2within this District through, at least, various fully interactive Internet websites, including thoseoperating under the Subject Domain Names. Defendants have also advertised and, uponinformation and belief, made sales and shipped infringing products into this judicial district.
Louis Vuitton is a corporation organized under the laws of the Republic of Francewith its principal place of business located in the Paris, France. Louis Vuitton operates boutiquesthroughout the world, including within this Judicial District. Louis Vuitton is, in part, engaged inthe business of manufacturing and distributing throughout the world, including within thisJudicial District, a variety of high quality luxury goods, including, but not limited to, handbags,wallets, shoes, belts, sunglasses, watches, and jewelry, under multiple world famous commonlaw and Federally registered trademarks including those identified in Paragraph 13 below. LouisVuitton offers for sale and sells its trademarked goods within this Judicial District. Defendants’sales of counterfeit and infringing Louis Vuitton branded products are causing damage to LouisVuitton within this Jurisdiction.4.
Like many other famous trademark owners in the luxury goods sector, LouisVuitton suffers ongoing daily and sustained violations of its trademark rights at the hands of counterfeiters and infringers, such as the Defendants herein, who wrongfully reproduce andcounterfeit Louis Vuitton’s trademarks for the twin purposes of (i) duping and confusing theconsuming public and (ii) earning substantial profits. The natural and intended byproduct of Defendants’ actions is the erosion and destruction of the overall luxury goods marketplace inwhich Louis Vuitton operates and the goodwill associated with the Louis Vuitton name andassociated trademarks and the destruction of the legitimate market sector in which they operate.
Case 1:12-cv-21778-PAS Document 1 Entered on FLSD Docket 05/10/2012 Page 2 of 33