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THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF FLORIDA

CHANEL, INC., a New York corporation,

Plaintiff,

vs.

THE PARTNERSHIPS and

UNINCORPORATED ASSOCIATIONSIDENTIFIED ON SCHEDULE A and

DOES 1-1000,

Defendants.

/

COMPLAINT FOR INJUNCTIVE RELIEF

Plaintiff, CHANEL, INC. (Chanel), a New York corporation, (Plaintiff or Chanel)

hereby sues Defendants THE PARTNERSHIPS and UNINCORPORATED ASSOCIATIONS

IDENTIFIED ON SCHEDULE A and DOES 1-1,000 (collectively Defendants) and alleges

as follows:

JURISDICTION AND VENUE

1. This is an action pursuant to 15 U.S.C. 1114, 1116, 1121 and 1125(a) and (d)and The All Writs Act, 28 U.S.C 1651(a). Accordingly, this Court has subject matter

jurisdiction under 28 U.S.C. 1331 and 1338. This Court has supplemental jurisdiction

pursuant to 28 U.S.C. 1367 over Chanels state law claims because those claims are so related

to the federal claims that they form part of the same case or controversy.

2. Venue is proper in this Court pursuant 28 U.S.C. 1391, and this Court mayproperly exercise personal jurisdiction over Defendants since all Defendants directly target

business activities towards consumers in Florida and cause harm to Chanels business within this

Case 1:13-cv-21684-XXXX Document 1 Entered on FLSD Docket 05/09/2013 Page 1 of 26

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District through, at least, various fully interactive Internet websites, including those operating

under their partnership and/or unincorporated association names (the Subject Domain Names).

THE PLAINTIFF

3. Chanel is a corporation duly organized under the laws of the State of New Yorkwith its principal place of business in the United States located at Nine West 57th Street, New

York, New York 10019. Chanel operates boutiques throughout the world, including within this

Judicial District. Chanel is, in part, engaged in the business of manufacturing and distributing

throughout the world, including within this Judicial District, a variety of high quality luxury

goods, including, but not limited to, handbags, wallets, shoes, boots, sunglasses, belts,

swimwear, cosmetics, protective covers for portable electronic devices, including cell phones,

watches, and costume jewelry, including necklaces, bracelets, and earrings under multiple world

famous common law and Federally registered trademarks including those identified in Paragraph

16 below. Chanel offers for sale and sells its trademarked goods within this Judicial District.

Defendants sales of counterfeit and infringing Chanel branded products are causing damage to

Chanel within this Jurisdiction. Chanel regularly enforces its intellectual property rights and

authorized that this action be brought in its name.

4. Like many other famous trademark owners in the luxury goods market, Chanelsuffers ongoing daily and sustained violations of its trademark rights at the hands of

counterfeiters and infringers, such as the Defendants herein, who wrongfully reproduce and

counterfeit Chanels trademarks for the twin purposes of (i) duping and confusing the consuming

public and (ii) earning substantial profits.

5. In order to combat the harm caused by the combined actions of Defendants andothers engaging in similar conduct, each year Chanel expends millions of dollars in connection


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with trademark enforcement efforts, including legal fees, investigative fees, and support

mechanisms for law enforcement, such as field training guides and seminars. The recent

explosion of counterfeiting over the Internet has created an environment which requires Chanel

to file a massive number of lawsuits, often it later turns out, against the same individuals and

groups, in order to protect both consumers and itself from the ill effects of confusion and the

erosion of the goodwill connected to the Chanel brand. The financial burden on Chanel and

companies similarly situated is staggering, as is the resulting burden on the Federal court system.

THE DEFENDANTS

6.

Defendants are partnerships or unincorporated business associations which

operate through domain names registered with registrars in multiple countries and are comprised

of individuals and/or business entities of unknown makeup, many of whom likely reside and/or

operate in the Peoples Republic of China or other foreign jurisdictions with lax trademark

enforcement systems. Defendants have the capacity to be sued pursuant to Federal Rule of Civil

Procedure 17(b). Defendants target their business activities towards consumers throughout the

United States, including within this Judicial District through the operation of the fully interactive

commercial websites operating under the Subject Domain Names identified on Schedule A

hereto.

7. Defendants are directly and personally contributing to, inducing and engaging inthe sale of counterfeit products as alleged herein, often times as partners, co-conspirators and/or

suppliers.

8. Defendants are part of an ongoing conspiracy to create and maintain an illegalmarketplace enterprise on the World Wide Web, the purposes of which are to (i) confuse

consumers regarding the source of the Defendants goods for profit, and (ii) expand the


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marketplace for illegal, counterfeit Chanel branded goods while shrinking the legitimate

marketplace for genuine Chanel goods. The natural and intended byproduct of Defendants

actions is the erosion and destruction of the overall marketplace in which Chanel operates and

the goodwill associated with the Chanel name and associated trademarks.

9. The partnerships or unincorporated association names used by Defendants are setforth on Schedule A hereto. Chanel is presently unaware of the true names of Does 1-1,000.

Chanel will move to amend this Complaint upon discovery of the identities of such fictitious

Defendants.

10.

Defendants are the past and present moving and conscious forces behind the

operation of the commercial Internet websites operating under the Subject Domain Names.

11. Defendants directly engage in unfair competition with Chanel by (i) offering forsale and selling counterfeit and infringing Chanel branded products within this Judicial District

through multiple commercial websites operating under the Subject Domain Names and

additional domain names not yet known to Plaintiff and (ii) creating and maintaining an illegal

marketplace enterprise for the purpose of diverting business from Chanels legitimate

marketplace for its genuine goods. Defendants have purposefully directed their illegal activities

towards consumers in the State of Florida through the advertisement, offer to sell, sale, and

shipment of counterfeit Chanel branded goods into the State and by operating an illegal

marketplace enterprise which impacts and interferes with commerce throughout the United

States, including within the State of Florida.

12. Upon information and belief, Defendants will continue to register or acquire newdomain names for the purpose of selling goods bearing counterfeits and infringements of

Chanels trademarks unless preliminarily and permanently enjoined. Moreover, upon


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information and belief, the Defendants and their coconspirators will continue to maintain and

grow their illegal marketplace enterprise at Chanels expense unless preliminarily and

permanently enjoined.

13. Defendants Internet-based website businesses and associated marketplaceamount to nothing more than massive illegal operations, infringing on the intellectual property

rights of Chanel and others.

14. Defendants use and have registered, established or purchased and\or maintainedthe Subject Domain Names. Upon information and belief, Defendants have engaged in

fraudulent conduct with respect to the registration of the Subject Domain Names by providing

false and/or misleading information to their various Registrars during the Registration or

maintenance process. Upon information and belief, many of the Defendants have anonymously

registered and maintained some of the Subject Domain Names for the sole purpose of engaging

in illegal counterfeiting activities.

15. Defendants business names, i.e., the Subject Domain Names and any otherdomain names used in connection with the sale of counterfeits bearing Chanels trademarks, are

essential components of Defendants counterfeiting and infringing activities. The Subject

Domain Names themselves are a significant part of the means by which Defendants further their

counterfeiting and infringing scheme and cause harm to Chanel. Moreover, Defendants are using

Chanels famous name and trademarks to drive Internet consumer traffic to their websites

operating under the Subject Domain Names, thereby creating and increasing the value of the

Subject Domain Names at Chanels expense.

COMMON FACTUAL ALLEGATIONS

Plaintiffs Trademark Rights


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16. Chanel is and at all times relevant hereto has been, the owner of all rights in andto the following trademarks, which are valid and registered on the Principal Register of the

United States Patent and Trademark Office (collectively the Chanel Marks):

TrademarkRegistration

Number

Registration

DateClasses/Goods

CHANEL0,612,169

September 13,1955

IC 014 Necklaces

CHANEL0,626,035 May 1, 1956 IC 018 Womens Handbags

CHANEL0,902,190

November 10,1970

IC 014 - Bracelets, Pins, and Earrings

CHANEL0,915,139 June 15, 1971 IC 025 - Women's Shoes

CHANEL0,955,074

March 13,

1973IC 014 Watches

CHANEL1,241,265 June 7, 1983

IC 025 - Suits, Jackets, Skirts, Dresses,Pants, Blouses, Tunics, Sweaters,

Cardigans, Coats, Raincoats, Scarves,

Shoes and Boots

1,314,511January 15,

1985IC 018 - Leather Goods-Namely,Handbags

CHANEL1,347,677 July 9, 1985

IC 018 - Leather Goods-namely,Handbags

1,501,898August 30,

1988

IC 006 Keychains

IC 014 - Costume Jewelry

IC 016 - Gift Wrapping Paper


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IC 025 -Blouses, Shoes, Belts,

Scarves, Jackets, Men's Ties

IC 026 Brooches and Buttons forClothing

CHANEL1,510,757

November 1,

1988IC 009 Sunglasses

CHANEL1,733,051

November 17,

1992

IC 018 - Leather Goods; namely,Handbags, Wallets, Travel Bags,

Luggage, Business and Credit Card

Cases, Change Purses, Tote Bags,Cosmetic Bags Sold Empty, and

Garment Bags for Travel

1,734,822November 24,

1992

IC 018 - Leather Goods; namely,Handbags, Wallets, Travel Bags,

Luggage, Business Card Cases,Change Purses, Tote Bags, and

Cosmetic Bags Sold Empty

3,025,934December 13,

2005IC 018 Handbags

CHANEL3,133,139

August 22,

2006

IC 014 - Jewelry and Watches

4,074,269December 20,

2011

IC 009 - Protective covers for portable

electronic devices, handheld digital

devices, personal computers and cellphones

IC 016 - Temporary tattoos

IC 018 - Key cases

J12 2,559,772 April 9, 2002 IC 009 - Timepieces; namely, watches,and parts thereof

3,025,936December 13,

2005

IC 009 - Eyeglass frames, sunglasses.

IC 025 - Gloves, swimwear

IC 026 - Hair accessories, namely,


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barrettes

1,654,252

August 20,

1991 IC 009 Sunglasses

CHANEL1,348,842 July 16, 1985

IC 003 Perfumery, Cosmetics andToiletries

1,347,094 July 9, 1985IC 003 Perfumery, Cosmetics and

Toiletries

CHANEL

0,195,360

February 24,

1925

IC 003 - Face Powder, Perfume, Eau

De Cologne, Toilet Water, Lip Stick,and Rouge

17. The Chanel Marks are used in connection with the manufacture and distributionof quality goods in the categories identified above.

18. The Chanel Marks have been used in interstate commerce to identify anddistinguish Chanel's high quality handbags, wallets, shoes, boots, sunglasses, belts, swimwear,

cosmetics, protective covers for portable electronic devices, including cell phones, watches,

costume jewelry, including necklaces, bracelets, and earrings, and other goods for an extended

period of time.

19. The Chanel Marks have never been assigned or licensed to any of the Defendantsin this matter.

20. The Chanel Marks are symbols of Chanel's quality, reputation and goodwill andhave never been abandoned.


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21. Further, Chanel has expended substantial time, money and other resourcesdeveloping, advertising and otherwise promoting the Chanel Marks. The Chanel Marks qualify

as famous marks as that term is used in 15 U.S.C. 1125(c)(1).

22. Chanel has extensively used, advertised and promoted the Chanel Marks in theUnited States in association with the sale of high quality handbags, wallets, shoes, boots,

sunglasses, belts, swimwear, cosmetics, protective covers for portable electronic devices,

including cell phones, watches, costume jewelry, including necklaces, bracelets, and earrings,

and other goods and has carefully monitored and policed the use of the Chanel Marks.

23.

As a result of Chanels efforts, members of the consuming public readily identify

merchandise bearing the Chanel Marks, as being high quality goods sponsored and approved by

Chanel.

24. Accordingly, the Chanel Marks have achieved secondary meaning as identifiersof high quality handbags, wallets, shoes, boots, sunglasses, belts, swimwear, cosmetics,

protective covers for portable electronic devices, including cell phones, watches, costume

jewelry, including necklaces, bracelets, and earrings, and other goods.

25. Genuine Chanel branded goods are widely legitimately advertised and promotedby Chanel and unrelated third parties via the Internet. Over the course of the past five to seven

years, visibility on the Internet, particularly via Internet search engines such as Google, Yahoo!,

and Bing has become increasingly important to Chanels overall marketing and consumer

education efforts. Thus, Chanel expends significant monetary resources on Internet marketing

and consumer education, including search engine optimization (SEO) strategies. Those

strategies allow Chanel to fairly and legitimately educate consumers about the value associated

with the Chanel brand and the goods sold thereunder. SEO is a now common marketing process


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whereby a company or individual designs, supports, structures and phrases Internet website

content in order to enhance a websites profile for search engines over a variety of search terms.

Defendants Infringing Acts

26. Upon information and belief, at all times relevant hereto, Defendants in this actionhave had full knowledge of Chanels ownership of the Chanel Marks, including its exclusive

right to use and license such intellectual property and the goodwill associated therewith.

27. Chanel has discovered Defendants are promoting and otherwise advertising,distributing, selling and/or offering for sale counterfeit products, including, at least, handbags,

wallets, shoes, boots, sunglasses, belts, swimwear, cosmetics, protective covers for portable

electronic devices, including cell phones, watches, and costume jewelry, including necklaces,

bracelets, and earrings, bearing marks which are exact copies or colorable imitations of the

Chanel Marks (the Defendants Goods). Specifically, upon information and belief, Defendants

are using the Chanel Marks for different quality goods.

28. The Defendants Goods are of a quality substantially different than that ofChanels genuine goods. Despite the nature of the Defendants Goods and the knowledge they

are without authority to do so, Defendants are actively using, promoting and otherwise

advertising, distributing, selling and/or offering for sale substantial quantities of such goods with

the knowledge that such goods will be mistaken for the genuine high quality products offered for

sale by Chanel. The net effect of Defendants actions will be to result in the confusion of

consumers at the time of initial interest, sale, and in the post-sale setting, who will believe

Defendants Goods are genuine goods originating from, associated with, and approved by

Chanel.


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29. Defendants advertise their products for sale to the consuming public. In soadvertising these products, Defendants improperly and unlawfully use the Chanel Marks. Upon

information and belief, the misappropriation of the Chanel Marks has been the proximate cause

of harm to Chanel.

30. As part of their overall infringement and counterfeiting scheme, the Defendantsare, upon information and belief, all employing substantially similar, and often times

coordinated, paid advertising and SEO strategies based, in large measure, upon an illegal use of

counterfeits and infringements of the Chanel Marks. Specifically, the Defendants are using

counterfeits of Chanels name and the Chanel Marks in order to make their websites selling

illegal goods appear more relevant and attractive to search engines across an array of search

terms. By their actions, the Defendants have created an illegal marketplace operating in parallel

to the legitimate marketplace for genuine Chanel goods. Defendants are causing concurrent and

indivisible harm to Chanel and the consuming public by (i) depriving Chanel and other third

parties of the ability to fairly compete for space within search engine results, (ii) causing an

overall degradation of the value of the goodwill associated with the Chanel Marks, (iii)

increasing Chanels overall cost to market its goods and educate consumers about the brand via

the Internet and (iv) maintaining an illegal marketplace enterprise which perpetuates the ability

of Defendants and future entrants to that marketplace to confuse consumers and harm Chanel

with impunity.

31. Upon information and belief, Defendants are concurrently conducting theircounterfeiting and infringing activities, at least, within this Judicial District and elsewhere

throughout the United States. As a result, Defendants are defrauding Chanel and the consuming

public for Defendants own benefit. Defendants infringement and disparagement of Chanel does


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not simply amount to the wrong description of their goods or the failure of the goods to conform

to the advertised quality or performance.

32. Defendants use of the Chanel Marks, including the promotion and advertisement,reproduction, distribution, sale, and offering for sale of Defendants Goods, is without Chanels

consent or authorization.

33. Further, Defendants are engaging in the above-described illegal counterfeiting andinfringing activities knowingly and intentionally or with reckless disregard or willful blindness to

Chanels rights for the purpose of trading on the goodwill and reputation of Chanel.

34.

Defendants above-identified infringing activities are likely to cause confusion,

deception and mistake in the minds of consumers, the public and the trade. Moreover,

Defendants wrongful use of the Chanel Marks is likely to create a false impression and deceive

customers, the public and the trade into believing there is a connection or association between

Chanel and Defendants Goods.

35. Chanel has no adequate remedy at law.36. Chanel is suffering irreparable and indivisible injury and damages as a result of

Defendants unauthorized and wrongful use of the Chanel Marks. If Defendants counterfeiting,

infringing, and unfairly competitive activities and their illegal marketplace enterprise are not

preliminarily and permanently enjoined by this Court, Chanel and the consuming public will

continue to be harmed.

37. The injuries and damages sustained by Chanel have been directly and proximatelycaused by Defendants wrongful reproduction, use, advertisement, promotion, offering to sell,

and sale of the Defendants Goods and by the creation, maintenance and very existence of the

Defendants illegal marketplace enterprise.


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38. Chanel has retained the undersigned counsel to represent it in this matter and isobligated to pay said counsel a reasonable fee for such representation.

COUNT I - TRADEMARK COUNTERFEITING AND INFRINGEMENT

39. Chanel hereby adopts and re-alleges the allegations set forth in Paragraphs 1through 38 above.

40. This is an action for trademark counterfeiting and infringement againstDefendants based on their use of counterfeits, copies, and/or colorable imitations of the Chanel

Marks in commerce in connection with the promotion, advertisement, distribution, sale and/or

offering for sale of the Defendants Goods.

41. Specifically, Defendants are promoting and otherwise advertising, selling,offering for sale and distributing, at least, counterfeit and/or infringing handbags, wallets, shoes,

boots, sunglasses, belts, swimwear, cosmetics, protective covers for portable electronic devices,

including cell phones, watches, and costume jewelry, including necklaces, bracelets, and earrings

bearing the Chanel Marks. Defendants are continuously infringing and inducing others to

infringe the Chanel Marks by using them to advertise, promote and sell, at least, counterfeit

and/or infringing handbags, wallets, shoes, boots, sunglasses, belts, swimwear, cosmetics,

protective covers for portable electronic devices, including cell phones, watches, and costume

jewelry, including necklaces, bracelets, and earrings.

42. Defendants concurrent counterfeiting, infringing, and unfairly competitiveactivities are likely to cause and, upon information and belief, actually are causing confusion,

mistake and deception among members of the trade and the general consuming public as to the

origin and quality of Defendants Goods bearing or sold using the Chanel Marks.


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43. Defendants unlawful actions have caused and are continuing to causeunquantifiable and irreparable harm to Chanel.

44. Defendants above-described illegal actions constitute counterfeiting andinfringement of the Chanel Marks in violation of Chanels rights under 32 of the Lanham Act,

15 U.S.C. 1114.

45. Chanel has suffered and will continue to suffer irreparable injury due to the abovedescribed activities of Defendants if Defendants are not preliminarily and permanently enjoined.

COUNT II - FALSE DESIGNATION OF ORIGIN

PURSUANT TO 43(a) OF THE LANHAM ACT


47. Defendants Goods bearing and sold under the Chanel Marks have been widelyadvertised and distributed throughout the United States.

48. Defendants Goods bearing and sold under the Chanel Marks are virtuallyidentical in appearance to each of Chanels genuine goods. However, the Defendants Goods are

different in quality. Accordingly, Defendants activities are likely to cause confusion in the trade

and among the general public as to at least the origin or sponsorship of the Defendants Goods.

49. Defendants, upon information and belief, have used in connection with theiradvertisement and sale of products, false designations of origins and false descriptions and

representations, including words or other symbols and trade dress which tend to falsely describe

or represent such goods and have caused such goods to enter into commerce with full knowledge

of the falsity of such designations of origin and such descriptions and representations, all to the

detriment of Chanel.


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50. Specifically, Defendants have authorized an infringing use of the Chanel Marks,in Defendants advertisement and promotion of their counterfeit and infringing handbags,

wallets, shoes, boots, sunglasses, belts, swimwear, cosmetics, protective covers for portable

electronic devices, including cell phones, watches, and costume jewelry, including necklaces,

bracelets, and earrings. Defendants have also misrepresented to members of the consuming

public that the products being advertised and sold by them are genuine, non-infringing products.

51. Additionally, Defendants are using counterfeits and infringements of the ChanelMarks in order to unfairly compete with Chanel and others for space within search engine

organic results, thereby jointly depriving Chanel of a valuable marketing and educational tool

which would otherwise be available to Chanel.

52. Defendants above-described actions are in violation of Section 43(a) of theLanham Act, 15 U.S.C. 1125(a).

53. Chanel has sustained indivisible injury and harm caused by Defendantsconcurrent conduct, and absent an entry of an injunction by this Court, Chanel will continue to

suffer irreparable injury to its goodwill and business reputation as well as monetary damages.

COUNT III - CLAIM FOR RELIEF FOR CYBERSQUATTING

UNDER 43(d) OF THE LANHAM ACTION, 15 U.S.C. 1125(d)


55. At all times relevant hereto, Chanel has been and still is the owner of the rights,title and interest in and to the Chanel Marks.

56. Upon information and belief, Defendants have acted with the bad faith intent toprofit from the Chanel Marks and the goodwill associated with the Chanel Marks by registering


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various domain names which are identical or confusingly similar to or dilutive of the Chanel

Marks.

57. Defendants have no intellectual property rights in or to the Chanel Marks.58. Defendants actions constitute cybersquatting in violation of 43(d) of the

Lanham Act, 15 U.S.C. 1125(d).

59. Defendants conduct is done with knowledge and constitutes a willful violation ofChanels rights in the Marks. At a minimum, Defendants conduct constitutes reckless disregard

for and willful blindness to Chanels rights.

60.

The aforesaid conduct is causing Chanel damages and immediate and irreparable

injury. Chanel has no adequate remedy at law.

COUNT IV - COMMON LAW UNFAIR COMPETITION


62. This is an action against Defendants based on their (i) manufacture, promotion,advertisement, distribution, sale and/or offering for sale of goods bearing marks which are

virtually identical, both visually and phonetically, to the Chanel Marks, and (ii) creation and

maintenance of an illegal, ongoing marketplace enterprise operating in parallel to the legitimate

marketplace in which Chanel sells its genuine goods, in violation of Floridas common law of

unfair competition.

63. Specifically, the Defendants are promoting and otherwise advertising, selling,offering for sale and distributing infringing and counterfeit handbags, wallets, shoes, boots,

sunglasses, belts, swimwear, cosmetics, protective covers for portable electronic devices,

including cell phones, watches, and costume jewelry, including necklaces, bracelets, and


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earrings. The Defendants are also using counterfeits and infringements of the Chanel Marks to

unfairly compete with Chanel and others for space in search engine results across an array of

search terms and within the World Wide Web in general.

64. Defendants infringing activities are likely to cause and actually are causingconfusion, mistake and deception among members of the trade and the general consuming public

as to the origin and quality of Defendants products by their use of the Chanel Marks.

65. Chanel has no adequate remedy at law and is suffering and irreparable injury as aresult of Defendants' actions.

PRAYER FOR RELIEF

66. WHEREFORE, Chanel demands judgment on all Counts of this Complaint andentry of an award of equitable relief against Defendants as follows:

a. Entry of preliminary and permanent injunction pursuant to Federal Rule ofCivil Procedure 65 enjoining Defendants, their agents, representatives, servants, employees, and

all those acting in concert or participation therewith, from manufacturing or causing to be

manufactured, importing, advertising or promoting, distributing, selling or offering to sell the

Defendants Goods; from infringing, counterfeiting, or diluting the Chanel Marks; from using the

Chanel Marks, or any mark or trade dress similar thereto, in connection with the sale of any

unauthorized goods; from using any logo, trade name or trademark or trade dress which may be

calculated to falsely advertise the services or products of Defendants as being sponsored by,

authorized by, endorsed by, or in any way associated with Chanel; from falsely representing

themselves as being connected with Chanel, through sponsorship or association, or engaging in

any act which is likely to falsely cause members of the trade and/or of the purchasing public to

believe any goods or services of Defendants, or in any way endorsed by, approved by, and/or


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associated with Chanel; from using any reproduction, counterfeit, infringement, copy, or

colorable imitation of the Chanel Marks in connection with the publicity, promotion, sale, or

advertising of any goods sold by Defendants, including, without limitation, handbags, wallets,

shoes, boots, sunglasses, belts, swimwear, cosmetics, protective covers for portable electronic

devices, including cell phones, watches, or costume jewelry, including necklaces, bracelets, and

earrings; from affixing, applying, annexing or using in connection with the sale of any goods, a

false description or representation, including words or other symbols tending to falsely describe

or represent Defendants goods as being those of Chanel, or in any way endorsed by Chanel and

from offering such goods in commerce; from engaging in search engine optimization strategies

using colorable imitations of the Chanel name or Marks; and from otherwise unfairly competing

with Chanel.

b. Entry of a preliminary and permanent injunction pursuant to 28 U.S.C1651(a), The All Writs Act, enjoining Defendants and all third parties from creating,

maintaining, operating, joining, participating in, including providing financial, technical or other

support to, the World Wide Web based illegal marketplace conspiracy to market, offer for sale,

sell or distribute non-genuine goods bearing counterfeits of the Chanel marks.

c. Entry of an Order that, upon Chanels request, those in privity withDefendants and those with notice of the injunction, including any Internet search engines, Web

hosts, domain-name registrars and domain-name registries or their administrators that are

provided with notice of the injunction, cease facilitating access to any or all domain names and

websites through which Defendants engage in the sale of counterfeit and infringing goods using

the Chanel Marks.


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d. Entry of an Order that, upon Chanels request, the top level domain (TLD)Registries for the Subject Domain Names and their administrators place the Subject Domain

Names on Registry Hold status, thus removing them from the TLD zone files maintained by the

Registries which link the Subject Domain Names to the IP addresses where the associated

websites are hosted.

e. Entry of an order canceling or, at Chanels election, transferring the

Subject Domain Names and any other domain names used by the Defendants to engage in their

counterfeiting of the Chanel Marks at issue to Chanels control so they may no longer be used

for illegal purposes.

f. Entry of an order that, upon Chanels request, the Internet Corporation for

Assigned Names and Numbers (ICANN) shall take all actions necessary to ensure that the

Registrars and the top level domain Registries responsible for the Subject Domain Names

transfer, change the Registrar of Record, and/or disable the Subject Domain Names as directed

by the Court.

g. Entry of an award of Chanels costs and reasonable attorneys fees andinvestigative fees associated with bringing this action.

h. Entry of further relief as the Court may deem just and proper.DATED: May 9, 2013. Respectfully submitted,

STEPHEN M. GAFFIGAN, P.A.

By: ____s:/smgaffigan/__________

Stephen M. Gaffigan (Fla. Bar No. 025844)Virgilio Gigante (Fla. Bar No. 082635)

401 East Las Olas Blvd., #130-453

Ft. Lauderdale, Florida 33301

Telephone: (954) 767-4819Facsimile: (954) 767-4821

E-mail: [email protected]


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E-mail: [email protected]

Attorneys for Plaintiff

CHANEL, INC.


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SCHEDULE A

DEFENDANTS BY SUBJECT DOMAIN NAMES AND DEFENDANT NUMBER

Defendant No. Domain Name

1 aaaluxurybelt.com

1 bags1stcity.com1 brandhandbagsshophere.co.uk

1 chanelastore.com

1 chanelbagsonline-outlet.com

1 chanelbagsuk2013.co.uk

1 chanelfemme.com

1 chanel-outlet-store.org

1 chanelpascherfr.org

1 chanelreplica.me.uk

1 chanelshop001.com

1 chanelshop002.com

1 chanelshop003.com1 chanelsreplicabagshandbags.com

1 chanelstore001.com



1 channnelbags.com

1 designbagsonline.com

1 discountluxuryhandbags.org

1 fakechanelbags2u.biz

1 fakechanelbagsreplica.biz

1 fakechanelsunglasses4sale.biz

1 fakechanelsunglassescheap.biz

1 fashionbrandhandbags.com

1 godisfashion.com

1 handbagoutlet.net

1 handbagsqueen.com

1 online-handbags.biz

1 purses-love.com

1 replicaahandbags.com

1 replicabagsboutique.com

1 replicabagsok.com

1 replicahandbags2u.net1 replicahandbagse.com

1 replicaschanelbagshandbags.com

1 replicawatchonline.com

1 top-chaneloutlet.com

1 top-chaneloutletus.com

1 vipshoesstore.com

1 vogueladies.biz


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2 chaneljapan2013.biz

2 chaneljapansale.biz

2 chanelonlinesale.biz

2 chaneloutlets.biz

2 chanelsale2013.biz

2 luxurywatch-cheapwatches.com3 gafaschanelshops.com

3 gafasschanelshops.com

4 modechaneloutlet.com

4 modechanelreplica.com

4 vipchaneloutlet.com

5 chanelok.com

5 chanelok.net

6 genuinechaneloutletshop.com

6 vipchaneloutlethandbags.com

7 chanelbagsukonlineshop.com

7 chanelhandbagbagsoutlet.com7 chanelhandbagsoutlet2013.net

7 cheapchanelpursesoutlet.net

7 outletchanelbagssale.net

8 designerhandbagspaypal.com

9 nikenettrade.com

9 nikesearcher.com

11 chanlemyloveboutique.com

11 nicechanelhome.com

12 chanel-onlineshop.info

12 chanelpascher.info

12 chanel-sacs.info

12 chaneltaschen.info

13 chanelbagsus2013.com

13 chanelsreplicahandbags.org

14 ewantbuymore.eu

14 newitisbags.eu

15 fashionbuy.us

15 stomarate.com

16 ereplicashop.com

16 hotsaleclan.com

17 chanelphonecase.com17 designerbagsfake.org

17 macmakeupwholesales.net

17 uscocobagsxoutetstores.info

18 finechanelgirlstore.com

18 lunetteschanelsoldes.com

18 outletchanelgirlsales.com

19 gggtrade.net


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19 outlet66.com

19 productsstore2012.com

20 chanelbagssn.info

20 cheapbagsoutletonline.com

21 2013chanelbags.org

22 2013chaneljapan.com23 2013replicachanel.com

24 360shopwiki.com

25 aaachanelstore.com

26 aaahandbagstore.com

27 bagorder.com

28 bags-chanel-outlet-uk.com

29 bagscoupons-2013.com

30 bestsunglassesmall.com

31 besttopmall.com

31 topshopol.com

32 bossesmalls.com33 brandbagzone.com

34 brandjewel.net

35 buychanelwatch.org

36 buywatchbuy.com

37 chanel-arena.com

38 chanelbagdiscount.co.uk

39 chanelbagsfashion.com

40 chanelbagsjpbagu.com

41 chanelbagsok.com

42 chanelbagsonlinestore.co.uk

43 chanelbagsoutleti.com

44 chanelbagsoutletonsale.org

45 chanelbagsoutlett.co.uk

46 chanelbagsoutletuk.org

47 chanelbagssales-online.com

48 chanelbolsos.com

49 chanelbrandjapan.com

50 chanelhandbagsretail.com

51 chanelhandbagssales.co.uk

52 chanelja.biz

53 chanel-janpan.com54 chaneljapanoutlet.com

55 chanellhandbags.com

56 chanelmisejp.com

57 chanelonlinereplica.com

58 chanelonrain.com

59 chaneloutletfor.com

60 chaneloutletstore.info


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61 chanel-rakutens.com

62 chanelstores.com

63 chanelvipboutique.com

64 chanoutletjp.com

65 charm-jewellery.com

66 cheapchanelbagsforsales.com67 cheapchanelbagsinuk.com

68 cheapchanelonline.net

69 cheapchaneloutlet2013.com

70 cheapcocobags.com

71 cheapdesignerhandbag.us

72 cheapreplicadesignerbags.com

73 designerbagfake.com

74 designerbags-shopping.com

75 designerhandbagsstock.com

76 discounbags.net

77 etopshop.com78 fashionbagcn.com

79 fashionbagsuk.com

80 getchanelhandbagsoutles.org

81 handbagluxurysale.com

82 handbags86.com

83 handbags-bags-store.org

84 icon-chanel-outlet.com

85 japan-chanelforbags.com

86 jpchanelhandbag-store2013.com

87 justpurse.com

88 knockoffhandbagsonsale.net

89 knockoffhandbagssale.com

90 latestchaneljp.com

91 likereplicas.com

92 lovechanel2013.com

93 lovechanelja.com

94 luxury-boots.com

95 lywatches.com

96 modechanelbags.com

97 modechanelpurses.com

98 mostbag.com99 mylittlesecretpurse.asia

100 needswisswatches.com

101 newoftenbags.com

102 nyuse.com

103 phoenix-handbag.com

104 reglasses.com

105 replicabagoutlet.com


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106 replicablogs.com

107 replicadesignerbagsoutlet.com

108 replica-luxury-watch.com

109 replicaschaneluk.co.uk

110 reproductionwatchesol.com

111 sacchanelfrpaccher.com112 saleschanelbags.com

113 shoes-pumps.com

114 sinowatches.net

115 specialchaneloutletjp.com

116 swissreplicawatcheshop.com

117 tobuybuy.com

118 topstoreol.com

119 ubeautystyle.com

120 uchanelus.com

121 vipchaneloutletforbags.com

122 vipjewelrymall.com123 wholesalebagus.com

124 wholesale-luxury.net

125 wholesalem.com

126 yrcorps.com

127 2013chanelonline.co.uk

128 watches-great.com

128 watches-shopping-watches.com

129 chanelbagsoutleto.info

129 chanelfactoryoutleto.info

129 chanelhandbagsoutleto.info

129 chaneloutletstoreo.info

130 chanelcheapsjapans.com

130 chanelshopsjapans.com

130 cocochaneljapans.com

131 wowreplica.net

131 wowreplicabag.com

132 chaneloutletbagsch.co.uk

132 fakechanelbagsuk.co.uk

133 fakechanelonline.com

133 fakechanelonsale.com

134 chanelshoppingpoint.com134 topchanelstore.com

135 sunglassesfree.com

136 luxurybagsonsale.org

137 hot-replicahandbags.com

138 chan1elonline-outlet.com

139 owngoodbags.com

140 chanel-online--shop.org


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141 designerbagss-sale.com

142 eluxury.me

143 wansacs.com

144 designerbagsdeal.com

145 fakeschanel.com

146 weewatches.net147 authenticbagsofchanel.com

148 replica3.net

149 authenticchanelbagsaut.co.uk

150 chanelhandbagscha.co.uk


001 - Complaint

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