United States District Court Southern District of Florida Case No. Richemont International Sa, Cartier International A.G., Montb
Case 0:16-cv-62612-BB Document 1 Entered on FLSD Docket 11/03/2016 Page 1 of 44 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. RICHEMONT INTERNATIONAL SA, CARTIER INTERNATIONAL A.G., MONTBLANC-SIMPLO GMBH, CHLOE S.A.S., and OFFICINE PANERAI A.G., Plaintiffs, vs. THE INDIVIDUALS, PARTNERSHIPS, AND UNINCORPORATED ASSOCIATIONS IDENTIFIED ON SCHEDULE “A,” Defendants. / COMPLAINT FOR INJUNCTIVE RELIEF AND DAMAGES Plaintiffs, Richemont International SA, Cartier International A.G., Montblanc-Simplo GMBH, Chloe S.A.S., and Officine Panerai A.G. (collectively “Plaintiffs”),1 hereby sue Defendants, the Individuals, Partnerships and Unincorporated Associations identified on Schedule “A” hereto (collectively “Defendants”). Defendants are promoting, selling, offering for sale and distributing goods using counterfeits and confusingly similar imitations of Plaintiffs’ respective trademarks within this district through various fully interactive commercial Internet websites operating under their individual, partnership, and/or business association names identified on Schedule “A” hereto (the “Subject Domain Names”). In support of their claims, Plaintiffs allege as follows: 1 Plaintiffs are all subsidiaries of Compagnie Financière Richemont SA, which is one of the world’s leading luxury goods groups. Case 0:16-cv-62612-BB Document 1 Entered on FLSD Docket 11/03/2016 Page 2 of 44 JURISDICTION AND VENUE 1. This is an action for federal trademark counterfeiting and infringement, false designation of origin, cybersquatting, common law unfair competition, and common law trademark infringement pursuant to 15 U.S.C. §§ 1114, 1116, 1125(a), and 1125(d), and The All Writs Act, 28 U.S.C. § 1651(a). Accordingly, this Court has subject matter jurisdiction over this action pursuant to 15 U.S.C.
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