Case 2:10-cv-02040-BBD-tmp Document 30 Filed 11/04/10 Page 1 of 7

THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TENNESSEE
WESTERN DIVISION

CHANEL, INC., )
a New York corporation, )
)
Plaintiff,
)
v. ) Case No. 2:10-cv-02040-BBD-tmp
)
CHAI XUHUI d/b/a WATCHVISA.COM, )
WHOLEWATCHES.COM, )
OVERWATCHES.COM, )
REPLICAME.COM, )
WATCHESMINE.COM, )
WATCHESVIEW.COM, )
WATCHBEEF.COM, BOOTSME.COM, )
AIMBAGS.COM, MYBAGSVIP.COM, )
MINEBAGS.COM, BAGSMINE.COM, )
BAGSHAND.COM, and )
HANDBAGSSELL.COM and DOES 1- )
10, )
Defendants. )

FINAL DEFAULT JUDGMENT AND PERMANENT INJUNCTION

THIS MATTER having come before the Court upon Plaintiff, Chanel, Inc.’s (“Chanel”

or “Plaintiff”) Motion for Final Default Judgment against Defendant Chai Xuxui (the

“Defendant”), and the Court having considered the moving papers and there being no opposition

thereto;

IT IS HEREBY ORDERED that Plaintiff’s Motion for Final Default Judgment is

GRANTED, and judgment is herby entered in favor of Plaintiff, Chanel, Inc, a New York

corporation, with its principal place of business in the United States located at Nine West 57th

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Street, New York, New York 10019, and against Defendant on all Counts of the Complaint as

follows:

(1) Permanent Injunctive Relief:

Defendant and his respective officers, agents, servants, employees, and attorneys, and all

persons acting in concert and participation with him are hereby permanently restrained and

enjoined from:

(a) manufacturing or causing to be manufactured, importing, advertising, or

promoting, distributing, selling or offering to sell counterfeit and

infringing goods using the Chanel Marks;

(b) using the Chanel Marks in connection with the sale of any unauthorized

goods;

(c) using any logo, and/or layout which may be calculated to falsely advertise

the services or products of Defendant offered for sale or sold via the

domain names listed in Schedule “1” annexed hereto (the “Subject

Domain Names”) and/or any other website or business, as being sponsored

by, authorized by, endorsed by, or in any way associated with Plaintiff;

(d) falsely representing himself as being connected with Plaintiff, through

sponsorship or association;

(e) 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

Defendant offered for sale of sold via the Subject Domain Names and/or

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any other website or business are in any way endorsed by, approved by,

and/or associated with Plaintiff;

(f) using any reproduction, counterfeit, copy, or colorable imitation of the

Chanel Marks in connection with the publicity, promotion, sale, or

advertising of any goods sold by Defendant via the Subject Domain

Names and/or any other website or business, including, without limitation,

handbags and watches;

(g) 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 goods offered for sale or

sold by Defendant via the Subject Domain Names and/or any other

website or business, as being those of Plaintiff or in any way endorsed by

Plaintiff;

(h) offering such goods in commerce;

(i) otherwise unfairly competing with Plaintiff;

(j) secreting, destroying, altering, removing, or otherwise dealing with the

unauthorized products or any books or records which contain any

information relating to the importing, manufacturing, producing,

distributing, circulating, selling, marketing, offering for sale, advertising,

promoting, renting or displaying of all unauthorized products which

infringe the Chanel Marks; and

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(k) effecting assignments or transfers, forming new entities or associations or

utilizing any other device for the purpose of circumventing or otherwise

avoiding the prohibitions set forth above.

(2) Additional Equitable Relief:

(l) In order to give practical effect to the Permanent Injunction, the Subject

Domains listed in Schedule “1” annexed hereto are hereby ordered to be

immediately transferred by Defendant, his assignees and/or successors in

interest or title, and the Registrars to Plaintiff’s control. To the extent the

current Registrars do not facilitate the transfer of the domain names to

Plaintiff’s control within ten (10) days of receipt of this judgment, the

United States based Registry shall, within thirty (30) days, transfer the

Subject Domain Names to a United States based Registrar of Plaintiff’s

choosing, and that Registrar shall transfer the Subject Domain Names to

Plaintiff;

(m) Upon Plaintiff’s request, the top level domain (TLD) Registry for the

Subject Domain Names shall place the Subject Domain Names on

Registry Hold status within thirty (30) days of receipt of this Order, thus

removing them from the TLD zone files maintained by the Registry which

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

websites are hosted; and

(n) Upon Plaintiff’s request, Defendant, those acting in concert with him, and

those with notice of the Injunction, including any Internet search engines,

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including Google, Yahoo!, and Bing, Web hosts, domain-name registrars

and domain-name registries that are provided with notice of the

Injunction, shall be and are hereby restrained and enjoined from

facilitating access to any or all websites through which Defendant engages

in the sale of counterfeit and infringing goods using the Chanel Marks.

(3) Statutory damages:

a. Plaintiff is awarded statutory damages against Defendant in the amount of

$132,000.00 pursuant to 15 U.S.C. § 1117(c), for which let execution issue;

(4) Costs of Suit: Plaintiff is awarded costs against Defendant in the amount of

$700.00 pursuant to 15 U.S.C. § 1117(a), for which let execution issue;

(5) Interest from the date this action was filed shall accrue at the legal rate.

IT IS SO ORDERED AND ADJUDGED.

Dated: November 4, 2010 s/Bernice Bouie Donald

HONORABLE BERNICE B. DONALD
UNITED STATES DISTRICT JUDGE

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Schedule “1”

Subject Domain Names

ebao-tesco.com
2010replicawatches.com ebartk.com
360ebagsonline.com ebtuy.com
agosell.com edhappy.com
agowatches.com eewatches.net
aimbags.com elubag.com
amwatches.com eluxuryblog.com
australia-luxury.com eluxzone.com
bagfanszone.com england-luxury.com
bagsabc.com etopclothing.com
bagsal.com evyzu.com
bagshand.com fakehandbags1.com
bagshy.com fantastic-replica.com
bagsla.com fantastic-replica.net
bagsmine.com francebags.com
bagsmix.com francwatches.com
bagsreplicashop.com handbagshot.com
bagsvc.com handbagsmine.com
bagsvendor.com handbagssell.com
bagswatches.com hotwatchsale.com
bagswell.com howvogue.com
bagswholesalemall.com in-watches.com
bootsme.com italywatches.com
brandbagonline.com Itisdesigner.com
brandofshoes.com itisreplica.com
brandwatch168.com iwholesalehandbags.com
buyforhandbags.com jiabob.com
buytopreplica.com jiasell.com
candicedesignerhandbag.com jiasell.net
chanelblog.org kikwatches.com
chanelguccibags.com knockoffsbag.com
chanel-mart.com latestrolex.com
cheap-fakebags.com likereplica.com
chinawholesalegoods.com linkreplica.com
classicalbags.com london-watches.com
designer-handbag-purses.com lowbags.com
designerhandbags2012.com lowhandbags.com
design-luxury.net luxury-french.com
dgjoe.com marisabags.com

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mimiwatches.com sleepwatches.com
mimiwatches.net somewatches.com
minebags.com ssuawd.com
montres-france.net standardwatch.com
mybaghomes.com stuff-buy.com
mybagsvip.com top1watch.com
mylacebags.com top50watches.com
no1replica.net topreplicabag.net
nowwatches.com topreplicawatch.net
oemwatches.com topwatchbrand.com
oiall.com trtime.com
oibns.com trustytime.net
oisell.com uggby.com
overshop.org universal-bags.com
overwatches.com usa-luxury.com
poperwatches.com usa-watch.com
prix-montre.com vip-bags.net
qualityfirstwatch.com voguetrading.com
rasbob.com watch59.com
rbbuy.com watchbeef.com
replicabagcenter.com watches-bags.com
replica-bags1.com watchescentre.com
replica-bags8.com watchesday.com
replicabagwell.com watchesdesk.com
replicabrand.net watchesmine.com
replica-chanel-bags.com watchesorg.com
replica-cheapbags.com watchessell.com
replicaebag.com watchestime.net
replicahandbags-shop.com watchesvia.com
replicame.com watchesview.com
replicamen.com watchvisa.com
replicaswiss.net watchvisa.net
replicawatch567.com weakbuy.com
replika-watch.com weousa.com
robbuy.com westoffer.com
robbuy.net wholesales-handbags.com
rubyashop.com wholewatches.com
searchingbag.com wowboots.com
seawatches.com wto-sell.com
sellergoods.com Memphis 1882541v1
shopbei.com
shopping-replica.com
sisterbagz.com