Multiple Documents Part Description 1 35 Pages 2 Exhibit a 3 Exhibit B 4 Exhibit C 5 Exhibit D 6 Exhibit E

Home , Gianni Versace, Greca (clothing), Versace

Gianni Versace S.r.l. v. FASHION NOVA, INC., a California corporation, Docket No. 2_19-cv-10074 (C.D. Cal. Nov 25, 2019), Court

Multiple Documents Part Description 1 35 pages 2 Exhibit A 3 Exhibit B 4 Exhibit C 5 Exhibit D 6 Exhibit E

1 KENDALL BRILL & KELLY LLP Bert H. Deixler (70614) 2 [email protected] Patrick J. Somers (318766) 3 [email protected] Amanda D. Barrow (313583) 4 [email protected] 10100 Santa Monica Blvd., Suite 1725 5 Los Angeles, California 90067 Telephone: 310.556.2700 6 Facsimile: 310.556.2705

7 PAUL, WEISS, RIFKIND, WHARTON & GARRISON LLP 8 Andrew Gordon (pro hac vice forthcoming) [email protected] 9 Lynn B. Bayard (pro hac vice forthcoming) [email protected] 10 Darren W. Johnson (pro hac vice forthcoming) [email protected] 11 1285 Avenue of the Americas New York, New York 10019 12 Telephone: 212.373.3000 Facsimile: 212.757.3990 13 Attorneys for Plaintiff 14 Gianni Versace S.r.l.

15 UNITED STATES DISTRICT COURT 16 CENTRAL DISTRICT OF CALIFORNIA, WESTERN DIVISION 17

18 GIANNI VERSACE S.R.L., Case No. 2:19-cv-10074 19 Plaintiff, COMPLAINT 20 v. 21 JURY TRIAL DEMAND FASHION NOVA, INC., 22 Defendant. 23 24 25 26 27 28

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1 Plaintiff Gianni Versace S.r.l. (“Versace”), by its attorneys Kendall Brill 2 & Kelly LLP and Paul, Weiss, Rifkind, Wharton & Garrison LLP, for its complaint 3 against Fashion Nova, Inc. (“Fashion Nova”), upon knowledge as to itself and its own 4 acts, and upon information and belief as to all other matters, alleges as follows. 5 Nature of the Action 6 1. This is an action for injunctive relief and damages to redress the 7 flagrant infringement of legendary fashion designer Versace’s iconic apparel—long 8 protected by copyright, trademark and trade dress—by Fashion Nova, a retailer and 9 serial infringer specializing in “fast-fashion” knock-offs. 10 2. Founded by Italian designer Gianni Versace in 1978, Versace is 11 one of the most recognized and influential fashion brands in the world. Versace 12 designs, manufactures, markets, distributes and sells a wide variety of luxury 13 products, including Haute Couture and ready-to-wear apparel, which are renowned 14 for their high quality and style, and are identified and recognized by the use of 15 copyrighted designs, and distinctive trademarks and trade dress (the “Versace 16 Apparel”). Examples of the Versace Apparel are depicted below: 17 18 19 20 21 22 23 24 25 26

27 28

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1 3. The Versace Apparel has become enormously popular, driven by 2 the brand’s arduous quality standards, innovative design, widespread marketing and 3 large international following. For example, the green “Jungle Pattern” dress 4 depicted above, which famously was worn by Jennifer Lopez at the 42nd Annual 5 Grammy Awards, was identified as one of the “most iconic dresses of all time” in a 6 2008 poll of consumers. Similarly, the black and gold “Barocco - 57” design 7 depicted above is among the most well-known designs in the fashion world, and 8 instantly recognizable by consumers as signature Versace. 9 4. Without Versace’s license or consent, and indeed with full 10 knowledge and willful disregard of Versace’s rights, Fashion Nova has 11 manufactured, marketed and sold apparel using the same or substantially similar 12 copyrighted designs and confusingly similar trademarks and trade dress (the 13 “Infringing Apparel”). Fashion Nova’s Infringing Apparel is plainly a deliberate 14 effort to exploit the popularity and renown of Versace’s signature designs, and to 15 trade on Versace’s valuable goodwill and business reputation in order to drive 16 profits and sales to line Fashion Nova’s pockets. Examples of the Infringing 17 Apparel are depicted below: 18 19 20 21 22 23 24 25 26 27

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1 5. The Infringing Apparel deliberately copies and imitates 2 Versace’s most famous and recognizable designs, marks, symbols and other 3 protected elements in violation of Versace’s exclusive registered copyrights, and in 4 a manner that is likely to cause maximum consumer confusion and deceive the 5 public regarding the Infringing Apparel’s source, sponsorship or affiliation. Fashion 6 Nova’s unlawful acts are irreparably harming Versace’s brand and its extremely 7 valuable goodwill among consumers. 8 6. Nor is this Fashion Nova’s first foray into infringements of 9 fashion designs. Since its launch in 2013, it has been sued at least eight times by 10 other designers (such as Adidas) for the same type of copyright and trademark 11 infringement as Versace asserts here. With this lawsuit, Versace seeks to bring an 12 end to Fashion Nova’s latest brazen attempt at copying the work of yet another 13 famous and world-renowned designer. 14 7. Versace therefore brings this action for copyright infringement, 15 trademark infringement and trade dress infringement, among other claims, to 16 immediately halt Fashion Nova’s unlawful conduct and redress Versace’s rights. 17 Jurisdiction and Venue 18 8. This action arises under the Copyright Act, 17 U.S.C. §§ 101 et 19 seq., and the Lanham Act, 15 U.S.C. §§ 1051 et seq. This Court’s jurisdiction is 20 based upon 17 U.S.C. §§ 101 et seq. and 28 U.S.C. §§ 1121, 1331 and 1338. 21 9. This Court has subject matter jurisdiction over the common and 22 state law claims under 28 U.S.C. § 1332 because a complete diversity of citizenship 23 exists between the parties, citizens of California and Italy, and the amount in 24 controversy exceeds $75,000. This Court also has subject matter jurisdiction over 25 the common and state law claims under 28 U.S.C § 1367 because they are so closely 26 related to the Copyright Act and Lanham Act claims that they form part of the same 27 case of controversy under Article III of the United States Constitution. 28

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1 10. This Court has personal jurisdiction over Fashion Nova because 2 a substantial part of the unlawful acts giving rise to the claims occurred and 3 continues to occur in this District, and because defendant Fashion Nova can be 4 found in this District. 5 11. Venue is proper in this District pursuant to 28 U.S.C. §§ 1391(b) 6 and (c), and 1400(a) because a substantial part of the unlawful acts giving rise to the 7 claims occurred and continues to occur in this District, and because defendant 8 Fashion Nova can be found in this District. 9 The Parties 10 12. Plaintiff Versace is a company organized and existing under the 11 laws of Italy, with its principal place of business at Piazza Einaudi No. 4 – 20124 12 Milan, Italy. Versace Apparel is distributed and sold to consumers throughout the 13 United States through Versace boutiques and luxury-brand retailers, including 14 through Versace’s own retail stores in this District, and authorized retailers in this 15 District such as Nordstrom, Bloomingdale’s and Saks Fifth Avenue, and through the 16 versace.com website. 17 13. Defendant Fashion Nova is a corporation organized and existing 18 under the laws of California, with its principal place of business at 2801 East 46th 19 Street, Vernon, California 90058. Upon information and belief, Fashion Nova 20 markets, distributes, offers for sale and sells its Infringing Apparel throughout the 21 United States, through its fashionnova.com website, including in this District, as 22 well as through retail stores in this District. 23 The Facts 24 Versace’s Iconic Copyrights, Trademarks and Trade Dress 25 14. Versace was founded by Italian fashion designer Gianni Versace 26 in 1978, and expanded under the creative leadership of Donatella Versace beginning 27 28

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1 in 1997, to become one of the most recognizable and sought-after fashion brands in 2 the world. 3 15. Versace Apparel has been worn by royalty, including Princess 4 Diana of Wales and Princess Caroline of Monaco, famous musicians, including 5 Elton John and Lady Gaga, and the biggest stars in Hollywood, including Jennifer 6 Lopez and Elizabeth Hurley. Versace Apparel also is the subject of a 2017 hit song 7 and music video by Bruno Mars entitled “Versace on the Floor” (see 8 https://en.wikipedia.org/wiki/Versace_on_the_Floor). 9 16. Versace is renowned for blending art and fashion, including 10 through its creation of bold and colorful prints and decorative design elements, 11 which consumers immediately recognize and associate with Versace. As a result of 12 Versace’s creative vision and artistry, Versace Apparel has been exhibited in 13 prestigious museums around the world, including the Metropolitan Museum of Art 14 in New York, the Victoria & Albert Museum in London, and the Musée de la Mode 15 in Paris. 16 Versace’s Copyrighted Designs 17 17. Many of the most iconic decorative and artistic designs presented 18 on Versace Apparel are original works protected under the United States Copyright 19 Act (collectively, the “Versace Copyrights”). 20 18. For example, Versace owns a valid copyright registered with the 21 Copyright Office for its “Barocco - 57” design, with Registration No. VA 2-176-201 22 (Exhibit A), which is depicted below, along with an example of Versace Apparel 23 bearing the Barocco - 57 copyrighted design: 24 25 26 27 28

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1 2 3 4 5 6 7

8 9 19. Versace also owns a valid copyright registered with the 10 Copyright Office for its “Pop Hearts” design, with Registration No. VA 2-173-519 11 (Exhibit B), which is depicted below, along with an example of Versace Apparel 12 bearing the Pop Hearts copyrighted design: 13

14 15 16 17 18 19 20

21 20. Versace also owns a valid copyright registered with the 22 Copyright Office for its “Jungle Print” design, with Registration No. VA 2-175-854 23 (Exhibit C), which is depicted below, along with an example of Versace Apparel 24 bearing the Jungle Print copyrighted design: 25

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1 2 3 4 5 6

7 8 9 10 11 21. At all times relevant, Versace has been the owner of all right, 12 title and interest in and to the “Barocco - 57,” “Pop Hearts” and “Jungle Print” 13 copyrighted works used on Versace Apparel, and such copyrights are valid and in 14 full force and effect. As the owner of the above copyrighted works, Versace has the 15 sole and exclusive right to reproduce and distribute them, in whole or in part, and to 16 create derivative works using them. 17 Versace’s Distinctive Trademarks 18 22. Versace also owns numerous distinctive trademarks that have 19 come to symbolize the high quality of Versace Apparel in the minds of consumers, 20 including the VERSACE and GIANNI VERSACE word marks (together, the 21 “Versace Word Marks”), which Versace has continuously used in connection with 22 the sale of Versace Apparel in the United States since at least as early as 1994. In 23 addition to the Versace Word Marks, for many years, Versace has used several 24 distinctive and well-known classical design marks, including “Medusa Head” 25 designs and “Greca” designs (collectively, the “Versace Design Marks,” and 26 together with the Versace Word Marks, the “Versace Trademarks”). Versace 27 28

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1 Apparel typically includes one or more of the Versace Trademarks to signify to 2 consumers that Versace is the source of the Versace Apparel. 3 23. Many of the Versace Trademarks are registered with the United 4 States Patent and Trademark Office. A non-exclusive list of the registered Versace 5 Trademarks is included below: 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

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1 Registration Trademark 2 Number

3 4,398,385 VERSACE (word mark) 4 4,626,622 5 1,875,093 (Medusa Head & Greca Design) 6 7 8

9 2,980,455 (Medusa Head Design) 10 11 12 13 14 15 3,194,501 (Greca Design)

16 17 3,199,127 (Greca Circle Design) 18 19 20 21

22 3,453,992 (Greca Element Design) 23 24 25 26 27 24. The above U.S. registrations for the Versace Trademarks are 28 valid, subsisting, in full force and effect, and many are incontestable pursuant to 15

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1 U.S.C. § 1065. The registrations for the Versace Trademarks constitute prima facie 2 evidence of their validity and of Versace’s exclusive right to use the Versace 3 Trademark. True and correct copies of the United States Registration Certificates 4 for the above-listed Versace Trademarks are attached as Exhibit D. 5 25. In addition to the U.S. registered trademarks depicted above, the 6 Versace Trademarks also include foreign registered trademarks and U.S. common law 7 trademark rights with respect to certain word marks and design marks, including: 8 Jurisdiction Registration Number Trademark 9

10 European Union 11,566,825 11 12 13

14 26. The Versace Trademarks signify to consumers that the apparel 15 bearing them was designed by Versace and is manufactured to Versace’s high 16 quality standards. Whether Versace manufactures the apparel itself or contracts 17 with others to do so, Versace exercises strict quality control to ensure that all 18 apparel bearing the Versace Trademarks is manufactured to the highest quality 19 standards. 20 27. The Versace Trademarks are famous marks, as that term is used 21 in 15 U.S.C. § 1125(c)(1) and California Business and Professions Code § 14247, 22 and have been continuously used and never abandoned. The innovative marketing 23 and product designs of Versace Apparel have enabled the Versace brand to achieve 24 widespread recognition and fame. In addition, Versace has expended substantial 25 time, money and other resources in advertising and promoting the Versace 26 Trademarks, and Versace Apparel has been the subject of extensive unsolicited 27 publicity resulting from their high-quality, innovative designs, including news 28

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1 stories touting the Versace Apparel as iconic. As a result, apparel bearing the 2 Versace Trademarks is exclusively associated by consumers, the public, and the 3 trade as being high-quality apparel sourced from Versace. Versace Apparel has 4 become among the most popular of its kind in the U.S. and the world, and the 5 Versace Trademarks have achieved tremendous fame and recognition with its 6 consumers. As such, the goodwill associated with the Versace Trademarks is of 7 incalculable and inestimable value to Versace. 8 Versace’s Distinctive Trade Dress 9 28. Versace also is the owner of a variety of unique and distinctive 10 trade dresses consisting of a combination of one or more features, including shapes, 11 colors, designs, fabrics and other non-functional elements comprising the overall 12 look and feel that are original and unique to Versace Apparel (the “Versace Trade 13 Dresses”). 14 29. One of the most famous examples of the Versace Trade Dresses 15 is the iconic green Versace dress worn by Jennifer Lopez to the 2000 Grammy 16 Awards, which has been recognized as one of the most iconic dresses of all-time, 17 and is the subject of its own Wikipedia entry (https://en.wikipedia.org/wiki/ 18 Green_Versace_dress_of_Jennifer_Lopez). This iconic dress, which is often 19 referred to as the “Jungle Dress,” is depicted below:

20 21 22 23 24 25 26 27 28

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1 2 3 4 5 6 7 8 9 10

11 30. The Jungle Dress consists of a distinctive combination of 12 elements that together constitute Versace’s protectable trade dress, including its 13 green tropical leaf and bamboo pattern, its plunging neckline extending to the navel, 14 its high cut leg slit, a circular brooch at the waist where the plunging neckline and 15 high cut leg slit meet, and long, flowing sleeves (the “Jungle Trade Dress”). 16 31. Another famous example of the Versace Trade Dresses is the 17 iconic Versace baroque-style print, consisting of bold, classical motifs inspired by 18 Italian frescos, including curling floral imagery, gold chains, Medusa heads and 19 leopard skins, typically printed in black and gold on shiny silk (the “Baroque Trade 20 Dress”). The Baroque Trade Dress has been described as “the essence” of the 21 classic Versace look. See https://www.thefader.com/2011/10/20/anatomy-of-a- 22 trend-versaces-baroque-print. An example of the Baroque Trade Dress is depicted 23 below: 24 25 26 27 28

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1 2 3 4 5 6 7 8 9 10 11 12 13 32. For many years, the Versace Trade Dresses have been 14 extensively marketed throughout the United States online, on television, and in 15 print, and Versace has spent millions of dollars in advertising and promoting the 16 Versace Trade Dresses using the Versace brand name. 17 33. As a result, consumers immediately identify Versace as the 18 single source of high quality apparel bearing the Versace Trade Dresses, including 19 the Jungle Trade Dress and the Baroque Trade Dress. 20 Fashion Nova’s Acts of Infringement 21 34. Fashion Nova was founded in 2006 as a chain of stores in Los 22 Angeles-area malls selling low-price “clubwear.” In 2013, Fashion Nova launched 23 an e-commerce site (fashionnova.com) to sell so-called “fast-fashion”—inexpensive 24 clothing produced rapidly by mass-market retailers in response to the latest original 25 fashion trends. Fashion Nova’s ability to churn out new clothing so quickly is due 26 in large part to its willingness to copy the copyrighted designs, trademarks and trade 27 dress elements of well-known designers such as Versace, and trade on their creative 28 efforts in order to bolster Fashion Nova’s bottom line.

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1 35. To that end, in blatant disregard of Versace’s rights, Fashion 2 Nova is designing, manufacturing, producing, marketing, distributing, promoting, 3 offering for sale and selling in interstate commerce apparel bearing designs that are 4 the same or substantially similar to the Versace Copyrights, and apparel that 5 includes the Versace Trademarks or words, symbols, designs and other elements 6 that are confusingly similar to the Versace Trademarks and Trade Dress. 7 36. Examples of Fashion Nova’s Infringing Apparel are depicted on 8 the following pages, which Infringing Apparel is substantially and confusingly 9 similar to the Versace Copyrights, Trademarks and Trade Dresses. Additional 10 examples (by way of illustration and not limitation) of Fashion Nova’s Infringing 11 Apparel are attached as Exhibit E. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

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1 Fashion Nova Dress Versace Dress

2 3 4 5 6 7 8 9

10 Infringing Designs Versace IP Infringed 11

13 14 Barocco - 57 Copyright U.S. Reg. No. VA 2-176-201 15 (detail) 16 17 18 Barocco - 57 Copyright 19 U.S. Reg. No. VA 2-176-201

20 (detail) 21 22 Greca Design Trademark 23 U.S. Reg. No. 3,194,501 24

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1 Fashion Nova Dress Versace Dress 2 3 4 5 6 7 8 9 10 11

12 Infringing Design Versace IP Infringed 13

14 15 Greca Design Trademark 16 U.S. Reg. No. 3,194,501 17 18 19

20 Greca Circle Design Trademark

21 U.S. Reg. No. 3,199,127 22

23 24 25 26 27 28

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1 Fashion Nova Dress Versace Dress 2 3 4 5 6 7 8 9 10 11 Infringing Design Versace IP Infringed 12 13 14 15 16 Pop Hearts Copyright 17 U.S. Reg. No. VA 2-173-519 18 (detail) 19 20 21 22 23 24 25 26 27 28

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1 Fashion Nova Dresses Versace Dress 2

3 4 5 6 7 8 9 10 11 12 13 14 15

16 17 18 19 Infringing Designs Versace IP Infringed 20

21 22

23 Jungle Print Copyright 24 U.S. Reg. No. VA 2-175-854

25 26 27 28

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1 Infringing Fashion Nova Dress Original Versace Jungle Dress 2 3 4 5 6 7 8 9 10 11 12 13

14 15 Versace Trade Dress Elements Infringing Design Elements 16 Infringed 17  Green tropical leaf and  Green tropical leaf and 18 bamboo pattern bamboo pattern 19  Plunging neckline extending to  Plunging neckline extending to 20 the navel the navel 21  High-cut leg slit  High-cut leg slit 22  Circular brooch where the  Circular brooch where the 23 plunging neckline meets the plunging neckline meets the 24 high-cut leg slit high-cut leg slit 25  Long, flowing sleeves  Long, flowing sleeves 26 27 28

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1 37. The Infringing Apparel designed, manufactured, produced, 2 distributed, marketed, promoted, offered for sale and sold by Fashion Nova is not 3 manufactured by Versace. 4 38. Nor is Fashion Nova associated, affiliated or connected with 5 Versace, or licensed, authorized, sponsored, endorsed or approved by Versace in 6 any way. 7 39. Versace created and used the Versace Copyrights, Trademarks 8 and Trade Dresses extensively and continuously in connection with Versace Apparel 9 long before Fashion Nova began distributing, marketing, promoting, offering for 10 sale or selling the Infringing Apparel. 11 40. Fashion Nova’s use of designs that are substantially similar to 12 the Versace Copyrights violates Versace’s exclusive registered copyrights. 13 41. Fashion Nova’s use of words, symbols, designs and other 14 elements that are confusingly similar to the Versace Trademarks and Trade Dress 15 violates Versace’s registered trademarks and trade dress. 16 42. Telling of the willfulness of Fashion Nova’s infringing conduct, 17 Fashion Nova also deceives unknowing consumers by using the Versace 18 Trademarks without authorization within the content, text and/or meta tags of its 19 website in order to attract various search engines crawling the Internet looking for 20 websites relevant to consumer searches for Versace Apparel. Moreover, Fashion 21 Nova uses other unauthorized search engine optimization tactics and/or social media 22 spamming so that Fashion Nova webpages show up at or near the top of relevant 23 search results and misdirect consumers searching for Versace Apparel. 24 43. Fashion Nova’s use of identical and/or confusingly similar 25 imitations of the Versace Trademarks and Trade Dress is likely to deceive, confuse 26 and mislead actual and prospective purchasers before, during and after purchase into 27 28

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1 believing that the Infringing Apparel is manufactured or authorized by, or in some 2 manner associated with, Versace, which it is not. 3 44. The likelihood of confusion, mistake and deception engendered 4 by Fashion Nova’s misappropriation of the Versace Trademarks and Trade Dress is 5 causing irreparable harm to the goodwill symbolized by the Versace Trademarks 6 and Trade Dress and the reputation for quality that they embody. 7 45. Fashion Nova has engaged in the above-described infringing 8 activities knowingly and intentionally, or with reckless disregard or willful 9 blindness to Versace’s rights, or with bad faith, for the purpose of trading on the 10 goodwill and reputation of the Versace Trademarks and Trade Dresses. 11 46. Versace objected to Fashion Nova’s infringing activities on 12 multiple occasions before filing this lawsuit, including on or about July 26, 2019, 13 September 20, 2019, October 1, 2019 and November 13, 2019. 14 47. Notwithstanding Versace’s objections, Fashion Nova continues 15 to use designs that are substantially similar to the Versace Copyrights, and 16 confusingly similar to the Versace Trademarks and Trade Dresses, in violation of 17 Versace’s exclusive registered copyrights, registered trademarks, common law 18 trademarks, and distinctive trade dresses. 19 Versace’s Injury 20 48. As a direct and proximate result of Fashion Nova’s infringing 21 conduct, Versace has been substantially damaged in, among other ways, the 22 infringement of the Versace Copyrights and the deprivation of Versace’s exclusive 23 right to control the manner of use of its Versace Copyrights. 24 49. As a result of Fashion Nova’s misuse of the Versace Copyrights, 25 Fashion Nova has caused, and will continue to cause, irreparable injury to Versace 26 and has damaged the value of the Versace Copyrights. 27 28

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1 50. In addition, Fashion Nova has enriched itself at Versace’s 2 expense by its commercial exploitation of the Versace Copyrights without Versace’s 3 consent and without any compensation to Versace. 4 51. Further, as a direct and proximate result of Fashion Nova’s 5 misuse of the Versace Trademarks and Trade Dresses, consumers are likely to be 6 confused and deceived into believing that a connection or association exists between 7 Versace and Fashion Nova, when there is none, causing additional injury to 8 Versace, and the reputation and goodwill of the Versace Trademarks and Trade 9 Dress. 10 52. Fashion Nova’s misuse of the Versace Trademarks and Trade 11 Dresses also dilutes the distinctiveness of the Versace Trademarks and Trade 12 Dresses by eroding the public’s exclusive identification of these famous trademarks 13 and trade dresses with Versace, tarnishing and degrading the positive associations 14 and prestigious connotations of these famous trademarks and trade dresses, and 15 otherwise lessening the capacity of the Versace Trademarks and Trade Dresses to 16 identify and distinguish Versace Apparel. 17 53. In addition, Fashion Nova has enriched itself at Versace’s 18 expense by its commercial exploitation of the Versace Trademarks and Trade 19 Dresses without Versace’s consent and without any compensation to Versace. 20 FIRST CLAIM 21 (Copyright Infringement Under the Copyright Act, 17 U.S.C. § 501) 22 54. Versace repeats and realleges the allegations in paragraphs 1 23 through 52. 24 55. As set forth above, the Versace Copyrights are valid and owned 25 by Versace, and have been registered with the U.S. Copyright Office. 26 56. Fashion Nova, without the permission or consent of Versace, has 27 designed, manufactured, produced, distributed, marketed, promoted, offered for sale 28

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1 and sold the Infringing Apparel, which is substantially similar to the Versace 2 Copyrights. 3 57. By reason of the foregoing, Fashion Nova has infringed, and 4 continues to infringe, the Versace Copyrights in violation of, without limitation, the 5 exclusive rights of reproduction and distribution and the exclusive right to prepare 6 derivative works under section 106 of the Copyright Act, and section 501 of the 7 Copyright Act. 8 58. Fashion Nova’s infringement of the Versace Copyrights has been 9 and continues to be intentional, willful and with full knowledge of Versace’s rights. 10 59. As a direct and proximate result of its infringing conduct, 11 Fashion Nova has made and will continue to make substantial profits and gains to 12 which it is not entitled. 13 60. As a direct and proximate result of Fashion Nova’s conduct, 14 Versace has suffered and will continue to suffer irreparable harm, for which it has 15 no adequate remedy at law. 16 61. As a direct and proximate result of Fashion Nova’s conduct, 17 Versace is entitled to actual damages and Fashion Nova’s profits pursuant to 17 18 U.S.C. § 504(b) attributable to Fashion Nova’s infringement. 19 62. Alternatively, Versace is entitled to the maximum statutory 20 damages, pursuant to 17 U.S.C. § 504(c), and such other amounts as may be proper 21 under 17 U.S.C. § 504(c). 22 63. Versace is further entitled to its attorneys’ fees and full costs 23 pursuant to 17 U.S.C. § 505. 24 25 26 27 28

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1 SECOND CLAIM 2 (Trademark Infringement Under 3 Section 32 of the Lanham Act, 15 U.S.C. § 1114(1)) 4 64. Versace repeats and realleges the allegations in paragraphs 1 5 through 62. 6 65. The Versace Trademarks are owned by Versace, and are valid 7 and subsisting. 8 66. Upon information and belief, Fashion Nova has used, is using, 9 and/or imminently intends to use the Versace Trademarks, or words and symbols 10 that are confusingly similar to the Versace Trademarks, in interstate commerce, 11 without the consent of Versace, in connection with the sale of goods and/or in 12 connection with the advertising and promotion of such goods. 13 67. Fashion Nova’s conduct as alleged above constitutes the 14 unauthorized use in interstate commerce in the United States of the Versace 15 Trademarks in connection with the sale, offering for sale, distribution, or advertising 16 of its products, and has caused and/or is likely to cause confusion or mistake or 17 deception of the public as to (i) the affiliation, connection, and/or association of 18 Versace with Fashion Nova and the Infringing Apparel; (ii) the origin of the 19 Infringing Apparel; and/or (iii) the sponsorship, endorsement, or approval of the 20 Infringing Apparel by Versace, in each case a violation of Section 32 of the Lanham 21 Act, 15 U.S.C. § 1114(1). 22 68. Upon information and belief, Fashion Nova’s actions were 23 deliberate, willful, and in conscious disregard of Versace’s superior rights in its 24 registered Versace Trademarks. 25 69. As a result of Fashion Nova’s conduct, Versace has suffered 26 irreparable harm to its Versace Trademarks, reputation and goodwill, for which it 27 28

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1 has no adequate remedy at law, and will continue to suffer irreparable injury unless 2 and until Fashion Nova’s infringing acts are enjoined by this Court. 3 70. Pursuant to 15 U.S.C. §§ 1116-1117, Versace is entitled to 4 injunctive relief, actual damages in an amount to be determined at trial, to have such 5 damages trebled, to Fashion Nova’s profits, and to the costs of this action and to 6 attorneys’ fees. 7 THIRD CLAIM 8 (Trade Dress Infringement Under 9 Section 43(a) of the Lanham Act, 15 U.S.C. § 1125(a)) 10 71. Versace repeats and realleges the allegations in paragraphs 1 11 through 69. 12 72. The Versace Trade Dresses are nonfunctional and their 13 inherently distinctive quality has achieved a high degree of consumer recognition 14 and serves to identify Versace as the source of high quality goods. 15 73. Upon information and belief, Fashion Nova has used, is using, 16 and/or imminently intends to use shapes, colors, designs, fabrics and other non- 17 functional elements that are identical and/or confusingly similar to the Versace 18 Trade Dresses without the consent of Versace, on Fashion Nova’s products or in 19 connection with the advertising and promotion of such goods. 20 74. Upon information and belief, Fashion Nova’s actions were 21 deliberate, willful, and in conscious disregard of Versace’s superior rights in its 22 Versace Trade Dresses. 23 75. Fashion Nova’s conduct as alleged above constitutes the 24 unauthorized use in commerce of the Versace Trade Dresses in connection with the 25 Infringing Apparel and has caused and/or is likely to cause confusion, mistake, or 26 deception of the public as to (i) the affiliation, connection, and/or association of 27 Versace with Fashion Nova and the Infringing Apparel; (ii) the origin of the 28

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1 Infringing Apparel; and/or (iii) the sponsorship, endorsement, or approval of the 2 Infringing Apparel by Versace, in each case in violation of Section 43(a) of the 3 Lanham Act, 15 U.S.C. § 1125(a). 4 76. As a result of Fashion Nova’s conduct, Versace has suffered 5 irreparable harm to its Versace Trade Dresses, reputation and goodwill, for which it 6 has no adequate remedy at law, and will continue to suffer irreparable injury unless 7 and until Fashion Nova’s infringing acts are enjoined by this Court. 8 77. Pursuant to 15 U.S.C. §§ 1116-1117, Versace is entitled to 9 injunctive relief, actual damages in an amount to be determined at trial, to have such 10 damages trebled, to Fashion Nova’s profits, and to the costs of this action and to 11 attorneys’ fees. 12 FOURTH CLAIM 13 (Unfair Competition and False Designation of Origin 14 Under Section 43(a) of the Lanham Act, 15 U.S.C. § 1125(a)) 15 78. Versace repeats and realleges the allegations in paragraphs 1 16 through 76. 17 79. In addition to the registered Versace Trademarks, Versace owns 18 valuable common law trademark rights in the Versace Trademarks, which, by virtue 19 of their use by Versace, in connection with the promotion and sale of goods and 20 services, has gained widespread consumer recognition, and has developed valuable 21 goodwill associated therewith. 22 80. Upon information and belief, Fashion Nova has used, is using, 23 and/or imminently intends to use the Versace Trademarks in interstate commerce, 24 without the consent of Versace, to identify Fashion Nova’s goods and/or in 25 connection with the advertising and promotion of such goods. 26 81. Fashion Nova’s conduct as alleged above constitutes the 27 unauthorized use in commerce of the Versace Trademarks in connection with the 28

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1 Infringing Apparel and has caused and/or is likely to cause confusion, mistake, or 2 deception of the public as to (i) the affiliation, connection, and/or association of 3 Versace with Fashion Nova and the Infringing Apparel; (ii) the origin of the 4 Infringing Apparel; and/or (iii) the sponsorship, endorsement, or approval of the 5 Infringing Apparel by Versace, in each case in violation of Section 43(a) of the 6 Lanham Act, 15 U.S.C. § 1125(a). 7 82. Upon information and belief, Fashion Nova’s actions were 8 deliberate, willful, and in conscious disregard of Versace’s rights. 9 83. Fashion Nova’s conduct as alleged above has caused and/or will 10 cause Versace to suffer injury, for which it has no adequate remedy at law. 11 84. Pursuant to 15 U.S.C. §§ 1116-1117, Versace is entitled to 12 injunctive relief, actual damages in an amount to be determined at trial, to have such 13 damages trebled, to Fashion Nova’s profits, and to the costs of this action and to 14 attorneys’ fees. 15 FIFTH CLAIM 16 (Dilution Under Section 43(c) of the Lanham Act, 15 U.S.C. § 1125(c)) 17 85. Versace repeats and realleges the allegations in paragraphs 1 18 through 83. 19 86. The Versace Trade Dresses and Versace Trademarks are famous 20 and distinctive within the meaning of Section 43(c) of the Lanham Act, 15 U.S.C. 21 § 1125(c), and Versace has built up valuable goodwill in the Versace Trade Dresses 22 and Versace Trademarks. The Versace Trade Dresses and Versace Trademarks 23 have enjoyed such distinction and fame since long before Fashion Nova commenced 24 unauthorized use of the Versace Trade Dresses and Versace Trademarks. 25 87. Upon information and belief, Fashion Nova has used, is using, 26 and/or intends to use the Versace Trade Dresses and Versace Trademarks in 27 28

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1 interstate commerce in connection with the advertising and promotion of goods and 2 services sold or offered by Fashion Nova. 3 88. Fashion Nova’s use of the Versace Trade Dresses and Versace 4 Trademarks has caused actual harm and is likely to cause harm to Versace by 5 diluting and weakening the unique and distinctive significance and quality of the 6 Versace Trade Dresses and Versace Trademarks to identify Versace’s goods and 7 services and by tarnishing the Versace Trade Dresses and Versace Trademarks in 8 the minds of consumers. 9 89. By reason of the foregoing, Fashion Nova has violated Section 10 43(c) of the Lanham Act, 15 U.S.C. § 1125(c). 11 90. Upon information and belief, Fashion Nova’s actions were 12 deliberate, willful, and in conscious disregard of Versace’s rights. 13 91. Fashion Nova’s conduct as alleged above has caused and/or will 14 cause Versace to suffer injury, for which it has no adequate remedy at law. 15 92. Pursuant to 15 U.S.C. §§ 1116-1117, Versace is entitled to 16 injunctive relief, actual damages in an amount to be determined at trial, to have such 17 damages trebled, to Fashion Nova’s profits, to the costs of this action, and to 18 attorneys’ fees. 19 SIXTH CLAIM 20 (Common Law Trademark Infringement) 21 93. Versace repeats and realleges the allegations in paragraphs 1 22 through 91. 23 94. Fashion Nova’s conduct as alleged above constitutes 24 infringement and misappropriation of the Versace Trademarks in violation of 25 Versace’s rights under common law and in equity. 26 95. Upon information and belief, Fashion Nova’s actions were 27 deliberate, willful, and in conscious disregard of Versace’s rights. 28

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1 96. Fashion Nova’s conduct as alleged above has caused and/or will 2 cause Versace to suffer injury, for which it has no adequate remedy at law. 3 97. Versace is entitled to injunctive relief, actual damages in an 4 amount to be determined at trial, to have such damages trebled, to Fashion Nova’s 5 profits, to the costs of this action, and to attorneys’ fees. 6 SEVENTH CLAIM 7 (Common Law Unfair Competition) 8 98. Versace repeats and realleges the allegations in paragraphs 1 9 through 96. 10 99. Upon information and belief, by using the Versace Trade Dresses 11 and Versace Trademarks in commerce without authorization by Versace, Fashion 12 Nova knowingly and willfully is confusing consumers by creating the false and 13 misleading impression that Fashion Nova and its Infringing Apparel are related to, 14 affiliated with, or connected with Versace. 15 100. Upon information and belief, Fashion Nova’s deliberate use of 16 the Versace Trade Dresses and Versace Trademarks in connection with the 17 marketing, advertising, promotion, and/or distribution of its Infringing Apparel was 18 done in bad faith with the intent to unfairly benefit from the expense, time, effort 19 and labor expended by Versace in developing and promoting the Versace Trade 20 Dresses and Versace Trademarks. 21 101. By reason of the foregoing, Fashion Nova’s conduct constitutes 22 willful and deliberate false designation of origin, false description and 23 representation, and unfair competition, in violation of Versace’s rights under 24 common law and in equity. 25 102. Upon information and belief, Fashion Nova’s actions were 26 deliberate, willful, and in conscious disregard of Versace’s rights. 27 28

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1 103. Fashion Nova’s conduct as alleged above has caused and/or will 2 cause Versace to suffer injury, for which it has no adequate remedy at law. Versace 3 is entitled to injunctive relief, actual damages in an amount to be determined at trial, 4 and to Fashion Nova’s profits attributable to its unlawful conduct. 5 EIGHTH CLAIM 6 (Dilution in Violation of Cal. & Bus. Prof. Code § 14247) 7 104. Versace repeats and realleges the allegations in paragraphs 1 8 through 102. 9 105. The Versace Trademarks and Trade Dresses are famous and 10 distinctive in the State of California, and Versace has built up valuable goodwill in 11 the Versace Trademarks and Trade Dresses. The Versace Trademarks and Trade 12 Dresses have enjoyed widespread publicity and recognition in the State of California 13 since long before Fashion Nova commenced use of the Versace Trademarks and 14 Trade Dresses. 15 106. Upon information and belief, Defendants have used, are using, 16 and/or intend to use the Versace Trademarks and Trade Dresses in commerce in 17 connection with the advertising and promotion of goods and services sold or offered 18 for sale by Fashion Nova in the State of California. 19 107. Fashion Nova’s use of the Versace Trademarks and Trade 20 Dresses has caused actual harm and is likely to cause harm to Versace by diluting 21 and weakening the unique and distinctive significance and quality of the Versace 22 Trademarks and Trade Dresses to identify the Versace Apparel and by tarnishing 23 Versace’s name, and the Versace Trademarks and Trade Dresses, in the minds of 24 consumers in the State of California. 25 108. By reason of the foregoing, Versace is being damaged by the 26 unauthorized and illegal use of the Versace Trademarks and Trade Dresses in the 27 manner set forth above, and will continue to be damaged unless Fashion Nova is 28

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1 immediately enjoined under Section 14247 of the California Business and 2 Professions Code from using any of the Versace Trademarks or Trade Dress. 3 NINTH CLAIM 4 (Unfair Competition Under California Unfair Business Practices Act, 5 Cal. & Bus. Prof. Code §§ 17200 et seq.) 6 109. Versace repeats and realleges the allegations in paragraphs 1 7 through 107. 8 110. Upon information and belief, by using the Versace Trademarks 9 and Trade Dresses in commerce without authorization by Versace, Fashion Nova 10 knowingly and willfully is confusing consumers by creating the false and 11 misleading impression that Fashion Nova and its Infringing Apparel are related to, 12 affiliated with, or connected with Versace. 13 111. Fashion Nova’s deliberate use of the Versace Trademarks and 14 Trade Dresses in connection with the marketing, advertising, promotion, and/or 15 distribution of its Infringing Apparel was done in bad faith with the intent to unfairly 16 benefit from the expense, time, effort and labor expended by Versace in developing 17 and promoting the Versace Trademarks and Trade Dresses. 18 112. By reason of the foregoing, Fashion Nova’s conduct constitutes a 19 violation of the California Unfair Business Practices Act, Cal. Bus. & Prof. Code, 20 §§ 17200 et seq. 21 113. Fashion Nova’s actions were deliberate, willful, and in conscious 22 disregard of Versace’s rights. 23 114. Fashion Nova’s conduct as alleged above has caused and/or will 24 cause Versace to suffer injury, for which it has no adequate remedy at law. Versace 25 is entitled to all available relief provided for in California Unfair Business Practices 26 Act, Cal. Bus. & Prof. Code, §§ 17200, et seq., including permanent injunctive 27 relief. 28

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1 WHEREFORE, Versace respectfully requests that this Court enter 2 judgment against Fashion Nova as follows: 3 A. Adjudging that Fashion Nova: (i) violated § 501 of the Copyright 4 Act of 1976, 17 U.S.C. § 501, with respect to the Versace Copyrights; (ii) violated 5 § 32 of the Lanham Act, 15 U.S.C. § 1114, with respect to the Versace Trademarks; 6 and (iii) violated § 43(a) of the Lanham Act, 15 U.S.C. § 1125, with respect to the 7 Versace Trade Dress; 8 B. Granting an injunction, pursuant to Rule 65 of the Federal Rules 9 of Civil Procedure, 17 U.S.C. § 502 and 15 U.S.C. § 1116, preliminarily and 10 permanently restraining and enjoining Fashion Nova, its officers, agents, employees 11 and attorneys, and all those persons or entities in active concert or participation with 12 them from designing, manufacturing, importing, advertising, marketing, promoting, 13 supplying, distributing, offering for sale and/or selling any products that bear the 14 Versace Copyrights, the Versace Trademarks and/or the Versace Trade Dresses, 15 and/or any other design, mark, symbol or other elements substantially similar or 16 confusingly similar thereto, including, without limitation, the Infringing Apparel, and 17 engaging in any other activity constituting an infringement of any of Versace’s rights 18 in the Versace Copyrights, the Versace Trademarks and/or the Versace Trade Dresses; 19 C. Requiring Fashion Nova to recall from any distributors and 20 retailers, and to deliver to Versace for destruction or other disposition all remaining 21 inventory of all Infringing Apparel, including all advertisements, promotional and 22 marketing materials therefor, as well as the means of making same; 23 D. Requiring Fashion Nova to file with this Court and to serve on 24 Versace within thirty (30) days after entry of the injunction a report in writing under 25 oath setting forth in detail the manner and form in which Fashion Nova has complied 26 with the injunction; 27 E. Directing such other and further relief as the Court may deem 28

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1 appropriate to prevent consumers, the public and/or the trade from deriving any 2 erroneous impression that any product at issue in this action that has been 3 manufactured, imported, advertised, marketed, promoted, supplied, distributed, 4 offered for sale and/or sold by Fashion Nova has been authorized by Versace, or is 5 related in any way with Versace and/or its products; 6 F. Awarding Versace statutory damages or, alternatively, its actual 7 damages suffered as a result of the copyright infringement and any profits of Fashion 8 Nova not taken into account in computing the actual damages, pursuant to 17 U.S.C. 9 § 504; 10 G. Ordering Fashion Nova to account to and pay to Versace all profits 11 realized by its wrongful acts, awarding Versace its actual damages, and directing that 12 such profits or actual damages be trebled in accordance with § 35 of the Lanham Act, 13 15 U.S.C. § 1117; 14 H. Awarding Versace punitive damages to which it is entitled under 15 applicable law; 16 I. Awarding Versace its attorneys’ fees, together with the costs and 17 disbursements of this action; 18 J. Awarding Versace pre-judgment interest on any monetary award 19 made part of the judgment against Fashion Nova; and 20 K. Granting Versace such other and further relief as the Court deems 21 just and proper. 22 JURY DEMAND 23 Plaintiff hereby demands a trial by jury of all issues so triable. 24 25 26 27 28

603207269.1 34 Case No. 2:19-cv-10074 COMPLAINT

Case 2:19-cv-10074 Document 1 Filed 11/25/19 Page 35 of 35 Page ID #:35

1 DATED: November 25, 2019 KENDALL BRILL & KELLY LLP

2 3 By: /s/ Patrick J. Somers 4 Patrick J. Somers (318766) 5 [email protected] Bert H. Deixler (70614) 6 [email protected] Amanda D. Barrow (313583) 7 [email protected] 10100 Santa Monica Blvd., Suite 1725 8 Los Angeles, California 90067 Telephone: 310.556.2700 9 Facsimile: 310.556.2705 10 PAUL, WEISS, RIFKIND, WHARTON & 11 GARRISON LLP Andrew Gordon (pro hac vice 12 forthcoming) [email protected] 13 Lynn B. Bayard (pro hac vice forthcoming) [email protected] 14 Darren W. Johnson (pro hac vice forthcoming) 15 [email protected] 1285 Avenue of the Americas 16 New York, New York 10019 Telephone: 212.373.3000 17 Facsimile: 212.757.3990

18 Attorneys for Plaintiff Gianni Versace S.r.l. 19

21 22 23 24 25 26 27 28

603207269.1 35 Case No. 2:19-cv-10074 COMPLAINT

Case 2:19-cv-10074 Document 1-1 Filed 11/25/19 Page 1 of 3 Page ID #:36

EXHIBIT A Case 2:19-cv-10074 Document 1-1 Filed 11/25/19 Page 2 of 3 Page ID #:37

, I This Certific_; te issued under the seal of the Copyright , J.· OffiEe-in accordanc~ with title 17', United States Code, - attests that regist~;tion h~ be;n ~ade for_the -work . ,-, - identified below. The information o-n thh certificate has , ·_ ' r \ , ' been tllade apar t: of-tlie,Cgpytigh:t qffie~r ecotds~ . , { Registration NiI"lber - . - ',, ~# _, ,I , ~ ,- ,\_ _ I r ( r •_y�,. _2-J76�2'0,, , 1: ' EffectiveDate of Registration: ';,,~-, -;,.~";tI-', ,· - . , . I. r I '" October 31, 2019 -, - - Registration Decision-Date: '. u~res ~~srerOi cop;;:,~ ..iiDl>J:,.;,, November 01, 2019

Year of Completiop: Date of. 1st Publication:, '~~tlon,of !51 Pu t?lication: - { \ ,_ ,i..

Organization Name: ,Gianni ,Versace S.r. l. ,,- 1 Name: Francesca Bosio- - Email: [email protected] T!lephoJ!e: +39027609,3441 - Addr�ss: Piazza Einaudi, 4 �ilap 20p4 Itafy- _ :t

EXHIBIT A 36 Case 2:19-cv-10074 Document 1-1 Filed 11/25/19 Page 3 of 3 Page ID #:38

EXHIBIT A 37 Case 2:19-cv-10074 Document 1-2 Filed 11/25/19 Page 1 of 3 Page ID #:39

EXHIBIT B Case 2:19-cv-10074 Document 1-2 Filed 11/25/19 Page 2 of 3 Page ID #:40 ' . Certificate of Registration - - -

Registration Number VA 2-173-519 - ~ffective Date of Registration: October D3, 201'9 - - Registration Decision Date: _ October 11, 2019

Title -of Work:

year bf Completion: Date of 1st Publication: .Nation ofl st Publication: -

Organization Name: Gianni Versac.e S.r.L Name: Francesca -Bosio Email: [email protected] Telephone: _ +390276093441 : Address: Piazza Einaudi, 4 Milan 20124 Italy

EXHIBIT B 38 Case 2:19-cv-10074 Document 1-2 Filed 11/25/19 Page 3 of 3 Page ID #:41

EXHIBIT B 39 Case 2:19-cv-10074 Document 1-3 Filed 11/25/19 Page 1 of 3 Page ID #:42

EXHIBIT C Case 2:19-cv-10074 Document 1-3 Filed 11/25/19 Page 2 of 3 Page ID #:43

Registration Number VA, 2-'llS-854 Effective Date of R~gistration: Dctober 30~2019- Registration Decision Date: October 3 i', 2019 -

Year of C,ompletiQn: Date-of 1st Publication: Nation of 151 Publication:

Gia nni Ve6ace 2-Dartw¢.ck N'o l_titlJ~ ·r Author: _Author Created: Work made for hire: e Domiciled in: }Jaly

Copyright Claimant: Gianni Versa~e S.r,I. Piazza Einaudi, 4, Milan, 20124, Italy Tran~fer statement: By written agreement_

EXHIBIT C 40 Case 2:19-cv-10074 Document 1-3 Filed 11/25/19 Page 3 of 3 Page ID #:44

\ , .. Organization. Name: Giam1i Vers_ace S.r.]. · . _· _ . N~~,lf: _ J E

EXHIBIT C 41 Case 2:19-cv-10074 Document 1-4 Filed 11/25/19 Page 1 of 23 Page ID #:45

EXHIBIT D Case 2:19-cv-10074 Document 1-4 Filed 11/25/19 Page 2 of 23 Page ID #:46

VERSACE

Reg. NO. 4,398,385 GIANNI VERSACE S.P.A. (ITALY CORPORATION) VIA MANZONI, 38 Registered Sep. 10, 2013 I-20121 MILANO ITALY Int. Cls.: 11, 14, 27 and 35 FOR: FIREPLACES; LAMPS, IN CLASS 11 (U.S. CLS. 13, 21, 23, 31 AND 34).

FOR: ARTICLES MADE OF PRECIOUS METALS AND ALLOYS OF PRECIOUS METALS TRADEMARK WITH OR WITHOUT PRECIOUS STONES, NAMELY, RINGS, NECKLACES, BRACELETS, BROOCHES, EARRINGS, TIE CLIPS, CUFFLINKS, DIAMONDS, JEWEL CASES, WATCHES, SERVICE MARK CLOCKS, CHRONOMETERS, WATCH CASES, COSTUME JEWELRY, PARTS AND FITTINGS FOR ALL THE AFORESAID GOODS, IN CLASS 14 (U.S. CLS. 2, 27, 28AND 50). PRINCIPAL REGISTER FOR: CARPETS, BATH MATS; RUGS, MATS AND MATTING, AND OTHER MATERIALS FOR COVERING EXISTING FLOORS; NON-TEXTILE WALL HANGINGS, IN CLASS 27 (U.S. CLS. 19, 20, 37, 42AND 50).

FOR: ADVERTISING; BUSINESS MANAGEMENT; BUSINESS ADMINISTRATION; OFFICE FUNCTIONS; DISSEMINATION OF ADVERTISEMENTS; DISSEMINATION OF ADVERT ISING MATTER; INDUSTRIAL BUSINESS MANAGEMENT CONSULTANCY AND ASSIST ANCE; PROFESSIONAL BUSINESS CONSULTANCY; FRANCHISING, NAMELY, SERVICES PROVIDED BY A FRANCHISOR FOR THIRD PARTIES IN HELPING, MANAGING AND DEVELOPING COMMERCIAL ENTERPRISES; GATHERING VARIOUS GOODS IN THE FIELD OF FASHION AND HOME FURNISHING AND ACCESSORIES ALLOWING THE CONSUMER TO VIEW AND BUY THE AFORESAID GOODS IN RETAIL STORES, IN CLASS 35 (U.S. CLS. 100, 101 AND 102).

THE MARK CONSISTS OF STANDARD CHARACTERS WITHOUT CLAIM TO ANY PAR TICULAR FONT, STYLE, SIZE, OR COLOR.

PRIORITY DATE OF 6-10-2010 IS CLAIMED.

OWNER OF INTERNATIONAL REGISTRATION 1073076 DATED 11-9-2010, EXPIRES 11- 9-2020.

AdlngDrredo,oftheUnitedStatesPatentandTrndemackOffice OWNER OF U.S. REG. NOS. 1,880,658, 2,278,257 AND OTHERS.

EXHIBIT D 42 Case 2:19-cv-10074 Document 1-4 Filed 11/25/19 Page 3 of 23 Page ID #:47

Reg. No. 4,398,385 sEc. 2(F).

SER. NO. 79-975,265, FILED 11-9-2010.

KIM MONINGHOFF, EXAMINING ATTORNEY

Page: 2 / RN # 4,398,385

EXHIBIT D 43 Case 2:19-cv-10074 Document 1-4 Filed 11/25/19 Page 4 of 23 Page ID #:48

REQUIREMENTS TO MAINTAIN YOUR FEDERAL TRADEMARK REGISTRATION

WARNING: YOUR REGISTRATION WILL BE CANCELLED IF YOU DO NOT FILE THE DOCUMENTS BELOW DURING THE SPECIFIED TIME PERIODS.

Requirements in the First Ten Years* What and When to File:

First Filing Deadline: You must file a Declaration of Use (or Excusable Nonuse) between the 5th and 6th years after the registration date. See 15 U.S.C. §§1058, 1141k. If the declaration is accepted, the registration will continue in force for the remainder of the ten-year period, calculated from the registration date, unless cancelled by an order of the Commissioner for Trademarks or a federal court.

Second Filing Deadline: You must file a Declaration of Use (or Excusable Nonuse) and an Application for Renewal between the 9th and 10th years after the registration date.* See 15 U.S.C. §1059.

Requirements in Successive Ten-Year Periods* What and When to File:

You must file a Declaration ofU se ( or Excusable Nonuse) and an Application for Renewal between every 9th and 10th-year period, calculated from the registration date.*

Grace Period Filings*

The above documents will be accepted as timely if filed within six months after the deadlines listed above with the payment of an additional fee.

The United States Patent and Trademark Office (USPTO) will NOT send you any future notice or reminder of these filing requirements.

* ATTENTION MADRID PROTOCOL REGISTRANTS: The holder of an international registration with an extension of protection to the United States under the Madrid Protocol must timely file the Declarations of Use (or Excusable Nonuse) referenced above directly with the USPTO. The time periods for filing are based on the U.S. registration date (not the international registration date). The deadlines and grace periods for the Declarations of Use (or Excusable Nonuse) are identical to those for nationally issued registrations. See 15 U .S.C. §§ 1058, 114 lk. However, owners of international registrations do not file renewal applications at the USPTO. Instead, the holder must file a renewal of the underlying international registration at the International Bureau of the World Intellectual Property Organization, under Article 7 of the Madrid Protocol, before the expiration of each ten-year term of protection, calculated from the date of the international registration. See 15 U.S. C. § 1141 j. For more information and renewal forms for the international registration, see http://www.wipo.int/madrid/en/.

NOTE: Fees and requirements for maintaining registrations are subject to change. Please check the USPTO website for further information. With the exception of renewal applications for registered extensions of protection, you can file the registration maintenance documents referenced above online at http ://www.uspto.gov.

Page: 3 / RN # 4,398,385

EXHIBIT D 44 Case 2:19-cv-10074 Document 1-4 Filed 11/25/19 Page 5 of 23 Page ID #:49

VERSACE

Reg. No. 4,626,622 GIANNI VERSACE S.P.A. (ITALY CORPORATION) VIA MANZONI, 38 Registered Oct. 28, 2014 I-20121 MILANO ITALY Int. Cls.: 16, 35 and 42 FOR: PRINTED MATTER, NAMELY, POSTERS, IN CLASS 16 (U.S. CLS. 2, 5, 22, 23, 29, 37, 38AND 50). TRADEMARK FOR: MODELING FOR BUSINESS PROMOTION, IN CLASS 35 (U.S. CLS. 100, 101 AND SERVICE MARK 102).

PRINCIPAL REGISTER FOR: CONSULTANCY IN THE FIELD OF PLANNING AND LAYOUT DESIGN OF THE IN TERIOR SPACE OF SHOPS, INTERIOR DESIGN, IN CLASS 42 (U.S. CLS. 100 AND 101).

THE MARK CONSISTS OF STANDARD CHARACTERS WITHOUT CLAIM TO ANY PAR TICULAR FONT, STYLE, SIZE, OR COLOR.

PRIORITY DATE OF 6-10-2010 IS CLAIMED.

OWNER OF INTERNATIONAL REGISTRATION 1073076 DATED 11-9-2010, EXPIRES 11- 9-2020.

OWNER OF U.S. REG. NOS. 1,880,658, 2,278,257 AND OTHERS.

SEC. 2(F).

SER. NO. 79-095,795, FILED 11-9-2010.

KIM MONINGHOFF, EXAMINING ATTORNEY

Deputy Director of the United States Patent and Trademark Office

EXHIBIT D 45 Case 2:19-cv-10074 Document 1-4 Filed 11/25/19 Page 6 of 23 Page ID #:50

REQUIREMENTS TO MAINTAIN YOUR FEDERAL TRADEMARK REGISTRATION

WARNING: YOUR REGISTRATION WILL BE CANCELLED IF YOU DO NOT FILE THE DOCUMENTS BELOW DURING THE SPECIFIED TIME PERIODS.

Requirements in the First Ten Years* What and When to File:

Second Filing Deadline: You must file a Declaration of Use (or Excusable Nonuse) and an Application for Renewal between the 9th and 10th years after the registration date.* See 15 U.S.C. §1059.

Requirements in Successive Ten-Year Periods* What and When to File:

You must file a Declaration ofU se ( or Excusable Nonuse) and an Application for Renewal between every 9th and 10th-year period, calculated from the registration date.*

Grace Period Filings*

The above documents will be accepted as timely if filed within six months after the deadlines listed above with the payment of an additional fee.

The United States Patent and Trademark Office (USPTO) will NOT send you any future notice or reminder of these filing requirements.

Page: 2 /RN# 4,626,622

EXHIBIT D 46 Case 2:19-cv-10074 Document 1-4 Filed 11/25/19 Page 7 of 23 Page ID #:51

Int. as.: 9, 14, 16, 21 and 30

Prior U.S. Cls.: 2, 3, 13, 23, 26, 27, 28, 30, 33, 37 and 46 Reg. No. 1,875,093 United States Patent and Trademark Office Registered Jan. 24, 1995

TRADEMARK PRINCIPAL REGISTER

EXHIBIT D 47 Case 2:19-cv-10074 Document 1-4 Filed 11/25/19 Page 8 of 23 Page ID #:52

GIANNI VERSACE SPA (ITALY CORPORA PENS, ROLLER PENS, MARKERS, MARKING TION) PENS, PENCIL AND PENCIL LEADS, REFILLS VIA DELLA SPIGA 25 FOR PENS, NON-ELECTRIC ERASERS , IN 20121 MILANO, ITALY CLASS 16 (U.S. CL. 37).

FOR: SPECTACLES AND SPECTACLES FOR: KITCHEN UTENSILS, FRAMES, IN CLASS 9 (U.S. CL. 26). NAMELY SERV ING SPOONS, BASTING SPOONS, CORK FOR: GOODS OF PRECIOUS METALS OR SCREWS, AND NAPKIN RINGS NOT OF PRE COATED THEREWITH, NAMELY NECK CIOUS METAL; HOUSEHOLD CONTAINERS, LACES, EARRINGS, BRACELETS, BROCHES, NAMELY ICE BUCKETS, CONTAINERS RINGS, FOR NECKTIE PINS, BADGES OF PRE FOOD AND SOAP; BEVERAGE GLASSWARE; CIOUS METAL, MEDALLIONS, BELT BUCK PORCELAIN DISHES IN GENERAL, EARTH LES OF PRECIOUS METAL (FOR CLOTHING), ENWARE, NAMELY MUGS, BASINS, BAS JEWELRY, PRECIOUS GEMSTONES, WATCH KETS, BEVERAGEWARE, BOWLS, BUCKETS, ES, CLOCKS, CHRONOMETERS, IN CLASS 14 CAKESERVERS, CANDLE HOLDERS, CHAM (U.S. CLS. 27 AND 28). BER POTS, .COMMEMORATIVE PLATES, FOR: STATIONERY ARTICLES, NAMELY COOKWARE, DECORATIVE PLATES, DISHES, NOTEBOOK PAPER, LETTER PAPER, WRIT DOORKNOBS MADE OF PORCELAIN OR ING PAPER, LOOSELEAF PAPER; PAPER EX EARTHENWARE, FIGURINES MADE OF PANDING FILES, WRITING AND MARKING CHINA, CRYSTAL, EARTHENWARE, GLASS, INSTRUMENTS, NAMELY FOUNTAIN PENS, PORCELAIN, OR TERRACOTTA, VASES, IN ROLLER BALLPOINT PENS, FELT TIPPED CLASS 21 (U.S. CLS. 2, 3, 13, 23, 30 AND 33).

EXHIBIT D 48 Case 2:19-cv-10074 Document 1-4 Filed 11/25/19 Page 9 of 23 Page ID #:53

2 1,875,093

FOR: PASTRY AND CONFECTIONERY; THE MARK CONSISTS OF A DEPICTION OF NAMELY, CHOCOLATES, IN CLASS 30 (U.S. THE HEAD OF THE MEDUSA, A CHARACTER CL. 46). IN GREEK MYTHOLOGY PRIORITY CLAIMED UNDER SEC. 44(0) ON ITALY APPLICATION NO. MI93C003112, FILED SER. NO. 74-391,423, FILED 5-17-1993. 4-28-1993, REG. NO. 6000025, DATED 6-15-1993, EXPIRES 4-28-2013. CATHERINE KAISER KREBS, EXAMINING OWNER OF U.S. REG. NO. 1,725,686. ATTORNEY

EXHIBIT D 49 Case 2:19-cv-10074 Document 1-4 Filed 11/25/19 Page 10 of 23 Page ID #:54

Side - 1

NOTICE OF ACCEPTANCE OF §8 DECLARATION AND §9 RENEWAL MAILING DATE: Jun 7, 2005

The declaration and renewal application filed in connection with the registration identified below meets the requirements of Sections 8 and 9 of the Trademark Act, 15 U.S.C. §§1058 and 1059. The declaration is accepted and renewal is granted. The registration remains in force.

For further information about this notice, visit our website at: http://www.uspto.gov. To review information regarding the referenced registration, go to http://tarr.uspto.gov.

REG NUMBER: 1875093 MARK: MISCELLANEOUS DESIGN OWNER: Gianni Versace SPA

Side - 2 UNITED STATES PATENT AND TRADEMARK OFFICE COMMISSIONER FOR TRADEMARKS FIRST-CLASS MAIL P.O. BOX 1451 U.S POSTAGE ALEXANDRIA, VA 22313-1451 PAID

LAWRENCE E ABELMAN ABELMAN FRAYNE & SCHWAB 26TH FL 150 E 42ND ST NEW YORK, NY 10017-5612

EXHIBIT D 50 Case 2:19-cv-10074 Document 1-4 Filed 11/25/19 Page 11 of 23 Page ID #:55

From: [email protected] Sent: Tuesday, February 3, 2015 11:01 PM To: [email protected] Subject: Official USPTO Notice of Acceptance and Renewal Sections 8 and 9: U.S. Trademark RN 1875093: Miscellaneous Design

Serial Number: 74391423 Registration Number: 1875093 Registration Date: Jan 24, 1995 Mark: Miscellaneous Design Owner: Gianni Versace SPA

Feb 3, 2015

NOTICE OF ACCEPTANCE UNDER SECTION 8

The declaration of use or excusable nonuse filed for the above-identified registration meets the requirements of Section 8 of the Trademark Act, 15 U.S.C. §1058. The Section 8 declaration is accepted.

NOTICE OF REGISTRATION RENEWAL UNDER SECTION 9

The renewal application filed for the above-identified registration meets the requirements of Section 9 of the Trademark Act, 15 U.S.C. §1059. The registration is renewed.

The registration will remain in force for the class(es) listed below for the remainder of the ten-year period, calculated from the registration date, unless canceled by an order of the Commissioner for Trademarks or a Federal Court.

Class(es): 009, 014, 016, 021

TRADEMARK SPECIALIST POST-REGISTRATION DIVISION 571-272-9500

REQUIREMENTS FOR MAINTAINING REGISTRATION IN SUCCESSIVE TEN-YEAR PERIODS

WARNING: Your registration will be canceled if you do not file the documents below during the specified time periods.

What and When to File: You must file a declaration of use (or excusable nonuse) and an application for renewal between every 9th and 10th-year period, calculated from the registration date. See 15 U.S.C. §§1058, 1059.

Grace Period Filings

The above documents will be considered as timely if filed within six months after the deadlines listed above with the payment of an additional fee.

***The USPTO WILL NOT SEND ANY FURTHER NOTICE OR REMINDER OF THESE REQUIREMENTS. THE REGISTRANT SHOULD CONTACT THE USPTO ONE YEAR BEFORE THE EXPIRATION OF THE TIME PERIODS SHOWN ABOVE TO DETERMINE APPROPRIATE REQUIREMENTS AND FEES.***

To view this notice and other documents for this application on-line, go to http://tdr.uspto.gov/search.action?sn=74391423. NOTE: This notice will only be available on-line the next business day after receipt of this e-mail.

EXHIBIT D 51 Case 2:19-cv-10074 Document 1-4 Filed 11/25/19 Page 12 of 23 Page ID #:56

Int. Cls.: 3, 8, 9, 11, 14, 18, 19, 20, 21, 24, 25 and 27 Prior U.S. Cls.: 1, 2, 3, 4, 6, 12, 13, 19, 20, 21, 22, 23, 25,26,27,28,29,30,31,32,33,34,36,37,38,39,40, 41, 42, 44, 50, 51 and 52 Reg. No. 2,980,455 United States Patent and Trademark Office Registered Aug. 2, 2005

TRADEMARK PRINCIPAL REGISTER

GIANNI VERSACE S.P.A. (ITALY CORPORA FIRST USE 1-0-1998; IN COMMERCE 1-0-1998. TION) VIA MANZONI, 38 FOR: APPARATUS FOR LIGHTING, NAMELY, MILAN, ITALY ELECTRIC LIGHTING FIXTURES FOR USE ON CEILINGS, CHANDELIERS, ELECTRIC, INCAN FOR: COSMETICS, NAMELY NIGHT AND DAY DESCENT, AND HALOGEN LIGHT BULBS, SAFE CREAMS, CLEANING PREPARATIONS FOR THE TY LAMPS, CANDLE, ELECTRIC, OIL, AND CARE OF THE FACE AND BODY, BATH-FOAM, PORTABLE PAPER LANTERNS, STANDARD SHAVING FOAM, AFTERSHAVES, FOUNDATION LAMPS; FIREPLACES; DECORATIVE WATER MAKEUP, NAIL POLISH, DEODORANTS FOR MEN FOUNTAINS; LAMPS, IN CLASS 11 (U.S. CLS. 13, AND WOMEN, HAND AND BODY SOAPS, HAIR 21, 23, 31 AND 34). SHAMPOOS AND RINSES, HAIR SPRAY, TOOTH PASTE AND FRAGRANCES, NAMELY PERFUME, FIRST USE 1-0-1998; IN COMMERCE 1-0-1998. TOILET WATER AND ESSENTIAL OILS FOR PER SONAL USE FOR MEN AND WOMEN, IN CLASS 3 FOR: ARTICLES MADE OF PRECIOUS METALS (U.S. CLS. 1, 4, 6, 50, 51 AND 52). AND ALLOYS OF PRECIOUS METALS WITH OR WITHOUT PRECIOUS STONES, NAMELY RINGS, FIRST USE 1-0-1998; IN COMMERCE 1-0-1998. NECKLACES, BRACELETS, BROOCHES, EARR INGS, TIE CLIPS, CUFF-LINKS, DIAMONDS, JEW FOR: TABLEWARE, NAMELY CUTLERY; ELRY CASES MADE OF PRECIOUS METAL, FORKS, KNIVES AND SPOONS; STERLING SILVER WATCHES, CLOCKS, CHRONOMETERS, WATCH TABLE FORKS, KNIVES AND SPOONS; DOMESTIC CASES, COSTUME JEWELRY, IN CLASS 14 (U.S. FIREPLACE BELLOWS, IN CLASS 8 (U.S. CLS. 23, 28 CLS. 2, 27, 28 AND 50). AND 44). FIRST USE 1-0-1998; IN COMMERCE 1-0-1998. FIRST USE 1-0-1998; IN COMMERCE 1-0-1998. FOR: LEATHER AND IMITATION OF LEATHER FOR: OPTICAL INSTRUMENTS, APPARATUS SOLD IN BULK, HANDBAGS, WALLETS, LUG AND EQUIPMENTS, NAMELY EYEGLASSES; GAGE, ATTACHE CASES, TOTE BAGS, BRIEFCA READING GLASSES, AND OPTICAL GLASSES; SES, SPORT BAGS, TRAVELING TRUNKS, CARRY SUNGLASSES; SPECTACLES; SPECTACLES ON BAGS, SHOULDER BAGS, GARMENT BAGS FRAMES; MONOCLES; LORGNETTES, IN CLASS 9 FOR TRAVELING, KEY CASES, UMBRELLAS, (U.S. CLS. 21, 23, 26, 36 AND 38). PARASOLS, WALKING STICKS, WHIPS, HARNES-

EXHIBIT D 52 Case 2:19-cv-10074 Document 1-4 Filed 11/25/19 Page 13 of 23 Page ID #:57

SES, SADDLERY; LEATHER KEY CHAINS , IN FIRST USE 1-0-1998; IN COMMERCE 1-0-1998. CLASS 18 (U.S. CLS. 1, 2, 3, 22 AND 41). FOR: FABRIC FOR TEXTILE USE, FABRIC OF FIRST USE 1-0-1998; IN COMMERCE 1-0-1998. IMITATION ANIMAL SKINS, FABRIC FOR BOOTS AND SHOES, BATH LINEN; BED LINEN; BLAN FOR: FIREPLACE SURROUND; FLOOR TILES; KETS; CURTAINS; UNFITTED FURNITURE COV WOOD TILE FLOORS; GLASS TILES; PARQUET ERS; HANDKERCHIEFS; KITCHEN TOWELS; FLOORING; STATUETTES OF STONE, CONCRETE, TEXTILE WALL HANGINGS, IN CLASS 24 (U.S. OR MARBLE; NON-METAL WALL PANELS, IN CLS. 42 AND 50). CLASS 19 (U.S. CLS. 1, 12, 33 AND 50). FIRST USE 1-0-1998; IN COMMERCE 1-0-1998. FIRST USE 1-0-1998; IN COMMERCE 1-0-1998. FOR: CLOTHING FOR MEN, WOMEN AND FOR: FURNITURE; MIRRORS, NAMELY LOOK CHILDREN, NAMELY BELTS, COATS, RAIN ING GLASSES; PICTURE FRAMES; CHAIRS; CUP COATS, WAISTCOATS, BLOUSES AND PULL BOARDS; CUSHIONS; DESKS; DIV ANS; PLASTIC OVERS, JACKETS, TROUSERS, SKIRTS, DRESSES, AND WOOD DOORKNOBS; FIGURES OF BONE, SUITS, SHIRTS AND CHEMISES, T-SHIRTS, SWEA IVORY, PLASTER, PLASTIC, WAX AND WOOD; TERS, UNDERWEAR, SOCKS AND STOCKINGS, PLASTIC AND WOOD FURNITURE HANDLES GLOVES, TIES, SCARVES, HATS AND CAPS, FOR DOORS, PLASTIC KEY CHAINS; MAGAZINE BOOTS, SHOES AND SLIPPERS, IN CLASS 25 (U.S. RACKS; OFFICE FURNITURE; PILLOWS; FITTED CLS. 22 AND 39). FURNITURE COVERS, IN CLASS 20 (U.S. CLS. 2, 13, 22, 25, 32 AND 50). FIRST USE 1-0-1998; IN COMMERCE 1-0-1998.

FIRST USE 1-0-1998; IN COMMERCE 1-0-1998. FOR: CARPETS, RUGS, MATS AND MATTING, LINOLEUM AND OTHER MATERIALS FOR COV FOR: HOUSEHOLD OR KITCHEN UTENSILS ERING EXISTING FLOORS; NON-TEXTILE WALL AND CONTAINERS, NAMELY, DINNERWARE; HANGINGS; NON-TEXTILE WALL DECORA BEVERAGE-WARE; GLASSWARE; SUGAR BOWLS; TIONS, IN CLASS 27 (U.S. CLS. 19, 20, 37, 42 AND 50). BEER MUGS; BOTTLE OPENERS; BOWLS; CANDLE HOLDERS NOT OF PRECIOUS METAL; CHINA FIRST USE 1-0-1998; IN COMMERCE 1-0-1998. ORNAMENTS; COOKWARE, NAMELY NON-ELEC TRIC FRYING PANS; CORKSCREWS; SOAP DIS PENSERS; FIGURINES IN CHINA, CRYSTAL, OWNER OF U.S. REG. NOS. 1,725,686, 1,875,093, EARTHENWARE, GLASS, PORCELAIN AND TER AND 2,081,230. RACOTTA; HOLDERS FOR FLOWERS AND PLANTS; PERFUME ATOMIZERS SOLD EMPTY; THE MARK CONSISTS OF THE REPRESENTA PLATES; POTS; SOAPBOXES; SOAP HOLDERS; VA TION OF A HEAD (MEDUSA'S HEAD). SES; FLOWER BASKETS; PORCELAIN AND EARTHENWARE DOORKNOBS AND FURNITURE SER. NO. 76-536,034, FILED 7-28-2003. HANDLES FOR DOORS, IN CLASS 21 (U.S. CLS. 2, 13, 23, 29, 30, 33, 40 AND 50). DOUGLAS LEE, EXAMINING ATTORNEY

EXHIBIT D 53 Case 2:19-cv-10074 Document 1-4 Filed 11/25/19 Page 14 of 23 Page ID #:58

From: [email protected] Sent: Wednesday, August 12, 2015 11:00 PM To: [email protected] Subject: Official USPTO Notice of Acceptance and Renewal Sections 8 and 9: U.S. Trademark RN 2980455: Miscellaneous Design

Serial Number: 76536034 Registration Number: 2980455 Registration Date: Aug 2, 2005 Mark: Miscellaneous Design Owner: Gianni Versace S.p.A.

Aug 12, 2015

NOTICE OF ACCEPTANCE UNDER SECTION 8

NOTICE OF REGISTRATION RENEWAL UNDER SECTION 9

The renewal application filed for the above-identified registration meets the requirements of Section 9 of the Trademark Act, 15 U.S.C. §1059. The registration is renewed.

Class(es): 003, 008, 009, 011, 014, 018, 019, 020, 021, 024, 025, 027

TRADEMARK SPECIALIST POST-REGISTRATION DIVISION 571-272-9500

REQUIREMENTS FOR MAINTAINING REGISTRATION IN SUCCESSIVE TEN-YEAR PERIODS

WARNING: Your registration will be canceled if you do not file the documents below during the specified time periods.

Grace Period Filings

The above documents will be considered as timely if filed within six months after the deadlines listed above with the payment of an additional fee.

To view this notice and other documents for this application on-line, go to http://tdr.uspto.gov/search.action?sn=76536034. NOTE: This notice will only be available on-line the next business day after receipt of this e-mail.

EXHIBIT D 54 Case 2:19-cv-10074 Document 1-4 Filed 11/25/19 Page 15 of 23 Page ID #:59

Int. Cls.: 3, 9, 14, 16, 18, 24, 25 and 26 Prior U.S. Cls.: 1, 2, 3, 4, 5, 6, 21, 22, 23, 26, 27, 28, 29, 36, 37, 38, 39, 40, 41, 42, 50, 51 and 52 Reg. No. 3,194,501 United States Patent and Trademark Office Registered Jan. 2, 2007

TRADEMARK PRINCIPAL REGISTER

GIANNI VERSACE S.P.A. FISCAL CODE N. TYPE; PRINTED MATTER, NAMELY, PERIODICAL 04636090963 (ITALY S.P.A.) MAGAZINES, BOOKS, AND LEAFLETS IN THE VIA MANZONI N. 38 FIELD OF FASHION, INTERIOR DESIGN, COS MILANO METICS, OPTICAL WEAR, AND FASHION ACCES ITALY SORIES, IN CLASS 16 (U.S. CLS. 2, 5, 22, 23, 29, 37, 38 AND 50). FOR: COSMETICS, INCLUDING NIGHT AND DAY CREAMS, CLEANING PREPARATIONS FOR FOR: LEATHER AND IMITATION LEATHER THE CARE OF THE FACE AND BODY, BATH GOODS, NAMELY, HANDBAGS, WALLETS, LUG FOAM, SHAVING FOAM, AFTERSHAVES, FOUN GAGE, ATTACHE CASES, TOTE BAGS, BRIEFCA DATION MAKEUP, NAIL POLISH, DEODORANTS SES, SPORT BAGS, TRAVELING TRUNKS, CARRY FOR MEN AND WOMEN, HAND AND BODY ON BAGS, SHOULDER BAGS, GARMENT BAGS SOAPS, HAIR SHAMPOOS AND RINSES, HAIR FOR TRAVELING, KEY CASES, UMBRELLAS, SPRAY, TOOTHPASTE AND FRAGRANCES, PARASOLS, WALKING STICKS, WHIPS, HARNES NAMELY PERFUME, TOILET WATER AND ESSEN SES, SADDLERY, IN CLASS 18 (U.S. CLS. 1, 2, 3, 22 TIAL OILS FOR PERSONAL USE FOR MEN AND AND 41). WOMEN, IN CLASS 3 (U.S. CLS. 1, 4, 6, 50, 51 AND 52).

FOR: OPTICAL INSTRUMENTS, APPARATUS FOR: FABRIC FOR TEXTILE USE, FABRIC OF AND EQUIPMENT, NAMELY, GLASSES, SUN IMITATION ANIMAL SKINS, FABRIC FOR BOOTS GLASSES, SPECTACLES, SPECTACLE FRAMES, AND SHOES, BATH LINEN, BED LINEN; BED MONOCLES, LORGNETTES, ACCESSORIES IN BLANKETS; CURTAINS; UNFITTED FABRIC FUR THE NATURE OF EYEGLASS CHAINS, AND NITURE COVERS; HANDKERCHIEFS; AND PARTS, FITTINGS, COMPONENTS AND CASES KITCHEN TOWELS, IN CLASS 24 (U.S. CLS. 42 FOR ALL THE AFORESAID GOODS, IN CLASS 9 AND 50). (U.S. CLS. 21, 23, 26, 36 AND 38). FOR: CLOTHING FOR MEN, WOMEN AND FOR: ARTICLES MADE OF PRECIOUS METALS CHILDREN, NAMELY BELTS, COATS, RAIN AND ALLOYS OF PRECIOUS METALS, WITH OR COATS, WAISTCOATS, BLOUSES AND PULL WITHOUT PRECIOUS STONES, NAMELY RINGS, OVERS, JACKETS, TROUSERS, SKIRTS, DRESSES, NECKLACES, BRACELETS, BROOCHES, EARR SUITS, SHIRTS AND CHEMISES, T-SHIRTS, SWEA INGS, TIE CLIPS, CUFF-LINKS, DIAMONDS, JEW TERS, UNDERWEAR, SOCKS AND STOCKINGS, EL CASES, WATCHES, CLOCKS, GLOVES, TIES, SCARVES, HATS AND CAPS, CHRONOMETERS, WATCH CASES, COSTUME BOOTS, SHOES AND SLIPPERS, IN CLASS 25 (U.S. JEWELLERY, PARTS AND FITTINGS FOR ALL CLS. 22 AND 39). THE AFORESAID GOODS, IN CLASS 14 (U.S. CLS. 2, 27, 28 AND 50). FOR: LACE AND EMBROIDERY, RIBBONS AND BRAID; CLOTHING BUTTONS, HOOKS AND EYES, FOR: STATIONERY ARTICLES, NAMELY PA SAFETY PINS AND NEEDLES; ARTIFICIAL FLOW PER, LETTER PAPER, LOOSE-LEAF PAPER, EXER ERS, IN CLASS 26 (U.S. CLS. 37, 39, 40, 42 AND 50). CISE BOOKS, ADDRESS BOOKS AND NOTEBOOKS, NUMERICAL AND ALPHABETICAL INSERTS, ENVELOPES, CARDS, ALBUMS, FILE PRIORITY DATE OF 3-17-2005 IS CLAIMED. BOOKS; WRITING AND MARKING INSTRU MENTS, NAMELY PENS, FELT-TIPPED PENS, MARKING PENS, PENCILS AND PENCIL LEADS, OWNER OF INTERNATIONAL REGISTRATION INK REFILLS FOR PENS, ERASERS; PRINTING 0866162 DATED 5-26-2005, EXPIRES 5-26-2015.

EXHIBIT D 55 Case 2:19-cv-10074 Document 1-4 Filed 11/25/19 Page 16 of 23 Page ID #:60

OWNER OF U.S. REG. NOS. 1,875,093, 2,078,918, SER. NO. 79-016,809, FILED 5-26-2005. AND 2,081,230. TINA L. SNAPP, EXAMINING ATTORNEY

EXHIBIT D 56 Case 2:19-cv-10074 Document 1-4 Filed 11/25/19 Page 17 of 23 Page ID #:61

NOTICE OF RENEWAL OF INTERNATIONAL REGISTRATION

SERIAL NUMBER: 79016809

The table below presents the data as entered.

Input Field Entered INTERNATIONAL REGISTRATION NUMBER 0866162 OFFICE REFERENCE 79016809 INSTRUMENT UNDER WHICH CONTRACTING Protocol PARTY IS DESIGNATED DATE OF RECORDAL IN THE INTERNATIONAL 05/26/2015 REGISTER LATEST DATE OF RENEWAL FOR THE MARK 05/26/2015 IB DOCUMENT ID 893985001 NEW EXPIRATION DATE 05/26/2025 TRANSACTION TYPE REN - Renewal

EXHIBIT D 57 Case 2:19-cv-10074 Document 1-4 Filed 11/25/19 Page 18 of 23 Page ID #:62

Int. Cls.: 3, 9, 14, 16, 18, 24 and 26 Prior U.S. Cls.: 1, 2, 3, 4, 5, 6, 21, 22, 23, 26, 27, 28, 29, 36, 37, 38, 39, 40, 41, 42, 50, 51 and 52 Reg. No. 3,199,127 United States Patent and Trademark Office Registered Jan. 16, 2007

TRADEMARK PRINCIPAL REGISTER

GIANNI VERSACE S.P.A. FISCAL CODE N. EL CASES, WATCHES, CLOCKS, 04636090963 (ITALY S.P.A.) CHRONOMETERS, WATCH CASES, COSTUME VIA MANZONI N. 38 JEWELLERY, PARTS AND FITTINGS FOR ALL MILANO THE AFORESAID GOODS, IN CLASS 14 (U.S. CLS. ITALY 2, 27, 28 AND 50).

FOR: COSMETICS, INCLUDING NIGHT AND FOR: STATIONERY ARTICLES, NAMELY PA DAY CREAMS, CLEANING PREPARATIONS FOR PER, LETTER PAPER, LOOSE-LEAF PAPER, EXER THE CARE OF THE FACE AND BODY, BATH CISE BOOKS, ADDRESS BOOKS AND FOAM, SHAVING FOAM, AFTERSHAVES, FOUN NOTEBOOKS, NUMERICAL AND ALPHABETICAL DATION MAKEUP, NAIL POLISH, DEODORANTS INSERTS, ENVELOPES, CARDS, ALBUMS, FILE FOR MEN AND WOMEN, HAND AND BODY BOOKS; WRITING AND MARKING INSTRU SOAPS, HAIR SHAMPOOS AND RINSES, HAIR MENTS, NAMELY PENS, FELT-TIPPED PENS, SPRAY, TOOTHPASTE, AND FRAGRANCES, MARKING PENS, PENCILS AND PENCIL LEADS, NAMELY PERFUME, TOILET WATER AND ESSEN INK REFILLS FOR PENS, ERASERS; PRINTING TIAL OILS FOR PERSONAL USE FOR MEN AND TYPE; PRINTED MATTER, NAMELY, PERIODICAL WOMEN, IN CLASS 3 (U.S. CLS. 1, 4, 6, 50, 51 AND 52). MAGAZINES, BOOKS, AND LEAFLETS IN THE FIELD OF FASHION, INTERIOR DESIGN, COS FOR: OPTICAL INSTRUMENTS, APPARATUS METICS, OPTICAL WEAR AND FASHION ACCES AND EQUIPMENT, NAMELY, GLASSES, SUN SORIES, IN CLASS 16 (U.S. CLS. 2, 5, 22, 23, 29, 37, 38 GLASSES, SPECTACLES, SPECTACLE FRAMES, AND 50). MONOCLES, LORGNETTES, ACCESSORIES IN THE NATURE OF EYEGLASS CHAINS, AND PARTS, FITTINGS, COMPONENTS AND CASES FOR: LEATHER AND IMITATION LEATHER FOR ALL THE AFORESAID GOODS, IN CLASS 9 GOODS, NAMELY, HANDBAGS, WALLETS, LUG (U.S. CLS. 21, 23, 26, 36 AND 38). GAGE, ATTACHE CASES, TOTE BAGS, BRIEFCA SES, SPORT BAGS, TRAVELING TRUNKS, CARRY FOR: ARTICLES MADE OF PRECIOUS METALS ON BAGS, SHOULDER BAGS, GARMENT BAGS AND ALLOYS OF PRECIOUS METALS, WITH OR FOR TRAVELING, KEY CASES, UMBRELLAS, WITHOUT PRECIOUS STONES, NAMELY RINGS, PARASOLS, WALKING STICKS, WHIPS, HARNES NECKLACES, BRACELETS, BROOCHES, EARR SES, SADDLERY, IN CLASS 18 (U.S. CLS. 1, 2, 3, 22 INGS, TIE CLIPS, CUFF-LINKS, DIAMONDS, JEW- AND 41).

EXHIBIT D 58 Case 2:19-cv-10074 Document 1-4 Filed 11/25/19 Page 19 of 23 Page ID #:63

FOR: FABRIC FOR TEXTILE USE, FABRIC OF PRIORITY DATE OF 3-17-2005 IS CLAIMED. IMITATION ANIMAL SKINS, FABRIC FOR BOOTS AND SHOES, BATH LINEN, BED LINEN; BED BLANKETS; CURTAINS; UNFITTED FABRIC FUR NITURE COVERS; HANDKERCHIEFS; AND OWNER OF INTERNATIONAL REGISTRATION KITCHEN TOWELS, IN CLASS 24 (U.S. CLS. 42 0863493 DATED 5-26-2005, EXPIRES 5-26-2015. AND 50).

FOR: LACE AND EMBROIDERY, RIBBONS AND SER. NO. 79-975,011, FILED 5-26-2005. BRAID; CLOTHING BUTTONS, HOOKS AND EYES, SAFETY PINS AND NEEDLES; ARTIFICIAL FLOW ERS, IN CLASS 26 (U.S. CLS. 37, 39, 40, 42 AND 50). TINA L. SNAPP, EXAMINING ATTORNEY

EXHIBIT D 59 Case 2:19-cv-10074 Document 1-4 Filed 11/25/19 Page 20 of 23 Page ID #:64

NOTICE OF RENEWAL OF INTERNATIONAL REGISTRATION

SERIAL NUMBER: 79015820

The table below presents the data as entered.

Input Field Entered INTERNATIONAL REGISTRATION NUMBER 0863493 OFFICE REFERENCE 79015820799750119975011 INSTRUMENT UNDER WHICH CONTRACTING Protocol PARTY IS DESIGNATED DATE OF RECORDAL IN THE INTERNATIONAL 05/28/2015 REGISTER LATEST DATE OF RENEWAL FOR THE MARK 05/26/2015 IB DOCUMENT ID 893984901 NEW EXPIRATION DATE 05/26/2025 TRANSACTION TYPE REN - Renewal

EXHIBIT D 60 Case 2:19-cv-10074 Document 1-4 Filed 11/25/19 Page 21 of 23 Page ID #:65

Int. Cls.: 3, 9, 16, 18, 20, 24, 25 and 26 Prior U.S. Cls.: 1, 2, 3, 4, 5, 6, 13, 21, 22, 23, 25, 26, 29, 32, 36, 37, 38, 39, 40, 41, 42, 50, 51 and 52 Reg. No. 3,453,992 United States Patent and Trademark Office Registered June 24, 2008

TRADEMARK PRINCIPAL REGISTER -

I -

GIANNI VERSACE S.P.A. (ITALY CORPORA- AND LEAFLETS IN THE FIELD OF FASHION, TION) INTERIOR DESIGN, COSMETICS, OPTICAL WEAR VIA A. MANZONI, 38 AND FASHION ACCESSORIES, IN CLASS 16 (U.S. 1-20121 MILANO CLS. 2, 5, 22, 23, 29, 37, 38 AND 50). ITALY FOR: LEATHER AND IMITATION LEATHER FOR: COSMETICS, INCLUDING NIGHT AND GOODS, NAMELY, HANDBAGS, WALLETS, LUG DAY CREAMS, CLEANING PREPARATIONS FOR GAGE, ATTACHE CASES, TOTE BAGS, BRIEFCA THE CARE OF THE FACE AND BODY, BATH SES, SPORT BAGS, TRAVELING TRUNKS, CARRY FOAM, SHAVING FOAM, AFTER SHAVES, FOUN ON BAGS, SHOULDER BAGS, GARMENT BAGS DATION MAKEUP, NAIL POLISH, DEODORANTS FOR TRAVELING, KEY CASES, UMBRELLAS, FOR MEN AND WOMEN, HAND AND BODY PARASOLS, WALKING STICKS, WHIPS, HARNES SOAPS, HAIR SHAMPOOS AND RINSES, HAIR SES, SADDLERY, IN CLASS 18 (U.S. CLS. 1, 2, 3, 22 SPRAY, TOOTHPASTE AND FRAGRANCES, AND 41). NAMELY, PERFUME, TOILET WATER AND ES SENTIAL OILS FOR PERSONAL USE FOR MEN FOR: FURNITURE; MIRRORS, NAMELY, LOOK AND WOMEN, IN CLASS 3 (U.S. CLS. 1, 4, 6, 50, 51 ING GLASSES; PICTURE FRAMES; CHAIRS; CUP AND 52). BOARDS; CUSHIONS; DESKS; DIV ANS; PLASTIC AND WOOD DOORKNOBS; FIGURES OF BONE, FOR: OPTICAL INSTRUMENTS, APPARATUS IVORY, PLASTER, PLASTIC, WAX AND WOOD; AND EQUIPMENT, NAMELY, GLASSES, SUN PLASTIC AND WOOD FURNITURE HANDLES GLASSES, SPECTACLES, SPECTACLE FRAMES, FOR DOORS; MAGAZINE RACKS; OFFICE FUR MONOCLES, LORGNETTES, ACCESSORIES IN NITURE; PILLOWS; PARTS AND FITTINGS FOR THE NATURE OF EYEGLASS CHAINS, AND CASES THE AFORESAID FURNITURE GOODS, NAMELY, FOR GLASSES, SUNGLASSES, SPECTACLES, FITTED FURNITURE COVERS NOT OF PAPER, IN MONOCLES, AND LORGNETTES, IN CLASS 9 CLASS 20 (U.S. CLS. 2, 13, 22, 25, 32 AND 50). (U.S. CLS. 21, 23, 26, 36 AND 38). FOR: FABRIC FOR TEXTILE USE, FABRIC OF FOR: STATIONERY ARTICLES, NAMELY, PA IMITATION ANIMAL SKINS, FABRIC FOR BOOTS PER, LETTER PAPER, LOOSE-LEAF PAPER, EXER AND SHOES, BATH LINEN; BED LINEN; BED CISE BOOKS, ADDRESS BOOKS AND BLANKETS; CURTAINS; UNFITTED FABRIC FUR NOTEBOOKS, REINFORCED STATIONERY TABS NITURE COVERS; HANDKERCHIEFS; KITCHEN THAT ARE MARKED BY NUMBER OR ALPHABE TOWELS, IN CLASS 24 (U.S. CLS. 42 AND 50). TICAL LETTER, ENVELOPES, GREETING CARDS, PHOTOGRAPH ALBUMS; WRITING AND MARK FOR: CLOTHING FOR MEN, WOMEN AND ING INSTRUMENTS, NAMELY, PENS, FELT-TIP CHILDREN, NAMELY, BELTS, COATS, RAIN PED PENS, MARKING PENS, PENCILS AND COATS, WAISTCOATS, BLOUSES AND PULL PENCIL LEADS, INK REFILLS FOR PENS, ERA OVERS, JACKETS, TROUSERS, SKIRTS, DRESSES, SERS; PRINTING TYPE; PRINTED MATTER, SUITS, SHIRTS AND CHEMISES, T-SHIRTS, SWEA NAMELY, PERIODICAL MAGAZINES, BOOKS, TERS, UNDERWEAR, SOCKS AND STOCKINGS,

EXHIBIT D 61 Case 2:19-cv-10074 Document 1-4 Filed 11/25/19 Page 22 of 23 Page ID #:66

GLOVES, TIES, SCARVES, HATS AND CAPS, OWNER OF INTERNATIONAL REGISTRATION BOOTS, SHOES AND SLIPPERS, IN CLASS 25 (U.S. 0922170 DATED 10-10-2006, EXPIRES 10-10-2016. CLS. 22 AND 39).

FOR: LACE AND EMBROIDERY, RIBBONS AND BRAID; CLOTHING BUTTONS, HOOKS AND EYES, SER. NO. 79-037,766, FILED 10-10-2006. SAFETY PINS AND NEEDLES; ARTIFICIAL FLOW- ERS, IN CLASS 26 (U.S. CLS. 37, 39, 40, 42 AND 50).

PRIORITY DATE OF 7-25-2006 IS CLAIMED. SHAILA SETTLES, EXAMINING ATTORNEY

EXHIBIT D 62 Case 2:19-cv-10074 Document 1-4 Filed 11/25/19 Page 23 of 23 Page ID #:67

NOTICE OF RENEWAL OF INTERNATIONAL REGISTRATION

SERIAL NUMBER: 79037766

The table below presents the data as entered.

Input Field Entered INTERNATIONAL REGISTRATION NUMBER 0922170 OFFICE REFERENCE 79037766 INSTRUMENT UNDER WHICH CONTRACTING Protocol PARTY IS DESIGNATED DATE OF RECORDAL IN THE INTERNATIONAL 11/09/2016 REGISTER LATEST DATE OF RENEWAL FOR THE MARK 10/10/2016 IB DOCUMENT ID 1012498901 NEW EXPIRATION DATE 10/10/2026 TRANSACTION TYPE REN - Renewal

EXHIBIT D 63 Case 2:19-cv-10074 Document 1-5 Filed 11/25/19 Page 1 of 14 Page ID #:68

EXHIBIT E Case 2:19-cv-10074 Document 1-5 Filed 11/25/19 Page 2 of 14 Page ID #:69

Fashion Nova Dress Infringing Designs Versace IP Infringed

, • .,. ,.A • - ' ~~ - ~ ~ Barocco - 57 Copyright U.S. Reg. No. VA 2-176-201 (detail)

Barocco - 57 Copyright U.S. Reg. No. VA 2-176-201 (detail)

E.U. Reg. No. 11,566,825

EXHIBIT E 64 Case 2:19-cv-10074 Document 1-5 Filed 11/25/19 Page 3 of 14 Page ID #:70

Fashion Nova Dress Infringing Designs Versace IP Infringed

Greca Design Trademark U.S. Reg. No. 3,194,501

622 Copyright U.S. Reg. No. VA 2-176-199 (registration attached hereto) (detail)

Gold Baroque – 523 Copyright U.S. Reg. No. VA 2-176-205 (registration attached hereto) (detail)

705 Copyright U.S. Reg. No. VA 2-176-545 (registration attached hereto) (detail)

EXHIBIT E 65 Case 2:19-cv-10074 Document 1-5 Filed 11/25/19 Page 4 of 14 Page ID #:71

Fashion Nova Apparel Infringing Designs Versace IP Infringed

Medusa Head & Greca Design Trademark U.S. Reg. No. 1,875,093

Greca Design Trademark U.S. Reg. No. 3,194,501

Greca Circle Design Trademark U.S. Reg. No. 3,199,127

Gold Baroque – 523 Copyright U.S. Reg. No. VA 2-176-205 (detail)

705 Copyright U.S. Reg. No. VA 2-176-545 (detail)

622 Copyright U.S. Reg. No. VA 2-176-199 (detail)

EXHIBIT E 66 Case 2:19-cv-10074 Document 1-5 Filed 11/25/19 Page 5 of 14 Page ID #:72

Fashion Nova Dress Infringing Designs Versace IP Infringed

Medusa Head & Greca Design Trademark U.S. Reg. No. 1,875,093

Greca Design Trademark U.S. Reg. No. 3,194,501

Gold Baroque – 523 Copyright U.S. Reg. No. VA 2-176-205 (detail)

705 Copyright U.S. Reg. No. VA 2-176-545 (detail)

EXHIBIT E 67 Case 2:19-cv-10074 Document 1-5 Filed 11/25/19 Page 6 of 14 Page ID #:73

Fashion Nova Dress Infringing Designs Versace IP Infringed

705 Copyright U.S. Reg. No. VA 2-176-545 (detail)

Gold Baroque – 523 Copyright U.S. Reg. No. VA 2-176-205 (detail)

705 Copyright U.S. Reg. No. VA 2-176-545 (detail)

Gold Baroque – 523 Copyright U.S. Reg. No. VA 2-176-205 (detail)

EXHIBIT E 68 Case 2:19-cv-10074 Document 1-5 Filed 11/25/19 Page 7 of 14 Page ID #:74

Fashion Nova Dress Infringing Designs Versace IP Infringed

705 Copyright U.S. Reg. No. VA 2-176-545 (detail)

Gold Baroque – 523 Copyright U.S. Reg. No. VA 2-176-205 (detail)

705 Copyright U.S. Reg. No. VA 2-176-545 (detail)

Gold Baroque – 523 Copyright U.S. Reg. No. VA 2-176-205 (detail)

EXHIBIT E 69 Case 2:19-cv-10074 Document 1-5 Filed 11/25/19 Page 8 of 14 Page ID #:75

Fashion Nova Dress Infringing Designs Versace IP Infringed

Gold Baroque – 523 Copyright U.S. Reg. No. VA 2-176-205 (detail)

EXHIBIT E 70 Case 2:19-cv-10074 Document 1-5 Filed 11/25/19 Page 9 of 14 Page ID #:76

VA 2il76-199 Eff~cti~e Date-or'Registration: Oct~ber 31, 2019 ~ • ~ ' ~ _, Registration Decifiion'· . Da(e: November 01, 2019· · ,.I

J I \ , l prganizatiQn Name: _ Giahrii Versace I , S.r.I'. - - - - Na1ne: Franc_es.ca Bo,sio - Email: ,. [email protected] ;. ' - -Telephone: +390276093441= ,. Adclress:_, Piazza Einaudi, 4 Milan 20124 Italy- ~,- , -~ -

EXHIBIT E 71 Case 2:19-cv-10074 Document 1-5 Filed 11/25/19 Page 10 of 14 Page ID #:77

EXHIBIT E 72 Case 2:19-cv-10074 Document 1-5 Filed 11/25/19 Page 11 of 14 Page ID #:78

EXHIBIT E 73 Case 2:19-cv-10074 Document 1-5 Filed 11/25/19 Page 12 of 14 Page ID #:79

- Name: Date:

EXHIBIT E 74 Case 2:19-cv-10074 Document 1-5 Filed 11/25/19 Page 13 of 14 Page ID #:80

EXHIBIT E 75 Case 2:19-cv-10074 Document 1-5 Filed 11/25/19 Page 14 of 14 Page ID #:81

EXHIBIT E 76