UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 19-62270-CIV-SMITH

GUCCI AMERICA, INC.,

Plaintiff,

vs.

AMPTDRESS, et al.,

Defendants.

/

ORDER GRANTING MOTION FOR ENTRY OF PRELIMINARY INJUNCTION

THIS CAUSE came before the Court upon Plaintiff’s Motion for Entry of Preliminary Injunction (the “Motion”) [DE 6]. The Court has carefully reviewed the Motion and the record and is otherwise fully advised in the premises. By the instant Motion, Plaintiff, Gucci America, Inc. (“Plaintiff”) moves for entry of a preliminary injunction against Defendants, the Individuals, Partnerships, and Unincorporated Associations Identified on Schedule “A” hereto (collectively “Defendants”) pursuant to

and Fed. R. Civ. P. 65, and The All Writs Act,

(a). The Court convened a hearing on October 7, 2019, at which only counsel for Plaintiff was present and available to present evidence supporting the Motion. Because Plaintiff has satisfied the requirements for the issuance of a preliminary injunction, the Court will now grant Plaintiff’s Motion for Preliminary Injunction. L Factual Background! Plaintiff is the owner of the following trademarks, which are valid and registered on the Principal Register of the United States Patent and Trademark Office (the “Gucci Marks’):

Registration Registration

IC 018 — pocketbooks, wallets, travel and duffel bags, attache cases, toilet cases sold empty and shoe bags. GUCCI 0,876,292 □□ 9, {IC 018 — umbrellas. IC 021 — vacuum bottles, compacts sold empty and vanity cases sold empty. IC 025 — shoes and boots.

. 1,097,555 July 25, 1978 IC 025 — neckties, scarves, footwear, ory shirts, sweaters, and coats.

November 21 IC 025 — neckties, scarves, belts, Gd 1,106,722 ’ |footwear, shirts, sweaters, coats, suits, . 1978 . . and bathing suits. IC 018 — wallets, purses, handbags, shoulder bags, clutch bags, tote bags, November 28, |card cases, partly and wholly of leather, 1,107,311 . 1978 key cases, passport cases, cosmetic cases, attache cases, valises, suitcases, duffles. i | | IC 018 — wallets, purses, handbags, | | 1.122.780 July 24, 1979 shoulder bags, clutch bags, tote bags, ce card cases, attache cases, valises, (Green Red Green suitcases, duffles, and key cases. Stripe Design) IC 025 — clothing-namely, neckties, 1,158,170 June 23, 1981 |scarves, belts, footwear, shirts, coats, hats, dresses, and bathing suits.

' The factual background is taken from Plaintiff’s Amended Complaint, Motion, and supporting Declarations submitted by Plaintiff.

Registration Registration

IC 025 — neckties, scarves, belts, September 8, |footwear, shirts, sweaters, coats, suits, GUCCI 1,168,477 1981 dressing gowns, hats, socks, dresses, and bathing suits.

ail ‘| S| 1,483,526 April 5, 1988 |IC 025 — footwear. (Green Red Green Stripe Design) Sig = FI 1.511.774 November 8, |IC 018 — purses, handbags, shoulder Ellie 1988 bags, clutch bags, and tote bags. (Blue Red Blue Stripe Design) January 10, 3,039,629 IC 025 — footwear and belts. 2006

IC 018 — wallets, purses, handbags, tote 3.039.630 January 10, _|bags, business card cases, credit card 2006 cases and key cases, partly or wholly of leather. OO, 6 “OO 3,072,547 | March 28, 2006 ete neckties, Scarves. belts, 9 Bmoves. IC 018 — wallets, purses, handbags, shoulder bags, clutch bags, tote bags, oO. 6 business card cases, credit card cases, 9... 3,072,549 March 28, 2006 |partly and wholly of leather, key cases, Gd Go cosmetic cases sold empty, briefcases, attaché cases, valises, suitcases and duffles.

Registration Registration

IC 009 — eyeglass frames and sunglasses. IC 014 — jewelry and watches. IC 016 — agendas and notebooks.

February 5 IC 018 — wallets, purses, handbags, 3,378,755 shoulder bags, clutch bags, tote bags, 2008 . business card cases, credit card cases, partly and wholly of leather, key cases, cosmetic cases sold empty, briefcases, attaché cases, valises, suitcases and duffles. IC 025 — scarves, belts, footwear, shirts, sweaters, coats, suits. IC 014 — jewelry. IC 018 — wallets, purses, handbags, shoulder bags, clutch bags, tote bags, business card cases, credit card cases 4,220,947 October 9, 2012 partly and wholly of leather, key cases, cosmetic cases sold empty, briefcases, attaché cases, valises, suitcases and duffel bags. IC 025 — neckties, scarves, belts, footwear and gloves. IC 014 — jewelry. IC 018 — wallets, purses, handbags, shoulder bags, clutch bags, tote bags, business card cases, credit card cases bY Fb by od be be 4,229,081 October 23, {partly and wholly of leather, key cases, a Gs 2012 cosmetic cases sold empty, briefcases, Gd Gd vd bs attache cases, valises, suitcases and duffel bags. IC 025 — neckties, scarves, belts, footwear and gloves.

Registration Registration

IC 025 — shorts, pants, jeans, leggings, t- shirts, polo shirts, shirts, sweaters, 4,379,039 August 6, 2013 sweatshirts, dresses, skirts, swimwear, one piece garments for infants and (Green Red Green toddlers, cloth bibs, scarves, ties, hats, Stripe Design) gloves, suspenders, belts. IC 009 — bicycle helmets; eyewear. IC 012 — bicycles. OG IC 018 — backpacks, cosmetic cases sold Guceé 4,559,556 June 24, 2014 empty partly and wholly of leather. IC 025 — scarves, belts, footwear, t- shirts, shirts, pants, blazers, sweatshirts, sweat pants, hats, and dresses. IC 009 — protective covers and cases for G9. oO mobile electronic devices and 69. 4,563,071 July 8, 2014 |computers. Oo @& IC 014 — watches. IC 009 — protective covers and cases for mobile electronic communication devices and computers; computer GUCCI 4,563,098 July 8, 2014 [application software for all mobile devices, namely, software for providing information in the field of fashion, the arts and lifestyle. IC 018 — handbags, shoulder bags, clutch bags, tote bags, briefcases, business card cases, credit card cases, backpacks, key cases, passport cases, GUCCI 4,563,132 July 8, 2014 cosmetic cases sold empty, valises, suitcases, luggage, all the foregoing being made in whole or in part of leather; pet accessories, namely, carriers, collars and leashes; pet collar accessories, namely, charms.

Registration Registration

IC 014 — jewelry and key rings of precious metal. IC 009 — eyeglasses and sunglasses and cases therefor; protective covers and cases for mobile electronic communication devices and computers; 4,567,112 July 15,2014 |cell phone straps; computer carrying cases. (Green Red Green Stripe Design) IC 018 — cosmetic cases sold empty, suitcases, luggage, duffle bags, diaper bags partly and wholly of leather; pet accessories, namely, carriers, collars and leashes. IC 009 — protective covers and cases for mobile electronic communications devices and computers; computer cases made of leather.

bd BI BI pd IC 014 — watches. dod bd be oo td ogg 4,583,258 August 12, 2014 |IC 018 — backpacks, trollies, baby bags, od nd eg computer cases made of leather, garment bags, pet accessories, namely, carriers, collars and leashes; pet collar accessories, namely, charms. IC 025 — clothing, namely, shirts and jackets. November 1, IC 018 — handbags and wallets. 5,073,022 016 IC 025 — belts and footwear. IC 018 — handbags, tote bags, shoulder . bags, pouches of leather, travelling cases BUND FOR LOVE 5,183,371 April 11, 2017 of leather and leather credit card cases and holders.

IC 014 — watches.

sa7g.aso | Septembers. nov ndwalles IC 025 — clothing, namely, scarves, neckties and footwear. (See Declaration of Jessica Haugen in Support of Plaintiff's Motion for Preliminary Injunction (“Haugen Decl.”) {J 4-5; see also United States Trademark Registrations of the Gucci Marks at issue attached as Composite Exhibit 1 to the Amended Complaint.) The Gucci Marks are used in connection with the manufacture and distribution of high quality goods in the categories identified above. (See

.) Defendants, by operating e-commerce stores via Internet marketplace platforms under their seller identification names or commercial Internet websites under their domain names identified on Schedule “A” hereto (the “Seller IDs and Subject Domain Names”), have advertised, promoted, offered for sale, or sold goods bearing and/or using what Plaintiff has determined to be counterfeits, infringements, reproductions, and/or colorable imitations of the Gucci Marks. (See Haugen Decl. {| 10-14; Declaration of T. Raquel Wiborg-Rodriguez in Support of Plaintiffs Motion for Preliminary Injunction (‘Wiborg-Rodriguez Decl.”) § 2; Declaration of Kathleen Burns in Support of Plaintiff's Motion for Preliminary Injunction (“Burns Decl.’”) § 4; Declaration of Eric Rosaler in Support of Plaintiff's Motion for Preliminary Injunction (“Rosaler Decl.”) §] 4.) Although each Defendant may not copy and infringe each Gucci Mark for each category of goods protected, Plaintiff has submitted sufficient evidence showing that each Defendant has infringed, at least, one or more of the Gucci Marks. (See Haugen Decl. {[f[ 10-14.) Defendants

are not now, nor have they ever been, authorized or licensed to use, reproduce, or make counterfeits, reproductions, or colorable imitations of the Gucci Marks. (See id. at ¶¶ 10, 13-14.) Plaintiff’s counsel retained Invisible Inc and AED Investigations, Inc. (“AED”), both licensed private investigative firms, to investigate the promotion and sale of counterfeit and

infringing versions of Plaintiff’s branded products by Defendants and to obtain the available payment account data for receipt of funds paid to Defendants for the sale of counterfeit versions of Plaintiff’s branded merchandise through the Seller IDs and Subject Domain Names. (Haugen Decl. ¶ 11; Burns Decl. ¶ 3; Rosaler Decl. ¶ 3; Wiborg-Rodriguez Decl. ¶ 2.) Invisible Inc and AED collectively accessed each2 of the e-commerce stores and commercial Internet websites operating under Defendants’ Seller IDs and Subject Domain Names, placed an order for the purchase of a product bearing counterfeits of, at least, one of the Gucci Marks at issue in this action, and requested each product to be shipped to one of their addresses in the Southern District of Florida. (See Burns Decl. ¶ 4; Rosaler Decl. ¶ 4.) Following submission of the orders, Invisible Inc and AED finalized payment for the Gucci branded items purchased from Defendants to Defendants’ respective payment accounts and/or payee3 as identified on Schedule

2 Invisible Inc made purchases from each Defendant as identified on Schedule “A” to the Declaration of Kathleen Burns in Support of Plaintiff’s Application for Preliminary Injunction. (See Burns Decl. ¶ 4, n.2.) However, during the preparation and filing of the Application for Preliminary Injunction, some Defendants changed their seller identification name. (Id.)

3 Defendant Numbers 1-50 operate via the non-party Internet marketplace platform, Amazon.com. (See Burns Decl. ¶ 4 n.3; Rosaler Decl. ¶ 4 n.1; Wiborg-Rodriguez Decl. ¶ 5.) Amazon.com is an e-commerce marketplace that allows Defendants to conduct their commercial transactions privately via Amazon’s payment processing and retention service, Amazon Payments, Inc. (See id.)

Defendant Numbers 51-107 and 117 use money transfer and retention services with PayPal, Inc. (See Burns Decl. ¶ 4; Wiborg-Rodriguez Decl. ¶ 6.)

Upon completion of Invisible Inc’s purchase from Defendant Number 63 and AED’s purchases from Defendant Numbers 100-107, no PayPal e-mail account was provided on the transaction “A” hereto.4 (Id.) At the conclusion of the process, the detailed web page captures and images of the Gucci branded items Invisible Inc and AED purchased via Defendants’ Seller IDs and Subject Domain Names, together with photographs of the some of the items Invisible Inc received, were sent to Plaintiff’s representative for review. (See Haugen Decl. ¶ 12; Burns Decl.

¶ 4; Rosaler Decl. ¶ 4; Wiborg-Rodriguez Decl. ¶ 2.) Plaintiff’s representative conducted a review and visually inspected the Gucci branded items Invisible Inc and AED purchased via the Seller IDs and Subject Domain Names and determined the products were non-genuine, unauthorized versions of Plaintiff’s products. (See Haugen Decl. ¶¶ 13-14.) On September 12, 2019, Plaintiff filed its Complaint [DE 1] and thereafter its Amended Complaint on October 4, 2019 [DE 18] against Defendants for federal trademark counterfeiting and infringement, false designation of origin, common law unfair competition, and common law trademark infringement. On September 12, 2019, Plaintiff filed its Ex Parte Application for Entry of Temporary Restraining Order, Preliminary Injunction, and Order Restraining Transfer of Assets [DE 6]. On September 17, 2019, this Court entered an Order Granting Ex Parte

Application for Entry of Temporary Restraining Order (the “TRO”) [DE 8] and temporarily restrained Defendants from infringing the Gucci Marks at issue and restrained funds in the

page. (See Burns Decl. ¶ 4 n.4; Rosaler Decl. ¶ 4 n.2.) However, PayPal is able to identify a PayPal account using the Transaction ID. (See id.) Accordingly, the Transaction IDs for Invisible Inc’s and AED’s purchases from Defendant Numbers 63 and 100-107 are identified on Schedule “A” (See id.)

The payee for the orders placed from Defendant Numbers 108-116’s Wish.com Seller IDs identifies “PayPal *Wish.” (See Burns Decl. ¶ 4 n.5; Wiborg-Rodriguez Decl. ¶ 7.) “WISH (ContextLogic Inc.)” is the named PayPal recipient for individual transactions conducted with sellers through Wish.com. (Id.)

Defendant Number 118 use money transfer services with TransferWise Inc. (See Burns Decl. ¶ 4; Wiborg-Rodriguez Decl. ¶ 8.)

4 Additional contact email addresses for Defendant Numbers 117 and 118 are is also identified on Schedule “A” hereto. (See Burns Decl. ¶ 4 n.6; Wiborg-Rodriguez Decl. ¶ 3.) payment accounts associated with the Defendants. Pursuant to the Court’s September 17, 2019 TRO, Plaintiff properly served Defendants with a copy of the Complaint, the Court’s September 17, 2019 TRO, and all filings in this matter [see DE Nos. 20 and 21]. On October 7, 2019, the Court conducted a hearing on Plaintiff’s Motion, at which only counsel for Plaintiff was in

attendance. II. Legal Standard In order to obtain a preliminary injunction, a party must demonstrate “(1) [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,

, 1225–26 (11th Cir. 2005); see also Levi Strauss & Co. v. Sunrise Int’l. Trading Inc.,

, 985 (11th Cir. 1995) (applying the test to a preliminary injunction in a Lanham Act case). III. Conclusions of Law

The declarations Plaintiff submitted in support of its Motion support the following conclusions of law: A. Plaintiff has a strong probability of proving at trial that consumers are likely to be confused by Defendants’ advertisement, promotion, sale, offer for sale, or distribution of goods bearing counterfeits, reproductions, or colorable imitations of the Gucci Marks, and that the products Defendants are selling and promoting for sale are copies of Plaintiff’s products that bear copies of the Gucci Marks. B. Because of the infringement of the Gucci Marks, Plaintiff is likely to suffer immediate and irreparable injury if a preliminary injunction is not granted. The following specific facts, as set forth in Plaintiff’s Amended Complaint, Motion, and accompanying declarations, demonstrate that immediate and irreparable loss, damage, and injury will result to Plaintiff and to consumers because it is more likely true than not that: 1. Defendants own or control e-commerce stores via Internet marketplace

platforms or commercial Internet websites operating under their seller identification names and domain names which advertise, promote, offer for sale, and sell products bearing counterfeit and infringing trademarks in violation of Plaintiff’s rights; and 2. There is good cause to believe that more counterfeit and infringing products bearing Plaintiff’s trademarks will appear in the marketplace; that consumers are likely to be misled, confused, or disappointed by the quality of these products; and that Plaintiff may suffer loss of sales for its genuine products. C. The balance of potential harm to Defendants in restraining their trade in counterfeit and infringing branded goods if a preliminary injunction is issued is far outweighed by the potential harm to Plaintiff, its reputation, and its goodwill as a manufacturer and

distributor of quality products if such relief is not issued. D. The public interest favors issuance of the preliminary injunction to protect Plaintiff’s trademark interests and protect the public from being defrauded by the palming off of counterfeit goods as Plaintiff’s genuine goods. E. Under

(a), Plaintiff may be entitled to recover, as an equitable remedy, the illegal profits gained through Defendants’ distribution and sales of goods bearing counterfeits and infringements of the Gucci Marks. See Reebok Int’l, Ltd. v. Marnatech Enters., Inc.,

, 559 (9th Cir. 1992) (quoting Fuller Brush Prods. Co. v. Fuller Brush Co.,

(7th Cir. 1962) (“An accounting of profits under § 1117(a) is not synonymous with an award of monetary damages: ‘[a]n accounting for profits . . . is an equitable remedy subject to the principles of equity.’”)). F. Requesting equitable relief “invokes the district court’s inherent equitable powers to order preliminary relief, including an asset freeze, in order to assure the availability of

permanent relief.” Levi Strauss & Co., 51 F.3d at 987 (citing Federal Trade Commission v. United States Oil & Gas Corp.,

(11th Cir. 1984)). G. In light of the inherently deceptive nature of the counterfeiting business, and the likelihood that Defendants have violated federal trademark laws, Plaintiff has good reason to believe Defendants will hide or transfer their ill-gotten assets beyond the jurisdiction of this Court unless those assets are restrained. Upon review of Plaintiff’s Amended Complaint, Motion, and supporting evidentiary submissions, it is hereby ORDERED that Plaintiff’s Motion for Preliminary Injunction [DE 6] is GRANTED, according to the terms set forth below:

(1) Each Defendant, its officers, directors, employees, agents, subsidiaries, distributors, and all persons in active concert or participation with any Defendant having notice of this Order are hereby restrained and enjoined until further Order of this Court: a. From manufacturing, importing, advertising, promoting, offering to sell, selling, distributing, or transferring any products bearing the Gucci Marks, or any confusingly similar trademarks, other than those actually manufactured or distributed by Plaintiff; and b. From secreting, concealing, destroying, selling off, transferring, or otherwise disposing of: (i) any products, not manufactured or distributed by Plaintiff, bearing and/or using the Gucci Marks, or any confusingly similar trademarks; (ii) any evidence relating to the manufacture, importation, sale, offer for sale, distribution, or transfer of any products bearing and/or using the Gucci Marks, or any confusingly similar trademarks; or (iii) any assets or other financial accounts subject to this Order, including inventory assets, in the actual or constructive possession of, or owned, controlled, or held by, or subject to access by, any Defendant, including, but not limited to, any assets held by or on behalf of any Defendant. (2) Each Defendant, its officers, directors, employees, agents, subsidiaries, distributors, and all persons in active concert or participation with any Defendant having notice of this Order shall immediately discontinue, until further Order of this Court, the use of the Gucci Marks, or any confusingly similar trademarks, on or in connection with all Internet based e-commerce stores and Internet websites owned and operated, or controlled by them, including the Internet based e-commerce stores and Internet websites operating under the Seller IDs and Subject Domain Names; (3) Each Defendant, its officers, directors, employees, agents, subsidiaries, distributors, and all persons in active concert or participation with any Defendant having notice of this Order shall immediately discontinue, until further Order of this Court, the use of the Gucci Marks, or any confusingly similar trademarks, within metatags or other markers within website source code, from use on any webpage (including as the title of any web page), from any advertising links to other websites, from search engines’ databases or cache memory, and any

other form of use of such terms that are visible to a computer user or serves to direct computer searches to Internet based e-commerce stores and Internet websites registered, owned, or operated by any Defendant, including the Internet based e-commerce stores and Internet websites operating under the Seller IDs and Subject Domain Names; (4) Each Defendant shall not transfer ownership of the Internet based e-commerce stores or Internet websites operating under their Seller IDs and Subject Domain Names during the pendency of this action, or until further order of the Court; (5) Each Defendant shall continue to preserve copies of all computer files relating to the use of any of the Internet based e-commerce stores or Internet websites under their Seller IDs and Subject Domain Names and shall take all steps necessary to retrieve computer files relating to the use of the Internet based e-commerce stores or Internet websites operating under the Seller IDs and Subject Domain Names that may have been deleted before the entry of this Order; (6) Upon receipt of notice of this Order, Defendants and all financial institutions,

payment processors, banks, escrow services, money transmitters, or marketplace platforms, including but not limited to, Amazon Payments, Inc. (“Amazon”), PayPal, Inc. (“PayPal”), ContextLogic, Inc., which operates the Wish.com website (“ContextLogic”), TransferWise Inc (“TransferWise”), and their related companies and affiliates shall, to the extent not already done, (i) immediately identify all financial accounts and/or sub-accounts, associated with the Internet based e-commerce stores and Internet websites operating under the Seller IDs and Subject Domain Names, and/or the e-mail addresses identified on Schedule “A” hereto, as well as any other accounts of the same customer(s); (ii) identify all other accounts which transfer funds into the same financial institution account(s) or any of the other financial accounts subject to this Order; (iii) restrain the transfer of all funds, as opposed to ongoing account activity, held or

received for their benefit or to be transferred into their respective financial accounts, and any other financial accounts tied thereto; and (iv) immediately divert those restrained funds to a holding account for the trust of the Court; (7) Upon receipt of notice of this Order, Defendants and any money transmitters, including but not limited to, TransferWise, and their related companies and affiliates, shall further, to the extent not already done, put a hold on and prohibit the withdraw and transfer of funds in any money transfer accounts used by Defendants for the receipt of funds in connection with the sale of goods bearing and/or using counterfeits and/or infringements of the Gucci Marks; (8) Upon receipt of notice of this Order, Defendants and all financial institutions, payment processors, bank, escrow services, money transmitters, or marketplace platforms receiving notice of this Order, including but not limited to, Amazon, PayPal, ContextLogic, TransferWise, and their related companies and affiliates, shall further, to the extent not already

done, provide the Plaintiff’s counsel with all data that details (i) an accounting of the total funds restrained and identifies the financial account(s) and sub-account(s) which the restrained funds are related to, and (ii) the account transactions related to all funds transmitted into the financial account(s) and sub-account(s) which have been restrained. No funds restrained by this Order shall be transferred or surrendered by any financial institution, payment processor, bank, escrow service, money transmitter, or marketplace website, including but not limited to, Amazon, PayPal, ContextLogic, TransferWise, and their related companies and affiliates for any purpose (other than pursuant to a chargeback made pursuant to their security interest in the funds) without the express authorization of this Court; (9) Any Defendant or financial institution account holder subject to this Order may

petition the Court to modify the asset restraint set out in this Order; (10) This Order shall apply to the Seller IDs and Subject Domain Names, associated e- commerce stores and websites, and any other seller identification names, e-commerce stores, domain names and websites, or financial accounts which are being used by Defendants for the purpose of counterfeiting the Gucci Marks at issue in this action and/or unfairly competing with Plaintiff; (11) Pursuant to

(d)(5)(D) and Federal Rule of Civil Procedure 65(c), Plaintiff shall maintain its previously posted bond in the amount of Ten Thousand Dollars and Zero Cents ($10,000.00), as payment of damages to which Defendants may be entitled for a wrongful injunction 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 an application be made in the interest of justice; (12) Additionally, for the purpose of providing additional notice of this proceeding, and all other pleadings, orders, and documents filed herein, the owners, operators and/or administrators of the Internet marketplace websites and/or financial institutions, payment processors, banks, escrow services, money transmitters, and marketplace platforms, including but not limited to Amazon.com, Inc., PayPal, eBay.com, ContextLogic, TransferWise, and their related companies and affiliates shall, to the extent not already done, at Plaintiff's request, provide Plaintiff's counsel with any e-mail address known to be associated with Defendants’ respective Seller IDs; (13) This Order shall remain in effect during the pendency of this action, or until such further date as set by the Court or stipulated to by the parties. DONE AND ORDERED in Fort Lauderdale, Florida, this 7 day of October, 2019.

RODNEY SMITH United States District Judge

Copies provided to: Counsel of Record

16

SCHEDULE “A” DEFENDANTS BY NUMBER, SELLER ID, SUBJECT DOMAIN NAME, FINANCIAL ACCOUNT INFORMATION, STORE URL, AND E-MAIL ADDRESS

Def. Store URL / Defendant / Seller ID Financial Account Information No. Customer Service E-mail 1 AMPTdress AM0Y5MQC3BRGD 2 Big Different Store A3MZL9PO82W5MF BOLBanana 3 a/k/a DZH A3SB0V061CEEA8 4 Boutique. A1HJD81J8Q4I26 5 BruceMarry AW5N7YOKBIWWL 6 China Culture and Art A3BYMVW9HW3B22 7 Cyclyyoo Store A1HWLKZ9KXQAZQ 8 Dale Nixon A34AAJYFQ3FVGZ 9 DeRoseStore AGND7OBE183ZN 10 DF24ddhg1 A2VS2UAA8S53XR 11 Dorapocket A3Q8H5FJOY270Z 12 DUOAI A7QIYBQNYANH9 13 EleeFun A18QIYPCFOQOLE 14 EXPEDER A12VR8BD9YFS77 15 Fendona A24ZJXKYQN7IXJ 16 Harry Brown A219K90V095X5W HOtsell 17 a/k/a afsfddsgfgh A39J22BZB45SQ9 18 KDUST AJ6JGJBZQTYQV langfangyingfabaowencailiaoyo 19 uxiangongsi A1U9FSOX0S08K7 20 Leadlion A2QYI3K782T5VW 21 MAGOR A9M9OG58PGJEN 22 MAKGOT A3FG8CJ1DDD8B1 23 MengXiangShangMao A1UKXMTPFGGPQF 24 Mingyuming A1AE8PBXQUQTZ0 25 MoYoTo A31JPCJVXCS1XQ 26 naizhelun A372K72U6WFLF9 NicebeltL 27 a/k/a HustonMc A271U4XS1OQYYX 28 qSkAif76xn AG3IBCJZXQZB1 29 Queenchanelv A1UKHPF6Q51DME 30 Rainbow after Storm A1N2J3YS40EKBF 31 ranmei89 A1N7K5TZKQ24CI 32 run2019belt A12BNCGNYZTXG3 33 Sasa eShop A3Q14VV9KDFIDU 34 ShannonSIsom AZCIRHK56XFV6 35 Sun Hui Bo AXU327NW4289D Def. Store URL / Defendant / Seller ID Financial Account Information No. Customer Service E-mail 36 Suzanne Aldridge A2K2WWFMEDC60V 37 T TOP A34DTF29NVF61K 38 Tian Tao2 A3I0TMBOPRARUL 39 TYMYsmyx A1IKWQ2N0RSMTX Usbandbug 40 a/k/a Mlover AJ6K1BJZG0D47 41 YoGEE-Official A29WJYZRP96VCN 42 youlongky A2D874I0QQQL2X 43 yunguantui7fr A1DDJMOIC44B56 44 yuyue20 A3IUHLBAB6ZAF4 45 ZERSGF A1HCDIT91XJMTS 46 CCLOIUY& A1BT2MEY7WRX8V 47 daituanjie321 A1A117JMUJPO27 48 kjelaeg A18L3WOLHA1SSQ 49 Liangdfgh A2NU1TJR926K3Q 50 TBETECH A1Z27LCTU8YTR0 51 4827069 [email protected] 52 ananmaru_0 [email protected] 53 andrea_case [email protected] 54 anxia_8857 [email protected] 55 asas8598 [email protected] 56 asno_45 [email protected] 57 bagupambud_0 [email protected] 58 bani-007 [email protected] 59 bizworld-99 [email protected] 60 blackrose838 [email protected] 61 breto3998 [email protected] 62 cakep_65 [email protected] Transaction 63 chicbali ID: 6CC0538242012442D 64 chuangtianjingmi [email protected] 65 dananindr0 [email protected] 66 denbast [email protected] 67 evbis-47 [email protected] 68 fangche_38 [email protected] 69 goodagain20179 [email protected] 69 sincerity7440 [email protected] 70 gzllshumei [email protected] 71 haryope [email protected] 72 homesepuluh0 [email protected] huamanlou25_0 73 a/k/a weba5869 [email protected] 74 jiucheng51009047 [email protected] Def. Store URL / Defendant / Seller ID Financial Account Information No. Customer Service E-mail 75 leste_mell [email protected] 76 maddpe-39 [email protected] 77 maulanric0 [email protected] 78 meldpratam-0 [email protected] 79 mendis-groups [email protected] 80 moshan_29 [email protected] 81 qipej2548 [email protected] qpbh9129 82 a/k/a high-quality-bag [email protected] 83 qunla-84 [email protected] 84 shouyashi475455-3 [email protected] 85 soufiane09 [email protected] 86 stars_jersey [email protected] store1081 87 a/k/a luxury1081 [email protected] 88 ts49cd [email protected] 89 w13716706723 [email protected] 90 wpeeq7772 [email protected] 91 xinge47763 [email protected] 92 xjub9500 [email protected] 93 xuweihai6688 [email protected] 94 yaguangdianzi_86 [email protected] 95 yehaha-store [email protected] 96 zeroyiyang [email protected] 97 zhigaowusi447 [email protected] 98 zhu81-93 [email protected] 99 zuozuowang [email protected] Transaction 100 aagun-22 ID: 8V963295H37651740 Transaction 101 albmelod_0 ID: 0TW708430B465503E Transaction 102 custom_g ID: 2PG970980H417240R Transaction 103 jokid24 ID: 3PP82053S51497037 Transaction 104 krisna_store ID: 74026054HF6375843 Transaction 105 lent.e.rab22 ID: 7U185761KP191830W Transaction 106 lutfhad-7 ID: 22706978T2383400T Transaction 107 ujansugand-0 ID: 5FT8745599701061E Def. Store URL / Defendant / Seller ID Financial Account Information No. Customer Service E-mail https://www.wish.com/merchant/ 108 aygxyyouth0106 PAYPAL *WISH 5aa1f41d2fbbdc2564750876 https://www.wish.com/merchant/ 109 BYHUA PAYPAL *WISH 5911aac14cb6762991bc5e83 https://www.wish.com/merchant/ 110 dhyyouth0119 PAYPAL *WISH 5a03fb9aeea5c573afed6043 https://www.wish.com/merchant/ 110 jinfeng zhang PAYPAL *WISH 5ac1aef5823a3e73cfbe768a https://www.wish.com/merchant/ 111 FANSER PAYPAL *WISH 596cad3acdf3291fa50f6069 https://www.wish.com/merchant/ 112 GSLS PAYPAL *WISH 5abd970b22fad71d2e32e4ea https://www.wish.com/merchant/ 113 jwkj PAYPAL *WISH 5971a386ec40ae735e897dbd https://www.wish.com/merchant/ 114 ninping6224 PAYPAL *WISH 58d12ee3acb37b6bbd5d3402 https://www.wish.com/merchant/ 115 wangwangh PAYPAL *WISH 5915d6414cb67610dade8dd4 https://www.wish.com/merchant/ 116 zhaoxiaojiededianpu PAYPAL *WISH 59292f01ff46145c81f5ebe6 117 bestluxurycases.com [email protected] [email protected] 117 topluxurycases.com [email protected] TransferWise E-mail: 118 hignice.com [email protected] [email protected]