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Case 0:18-Cv-62790-DPG Document 1-1 Entered on FLSD Docket 11/16/2018 Page 1 of 1 Case 0:18-Cv-62790-DPG Document 1 Entered on FLSD Docket 11/16/2018 Page 1 of 63

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Case 0:18-Cv-62790-DPG Document 1-1 Entered on FLSD Docket 11/16/2018 Page 1 of 1 Case 0:18-Cv-62790-DPG Document 1 Entered on FLSD Docket 11/16/2018 Page 1 of 63 Case 0:18-cv-62790-DPG Document 1-1 Entered on FLSD Docket 11/16/2018 Page 1 of 1 Case 0:18-cv-62790-DPG Document 1 Entered on FLSD Docket 11/16/2018 Page 1 of 63 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA AUDEMARS PIGUET HOLDING SA, BREITLING U.S.A. INC., CHANEL, INC., GUCCI AMERICA, INC., HENRI STERN WATCH AGENCY, INC., HUBLOT SA, GENÈVE, COMPAGNIE DES MONTRES LONGINES, FRANCILLON S.A., MOVADO LLC, OMEGA SA, RADO UHREN AG, TURLEN HOLDING SA, and LVMH SWISS MANUFACTURES SA, Plaintiffs, vs. BLUELANS, CHENGLIAN, CRAZY STORE, ENGHUANIU, ETHEREAL, EVERGRAND, FASHION&PRETTY, FLEECEBOO, GUOMIAOMIAO1314, HERUN INDUSTRIAL CO., LTD., ZHEJIANG, JIANGLINA, JIANGQIONG STORE, JINGJIANSTORE, MENGHONGYAN, MINGXINGBIAOYEYOUXIANGONGSI, MONTH CLOUD, ROADTOALLWAYS, SHENZHENSHIQINGMEIKEJIYOUXIANGONGSI, SHIXIN888999666, SILVER CHINESE, TOPBIRDY, WEIYE, XINLINGZHONGBIAO, YICHENG TESCO, GOD BLESS US & MY TIME ZONE STORE, MY TIME ZONE, WATCHESTIME, BEST4CHOOSE, CORPOR2008, GUDAOXIAGU-0, JOFTBENN7, KHER6424, MIKI2016, SPRINGENN, FAFAFA8886, KISSCOME0411, LEEHOMWANG, PAYCAY, VIVAQ8, WRISTWATCHESHERE, ZHIMAKAIHUA2015, BAGAHOLICS20000, BESTWATCHES88, HB_LUXURY_BAGS, HYPE_REPLUG, LUXURY_BAG_SHOES_SHOP, LUXURYBRAND.FACTORY1314, LUXURYGIRL9328, MSHOP8_TEL_89516445438, ROLEXFULLDIAMANTES, ROLEXWATCH2018, WATCH_HAPPENS, WATCHESPAGES, PHAN.OFFICIAL9 a/k/a PHANOFFICIAL.COM, XFASHION_BOUTIQUE222 a/k/a KINGLUXURY222.COM, CLASSEMPORIUM.COM, and SWISSREPLICAWATCHESININDIA.COM, each an Individual, Partnership, Business Entity, or Unincorporated Association, Defendants. / COMPLAINT FOR DAMAGES AND INJUNCTIVE RELIEF Plaintiffs, Audemars Piguet Holding SA, Breitling U.S.A. Inc., Chanel, Inc., Gucci America, Inc., Henri Stern Watch Agency, Inc., Hublot SA, Genève, Compagnie des Montres Longines, Francillon S.A., Movado LLC, Omega SA, Rado Uhren AG, Turlen Holding SA, and Case 0:18-cv-62790-DPG Document 1 Entered on FLSD Docket 11/16/2018 Page 2 of 63 LVMH Swiss Manufactures SA (collectively “Plaintiffs”), hereby sue Defendants, individuals, partnerships, business entities, or unincorporated associations identified in the caption, which are set forth on Schedule “A” hereto (collectively “Defendants”). Defendants are promoting, selling, offering for sale and/or distributing goods bearing counterfeits and confusingly similar imitations of Plaintiffs’ respective trademarks within this district through at least the Internet based e- commerce stores, social media accounts, and commercial Internet website operating under their seller identities and domain names identified on Schedule “A” hereto (the “Seller IDs and Subject Domain Names”). In support of their claims, Plaintiffs allege as follows: JURISDICTION AND VENUE 1. This is an action for federal trademark counterfeiting and infringement, false designation of origin, common law unfair competition, and common law trademark infringement, pursuant to 15 U.S.C. §§ 1114, 1116, and 1125(a), The All Writs Act, 28 U.S.C. § 1651(a), and Florida’s common law. Accordingly, this Court has subject matter jurisdiction over this action pursuant to 15 U.S.C. § 1121 and 28 U.S.C. §§ 1331 and 1338. This Court has supplemental jurisdiction pursuant to 28 U.S.C. § 1367 over Plaintiffs’ state law claims because those claims are so related to the federal claims that they form part of the same case or controversy. 2. Defendants are subject to personal jurisdiction in this district, because they direct business activities toward and conduct business with consumers throughout the United States, including within the State of Florida and this district through at least the Internet based e- commerce stores, social media accounts, or fully interactive commercial Internet websites accessible in Florida and operating under the Seller IDs and Subject Domain Names. 2 Case 0:18-cv-62790-DPG Document 1 Entered on FLSD Docket 11/16/2018 Page 3 of 63 3. Venue is proper in this Court pursuant to 28 U.S.C. § 1391 since Defendants are, upon information and belief, aliens engaged in infringing activities and causing harm within this district by advertising, offering to sell, selling, and/or shipping infringing products into this district. THE PLAINTIFFS 4. Audemars Piguet Holding SA (“Audemars Piguet”) is a societe anonyme organized under the laws of Switzerland, having its principal office in Le Brassus, Switzerland. Audemars Piguet, through and in connection with related companies, designs, manufactures, markets, and sells watches and related goods throughout the world, including within this district, under multiple world-famous common law and federally registered trademarks including the trademarks identified in Schule “B” hereto. 5. Breitling U.S.A. Inc. (“Breitling USA”), is a corporation organized and existing under the laws of the State of Connecticut with its principal place of business in the United States in Wilton, Connecticut. Breitling USA is a subsidiary of Breitling SA, a corporation organized and existing under the laws of Switzerland. Breitling SA designs, manufactures, markets, and sells Breitling branded watches and related goods. Breitling USA is the exclusive distributor of Breitling brand watches in the United States. Breitling USA and Breitling SA are collectively referred to herein as “Breitling.” Breitling designs, manufactures, markets, and sells watches and related goods throughout the world, including this district, under multiple world- famous common law and federally registered trademarks including the trademarks identified in Schedule “C” hereto. 6. Chanel, Inc. (“Chanel”) is a corporation organized under the laws of the State of New York with its principal place of business in the United States in New York, New York. 3 Case 0:18-cv-62790-DPG Document 1 Entered on FLSD Docket 11/16/2018 Page 4 of 63 Chanel is, in part, engaged in the business of manufacturing and distributing throughout the world, including within this district, a variety of high quality luxury goods, including watches and related goods, under multiple world famous common law and federally registered trademarks, including those identified in Schedule “D” hereto. 7. Gucci America, Inc. (“Gucci”) is a corporation organized and existing under the laws of the State of New York with its principal place of business in New York, New York. Gucci is, in part, engaged in the business of manufacturing and distributing throughout the world, including within this district, a variety of high quality luxury goods, including watches and related goods, under multiple world-famous common law and federally registered trademarks, including those identified in Schedule “E” hereto. 8. Henri Stern Watch Agency, Inc. (“Henri Stern”) is a corporation organized and existing under the laws of the State of New York with its principal place of business in the United States New York, New York. Henri Stern is a subsidiary of Patek Philippe SA Geneve, a societe anonyme organized under the laws of Switzerland. Patek Philippe SA Geneve designs, develops, and markets Patek Philippe brand watches and related goods. Henri Stern is the exclusive importer and distributor of Patek Philippe brand watches in the United States. Patek Philippe SA Geneve and Henri Stern are collectively referred to herein as “Patek Philippe.” Patek Philippe designs, develops, markets, and sells watches and related goods throughout the world, including within this district, under multiple world-famous common law and federally registered trademarks including the trademarks identified in Schedule “F” hereto. 9. Hublot SA, Genève (“Hublot”) is a societe anonyme organized under the laws of Switzerland with a principal place of business in Geneve, Switzerland. Hublot, through and in connection with related companies, designs, manufactures, markets, and sells watches and 4 Case 0:18-cv-62790-DPG Document 1 Entered on FLSD Docket 11/16/2018 Page 5 of 63 related goods throughout the world, including within this district, under multiple world-famous common law and federally registered trademarks including the trademarks identified in Schedule “G” hereto. 10. Compagnie des Montres Longines, Francillon S.A. (“Longines”) is a corporation organized and existing under the laws of Switzerland with its principal place of business located in Saint-Imier, Switzerland. Longines manufactures, markets, and sells watches and related goods throughout the world, including within this district, under multiple world-famous common law and federally registered trademarks including the trademarks identified in Schedule “H” hereto 11. Movado LLC (“Movado”) is a limited liability company organized under the laws of the State of Delaware with its principal place of business in the United States in Wilmington, Delaware. Movado, through and in connection with related companies, manufactures, markets, and sells watches and related goods throughout the world, including within this district, under multiple world-famous common law and federally registered trademarks including the trademarks identified in Schule “I” hereto 12. Omega SA (“Omega”) is a societe anonyme organized under the laws of Switzerland with its principal place of business located in Bienne, Switzerland. Omega manufactures, markets, and sells watches and related goods throughout the world, including within this district, under multiple world-famous common law and federally registered trademarks including the trademarks identified in Schedule “J” hereto. 13. Rado Uhren AG (“Rado”) is a corporation organized and existing under the laws of Switzerland with its principal place
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