Adidas AG et al v. adilkas et al

Filing 22

ORDER granting 7 Plaintiff's Application for Entry of Temporary Restraining Order, Preliminary Injunction, and Order Restraining Transfer of Assets and Memorandum of Law in Support Thereof Signed by Judge Marcia G. Cooke on 8/20/2015. (tm)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 15-61492-CIV-COOKE/TORRES
ADIDAS AG, et al.,
Plaintiffs,
vs.
ADILKAS, et al.,
Defendants.

/

ORDER GRANTING PLAINTIFFS’ APPLICATION
FOR PRELIMINARY INJUNCTION
THIS MATTER is before me on Plaintiffs’1 Application for Preliminary Injunction
against Defendants2 pursuant to 15 U.S.C. § 1116 and Federal Rule of Civil Procedure 65,
for alleged violations of the Lanham Act, 15 U.S.C. §§ 1114, and 1125(a) (the “Application
for Preliminary Injunction”) (ECF No. 7). I have reviewed the Application for Preliminary
Injunction and accompanying attachments, the record, and the relevant legal authority.
Defendants have not responded to the Application for Preliminary Injunction, nor
made any filing in this case, nor have Defendants appeared in this matter either individually
or through counsel. Defendants were on notice that failure to appear at the hearing may
result in the imposition of a preliminary injunction. ECF No. 13 at IV(16). For the reasons
discussed below, Plaintiffs’ Application for Preliminary Injunction (ECF No. 7) is
GRANTED.

1

Plaintiffs include adidas AG (“adidas AG”), adidas International Marketing B.V. (“adidas
International”), and adidas America, Inc. (“adidas America”) (collectively, “adidas”), as well as
Reebok International Limited (“Reebok International”) and Reebok International Ltd. (“Reebok
Ltd.”) (collectively, "Reebok"), and Sports Licensed Division of the adidas Group, LLC
(“SLD”).
2

Defendants are the Individuals, Partnerships and Unincorporated Associations identified on
Schedule “A” hereto and Does 1-10.

I.

FACTUAL BACKGROUND3

Plaintiff adidas is the registered owner of the following trademarks on the Principal
Register of the United States Patent and Trademark Office (collectively, the “adidas
Marks”):
Trademark

Registration
Number

Registration
Date

Class / Goods

0,891,222

0,973,161

IC 25 - specific purpose athletic shoes;
November 20, general purpose sport shoes, sportswear1973
namely, suits, shorts, pants, tights, shirts,
jerseys, socks, and gloves.

1,300,627

ADIDAS

IC25 - sportswear namely, suits, shorts,
pants, tights, shirts, gloves, and the like;
May 19, 1970 jerseys; socks; sport shoes namely, track
and field training shoes, basketball
shoes, and tennis shoes.

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.

1,310,140

October 16,
1984

IC 025 - sportswear-namely, suits,
shorts, pants, tights, shirts, jerseys,
December 18, socks, gloves, jackets, coats, swimwear,
1984
sweaters, caps, pullovers, warm-up suits,
rain suits, ski suits, jump suits, boots,
shoes, slippers.

3

The factual background is taken from Plaintiffs’ Complaint (ECF No. 1), Plaintiffs’
Application for Preliminary Injunction (ECF No. 7), and supporting evidentiary submissions.
Plaintiffs filed declarations and exhibits annexed thereto in support of its Application for
Preliminary Injunction. The declarations are available in the docket at the following entries:
Declaration of Jeni B. Zuercher (ECF No. 8), Declaration of Virgilio Gigante (ECF No. 9),
Declaration of Eric Rosaler (ECF No. 10), and Declaration of Kathleen Burns (ECF No. 11).
2

IC 018 - all purpose sport bags, athletic
bags, traveling bags, backpacks,
knapsacks, beach bags.

2,411,802

IC 025 - sports and leisure wear, namely,
shorts, pants, shirts, t-shirts, jerseys,
tights, socks, gloves, jackets, swimwear,
December 12, caps and hats, pullovers, sweat-shirts,
2000
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.
IC 009 - optical apparatus and
instruments, namely, eyeglasses and
sunglasses.
IC 014 - horological and chronometric
instruments, namely, watches

3,104,117

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
June 13, 2006 leather and goods made from these
materials, namely, wallets, briefcases.
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, warmup 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.

3

4,679,762

January 27,
2015

IC 009 - Mobile phone covers; laptop
covers and sleeves; protective covers and
sleeves for tablet computer

4,679,763

January 27,
2015

IC 009 - Mobile phone covers; laptop
covers and sleeves; protective covers and
sleeves for tablet computer

(See Declaration of Jeni B. Zuercher in Support of Plaintiffs’ Application for Preliminary
Injunction [“Zuercher Decl.”] ¶ 5.) The adidas Marks are used in connection with the
manufacture and distribution of goods in the categories identified above. (Id.)
Plaintiff Reebok is the registered owner of the following trademarks on the Principal
Register of the United States Patent and Trademark Office (collectively, the “Reebok
Marks”):
Trademark

Registration
Number

Registration
Date

Class / Goods
IC 18 - all purpose sport bags

REEBOK

1,390,793

April 22, 1986

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.

1,848,848

August 9, 1994

4

IC 025 - footwear and apparel;
namely, t-shirts, shirts, sweatshirts,
sweaters, jackets, hats, visors, socks,
sweatpants, pants, shorts, skirts,
unitards, and leotards.

Trademark

RBK

Registration
Number

3,074,802

Registration
Date

Class / Goods

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,
March 28, 2006 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.]

(See Zuercher Decl. ¶ 14.) The Reebok Marks are used in connection with the manufacture
and distribution of goods in the categories identified above. (Id.)
SLD is the owner of the following trademark registered on the Principal Register of
the United States Patent and Trademark Office (the “Mitchell & Ness Mark”):
Trademark

Registration
Number

Registration
Date

MITCHELL &
NESS

2,860,283

July 6, 2004

Class / Goods
IC 025 - sports jerseys, jackets,
shirts, t-shirts, sweaters, caps, hats,
head bands and wrist bands

(See Zuercher Decl. ¶ 23.) The Mitchell & Ness Mark is used in connection with the
manufacture and distribution of goods in the categories identified above. (Id.)
Defendants, through the operation of Internet e-commerce stores under their seller
identification names identified on Schedule “A” hereto (collectively the “Seller IDs”), have
advertised, promoted, offered for sale, or sold goods bearing what Plaintiffs have
determined to be counterfeits, infringements, reproductions or colorable imitations of the

5

adidas Marks, the Reebok Marks, or the Mitchell & Ness Mark (collectively, “Plaintiffs’
Marks”). (See Zuercher Decl. ¶¶ 31-36.)
Although each Defendant may not copy and infringe each of Plaintiffs’ Marks for
each category of goods protected, Plaintiffs have submitted sufficient evidence showing each
Defendant has infringed, at least, one or more of Plaintiffs’ Marks at issue. (Id.) Defendants
are not now, nor have they ever been, authorized or licensed to use, reproduce, or make
counterfeits, reproductions, or colorable imitations of Plaintiffs’ Marks. (See Zuercher Decl.
at ¶ 31.)
Plaintiffs retained Aries Claim Services and AED Investigations, Inc., both licensed
private investigative firms, to investigate the sale of counterfeit versions of Plaintiffs’
products by Defendants. (See Zuercher Decl. at ¶ 32; Declaration of Kathleen Burns in
Support of Plaintiffs’ Application for Preliminary Injunction [“Burns Decl.”] ¶ 3;
Declaration of Eric Rosaler in Support of Plaintiffs’ Application for Preliminary Injunction
[“Rosaler Decl.”] ¶ 3. Kathleen Burns, a partner at Aries Claims Services, accessed the
Internet based e-commerce stores operating under the Seller IDs identified on Schedule
“B-­‐1” hereto, and placed orders from each Seller ID for the purchase of various products, all
bearing at least one of Plaintiffs’ respective trademarks at issue in this action, and requested
each product be shipped to her address in the Southern District of Florida. (See Burns Decl.
¶ 4.) Following the submission of her orders, Ms. Burns was instructed that she could
finalize her purchase by making payment to Defendants' respective PayPal accounts, which
are identified on Schedule B-1. (Id.) While accessing each e-commerce store, Ms. Burns also
captured and downloaded webpages reflecting the products being sold and all purchase
transaction and payment instructions. (Id.)
Additionally, Eric Rosaler, an officer of AED Investigations, Inc., accessed the
Internet based e-commerce stores operating under the Seller IDs identified on Schedule
“B-­‐2” hereto, and placed orders from each Seller ID for the purchase of various products, all
bearing at least one of Plaintiffs’ respective trademarks at issue in this action, and requested
each product to be shipped to his address in the Southern District of Florida. (See Rosaler
Decl. ¶ 4.) Following submission of his orders, Mr. Rosaler was likewise instructed that he
could finalize his purchase by making payment to Defendants’ respective PayPal accounts,
which are identified on Schedule B-2. (Id.) While accessing each e-commerce store, Mr.

6

Rosaler also captured and downloaded webpages reflecting the products being sold and all
purchase transaction and payment instructions. (Id.)
Plaintiffs' representative visually inspected the items offered for sale under Plaintiffs'
Marks on the e-commerce stores operating under each of the Seller IDs, and determined the
products were not genuine versions of Plaintiffs' products. (See Zuercher Decl. ¶¶ 34-36.)
On July 22, 2015, Plaintiffs filed their Ex Parte Application for Entry of Temporary
Restraining Order, Preliminary Injunction, and Order Restraining Transfer of Assets (the
“Ex Parte Application”) (ECF No. 7, entered on docket July 23, 2015). On August 5, 2015,
I issued a Sealed Order Granting Plaintiffs’ Ex Parte Application for Entry of Temporary
Restraining Order (ECF No. 13, entered on docket August 6, 2015) thereby temporarily
restraining Defendants from infringing Plaintiffs’ Marks at issue. On August 11, 2015 and
August 12, 2105, Plaintiffs served Defendants in the manner set forth in the Order Granting
Plaintiffs’ Ex Parte Application for Entry of Temporary Restraining Order, and on August
18, 2015, filed proofs of service. (ECF Nos. 16 and 17).
II.

LEGAL STANDARD

In order to obtain a preliminary injunction, 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 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).
III.

ANALYSIS

The declarations Plaintiffs submitted in support of its Application for Preliminary
Injunction support the following conclusions of law:
A.

Plaintiffs have a strong probability of proving at trial that consumers are likely

to be confused by Defendants’ advertisement, promotion, sale, offer for sale, or distribution
of goods bearing counterfeits, reproductions, or colorable imitations of Plaintiffs’ Marks,
and that the products Defendants are selling and promoting for sale are copies of Plaintiffs
products that bear copies of Plaintiffs’ Marks.

7

B.

Because of the infringement of the Plaintiffs’ Marks, Plaintiffs are likely to

suffer immediate and irreparable injury if a preliminary injunction is not granted. The
following specific facts, as set forth in Plaintiffs’ Complaint, Application for Preliminary
Injunction, and accompanying declarations demonstrate that immediate and irreparable
loss, damage, and injury will result to Plaintiffs and to consumers because it is more likely
true than not that:
1.

Defendants own or control e-commerce stores via Internet marketplace

websites operating under their seller identification names which advertise, promote, offer for
sale, and sell products bearing counterfeit and infringing trademarks in violation of
Plaintiffs’ respective rights;
2.

There is good cause to believe that more counterfeit and infringing

products bearing Plaintiffs’ trademarks will appear in the marketplace; that consumers are
likely to be misled, confused, or disappointed by the quality of these products; and that
Plaintiffs may suffer loss of sales for its genuine products.
C.

The balance of potential harm to Defendants in restraining their trade in

counterfeit and infringing branded goods if a preliminary injunction is issued is far
outweighed by the potential harm to Plaintiffs, their reputation, and goodwill as a
manufacturer and distributor of quality products, if such relief is not issued.
D.

The public interest favors issuance of the preliminary injunction in order to

protect Plaintiffs’ trademark interests and protect the public from being defrauded by the
palming off of counterfeit goods as Plaintiffs’ genuine goods.
E.

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 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.’”))
F.

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., 51 F.3d at 987 (11th Cir. 1995) (citing

8

Federal Trade Commission v. United States Oil and Gas Corp., 748 F.2d 1431, 1433-34 (11th Cir.
1984)).
G.

In light of the inherently deceptive nature of the counterfeiting business, and

the likelihood that Defendants have violated federal trademark laws, Plaintiffs have 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 Plaintiffs
Application for Preliminary Injunction (ECF No. 7) is GRANTED as follows:
(1)

Each Defendant, its officers, directors, employees, agents, subsidiaries,

distributors, and all persons in active concert or participation with any Defendant having
notice of this Order are hereby restrained and enjoined until further Order of this Court:
a. From manufacturing, importing, advertising, promoting, offering to
sell, selling, distributing, or transferring any products bearing the
Plaintiffs’ Marks, or any confusingly similar trademarks, other than
those actually manufactured or distributed by Plaintiffs; and
b. From secreting, concealing, destroying, selling off, transferring, or
otherwise disposing of: (i) any products, not manufactured or
distributed by Plaintiffs, bearing Plaintiffs’ 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 Plaintiffs’ Marks, or any confusingly similar
trademarks.
(2)

Each Defendant, its officers, directors, employees, agents, subsidiaries,

distributors, and all persons in active concert or participation with any Defendant having
notice of this Order shall immediately discontinue, until further Order of this Court, the use
of Plaintiffs’ Marks or any confusingly similar trademarks, on or in connection with all
Internet based e-commerce stores operated or controlled by them under their Seller IDs;
(3)

Each Defendant, its officers, directors, employees, agents, subsidiaries,

distributors, and all persons in active concert or participation with any Defendant having
notice of this Order shall immediately discontinue, until further Order of this Court, the use
of Plaintiffs’ Marks, or any confusingly similar trademarks within metatags or other markers
within website source code, from use on any webpage (including as the title of any web

9

page), from 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 Internet based e-commerce stores and auction website
businesses registered by, owned, or operated by each Defendant, including the e-commerce
stores operating under their respective Seller IDs;
(4)

Each Defendant shall not transfer ownership of the Internet based e-

commerce store and auction website businesses under their Seller IDs during the pendency
of this Action, or until further Order of the Court;
(5)

Each Defendant shall preserve, and continue to preserve, copies of all their

computer files relating to the use of any of the Internet based e-commerce store and auction
website businesses under their Seller IDs and shall take all steps necessary to retrieve
computer files relating to the use of the Internet based e-commerce store under their Seller
IDs that may have been deleted before the entry of this Order;
(6)

Within five days of receiving notice of this Order, iOffer, Inc. (“iOffer”) shall,

to the extent not already done, provide Plaintiffs’ counsel with all data identifying any and
all payment accounts, including PayPal accounts, used by Defendants and/or their ecommerce stores identified on Schedule “A” hereto. Upon receipt of the payment data from
iOffer, Plaintiffs shall provide any identified PayPal accounts to PayPal, which shall restrain
such accounts in accordance with Paragraph 7, below;
(7)

Upon receipt of notice of this Order, PayPal, Inc. (“PayPal”)4 and its related

companies and affiliates shall, to the extent not already done, immediately restrain all funds,
as opposed to ongoing account activity, in or which hereafter are transmitted into the
PayPal accounts related to Defendants and associated PayPal accounts and e-mail addresses
identified on Schedule “A” hereto, 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 Seller IDs identified on Schedule “A” hereto;

4

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 Declaration of Virgilio
Gigante in Support of Plaintiffs’ Application for Preliminary Injunction ¶ 3.)
10

(8)

PayPal shall also immediately, to the extent not already done, divert to a

holding account for the trust of the Court all funds in all PayPal accounts related to
Defendants and associated PayPal accounts and e-mail addresses identified on Schedule
“A,” and all funds in all PayPal accounts related to the PayPal account recipients identified
by iOffer, 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;
(9)

PayPal shall further, to the extent not already done, within five business days

of receiving this Order, provide Plaintiffs’ counsel with all data which details (i) an
accounting of the total funds restrained and identifies the PayPal account(s) which the
restrained funds are related to, and (ii) the account transactions related to all funds
transmitted into the PayPal account(s) which have been restrained. Such restraining of the
funds and the disclosure of the related financial institution account information shall be
made without notice to the account owners until those accounts are restrained. No funds
restrained by this Order shall be transferred or surrendered by PayPal for any purpose (other
than pursuant to a chargeback made pursuant to PayPal’s security interest in the funds)
without the express authorization of the Court;
(10)

This Order shall apply to the Seller IDs, associated e-commerce stores, and

any other Seller IDs, e-commerce stores, or PayPal accounts which are being used by
Defendants for the purpose of counterfeiting Plaintiffs’ Marks at issue in this action and/or
unfairly competing with Plaintiffs;
(11)

PayPal or any Defendant or PayPal account holder may petition the Court to

modify the asset restraint set out in this Order;
(12)

Pursuant to 15 U.S.C. § 1116(d)(5)(D) and Federal Rule of Civil Procedure

65(c), Plaintiffs shall maintain their previously posted 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, 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 an application be made in the interest of justice;
(13)

This Preliminary Injunction shall remain in effect during the pendency of this

action, or until further Order of this Court.

11

2015.

DONE and ORDERED in chambers, at Miami, Florida, this 20th day of August

Copies furnished to:
Edwin G. Torres, U.S. Magistrate Judge
Counsel of record via e-mail

12

SCHEDULE “A”
DEFENDANTS BY SELLER ID AND ASSOCIATED PAYPAL ACCOUNT
Defendant
Number
1
2
3
4
5
6
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
28
29
30
31
32
33
34
35
36

Defendant / Seller ID
adilkas
acsmartshop
alfons
appiz2207
best-deal2014
bluemoonshop
sport101
Dismissed
cristiano_ronaldo
darren4
dursamil
elian
Dismissed
firststore
funandhappy
globalmax365
grandmall
jajashoppe
joeybless
kiatisak
loopsjerseys
lyubkom
maximato
maxishop
mejor
memeshop
miraaccesories
mitsu_mirage
mshuk
mycheapstore
mvpding
nextstore
okshop
outlander-sport
pagalbiter
rachmania
rainbowstore
ristadi3

PayPal Account
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]

13

37
38
39
40
41
42
43
44
45
46
47
48
49

seri_2014
soccerjerseysports
taylor34
theflock
todosportstore
virtu303
waza
zigzagstore
chouweixiangtou2015
customjersey
italydesign
mahiccoo
myshopehere

50

wonfu

51

ya99jj

[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]

14

SCHEDULE “B”
DEFENDANTS’ RESPECTIVE PAYPAL ACCOUNTS
Schedule “B-­‐1” -­‐ Kathleen Burns’ Investigation
Defendant
Number

Defendant / Seller ID

PayPal Account

1

adilkas

[e-mail]

2

acsmartshop

[e-mail]

3

alfons

[e-mail]

4

appiz2207

[e-mail]

5

best-deal2014

[e-mail]

6

bluemoonshop

[e-mail]

6

sport101

[e-mail]

8

cristiano_ronaldo

[e-mail]

9

darren4

[e-mail]

10

dursamil

[e-mail]

11

elian

[e-mail]

13

firststore

[e-mail]

14

funandhappy

[e-mail]

15

globalmax365

[e-mail]

16

grandmall

[e-mail]

17

jajashoppe

[e-mail]

18

joeybless

[e-mail]

19

kiatisak

[e-mail]

20

loopsjerseys

[e-mail]

21

lyubkom

[e-mail]

22

maximato

[e-mail]

23

maxishop

[e-mail]

24

mejor

[e-mail]

25

memeshop

[e-mail]

26

miraaccesories

[e-mail]

27

mitsu_mirage

[e-mail]

28

mshuk

[e-mail]

28

mycheapstore

[e-mail]
15

29

mvpding

[e-mail]

30

nextstore

[e-mail]

31

okshop

[e-mail]

32

outlander-sport

[e-mail]

33

pagalbiter

[e-mail]

34

rachmania

[e-mail]

35

rainbowstore

[e-mail]

36

ristadi3

[e-mail]

37

seri_2014

[e-mail]

38

soccerjerseysports

[e-mail]

39

taylor34

[e-mail]

40

theflock

[e-mail]

41

todosportstore

[e-mail]

42

virtu303

[e-mail]

43

waza

[e-mail]

44

zigzagstore

[e-mail]

45

chouweixiangtou2015

[e-mail]

46

customjersey

[e-mail]

47

italydesign

[e-mail]

50

wonfu

[e-mail]
[e-mail]

51

ya99jj

[e-mail]

16

Schedule “B-­‐2” -­‐ Eric Rosaler’s Investigation
Defendant
Number

Defendant / Seller ID

PayPal Account

48

mahiccoo

[e-mail]

49

myshopehere

[e-mail]

17