-RJJ Louis Vuitton Malletier, S.A. v. 1854louisvuitton.com et al, No. 2:2011cv00738 - Document 65 (D. Nev. 2011)
Court Description: TEMPORARY RESTRAINING ORDER Granting 62 Motion for Temporary Restraining Order and Order Setting Deadlines re: 63 Motion for Preliminary Injunction. Responses due by 1/3/2012. Motion Hearing set for 1/4/2012 09:30 AM in LV Courtroom 7C before Judge Philip M. Pro. Signed by Judge Philip M. Pro on 12/22/11. (Copies have been distributed pursuant to the NEF - ASB)
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-RJJ Louis Vuitton Malletier, S.A. v. 1854louisvuitton.com et al Doc. 65 Case 2:11-cv-00738-PMP -RJJ Document 63-1 (Ex Parte) 1 2 3 4 5 6 7 8 9 Filed 12/22/11 Page 1 of 12 Ryan E. Johnson Nevada Bar # 9070 The Law Office of WATSON ROUNDS 10000 West Charleston Blvd., Suite 240 Las Vegas, NV 89135 Telephone: (702) 636-4902 Facsimile: (702) 636-4904 rjohnson@watsonrounds.com Stephen M. Gaffigan (Admitted Pro Hac Vice) STEPHEN M. GAFFIGAN, P.A. 401 East Las Olas Blvd., Suite 130-453 Ft. Lauderdale, Florida 33301 Telephone: (954) 767-4819 Facsimile: (954) 767-4821 stephen@smgpa.net 10 11 Attorneys for Plaintiff LOUIS VUITTON MALLETIER, S.A. 12 THE UNITED STATES DISTRICT COURT 13 FOR THE DISTRICT OF NEVADA 14 15 LOUIS VUITTON MALLETIER, S.A., a foreign business entity, 16 Plaintiff, 17 v. 18 19 20 1854LOUISVUITTON.COM, et al., Defendants. ) ) ) ) ) ) ) ) ) ) ) Case No. 2:11-cv-00738-PMP-RJJ PROPOSED] ORDER GRANTING PLAINTIFF’S SECOND EX PARTE APPLICATION FOR ENTRY OF TEMPORARY RESTRAINING ORDER AND PRELIMINARY INJUNCTION 21 THIS CAUSE is before the Court on Plaintiff’s Second Ex Parte Application For Entry of a 22 Temporary Restraining Order and Preliminary Injunction (the “Second Application for TRO”). 23 Plaintiff, Louis Vuitton Malletier, S.A. (“Plaintiff” or “Louis Vuitton”), moves, on an ex parte basis, 24 for entry of a temporary restraining order, and, upon expiration of the temporary restraining order, a 25 preliminary injunction against Defendants 183-222, the Partnerships and Unincorporated 26 Associations identified on Schedule “A” attached hereto (“Defendants 183-222”), pursuant to 15 27 28 1 ________________________________________________________________________________ [PROPOSED] ORDER GRANTING PLAINTIFF’S SECOND EX PARTE APPLICATION FOR ENTRY OF TEMPORARY RESTRAINING ORDER Dockets.Justia.com Case 2:11-cv-00738-PMP -RJJ Document 63-1 (Ex Parte) Filed 12/22/11 Page 2 of 12 1 U.S.C. § 1116 and Fed. R. Civ. P. 65 for alleged violations of the Lanham Act, 15 U.S.C. §§ 1114, 2 and 1125(a) and (d). 3 For reasons set forth herein, Plaintiff’s Second Application for TRO is GRANTED. I. 4 Factual Background 5 The Court bases this Second Temporary Restraining Order on the following facts from 6 Plaintiff’s First Amended Complaint, Application for TRO, Second Application for TRO and 7 supporting evidentiary submissions on file in this action. 8 Louis Vuitton is a corporation duly organized under the laws of The Republic of France with 9 its principal place of business located in the Paris, France. (First Amended Compl. ¶ 3.) Louis 10 Vuitton operates boutiques throughout the world, including within this Judicial District. See id. 11 Louis Vuitton is, in part, engaged in the business of manufacturing and distributing throughout the 12 world, including within this Judicial District, a variety of high quality luxury goods. (Declaration of 13 Nikolay Livadkin in Support of Plaintiff’s Second Ex Parte Application for TRO [“Livadkin Second 14 Decl.”] ¶ 5.) 15 Louis Vuitton is, and at all times relevant hereto has been, the owner of all rights in and to 16 the following trademarks: 17 Trademark Registration No. Registration Date 0,297,594 September 20, 1932 1,045,932 August 10, 1976 20 1,519,828 January 10, 1989 21 1,938,808 November 28, 1995 1,990,760 August 6, 1996 23 2,177,828 August 4, 1998 24 2,181,753 August 18, 1998 25 2,361,695 June 27, 2000 2,378,388 August 22, 2000 2,399,161 October 31, 2000 18 19 22 26 27 28 LOUIS VUITTON LOUIS VUITTON LOUIS VUITTON PARIS 2 _________________________________________________________________________________ [PROPOSED] ORDER GRANTING PLAINTIFF’S SECOND EX PARTE APPLICATION FOR ENTRY OF TEMPORARY RESTRAINING ORDER Case 2:11-cv-00738-PMP -RJJ Document 63-1 (Ex Parte) Filed 12/22/11 Page 3 of 12 1 2,421,618 January 16, 2001 2 2,773,107 October 14, 2003 3 3,023,930 December 6, 2005 4 3,051,235 January 24, 2006 5 3,021,231 November 29, 2005 6 (the “Louis Vuitton Marks”) which are registered on the Principal Register of the United States 7 Patent and Trademark Office and are used in connection with the manufacture and distribution of 8 high quality goods in the categories identified above. (Livadkin Second Decl. ¶ 5; see also United 9 States Trademark Registrations of the Louis Vuitton Marks at issue [“Louis Vuitton Trademark 10 Registrations”] attached as Exhibit A to the Livadkin Second Decl.). 11 Defendants 183-222, via the domain names identified on Schedule “A” hereto (the “Group II 12 Subject Domain Names”) have advertised, promoted, offered for sale, and/or sold, at least, 13 handbags, wallets, luggage, shoes, belts, scarves, sunglasses, charms, watches, and jewelry bearing 14 what Plaintiff has determined to be counterfeits, infringements, reproductions, and/or colorable 15 imitations of the Louis Vuitton Marks. Although each of the Defendants may not copy and infringe 16 each Louis Vuitton Mark for each category of goods protected, Louis Vuitton has submitted 17 sufficient evidence showing each Defendant has infringed, at least, one or more of the Louis Vuitton 18 Marks. (Livadkin Second Decl. ¶¶ 11-15; Declaration of Brandon Tanori in Support of Plaintiff’s 19 Second Ex Parte Application for Entry of Temporary Restraining Order and Preliminary Injunction 20 [“Tanori Second Decl.”] ¶ 4; Declaration of Stephen M. Gaffigan in Support of Plaintiff’s Second Ex 21 Parte Application for Entry of Temporary Restraining Order and Preliminary Injunction [“Gaffigan 22 Second Decl.”] ¶ 3 and Composite Exhibit B attached thereto.) Defendants 183-222 are not now, 23 nor have they ever been, authorized or licensed to use, reproduce, or make counterfeits, 24 infringements, reproductions, and/or colorable imitations of the Louis Vuitton Marks. (Livadkin 25 Second Decl. ¶ 9.) 26 Plaintiff’s counsel retained Brandon Tanori (“Tanori”) of Investigative Consultants, a 27 licensed private investigative firm, to investigate suspected sales of counterfeit Louis Vuitton 28 3 _________________________________________________________________________________ [PROPOSED] ORDER GRANTING PLAINTIFF’S SECOND EX PARTE APPLICATION FOR ENTRY OF TEMPORARY RESTRAINING ORDER Case 2:11-cv-00738-PMP -RJJ Document 63-1 (Ex Parte) Filed 12/22/11 Page 4 of 12 1 branded products by Defendants 183-222. (Livadkin Second Decl. ¶ 10; Tanori Second Decl. ¶ 3.) 2 On November 18, 2011, Tanori accessed the Internet websites operating under the three of the 3 domain names at issue in this action, handbag-brandreplica.com, replicalouisvuitton.org, and 4 replicalouisvuittonoutlets.com, placed orders for the purchase of various Louis Vuitton branded 5 products, including charms, a handbag, and a wallet, and requested each product purchased be 6 shipped to his address in Las Vegas, Nevada. (Tanori Second Decl. ¶ 4 and Composite Exhibit A 7 attached thereto.) Tanori’s purchases were processed entirely online, which included providing 8 shipping and billing information, payment, and confirmation of his orders. (Tanori Second Decl. ¶ 4 9 and Composite Exhibit A attached thereto.) 10 Thereafter, a representative of Louis Vuitton, Nikolay Livadkin, reviewed and visually 11 inspected the web page listings, including images, for each of the Louis Vuitton branded goods 12 purchased by Tanori and determined the items were non-genuine Louis Vuitton products. (Livadkin 13 Second Decl. ¶¶ 11-12, 15.) Additionally, Livadkin reviewed and visually inspected the items 14 bearing the Louis Vuitton Marks offered for sale via the Internet websites operating under the 15 partnership and/or unincorporated association names identified on Schedule “A” hereto, the “Group 16 II Subject Domain Names,” and determined the products were non-genuine Louis Vuitton products. 17 (Livadkin Second Decl. ¶¶ 13-15 and Composite Exhibit B attached thereto; Gaffigan Second Decl. 18 ¶ 3 and Composite Exhibit B attached thereto.) II. 19 20 21 22 Conclusions of Law The declarations Plaintiff submitted in support of its Second Application for TRO support the following conclusions of law: A. Plaintiff has a very strong probability of proving at trial that consumers are likely to 23 be confused by the Defendants 183-222’s advertisement, promotion, sale, offer for sale, and/or 24 distribution of handbags, wallets, luggage, shoes, belts, scarves, sunglasses, charms, watches, and 25 jewelry bearing counterfeits, infringements, reproductions, and/or colorable imitations of the Louis 26 Vuitton Marks, and that the products Defendants 183-222 are selling are copies of Plaintiff’s 27 products that bear marks which are substantially indistinguishable from and/or colorful imitations of 28 4 _________________________________________________________________________________ [PROPOSED] ORDER GRANTING PLAINTIFF’S SECOND EX PARTE APPLICATION FOR ENTRY OF TEMPORARY RESTRAINING ORDER Case 2:11-cv-00738-PMP -RJJ Document 63-1 (Ex Parte) Filed 12/22/11 Page 5 of 12 1 the Louis Vuitton Marks on handbags, wallets, luggage, shoes, belts, scarves, sunglasses, charms, 2 watches, and jewelry. Because of the infringement of the Louis Vuitton Marks, Plaintiff is likely to 3 suffer immediate and irreparable injury if a temporary restraining order is not granted. It clearly 4 appears from the following specific facts, as set forth in Plaintiff’s First Amended Complaint, 5 Plaintiff’s Second Application for TRO, and accompanying declarations on file, that immediate and 6 irreparable loss, damage, and injury will result to Plaintiff and to consumers before Defendants 183- 7 222 can be heard in opposition unless Plaintiff’s request for ex parte relief is granted: 8 1. Defendants 183-222 own or control Internet business operations which 9 advertise, promote, offer for sale, and sell, at least, handbags, wallets, luggage, shoes, belts, scarves, 10 sunglasses, charms, watches, and jewelry bearing counterfeit and infringing trademarks in violation 11 of Plaintiff’s rights; 12 2. There is good cause to believe that more counterfeit and infringing handbags, 13 wallets, luggage, shoes, belts, scarves, sunglasses, charms, watches, and jewelry bearing Plaintiff’s 14 trademarks will appear in the marketplace; that consumers may be misled, confused, and 15 disappointed by the quality of these products; and that Plaintiff may suffer loss of sales for its 16 genuine products; 17 3. There is good cause to believe that if Plaintiff proceeds with normal advance 18 notice to Defendants 183-222 on this Second Application for TRO, Defendants 183-222 can easily 19 and quickly transfer the registrations for many of the Group II Subject Domain Names, or modify 20 registration data and content, change hosts, and redirect traffic to other websites, thereby thwarting 21 Plaintiff’s ability to obtain meaningful relief; 22 4. The balance of potential harm to Defendants 183-222 in restraining their trade 23 in counterfeit and infringing branded goods if a temporary restraining order is issued is far 24 outweighed by the potential harm to Plaintiff, its reputation and goodwill as a manufacturer of high 25 quality handbags, wallets, luggage, shoes, belts, scarves, sunglasses, charms, watches, and jewelry if 26 such relief is not issued; and 27 28 5 _________________________________________________________________________________ [PROPOSED] ORDER GRANTING PLAINTIFF’S SECOND EX PARTE APPLICATION FOR ENTRY OF TEMPORARY RESTRAINING ORDER Case 2:11-cv-00738-PMP -RJJ Document 63-1 (Ex Parte) 5. 1 Filed 12/22/11 Page 6 of 12 The public interest favors issuance of a temporary restraining order in order to 2 protect Plaintiff’s trademark interests and to protect the public from being defrauded by the palming 3 off of counterfeit goods as genuine goods of the Plaintiff. 4 5 6 7 Upon review of Plaintiff’s First Amended Complaint, Second Application for TRO, and supporting evidentiary submissions, it is hereby ORDERED that Plaintiff’s Second Application for TRO is GRANTED, according to the terms set forth below: SECOND TEMPORARY RESTRAINING ORDER 8 9 (1) Defendants 183-222, their officers, directors, employees, agents, subsidiaries, 10 distributors, and all persons in active concert or participation with Defendants 183-222 having notice 11 of this Second Temporary Restraining Order are hereby temporarily restrained: (a) 12 From manufacturing, importing, advertising, promoting, offering to sell, 13 selling, distributing, or transferring any products bearing the Louis Vuitton 14 Marks, or any confusingly similar trademarks, other than those actually 15 manufactured or distributed by Plaintiff; and (b) 16 From secreting, concealing, destroying, selling off, transferring, or otherwise 17 disposing of: (i) any products, not manufactured or distributed by Plaintiff, 18 bearing the Louis Vuitton Marks, or any confusingly similar trademarks; or 19 (ii) any evidence relating to the manufacture, importation, sale, offer for sale, 20 distribution, or transfer of any products bearing the Louis Vuitton Marks, or 21 any confusingly similar trademarks. 22 (2) Defendants 183-222, their officers, directors, employees, agents, subsidiaries, 23 distributors, and all persons in active concert or participation with Defendants 183-222 having notice 24 of this Second Temporary Restraining Order shall immediately discontinue the use of the Louis 25 Vuitton Marks or any confusingly similar trademarks, on or in connection with all Internet websites 26 owned and operated, or controlled by them including the Internet websites operating under the 27 Group II Subject Domain Names; 28 6 _________________________________________________________________________________ [PROPOSED] ORDER GRANTING PLAINTIFF’S SECOND EX PARTE APPLICATION FOR ENTRY OF TEMPORARY RESTRAINING ORDER Case 2:11-cv-00738-PMP -RJJ Document 63-1 (Ex Parte) 1 (3) Filed 12/22/11 Page 7 of 12 Defendants 183-222, their officers, directors, employees, agents, subsidiaries, 2 distributors, and all persons in active concert or participation with Defendants 183-222 having notice 3 of this Second Temporary Restraining Order shall immediately discontinue the use of the Louis 4 Vuitton Marks, or any confusingly similar trademarks within domain name extensions, metatags or 5 other markers within website source code, from use on any webpage (including as the title of any 6 web page), any advertising links to other websites, from search engines’ databases or cache memory, 7 and any other form of use of such terms which is visible to a computer user or serves to direct 8 computer searches to websites registered by, owned, or operated by Defendants 183-222, including 9 the Internet websites operating under the Group II Subject Domain Names; 10 11 12 (4) Defendants 183-222 shall not transfer ownership of the Group II Subject Domain Names during the pendency of this Action, or until further Order of the Court; (5) Upon entry of this Order, Plaintiff shall provide a copy of the Order by email to the 13 Registrar of record for each of the Group II Subject Domain Names, so that the Registrar of record 14 of each of the Group II Subject Domain Names may, in turn, notify each registrant of the Order and 15 provide notice of the locking of the domain name to the registrant of record. After providing such 16 notice to the Registrars so the domain names may be locked, Plaintiff shall also provide notice and a 17 copy of this Order to the registrant of each Group II Subject Domain Name via email to the email 18 address provided as part of the domain registration data for each of the Group II Subject Domain 19 Names identified in Composite Exhibit C to the Declaration of Stephen M. Gaffigan in Support of 20 the Second Application for TRO. If an email address was not provided as part of the domain 21 registration data for a Group II Subject Domain Name, Plaintiff shall provide notice and a copy of 22 this Order to the operators of the Internet websites via the email addresses and/or online submissions 23 forms provided on the Internet websites operating under such Group II Subject Domain Names. 24 After forty-eight (48) hours have elapsed after the emailing of this Order to the Registrars of record 25 and the registrants, Plaintiff shall provide a copy of this Order to the Registries for the Group II 26 Subject Domain Names for the purposes described in Paragraph 6 infra. 27 28 7 _________________________________________________________________________________ [PROPOSED] ORDER GRANTING PLAINTIFF’S SECOND EX PARTE APPLICATION FOR ENTRY OF TEMPORARY RESTRAINING ORDER Case 2:11-cv-00738-PMP -RJJ Document 63-1 (Ex Parte) 1 (6) Filed 12/22/11 Page 8 of 12 The Registrars and the top-level domain (TLD) Registries for the Group II Subject 2 Domain Names, within ten (10) business days of receipt of this Second Temporary Restraining 3 Order, shall, change or assist in changing, the Registrar of record for the Group II Subject Domain 4 Names, excepting any such domain names which such Registries have been notified in writing by 5 the Plaintiff have been or will be dismissed from this action, to a holding account the United States 6 based Registrar, GoDaddy.com, Inc. As a matter of law, this Second Temporary Restraining Order 7 shall no longer apply to any Defendant or associated domain name dismissed from this action. Upon 8 the change of the Registrar of record for the Group II Subject Domain Names to GoDaddy.com, Inc., 9 GoDaddy.com, Inc. will maintain access to the Group II Subject Domain Names in trust for the 10 Court during the pendency of this action. Additionally, GoDaddy.com, Inc. shall immediately update 11 the Domain Name System (“DNS”) data it maintains for the Group II Subject Domain Names, which 12 link the domain names to the IP addresses where their associated websites are hosted, to 13 NS1.MEDIATEMPLE.NET and NS2.MEDIATEMPLE.NET, which will cause the domain names to 14 resolve to the website where a copy of the Complaint, Summonses, First Amended Complaint, First 15 and Second Temporary Restraining Orders, and all other documents on file in this action are 16 displayed. Alternatively, GoDaddy.com, Inc. may institute a domain name forwarding which will 17 automatically redirect any visitor to the Group II Subject Domain Names to the following Uniform 18 Resource Locator (“URL”) http://servingnotice.com/ofn/index.html whereon copies of the 19 Complaint, Summonses, First Amended Complaint, First and Second Temporary Restraining Orders, 20 and all other documents on file in this action are displayed. After GoDaddy.com, Inc. has effected 21 this change the Group II Subject Domain Names shall be placed on Lock status, preventing the 22 modification or deletion of the domains by the Registrar or the Defendants; 23 (7) Plaintiff may enter the Group II Subject Domain Names into Google’s Webmaster 24 Tools and cancel any redirection of the domains that have been entered there by Defendants 183-222 25 which redirect traffic to the counterfeit operations to a new domain name and thereby evade the 26 provisions of this Second Temporary Restraining Order; 27 28 8 _________________________________________________________________________________ [PROPOSED] ORDER GRANTING PLAINTIFF’S SECOND EX PARTE APPLICATION FOR ENTRY OF TEMPORARY RESTRAINING ORDER Case 2:11-cv-00738-PMP -RJJ Document 63-1 (Ex Parte) 1 (8) Filed 12/22/11 Page 9 of 12 Defendants 183-222 shall preserve copies of all their computer files relating to the 2 use of any of the Group II Subject Domain Names and shall take all steps necessary to retrieve 3 computer files relating to the use of the Group II Subject Domain Names and that may have been 4 deleted before the entry of this Second Temporary Restraining Order; 5 (9) This Second Temporary Restraining Order shall remain in effect until the date for the 6 hearing on the Second Motion for Preliminary Injunction set forth below, or until such further dates 7 as set by the Court or stipulated to by the parties; 8 (10) This Second Temporary Restraining Order shall apply to the Group II Subject 9 Domain Names and any other domain names properly brought to the Court’s attention and verified 10 by sworn affidavit which verifies such new domain names are being used by Defendants 183-222 for 11 the purpose of counterfeiting the Louis Vuitton Marks at issue in this action and/or unfairly 12 competing with Louis Vuitton in connection with search engine results pages; BOND TO BE MAINTAINED 13 14 (11) Pursuant to 15 U.S.C. § 1116(d)(5)(D), Plaintiff shall maintain its previously posted 15 bond in the amount of Twenty Thousand Dollars and Zero Cents ($20,000.00), as payment of 16 damages to which Defendants 183-222 may be entitled for a wrongful injunction or restraint. SECOND PRELIMINARY INJUNCTION 17 18 (12) A hearing is set before this Court in the United States Courthouse located 333 S. Las 19 Vegas Blvd, Las Vegas, Nevada 89101, Courtroom 7C, on Wednesday, January 4, 2012 at 9:30am __________________, ____, ______, 20 or at such other time that this Court deems appropriate, on Plaintiff’s Second Motion for a 21 Preliminary Injunction restraining Defendants 183-222, their officers, directors, employees, agents, 22 subsidiaries, distributors, and all persons in active concert or participation with Defendants 183-222 23 from engaging in the activities that are subject of the above Second Temporary Restraining Order; 24 (13) Plaintiff shall serve copies of the First Amended Complaint, Second Application for 25 TRO and this Second Temporary Restraining Order and all other pleadings and documents on file in 26 this action on Defendants 183-222 by email as described above and by posting copies of the Second 27 Application for TRO and this Second Temporary Restraining Order on the website located at 28 9 _________________________________________________________________________________ [PROPOSED] ORDER GRANTING PLAINTIFF’S SECOND EX PARTE APPLICATION FOR ENTRY OF TEMPORARY RESTRAINING ORDER Case 2:11-cv-00738-PMP -RJJ Document 63-1 (Ex Parte) Filed 12/22/11 Page 10 of 12 1 http://servingnotice.com/ofn/index.html within forty-eight (48) hours of control of the Group II 2 Subject Domain Names being changed to the Court via the GoDaddy.com, Inc. holding account, and 3 such notice so given shall be deemed good and sufficient service thereof. Plaintiff shall continue to 4 provide notice of these proceedings and copies of the documents on file in this matter to Defendants 5 183-222 by regularly updating the website located at http://servingnotice.com/ofn/index.html or by 6 other means reasonably calculated to give notice which is permitted by the Court. Any response or 7 opposition to Plaintiff’s Second Motion for Preliminary Injunction must be filed and served on 8 January 4, 2012 Plaintiff’s counsel prior to the hearing set for __________, ____, and filed with the Court, along 9 January 3, 2012 with Proof of Service, on _________________, ____. Plaintiff shall file any Reply Memorandum on 10 or before ____________, ____. The above dates may be revised upon stipulation by all parties and 11 approval of this Court. Defendants 183-222 are hereby on notice that failure to appear at the hearing 12 may result in the imposition of a preliminary injunction against them pursuant to 15 U.S.C. § 13 1116(d) and Fed. R. Civ. P. 65. 14 15 16 17 IT IS SO ORDERED. December 22, 2011 DATED:_______________ ________________________________ PHILIP M. PRO United States District Judge 18 19 20 21 22 23 24 25 26 27 28 10 _________________________________________________________________________________ [PROPOSED] ORDER GRANTING PLAINTIFF’S SECOND EX PARTE APPLICATION FOR ENTRY OF TEMPORARY RESTRAINING ORDER Case 2:11-cv-00738-PMP -RJJ Document 63-1 (Ex Parte) Filed 12/22/11 Page 11 of 12 1 2 3 SCHEDULE A 4 THE PARTNERSHIPS and UNINCORPORATED ASSOCIATIONS 5 6 Defendant No. Domain Name 7 Defendant 183 Defendant 184 Defendant 185 Defendant 186 Defendant 187 Defendant 188 Defendant 189 Defendant 190 Defendant 191 Defendant 192 Defendant 193 Defendant 194 Defendant 195 Defendant 196 Defendant 197 Defendant 198 Defendant 199 Defendant 200 Defendant 201 Defendant 202 Defendant 203 Defendant 204 Defendant 205 Defendant 206 Defendant 207 Defendant 208 Defendant 209 Defendant 210 Defendant 211 Defendant 212 bmwbags.com gubags.com chaneltote.net cheaphandbagselling.com cheaplouisvuittonsell.com clonesbar.com fakelouisvuitton2un.com handbag-brandreplica.com handbags-louis-vuitton.com idolbagsshop.com itisbags.com louisvuittonfakes.co louisvuittonhandbags4u.com knockoffhandbags.us louisvuitton-onsale.net louisvuittonoutletonline-2012.org louisvuittonoutlet2000.com louisvuittonreplica2w.com replicashopbella.com lovinggucci.com luxuriesbrands.com lv-bagsmall.com lvreplicaluggages.com replicabagonline.com replicalouisvuitton.org replicalouisvuitton2uk.com replicalouisvuittonoutlets.com replicalouisvuitton-sale.com replicalouisvuittonssale.com replicalouisvuittonusa.com 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 E-Commerce Website Blog Style Website x x x x x x x x x x x x x x x x x x x x x x x x x x x x x x 11 _________________________________________________________________________________ [PROPOSED] ORDER GRANTING PLAINTIFF’S SECOND EX PARTE APPLICATION FOR ENTRY OF TEMPORARY RESTRAINING ORDER Case 2:11-cv-00738-PMP -RJJ Document 63-1 (Ex Parte) 1 2 3 4 5 6 7 Defendant 213 Defendant 214 Defendant 215 Defendant 216 Defendant 217 Defendant 218 Defendant 219 Defendant 220 Defendant 221 Defendant 222 replicalouisvuittonmall.com shoes-belt-china.com tobenone.com topdesignerhandbagsdiscount.com louisvuittonreplicanyc.com topreplicadesignerbags.com top-replica-handbagss.com top-replicahandbags.co trna2010.com webgrabbag.com Filed 12/22/11 Page 12 of 12 x x x x x x x x x x 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 12 _________________________________________________________________________________ [PROPOSED] ORDER GRANTING PLAINTIFF’S SECOND EX PARTE APPLICATION FOR ENTRY OF TEMPORARY RESTRAINING ORDER
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