Professional Documents
Culture Documents
Plaintiffs,
vs.
GDERICK.COM, et al.,
Defendants.
/
THIS MATTER came before the Court on Plaintiffs’ Ex Parte Application for Entry
pursuant to 15 U.S.C. § 1116 and Fed. R. Civ. P. 65, for alleged violations of the
Lanham Act, 15 U.S.C. §§ 1114, and 1125(a) and (d) [D.E. 8]. Because Plaintiffs have
satisfied the requirements for the issuance of a temporary restraining order, the Court
will grant Plaintiffs’ Application for Temporary Restraining Order [D.E. 8] for the reasons
discussed below.
1
Defendants are the Partnerships or Unincorporated Associations identified on
Schedule “A” hereto and Does 1-1,000 (collectively “Defendants”).
Case 0:14-cv-60803-KMW Document 13-4 Entered on FLSD Docket 04/21/2014 Page 2 of 36
I. Factual Background2
trademarks, which are valid and registered on the Principal Register of the United
Registration Registration
Trademark Class(es) / Relevant Goods
Number Date
IC 025 – Shirts For Men, Women and
Children, Sweaters, Tennis Shorts,
October 21,
LACOSTE 0,879,171 Walking Shorts, Socks, Beach Jackets,
1969
Dresses For Women and Children, Swim
Trunks, Caps, Hats, and Skirts.
IC 025 – Men’s, Women’s And Children’s
December 12, Sport Shirts And Sweaters, Men's Socks,
1,108,987
1978 Outer Shorts, Hats and Caps, Women’s
and Children’s Dresses.
IC 009 – Eyeglasses; Sunglasses;
January 26, Eyeglasses and Eyeglass Case Sold as
LACOSTE 1,187,445
1982 Unit, and Sunglasses and Sunglass
Case as Unit.
January 9,
LACOSTE 1,947,111 IC 014 – Watches.
1996
IC 025 – Polo Shirts, Sweatshirts,
Blousons, Shirts, Pants, Shorts, Skirts,
October 1, Dresses, Jogging Suits, Sweaters,
2,004,314
1996 Jackets, Parkas, Headwear, Robes,
Swimwear, Footwear, Socks, Belts,
Gloves.
2
The factual background is taken from Plaintiffs’ Amended Complaint [D.E. 12],
Application for Temporary Restraining Order, Plaintiffs’ Supplemental Brief in Support of
the Application for Temporary Restraining Order [D.E. 13], and supporting evidentiary
submissions. Plaintiffs filed declarations and exhibits annexed in support of their
Application for Temporary Restraining Order. The declarations are available in the
docket at the following entries: Declaration of Erinda Marga [D.E. 8-1], Declaration of
Stephen M. Gaffigan [D.E. 8-4], Declaration of Eric Rosaler [D.E. 8-18], Declaration of
Kathleen Burns [D.E. 8-22], Declaration of Erinda Marga in Support of Supplemental
Brief [D.E. 13-1], and Declaration of Eric Rosaler in Support of Supplemental Brief [D.E.
13-2].
2
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Registration Registration
Trademark Class(es) / Relevant Goods
Number Date
(See Declaration of Erinda Marga [“Marga Decl.”] ¶ 4.) The Lacoste Marks are used in
connection with the manufacture and distribution of high quality goods in the categories
3
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Domain Names and E-Stores”), have advertised, promoted, offered for sale, and/or
sold, at least, shirts, polo shirts, t-shirts, sweaters, blazers, sweatshirts, trousers, track
suits, underwear, dresses, swimwear, such as swim trunks and bikinis, jackets,
headwear, such as caps and hats, sunglasses, tote bags, shoulder bags, wallets, socks,
footwear, such as boots, shoes, and sneakers, and watches, bearing what Plaintiffs
imitations of the Lacoste Marks. (See id. at ¶¶ 10-16; Declaration of Erinda Marga in
3. Although each Defendant may not copy and infringe each Lacoste Mark
for each category of goods protected, Plaintiffs have submitted sufficient evidence
showing each Defendant has infringed, at least, one or more of the Lacoste Marks. (See
Application for Temporary Restraining Order [“Gaffigan Decl.”] ¶ 2-3 and Composite
Exhibit “A” attached thereto; Marga Decl. in Support of Suppl. Brief ¶¶ 5, 8-9.)
Defendants are not now, nor have they ever been, authorized or licensed to use,
Lacoste Marks. (See Marga Decl. ¶ 16; Marga Decl. in Support of Suppl. Brief ¶ 5.)
both licensed private investigative firms, to investigate the sale of counterfeit versions of
Support of Plaintiffs’ Ex Parte Application [“Burns Decl.”] ¶ 3; Marga Decl. ¶ 11; Gaffigan
4
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the Internet website existing under the Subject Domain Name, gderick.com, placed an
order for the purchase of a polo shirt from the website – bearing counterfeits of, at least,
one of the Lacoste Marks at issue in this action – and requested the product be shipped
to his address in the Southern District of Florida. (Rosaler Decl. ¶ 4.) Rosaler finalized
payment for the Lacoste branded polo shirt ordered from gderick.com via PayPal, Inc.
(“PayPal”) to the PayPal account, cassie138@163.com. (Id. and Comp. Ex. A thereto.)
attached hereto as Schedule C (1), and went through the purchasing process3 for a
product that bore counterfeits of, at least, one of the Lacoste Marks at issue in this
action. (See Rosaler Decl. ¶ 5 and Composite Exhibit B thereto.) Following submission
of his order, Rosaler received information for finalizing payment for the item ordered via
operating under the E-Stores, as identified on the table attached hereto as Schedule C
3
Rosaler was instructed to not finalize his purchase from the Internet website operating
under the Subject Domain Name, chaussureessentieltn.com, so as to avoid contributing
funds to Defendants’ coffers. (See Gaffigan Decl. ¶ 4; Rosaler Decl. ¶ 5, n.1.)
5
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(2), and went through the purchasing process4 for various products, all of which bore
counterfeits of, at least, one of the Lacoste Marks at issue in this action. (Id. at ¶ 6 and
information for finalizing payment for each of the various products ordered via PayPal to
id.)
Stores, as identified on the table attached hereto as Schedule C (3), and went through
the purchasing process5 for various products, all of which bore counterfeits of, at least,
one of the Lacoste Marks at issue in this action. (Burns Decl. ¶ 4 and Composite Exhibit
A thereto.) Following submission of her orders, Burns received information for finalizing
payment for each of the various products ordered via PayPal to Defendants’ respective
stores operating under the E-Stores, as identified on the table attached hereto as
Schedule C (4), and went through the purchasing process6 for various products, all of
4
Rosaler was instructed to not finalize his purchases from the majority of the e-
commerce iOffer.com marketplace stores so as to avoid contributing funds to
Defendants' coffers. (See Gaffigan Decl. ¶ 4; Rosaler Decl. ¶ 6, n.3.)
5
Burns intentionally did not finalize her purchases from the e-commerce marketplace
stores so as to avoid contributing funds to Defendants’ coffers. (See Gaffigan Decl. ¶ 4;
Burns Decl. ¶ 4, n.1.)
6
Rosaler was instructed to not finalize his purchases from the majority of the e-
commerce iOffer.com marketplace stores so as to avoid contributing funds to
Defendants' coffers. (Rosaler Decl. in Support of Suppl. Brief ¶ 5.)
6
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which bore counterfeits of, at least, one of the Lacoste Marks at issue in this action.
Following submission of his orders, Rosaler received information for finalizing payment
for each of the various products ordered via PayPal to Defendants’ respective PayPal
branded polo shirt purchased via the Internet website operating under the Subject
Domain Name, gderick.com, and determined the polo shirt was a non-genuine,
Plaintiffs’ representative reviewed and visually inspected the items bearing Plaintiffs’
trademarks offered for sale through each of the Internet websites and e-commerce
iOffer.com and C2Coffer.com marketplace stores operating under the Subject Domain
versions of Plaintiffs’ products. (Marga Decl. ¶¶ 14-16; Marga Decl. in Support of Suppl.
Brief ¶¶ 8-9.)
[there is] a substantial likelihood of success on the merits; (2) that irreparable injury will
be suffered if the relief is not granted; (3) that the threatened injury outweighs the harm
the relief would inflict on the non-movant; and (4) that the entry of the relief would serve
the public interest.” Schiavo ex. rel Schindler v. Schiavo, 403 F.3d 1223, 1225–26 (11th
Cir. 2005); see also Levi Strauss & Co. v. Sunrise Int’l. Trading Inc., 51 F. 3d 982, 985
(11th Cir. 1995) (applying the test to a preliminary injunction in a Lanham Act case).
7
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Additionally, a court may only issue a temporary restraining order without notice to the
serving their underlying purpose of preserving the status quo and preventing irreparable
harm just so long as is necessary to hold a hearing and no longer.” Granny Goose
Foods, Inc. v. Brotherhood of Teamsters & Auto Truck Drivers Local No. 70 of Alameida
III. ANALYSIS
are likely to be confused by Defendants’ advertisement, promotion, sale, offer for sale,
and/or distribution of shirts, polo shirts, t-shirts, sweaters, blazers, sweatshirts, trousers,
track suits, underwear, dresses, swimwear, such as swim trunks and bikinis, jackets,
headwear, such as caps and hats, sunglasses, tote bags, shoulder bags, wallets, socks,
footwear, such as boots, shoes, and sneakers, and watches bearing counterfeits,
reproductions, and/or colorable imitations of the Lacoste Marks, and that the products
Defendants are selling and promoting are copies of Plaintiffs’ products that bear copies
of the Lacoste Marks on shirts, polo shirts, t-shirts, sweaters, blazers, sweatshirts,
trousers, track suits, underwear, dresses, swimwear, such as swim trunks and bikinis,
8
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jackets, headwear, such as caps and hats, sunglasses, tote bags, shoulder bags,
wallets, socks, footwear, such as boots, shoes, and sneakers, and watches.
suffer immediate and irreparable injury if a temporary restraining order is not granted. It
clearly appears from the following specific facts, as set forth in Plaintiffs’ Complaint,
that immediate and irreparable loss, damage, and injury will result to Plaintiffs and to
consumers before Defendants can be heard in opposition unless Plaintiffs’ request for
advertise, promote, offer for sale, and sell, at least shirts, polo shirts, t-shirts, sweaters,
blazers, sweatshirts, trousers, track suits, underwear, dresses, swimwear, such as swim
trunks and bikinis, jackets, headwear, such as caps and hats, sunglasses, tote bags,
shoulder bags, wallets, socks, footwear, such as boots, shoes, and sneakers, and
products bearing Plaintiffs’ trademarks will appear in the marketplace; that consumers
are likely to be misled, confused, and disappointed by the quality of these products; and
that Plaintiffs may suffer loss of sales for their genuine products; and;
Defendants on this Application for Temporary Restraining Order, Defendants can easily
and quickly transfer the registrations for many of the Subject Domain Names, or modify
9
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registration data and content, change hosts, redirect traffic to other websites, and
conceal or transfer their assets, thereby thwarting Plaintiffs’ ability to obtain meaningful
relief;
counterfeit and infringing branded goods if a temporary restraining order is issued is far
order to protect Plaintiffs’ trademark interests and protect the public from being
equitable remedy, the illegal profits gained through Defendants’ distribution and sales of
products bearing counterfeits and infringements of Plaintiffs’ Marks. See Reebok Int’l,
Ltd. v. Marnatech Enters., Inc., 970 F.2d 552, 559 (9th Cir. 1992) (quoting Fuller Brush
Products Co. v. Fuller Brush Co., 299 F.2d 772, 777 (7th Cir. 1962) (“An accounting of
profits under § 1117(a) is not synonymous with an award of monetary damages: ‘[a]n
powers to order preliminary relief, including an asset freeze, in order to assure the
availability of permanent relief.” Levi Strauss & Co. v. Sunrise Int’l Trading Inc., 51 F.3d
982, 987 (11th Cir. 1995) (citing Federal Trade Commission v. United States Oil and
10
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and Defendants’ blatant violation of the federal trademark laws, Plaintiffs have good
reason to believe Defendants will hide or transfer their ill-gotten assets beyond the
IV. CONCLUSION
distributors, and all persons in active concert or participation with any Defendant having
distributors, and all persons in active concert or participation with any Defendant having
notice of this Order shall immediately discontinue the use of the Lacoste Marks or any
owned and operated, or controlled by them including the Internet websites and e-
11
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distributors, and all persons in active concert or participation with any Defendant having
notice of this Order shall immediately discontinue the use of the Lacoste Marks, or any
markers within website source code, from use on any webpage (including as the title of
any web page), any advertising links to other websites, from search engines’ databases
or cache memory, and from any other form of use of such terms which is visible to a
computer user or serves to direct computer searches to websites registered by, owned,
or operated by each Defendant, including the Internet websites operating under the
domain names used and controlled by Defendants 1-2 and 34-137 (collectively the
(4) Each Defendant shall not transfer ownership of the Subject Domain
Names during the pendency of this Action, or until further Order of the Court;
(5) The domain name Registrars for the Subject Domain Names are directed
to transfer to Plaintiffs’ counsel, for deposit with this Court, domain name certificates for
(6) Upon Plaintiffs’ request, the privacy protection service for any Subject
Domain Names for which the Registrant uses such privacy protection service to conceal
the Registrant’s identity and contact information are ordered to disclose to Plaintiffs the
12
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(7) The domain name Registrars for the domain names identified on Schedule
“D” hereto (the “Redirecting Subject Domain Names”) shall immediately assist in
changing the Registrar of record for the Redirecting Subject Domain Names, excepting
any such domain names which such Registrars have been notified in writing by Plaintiffs
have been or will be dismissed from this action, to a holding account with a Registrar of
Plaintiffs’ choosing (the “New Registrar”). To the extent the Registrars do not assist in
changing the Registrars of Record for the domains under their respective control within
one (1) business day of receipt of this Order, the top-level domain (TLD) Registries (or
their administrators) for the Redirecting Subject Domain Names, within five (5) business
days of receipt of this Order, shall, change or assist in changing, the Registrar of record
for the Redirecting Subject Domain Names, excepting any such domain names which
such Registries have been notified in writing by Plaintiffs have been or will be dismissed
from this action, to a holding account with the New Registrar. As a matter of law, this
Order shall no longer apply to any Defendant or associated domain name dismissed
from this action. Upon the change of the Registrar of record for the Redirecting Subject
Domain Names, the New Registrar will maintain access to the Redirecting Subject
Domain Names in trust for the Court during the pendency of this action. Additionally, the
New Registrar shall immediately institute a temporary 302 domain name redirection
which will automatically redirect any visitor to the Redirecting Subject Domain Names to
Temporary Restraining Order, and all other documents on file in this action are
displayed. Alternatively, the New Registrar may update the Domain Name System
13
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(“DNS”) data it maintains for the Redirecting Subject Domain Names, which link the
domain names to the IP addresses where their associated websites are hosted, to
names to resolve to the website where copies of the Complaint, Temporary Restraining
Order, and all other documents on file in this action are displayed. After the New
Registrar has effected this change the Redirecting Subject Domain Names shall be
placed on Lock status, preventing the modification or deletion of the domains by the
(8) Plaintiffs may enter the Redirecting Subject Domain Names into Google’s
Webmaster Tools and cancel any redirection of the domains that have been entered
there by Defendants which redirect traffic to the counterfeit operations to a new domain
name or website;
(9) Each Defendant shall preserve copies of all computer files relating to the
use of any of the Subject Domain Names and E-Stores and shall take all steps
necessary to retrieve computer files relating to the use of the Subject Domain Names
and E-Stores that may have been deleted before the entry of this Order;
(10) Upon receipt of notice of this Order, PayPal, Inc. (“PayPal”)7 and its
related companies and affiliates shall immediately restrain all funds, as opposed to
ongoing account activity, in or which hereafter are transmitted into the PayPal accounts
related to the Defendants and associated e-mail addresses identified on Schedule “B”
7
PayPal is licensed to do business in the State of Florida by the Florida Office of the
Controller and is therefore subject to personal jurisdiction in this Court. (See Gaffigan
Decl. ¶ 9.)
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Account
cassie138@163.com
okbuythem@gmail.com
ratsviyk1@gmail.com
yuedssa@outlook.com
danqing321@126.com
igmhigmh555@126.com
xiangcuaq4466@126.com
xingyunxing456@outlook.com
caiyuangungun001@outlook.com
kjqnqqb@126.com
ganzhe599@hotmail.com
shuguang810@163.com
guonianzhenhao8@163.com
wasdjkmcx@163.com
onlineselling2014@gmail.com
gaiju88@126.com
haoyundaolai@outlook.com
xinxiangshicheng003@outlook.com
laifu789@126.com
rriftghy@126.com
kkk888131@163.com
goodluckwithus369@163.com
haoe88811@163.com
k20003@126.com
guoqingdajia@outlook.com
link3699@163.com
2974149529@qq.com
xianzhushanmiao@126.com
wuhanwuhan001@outlook.com
Elissasparks12@gmail.com
kaixinyongyuan@outlook.com
zhengfang_0930@hotmail.com
dongfangxuri2013@hotmail.com
haonianhua159gg@hotmail.com
wwssy202@163.com
paypal201312@163.com
bestwish3678@163.com
springcomming09@sina.com
bushhh888@163.com
snrt555888@126.com
zclm2001@126.com
wdfhjmkzs@163.com
caiyuangungun003@outlook.com
xinmai789@126.com
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Account
peipei8886666@126.com
songshaodonghaohao@163.com
as well as all funds in or which are transmitted into (i) any other related accounts of the
same customer(s), (ii) any other accounts which transfer funds into the same financial
institution account(s), and/or any of the other PayPal accounts subject to this Order; and
(iii) any other PayPal accounts tied to or used by any of the Subject Domain Names and
(11) PayPal shall also immediately divert to a holding account for the trust of
the Court all funds in all PayPal accounts related to the PayPal account recipients listed
below:
Account
cassie138@163.com
okbuythem@gmail.com
ratsviyk1@gmail.com
yuedssa@outlook.com
danqing321@126.com
igmhigmh555@126.com
xiangcuaq4466@126.com
xingyunxing456@outlook.com
caiyuangungun001@outlook.com
kjqnqqb@126.com
ganzhe599@hotmail.com
shuguang810@163.com
guonianzhenhao8@163.com
wasdjkmcx@163.com
onlineselling2014@gmail.com
gaiju88@126.com
haoyundaolai@outlook.com
xinxiangshicheng003@outlook.com
laifu789@126.com
rriftghy@126.com
kkk888131@163.com
goodluckwithus369@163.com
haoe88811@163.com
k20003@126.com
16
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Account
guoqingdajia@outlook.com
link3699@163.com
2974149529@qq.com
xianzhushanmiao@126.com
wuhanwuhan001@outlook.com
Elissasparks12@gmail.com
kaixinyongyuan@outlook.com
zhengfang_0930@hotmail.com
dongfangxuri2013@hotmail.com
haonianhua159gg@hotmail.com
wwssy202@163.com
paypal201312@163.com
bestwish3678@163.com
springcomming09@sina.com
bushhh888@163.com
snrt555888@126.com
zclm2001@126.com
wdfhjmkzs@163.com
caiyuangungun003@outlook.com
xinmai789@126.com
peipei8886666@126.com
songshaodonghaohao@163.com
and any other related accounts of the same customer(s), as well as any other accounts
that transfer funds into the same financial institution account(s) as any of the other
(12) PayPal shall further, within five business days of receiving this Order,
provide Plaintiffs’ counsel with all data which details (i) an accounting of the total funds
restrained and identifies the PayPal account(s) which the restrained funds are related
to, and (ii) the account transactions related to all funds transmitted into the PayPal
account(s) which have been restrained. Such restraining of the funds and the
disclosure of the related financial institution account information shall be made without
notice to the account owners or the financial institutions until further order of this Court.
PayPal shall receive and maintain this Order and its contents as confidential until further
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order of this Court. No funds restrained by this Order shall be transferred or surrendered
by PayPal for any purpose (other than pursuant to a chargeback made pursuant to
PayPal’s security interest in the funds) without the express authorization of this Court;
(13) This Temporary Restraining Order shall remain in effect until the date for
the hearing on the Motion for Preliminary Injunction set forth below, or until such further
(14) This Temporary Restraining Order shall apply to the Subject Domain
Names, associated websites, E-Stores, and any other domain names, websites, or e-
Court’s attention and verified by affidavit that such new domain names and e-commerce
marketplace stores are being used by Defendants for the purpose of counterfeiting the
Lacoste Marks at issue in this action and/or unfairly competing with Plaintiffs on the
shall post a bond in the amount of Ten Thousand Dollars and Zero Cents ($10,000.00),
or restraint, during the pendency of this action, or until further Order of the Court. In the
Court’s discretion, the bond may be subject to increase should the amount of the funds
(16) A COURT HEARING is set before this Court in the United States
Courthouse located at 400 North Miami Avenue, Miami, Florida, 33128, Courtroom 11-
3, on _______ __, 2014, at ____, or at such other time that this Court deems
appropriate, at which time Defendants and/or any other affected persons may challenge
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the appropriateness of this Order and move to dissolve the same and at which time the
(17) SERVICE: After Plaintiffs’ counsel has received confirmation from PayPal
regarding funds restrained as directed herein, Plaintiffs shall serve a copy of the
Complaint, the Application for Temporary Restraining Order, and this Order, on each
Defendant via the corresponding e-mail addresses provided by Defendants (i) as part of
the domain registration data for each of their respective domain names, or (ii) on their
and the customer service e-mail addresses used to communicate with Plaintiffs’
investigator, which are identified on Schedule “B” hereto, or (iii) on each Defendant via
the online submission forms provided on the Internet websites and e-commerce
Subject Domain Names and E-Stores, and provide a copy of the Order by e-mail to the
registrar of record for each of their respective domain names and e-commerce
calculated to give notice which is permitted by the Court. In addition, Plaintiffs shall post
a copy of the Complaint, the Application for Temporary Restraining Order, and this
Order, as well as all other documents filed in this action on the website located at
of the Redirecting Subject Domain Names being changed to the Court via the New
Registrar’s holding account, and such notice so given shall be deemed good and
sufficient service thereof. Plaintiffs shall continue to provide notice of these proceedings
and copies of the documents on file in this matter to Defendants by regularly updating
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Injunction must be filed and served on Plaintiffs’ counsel by _________, ________ __,
2014, and filed with the Court, along with Proof of Service. Plaintiffs shall file any Reply
Memorandum prior to the hearing scheduled for __________ __, 2014. The above
dates may be revised upon stipulation by all parties and approval of this Court.
Defendants are hereby on notice that failure to appear at the hearing may result in
2014 at ________.
________________________________
KATHLEEN M. WILLIAMS
UNITED STATES DISTRICT JUDGE
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SCHEDULE A
DEFENDANTS BY NUMBER AND
SUBJECT DOMAIN NAMES AND E-STORES
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SCHEDULE “B”
DEFENDANT BY SUBJECT DOMAIN NAMES AND E-STORES
AND ASSOCIATED E-MAIL ADDRESSES
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SCHEDULE “C”
DEFENDANTS’ RESPECTIVE PAYPAL ACCOUNTS
8
Rosaler received information for finalizing his purchasing process via fashion266 using
two different PayPal accounts. (See Rosaler Decl. ¶ 6 n.4.)
9
Rosaler received information for finalizing his purchasing process via styleno1using
two different PayPal accounts. (See Rosaler Decl. ¶ 6 n.5.)
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10
Burns received identical PayPal account information following the purchasing process
via accept2011 and llkkstyle96188. (See Burns Decl. ¶ 4 n.3.)
11
Burns received identical PayPal account information following the purchasing process
via amigoodluck888, flagship2011, and kaitoushun518. (See Burns Decl. ¶ 4 n.4.)
12
Burns received identical PayPal account information following the purchasing process
via becauseofyou and enjoyyourshopping. (See Burns Decl. ¶ 4 n.5.)
13
Burns received identical PayPal account information following the purchasing process
via cheapstore168 and likelegantlive. (See Burns Decl. ¶ 4 n.6.)
14
Burns received identical PayPal account information following the purchasing process
via cheers and happy2013. (See Burns Decl. ¶ 4 n.7.)
15
Burns received identical PayPal account information following the purchasing process
via cnbestwholesale, the best quality, and trustwholesale. (See Burns Decl. ¶ 4 n.8.)
16
Burns received identical PayPal account information following the purchasing process
via qingyuan and shuoshuoma, identifying the PayPal account,
wuhanwuhan001@outlook.com. Burns also received information to finalize the
purchasing process via qingyuan to the PayPal account, Elissasparks12@gmail.com,
and she received information to finalize the purchasing process via shuoshuoma to the
PayPal account, kaixinyongyuan@outlook.com. (See Burns Decl. ¶ 4 n.9.)
32
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17
Burns received information for finalizing the purchasing process via supermarket
using two different PayPal accounts. (See Burns Decl. ¶ 4 n.10.)
18
Burns received information for finalizing the purchasing process via wholesalewatchs
using two different PayPal accounts. (See Burns Decl. ¶ 4 n.11.)
19
Rosaler received identical PayPal account information following the purchasing
process via gdgdiykgn and ftxfgghcn. (See Rosaler Decl. in Support of Suppl. Brief ¶ 4,
n.2.)
33
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SCHEDULE “D”
REDIRECTING SUBJECT DOMAIN NAMES
34
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35
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36