distribution, or 

transfer of any products bearing the Tiffany Marks, or any 




notice of this Order shall immediately discontinue the use of the Tiffany Marks or any 

confusingly similar trademarks, on or in connection with all Internet websites owned 

7



261 

and operated, or controlled by them including the Internet websites operating under 




notice of this Order shall immediately discontinue the use of the Tiffany Marks, or any 


markers within website source code, from use on any webpage (including as the title 

of any web page), any advertising links to other websites, from search engines’ 



owned, or operated by each Defendant, including the Internet websites operating under 





to transfer to Tiffany’s counsel, for deposit with this Court, domain name certificates 

for the Subject Domain Names; 


Domain Names, within ten (10) days of receipt of this Temporary Restraining Order 

shall caused to be changed or change the registrar of record for the Subject Domain 

Names to a holding account with the United States based Registrar, GoDaddy.com, 

Inc. Upon transfer of the Subject Domain Names into the holding account, 

8



261 

GoDaddy.com, Inc. will hold the Subject Domain Names in trust for the Court during 

the pendency of this action. Additionally, GoDaddy.com, Inc. shall immediately update 

the Domain Name System (“DNS”) data it maintains for the Subject Domain Names, 

which links the domain names to the IP addresses where their associated websites are 

hosted, to NS1.MEDIATEMPLE.NET and NS2.MEDIATEMPLE.NET, which will 

cause the domain names to resolve to the website where a copy of the Complaint, 

Summonses, and Temporary Restraining Order and other documents on file in this 

action are displayed. Alternatively, GoDaddy.com, Inc. may institute a domain name 

forwarding which will automatically redirect any visitor to the Subject Domain Names 

to the following Uniform Resource Locator (“URL”) 

http://www.servingnotice.com/yaoqiang/index.html whereon a copy of the Complaint, 


action are displayed. After GoDaddy.com, Inc. has effected this change the Subject 

Domain Names shall be placed on Lock status, preventing the modification or deletion 

of the domains by the registrar or the Defendants; 

7. Tiffany may enter the Subject Domain Names into Google’s Webmaster 






9



261 



9. Upon receipt of this Order, PayPal, Inc. (“PayPal”) and its related 


PayPal account recipients: discounttiffanyweb@hotmail.com, suwgday@gmail.com, 

modenthree@hotmail.com, jimmy20110907@hotmail.com, goseem@hotmail.com, 

yuyoucun@live.com, mybestsugar@yahoo.com.cn, tonyjian57@gmail.com, 

freeshippingnow@yahoo.com, billing@bagbook.info, susanyan214@hotmail.com, 

intbayservice@gmail.com, fashionlee1990@hotmail.com, paypal_pay@yahoo.cn, 

pengpengebaystore@gmail.com, glassface001@gmail.com, number1949@hotmail.com, 

tradetoworld@hotmail.com, onlinemallsale@hotmail.com and any other related 

accounts of the same customer(s); 



to, all PayPal accounts related to the PayPal account recipients 

discounttiffanyweb@hotmail.com, suwgday@gmail.com, modenthree@hotmail.com, 

jimmy20110907@hotmail.com, goseem@hotmail.com, yuyoucun@live.com, 

mybestsugar@yahoo.com.cn, tonyjian57@gmail.com, freeshippingnow@yahoo.com, 

billing@bagbook.info, susanyan214@hotmail.com, intbayservice@gmail.com, 

fashionlee1990@hotmail.com, paypal_pay@yahoo.cn, pengpengebaystore@gmail.com, 

glassface001@gmail.com, number1949@hotmail.com, tradetoworld@hotmail.com, and 

onlinemallsale@hotmail.com and any other related accounts of the same customer(s); 

10



261 


provide Tiffany’s counsel with all data which identifies the PayPal accounts frozen, as 

well as an accounting of the funds in the frozen accounts. Such freezing of the accounts 

and the disclosure of the related finanical institution account information shall be 

made without notice to the account owners or the financial institutions until further 

order fo this Court. PayPal shall receive and maintain this Order and its contends as 

confidential until further order of this Court. Tiffany’s counsel shall bear any costs to 

PayPal arising from this request. 





13. Pursuant to 15 U.S.C. § 1116(d)(5)(D), Tiffany shall post a bond in the 


to which Defendants may be entitled for a wrongful injunction or restraint. Tiffany 

shall post the bond prior to requesting the Registry to transfer control of the Subject 

Domain Names; 


14. An evidentiary hearing shall take place on Tuesday, December 27, 2011, 

at 3:00 p.m., James Lawrence King Bldg., 99 N.E. Fourth Street, Tenth Floor, 

Courtroom 5, Miami, Florida, before the undersigned Magistrate Judge. Defendants 

11



261 

shall present evidence at that hearing why the temporary restraining order should be 

vacated and why a preliminary injunction order pending trial not be entered. 

15. Tiffany shall serve a copy of the Ex Parte Application for TRO and this 

Order on each Defendant via their known e-mail addresses, specifically: upon 

Defendant Chen Yaoqiang at the e-mail addresses,discountdownjacket@gmail.com and 

discounttiffanyweb@hotmail.com; upon Defendant Xiao Feng at the e-mail addresses, 

51321641@qq.com and noreplay@sendmailhost.com; upon Defendant Ma Xisheng at 

the e-mail address, lasig@sohu.com; upon Defendant Xiaoli Xiang at the e-mail 

address, yuansunet@gmail.com; upon Defendant Lv Shuxin at the e-mail addresses, 

support@hostmonster.com and shinytiffany@gmail.com; upon Defendant Zhenyao Xu 

at the email addresses, 137675539@qq.com, 314167127@qq.com, 

tiffanyjewelryoutletusa@hotmail.com, tiffanyjewelryoutletus@hotmail.com, and 

ttfyggi4eb34239761c9@oqjij874d9300d54bd95.privatewhois.net; and upon Defendant 

Qiu Shaomin at the e-mail addresses, TIFFANY- 

NECKLACE.BIZ@domainsbyproxy.com, service@tiffany-necklace.biz, and 

tiffanynecklace@hotmail.com, and upon the remaining Defendants via the 

corresponding e-mail addresses provided to the Registrars responsible for the Subject 

Domain Names and the customer service e-mail addresses used to communicate with 

Tiffany’s investigator all of which are identified on Schedule “B” hereto. In addition, 

Tiffany shall post a copy of the Complaint, Summonses, the Ex Parte Application for 

TRO and this Order, as well as all other documents filed in this action on the website 

located at http://www.servingnotice.com/yaoqiang/index.html, upon transfer of the 

12



261 

Subject Domain Names into the holding account with GoDaddy.com, Inc., and such 

notice so given shall be deemed good and sufficient service thereof. Any response or 

opposition to Tiffany’s Motion for Preliminary Injunction must be filed with the Court 

and served on Tiffany’s counsel by December 19, 2011. Tiffany shall file any Reply 

Memorandum on or before December 23, 2011. The above dates may be revised upon 

stipulation by all parties and approval of this Court. Defendants are hereby on notice 

that failure to appear at the hearing may result in the imposition of a preliminary 

injunction against them pursuant to 15 U.S.C. § 1116(d) and Fed. R. Civ. P. 65. 


December, 2011. 

13 






261 


SUBJECT DOMAIN NAMES 

Defendant 1: 925jewlryoutlet.com 

Defendant 2: chanjewlrey.com 

Defendant 3: china-cheap-bags.com 

Defendant 4: cooltrade123.com 

Defendant 5: crowntco.com 

Defendant 6: discounttiffanyweb.com 

Defendant 7: freeshippingnow.com 

Defendant 8: handbagestore.info 

Defendant 9: heidoudou.com 

Defendant 10: intbay.com 

Defendant 11: itisbay.com 

Defendant 12: jackcart.com 

Defendant 13: jewelryshop365.com 

Defendant 14: myluxuryshop.info 

Defendant 15: progiftstore.com 

Defendant 16: shinytiffany.com 

Defendant 17: sitetiffany.com 

Defendant 18: tiffanycorings.com 

Defendant 19: tiffanyjewelryoutletes.com, tiffanyjewelryoutletus.org, 

tiffanyjewelryoutletusa.org, tiffanyjewelryoutletu.com 

Defendant 20: tiffany-necklace.biz 

14



261 

Defendant 

Number 

Defendant 

1 

Defendant 

2 

Defendant 

3 

Defendant 

4 

Defendant 

5 

Defendant 

6 

Defendant 

7 

Defendant 

8 

Defendant 

9 

Defendant 

10 

Defendant 

11 

Defendant 

12 

Defendant 

13 

Defendant 

14 

Defendant 

15 

Defendant 

16 

SCHEDULE B 



Defendant / 


E-Mail Addresses 

925jewelryoutlet.com heting@126.com 

chanjewelry.com 

china-cheap-bags.com 

cooltradel23.com 

crowntco.com 

discounttiffanyweb.com 

freeshippingnow.com 

handbagestore.info 

heidoudou.com 

intbay.com 

itisbags.com 

jackcart.com 

jewelryshop3 65.com 

myluxuryshop.info 

progiftstore.com 

shinytiffany.com 

15 

fashion8958@gmail.com 

hostmaster@lunarpages.com 

925arthur@gmail.com 

mydata@163.com 

zhihua2008@live.com 

cooltradel23@yahoo.com.cn 

crowntco@gmail.com 

discountdownjacket@gmail.com 

discounttiffanyweb@hotmail.com 

contact@privacyprotect.org 

info@freeshippingnow.com 

1057529439@qq.com 

78579554@163.com 

sales@heidoudou.com 

newdomains@siteground.com 

51321641@qq.com 

noreplay@sendmailhost.com 

lasig@sohu.com 

newdomains@siteground.com 

jewelryshop365@gmail.com 

babalal 518@gmail.com 

1057529439@qq.com 

yuansunet@gmail.com 

support@hostmonster.com 

shinytiffany@gmail.com



261 

Defendant 

17 

Defendant 

18 

Defendant 

20 

sitetiffany.com 

tiffanycorings.com 

tiffanyjewelryoutletes.com 

Defendant tiffanyjewelryoutletus.org 

19 tiffanyjewelryoutletusa.org 

tiffanyjewelryoutletu.com 

tiffany-necklace.biz 

lzx888999@yahoo.com.cn 

parksoncoltd@gmail.com 

hhl_happy@yeah .net 

tiffanycorings@gmail.com 

137675539@qq.com 

314167127@qq.com 

tiffanyjewelryoutletusa@hotmail.com 

tiffanyjewelryoutletus@hotmail.com 

ttfyggi4eb34239761c9@oqjij874d9300d54bd95.privatewhois.net 

TIFFANY-NECKLACE.BIZ@domainsbyproxy.com 

service@tiffany-necklace.biz 

tiffanynecklace@hotmail.com 

16



261 

PHILIP MORRIS USA INC, 

vs. 

� 

Plaintiff, 

ZHILIN JIANG, et al., 

Defendants. 

IN THE UNITED STATES DISTRICT COURT 

FOR THE SOUTHERN DISTRICT OF FLORIDA 


ORDER GRANTING EX PARTE APPLICATION 

FOR A TEMPORARY RESTRAINING ORDER 

1 

/ 

THIS CAUSE came before the Court upon Plaintiff’s Ex Parte Application for Entry of 


Tied to the Counterfeiting Operation (“Plaintiff’s Ex Parte Application”) (ECF No. 7). UPON 

CONSIDERATION of the Motion, the pertinent portions of the Record, and being otherwise 

fully advised in the premises, the Court enters the following Order. 

I. BACKGROUND 1 

Plaintiff Philip Morris USA is the registered owner of numerous trademarks used in 

connection with the manufacture and distribution of cigarettes. Among these trademarks are 

trademarks associated with United States Patent and Trademark Office (“USPTO”) No. 68,502, 

registered on April 14, 1908, and USPTO No. 938,510, registered on July 25, 1972 (collectively, 

“Philip Morris USA Marks”). Defendants are unknown individuals, residing in the People’s 

Republic of China (“PRC”), who are believed to use, or assist others in using, the aliases “Lin 

�� 

1 

The facts herein are taken from Plaintiff’s Complaint (ECF No. 1) and Plaintiff’s Ex Parte 

Application (ECF No. 7).



261 

Wenquan,” “Li Xiaodong,” “Xiao Zhang,” “Asdf Asd,” “Asdfaasd Dfsh,” “Asdfaasd Dsh,” 

“Asdfaasd Ja,” and “Wang Guobing.” 

� 

Recently Plaintiff became aware of the potential sale of counterfeit versions of Plaintiff’s 

products by Defendants. This is alleged to have been accomplished by Defendants through the 

operation of commercial Internet websites operating under domain names such as 

marlborocigarette.biz, marlboro-gold.biz, and marlborowholesale.com. 2 In response to 

Defendants’ alleged trademark infringement, Plaintiff retained Investigative Consultants, a 

licensed private investigative firm, to investigate the sale of counterfeit versions of Plaintiff’s 

products by Defendants. 

From September 2011 through October 2011, Brandon Tanori, an employee of 

Investigative Consultants, purchased a number of cigarettes bearing the Philip Morris USA 

Marks at issue via the various Internet websites operated by Defendants. See Decl. of Brandon 

Tanori (ECF No. 7-12), at 4–16. Tanori was able to purchase these cigarettes using either 

Western Union (with a Money Transfer Control Number provided by Defendants), or Paypal. Id. 

Upon his receipt of the purchased goods, Mr. Tanori forwarded the products to Philip Morris 

USA’s representative, Sissy S. Sawyer, for physical inspection. Id. Ms. Sawyer personally 

examined each carton—and at least one pack of cigarettes from each carton—and determined 

that the cartons and packs of what appeared to be Marlboro cigarettes were in fact counterfeit. 

See Decl. of Sissy S. Sawyer (ECF No. 7-2), at 16–17. Additionally, Ms. Sawyer reviewed 

and visually inspected the Internet websites operating under each of the Subject Domain Names, 

as well as pictures of items bearing the Philip Morris USA Marks offered for sale on the Internet 

�� 

2 The complete list of websites includes nearly sixty domain names. For a complete list, see 

Schedule A of this Order. � 

2



261 

websites, and determined that the products were not genuine and/or authorized Philip Morris 

USA products. Id. 

II. LEGAL STANDARD 

show that 

� 

In order to prevail on a motion for an ex parte temporary restraining order, Plaintiff must 

(1) it clearly appears from specific facts shown by affidavit or by the verified 

complaint that immediate and irreparable injury, loss, or damage will result to the 

applicant before the adverse party or that party’s attorney can be heard in 

opposition, and (2) the applicant’s attorney certifies to the court in writing the 

efforts, if any, which have been made to give the notice and the reasons 

supporting the claim that notice should not be required. 

Fed. R. Civ. P. 65(b). “An ex parte restraining order is an extreme remedy only to be used with 

the utmost caution.” Levine v. Comcoa, Ltd., 70 F.3d 1191, 1194 (11th Cir. 1995). 

Once the moving party meets the threshold requirements of Rule 65(b) to secure an ex 

parte temporary restraining order, Plaintiff must demonstrate (1) a substantial likelihood of 

success on the merits; (2) that irreparable injury will be suffered unless the injunction issues; (3) 

the threatened injury to the movant outweighs whatever damage the proposed injunction may 

cause the opposing party; and (4) if issued, the injunction would not be adverse to the public 

interest in order to obtain injunctive relief. Four Seasons Hotels and Resorts, B.V. v. Consorcio 

Barr, S.A., 320 F.3d 1205, 1210 (11th Cir. 2003); McDonald’s Corp. v. Robertson, 147 F.3d 

1301, 1306 (11th Cir. 1998). 

III. ANALYSIS 

The declarations Plaintiff submitted in support of its Application for a temporary 

restraining order (“TRO”) support the following conclusions of law: 

1. Plaintiff has a very strong probability of proving at trial that consumers are likely to be 

confused by Defendants’ advertisement, promotion, sale, offer for sale, and/or 

3



261 

� 

distribution of cigarettes bearing counterfeits, reproductions, and/or colorable imitations 

of the Philip Morris USA Marks, and that the cigarettes Defendants are selling are copies 

of Plaintiff’s cigarettes that bear copies of the Philip Morris USA Marks. 

2. Because of the infringement of the Philip Morris USA Marks, Plaintiff is likely to suffer 

immediate and irreparable injury if a temporary restraining order is not granted. 

a. Through the operation of nearly sixty commercial Internet websites Defendants 

are operating Internet businesses which advertise, promote, offer for sale, and sell, 

cigarettes bearing counterfeit and infringing trademarks in violation of Plaintiff’s 

rights; 

b. There is good cause to believe that more counterfeit and infringing cigarettes 

bearing Plaintiff’s trademarks will appear in the marketplace; that consumers may 

be misled, confused, and disappointed by the quality of these cigarettes; and that 

Plaintiff may suffer loss of sales for its genuine cigarettes; 

c. Given the ease with which Defendants may transfer and/or redirect commercial 

activity from one Internet Domain Name to another, there is good cause to believe 

that if Plaintiff proceeds on notice to Defendants on this Application for TRO, 

Plaintiff’s ability to obtain meaningful relief will be thwarted; 

d. The balance of potential harm to Defendants in restraining their trade in 

counterfeit and infringing branded products if a TRO is issued is far outweighed 

by the potential harm to Plaintiff, its reputation and goodwill as a manufacturer of 

high quality products, if such relief is not issued; and 

4



261 

� 

e. The public interest favors issuance of the TRO in order to protect Plaintiff’s 

trademark interests and the public from being defrauded by the palming off of 

counterfeit products as genuine products of Plaintiff. 

3. Under 15 U.S.C. § 1117(a), Plaintiff may be entitled to recover, as an equitable remedy, 

the illegal profits gained through Defendants’ distribution and sales of cigarettes bearing 

counterfeits and infringements of the Philip Morris USA Marks. 

4. Requesting equitable relief “invokes the district court’s inherent equitable powers to 

order preliminary relief, including an asset freeze, in order to assure the availability of 

permanent relief.” Levi Strauss & Co. v. Sunrise Int’l Trading Inc., 51 F.3d 982, 987 

(11th Cir. 1995) (citing Fed. Trade Comm’n v. U.S. Oil and Gas Corp., 748 F.2d 1431, 

1433–34 (11th Cir. 1984)). 

5. In light of the inherently deceptive nature of the counterfeiting business, and Defendants’ 

blatant violation of the federal trademark laws, Plaintiff has good reason to believe 

Defendants will hide or transfer their ill-gotten assets beyond the jurisdiction of this 

Court unless those assets are restrained. 

IV. CONCLUSION 

For the foregoing reasons, it is ORDERED AND ADJUDGED that Plaintiff’s Ex Parte 

Application (ECF No. 7) is GRANTED. It is further 

ORDERED AND ADJUDGED that 



are hereby temporarily restrained: 

5



261 

� 

a. From manufacturing, importing, advertising, promoting, offering to sell, selling, 

distributing, or transferring any products bearing the Philip Morris USA Marks, or 

any confusingly similar trademarks, other than those actually manufactured or 




bearing the Philip Morris USA Marks, or any confusingly similar trademarks; or 

(ii) any evidence relating to the manufacture, importation, sale, offer for sale, 

distribution, or transfer of any products bearing the Philip Morris USA Marks, or 




shall immediately discontinue the use of the Philip Morris USA Marks or any 

confusingly similar trademarks, on or in connection with all Internet websites owned and 

operated, or controlled by them including the Internet websites operating under the 

Subject Domain Names; 3 



shall immediately discontinue the use of the Philip Morris USA Marks, or any 


markers within website source code, from use on any webpage (including as the title of 

any web page), any advertising links to other websites, from search engines' databases or 

�� 

3 See Schedule A of this Order. 

6



261 

� 

cache memory, and any other form of use of such terms which is visible to a computer 

user or serves to direct computer searches to websites registered by, owned, or operated 

by each Defendant, including the Internet websites operating under the Subject Domain 

Names; 

4. Each Defendant shall not transfer ownership of the Subject Domain Names during the 



Plaintiff’s counsel, for deposit with this Court, domain name certificates for the Subject 

Domain Names; 

6. The Registrars and the top-level domain (TLD) Registries for the Subject Domain 

Names, within ten (10) days of receipt of this TRO, shall cause to be changed or change 

the registrar of record for the Subject Domain Names, excepting any such domain names 

which such Registries have been notified in writing by Plaintiff have been or will be 

dismissed from this action, to a holding account with the United States based Registrar, 

GoDaddy.com, Inc. Upon transfer of control over the Subject Domain Names into the 

holding account, GoDaddy.com, Inc. will hold the registrations for the Subject Domain 

Names in trust for the Court during the pendency of this action. Additionally, 

GoDaddy.com, Inc. shall immediately update the Domain Name System (“DNS”) data it 

maintains for the Subject Domain Names, which links the domain names to the IP 

addresses where their associated websites are hosted, to NS1.MEDIATEMPLE.NET and 

NS2.MEDIATEMPLE.NET, which will cause the domain names to resolve to the 

website where a copy of the Complaint, Summonses, Temporary Restraining Order, and 

other documents on file in this action are displayed. Alternatively, GoDaddy.com, Inc. 

7



261 

� 

may institute a domain name forwarding which will automatically redirect any visitor to 

the Subject Domain Names to the following Uniform Resource Locator (“URL”), 

http://servingnotice.com/jiang/index.html, whereon a copy of the Complaint, 

Summonses, Temporary Restraining Order, and other documents on file in this action are 

displayed. After GoDaddy.com, Inc. has effected this change the Subject Domain Names 

shall be placed on Lock status, preventing the modification or deletion of the domains by 

the registrar or Defendants; 

7. Plaintiff may enter the Subject Domain Names into Google’s Webmaster Tools and 

cancel any redirection of the domains that have been entered there by Defendants which 



8. Each Defendant shall preserve copies of all their computer files relating to the use of any 

of the Subject Domain Names and shall take all steps necessary to retrieve computer files 

relating to the use of the Subject Domain Names that may have been deleted before the 

entry of this Order; 

9. Upon receipt of this Order, Western Union Financial Services, Inc. (“Western Union”) 

shall divert all money transfers sent by United States consumers to: (1) Zhilin Jiang in 

Putian, China, with the date of birth and identification number provided by the recipient 

of MTCN 455-906-9491; (2) Haidong Huang in Putian, China, with the date of birth and 

identification number provided by the recipient of MTCN 853-673-9729; and (3) 

Haidong Huang in Putian, China, with the date of birth and identification number 

8



261 

� 

provided by the recipient of MTCN 9464580813, and hold such transfers until it receives 

further direction from the Court; 4 

10. In the event any money transfers are diverted in accordance with Paragraph 9 of this 

Order, Western Union shall be permitted to inform consumers who may contact Western 

Union about the transfers that the transfers are being held pursuant to a Court Order in 

Philip Morris USA Inc. v. Jiang, entered by the United States District Court for the 

Southern District of Florida and that they may contact Plaintiff's counsel for additional 

information; 

11. Western Union shall also, within five business days of receiving this Order, provide to 

Plaintiff's counsel records of all money transfers that have been paid to: (1) Zhilin Jiang 

in Putian, China, with the date of birth and identification number provided by the 

recipient of MTCN 455-906-9491; (2) Haidong Huang in Putian, China, with the date of 

birth and identification number provided by the recipient of MTCN 853-673-9729; and 

(3) Haidong Huang in Putian, China, with the date of birth and identification number 

provided by the recipient of MTCN 9464580813, as well as records of money transfers 

that have been diverted in accordance with Conclusion Paragraph 9 of this Order. For 

any transfers that have been diverted in accordance with this Order, Plaintiff's counsel 

will respond to any consumer inquiries and will provide notice of the Order and the 

disposition of the transfers to any affected consumer; 

12. This Temporary Restraining Order shall remain in effect until the date for the hearing on 

the Motion for Preliminary Injunction set forth below, or until such further dates as set by 

the Court or stipulated to by the parties, but under no circumstances shall this Temporary 

�� 

4 Western Union is licensed to do business in the State of Florida by the Florida Office of 

Financial Regulation and is therefore subject to personal jurisdiction in this Court. 

9



261 

� 

Restraining Order remain in effect for more than fourteen (14) days from the date of this 

Order; 

13. Pursuant to 15 U.S.C. § 1116(d)(5)(D), Plaintiff shall post a bond in the amount of One 

Hundred Thousand Dollars and Zero Cents ($100,000.00), as payment of damages to 

which Defendants may be entitled for a wrongful injunction or restraint. Plaintiff shall 

post the bond prior to requesting the Registry to transfer control of the Subject Domain 

Names; 

14. A hearing is set before this Court in the United States Courthouse located at 400 North 

Miami Avenue, Miami, Florida 33128, Courtroom 13-1, on November 21, 2011, at 

10:30am, at which time Defendants and/or any other affected persons may challenge the 

appropriateness of this Order and move to dissolve the same and at which time the Court 

will hear argument on Plaintiff’s requested preliminary injunction; 

15. Plaintiff shall serve a copy of the Ex Parte Application for TRO and this Order on 

Defendants via their known e-mail addresses; specifically the e-mail addresses provided 

to the Registrars responsible for the Subject Domain Names: 1@qq.com, 

1394376540@qq.com, 1664536152@qq.com, 1668132581@qq.com, 737561273 

@qq.com, contact@privacyprotect.org, and elicoco@qq.com; and the customer service e- 

mail addresses used to communicate with Plaintiff’s investigator: 

mygodcigar@hotmail.com, and anniecig2011@hotmail.com. In addition, Plaintiff shall 

post a copy of the Application for TRO and this Order on the website located at 

http://servingnotice.com/jiang/index.html, upon transfer of the Subject Domain Names 

into the holding account with GoDaddy.com, Inc., and such notice so given shall be 

deemed good and sufficient service thereof. Any response or opposition to Plaintiff’s 

10



261 

� 

Motion for Preliminary Injunction must be filed and served on Plaintiff’s counsel forty- 

eight (48) hours prior to the hearing set for November 21, 2011, and filed with the Court, 

along with Proof of Service, on or before November 19, 2011. Plaintiff shall file any 

Reply Memorandum on or before November 20, 2011. The above dates may be revised 

by this Court or upon stipulation by all parties and approval of this Court. Defendants are 

hereby on notice that failure to appear at the hearing may result in the imposition of a 

preliminary injunction against them pursuant to 15 U.S.C. § 1116(d) and 

Fed. R. Civ. P. 65. 

DONE AND ORDERED in Chambers at Miami, Florida, this ____ day of November, 2011. 

cc: All counsel of record 

11 

________________________________ 

K. MICHAEL MOORE 


Case 1:11-cv-24049-KMM 1:12-cv-23295-JLK Document 6-10 11 Entered on on FLSD Docket 11/16/2011 09/12/2012 Page 12 189 of 12 of 

261 


1. cheapcigarettes-online.net 

2. cheapmarlborocigarettes.org 

3. cheappricecigarettes.com 

4. cigarettesnewport.com 

5. cigarettes-online.org 

6. cigarettesonline.us 

7. discountcamelcigarettes.com 

8. discountscigarette.com 

9. koolcigarettes.us 

10. marlborocigarette.biz 

11. marlborocigarettes.biz 

12. marlboro-cigarettes.us 

13. marlborocigarettescoupons.com 

14. marlborocigarettesus.com 

15. marlborogold.biz 

16. marlboro-gold.biz 

17. marlboro-gold.net 

18. marlboro-gold.org 

19. marlborogold.us 

20. marlborogoldcigarettes.com 

21. marlborolights.biz 

22. marlboro-lights.biz 

23. marlboro-lights.net 

24. marlborolights.us 

25. marlboro-lights.us 

26. marlborored.org 

27. marlbororedcigarettes.biz 

28. marlbororedcigarettes.com 

29. marlbororedcigarettes.net 

� 

SCHEDULE A 


12 

30. marlbororedcigarettes.org 

31. marlbororedcigarettes.us 

32. marlborosale.com 

33. marlboroskyline.biz 

34. marlborowholesale.com 

35. newport100s.biz 

36. newport100s.com 

37. newport100s.us 

38. newportbox100s.biz 

39. newportbox100s.com 

40. newportbox100s.net 

41. newportbox100s.org 

42. newportbox100s.us 

43. newportcigarette.net 

44. newportcigaretteswebsite.biz 

45. newportcigaretteswebsite.org 

46. newportcigaretteswebsite.us 

47. newportcigaretteswholesale.biz 

48. newportcigaretteswholesale.com 

49. newportcigaretteswholesale.us 

50. newportmentholbox.biz 

51. newportmentholbox.com 

52. newportmentholbox.net 

53. newportmentholbox.us 

54. newportmentholcigarettes.com 

55. newportregular.com 

56. newportscigarettes.net 

57. newportshort.com 

58. uppermarlborocigarettes.com

D 



261 

ACUSHNET COMPANY, ef aI., 

VS . 

Plaintiffs, 

TANG HAm AN, ef al., 

Defendants. 



CASE NO. 1 1-23557-ClV-UNGARO 

ORDER GM NTING TEMPORARY RESTRAINING ORDER EXPARTE 

THIS C AUSE i s before t he C ourt on P laintiffs' Ex Parte Application f or Entry o f 


Tied to th e C ounterfeiting O peration (the $A pplication f or T RO'). The C ourt h as car efuly 

reviewed the Application, the entire court f5le and is otherwise fuly advised in the premises. 

By t he i nstant A pplication, Plaintifs A cushnet C ompany, C alaway Golf C ompany, 

Roger Cleveland Golf Company, lnc., SRI Sports Limited, Karsten Manufacturing Corporation, 

and Taylor M ade Golf Company, Inc. ( colectively 'Plaintifs') move ex parte, for entry of a 

temporary r estraining o rder against Defendants T ang H ainan, X ud Zhang, a nd D oes 1 -1 0 

(colectively (sDefendants') doing business as the domain names identified on Schedules $iA' and 

$iB' hereto (the isubject Domain N ames') and an order restraining the financial accounts used 

by Defendant Tang Hainan, pursuant to 15 U.S.C. j l 1 16 and Fed. R. Civ. P. 65. 

1. Factual Backeround 

The Court bases this Order on t he folowing facts from Plaintiffs' Complaint, Ex Parte 

Application for TRO, and supporting evidentiary submissions.



261 

Plaintiff Acushnet Company (itAcushnet') is a corporation organized under the l aws of 

Delaware, h aving i ts o ffice an d principal pl ace of bus iness at 333 B ridge S treet, Fairhaven, 

Massachusetts 02719 . (Compl. ! 2.) Acushnet is e ngaged i n t he m anufacture, pr omotion, 

distribution, and sale in interstate commerce, in cluding within th is Judicial D istrict, o f quality 

golf e quipment a nd r elattd pr oducts under multiple f ederaly registered tr ademarks. ( See 

Declaration of Lisa Rogan in Support of Ex Parte Application for TRO risRogan Decl,') !! 4-5.) 

Acushnet is the owner of al rights in and to the folowing trademarks which are valid and 

registered o n th e P rincipal R egister o f th e United S tates P atent and T rademark Office 

(colectively the 'Acushnet Marks'): 

Trademark Registration 

Number 


TITLEIST 316,1 18 August 14, 1934 IC 028 - golf balls 

TITLEIST 934.406 

IC 028 - golf equipment comprising golf balls, 

May 23, 1972 golf clubs, golf bags, golf gloves and golf 

headcovers 

IC 028 - golf equipment, namely, golf bals, 

. wz#,yx.o 1,j55,766 uay 26, I9s1 j- ujutjs and golf bags 

.2 # o 

Y W * l 3 60 l 3034 

June l2, 1990 IC 023 - golf bals 

' WWW 

PRO V1 2,806,919 January 20, 2004 IC 028 - golf balls 

AP2 3,83 1,911 August 10, 2010 IC 028 - golf clubs 

- - 3,83 1,914 August l0, 2010 IC 023 - golf clubs 

The Acushnet Marks are us ed i n c onnection w ith t he m anufacture a nd distribution of 

high qua lity goods in at least the categories id entified above. (See Rogan Decl. ! 5 ; see also 

United States Trademark Registrations o f th e Acushnet Marks at i ssue (éçAcushnet Trademark 

Registrations'l attached as Composite Exhibit A to the Rogan Decl.)



261 

Plaintif Calaway Golf Company (sfallaway Golf') is a comoration organized under the 

laws o f Delaware, having i ts office and pr incipal pl ace of bus iness at 2 180 Rutherford Road, 

Carlsbad, C alifornia 92 008. (Compl. ! 3.) Calaway Golf is en gaged i n t he m anufacture, 

promotion, d istribution, and sale in interstate commerce, including within th is Judicial District, 

of qua lity golf e quipment and rtlated products under multiple federaly registered trademarks. 

fsee Declaration of Mike Dow in Support of Ex Parte Application for TRO (siDow Decl.') !! 4- 

Calaway Golf is the owner of a 1 rights i n and to the folowing trademarks which are 

valid and registered on the Principal Register of the United States Patent and Trademark Office 

(colectively the 'icalaway Golf Marks'): 

Registration 

Trademark Registration Date Class / Goods 

Namber 

IC 028 - golf clubs, golf bags, golf club heads, 

Odyssey 1,704,295 July 28, 1992 golf club shafts, head covers for golf clubs, 

hand grips for golf clubss and golf balls 

IC 024 - golf towels 

IC 025 - shirts, sweaters, jackets, hats, caps 

Callaway Golf 2, 160, 157 May 26, 1998 and Visors 

IC 028 - golf clubss golf bags, and golf club 

head covers 

IC 024 - golf towels 

IC 025 - shirts, sweaters, jackets, hats, caps, 

41 2 161,569 lune 2, 1998 and ViS0rS 

mn ç ' IC 028 - golf clubs, golf bags, and golf club 

head covers 

Callaway 2,166,033 June 16, 1998 IC 028 - golf clubs 

Calaway 2,360,664 June 20, 2000 IC 023 - golf balls 

September 30. IC 028 - golf club, golf club head covers and 

Big Bertha 2,769,319 2003 golf bags



261 

IC 025 . shirts, sweaters, jackets, wind 

oth. 2 883,072 September 2004 7, resistantjackets, hats, caps, visors, pants, 

, 

shorts. t-shirts, golf shoes and spikes 

Callaway Golf 2,941,846 April l9, 2005 IC 025 . golf shoes and spikes 

FT-i 3,263,223 July l0, 2007 IC 028 - golf clubs 

IC 028 - covers for golf clubs; golf club 

FT-9 3,593,203 March l7, 2009 covers; golf clubs 

IC 028 - golf clubs; head covers for golf clubs) 

BI() BERTHA DIABI.f) 3.595,821 March 24, 2009 g olf bags; golf bals 

osia*o a oyy g(p September l , IC 028 - golf bags; golf bals; golf clubs; head 

+ ' ' 2009 covers for golfclubs 

IC 028 - golf clubs, golf club head covers, golf 

FT-iZ 3,737,687 January 12, 2010 b ags and component club heads 

X-24 HOT 3.:74,857 November 9, 2010 IC 028 - golf clubs 

RAZR Hawk 3,979,419 June 14, 20l l IC 028 - golf clubs 

The Callaway Golf Marks are used in connection with the manufacture and distribution 

of hi gh qua lity goods in at least the categories i dentified above. (See Dow Decl. ! 5 ; see also 

United S tates T rademark Registrations o f th e Calaway Golf Marks at i ssue ( icalaway Golf 

Trademark Registrations'j atached as Composite Exhibit A to the D0w Decl.) 

Plaintiff Roger Cleveland Golf Company, Inc. is a corporation organized under the laws 

of California, having its office and principal place of business at 5601 Skylab Road, Huntington 

Beach, California 92647. Plaintiff SRl Sports Limited is the parent company of Roger Cleveland 

Golf Company, lnc. and a corporation organized and existing under the Iaws of Japan, having its 

principle place of business in Chuo-Ku Kobe Japan. Roger Cleveland Golf Company, lnc. and 

SRl Sports Limited shal bejointly referred to herein as Cleveland Golf. (Compl. ! 4.) Cleveland 

Golf is e ngaged i n t he manufacture, pr omotion, di stribution, and s aIe i n i nterstate c ommerce, 

including w ithin th is J udicial D istrict, o f q uality golf equipment a nd r elated pr oducts under 

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multiple federally registered trademarks. (See Declaration of Donald J . Reino in Support of Ex 

Parte Application for TRO riReino Decl.'1 !! 4-5.) 

SRI Sports Limited is the owner, and Roger Cleveland Golf Company, lnc. is the licensee 

of al rights in and to the folowing trademarks, which are valid and registered on t he Principal 

Register o f t he United States P atent an d T rademark O ffice (colectively the dC leveland G olf 

)?1 ark s') 


Trademark Class / Goods 

Number Date 

IC 01 8 - carry a1I bags and umbrellas. 

IC 025 - golf apparel, namely, shirts, 

caps, visors, sweatshirts and sweater 

vests. 

el- ln-H 2,070,051 June 10, 1997 IC 028 - golf clubs, golf club heads, 

golf club shafts, golf club grips, golf 

bags, golf bag covers, and golf club 

head covers. 

IC 018 - carry all bags and umbrelas. 

IC 025 - golf apparel, namely, shirts. 

caps, visors, sweatshirts and sweater 

vests. 

CLEVELAND 2,070,054 June 10, 1997 IC 028 - golf clubs, golf club heads, 

golf club shafts, golf club grips, golf 

bags, golf bag covers, and golf club 

head covers. 

C 2 .302,25 1 December jqvg 21, heads IC 028 - golf clubs, and golf club 

, namely, woods, irons and puters 

IC 025 - Golf wear, namely, caps. 

Dccembcr l6, IC 028 - Bags, namely, golf bags, 

SRIXON 2,993,532 1997 equipment for golfk especially , but not 

limited to, golf balls, golf clubs. 

IC 028 - Golf clubs and golf club heads, 

namely, wedges, iron-type golf clubs 

ZlP GROOVES 3,463,468 July 8, 2008 and metal wood-type golf clubs and 

heads.



261 

The Cleveland Golf Marks are used in connection with the manufacture and distribution 

of high quality goods in at least the categories identified above. (See Reino Decl. ! 5 ; see also 

United States Trademark Registrations of the Cleveland Golf Marks at i ssue (ûfleveland Golf 

Trademark Registrations'j atached as Composite Exhibit A to the Reino Decl.) 

Plaintiff Karsten Manufacturing C orporation (iKarsten') is a c orporation or ganized 

under the laws o f Arizona having its office and principal place () f business at 2201 W . Desert 

Cove, Phoenix, Arizona 85029. (Compl. ! 5.) Karsten is engaged in the manufacture, promotion, 

distribution, and sale in interstate commerce, in cluding w ithin th is Judicial D istrict, o f q uality 

golf e quipment a nd r elated pr oducts under multiple f ederaly registered tr ademarks. ( See 

Declaration of Jud Hawken in Support of Ex Parte Application for TRO (isl-lawken Decl.'1 !! 4- 

5.) 

Karsten is the owner of all rights in and to the folowing trademark which is valid and 

registered o n t he P rincipal R egister o f t he United S tates P atent and T rademark O ffice (the 

iKarsten Mark') 



Number Date 

PING 704,552 

September 

1960 

20, 

IC 28 - Golf clubs 

The Karsten Mark i s used i n connection w ith the manufacture and di stribution of hi gh 

quality goods in at least the categories identified above. (See Hawken Decl. ! 5) see also United 

States Trademark Registrations of the Karsten Mark at issue (slKarsten Trademark Registration'l 

atached as Composite Exhibit A to the Hawken Decl.) 

Plaintiff Taylor M ade G olf C ompany, lnc., a s ubsidiary of adidas A G (i-faylorMade- 

adidas G olP'), is a c orporation or ganized unde r t he l aws of Delaware, having i ts of fice a nd 

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261 

principal pl ace of bus iness at 5545 Fermi C ourt, C arlsbad, C alifornia 92008. (Compl. ! 6.) 

TaylorMade-adidas Golf is e ngaged i n t he m antlfacture, pr omotion, di stribution, a nd s ale i n 

interstate commerce, including within this Judicial District. of quality golf equipment and related 

products under multiple federaly registered trademarks. (See Declaration of Jeni B. Zuercher in 

Support of Ex Parte Application for TRO (ikzuercher Decl.'J !! 4-5.) 

TaylorMade-adidas Golf is t he ow ner of a 1 r ights i n and t o t he f ollowing t rademarks 

which ar e v alid an d r egistered o n t he P rincipal R egister o f t he United S tates P atent an d 

Trademark Ofice (colectively the S'TaylorMade-adidas Marks') 



Number Date 

TAYLOR MADE 1,200,542 July 6, 1982 IC 028 - Golf Clubs. 

TAYLOR MADE 1,374,009 1985 covers . 

December 3, IC 028 - golf bags and golf club head 

September 30, 

BURNER 1,41 1,498 IC 028 - golf clubs. 

1986 

RESCUE 2,092,034 August 199726, 

IC 028 - goj-cjubs 

. 

IC 0l8 - Golf umbrelas, luggage and 

bags, namely, non-canvas tote bags, 

for golfers. 

IC 025 - Clothing, namely, hats, visors, 

C d* 2 557,1 10 April 2, 2002 OPS. 

IC 028 - Golf equipment, namely golf 

clubs, golf grips, putters, shafts, golf 

bals, golf gloves, golf tees, golf club 

covers, and golf bags. 

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261 

IC 018 - Golf umbrellas, Iuggage and 

bags, namely, non-canvas tote bags, 

for golfers. 

IC 025 - Clothing, namely, hats, visors, 

caps, shirts, skirts, blouses, sweaters, 

Rf 2 ' 557,1 1 April 2, 2002 Slacks, digans shorts, and shoes. jackets, coats, pulovers. 

car 


clubs, golf grips, putters, shahs, golf 

balls, golf gloves, golf tees, golf club 

covers, and golf bags. 

IC 028 - Golf equipment, namely, golf 

ROSSA 2,820,220 March 2, 2004 clubs, golf grips, putters, shahs, golf 

club covers, and golf bags. 


11.7 2,960,850 June 7, 2005 clubs, wedges, irons, golf club heads, 

golf club shafts. 

December 20, IC 028 - Golf equipment, namely, golf 

3 ,032,873 2005 

clubs, shafts, golf club covers. 


clubs, golf putters, golf clubheads, golf 

AGSI 3,252,375 June l2, 2007 clubhead inserts, golf club covers, and 

golf bags. 


.v x.-p 3,276,214 August 7, 2007 clubs, and shahs. 

FoUeF*#FW*--o 

1.9 3,652,607 July 7, 2009 


clubs, golf heads, golf club shafts. 

BURNER PLUS 3 August 25, 

,673,923 2009 IC 028 - Golf clubs. 

BURNER 3 September 8, 

,680,379 2009 IC 028 - Golf balls 

IC 028 - golf equipment, namely, golf 

w 3 October 26, 

,868,743 clubs, shaûs, golf bals, golf gloves, 

. 2010 

golf club covers and golf bags. 


Rl 1 3,95 1,066 April 26, 201 l clubs, golf grips, golf club heads, golf 

club shahs, and golf bags. 

8



261 

The TaylorMade-adidas Golf M arks are us ed i n c onnection w ith t he m anufacture a nd 

distribution of high quality goods in at least the categories identified above. (See Zuercher Decl. 

! 5 ; see also United S tates Trademark Registrations o f th e TaylorMade-adidas Golf Marks at 

issue (i-raylorMade-adidas Golf Trademark Registrations'l atached as Composite Exhibit A to 

the Zuercher Decl.) 

Plaintiffs retained Investigative Consultants to investigate the sale of counterfeit versions 

of Plaintifs' respective products by Defendants. (See Rogan Decl. ! 12; Dow Decl. ! 12; Reino 

Decl. ! 12; Hawken Decl. ! 12; Zuercher Decl. ! 12; Declaration of Brandon Tanori in Support 

of P laintiffs' A pplication f or T RO (si-l-anori D ecl.'1 ! 3.) ln A ugust 2 01 1 , Brandon T anori 

($'Tanori'), an employee of lnvestigative Consultants, placed an order for the purchasc of ( i) a 

golf c lub and golf ba ls, bot h be aring t he A cushnet M arks a t i ssue vi a t he lnternet website 

operating under the dom ain name greatestgolfclubs.com; ( i) a golf c Iub bearing the C alaway 

Golf Marks at issue via the lnternet website operating under the domain name golfstore 18.com; 

(i) a g olf c lub be aring the C leveland G olf M arks at i ssue vi a t he lntenwt w ebsite operating 

under the domain name golfsuno.com; (iv) a golf club bearing the Karsten Mark at issue via the 

lnternet w ebsite op erating unde r t he dom ain na me g olfsuno.com; a nd golf c lubs be aring t he 

TaylorMade-adidas G olf M arks at i ssue vi a t he lnternet w ebsite ope rating unde r t he dom ain 

name golfsales36s,com. (See Tanori Decl. !! 4 -8 and Composite Exhibit A through E atached 

thereto.) Tanori finalized his purchase of the TaylorMade-adidas Golf branded golf clubs using 

Paypal to th e P aypal account i dentified as $ expectatiol6orri,htlttnail.ctnlm,'' and h e received a 

receipt for his payment identifying Tang Hainan 1 as the 

merchant and providing the transaction 

l The merchant's name identified on the Paypal receipt for the Taylor Made branded golf clubs 

purchased via golfsales36s.com, /#XI$, is translated into English as Tang Hainan. (See 

Gaffigan Decl. ! 10.) 

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261 

identification number, 24D5435 1 EW6502246. Lsee Tanori Decl. ! 8 and Composite Exhibit E 

attached thereto; Declaration of S tephen M . G affigan i n S upport of P laintiffs' A pplication for 

TRO (iûGaffigan Decl,') ! 10.) Each of Tanori's purchases was processed entirely online, and he 

received co nfirmation o f h is p urchases via e -mail. (See Tanori Decl. !! 4 -8 and Composite 

Exhibit A through E atached thereto.) 

Thereaher, t he golf c lub a nd g olf b als be aring P laintiffs' i ndividual t rademarks 

purchased b y T anori were i nspected b y P laintiffs' r espective representatives, an d ea ch 

determined the items to be non genuine, unauthorized versions of Plaintiffs' rcspective products. 

(See Rogan Decl. ! 1 4; Dow Decl. ! 14; Reino Decl. ! 14; Hawken Decl. ! 14; Zuercher Decl. ! 

14,) Additionaly, P laintiffs' r epresentatives each r eviewed and v isualy in spected th e ite ms 

bearing Plaintiffs' respective trademarks offered for sale on the lnternet websites operating under 

the r elevant S ubject D omain N ames a nd de termined t he pr oducts w ere una uthorized, non - 

genuine ve rsions of P laintiffs' respective products. (See Rogan D ecl. ! 1 5; Do w Decl, ! 1 5; 

Reino Decl. ! l 5; Hawken Decl, ! 15; Zuercher Decl. ! l 5,) 

Based on the investigations, Plaintifs allege Defendants have advertised, offered for sale, 

and/or sold at least (i) golf clubs, golf bals, golf bags, and golf gloves bearing counterfeit and 

infringing trademarks which are exact copies of the Acushnet Marks; (i) golf clubs, golf bals, 

golf bags, golf shoes, golf towels, and caps bearing counterfeit and infringing trademarks which 

are exact copies of the Calaway Golf Marks; (i) golf clubs bearing counterfeit and infringing 

trademarks which a re e xact c opies of t he C leveland G olf M arks; ( iv) g olf c lubs be aring 

counterfeit and infringing trademarks which are exact copies of the Karsten Mark; and (v) golf 

clubs, golf putters, golf balls, golf bags, umbrellas, and caps bearing counttrfeit and infringing 

trademarks which are exact copies of the TaylorMade-adidas Golf Marks. (See Rogan Decl. !! 

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261 

1 1-1 7; Dow Decl. !! l 1 -1 7; Reino Decl. !! 1 1 -1 7; Hawken Decl. !! l 1 -17; Zuercher D ecl. !! 

1 l -1 7; Tanori Decl. T! 4-8 and Composite Exhibits A through E atached thereto; Gaffigan Decl. 

!! 2 -4, and E xhibits B and C attached t hereto; see also relevant w eb p ages f rom D efendants' 

lnternet websites operating under the Subject Domain Names (ioefendants' Websites') attached 

as Composite Exhibit A to the Gaffigan Decl.) Defendants are not now, nor have they ever been, 

authorized or l icensed to use, reproduce, or m ake counterfeits, reproductions, and/or colorable 

imitations of the Acushnet Marks, Callaway Golf Marks, Cleveland Golf Marks, Karsten Mark, 

and TaylorMade-adidas Golf M arks (collectively ip laintifs' M arks'), (See Rogan Decl. ! l 1 ; 

Dow Decl. ! l 1 ; Reino Decl. ! 1 l ; Hawken Decl. ! l 1 ; Zuercher Decl. ! l l .) 

lI. Conclusions of Law 

The d eclarations P laintiffs submitted i n s upport of their Ex Parte Application for T RO 

support the following conclusions of law: 

Plaintiffs have a v ery strong pr obability of pr oving at t rial t hat c onsumers a re 

likely t o be c onfused b y Defendants' a dvertisement, pr omotion, s ale, offer f or s ale, a nd/or 

distribution of g oIf e quipment a nd r elated goods be aring c ounterfeits, r eproductions, a nd/or 

colorable imitations of Plaintiffs' Marks. and that the products Defendants are selling are copies 

of Plaintiffs' respective products that bear copies of the Acushnet Marks on golf clubs, golf balls, 

golf bags, and golf gloves, the Callaway Golf Marks on golf clubs, golf balls, golf bags, and golf 

glovess t he C leveland Golf M arks on golf clubs, t he K arsten M ark o n g olf clubs, a nd t he 

TaylorMade-adidas Golf Marks on golf clubs, golf putters, golf balls, golf bags, umbrellas, and 

CaPS. 

B. Because of the infringement of the Plaintiffs' Marks, Plaintiffs are likely to suffer 

immediate a nd i rreparable i njury if a t emporary restraining or der i s not g ranted. lt cl early 

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261 

appears f rom th e f ollowing s pecitic f acts, a s s et f orth in Plaintiffs' Complaint, Ex Parte 

Application f or T RO, an d acco mpanying d eclarations o n f ile, t hat i mmediate an d i rreparable 

loss, d amage, a nd injury wil r esult to P laintiffs and t o c onsumers be fore D efendants c an b e 

heard in opposition unless Plaintifs' request for cx parte relief is granted: 

Defendants ar e o perating Internet b usinesses w hich ad vertise, o ffer for 

sale, and sel, at l east golf c lubs, golf bals, golf bags, and golf gloves bearing counterfeit and 

infringing trademarks in v iolation o f A cushnet's r ights; g oIf clubs, golf balls, g olf ba gs, golf 

shoes, g oIf t owels, a nd c aps be aring c ounterfeit a nd i nfringing t rademarks i n vi olation of 

Calaway Golf's rights; golf clubs bearing counterfeit and infringing trademarks in violation of 

Cleveland Golf's rights; golf clubs bearing counterfeit and infringing trademarks in violation of 

Karsten's rights; and golf clubs, golf putters, golf bals, golf bags, umbrelas, and caps bearing 

counterfeit and infringing trademarks in violation of TaylorMade-adidas Golf's rights; 

There i s good c ause t o be lievt t hat m ore c ounterfeit a nd i nfringing 

products bearing Plaintiffs' respective trademarks wil appear in the marketplace; that consumers 

may be m isled, confused, and disappointed by the quality of these products; and that Plaintiffs 

may snffer Ioss of sales for their respective genuine products; 

There i s g ood c ause t o be lieve t hat i f P Iaintifs proceed on not ice t o 

Defendants on this Ex Parte Application for TRO, Defendants can easily and quickly transfer the 

registrations for m any o f the S ubject D omain N ames, or m odify registration data and content, 

change hosts, and redirect traffic to other websites, thereby thwarting Plaintiffs' ability to obtain 

meaningful relief; 


counterfeit a nd i nfringing br anded goods i f a t emporary r estraining order i s i ssued i s f ar 

12



261 

outweighed b y th e p otential h arm to Plaintiffs, their respective reputations, and goodwill as a 

manufacturer of high quality products if such relief is not issued; and 

5. The public i nterest favors i ssuance o f the temporary restraining o rder i n 

order to protect Plaintiffs' trademark interests and protect the public from being defrauded by the 

palming off of counterfeit goods as genuine goods of the respective Plaintiffs. 

C. Under 15 U .S.C. j 1 1 17( a), Plaintiffs may be entitled to recover, as an equitable 

remedy, th e illegal profits gained through Defendants' distribution and sales of goods bearing 

counterfeits and infringements of Plaintiffs' Marks. See Reebok Int 'l, Ltd. v. Marnatech Enters., 

Inc., 970 F .2d 552, 559 (9th Cir. l 992) (quoting Fuler Brush Products Co. v, Fuler srlf-ç/l Co., 

299 F.2d 772, 777 (7th Cir. 1962) ($dAn accounting of profits under j 1 1 17(a) is not synonymous 

with an award o f m onetary d amages: ilaln acco unting f or p rofits . . . i s an equitable remedy 

subject to the principles of equity.').) 

D. Requesting equitable relief invokes the district court's inherent equitable powers 

to order preliminary relief, in cluding a restrain of assets, i n order to assure t he availability o f 

permanent relief.' f evi Strauss & Co. v. Sunrise 1nt 1 Trading Inc., 5 1 F.3d 982, 987 ( 1 1th C ir. 

1995) ( citing Federal Trade Commission v. United States Oil and Gas Corp., 748 F .2d 143 l , 

1433-34 (1 1th Cir. 1984)). 

E. In l ight of t he i nherently deceptive na ture of t he c ounterfeiting bus iness, a nd 

Defendants' blatant v iolation o f th e f ederal tr ademark la ws, P laintiffs have good r eason t o 

believe D efendants wil h ide o r t ransfer their il-goten a ssets be yond t he j urisdiction of t his 


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261 


ORDERED AND ADJUDGED that P laintiffs' Ex Parte Application for a T emporary 



Each Defendant, their officers, di rectors, e mployees, agents, s ubsidiaries, 

distributors, and a 11 persons i n active concert o r participation w ith them having notice of this 


a.From m anufaduring, i mporting, advertising, promotinj, of fering t o sel, 

selling, di stributing, or transferring any p roducts b earlng t he Acushnet 

Marks, C allaway G olf Marks, C leveland G oIf M arks, K arsten M ark, 

and/or TaylorMade-adidas G olf M arks, or a ny confusingly s imilar 

trademarks, ot her t han those a ctually m anufactured or di stributed b y 

Plaintiffs; and 

b. From s ecreting, concealing, de stroying, s elling of f, t ransferring, or 

otherwise di sposing of : ( i) any products, not m anufactured or di stributed 

by P laintiffs, b earing tht Acushnet M arks, Callaway G oIf M arks, 

Cleveland G olf M arks, Karsten M ark, a nd/or TaylorMade-adidas G olf 

Marks, or any confusingly similar trademarks; or (i) any evidence relating 

to the m anufacture, i mportation, s ale, of fer f or s ale, di stribution, or 

transfer of a ny products be aring t he Acushnet M arks, C allaway Golf 

Marks, C leveland G oIf Marks, K arsten M ark, and/or TaylorMade-adidas 

Golf Marks, or any confusingly similar trademarks. 

(2) Each Defendant, their officers, di rectors, e mployees,agents, s ubsidiaries, 


Order s hall i mmediately di scontinue t he us e of t he Acushnet M arks, Callaway G olf M arks, 

Cleveland Golf Marks, Karsten Mark, and/or TaylorMade-adidas Golf Marks or any confusingly 

similar t rademarks, on or i n c onnection w ith all lnternet w ebsites ow ned a nd ope rated, or 

controlled by them, including the lnternet websites operating under the Subject Domain Names; 

Each Defendant, t heir of ficers, di rectors, e mployees, agents, s ubsidiaries, 


14



261 

Order s hall i mmediately di scontinue t he us e of t he Acushnet M arks, Callaway G olf M arks, 

Cleveland Golf Marks, Karsten Mark, and/or TaylorMade-adidas Golf Marks, or any confusingly 

similar trademarks within domain n ame extensions, metatags o r other m arkers within webshe 



use of such terms which is vi sible to a computer user or serves to d irect computer searches to 

websites registered b y, owned, or operated by each Defendant, i ncluding the Internet websites 


(4) Each Defendant shal not transfer ownership of the Subject Domain Names during 

the pendency of this Action, or until further Order of the Court; 

(5) The d omain n ame R egistrars f or t he S ubject Domain N ames a re d irected t o 

transfer to P Iaintiffs' counsel, f or de posit w ith this C ourt, dom ain na me c ertificates f or t he 


(6) The Rtgistrars and the top-level domain (TLD) Registries for the Subject Domain 

Names, within ten ( 10) days of receipt of this Temporary Restraining Order, shall caused to be 

changed or change the registrar of record for the S ubject Domain Names to a holding account 

with the United States based Registrar, GoDaddy.com, Inc. U pon transfer of control over the 

Subject Domain Names into tht holding account, GoDaddy.com, lnc. wil hold the registrations 

for t he Subject D omain N amts i n t rust f or t he C ourt dur ing t he pe ndency of t his a ction. 

Additionaly, GoDaddy,com, Inc. shal immediately update the Domain Name System (ç:DNS') 

data i t m aintains f or t he S ubject D omain N ames, w hich l inks t he dom ain na mes t o t he IP 

addresses w here their associated w ebsites a re h osted, t o N S1 .MEDIATEMPLE.NET a nd 

NSZ.MEDIATEMPLE.NET, which will cause the domain names to resolve to the website where 

15



261 

a copy of the Complaint, Summonses, Temporary Restraining Order, and other documents on 

file in this action are displayed. Alternatively, GoDaddy.com, lnc. may institute a domain name 

forwarding which wil automaticaly redirect any visitor to the Subject Domain Names to the 

following Uniform Resource Locator ($URL') ltp:/uwvk.servilA-fxnotice.eolxl/lpainan/index.ltlzll 

whereon a copy of the Complaint, Summonses, Temporary Restraining Order, and other 

documents on file in this action are displayed. Aûer GoDaddy.com, lnc. has effected this change 

the Subject Domain Names shal be placed on Lockstatus, preventing the modification or 

deletion of the domains by the registrar or Defendants; 

Plaintiffs may enter the Subject Domain Names into Google's Webmaster Tools 

and cancel any redirection of the domains that have been entered there by Defendants which 



(8) Each Defendant shal preserve copies of al their computer files relating to the use 

of any of the Subject Domain Names and shal take al steps necessary to retrieve computer files 

relating to the use of the Subject Domain Names that may have been deleted before the entry of 

this Order; 

(9) Upon receipt of notice of this Order, Paypal, lnc. (ç$PayPal') and its related 

companies and affiliates shall immediately freeze aIl Paypal accounts related to the Paypal 

account recipient iexpectatitla6orplhotlnail.coln' and any other related accounts of the same 

2 

customer; 

(10) Paypal shal also immediately divert to a holding account for the trust of the Court 

all funds currently in, or which during the pendency of this Order come in to, aIl Paypal accounts 

2 Pa Pal is licensed to do business in the State of Florida by the Florida Office of the Controller 

and ls therefore subject to personal jurisdiction in this Court. (See Gaffigan Decl. ! 1 1 and 

Exhibit F atached thereto.) 

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261 

related to the Paypalaccount recipient StexpectfltitànfA'os/fltptlnail.ctlll' and any other related 

accounts Of the same customer; 

Paypal shal further, within five days of receiving this Order, provide Plaintiffs' 

counsel with a1 data which identifies the Paypal accounts frozen as wel as an accounting of the 

funds in the frozen accounts. Such freezing of the accounts and the disclosure of the related 

financial institution account information shall be made without notice to the account owners or 

the financial institutions until further order of this Court.Paypal shall receive and maintain this 

Order and its contents as confidential until ftlrther order of this Court 

(12) This Temporary Restraining Order shal remain in effect nntil the date for the 

hearing on the Motion for Preliminary lnjunction set forth below, or until such further dates as 

set by the Court or stipulated to by the parties; 

(13) Pursuant to l 5 U.S.C. j l l 16(d)(5)(D), Plaintiffs shal post a bond in the amount 

of Ten Thousand Dolars and Zero Cents ($10,000.00), as payment of damages to which 

Defendants may be entitled for a wrongful injunction or restraint. Plaintifs shal post the bond 

prior to requesting the Registry to transfer control of the Subject Domain Names; 

(14) A hearing is set before the Honorable Edward G. Torres in the United States Courthouse at 

99 Northeast 4th Street, Miami, Florida 33132, Courtroom 1027, on November 1 5, 20l 1, at l :30 p.m., or 

at such other time that this Court deems appropriate, at which time Defendants and/or any other 

afected persons may chalenge the appropriateness of this Order and move to dissolve the same 

and at which time the Court wil hear argument on Plaintifs' requested preliminary injunction; 

(15) Plaintiffs shal serve a copy of the Ex Parte Application for TRO and this Order 

on Defendants via their known e-mail addresses; specificaly the e-mail addresses provided by 

Defendants to the Registrars responsible for the Subject Domain Names: 

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261 

02054975 1 62@ tom.com, 384 l220r2qq.com, acolfjàgmail.com, banahaoxmank hotmail.com, 

ca50 1 794@1) gl-nai l-col'n, downzq 87f-,àfp,gl'nai l-col-n, 

easybtlygol tlt/yfzmai l .coln, 

go l fsal es36 '.'.iib. .i' n-l ai I .com , idea l go I tk l ubs-col'n ('lldonlai 1 sbvproxv-com , I-n bt-tl-yg (l-y'0(i't gnna i I .com , 

I'n3.'k'ol fburchasett k'm ai I .conl, proxN.'2603679r.i) l antl 1 -pri vate-reg istrat ion-eonl, 

rokaer-cooktyhtntlxnail-ctlm, servicetp). yxoldbtlN'discotlpt-coln, servicelk/.gol fdiscountdirect-conn, 

ssssc l 22 .cc, tkl inltoggrklrkzookzlenyail.com, xhct 1 tlsr.@?amail.com, xhct 1 ostrArhotmai l.col'n, 

w't@. 

xiefenkyboyrtélhotmail .c()m, yovohaio7 1 (t-. thgmai lmcom, and zhankxinaki) 1 26.com; and the e-mail 

addresses Defendants used to communicate with Plaintifs' investigator'. 

servicer/i-hcreatestao I fklubs-coln, serv icetfit jzolfstore I 8.eolM, sunogol ftilglnai 1 .c()m, and 

servicer.ilvztnlt-sales36s.ctlln. ln addition, Plaintiffs shal post a copy of the Ex Parte Application 

for TRO and this Order on the website located at 

htp:/wNvv.sel'vinyxlotice.com/lailal/ilpdex.html, upon transfer of the Subject Domain Names 

into the holding account with GoDaddy.com, Inc., and such notice so given shal be deemed 

good and sufficient service thereof Any response or opposition to Plaintiffs' Motion for 

Preliminary lnjunction must be filed and served on Plaintifs' counsel forty-eight (48) hours 

prior to the hearing set for /œ-t6, 201 1, and sled with the court, along with Proof of Service, 

9#. $5 

on 449* l $ , 2O1 l . Plaintifs shal file any Reply Memorandum on or before 9m O , 

20l 1. The above dates may be revised upon stipulation by all parties and approval of this Court. 

Defendants are hereby on notice that failure to appear at the hearing may result in the imposition 

of 

a preliminary injunction against them pursuant to 15 U.S.C. j 1 l l6(d) and Fed. R. Civ. P. 65. 

DONE AND ORDERED in chambers in Miami , Florida, this esday of ., 20l 1. 

URSULA UNGARO 

United States District Judge 

18



261 

allstockonline.com 

buzzgolfclubs.com 

clubsgolfsale.com 

discountgolfclubsls.com 

drgolfstore.com 

easybuyqolf.com 

golfbuydlscount.com 

golfclubcheap.com 

golfclubsbest.com 

golfdiscountdirect.com 

golfequiponline.com 

golforderonline.com 

golfsalel8.com 

golfsaIes365.com 

golfsaleus.com 

golfsaleworld.com 

golfseasonss.com 

golfsmartdeal.com 

golfstorel 8.com 

golfstore365.com 

golfstoreorder.com 

golfsuno.com 

golfsuperl l 8.com 

golfsuperprice.com 

golfsuperstoreonline.com 

golfsuperworld.com 

golfwholesale36s.com 

golfwholesaleseller.com 

golfwon.com 

golfzonels.com 

greatestgolfclnbsmcom 

greatsnowboots.com 

higolfclubs.com 

hotsalegolfcom 

idealgolfclubs.com 

igolfnuts.com 

istockgolf.com 

lovegolfclubs.com 

mygolfclubsforsale.com 

mygolfpurchase-com 

onlinegolfl 8.com 

pickgf.com 

pickgolfclubs.com 

SCHEDULE CA' 


19



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44. puterbuy.com 

45. tmjolfclub.com 

46. usdlscountgolf.com 

47. usgolfsale.com 

48. usgolfsalel 8.com 

49. wgbuy.com 

50. wholesalegolfl 18.com 

5 l . yourgolfhomes.com 

20



261 

1 . athleticsbar.com 

2. bestsportinglife.com 

3. comeongolf.com 

4. golfheavenus.com 

5. golfutilityclubs.com 

6. golfworldls.com 

7. lovegolfonline.com 

8. prosportsoutdoor.com 

9. sportingturner.com 

l0. sportssaleonline.com 

1 1 . taylormadergirons.org 

SCHEDULE B 

SUBJECT DOM AIN NAMES 

21



261 

GUCCI AMERICA, INC. et al., 

v. 

Plaintiffs, 

NA ZHANG, et al., 

Defendants. 

_____________________________/ 



CASE NO.: 11-23380-CIV-UNGARO 

ORDER ADOPTING MAGISTRATE JUDGE’S REPORT AND RECOMMENDATION 

THIS CAUSE came before the Court upon Plaintiff’s Plaintiffs’ Ex Parte 

Application for Entry of Temporary Restraining Order and Preliminary Injunction 

(“Motion”). [D.E.5]. Following the referral of D.E. 5, Magistrate Torres filed a Report and 

Recommendation, (D.E. 10) concluding that Plaintiffs’ Motion should be GRANTED insofar as 

the Ex Parte Motion should be entered and a preliminary injunction should be set for November 

2, 2011. In said Report, Magistrate Torres set a deadline of October 25, 2011, for the parties to 

respond to his report. The Court notes that the neither party, including Defendants against whom 

the Ex Parte Motion was directed, have responded. 

THIS COURT has made a de novo review of the entire file and record herein, and, is 

otherwise fully advised in the premises. Accordingly, it is hereby 

ORDERED and ADJUDGED (1) that United States Magistrate Judge Torres’ 

Report and Recommendation (D.E. 10) is RATIFIED, AFFIRMED and ADOPTED; (2) that the 

Ex Parte Motion should be entered and a preliminary injunction should be set for November 2, 

2011. 

DONE and ORDERED at Miami, Florida, this 26th day of October, 2011.



261 

cc: All Counsel of Record 

Magistrate Torres 

2 

____________________________________ 




261 

1



261 




GUCCI AMERICA, INC., and BOTTEGA 

VENETA INERNATIONAL, S.A.R.L., 

v. 

Plaintiffs, 

NA ZHANG, LIMIN FANG and DOES 1-10, 

Defendants. 

_____________________________________/ 


ON PLAINTIFFS’ EX PARTE APPLICATION FOR ENTRY OF 


This matter came before the Court upon Plaintiffs’ Ex Parte Application for 


1 

5]. Based on the motion, affidavits and documents submitted therewith, we conclude 

that Plaintiffs’ Motion should be GRANTED insofar as the Ex Parte Motion should be 

entered and a preliminary injunction hearing should be set for November 2, 2011. 






1 

By Order dated September 28, 2011, the Honorable Ursula Ungaro referred 

this motion to the undersigned [D.E. 6].



261 

disserve the public interest. See, e.g., Tefel v. Reno, 180 F.3d 1286, 1295 (11th Cir. 







In this case, Gucci American, Inc. (“Gucci”) and Bottega Veneta International, 

S.A.R.L. (“Bottega”) (collectively “Plaintiffs”) make a sufficient evidentiary showing to 

support issuing a temporary restraining order. The Court bases its ruling on the facts 

found in Plaintiffs’ Complaint, Ex Parte Motion, Declarations of Stephen M. Gaffigan, 2 

3 4 

(Plaintiffs’ attorney), Stacy Feldman, Brandon Tanori, exhibits thereto, and the 

complete record. 

Gucci is engaged in the manufacture, promotion, distribution, and sale in 

interstate commerce, including within this Judicial District, of high quality products 

under multiple federally registered trademarks. Feldman Decl. at 5. Gucci is the 

2 

See [D.E. 5-2 – 5-5; Declaration of Stephen M. Gaffigan (“Gaffigan Decl.”)]. 

3 

A Gucci paralegal responsible, in part, for the trademark and anticounterfeiting 

efforts in the United States of several brands of the luxury group for 

PPR, Gucci’s parent company, including Gucci and Bottega. See [D.E. 5-5,6; 

Declaration of Stacy Feldman (“Feldman Decl.”) at 3]. 

4 

An employee of Investigative Consultants, a licensed private investigative firm 

that Plaintiffs hired to investigate the suspected sale of counterfeit versions of 

Plaintiffs’ respective products by Defendant via the Internet. See [D.E. 5-7; Declaration 

of Brandon Tanori (“Tanori Decl.”) at 2-3]. 

2



261 

owner of all rights in and to those trademarks which are valid and registered on the 

Principal Register of the United States Patent and Trademark Office (collectively the 

“Gucci Marks”). Feldman Decl. at Ex. A. The Gucci Marks are used in connection with 

the manufacture and distribution of high quality goods in at least the categories 

identified above. Id. at 5. 

Bottega, a foreign corporation, is engaged in the manufacture, promotion, 

distribution, and sale in interstate commerce, including within this Judicial District, 

of high quality products under its federally registered trademark. Id. at 10-11, Ex. 

B. Bottega is the owner of that trademark, which is valid and registered on the 

Principal Register of the United States Patent and Trademark Office (the “Bottega 

Mark”). The Bottega Mark is used in connection with the manufacture and 

distribution of high quality goods in at least the categories identified above. Id. 

Defendants have advertised, offered for sale and/or sold counterfeit products, 

including handbags, wallets, and watches bearing Gucci Marks and, at least, handbags 

bearing the Bottega Mark. Id. at 18-22; Tanori Decl. at 4, 6, 10; Gaffigan Decl. at 

2-4, Comp. Ex. B. The Gucci and Bottega Marks have never been assigned or 

licensed to the Defendants, and the Defendants do not have, nor have they ever had, 

the right or authority to use the Gucci or Bottega Marks for any purpose. Id. 

Plaintiffs retained Brandon Tanori (“Tanori”) to investigate the suspected sale 

of counterfeit versions of Plaintiffs’ products by Defendants through the internet on 

various domain names operated by the Defendants. Feldman Decl. at 17, 22-23; 

3



261 

5 

Tanori Decl. at 3. Tanori accessed one of Defendants’ websites, 

“replicahandbag88.net,” and placed an order to purchase a Bottega handbag. Tanori 

Decl. at 4, Ex. A. Defendant Zhang provided Tanori a transaction number and, in 

email correspondence, cautioned Tanori from using the words “replica” and “fake” when 

paying to avoid account issues with Paypal. Id. at 5-6. Later, Tanori received the 

handbag, which Feldman confirmed was a non-genuine Bottega product. Id. at 7; 

Feldman Decl. at 3, 18-21. 

Tanori repeated this process with another of Defendants’ websites, 

“oemwatchesreplicas.net,” and purchased what Feldman later confirmed to be a non- 

genuine Gucci branded watch. Tanori Decl. at 8-12; Feldman Decl. at 3, 18-21. 

Feldman also reviewed the webpage listings of these two websites and determined that 

the listings for sale were non-genuine versions of Plaintiffs’ respective products. 

Feldman Decl. at 22-23. 

On this record, we find that Plaintiffs have a substantial likelihood of success 

on the merits and thus satisfied this prong. 

Moreover, Defendants’ unauthorized use of the Gucci and Bottega Marks and 

sale of counterfeit products is sufficiently likely to cause confusion that may “by itself 


L.P. v. Barrow, 143 Fed. App’x. 180, 191 (11th Cir. 2005) (citing McDonald’s Corp. v. 


5 

A list of Defendants’ domain names (“Subject Domain Names”) is reproduced 

below at Schedule “A.” 

4



261 

us, Plaintiffs are likely to suffer an irreparable injury to their reputation if Defendants 

are permitted to continue their activities. 



far outweighed by the potential harm to Plaintiffs, their reputation and goodwill as 

manufacturers of, among other things, high quality handbags, wallets and watches. 

Furthermore, public interest favors issuance of the temporary restraining order in 

order to protect Plaintiffs’ trademarks and the public from Defendants’ sale of non- 

genuine products. 




other websites to evade Plaintiffs’ ability to obtain the relief sought. We find good 

cause exists for entry of this Order without notice to Defendants to assure retention of 

the Subject Domain Names under the control of this Court. We thus find that 

Plaintiffs’ counsel’s certification attached to the Motion is merited and satisfies Rule 

65(b)(1)(B). See Gaffigan Decl. at 5-8. 

Under 15 U.S.C. § 1117(a), Plaintiffs may be entitled to recover, as an equitable 

remedy, the illegal profits gained through Defendants’ distribution and sales of 

counterfeit and infringing Gucci branded goods and Bottega branded goods. See Reebok 

Int’l, Ltd. v. Marnatech Enters., Inc., 970 F.2d 552, 559 (9th Cir. 1992) (quoting Fuller 

Brush Products Co. v. Fuller Brush Co., 299 F.2d 772, 777 (7th Cir. 1962) (“An 

5



261 

accounting of profits under § 1117(a) is not synonymous with an award of monetary 

damages: ‘[a]n accounting for profits... is an equitable remedy subject to the principles 

of equity.’”)). 







Defendants’ blatant violation of the federal trademark laws, Plaintiffs have good 

reason to believe Defendants will hide or transfer their ill-gotten assets beyond the 


Based on the foregoing reasons, we respectfully RECOMMEND that Plaintiffs’ 

Ex Parte Motion [D.E. 5] be GRANTED. It should also be ORDERED and 

ADJUDGED as follows: 







the Gucci Marks and/or the Bottega Mark, or any confusingly 

similar trademarks, other than those actually manufactured or 


6



261 



distributed by Plaintiffs, bearing the Gucci Marks and/or Bottega 

Mark, or any confusingly similar trademarks; or (ii) any evidence 

relating to the manufacture, importation, sale, offer for sale, 

distribution, or transfer of any products bearing the Gucci Marks 

and/or Bottega Mark, or any confusingly similar trademarks. 



notice of this Order shall immediately discontinue the use of the Gucci Marks and/or 

Bottega Mark or any confusingly similar trademarks, on or in connection with all 

Internet websites owned and operated, or controlled by them including the Internet 

websites operating under the Subject Domain Names; 



notice of this Order shall immediately discontinue the use of the Gucci Marks and/or 

Bottega Mark, or any confusingly similar trademarks within domain name extensions, 

metatags or other markers within website source code, from use on any webpage 

(including as the title of any web page), any advertising links to other websites, from 

search engines’ databases or cache memory, and any other form of use of such terms 

which is visible to a computer user or serves to direct computer searches to websites 

registered by, owned, or operated by each Defendant, including the Internet websites 




7



261 


to transfer to Plaintiffs’ counsel, for deposit with this Court, domain name certificates 

for the Subject Domain Names; 


Domain Names, within ten (10) days of receipt of this Temporary Restraining Order 

shall caused to be changed or change the registrar of record for the Subject Domain 

Names to a holding account with the United States based Registrar, GoDaddy.com, 

Inc. Upon transfer of the Subject Domain Names into the holding account, 

GoDaddy.com, Inc. will hold the Subject Domain Names in trust for the Court during 

the pendency of this action. Additionally, GoDaddy.com, Inc. shall immediately update 

the Domain Name System (“DNS”) data it maintains for the Subject Domain Names, 

which links the domain names to the IP addresses where their associated websites are 

hosted, to NS1.MEDIATEMPLE.NET and NS2.MEDIATEMPLE.NET, which will 

cause the domain names to resolve to the website where a copy of the Complaint, 


action are displayed. Alternatively, GoDaddy.com, Inc. may institute a domain name 

forwarding which will automatically redirect any visitor to the Subject Domain Names 

to the following Uniform Resource Locator (“URL”) 

http://www.servingnotice.com/zhang/index.html whereon a copy of the Complaint, 


action are displayed. After GoDaddy.com, Inc. has effected this change the Subject 

8



261 

Domain Names shall be placed on Lock status, preventing the modification or deletion 

of the domains by the registrar or the Defendants; 

7. Plaintiff may enter the Subject Domain Names into Google’s Webmaster 








9. Upon receipt of this Order, Western Union Financial Services, Inc. 

(“Western Union”) shall divert all money transfers sent by United States consumers 

to Na Zhang and/or Limin Fang in Guangdong, China, People's Republic of China, with 

the date of birth and identification number provided by the recipient of MTCN 312- 

402-9915, and hold such transfers until it receives further direction from the Court; 6 

10. In the event any money transfers are diverted in accordance with 

Paragraph 9 of this Order, Western Union shall be permitted to inform consumers who 

may contact Western Union about the transfers that the transfers are being held 

pursuant to a Court Order in Gucci America, Inc. v. Zhang, Case No. 11-cv-23380-UU, 

6 

Western Union is licensed to do business in the State of Florida by the Florida 

Office of Financial Regulation and is therefore subject to personal jurisdiction in this 

Court. See Gaffigan Decl. at 11, Ex. E. 

9



261 

entered by the United States District Court for the Southern District of Florida and 

that they may contact Plaintiffs’ counsel for additional information; 

11. Western Union shall also, within fifteen (15) days of receiving this 

Order, provide to Plaintiffs’ counsel records of all money transfers that have been paid 

to Na Zhang and/or Limin Fang in Guangdong, China, People's Republic of China, with 

the date of birth and identification number provided by the recipient of MTCN 312- 

402-9915, as well as records of money transfers that have been diverted in accordance 

with Paragraph 9 of this Order. Plaintiffs’ counsel shall bear the cost of any such 

records. For any transfers that have been diverted in accordance with this Order, 

Plaintiffs’ counsel will respond to any consumer inquiries and will provide notice of the 

Order and the disposition of the transfers to any affected consumer. Western Union 

shall receive and maintain this Order and its contents as confidential as to Na Zhang 

and/or Limin Fang and any other recipient associated with the MTCN 312-402-9915, 

until further order of this Court; 

12. Upon receipt of notice of this Order, PayPal, Inc. (“PayPal”) and its related 


PayPal account recipient “payingok@gmail.com” and any other related accounts of the 

same customer; 7 

7 

PayPal is licensed to do business in the State of Florida by the Florida Office 

of the Controller and is therefore subject to personal jurisdiction in this Court. See 

Gaffigan Decl. at 12, Ex. F. 

10



261 



to, all PayPal accounts related to the PayPal account recipient “payingok@gmail.com” 

and any other related accounts of the same customer; 


provide Plaintiffs’ counsel with all data which identifies the PayPal accounts frozen as 

well as an accounting of the funds in the frozen accounts. Plaintiffs’ counsel shall 

bear the cost of any such records. Such freezing of the accounts and the disclosure of 

the related financial institution account information shall be made without notice to 

the account owners or the financial institutions until further order of this Court. 

PayPal shall receive and maintain this Order and its contents as confidential until 

further order of this Court; 





16. Pursuant to 15 U.S.C. § 1116(d)(5)(D), Plaintiffs shall post a bond in the 


to which Defendants may be entitled for a wrongful injunction or restraint. Plaintiffs 

shall post the bond prior to requesting the Registry to transfer control of the Subject 

Domain Names; 

11



261 


17. An evidentiary hearing shall take place on Wednesday, November 2, 2011, 

at 2:00 p.m., James Lawrence King Bldg., 99 N.E. Fourth Street, Tenth Floor, 

Courtroom 5, Miami, Florida, before the undersigned Magistrate Judge. Defendants 

shall present evidence at that hearing why the temporary restraining order should be 

vacated and why a preliminary injunction order pending trial not be entered. 

18. Plaintiffs shall serve a copy of the Ex Parte Application for TRO and this 

Order on each Defendant via e-mail to the known customer service e-mail addresses 

provided by Defendants to Plaintiffs’ investigator, infohandbags@gmail.com and 

oemwatches@gmail.com and to the known e-mail addresses provided by Defendants to 

the Registrars responsible for the Subject Domain Names: 329920604@qq.com, 

support168@hotmail.com, and watch-well@hotmail.com. In addition, Plaintiffs shall 

post a copy of the Ex Parte Application for TRO and this Order on the website located 

at http://www.servingnotice.com/zhang/index.html, upon transfer of the Subject 

Domain Names into the holding account with GoDaddy.com, Inc., and such notice so 

given shall be deemed good and sufficient service thereof. Any response or opposition 

to Plaintiffs’ Motion for Preliminary Injunction must be filed with the Court and served 

on Plaintiffs’ counsel by October 25, 2011. Plaintiffs shall file any Reply Memorandum 

on or before November 1, 2011. The above dates may be revised upon stipulation by 

all parties and approval of this Court. Defendants are hereby on notice that failure to 

appear at the hearing may result in the imposition of a preliminary injunction against 

them pursuant to 15 U.S.C. § 1116(d) and Fed. R. Civ. P. 65. 

12



261 


October, 2011. 

Copies provided to: 

District Judge Ursula Ungaro 

All Counsel of Record 

13 






261 

1. bags-replica-shop.com 

2. bags-watches-replica.biz 

3. bags-watches-replica.net 

4. bags-watches-replica.org 

5. bags-watchess.com 

6. buy-top-replica.biz 

7. buy-top-replica.net 

8. buy-top-replica.org 

9. buy-top-replicas.net 

10. handbagsbase.biz 

11. handbags-base.biz 

12. handbags-base.org 

13. handbags-replica-shop.biz 

14. handbags-watches.biz 

15. handbags-watches.net 

16. handbags-watches.org 

17. link-replica.biz 

18. link-replicas.net 

19. oemwatchesreplica.biz 

20. oemwatchesreplicas.net 

21. replicahandbag88.com 

22. replicahandbag88.biz 

23. replicahandbag88.net 

24. replicahandbags88.biz 

25. replicahandbags88.org 

26. vip-handbags.com 

27. vip-handbags.net 

28. watchestime.biz 

29. watches-time.biz 

30. watchestime.org 



14

Case 1:11-cv-23051-DLG Document 8 Entered on FLSD Docket 09/07/2011 Page 1 of 3 


261



261



261



261 

CHANEL, INC. and LOUIS VUITTON 

MALLETIER, S.A., 

v. 

Plaintiffs, 

ZHITIAN DAI et al., 

Defendants. 



CASE NO. 1:11-cv-23051-GRAHAM/GOODMAN 

REPORT AND RECOMMENDATIONS 

ON EX PARTE MOTION FOR TEMPORARY RESTRAINING ORDER 

THIS CAUSE is before the Court on Plaintiffs’ Ex Parte Application for Entry of 

Temporary Restraining Order and Preliminary Injunction and Order Restraining Transfer of 

Assets Tied to the Counterfeiting Operation (the “Ex Parte Application for TRO and Asset 

Restraint”). The District Court referred this motion to the Undersigned for a report and 

recommendations on September 1, 2011. (DE# 6.) By the instant Application, Plaintiffs, 

Chanel, Inc. (“Chanel”) and Louis Vuitton Malletier, S.A. (“Louis Vuitton”) (collectively 

“Plaintiffs”), move ex parte, for entry of a temporary restraining order and order freezing the 

financial accounts used by Defendants Zhitian Dai (“Dai”) and Does 1-10 (collectively the 

“Defendants”) doing business as the domain names identified on Schedule “A” hereto (the 

“Subject Domain Names”), pursuant to 15 U.S.C. § 1116 and Fed. R. Civ. P. 65. 

The Undersigned carefully reviewed the Application and is otherwise fully advised in the 

premises. For the reasons discussed below, the Undersigned RESPECTFULLY 

RECOMMENDS that the District Court (1) GRANT Plaintiffs’ motion; (2) ENTER a



261 

temporary restraining order as set forth below; and (3) SCHEDULE a hearing on the requested 

preliminary injunction WITHIN 14 DAYS. 

I. 

This report and recommendations is based on the following facts taken from Plaintiffs’ 

Complaint, Ex Parte Application for TRO and Asset Restraint, and supporting evidentiary 

submissions. 

Factual Background 

Plaintiff Chanel is a corporation duly organized under the laws of the State of New York 

with its principal place of business in the United States located at Nine West 57th Street, New 

York, New York 10019. (Complaint 2.) Plaintiff Louis Vuitton is a foreign business entity 

organized under the laws of the Republic of France with its principal place of business in Paris, 

France. (Id. at 3.) 

Plaintiffs are engaged in the manufacture, promotion, distribution, and sale in interstate 

commerce, including within this Judicial District, of high quality products under multiple 

federally registered trademarks. (Declaration of Adrienne Hahn Sisbarro in Support of 

Plaintiffs’ Ex Parte Application for Entry of Temporary Restraining Order and Preliminary 

Injunction and Order Restraining Transfer of Assets Tied to the Counterfeiting Operation [“Hahn 

Decl.”] 4-5; Declaration of Nikolay Livadkin in Support of Plaintiffs’ Ex Parte Application 

for Entry of Temporary Restraining Order and Preliminary Injunction and Order Restraining 

Transfer of Assets Tied to the Counterfeiting Operation [“Livadkin Decl.”] 4-5.) 

Chanel is, and at all times relevant hereto has been, the owner of all rights in and to the 

following federally registered trademarks, which are valid and registered on the Principal 

Register of the United States Patent and Trademark Office (collectively the “Chanel Marks”): 

2



261 

Trademark Registration No. 

CHANEL 0,626,035 May 1, 1956 

3 

Registration Date 

1,314,511 January 15, 1985 

CHANEL 1,347,677 July 9, 1985 

CHANEL 1,510,757 November 1, 1988 

1,654,252 August 20, 1991 

CHANEL 1,733,051 November 17, 1992 

1,734,822 November 24, 1992 

3,025,936 December 13, 2005 

CHANEL 3,134,695 August 29, 2006 

The Chanel Marks are registered in International Classes 9 and 18, and are used in 

connection with the manufacture and distribution of, among other things, handbags, wallets, and 

sunglasses. (Hahn Decl. 5; see also United States Trademark Registrations of the Chanel Marks 

at issue [“Chanel Trademark Registrations”] attached as Composite Exhibit A to the Hahn Decl.) 

Louis Vuitton is, and at all times relevant hereto has been, the owner of all rights in and 

to the following trademarks, which are valid and registered on the Principal Register of the 

United States Patent and Trademark Office (collectively the “Louis Vuitton Marks”): 

Trademark Registration No. Registration Date 

0,297,594 September 20, 1932 

LOUIS VUITTON 1,045,932 August 10, 1976 

1,519,828 January 10, 1989 

LOUIS VUITTON 1,990,760 August 6, 1996



261 

LOUIS VUITTON PARIS 

2,177,828 August 4, 1998 

2,181,753 August 18, 1998 

2,378,388 August 22, 2000 

2,421,618 January 16, 2001 

2,773,107 October 14, 2003 

3,021,231 November 29, 2005 

3,023,930 December 6, 2005 

3,051,235 January 24, 2006 

The Louis Vuitton Marks are registered in International Classes 9 and 18 and are used in 

connection with the manufacture and distribution of, among other things, handbags, wallets, and 

sunglasses. (Livadkin Decl. 5; see also United States Trademark Registrations of the Louis 

Vuitton Marks at issue [“Louis Vuitton Trademark Registrations”] attached as Composite 

Exhibit A to the Livadkin Decl.) 

Defendants have advertised, offered for sale, and/or sold, at least, handbags, wallets, and 

sunglasses bearing what Plaintiffs have respectively determined to be counterfeits, reproductions, 

and/or colorable imitations of the Chanel Marks and Louis Vuitton Marks (collectively the 

“Plaintiffs’ Marks”). (Hahn Decl. 12-14; Livadkin Decl. 12-14; Declaration of Eric Rosaler 

in Support of Plaintiffs’ Ex Parte Application for Entry of Temporary Restraining Order and 

Preliminary Injunction [“Rosaler Decl.”] 4-12 and Composite Exhibits A through G attached 

thereto; Declaration of Stephen M. Gaffigan in Support of Plaintiffs’ Ex Parte Application for 

Entry of Temporary Restraining Order and Preliminary Injunction [“Gaffigan Decl.”] 2-4 and 

4



261 

Composite Exhibits A, B, and C attached thereto.) Defendants are not now, nor have they ever 

been, authorized or licensed to use, reproduce, or make counterfeits, reproductions, and/or 

colorable imitations of the Plaintiffs’ Marks. (Hahn Decl. 9; Livadkin Decl. 9.) 

Plaintiffs’ counsel retained Eric Rosaler (“Rosaler”) of AED Investigations, Inc., a 

licensed private investigative firm, to investigate suspected sales of counterfeit versions of 

Plaintiffs’ respective products by Defendants. (Hahn Decl. 10; Livadkin Decl. 10; Rosaler 

Decl. 3.) Rosaler accessed the Internet website operating under the domain name 

nicegiftsforu6.com and placed an order for the purchase of a Chanel branded wallet to be 

shipped directly to his address located in Aventura, Florida. (Rosaler Decl. 4 and Composite 

Exhibit A attached thereto.) Rosaler finalized payment for the Chanel branded wallet via 

Western Union Financial Services, Inc. (“Western Union”) to the payee, “ZHITIAN DAI” and 

was given a Money Transfer Control Number (“MTCN”) of 357-057-5291. (Rosaler Decl. 6 

and Comp. Ex. C thereto.) Rosaler also accessed another one of the Internet websites operated 

by Defendants, luxurybagsnow.com, and finalized a purchase via credit card for a Louis Vuitton 

branded wallet, similarly to be shipped directly to his address located in Aventura, Florida. 

(Rosaler Decl. 8 and Comp. Ex. D thereto.) Although Rosaler had paid via credit card, he sent 

an e-mail message to Defendants at sales@nicegiftsforu3.com, to request information for 

finalizing his payment via PayPal, Inc. (“PayPal”) for the Louis Vuitton branded wallet 

purchased using luxurybagsnow.com. (Id. at 9 and Comp. Ex. E thereto.) Shortly thereafter, 

Defendants directly responded to his e-mail via sales@nicegiftsforu3.com, expressly instructing 

Rosaler to make payment through PayPal to the PayPal account 

“xmleading2012@hotmail.com.” (Id.) Furthermore, Rosaler also inquired as to payment using 

Western Union, and was given instruction to deposit payment into the account belonging to 

5



261 

“Zhitian Dai, Xiamen City, Fujian Province, China 361009,” which is the same payee account 

for his purchase of the Chanel branded wallet via nicegiftsforu6.com. (Id. at 11 and Comp. Ex. 

G thereto.) Indeed, in independent correspondence received from Defendants in regards to both 

of his purchases, Defendants stated that they would offer Rosaler a ten percent discount if 

payment for the Chanel branded wallet purchased via nicegiftsforu6.com and payment for the 

Louis Vuitton branded wallet purchased via luxurybagsnow.com were effected using Western 

Union. (Id. at 5, 11 and Comp. Exs. B and G thereto.) Moreover, Defendants also admitted 

to being a related business with the Internet website operating under the Subject Domain, 

nicegiftsforu3.com. (Id. ) 

Thereafter, Chanel’s representative, Adrienne Hahn Sisbarro (“Hahn”), analyzed the 

Chanel branded wallet Rosaler purchased and received from Defendants’ nicegiftsforu6.com 

website, including the web page listings, and determined the wallet to be a non-genuine Chanel 

product. (Hahn Decl. 12.) Additionally, Louis Vuitton’s representative, Nikolay Livadkin 

(“Livadkin”), reviewed and visually inspected the web page listings of the Louis Vuitton branded 

wallet purchased by Rosaler from Defendants’ luxurybagsnow.com website, and determined the 

wallet to be a non-genuine Louis Vuitton product. (Livadkin Decl. 12.) Moreover, Ms. Hahn 

Sisbarro and Mr. Livadkin reviewed and visually inspected the items bearing the Plaintiffs’ 

respective Marks offered for sale by Defendants via their Internet websites operating under the 

Subject Domain Names and determined the products were non-genuine products. (Id. at 13.) 

6



261 

II. 

Conclusions of Law 

Plaintiffs’ Declarations submitted in support of their Ex Parte Application for TRO and 

Asset Restraint support the following conclusions of law: 

A. Plaintiffs have a very strong probability of proving at trial that consumers are 

likely to be confused by Defendants’ advertisement, promotion, sale, offer for sale, and/or 

distribution of handbags, wallets, and sunglasses respectively bearing counterfeits, 

reproductions, and/or colorable imitations of Plaintiffs’ Marks, and that the products Defendants 

are selling are copies of Plaintiffs’ respective products that bear copies of Plaintiffs’ Marks on 

handbags, wallets, and sunglasses. 

B. Because of the infringement of Plaintiffs’ Marks, Plaintiffs are likely to suffer 


appears from the following specific facts, as set forth in Plaintiffs’ Complaint, Ex Parte 

Application for TRO and Asset Restraint, and accompanying declarations on file, that immediate 

and irreparable loss, damage, and injury will result to Plaintiffs and to consumers before 

Defendants can be heard in opposition unless Plaintiffs’ request for ex parte relief is granted: 

1. Defendants are operating Internet businesses which advertise, offer for 

sale, and sell, at least, handbags, wallets, and sunglasses bearing counterfeit and infringing 

trademarks which are exact copies of Plaintiffs’ Marks in violation of Plaintiffs’ respective 

rights; 


handbags, wallets, and sunglasses bearing Plaintiffs’ respective trademarks will appear in the 

marketplace; that consumers may be misled, confused, and disappointed by the quality of these 

products; and that Plaintiffs may suffer loss of sales for their respective genuine products; 

7



261 

3. There is good cause to believe that if Plaintiffs proceed on notice to 

Defendants on this Ex Parte Application for TRO and Asset Restraint, Defendants can easily and 

quickly transfer the registrations for many of the Subject Domain Names, or modify registration 

data and content, change hosts, and redirect traffic to other websites, thereby thwarting Plaintiffs’ 

ability to obtain meaningful relief; 


counterfeit and infringing branded goods if a temporary restraining order is issued is far 

outweighed by the potential harm to Plaintiffs, their respective reputations and goodwill as 

manufacturers of high quality handbags, wallets, and sunglasses, if such relief is not issued; and 

5. The public interest favors issuance of the temporary restraining order in 

order to protect Plaintiffs’ respective trademark interests and protect the public from being 

defrauded by the palming off of counterfeit goods as genuine goods of the Plaintiffs. 

C. Under 15 U.S.C. § 1117(a), Plaintiffs may be entitled to recover, as equitable 

remedies, the illegal profits gained through Defendants distribution and sales of counterfeit and 

infringing Chanel branded goods and Louis Vuitton branded goods. See Reebok Int’l, Ltd. v. 

Marnatech Enters., Inc., 970 F.2d 552, 559 (9th Cir. 1992) (quoting Fuller Brush Prods. Co. v. 

Fuller Brush Co., 299 F.2d 772, 777 (7th Cir. 1962) (“An accounting of profits under § 1117(a) 

is not synonymous with an award of monetary damages: ‘[a]n accounting for profits . . . is an 

equitable remedy subject to the principles of equity.’”) 

D. Requesting equitable relief “invokes the district court’s inherent equitable powers 


permanent relief.” Levi Strauss & Co. v. Sunrise Int’l Trading Inc., 51 F.3d 982, 987 (11th Cir. 

8



261 

1995) (citing Federal Trade Comm’n v. United States Oil & Gas Corp., 748 F.2d 1431, 1433-34 

(11th Cir. 1984)). 


Defendants’ blatant violation of the federal trademark laws, Plaintiffs have good reason to 

believe Defendants will hide or transfer their ill-gotten assets beyond the jurisdiction of this 



RESPECTFULLY RECOMMENDED that the District Court GRANT Plaintiffs’ Ex 

Parte Application For a Temporary Restraining Order and Order Restraining Transfer of Assets 

Tied to the Counterfeiting Operation as follows: 

(1) Defendants, their officers, directors, employees, agents, subsidiaries, distributors, 

and all persons in active concert or participation with them having notice of this Order are hereby 

temporarily restrained: 


selling, distributing, or transferring any products bearing the Chanel 

Marks and/or the Louis Vuitton Marks, or any confusingly similar 

trademarks, other than those actually manufactured or distributed by 

Plaintiffs; and 



by Plaintiffs, bearing the Chanel Marks and/or the Louis Vuitton Marks, 

or any confusingly similar trademarks; or (ii) any evidence relating to the 

manufacture, importation, sale, offer for sale, distribution, or transfer of 

any products bearing the Chanel Marks and/or the Louis Vuitton Marks, or 




immediately discontinue the use of the Chanel Marks and/or the Louis Vuitton Marks or any 

9



261 

confusingly similar trademarks, on or in connection with all Internet websites owned and 

operated, or controlled by them including the Internet websites operating under the Subject 

Domain Names; 



immediately discontinue the use of the Chanel Marks and/or the Louis Vuitton Marks, or any 

confusingly similar trademarks within domain name extensions, metatags or other markers 

within website source code, from use on any webpage (including as the title of any web page), 

any advertising links to other websites, from search engines’ databases or cache memory, and 

any other form of use of such terms which is visible to a computer user or serves to direct 

computer searches to websites registered by, owned, or operated by Defendants, including the 

Internet websites operating under the Subject Domain Names; 

(4) Defendants shall not transfer ownership of the Subject Domain Names during the 



transfer to Plaintiffs’ counsel, for deposit with this Court, domain name certificates for the 


(6) The Registrars and the top-level domain (TLD) Registries for the Subject Domain 

Names, within ten (10) days of receipt of this Temporary Restraining Order shall change the 

registrar of record for the Subject Domain Names to a holding account with the United States 

based Registrar, GoDaddy.com, Inc. Upon transfer of the Subject Domain Names into the 

holding account, GoDaddy.com, Inc. will hold the Subject Domain Names in trust for the Court 

during the pendency of this action. Additionally, GoDaddy.com, Inc. shall immediately update 

10



261 

the Domain Name System (“DNS”) data it maintains for the Subject Domain Names, which links 

the domain names to the IP addresses where their associated websites are hosted, to 

NS1.MEDIATEMPLE.NET and NS2.MEDIATEMPLE.NET, which will cause the domain 

names to resolve to the website where a copy of the Complaint, Summonses, Temporary 

Restraining Order, and other documents on file in this action are displayed. Alternatively, 

GoDaddy.com, Inc. may institute a domain name forwarding which will automatically redirect 

any visitor to the Subject Domain Names to the following Uniform Resource Locator (“URL”) 

http://servingnotice.com/ZhitianDai/index.html whereon a copy of the Complaint, 

Summonses, Temporary Restraining Order, and other documents on file in this action are 

displayed. After GoDaddy.com, Inc. has effected this change the Subject Domain Names shall 

be placed on Lock status, preventing the modification or deletion of the domains by the registrar 

or Defendants; 

(7) Plaintiffs may enter the Subject Domain Names into Google’s Webmaster Tools 

and cancel any redirection of the domains that have been entered there by Defendants which 



(8) Defendants shall preserve copies of all their computer files relating to the use of 

any of the Subject Domain Names and shall take all steps necessary to retrieve computer files 

relating to the use of the Subject Domain Names that may have been deleted before the entry of 

this Order; 

(9) Upon receipt of this Order, Western Union Financial Services, Inc. (“Western 

Union”) shall divert all money transfers sent by United States consumers to Zhitian Dai of 

Xiamen City, Fujian Province, People's Republic of China, with the date of birth and 

11



261 

identification number provided by the recipient of MTCN 357-057-5291, and hold such transfers 

until it receives further direction from the Court; 1 

(10) In the event any money transfers are diverted in accordance with Paragraph 9 of 

this Order, Western Union shall be permitted to inform consumers who may contact Western 

Union about the transfers that the transfers are being held pursuant to a Court Order in Chanel, 

Inc., et al. v. Dai, et al., Case No. 1:11-cv-23051-DLG, entered by the United States District 

Court for the Southern District of Florida and that they may contact Plaintiffs’ counsel for 

additional information; 

(11) Western Union shall also, within five business days of receiving this Order, 

provide to Plaintiffs’ counsel records of all money transfers that have been paid to Zhitian Dai of 

Xiamen City, Fujian Province, People's Republic of China, with the date of birth and 

identification number provided by the recipient of MTCN 357-057-5291, as well as records of 

money transfers that have been diverted in accordance with Paragraph 9 of this Order. For any 

transfers that have been diverted in accordance with this Order, Plaintiffs’ counsel will respond 

to any consumer inquiries and will provide notice of the Order and the disposition of the 

transfers to any affected consumer. Western Union shall receive and maintain this Order and its 

contents as confidential as to Zhitian Dai and any other recipient associated with the MTCN 357- 

057-5291, until further order of this Court; 

(12) Upon receipt of notice of this Order, PayPal, Inc. (“PayPal”) and its related 

companies and affiliates shall immediately freeze all PayPal accounts related to the PayPal 

1 Western Union is licensed to do business in the State of Florida by the Florida Office of 

Financial Regulation and is therefore subject to personal jurisdiction in this Court. (See Gaffigan 

Decl. 11 and Exhibit G attached thereto.) 

12



261 

account recipient “xmleading2012@hotmail.com” and any other related accounts of the same 

customer; 2 

(13) PayPal shall also immediately divert to a holding account for the trust of the Court 

all funds currently in, or which during the pendency of this Order come in to, all PayPal accounts 

related to the PayPal account recipient “xmleading2012@hotmail.com” and any other related 

accounts of the same customer; 

(14) PayPal shall further, within five (5) days of receiving this Order, provide 

Plaintiff’s counsel with all data which identifies the PayPal accounts frozen as well as a list 

which breaks down and summarizes the funds in the frozen accounts. Such freezing of the 

accounts and the disclosure of the related financial institution account information shall be made 

without notice to the account owners or the financial institutions until further order of this Court. 

PayPal shall receive and maintain this Order and its contents as confidential until further order of 

this Court; 

(15) This Temporary Restraining Order shall remain in effect until the date for the 

hearing on the Motion for Preliminary Injunction set forth below, or until such further dates as 

set by the Court or stipulated to by the parties; 

(16) Pursuant to 15 U.S.C. § 1116(d)(5)(D), Plaintiffs shall post a bond in the amount 

of Ten Thousand Dollars and Zero Cents ($10,000.00), as payment of damages to which 

Defendants may be entitled for a wrongful injunction or restraint. Plaintiffs shall post the bond 

prior to requesting the Registries to transfer control of the Subject Domain Names; 

(17) A hearing is set before this Court in the United States Courthouse located at 400 

North Miami Avenue, Miami, Florida 33128-1812, Courtroom 13-4, on __________________, 

2 PayPal is licensed to do business in the State of Florida by the Florida Office of the Controller 

and is therefore subject to personal jurisdiction in this Court. (See Gaffigan Decl. 12 and 

Exhibit H attached thereto.) 

13



261 

2011, at ______, or at such other time that this Court deems appropriate, at which time 

Defendants and/or any other affected persons may challenge the appropriateness of this Order 

and move to dissolve the same and at which time the Court will hear argument on Plaintiffs’ 

requested preliminary injunction; 

(18) Plaintiffs shall serve a copy of the Ex Parte Application for TRO and Asset 

Restraint and this Order on Defendants by posting a copy of the Ex Parte Application for TRO 

and Asset Restraint and this Order on the website located at 

http://servingnotice.com/ZhitianDai/index.html, upon transfer of the Subject Domain Names 

into the holding account with GoDaddy.com, Inc., and such notice so given shall be deemed 

good and sufficient service thereof. Any response or opposition to Plaintiffs’ Motion for 

Preliminary Injunction must be filed and served on Plaintiffs’ counsel at least seventy-two (72) 

hours before the hearing set for ______________, 2011, and filed with the Court, along with 

Proof of Service, on ___________, 2011. Plaintiffs may file a Reply Memorandum on or before 

________________, 2011. The above dates may be revised upon stipulation by all parties and 

approval of this Court. Defendants are hereby on notice that failure to appear at the hearing may 

result in the imposition of a preliminary injunction against them pursuant to 15 U.S.C. § 1116(d) 

and Fed. R. Civ. P. 65. 

RESPECTFULLY RECOMMENDED in chambers in Miami, Florida, this 2nd day of 

September, 2011. 

cc: Donald L. Graham, United States District Judge; All Counsel of Record 

14



261 

1. beautifulcity.info 

2. bestapparelforu.info 

3. luxurybagsnow.com 

4. niceapparel.info 

5. nicegiftsforu.info 

6. nicegiftsforu1.info 

7. nicegiftsforu2.com 





12. nicegiftsforutoday.info 

13. shopwhatulove.info 

14. uggaustraliashoes.info 


SUBJECT DOMAIN NAMES



261 

GUCCI AMERICA, INC., 

v. 

Plaintiff, 

GUODONG ZHOU, et at., 

Defendants. 

-------------------------------/ 



CASE NO. 11-22734-CIV -SEITZ/SIMONTON 

ORDER GRANTING TEMPORARY RESTRAINING ORDER EX PARTE 

THIS CAUSE is before the Court on Plaintiffs Ex Parte Application for Entry of 

Temporary Restraining Order and Preliminary Injunction and Order Restraining Transfer of 

Assets Tied to the Counterfeiting Operation (the "Ex Parte Application for TRO and Asset 

Restraint"). The Court has carefully reviewed the Application, the entire Court file and is 

otherwise fully advised in the premises. 

By the instant Application, Plaintiff, Gucci America, Inc. ("Gucci"), moves ex parte, for 

entry of a temporary restraining order and order freezing the financial accounts used by 

Defendants Guodong Zhou, Zheng Yueruo, Lin Feng, Wu Weilong, Shaosong Lin, Wu Jinlong, 

and Does 1-1 0 (collectively "Defendants") doing business as the domain names identified on 

Schedule "A" hereto (the "Subject Domain Names"), pursuant to 15 U.S.C. § 1116 and Fed. R. 

Civ. P. 65. 

1



261 

are selling are copies of Plaintiff s products that bear copies of the Gucci Marks on handbags, 

wallets, footwear, belts, shirts, hats, sunglasses, and watches. 

B. Because of the infringement of the Gucci Marks, Plaintiff is likely to suffer 


appears from the following specific facts, as set forth in Plaintiffs First Amended Complaint, Ex 

Parte Application for TRO and Asset Restraint, and accompanying declarations on file, that 

immediate and irreparable loss, damage, and injury will result to Plaintiff and to consumers 

before Defendants can be heard in opposition unless Plaintiff s request for ex parte relief is 

granted: 

1. Defendants are operating Internet businesses which advertise, offer for 

sale, and sell, at least handbags, wallets, footwear, belts, shirts, hats, sunglasses, and watches 

bearing counterfeit and infringing trademarks in violation of Plaintiff s rights; 


handbags, wallets, footwear, belts, shirts, hats, sunglasses, and watches s bearing Plaintiffs 

trademarks will appear in the marketplace; that consumers may be misled, confused, and 

disappointed by the quality of these products; and that Plaintiff may suffer loss of sales for its 

genuine products; 


Defendants on this Ex Parte Application for TRO and Asset Restraint, Defendants can easily and 

quickly transfer the registrations for many of the Subject Domain Names, or modifY registration 

data and content, change hosts, and rcdirect traffic to other web sites, thereby thwarting 

Plaintiff s ability to obtain meaningful relief; 

5



261 




ORDERED AND ADJUDGED that Plaintiffs Ex Parte Application For a Temporary 







selling, distributing, or transferring any products bearing the Gucci Marks, 

or any confusingly similar trademarks, other than those actually 




by Plaintiff, bearing the Gucci Marks, or any confusingly similar 

trademarks; or (ii) any evidence relating to the manufacture, importation, 


Gucci Marks, or any confusingly similar trademarks. 



Order shall immediately discontinue the use of the Gucci Marks or any confusingly similar 

trademarks, on or in connection with all Internet websites owned and operated, or controlled by 

them including the Internet websites operating under the Subject Domain Names; 



7



261 

Order shall immediately discontinue the use of the Gucci Marks, or any confusingly similar 

trademarks within domain name extensions, metatags or other markers within website source 

code, from use on any webpage (including as the title of any web page), any advertising links to 

other websites, from search engines' databases or cache memory, and any other form of use of 

such terms which is visible to a computer user or serves to direct computer searches to websites 

registered by, owned, or operated by each Defendant, including the Internet websites operating 

under the Subject Domain Names; 

(4) Each Defendant shall not transfer ownership of the Subject Domain Names 

during the pendency of this Action, or until further Order of the Court; 


transfer to Plaintiff s counsel, for deposit with this Court, domain name certificates for the 


(6) The Registrars and VeriSign Global Registry Services, the top-level domain 

(TLD) Registries for the Subject Domain Names, within ten (10) days of receipt of this 

Temporary Restraining Order shall change the registrar of record for the Subject Domain Names 

to a holding account with the United States based Registrar, GoDaddy.com, Inc. Upon transfer 

of the Subject Domain Names into the holding account, GoDaddy.com, Inc. will hold the Subject 

Domain Names in trust for the Court during the pendency of this action. Additionally, 

GoDaddy.com, Inc. shall immediately update the Domain Name System ("DNS") data it 

maintains for the Subject Domain Names, which links the domain names to the IP addresses 

where their associated websites are hosted, to NS I.MEDIA TEMPLE.NET and 

NS2.MEDIATEMPLE.NET, which will cause the domain names to resolve to the website where 

8



261 

1. 

2. 

3. 

4. 

5. 

6. 

7. 

8. 

9. 

10. 

11. 

12. 

13. 

14. 

15. 

16. 

17. 

18. 

19. 

20. 

21. 

22. 

23. 

24. 

25. 

26. 

27. 

28. 

29. 

30. 

31. 

32. 

33. 

34. 

35. 

36. 

37. 

38. 

39. 

40. 

5 Inike.com 

8000bag.com 

abercrombiefitch-tp.com 

adaxie.com 

adaydxie.com 

adidas-20 II.com 

adidas543.com 

adidas668-tw.com 

adidas88-tp.com 

adidasclot.com 

adidashk.com 

adidasoutlet-tw.com 

adidas-play.com 

adidasshoes-tp.com 

adidassuperstar-shoes.com 

adidas-tshirt.com 

adidasy3-tp.com 

airmax555.com 

alife555.com 

alifexie.com 

allstar555.com 

all star-star. com 

asoshoes-tw.com 

balenciagatw.com 

bape-ape-tw.com 

birkenstockdavos.com 

blsj II.com 

brandbag2wholesale.com 

brandbagsave.com 

brandhandbags4u.com 

btp-shoes.com 

burberry2011.com 

celine-tw.com 

cjbl-shoes.com 

ckckbe.com 

coalI.com 

coatw.com 

cons-tp.com 

converse998.com 

converseonestar-tp.com 

SCHEDULE "A" 


13



261 

41. conversetp.com 

42. converse-tp.com 

43. dcdcdc-tw.com 

44. diesel-fashion. com 

45. doctorj-tw.com 

46. dunhill2010-tw.com 

47. dunk555.com 

48. elle-tw.com 

49. facebook -tp.com 

50. footballclub-tw.com 

51. freestyle-tw.com 

52. g2000-tw.com 

53. giftsofurs.com 

54. grabbinghandbags.com 

55. grabbinglux.com 

56. gucci-1689.com 

57. gucci2handbags.com 

58. gucci4saleonline.com 

59. guccibags2sale.com 

60. guccibagsestore.com 

61. gucci-bb.com 

62. guccireplicabag.com 

63. guccireplicabags.com 

64. guccireplicahandbag.com 

65. guccireplicastore.com 

66. gucci styledrops. com 

67. hermes-tw.com 

68. hungerforurbrand.com 

69. idearock-tw.com 

70. iwc-2011.com 

71. jingpinlb.com 

72. kedsshoes-tp.com 

73. kikstyo-tp.com 

74. lacostepolo 168 .com 

75. lee-tp.com 

76. luxurybags4sale.com 

77. lv-i.eom 

78. melissa-dg.eom 

79. momo20 II.com 

80. montblanc20 1 O-tw.com 

81. msprad.com 

82. msriben.com 

83. mssisley.com 

84. mygucci bagestore. com 

14



261 

85. myguccibagestores.com 

86. mygucci bagsstore.com 

87. mygucci bagstores.com 

88. mygucci -estore.com 

89. mygucci-estores.com 

90. mygucci-store.com 

91. myworldofwatch.com 

92. nba-nike.com 

93. newbuffalo-tw.com 

94. nike543.com 

95. nike88888.com 

96. nike9a.com 

97. nike-airforce3.com 

98. nikeji.com 

99. nikepro-tp.com 

100. nikesb-taiwan.com 

101. nike-tshirt.com 

102. playboy-taiwan. com 

103. play-timberland. com 

104. polo-polojeans.com 

105. polot-shirt318.com 

106. porter2010.com 

107. porter-tp.com 

108. pradatw.com 

109. pramomo.com 

110. puma66-tp.com 

Ill. pumatshist.com 

112. ryl-shoes.com 

113. shoes543.com 

114. shoes-tp.com 

115. shoesws.com 

116. stage-polo .com 

117. star-crocs.com 

118. stayreal-tp.com 

119. tbl-shoes.com 

120. tiffany-co 5 .com 

121. timberland5 5 5 .com 

122. timberland-xie.com 

123. tland-tw.com 

124. tommy-tw.com 

125. travelfox-tw.com 

126. tw-allstar.com 

127. valentino-tw.com 

128. vans555.com 

15



261 

129. vans99.com 

130. watchoutlet-online.com 

131. yesguccigift2u.com 

132. yesguccigifts2u.com 

133. yesluxurybagssale.com 

134. yes-myluxurybags.com 

135. yeswatcheshop.com 

136. zara-tw.com 

137. zlxie-tp.com 

16


Exhibit F


PayPal State Licenses - PayPal 


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PayPal, Inc. is licensed in the following US jurisdictions: 

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Economic Development 

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District of 

Columbia 

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Regulatory Affairs 

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of 2006 

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Regulation 

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Money Transfers 

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of 1994 

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