LOUIS VUITTON MALLETIER v. aaalvsale.com et al

Filing 19

ORDER GRANTING #6 PLAINTIFF'S MOTION FOR ENTRY OF PRELIMINARY INJUNCTION Signed by Judge Beth Bloom on 4/27/2021. See attached document for full details. (jbs)

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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No. 21-cv-60790-BLOOM/Valle
LOUIS VUITTON MALLETIER,
Plaintiff,
v.
AAALVSALE.COM, et al.,
Defendants.
_____________________________/
ORDER GRANTING PLAINTIFF’S MOTION
FOR ENTRY OF PRELIMINARY INJUNCTION
THIS CAUSE is before the Court upon Plaintiff’s Motion for Preliminary Injunction, ECF
No. [6] (“Motion”). The Court has carefully considered the Motion, the record in this case, and the
applicable law, and is otherwise fully advised.
By the instant Motion, Plaintiff, Louis Vuitton Malletier, moves for entry of a preliminary
injunction against Defendants,1 for alleged violations of the Lanham Act, 15 U.S.C. §§ 1114 and
1125(a) and (d). The Court held a hearing by video conference on April 27, 2021, which was
attended by counsel for Plaintiff only. During the hearing, Plaintiff directed the Court to evidence
supporting the Motion for Preliminary Injunction. None of the Defendants formally responded to
the Motion, nor have they made any appearance or filing in this case, either individually or through
counsel.2 Because Plaintiff has satisfied the requirements for the issuance of a preliminary
injunction, the Court grants the Motion.
Defendants are the Individuals, Partnerships, and Unincorporated Associations identified on Schedule “A”
hereto (collectively “Defendants”).
2
Plaintiff’s counsel was contacted via email by Defendant Number 158 regarding a possible resolution of
the matter. However, Defendant Number 158 has not filed any response with the Court as of this date and
has not entered any formal appearance, either individually or through counsel.
1

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I.

FACTUAL BACKGROUND3
Plaintiff is the registered owner of the following trademarks, which are valid and registered

on the Principal Register of the United States Patent and Trademark Office (the “Louis Vuitton
Marks”):
Trademark

Registration
Number
0,297,594

LOUIS
VUITTON

Registration
Date

Class(es) / Relevant Goods

IC 18. Trunks, valises, traveling bags, satchels, hat boxes
September 20,
and shoe boxes used for luggage, hand bags, and
1932
pocketbooks.

1,045,932

August 10,
1976

1,519,828

IC 18. Trunks, valises, traveling bags, satchels, hat boxes
January 10,
and shoe boxes used for luggage, hand bags,
1989
pocketbooks.

IC 18. Luggage and ladies’ handbags.

IC 25. Clothing for men and women, namely, shawls,
sashes, scarves; headgear.

1,770,131

May 11, 1993

1,794,905

IC 16. Stationery, pads of stationery, calendars, indexes
for articles made for travellers, notebooks, envelopes;
writing paper, office requisites in the nature of writing
September 28,
pads, pencil holders, pen cases, pencil cases, nibs, nibs
1993
of gold, inkwells, inkstands.
IC 25. Clothing for men and women; namely belts,
shawls, sashes, scarves; footwear headgear.

1,938,808

November 28, IC 14. Jewelry, watches and straps for wrist watches.
1995
IC 24. Travel blankets made of textile.

The factual background is taken from Plaintiff’s Complaint, ECF No. [1], Plaintiff’s Motion for
Preliminary Injunction, ECF No. [6], and supporting evidentiary submissions. Plaintiff filed declarations
and exhibits annexed thereto in support of its Motion for Preliminary Injunction. The declarations are
available in the docket at the following entries: Declaration of Hadrien Huet, ECF No. [6-2], and
Declaration of Stephen M. Gaffigan, ECF No. [6-3].
3

2

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LOUIS
VUITTON

1,990,760

2,177,828

IC 14. Watches and straps for wrist watches.
IC 16. Catalogues featuring luggage and travel
accessories, bags, small leather goods, and garments;
notebooks, anthologies, and pamphlets referring to
travel; calendars; telephone indexes; fountain pens,
ballpoint pens, nibs, covers for pocket and desk diaries,
and checkbook holders.
IC 18. Trunks; traveling trunks; suitcases; traveling bags;
luggage; garment bags for travel; hat boxes for travel;
August 6, 1996 shoe bags for travel; umbrellas; animal carriers;
rucksacks; haversacks; leather or textile shopping bags;
beach bags; handbags; vanity cases sold empty; attaché
cases; tote bags, travel satchels; clutch bags; briefcases;
wallets; pocket wallets; credit card cases; business card
cases; bill and card holders; checkbook holders; key
cases; change purses; briefcase-type portfolios.
IC 24. Travel blankets
IC 25. Shirts; sweatshirts; polo shirts; T-shirts;
headwear; jackets; ties; belts; shawls; scarves.
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 wristwatches, 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,
August 4, 1998
rucksacks, hand bags, beach bags, shopping bags,
shoulder bags, attaché cases, briefcases, and fine leather
goods, namely, pocket wallets, purses, leather key
holders, business card cases, calling card cases, and
credit card cases, umbrellas.
IC 25. Clothing and underwear, namely, shirts,
waistcoats, raincoats, skirts, coats, pullovers, trousers,
dresses, jackets, shawls, stoles, scarves, neckties, pocket
squares, belts, shoes, boots, and sandals.

3

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2,181,753

2,361,695

LOUIS
VUITTON
PARIS

2,378,388

2,399,161

IC 14. Jewelry, namely, rings, ear rings, 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,
August 18,
rucksacks, hand bags, beach bags, shopping bags,
1998
shoulder bags, attaché cases, briefcases, and fine leather
goods, namely, pocket wallets, purses, leather key
holders, business card cases, calling card cases, credit
card cases, and umbrellas.
IC 25. Clothing and underwear, namely, shirts,
waistcoats, raincoats, skirts, coats, pullovers, trousers,
dresses, jackets, shawls, stoles, scarves, neckties, pocket
squares, belts, shoes, boots, and sandals.
IC 25. Clothing, namely, sweaters, shirts, sweatshirts,
polo shirts, t-shirts, suits, waistcoats, raincoats, skirts,
coats, pullovers, trousers, dresses, jackets, shawls, stoles,
June 27, 2000
scarves, neckties, pocket squares, pocket handkerchief
squares for wear, gloves, ties, belts, bathing suits, shoes,
boots and sandals, and hats.
IC 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,
August 22, traveling bags, * traveling sets for containing cosmetics
2000
and jewelry, * 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.
IC 25. Clothing and underwear, namely, shirts, polo
shirts, t-shirts, waistcoats, raincoats, skirts, coats,
October 31,
trousers, dresses, jackets, shawls, stoles, scarves,
2000
neckties, gloves, ties, belts, bathing suits, shoes, boots
and sandals, hats.

4

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2,773,107

October 14,
2003

LOUIS
VUITTON

2,904,197

November 23,
2004

LOUIS
VUITTON

2,909,003

December 7,
2004

3,107,072

June 20, 2006

IC 14. Jewelry including rings, earrings, cuff links,
bracelets, charms, necklaces, and medallions;
horological and chronometric instruments and apparatus,
namely, watches,
IC 18. Travel bags, travel bags made of leather; luggage
trunks and valises, garment bags for travel, vanity-cases
sold empty; rucksacks, shoulder bags, handbags; attaché
cases, briefcases, drawstring pouches, pocket wallets,
purses, umbrellas, business card cases made of leather or
of imitation leather, credit card cases made of leather or
of imitation leather; key holders made of leather or of
imitation leather.
IC 25. Clothing, namely, shirts, T-shirts, belts, scarves,
neck ties, shawls, skirts, raincoats, overcoats, trousers,
jeans, pullovers, frocks, highheeled shoes, low-heeled
shoes, boots, tennis shoes; hats
IC 14: jewelry, namely, rings, earrings, cuff links,
bracelets, charms, necklaces, (( tie pins, and medallions;
keyrings made of precious metal; )) horological and
chronometric instruments, namely, watches, wristwatches, (( clocks, )) (( alarm clocks; )) straps for wristwatches and watch cases.
IC 009. Optical instruments and apparatus, namely,
spectacles, eyeglasses, spectacle cases.
IC 024. Textiles and textile goods, namely, household
linen including bed [ and bath ] linen [, handkerchiefs of
textile ].
IC 09. Spectacles, sunglasses and spectacle cases.
IC 14. Jewelry, namely, rings, earrings and ear clips, cuff
links, bracelets, charms, necklaces, tie pins, 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, attaché 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, shirts, teeshirts, belts, scarves, neckties, shawls, skirts, raincoats,
overcoats, trousers, denim trousers, dresses, jackets,
sashes for wear, bathing suits, shoes, boots.

5

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3,576,404

4,192,541

IC 18: boxes of leather or imitation leather for packaging
and carrying goods, trunks, suitcases, traveling sets
comprised of matching luggage, traveling bags, luggage,
garment bags for travel, ((vanity cases not fitted, ))
February 17, toiletry cases sold empty, rucksacks, satchels, handbags,
2009
beach bags, leather shopping bags, sling bags, suit
carriers, shoulder bags, waist bags, purses, travel cases,
briefcases, briefcase-type portfolios, leather pouches,
wallets, change purses, key cases, business card cases,
calling card cases.
IC 03. Soaps for personal use; perfumery; essential oils;
cosmetics; creams for the hair, face, and body; lotions
for the hair, face, and body; shower and bath gels;
shower and bath preparations; shampoos; make-up
preparations, namely, foundations, lipsticks, eye
shadows, mascara, make-up powder, and nail polish.
IC 09. Sunglasses; spectacles; optical lenses; spectacle
cases; telephones; mobile telephones; smart phones; PC
tablets; personal digital assistants; MP3 players;
accessories for telephones, mobile telephones, smart
phones, PC tablets, personal digital assistants, and MP3
players, namely, hands-free kits for telephones, batteries,
covers, housings, façades, chargers, hand straps, and
neck straps.
IC 14. Jewelry; key rings of precious metal; tie pins;
medallions; jewelry boxes; watches; watch bands; alarm
clocks; cases for timepieces.
August 21, IC 16. Printed matter, namely, pamphlets, catalogs, and
2012
books in the field of travel, luggage, luxury goods,
fashion, clothing, sports, the arts; publications, namely,
brochures and booklets in the field of travel, luggage,
luxury goods, fashion, clothing, sports, the arts;
stationery; stationery articles, namely, note pads, writing
books, drawing books, calendars, agendas, notebooks,
envelopes, letter paper, and index cards; covers for
diaries, indexes, and pads; office requisites, namely,
letter trays, paper cutters, pencils, inkstands, inkwells,
paperweights, pencil holders, pen holders, writing pads,
pens, balls, and nibs for pens; postcards; paper labels;
newspapers; printed documents, namely, printed
certificates.
IC 18. Boxes of leather or imitation leather for
packaging and carrying goods; traveling bags; leather
traveling sets of luggage; trunks; suitcases; garment bags
for travel; vanity cases sold empty; toiletry bags sold
empty; backpacks; handbags; attaché cases; leather

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LOUIS
VUITTON

4,530,921

document cases; wallets; purses; leather key cases;
umbrellas.
IC 24. Textiles and textile goods, namely, bath linen, bed
linen, table linen, towels, bed covers, textile table cloths.
IC 25. Clothing, namely, underwear, shirts, tee-shirts,
pullovers, skirts, dresses, trousers, coats, jackets, belts
for clothing, scarves, sashes for wear, gloves, neckties,
socks, bathing suits; footwear; headwear.
IC 34. Cigar and cigarette cases of leather and imitation
leather.
IC 09. Optical apparatus, namely, binoculars; blank USB
sticks; spectacles; sunglasses; spectacle frames; spectacle
glasses; spectacle cases; accessories for telephones,
mobile phones, smart phones, tablet devices, PDAs, and
MP3 Players, namely, covers, neck straps, neck cords,
and bags and cases specially adapted for holding or
carrying portable telephones and telephone equipment
and accessories.
IC 16. Paper bags; boxes of cardboard or paper;
cardboard and paperboard envelopes and pouches for
packaging; plastic materials for packaging, namely,
bags; posters; pamphlets referring to travel; postcards;
catalogs featuring luggage, travel accessories, bags,
small leather goods, and clothing; paper labels; trading
cards; greeting cards; business cards; invitation cards;
printed publications, namely, books, newspapers,
leaflets, and magazines featuring luggage, travel
accessories, purses, small leather goods, and clothing;
May 13, 2014
bookbinding materials; printed photographs; photograph
albums; stationery, namely, note pads, desk pads, writing
pads, drawing pads, envelopes, note paper; calendars;
pocket calendars; note books; telephone indexes; diary
covers; diaries; office requisites, namely, letter trays,
paper knives, ink stands, inkwells, paper weights, pencil
holders, pen holders, pencil tubs, blotting pads, pencils,
fountain pens, rubber erasers, pen cases; printing types;
printing blocks; table linens of paper.
IC 25. Clothing, namely, pullovers, vests, shirts, teeshirts, trousers, jackets, suits, coats, rain coats,
waterproof jackets, waterproof pants, overcoats, parkas,
skirts, dresses, pajamas, dressing gowns, nightgowns,
robe, gloves, neck ties, belts for clothing, leather belts,
scarves, pocket squares, sashes for wear, shawls,
stockings, socks, tights, braces for clothing, suspenders,
stoles, underwear, lingerie, bathing suits; headwear;
shoes; slippers; boots; half-boots.

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4,614,736

IC 26. Buttons; hooks and eyes; shoe buckles; hair
accessories, namely, hair pins, barrettes, hair bows, hair
clips, hair bands, hair wraps; hair ornaments; brooches
for clothing; clothing fasteners, namely, scarf holders.
IC 09. Optical apparatus, namely, binoculars; blank USB
sticks; spectacles; sunglasses; spectacle frames; spectacle
glasses; spectacle cases; accessories for telephones,
mobile phones, smart phones, tablet devices, PDAs, and
MP3 players, namely, covers, neck straps, neck cords,
and bags and cases specially adapted for holding or
carrying portable telephones and telephone equipment
and accessories.
IC 16. Paper bags, boxes of cardboard or paper,
cardboard and paperboard envelopes and pouches for
packaging; plastic materials for packaging, namely,
bags; posters; pamphlets referring to travel; postcards;
catalogs featuring luggage, travel accessories, bags,
small leather goods, and clothing; paper labels; trading
cards; greeting cards; business cards; invitation cards;
September 30,
printed publications, namely, books, newspapers,
2014
leaflets, and magazines featuring luggage, travel
accessories, purses, small leather goods, and clothing;
bookbinding materials; printed photographs; photograph
albums; stationery, namely, note pads, desk pads, writing
pads, drawing pads, envelopes, note paper; calendars;
pocket calendars; note books; telephone indexes; diary
covers; diaries; office requisites, namely, letter trays,
paper knives, ink stands, inkwells, paper weights, pencil
holders, pen holders, pencil tubs, blotting pads, pencils,
fountain pens, rubber erasers, pen cases; printing types;
printing blocks; table linens of paper.
IC 26. Buttons; hooks and eyes; shoe buckles; hair
accessories, namely, hair pins, barrettes, hair bows, hair
clips, hair bands, hair wraps; hair ornaments; brooches
for clothing; clothing fasteners, namely, scarf holders.

See Declaration of Hadrien Huet, ECF No. [6-2] at ¶ 4; ECF No. [1-3] (containing Certificates of
Registration for the Louis Vuitton Marks at issue). The Louis Vuitton Marks are used in connection
with the manufacture and distribution of high-quality luxury goods in the categories identified above.
See Declaration of Hadrien Huet, ECF No. [6-2] at ¶¶ 4-5.

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Defendants, through the fully interactive,4 commercial Internet websites and supporting
domains operating under the domain names identified on Schedule “A” hereto (the “Subject Domain
Names”), have advertised, promoted, offered for sale, or sold goods bearing what Plaintiff has
determined to be counterfeits, infringements, reproductions, or colorable imitations of the Louis
Vuitton Marks. See Declaration of Hadrien Huet, ECF No. [6-2] at ¶¶ 9-11.
Although each Defendant may not copy and infringe each Louis Vuitton Mark for each
category of goods protected, Plaintiff has submitted sufficient evidence showing each Defendant has
infringed, at least, one or more of the Louis Vuitton Marks. See Declaration of Hadrien Huet, ECF
No. [6-2] at ¶¶ 10-11). Defendants are not now, nor have they ever been, authorized or licensed to
use, reproduce, or make counterfeits, reproductions, or colorable imitations of the Louis Vuitton
Marks. See Declaration of Hadrien Huet, ECF No. [6-2] at ¶¶ 9-11.
Plaintiff’s representative reviewed and visually inspected the Internet websites, including
images reflecting the various items bearing the Louis Vuitton Marks offered for sale by Defendants
through the Internet websites operating under the Subject Domain Names, and determined the
products were non-genuine, unauthorized versions of Plaintiff’s products. See Declaration of
Hadrien Huet, ECF No. [6-2] at ¶¶ 10-11.
On April 12, 2021, Plaintiff filed its Complaint, ECF No. [1], against Defendants for
trademark counterfeiting and infringement, false designation of origin, cybersquatting, common
law unfair competition, and common law trademark infringement. On April 13, 2021, Plaintiff
filed its Ex Parte Application for Entry of Temporary Restraining Order and Preliminary
Injunction, ECF No. [6]. On April 14, 2021, this Court entered a Temporary Restraining Order,

4

Plaintiff asserts multiple Defendants use some of their Subject Domain Names to act as supporting domain
names to direct traffic to their fully-interactive, commercial websites, including those operating under other
Subject Domain Names, from which consumers can complete purchases. See Declaration of Stephen M.
Gaffigan [5-3] at ¶ 2, n.1.

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enjoining Defendants from, among other actions, continuing to manufacture, promote, and/or sell
any products bearing Plaintiff’s alleged infringed trademarks. Pursuant to the Court’s April 14,
2021 Order, Plaintiff served Defendants with a copy of the Complaint together with copies of the
Ex Parte Application for Entry of Temporary Restraining Order and Preliminary Injunction, and
the Court’s April 14, 2021 Temporary Restraining Order, thereby providing notice and copies of
the April 14, 2021 Temporary Restraining Order and Plaintiff’s Ex Parte Application for Entry of
Temporary Restraining Order and Preliminary Injunction via e-mail to each Defendant’s
corresponding email/online contact form, or via e-mail to Defendant’s registrar of record, and by
posting copies of the Temporary Restraining Order and all other pleadings and documents on file
in this action on the website located at http://servingnotice.com/Ls37a2/index.html. Thereafter,
Certificates of Service were filed confirming service on each Defendant, ECF Nos. [14], [15], and
[16].
II.

LEGAL STANDARD
To obtain a preliminary injunction, a party must demonstrate “(1) 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).
III.

ANALYSIS
The declarations Plaintiff submitted in support of its Motion for Preliminary Injunction

support the following conclusions of law:

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A.

Plaintiff has 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 the Louis Vuitton Marks, and that
the products Defendants are selling and promoting for sale are copies of Plaintiff’s 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 preliminary injunction is not granted. It clearly appears from
the following specific facts, as set forth in Plaintiff’s Complaint, Motion for Preliminary
Injunction, and accompanying declarations on file, that immediate and irreparable loss, damage,
and injury will result to Plaintiff and to consumers because it is more likely true than not that:
1.

Defendants own or control Internet websites, domain names, or website

businesses which advertise, promote, offer for sale, and sell products bearing and/or using
counterfeit and infringing trademarks in violation of Plaintiff’s rights; and
2.

There is good cause to believe that more counterfeit and infringing products

bearing Plaintiff’s trademarks will appear in the marketplace; that consumers 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 and an unnatural erosion of the legitimate marketplace in
which it operates.
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 Plaintiff, its reputation, and its goodwill as a manufacturer and distributor of quality
products, if such relief is not issued.

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D.

The public interest favors issuance of the preliminary injunction to protect

Plaintiff’s trademark interests and protect the public from being defrauded by the palming off of
counterfeit goods as Plaintiff’s genuine goods.
CONCLUSION

IV.

Accordingly, it is ORDERED AND ADJUDGED that Plaintiff’s Motion, ECF No. [6],
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 enjoined and restrained, until further Order of this Court:
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
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 and/or using 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 Louis Vuitton 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 the Louis
Vuitton Marks or any confusingly similar trademarks, on or in connection with all Internet
websites, domain names, or businesses owned and operated, or controlled by them, including the
Internet websites operating under the Subject Domain Names;
(3)

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

distributors, and all persons in active concert or participation with any Defendant having notice of

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this Order shall immediately discontinue, until further Order of this Court, the use of 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), 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 websites registered, 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)

Each Defendant shall continue to preserve copies of all 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;
(6)

Upon Plaintiff’s request, the domain name registrar and/or privacy protection

service for any of the Subject Domain Names are ordered to disclose to Plaintiff the true identities
and contact information of the registrant of the Subject Domain Name;
(7)

The domain name registrars for the Subject Domain Names shall immediately, to

the extent not already done, assist in changing the registrar of record for the Subject Domain
Names, to a holding account with a registrar of Plaintiff’s choosing (the “New Registrar”),
excepting any such domain names which such registrars have been notified in writing by Plaintiff
have been or will be dismissed from this action, or as to which Plaintiff has withdrawn its request
to immediately transfer such domain names. 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

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of receipt of this Order, the top-level domain (TLD) registries, for the Subject Domain Names, or
their administrators, including backend registry operators or administrators, within five (5)
business days of receipt of this Order, shall change, or assist in changing, the registrar of record
for the Subject Domain Names to a holding account with the New Registrar, excepting any such
domain names which such registries have been notified in writing by Plaintiff have been or will
be dismissed from this action, or as to which Plaintiff has withdrawn its request to immediately
transfer such domain names. 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, or until further order of the Court. 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/Ls37a2/index.html whereon copies of the Complaint,
this Order, 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, this 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 by the New Registrar, preventing the
modification or deletion of the domains by the New Registrar or Defendants;
(8)

This Order shall apply to the Subject Domain Names, associated websites, and any

other domain names and websites which are being used by Defendants for the purpose of
counterfeiting the Louis Vuitton Marks at issue in this action and/or unfairly competing with Plaintiff

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Case No. 21-cv-60790-BLOOM/Valle

on the World Wide Web;
(9)

As a matter of law, this Order shall no longer apply to any Defendant or associated

domain name dismissed from this action, or as to which Plaintiff has withdrawn its request for a
preliminary injunction;
(10)

Pursuant to 15 U.S.C. § 1116(d)(5)(D) and Federal Rule of Civil Procedure 65(c),

Plaintiff shall maintain its 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; and
(11)

This Order shall remain in effect during the pendency of this action or until further

Order of this Court.
DONE AND ORDERED in Chambers at Miami, Florida, on April 27, 2021.

________________________________
BETH BLOOM
UNITED STATES DISTRICT JUDGE
Copies to:
Counsel of Record

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Case No. 21-cv-60790-BLOOM/Valle
SCHEDULE “A”
DEFENDANTS BY NUMBER AND SUBJECT DOMAIN NAME
Defendant
Number
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
23
23
23
23
23
24
25
26
27
28
29
30
31
32
33
34
35

Defendant / Domain Name
aaalvsale.com
bestlvbag.com
fakeslouisvuitton.com
gotlouisvuitton.com
louis-sa.com
louistore.ru
louisvuitton24.com
louisvuittonbagmall.com
louisvuittonboutique.vip
louisvuittoncity.com
louisvuittondeal.vip
louisvuittonfemme.com
louisvuittonhk.com
louisvuittonid.com
louisvuitton-id.com
louisvuittonid.shop
louisvuitton-id.shop
louisvuittonmalaysia.shop
louisvuittonmode.com
louisvuittonn.online
louisvuittonn.vip
louisvuitton-ph.com
louisvuittonph.shop
louisvuitton-ph.store
louisvuittons.today
louisvuittonsg.live
louisvuittonsg.world
louisvuittonshop.today
louisvuittonphpp.com
louisvuittonppi.com
louisvuittonpro.com
louisvuittonpurse.net
louisvuittonreplicabags.org
louisvuittons.shop
louisvuitton-sg.com
louisvuitton-sgp.com
louisvuittonshop.live
louisvuittonshopping.live
louisvuittonsolde.com
louisvuittonsuperdiscount.shop
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Case No. 21-cv-60790-BLOOM/Valle

36
37
38
39
40
41
42
43
43
43
43
43
43
43
43
43
43
43
43
43
43
43
43
43
43
43
43
43
43
43
43
43
43
43
43
43
43
43
43
43
43
43
43
43
43

louisvuittonter.com
louisvuittonv.vip
louisvuittonvillage.com
lvecv.com
lvluxurybags.xyz
replicalvsell.com
replicaslouisvuitton.com
luxoii.com
bage.icu
bag-shop.online
bagsshop.icu
batt.shop
bbfl.icu
blvck.icu
finnmilesluxuryhomes.icu
funko.icu
geox.icu
gopro.icu
grih.icu
jabra.icu
jjre.icu
kmart.icu
leasetoownluxuryhomes.icu
lopo.club
louisvuittons-milano.icu
louisvuittonsoutletonline.icu
luxurybag.icu
luxurybrandshop.icu
luxury-shop.xyz
luxury-shops.icu
luxuryskinshop.icu
luxury-style.icu
lv-online-shop.icu
maloneluxurymarketing.icu
martinluxuryhomes.icu
mavi.icu
mcmhi.icu
mmmz.icu
mmxl.icu
myluxury.club
mytheresa.xyz
newseasonbag.icu
omio.icu
qlly.icu
qlvse.icu
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Case No. 21-cv-60790-BLOOM/Valle

43
43
43
43
43
43
44
45
46
47
48
49
50
51
52
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81

shophandbag.top
shoppingbags.icu
tradesy.top
wkkj.icu
xmasgift.icu
yycx.icu
2020cokn.com
2020copy.com
acaxro.com
aeozv.com
ahandbags.com
aik-shop.com
alexcn.shop
alimorluxury.nl
angelbags.info
angelbags.pro
asibags.club
bagreplica.ru
bags-bag.net
bagsho.com
becomebag.com
brand-kingdom.com
brandsindustry.net
brendof-club.com
buildtote.com
byluxuryshopping.com
chinaluxurybag.com
closebags.com
collectbrand.com
copy432.com
copymm666.com
costbags.com
cozaka.com
crisandcoco.co
criticbags.com
cwen333.com
deathtote.com
dependbag.com
desgnrbrands.nl
discountretailbag.com
doubtbags.com
dresstote.com
ehinoh.com
ejfsbag.com
ekabags.club
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Case No. 21-cv-60790-BLOOM/Valle

82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100
101
102
103
104
105
106
106
107
108
108
108
109
110
111
112
113
114
115
116
117
118
119
120
121
122
123

elsebags.com
equaltote.com
exceptbags.com
exclusivekicks.co.uk
famebags.com
fasbags.com
fc888luxury.com
giybags.club
hacopy.com
handbagsonlinesales.com
happenbag.com
hebags.club
honbags.club
hubags.club
humanbags.com
idisad.com
igiwoc.com
ilebags.club
instockbags.com
istanbulbags.com
jwellis.ru
kjvips.com
labags.club
latterbag.com
lawobag.com
periclone.com
leibag.shop
lg4e62.vip
outaubags.com
qg5s63.vip
likelybag.com
likelybags.com
luiscanta.com
luxbag.ru
luxeborse.com
luxehandbageu.com
luxehandbagseu.com
lux-jp.com
luxmallac.com
luxurybagsi.com
luxurydrippers.online
luxury-dupes.com
mebbags.club
nasbags.club
ninki-111.com
19

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Case No. 21-cv-60790-BLOOM/Valle

124
125
126
127
128
129
130
131
132
133
134
135
136
137
138
139
140
141
142
143
144
145
146
147
147
147
147
147
148
148
149
150
151
152
153
154
154
154
155
156
157
158
159
160
161

noticebag.com
ogebags.club
onbags.club
otihop.com
outusbags.com
perfectfakehandbags.com
perfectkits.club
personbag.com
polbags.club
provebags.com
raisebags.com
replicabagselling.com
replicapursesshop.com
replicasbagsale.com
replicasbagshop.com
replybags.com
resbags.club
rwlbag.com
salecabag.com
saobag.com
sulbags.club
tihbags.club
toke333.com
top-qual.net
topqualm.com
xn--5-xz0gou.com
xn--6-xz0gou.com
xn--original-qk40bt8c.com
tracob.online
tracob.ru
tutbags.club
typebags.com
ulebags.club
underbags.com
usalbags.com
usaubags.com
usfsbags.com
xmwshjw.com
uscabags.com
usftbags.com
ushotbag.com
vogueaccent.com
voguebrands.net
vsnc333.com
wabagjp.net
20

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Case No. 21-cv-60790-BLOOM/Valle

162
163
164
165

wantmybags.com
weekbags.com
yayakopi.net
yourfashionoutlet.us

21